-------
Sal
I;
^ IM
i§
l
H
I !
1 1
Q Q
Z Z
o
lation
i :
i :
1 !
§
ii
P
»
halatio
|
i i
i i
§
i§
! «a
e o
l-'i
a
i t
i i
g
i i
i :
a o
z z
alati
Oral
I l
! i
g g
l«
i 12
:§
,«
!ti
8
8
Q +
g g
I
-------
risks and non-carcinogenic risks. The results of the risk
characterization potentially provide a basis for any remedial
action that might be needed to protect public health and the
environment.
Human health risks or hazards are generally classified into 1)
incremental risks of cancer, and 2) noncancer effects as determined
by the hazard index.
According to the 1990 National Oil and Hazardous Substances
Pollution Contingency Plan (NCP, 1990), which provides the
framework for implementation of the Superfund program, the lifetime
incremental (excess) cancer risk should not exceed the 1 xlO"4 to
1 x 10'6 range. OSWER Directive 9355.0-30 (EPA, 1991a) states,
"Where the cumulative carcinogenic site risk to an individual based
on an RME scenario for the current and future use is less than 1 x
10~4, and the noncarcinogenic hazard quotient (index) is less than
one, remedial action is generally not warranted. . .."
Noncarcinogenic health hazards are expressed in terms of a Hazard
Quotient (HQ) for a single substance or Hazard Index (HI) for
multiple substances and/or exposure pathways. These are ratios of
particular chemical exposures compared to reference doses as
discussed further below. If the value of the HQ is less than." 1,
the hazards are not considered to pose a threat to public health,
including sensitive subgroups.
Carcinogenic Risk
Carcinogenic risks are estimated as the incremental.probability of
an individual developing cancer over a lifetime as a result of
exposure to a potential carcinogen. The estimate of excess
lifetime cancer risk is calculated by multiplying the chronic
(lifetime) daily intake (GDI) by the cancer slope factor (SF).
EPA policy must be considered in order to interpret the
significance of the cancer risk estimates. In the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP) (40 CFR §
300.430(e)(2)(i)(A)(2)), EPA states that: "For known or suspected
carcinogens, acceptable exposure levels are generally concentration
levels that represent an excess upper-bound lifetime cancer risk to
an individual of between 10'4 and 10'6." The agency further
discusses in the preamble to the NCP that the 10"6 risk level .be
used as a point of departure for establishing remediation goals for
the risks from constituents at Superfund sites (Federal Register
Vol.55, No. 46, 8713). Recent EPA guidance indicates that if the
estimated total cancer risk based on maximum exposure conditions is
1 x 10'4 or less, further action at the site is generally not
34
-------
warranted unless there are adverse environmental impacts, or
drinking water standards [Maximum Contaminant Levels (MCLs) or
Maximum Contaminant Level Goals (MCLGs) ] are exceeded (40 CFR Parts
141 and 143; EPA, 1986a).
Noncarcinoaenic Risk
The potential for noncarcinogenic health effects, expressed as the
hazard quotient and hazard index, is calculated in a manner similar
to the carcinogenic risks. The hazard quotient applies to
individual chemicals, whereas the hazard index applies to the sum
of potential noncarcinogenic health effects for all chemicals of
concern in a given exposure scenario. The hazard quotient is
calculated by dividing the daily intake by the reference dose.
Risk Characterization for Each Receptor
Carcinogenic risks and noncarcinogenic health hazards were
estimated for each risk assessment scenario, exposure pathway and
chemical of concern using the chemical intake factors and exposure
point concentrations presented above. Tabulated hazard indices and
cancer risks for each receptor for both the average and RME
exposure scenarios are shown in Table 10.
Offsite Child Residents
Offsite child residents are assumed to live on properties adjacent
to the site. These residents are assumed to live in the residences
for 9 and 20 years for average and RME scenarios. The total
chronic hazard indices calculated for noncarcinogenic effects due
to soil ingestion and dermal exposure and to particulate inhalation
are 0.6 and 0.3 for average and RME scenarios, respectively. Both
hazard indices are below 1.0, which indicates that no adverse
health effects are to be anticipated even to sensitive individuals
under RME conditions. The magnitude of the hazard index is due
primarily to the inorganics present at the site (soil ingestion
pathway). Organic contaminants at the site did not contribute
significantly to the overall hazard index for this receptor.
The lifetime excess cancer risk for the off-site child resident is
3 x 10'5 and 4 x 10'5 for average and RME scenarios, respectively.
These levels, which are the result of exposure by soil ingestion,
dermal exposure and particulate inhalation, are within the 1 x 10'4
to 1 x 10"6 range considered acceptable by EPA.
