Texas Army National Guard Armory Property Preliminary Assessment Study found High levels of Arsenic and Beryllium
By: Jose G. Landa, Copyright 2015, Eagle Pass Business Journal, Inc.
The proposed City of Eagle Pass real property for the construction of the new Public Safety Headquarters, the former Texas Army National Guard Armory located at 489 South Monroe Street, Eagle Pass, Texas, had two Preliminary Assessment studies done on it, one in 1993 and another in 1995 due to potential contamination of hazardous and toxic materials.
In October of 1995, a Preliminary Assessment (PA) study by Pacific Western Technologies, LTD of the Texas Army National Guard Armory property was conducted in a manner consistent with both the United States Department of Defense Installation Restoration Program (IRP) and the United States Environmental Protection Agency (EPA) potential hazardous waste site preliminary assessment guidance and under the authority and direction of the IRP and the Comprehensive Environmental Response and Liability Act (CERCLA) and the Superfund Amendments and Reauthorization Act of 1986.
The 1995 Preliminary Assessment study states that an earlier 1993 report entitled Texas Army National Guard Armory Final Environmental Comprehensive Assessment Report, dated April 1993, clearly indicated that the Eagle Pass, Texas Army National Guard Armory site had not been previously screened for pre-existing environmental impacts and concerns prior to its acquisition.
The 1993 study at that time stated that during a site visit conducted during the study found that some areas of unusually stressed vegetation and lack of biotic diversity on the armory property indicated possible soil contamination.
The 1993 study addressed potential operations around the vicinity at some point in time, including a Fluorspar material stockpile which was located approximately 300 feet south of the Armory site and an Fluorspar ore processing plant approximately 500 feet south of the site as well.
The 1995 report states that a SESA Fluorspar Ore Refining Plant was located in proximity of the Eagle Pass,Texas Army National Guard Armory site.
The Fluorspar Ore Refining Plant came into operation in the 1950’s and operated for close to 40 years into the 1990’s.
The Fluorspar Ore Refining Plant main function was to produce acid-grade fluorspar which is involved in the production of aluminum and other components. Another company called Reynolds Aluminum operated the fluorspar ore refining plant. The fluorspar product was manufactured for the U.S. Department of Defense.
“The raw ore (fluorspar) was obtained from Mexico. Over the years, this ore processing activity generated large quantities of tailings and wastewater which has been stored in piles and man-made ponds over an estimated 200 acre area adjacent to the Rio Grande and approximately 2,000 feet southwest of the armory property.”
Fluorspar is an industrial mineral that is composed of calcium fluoride (CaF2), which is made up of 51.1 percent calcium and 48.9 percent fluorine. Fluorspar takes its name from the Latin word “fluo”— which means “flow”— as it lowers the melting point of metal ore and and helps it flow more easily.
The presence of impurities like silica, ferric oxide, arsenic, phosphorus, lead, zinc and limestone-as well as the texture of the ore-determines the type of concentrate that can be produced.
There are three main types of commercial fluorspar concentrate: ceramic, which is 85 to 96 percent fluorspar; metallurgical—also known as metspar—which is over 80 percent fluorspar and is 10 to 75 mm in size; and acid grade, known as acid spar, which is fine grained and contains over 97 percent fluorspar.
Fluorine, a relatively soluble mineral contained in Fluorite, can lead to a severe bone disease called skeletal fluorosis, a skeletal bone disease caused by excessive accumulation of fluoride in the bones. In advanced cases, skeletal fluorosis causes pain and damage to bones and joints.
Fluorspar or Fluorite is also known to have high contents of arsenic, an element that often causes toxicity for multicellular life due to its presence in quantities far larger than needed.
Arsenic is a known substance harmful to human beings in high levels of contamination.
Arsenic contamination of groundwater is one of the problems that affects millions of people across the world.
Much of the arsenic in the atmosphere comes from high-temperature processes such as coal-fired electricity power plants, burning vegetation, and volcanic activity. The arsenic is released into the atmosphere primarily as arsenic trioxide where it adheres readily onto the surface of particles. These particles are dispersed by the wind and eventually fall back to the earth due to their weight or during rain.