35
-------
Ui
2g
-I
if
Ed 3
-£
td ^
E w
23!
si§
Hi
I2
3«
a|
u w
Q u
2S
§§
I"
I
=
c3
s-s
g^gi
fr) pj (fll
1-1 CO -8|
.20.3
**S
O O
w.
10 CM
1
o 2 2 2
: ;
-------
Offsite Adult Residents
Like the child residents, offsite adult residents reside in areas
adjacent to the site. Residence times are 9 and 30 years for
average and RME scenarios, respectively. The total chronic hazard
indices for all exposure pathways are 0.07 and 0.1 for average and
RME. As was noted for the child residents, these values are well
below the 1.0 point of departure recommended by EPA (EPA, 1989a)
for protection against noncarcinogenic hazards. Similarly, the
magnitude of the total hazard index is primarily associated with
inorganic site constituents.
The cumulative excess lifetime cancer risk for offsite adult
residents is 4 x 10"6 and 2 x 10'5 for average and RME exposure
scenarios, respectively. These .figures are also well within the
acceptable range for excess lifetime cancer risk (EPA, 1989a).
Onsite Child Trespassers
Onsite child trespassers are assumed to trespass on the site for 12
and 52 days/year for average and RME scenarios, respectively. The
total cumulative chronic hazard indices for this receptor were 0.02
and 0.04 for average and RME, both well below 1.0. This indicates
that a noncarcinogenic health hazard to this receptor is unlikely.
The soil ingestion pathway constituted the most significant
cumulative hazard index for this receptor. Again, inorganics
contributed the most to the hazard index, not site organics.
The cumulative excess lifetime cancer risks were also within the
acceptable range for this receptor (EPA, 1989a). The average and
RME excess cancer risks were 1 x 10"6 and 4 x 10"6, respectively.
Future Onsite Residents (Adults and Children)
To be conservative, hypothetical future onsite adult and children
residents were evaluated. Total cumulative hazard indices for
average RME exposures were 0.5 and 0.3 for children and 0.07 and
0.1 for adults. Excess lifetime cancer risks for these
hypothetical receptors were calculated for average and RME exposure
scenarios as 4 x 10'5 and 5 x 10'5 for children and 5 x 10'6 and
2 x 10"5 for adults. All hazard indices and excess lifetime cancer
risks for these receptors are within acceptable ranges.
37
-------
UNCERTAINTIES AND LIMITATIONS
EPA guidance for risk assessment provides a systematic means for
organizing, analyzing, and presenting information on the nature^ and
magnitude of potential risks to public health and the environment
from chemical exposures. Despite the advanced state of the current
methodology, uncertainties and limitations are inherent in the risk
assessment process. Available data quality, incomplete information
about existing conditions and future circumstances, as well as
other factors discussed below contribute to these uncertainties and
limitations. This section discusses the following sources of
uncertainties and limitations associated with this risk assessment:
Data Collection
Data used in the human health risk assessment were collected from
the site during phases of the RI. The data collected durinr the RI
are subject to uncertainty associated with sampling and analysis.
Inorganics were included in the risk assessment to be conservative
even though the concentrations were within background.
Due to the limits of analytical methodologies and the complexity of
matrices for environmental samples, some chemicals present in low
concentrations in samples may not be detected, leading to a
possible underestimation of risk. This potential source of
uncertainty is addressed during data evaluation, as described
below.
Data Evaluation
In compiling most of the data for use in the risk assessment,
arithmetic means and 95 percentile upper confidence limits on the
mean concentrations of chemicals detected in each media were
compiled. In compiling data, one-half of the detection limit was
used for those samples which contained chemical concentrations
below the detection limit. This assumption is conservative and may
lead to overestimation of risk, particularly for those chemicals
reported with low frequencies and low concentrations. The
arithmetic mean concentration was used in evaluation of average
exposures, an assumption which does not over or underestimate risk.
In estimating RME exposures, the 95th percentile UCL concentrations
were used, which results in overestimation of potential risks.
Exposure Assessment
The exposure assessment is based on a series of assumptions
concerning concentrations of chemicals to which humans are exposed
(exposure point concentrations) and patterns of behavior leading to
exposure or intake of chemicals (exposure scenarios).
38
-------
Toxicitv Assessment
In general, the available scientific information is insufficient to
provide a thorough understanding of all the potential toxic
properties of chemicals to which humans are potentially exposed.
Consequently, varying degrees of uncertainty surround the
assessment of adverse health effects in exposed populations.
Sources of uncertainty related directly to toxicity data include:
Use of dose-response data from experiments on homogenous,
sensitive animal populations to predict effects in
heterogenous human populations with a wide range of
sensitivities
Extrapolation of data from 1} high-dose animal studies to low
dose human exposures, 2) acute or subchronic exposure to
chronic exposure, and 3) one exposure route to anothei- (e.g.,
from ingestion to inhalation or dermal absorption)
Use of single-chemical test data that do not account for
multiple exposures or synergistic and antagonistic responses
Absence of generally accepted toxicity values for certain
chemicals
Use of sensitive subpopulations, i.e., the very young and old
Impacts to the Environment:
A qualitative environmental evaluation was performed at the site
based on the condition of the site after the ERA. This evaluation
was restricted to a review of the local ecology, potential exposure
pathways and the presence of any potential sensitive, endangered or
threatened species in the vicinity of the site. According to the
U. S. Fish and Wildlife Service, no threatened or endangered
species live in the vicinity of the site. Because of the proximity
of the site to Interstate 10 and a residential area and due to the
fact that the site is surrounded by fencing, the availability and
accessibility of potential biotic receptors to the site is reduced.
In general, the fenced site includes several trees, grassy areas
including areas over clay caps placed by remediation activities
during the ERA, and areas covered by shell. Clay caps will be
monitored and maintained to ensure that cap integrity is retained.
Such maintenance will prevent tree roots and burrowing/digging
animals from disrupting the integrity of the clay cap and will,
therefore, limit the potential for exposure to subsurface site
constituents.
39
-------
Chemical analyses of surface soils indicate concentrations of site-
related organic constituents to be low. Therefore, potential
exposures of site-related organics via contact with surface soils
or surface water run-off (i.e., offsite ditches, Grand Goudine
Bayou) to biotic receptors is expected to be insignificant.
Potential ground water to surface water exposures are expected to
be negligible. For example, during the ERA, water sampled between
the primary and secondary berms around the ponds was shown to meet
discharge standards. This surface water, in contact with
subsurface soils and shallow ground water, would be expected to
represent a worst case surface water contamination scenario. Yet,
concentrations of site constituents met discharge criteria without
further treatment. Therefore, risk from potential exposures to
biota via ground water to surface water scenarios is expected to be
negligible. Because of the lack of significant indicator species
and exposure pathways, exposure of biota to site constituents at
the site is not expected to result in any increased risk to the
biota in the area of the site.
Remedial Action Objectives And Goals
Remedial action goals consist of'medium-specific or operable unit-
specific goals for protecting human health and the environment.
Remedial Action Objectives for Soils
The remedial action objectives for soils at the site are based on
human health risks and environmental protection as follows:
Prevent ingestion/direct contact with soil having non-
carcinogenic chemicals of concern in excess of a hazard index
of 1 (a hazard index less than 1 means that no adverse non-
cancer health effects are expected),
Prevent ingestion/direct contact with soils having greater
than l x 10"4 (1 in ten thousand) to 1 x 10"6 (1 in one
million) excess cancer risks from carcinogenic chemicals of
concern,
Prevent inhalation of carcinogenic chemicals of concern
posing excess cancer risks greater than 1 x 10"4 (1 in ten
thousand) to 1 x 10*° (1 in one million).
The primary sources of contamination at the site were the holding
pond, the small waste oil pit, and the aboveground storage tanks.
These sources, together with soils with concentrations greater than
4 ppm benzene, were removed during the ERA. The areas previously
occupied by the holding pond and waste pit were covered with an 18-
inch compacted clay cap. The area previously occupied by the
vertical storage tanks was covered with six inches of compacted
clay fill.
40
-------
The risk assessment conducted as part of the RI evaluated potential
human health risks/hazards and environmental effects due to
exposure to chemicals remaining at the site. As presented in Table
10, the baseline risk assessment showed that all excess cancer
risks from the RME are less than 5 x 10'5 (5 in one hundred
thousand) and all hazard indices calculated for non-carcinogens are
below 1. The calculated excess cancer risks and hazard indices
fall with EPA's acceptable risk range.
The National Oil and Hazardous Substances Pollution Contingency
Plan (40 CFR § 300.430(e)(2)(i)(A)(2) states that: "For known or
suspected carcinogens, acceptable exposure levels are generally
concentration levels that represent an excess upper-bound lifetime
cancer risk to an individual of between 10"4 and 10"6." OSWER
Directive 3355.0-30 (EPA 1991) states, "Where the cumulative
carcinogenic site risk to an individual based on reasonable maximum
exposure for both current and future land use is less than 10"*, and
the non-carcinogenic hazard quotient is less than 1, action
generally is not warranted unless there are adverse environmental
impacts."