Symptoms of arsenic poisoning begin with headaches, confusion, severe diarrhea, and drowsiness. As the poisoning develops, convulsions and changes in fingernail pigmentation called leukonychia striata, Mees’ lines, or Aldrich-Mees’ lines may occur. When the poisoning becomes acute, symptoms may include diarrhea, vomiting, blood in the urine, cramping muscles, hair loss, stomach pain, and more convulsions. The organs of the body that are usually affected by arsenic poisoning are the lungs, skin, kidneys, and liver. The final result of arsenic poisoning is coma and death.
The 1995 Preliminary Assessment report states that fluorspar from the plant was acquired by the federal government as strategic materials and was stored approximately 300 feet south of the Armory property.
“In 1982, the SESA site (Fluorspar Ore Refining Plant) was listed in the CERCLA information system known as the Superfund or Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). CERCLA is a United States federal law designed to clean up sites contaminated with hazardous substances as well as broadly defined “pollutants or contaminants) as a discovered site and was the subject of a PA by the U.S. EPA in early 1983. The 1995 PA Study listed status of this site (Armory) is not currently nor was formerly on the proposed or final National Priority List (NPL) and no further remedial action planned.” The 1995 PA Study of the Armory site concludes that “This facility is no longer active.” Consequently, the Armory site is not an EPA Superfund Site, but does not mean that there are not any hazardous or toxic materials on the property.
During the 1995 PA Study of the Armory property, there were multiple soil samplings taken from the 5 acre property where the Texas Army National Guard Armory is located at 489 South Monroe Street property.
The 1995 PA Study found that an analysis of the soil samples indicated that the area south of the Armory parking lot “indeed contained elevated concentrations of Arsenic and Beryllium which were above the Texas Risk Reduction Standards for those elements.”
The 1995 PA Study states that borings of up to 24 inches in depth were drilled and arsenic and Beryllium in higher concentrations were detected at the top levels of soil up to 12 inches in depth.
Based on the current Risk Reduction Standards in the Texas Industrial and Municipal Solid Waste Regulations (30 TAC 335, Subchapter S) and TCEQ the working action level concentration for total arsenic is 20 parts per million (PPM) . Four of the soil samples obtained from the Armory parking lot site were found to be at or above this concentration.
The four samples detected of concern had 31 PPM, 34PPM, 23 PPM and 20 parts per million respectively.
The 1995 PA Study concludes that the Texas Natural Resources Conservation Commission (TNRCC), the predecessor of TCEQ, recommends the removal of arsenic contaminated soils containing concentrations above 20 ppm and submit information regarding soil contamination to public records for deed recordation.
Beryllium in high level exposure also has possible ill-effects to those who are exposed to it.
Although the general population is exposed to normally low levels Beryllium in air, food and water in the course of their daily lives, people working or living near Beryllium industries have a greater risk potential of exposure. People working in industries where beryllium is mined, processed, machined, or converted into metal, alloys, and other chemicals may be exposed to high levels of beryllium.
Higher-than-normal levels of beryllium may also be in soil at hazardous waste sites so those living near uncontrolled hazardous waste sites may be exposed to higher than normal levels of beryllium as well.
Exposure to beryllium can affect the lungs and/or skin. However, not everyone will develop health effects from beryllium exposure.
People who work closely with beryllium as part of their employment have the greatest risk of developing health effects from beryllium. However, people who have had only infrequent exposure to beryllium may still develop health effects. Some individuals develop health effects shortly after exposure, while others may develop health effects many years after exposure has stopped.
Once a person has been exposed to beryllium, they have a lifelong risk of developing disease even if exposure stops.
Beryllium usually affects the respiratory system, although it can affect other parts of the body as well. Different types of illnesses or health effects associated with beryllium include Beryllium sensitization, Chronic Beryllium Disease (CBD), Lung Cancer, Acute Beryllium Disease and Skin Diseases.
The 1995 Preliminary Assessment Study further states that Robert E. Lee Elementary School, which is located approximately 1,200 feet northwest of the Armory property, as the closest facility with an at-risk population based on the age group and consistency of occupation near the site.