To evaluate whether any chemical of potential concern for onsite
surface soils could exceed EPA's acceptable excess lifetime cancer
risk or non-carcinogenic risk, a comparative analysis was
performed. The comparative analysis evaluated target remediation
goals for potential chemicals of concern in onsite soils for
residential land use, versus the concentrations of onsite soil
contaminants identified during the RI. The target remediation
goals were calculated in accordance with Risk Assessment Guidance
for Superfund: Volume 1 - Human Health Evaluation Manual, Part B:
Development of Risk-based Remediation Goals (OSWER Directive
9285.7-01B) for cancer risks of l x 10'4 and 1 x 10'6, and a hazard
index of 1. As presented in Table 11, the concentrations of the
chemicals of potential concern for onsite surface soils fall within
the target remediation goals calculated for EPA's acceptable excess
cancer risk range of 1 x 10"4 to 1 x 10*6, and are below the non-
carcinogenic hazard index of 1.
Since the risks posed by exposure to surface soils at the site fall
within EPA's acceptable risk range of 1 x 10'4 to 1 x 10'6, under
current and no action conditions, there is no need to establish
additional numerical cleanup standards for soils. Ecological
effects due to exposure to site contaminants were qualitatively
addressed in the RI report and showed that potential for adverse
ecological impact was minimal.
41
-------
a)
H
(0
a)
n
D
1
5
10
I
to
& 0)
p
I -H
CO
(0
H .p
10 C
O 0)
u e
P
C 10
O Q)
H >H
P E-<
(0
Q) O
O C
*B
.p -p
Q) JS
tP U
<0 3
EH Q
^^
C7*
>>
^^
ty*
g
^^
rH
<0
O
o
c
o
H
4J
iH
o
OJ
g
OJ
^
c
^
g
H
rH
OJ
p(
0>
H
O
CO
OJ
O
(0
CO
en
N
o
o
vo
d
H
|
^
O
rH
$
0
%
OJ
CO
(X
n
o
(S»
P)
^
in
U
H
C
0)
10
%
t
O
3
1
O
o
0
^
^*
H
rij
>^
g
^«
x^
2
ON
OJ
g
3
H
10
n
o
^d*
rH
rtj
^*^
g;
rtj
**^
55
H
.
0
6
H
10
O
o
o
^1
«t
H
(dj
**^
55
^
'x^
2
rH
H
g
rH
§
H
6
o
o
o
%
r*
CJ
rtj
v^
2
rtj
*x»
2
^
.
O
0)
c
OJ
N
c
0)
H
>i
4J
H
O
O
o
^
f^
OJ
rtj
^^,
55
rtj
**^
g
I/N
UI
in
Q)
ca
S
10
Cn
c
10
s
M
CO
(4j
^^
55
,4;
^^^
2
en
.
0
>i
g
^
E
o
^3*
H
rtj
x,^
2
^;
x^
2
H
H
OJ
c
0)
N
c
OJ
o
H
0
o
en
H
-------
Remedial Action Objectives for Ground Water
The remedial action objectives for ground water at the site are as
follows:
Prevent human exposure to contaminated water,
Prevent contamination of the underlying 150-foot drinking
water aquifer, and
Restore contaminated shallow ground water, based on its
classification, for future use.
Each of these remedial action objectives is discussed below in
terms of remedial actions at the site.
Prevent Exposure to Contaminated Ground Water
The contamination plumes identified at the site are all located in
the shallow water-bearing unit from 0 to 14 feet below ground
surface. This shallow water-bearing unit is a Class III ground
water unit. The shallow aquifer does not contain any drinking
water wells and does not support sufficient yield to serve as a
drinking water supply aquifer. The local drinking water supply
aquifers are 150 feet or deeper below ground surface. The risk
assessment completed in conjunction with the RI could not identify
a current or future path for the ground water in the shallow water-
bearing unit to directly impact any potential receptors or the
deeper underlying drinking water aquifers.
Prevent Contamination of Drinking Water Aquifer
Computer ground water modeling conducted during the RI showed
minimal hydraulic connectivity between the shallow water-bearing
unit and the deeper aquifer used for drinking water. The first
usable drinking water aquifer beneath the site is approximately 140
feet below the contaminated shallow-water bearing unit, however,
the closest completed water wells are in water bearing intervals
greater than 200 feet. The deeper water-bearing unit at the site
(30 feet deep) is monitored by several wells and has shown no
contamination to date. Monitoring of these deeper wells should
detect any downward migration of contamination from the shallow
zone long before it could potentially reach the underlying drinking
water aquifer, thus providing time to take measures for its
protection, if necessary.
43
-------
Restore Contaminated Ground Water for Future Use
Although contamination in the shallow ground water is above Maximum
Contaminant Levels (MCLs) for several chemicals, restoration of the
shallow water-bearing unit beneath the site is not warranted since
the aquifer is not identified as a potential usable ground water
source. This unit is a Class III ground water unit and will not be
used in the future for drinking water due to its low yield.
Remedial Action Goals
The risk assessment associated with the RI could not identify a
pathway between the shallow water-bearing unit and any potential
receptor population. Since no pathway was identified, a numerical
health-based cleanup level based on exposure can not be developed.
According to the EPA (OSWER Directive 9283.1-2), health-based
drinking water levels are usually not appropriate for Class III
ground water. Environmental considerations and prevention of plume
expansion determine cleanup levels for Class III ground water.
Since exposure to surface and subsurface soils at the site are not
expected to result in any excess risk/hazard to human health and
the environment under current and no action conditions, and since
no current or future exposure pathway was identified for the
contaminated shallow aquifer, there are no numerical cleanup
standards for soils or ground water.
VII. DESCRIPTION OF ALTERNATIVES
A Feasibility Study (FS) was conducted to develop and evaluate
alternatives to meet the remedial action objectives for the site.
Remedial alternatives were assembled from applicable remedial
technology process options and were initially evaluated for
effectiveness, implementability, and cost based on engineering
judgement. The alternatives selected for detailed analysis were
evaluated and compared to the nine criteria required by the NCP
(see Section VIII. of this ROD). As a part of the remedial
alternative evaluation process, the NCP requires that a no-action
alternative be considered at every site. The no-action alternative
serves as a basis of comparison for the other alternatives.
Since the remedial action objectives for soils have been met, the
only alternatives presented are for the ground water contamination.
The ground water remedial alternatives developed for the two ground
water contamination plumes at the site include active restoration,
44
-------
passive restoration, and no action alternatives. Several ground
water treatment technologies have been combined to develop a series
of active restoration technologies.
Except for the "No Action" alternative, all of the alternatives
being considered for the site include the following common
elements:
Institutional controls are considered in conjunction with
every proposed remedy. Institutional controls include
actions that neither treat nor remove contaminants, but
restrict contact with contaminants considered. These
actions include fencing the site, maintaining the
existing cap, posting signs, deed notices, and land use
restrictions. The institutional controls would utilize
some existing resources. Costs for the institutional
controls are included in the monitoring costs for each
alternative. During the semiannual inspections of the
site, the fence will be inspected for holes, structural
integrity, and/or other damage. Inadequate areas of
fencing will be repaired within one month of inspection.
The fence inspection schedule should be reevaluated after
five years.
Site-use restrictions will be implemented as part of all
alternatives to prohibit activities such as soil
excavation and construction of buildings and/or
installation of domestic water wells either at the site
or on land adjacent to the site.
Alternative l: No Action
Present Worth (PW): $28,808
Implementation Time: 0 months
EPA is required by the NCP (40 CFR Part 300) to consider the "No
Action" alternative. No action assumes that nothing would be done
to restrict site access, monitor ground water quality, maintain
site cap and fence, or install new monitoring wells. This
alternative also assumes that no offsite or onsite monitoring would
be performed. No action would be taken to prevent migration of
contaminated ground water at the site. The only costs associated
with this alternative are the preparation of Five-Year Reports.
This alternative will not provide overall protection of human
health and the environment; long-term or short-term effectiveness;
or, reduce toxicity, mobility or volume of hazardous substances
and, therefore, it is not favored by EPA.
45
-------
Alternative 2: Natural Attenuation - EPA's SELECTED REMEDY
PW: $760,197
Implementation Time: Indefinite
Natural attenuation relies on the ground water's natural ability to
lower the contaminant concentrations over time through physical,
chemical, and biological processes. In this alternative, ground
water will be monitored to determine if current conditions improve
through time, remain constant, or worsen. To accurately assess the
ground water conditions, additional monitoring wells would be
installed both onsite and offsite, and ground water would be
monitored in both the onsite and offsite wells.
If ground water monitoring indicates an increase in contaminant
concentrations (either vertically or horizontally), contingency
measures (which include active treatment) will be implemented at
the site. The contingency measures are described in Section IX of
the Record of Decision.
Institutional controls in the form of access restrictions,
installation of signs, restrictions on future use of the property,
fencing and deed notices and/or restrictions on the use of ground
water from site water wells will be implemented. In addition, the
existing cap and fence will continue to be maintained. One
residential well on the Watt's property will be closed out and a
replacement well drilled. An agreement to close out the well on
the Watt's property was reached by EPA and the responsible parties
following completion of the feasibility study, therefore, the costs
associated with closing out the residential well and the drilling
of a replacement well are not included in the cost estimate
presented above. It is believed that the costs associated with
these activities will not substantially change the PW cost of this
alternative.