The 1995 PA Study further states that public parks and baseball fields are also located 200 feet directly west of the Armory property but that occupation of those facilities are intermittent. The nearest residential areas to the armory are located approximately 500 feet east and 700 feet north of the site in accordance to the PA report.
The 1995 PA Study states that an estimated permanent residential population of 400 was located within a quarter of a mile radius of the Armory property. Today, that population level is estimated to have multiplied by more than three to four times around the same perimeter described in the study.
The 1995 PA report’s interpretation of findings, recommendations and conclusions state that after the assessment it was determined that the operations on the Armory property had not contributed to the presences of substances that were under investigation on or near the property.
“Findings of this PA indicate that pre-existing conditions and previous uses of the site and vicinity are the primary sources of potentially harmful substances found on the Armory property and the surrounding area. Elevated concentrations of heavy metals, particularly arsenic and beryllium, were found in the soil collected at the Armory site. The analysis of greatest concern that was detected in the samples analyzed was arsenic.”
The 1995 PA report’s conclusion does state that the potentially harmful constituents detected in the soil samples obtained on the Armory site during the modified PA include arsenic and beryllium; however, the concentrations of these substances were not regarded as immediately harmful to life and health at the time of the study in 1995.
“The maximum concentrations of arsenic and beryllium (34 mg/kg and 1.7 mg/kg, respectively) exceed Texas Risk Reduction Standards as set forth in the Industrial and Solid Waste Regulations (30TAC 335) and therefore constitute an undetermined level of concern to personnel on the site and nearby civilian populations. An estimated 12,000 to 20,000 square feet of the surface soil to depths ranging from 0.5 to 1 foot or 6,000 to 20,000 cubic feet or 222 to 740 cubic yards appear to contain detectable concentrations of arsenic which exceed the maximum Texas Risk Reduction Standards,” says the Study.
The 1995 PA report states that the most likely route of transport of contaminants from the Armory site would be by mechanical or airborne particulates. The report does state that the City of Eagle Pass potable water is not compromised due to the findings under the study.
The studies recommendations were to control the access to the site to limit the exposure to civilian populations. Avoid disturbance of the ground surface, particularly non-vegetated areas. The report also recommended that a coordination process be set with the Texas Commission on Environmental Quality (TCEQ) regarding stabilization or removal of surface soils in the areas adjacent to the parking lot south of the armory building.
The report further gives other alternatives through TCEQ’s Industrial Hazardous Waste Corrective Action Section Closure Team personnel.
Among the alternatives defined are to remove arsenic contaminated soils containing concentrations above background levels. This action would not require deed recordation and future legal liability would be minimized; remove arsenic contaminated soils containing concentrations above 20 ppm and submit information regarding soil contamination to public records for deed recordation. Legal liabilities for, hazardous substances would be extant; install engineering controls to prevent dispersal of contamination and install monitor wells for perpetual detection of potential contamination migration. Deed recordation would be required and legal liabilities would be extant; provide a suitable ground cover to prevent airborne or mechanical dispersal of surface soils and provide analytical evidence that the risk of leaching of hazardous substances will remain low. Deed recordation would be required and legal liabilities would be extant.
Other facilities specified to have been in proximity of the location being studied were an agriculture fumigation and quarantine facility, freight transfer and storage facilities, municipal wastewater treatment plant, other commercial facilities and the proposed site for the Eagle Pass International Bridge and border station.
It is unknown if those measures recommended under the 1995 PA study were ever taken at the Armory property site by any entity.
Although the proposed property for the new City of Eagle Pass Public Safety Headquarters-the
Armory site-was not found to have such high contamination levels to be placed on the EPA Superfund Cleanup Site list, high concentrations of arsenic and beryllium were found on soil samples taken at the Armory and its parking lot site. The City of Eagle Pass would be wise to nonetheless conduct its own environmental impact assessment study of the Armory site before it spends $6.5 Million of taxpayers monies to construct its new Public Safety Headquarters at this property.