EPA's evaluation of the site specific data indicates that active
treatment of the ground water contamination is not warranted at
this time. Active treatment is not warranted because 1) the
contaminated ground water is a Class III aquifer, and 2) the ground
water modeling data showed that the ground water contaminants
should never reach the 150-foot drinking aquifer and that the
concentrations of benzene, ethylbenzene and styrene would be below
MCLs by the time they migrated to 28 feet below ground surface.
However, EPA believes it is prudent to monitor ground water to
ensure that any exposure pathway is not completed or that
contaminated ground water does not migrate to the underlying
drinking water aquifer.
46
-------
In this alternative the monitoring wells that are currently in
place around both the former holding pond and waste oil pit would
be used to monitor the status of the two ground water plumes.
Ground water monitoring would occur quarterly for the first year,
semiannually for the next four years, and annually thereafter
unless circumstances warrant more frequent sampling. This
monitoring program will detect any movement of the contaminant
plumes before any exposure pathway could be completed. The ground
water monitoring would monitor both vertical and horizontal extent
of the two ground water plumes.
Alternative 3: In-Situ Biological Treatment
PW: $16,764,211
Implementation Time: Unknown
Rather than recover contaminated ground water for treatment in an
above ground system, in-situ biological treatment would be used to
treat the ground water in-place in the shallow aquifer. In this
alternative, a slurry of a mixture of oxygen sources, nutrient
sources and microbes would be injected under pressure into the
areas of contamination. An initial treatment would be applied and
a second treatment would be made after three years if necessary.
The progress of the remediation would be monitored by collecting
ground water samples from the monitoring wells. The increase in
biodegradation rates is dependent on the site conditions and may
require pilot testing. Low permeability soils such as those found
in the shallow water-bearing zone at the site could inhibit the
hydraulic transport of the microbes, oxygen and nutrients required
to degrade the contaminants.
This alternative would reduce the potential for further migration
of contaminants from the shallow aquifer, and no waste treatment
residuals will be generated. Although this alternative is a viable
and feasible alternative, for the reasons discussed above, active
remediation is not warranted at this time.
Alternative 4A
Ground Water Extraction, Activated Carbon Treatment, and Surface
Water Discharge:
PW: $3,383,907
Years to Implement: Unknown
The extraction technology associated with this alternative is the
use of the french drain located in the area of the former waste pit
and the installation of three french drains around the area of the
47
-------
former holding pond. The three french drains would be installed
parallel to and just inside the property boundaries in the areas
where ground water data indicate there may be ground water with
levels of contaminants above the MCLs. By locating the drains at
the property boundaries, the drains will prevent further migration
of contaminants offsite while simultaneously recovering the
existing portion of the plume which has already migrated beyond the
site boundaries. Pulsed pumping which is a variation of continuous
pumping could be used to pump the french drains. Pulsed pumping
involves cycling of the ground water extraction system through
alternating "active" and "resting" phases.
To ensure that adequate remediation of the ground water is
occurring, monitoring of the contamination plume will take place.
Monitoring would consist of quarterly sampling for the first year,
semiannual sampling for the next four years, and annual sampling
thereafter of all wells in each contamination plume and on the
perimeter of each plume.
Activated carbon adsorption has been used successfully at the site
to treat contaminated ground water. The carbon units would be
rented and the spent carbon returned for regeneration. Following
treatment of the ground water it will be stored onsite for testing
prior to surface water discharge to the 1-10 drainage ditch. This
surface water discharge point was used successfully during the ERA.
The ARARs presented in Table 12 which pertain to discharges to
surface would be met under this alternative.
Alternative 4B
Ground Water Extraction, Air Stripping for Treatment, and Surface
Water Discharge:
PW: $2,604,324'
Years to Implement: Unknown
The ground water extraction technology described under Alternative
4A would also be implemented under this alternative to recover
ground water. Under this alternative, air stripping would be used
to remove the organic compounds from the ground water. The air
stripper unit would emit volatile organic compounds and may require
treatment (e.g. carbon adsorption) to meet air emission standards.
The ARARs presented in Table 12 which pertain to air stripping
would be met under this alternative. The treated ground water
would be discharged to the 1-10 drainage ditch as described in
Alternative 4A.
To ensure that adequate remediation of the ground water is
i
48
-------
occurring, monitoring of the contamination plume will take place.
Monitoring would consist of quarterly sampling for the first year,
semiannual sampling for the next four years, and annual sampling
thereafter of all wells in each contamination plume and on the
perimeter of each plume.
Alternative 4C
Ground Water Extraction and Deep Well injection:
PW: $6,670,097
Years to Implement: Unknown
The ground water extraction technology described under Alternative
4A would also be implemented under this alternative to recover
ground water. Under this alternative the recovered ground water
would be held onsite in above ground storage tanks and then trucked
to a local commercial deep well for injection. Deep well injection
was utilized at the site to dispose of water collected from the
french drain. The ARARs presented in Table 12 which pertain to
underground injection would be met under this alternative.
To ensure that adequate remediation of the ground water is
occurring, monitoring of the contamination plume will take place.
Monitoring would consist of quarterly sampling for the first year,
semiannual sampling for the next four years, and annual sampling
thereafter of all wells in each contamination plume and on the
perimeter of each plume.
Alternative 4D
Ground Water Extraction/ Biological Water Treatment, and Surface
Water Discharge:
PW: $3,861,599
Years to Implement: Unknown
The ground water extraction technology described under Alternative
4A would also be implemented under this alternative to recover
ground water. Under this alternative, recovered ground water would
be treated onsite using either aeration lagoons or a packaged waste
water treatment plant such as a sequencing batch reactor. Both
systems supply additional dissolved oxygen to support microbes
which biodegrade the organic compounds present in the recovered
ground water.
Following treatment of the ground water by biological treatment, it
will be stored onsite for testing prior to surface water discharge
to the 1-10 drainage ditch. To ensure that adequate remediation of
49
-------
the ground water is occurring, monitoring of the contamination
plume will take place. Monitoring would consist of quarterly
sampling for the first year, semiannual sampling for the next four
years, and annual sampling thereafter of all wells in each
contamination plume and on the perimeter of each plume.
VIII. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
The EPA uses nine criteria to evaluate alternatives for addressing
a Superfund site. These nine criteria are categorized into three
groups: threshold, primary balancing, and modifying. The threshold
criteria must be met in order for an alternative to be eligible for
selection. The primary balancing criteria are Used to weigh major
tradeoffs among alternatives. The modifying criteria are taken
into account after state and public comment is received on the
Proposed Plan of Action. ,
NINE EVALUATION CRITERIA
The nine criteria used in evaluating all of the alternatives are as
follows:
Threshold Criteria
Overall Protection of Human Health and the Environment addresses
the way in which an alternative would reduce, eliminate, or control
the risks posed by the site to human health and the environment.
The methods used to achieve an adequate level of protection vary
but nay include treatment and engineering controls. Total
elimination of risk is often impossible to achieve. However, a
remedy must minimize risks to assure that human health and the
environment are protected.
Compliance with ARARsf or "applicable or relevant and appropriate
requirements," assures that an alternative will meet all related
federal, state, and local requirements.
Primary Balancing Criteria
Long-term Effectiveness and Permanence addresses the ability of an
alternative to reliably provide long-term protection for human
health and the environment after the remediation goals have been
accomplished.
50
-------
Reduction of Toxicity. Mobility, or Volume of Contaminants through
Treatment assesses how effectively an alternative will address the
contamination on a site. Factors considered include the nature of
the treatment process; the amount of hazardous materials that will
be destroyed by the treatment process; how effectively the process
reduces the toxicity, mobility, or volume of waste; and the type
and quantity of contamination that will remain after treatment.
Short-term Effectiveness addresses the time it takes for remedy
implementation. Remedies often require several years for
implementation. A potential remedy is evaluated for the length of
time required for implementation and the potential impact on human
health and the environment during implementation.
Imp1ementabi1itv addresses the ease with which an alternative can
be accomplished. Factors such as availability of materials and
services are considered.
Cost (including capital costs and projected long-term operation and
maintenance costs) is considered and compared to the benefit that
will result from implementing'the alternative.
Modifying Criteria
State Acceptance allows the State to review the proposed plan and
offer comments to the EPA. A State may agree with, oppose or have
no comment on the proposed remedy.
Community Acceptance allows for a public comment period for
interested persons or organizations to comment on the proposed
remedy. EPA considers these comments in making its final remedy
selection. The comments are addressed in the responsiveness
summary which is part of this ROD.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
The comparative analysis was conducted to evaluate the relative
performance of each alternative, compared to the other
alternatives, in relation to each specific evaluation criterion.
Protection of Human Health and the Environment
Each of the ground water alternatives, other than the "No Action"
alternative, will provide some degree of overall protection to
51
-------
human health and the environment. The manner in which each of the
alternatives protects human health and the environment varies.
Alternative 1 does not achieve the remedial action objectives and
does not provide protection to human health and the environment.
Although contaminant concentrations should naturally decrease over
time, Alternative 1 does not provide for monitoring of the
contaminant plumes to ensure that the plumes do not migrate
laterally or vertically.
Alternative 2 provides greater overall protection of human health
and the environment through implementation of institutional
controls, natural attenuation of the ground water contamination,
ground water monitoring to detect any movement of the two
contaminant plumes (both vertically and horizontally) that would
complete an exposure pathway. In addition, contingency measures,
which are described in Section IX of the ROD, are to be implemented
if ground water monitoring indicates an increase in contaminant
concentrations. The cap installed during the ERA will also
continue to be maintained.
The in-situ biological treatment (Alternative 3), which is a
relatively new technology for in-situ bioremediation of
contaminated shallow aquifers, is expected to be more protective of
human health and the environment since active treatment will be
used to reduce the concentration of contaminants in the ground
water.
The four ground water recovery alternatives (Alternatives 4A - 4D)
utilize proven active treatment technologies to prevent further
migration of the contaminant plumes, thus minimizing the potential
for establishing an exposure pathway which might endanger human
health and the environment.
Restoration of the contaminated ground water at the site is not
warranted at this time since the aquifer is a Class III aquifer and
will not be used as a future source of drinking water.
Compliance with Applicable Relevant and Appropriate Requirements
(ARARs)
All alternatives can meet the requirement for compliance with
chemical-specific, action specific, and location-specific ARARs.
52
-------
The ARARs for the alternatives may be found in Table 12. This
discussion compares each of the alternatives to the three
categories of ARARs and addresses whether the alternatives comply
with ARARs.
Chemical Specific ARARs
NPDES, Federal, and State water quality requirements may be ARARs
for the discharge of extracted, treated ground water. Alternatives
4A, 4B, and 4D incorporated active collection and treatment of
ground water, thus it most likely would meet all chemical specific
ARARs. The remaining alternatives do not include remedial actions
that discharge treated ground water to surface water, therefore,
chemical specific ARARs do not apply. Since the ground water in
the contaminated shallow aquifer is considered a Class III aquifer,
remediation to MCLs is not required. For this reason, there are no
chemical specific ARARs that are applicable or relevant and
appropriate for the site.
Action-specific ARARs
Actionrspecific ARARs potentially apply to discharge of ground
water to surface water, underground injection of contaminated or
treated ground water, excavation and construction of French drains
around the former holding pond to recover ground water, and air
stripping.
Alternatives 4A, 4B, and 4D are expected to meet the action-.
specific ARARs for discharge of ground water to a surface water
body under an NPDES permit. Alternative 4C is expected to meet the
action-specific ARARs for underground injection of contaminated or
treated ground water.
Alternative 4B is expected to meet the action-specific ARARs
(NESHAP standards for emissions of benzene from air strippers) for
air stripping. Alternative 4C is expected to meet the Federal Safe
Drinking Water Act requirements for underground injection.
Location-specific ARARs
There are no location-specific ARARs that are applicable or
relevant and appropriate for the site.
Long-Term Effectiveness and Permanence
The goals for all of the remedial alternatives are'to prevent human
exposure to contaminated shallow ground water and prevent
contamination of the underlying "150-foot" drinking water aquifer.
Alternative 2 meets the goals through natural attenuation and
should be as effective in the long term as the active treatment
alternatives since natural attenuation
53
-------
i
I
3
a
o
CA
3
\l
i
-------
§
1
I
2
2
I
I
j
11
SI
?»
91
-------
o
tn
!!
I
3
1
9
2
S
ft
a
1
!'
ssi-s'ss;
irfjHi
IK? s
l!
"
i
1
:
'I
,1!
iii
Ml!
ill?
if*
iii
i«)
-------
u
aa
I
1
s
1
O
sa~I 3 !isa!
fill vilijl]
fi'fii?!11*1
II {I
|i|[|ii|^i|i2i
1
i
=p
|i!
ll
I
iM «
JO* i
s. J
?I:
i is
111 !]
Ill J]
a s I a-8
ill h
i«
:«i
ill'
11
*** 5
§1
II?
IIS 5
N
II
f
tin
PH|
Hit fiPi
j 3* o *° Jc « J
JS S i 3 a 2
t . o 8 «. v
i a » s 'E s s
!5 B £ S o o _
!|g, jlffS S
!1
-------
will result in the lowering of contaminants of concern to the same
levels as would be achieved with active ground water treatment. In
addition, the preferred alternative provides that contingency
measures be implemented if contaminant concentrations or extent of
contamination increase over time.
Alternative 1 is considered to be effective in meeting the goals
for long-term effectiveness and permanence if current site
conditions remain constant or improve over time, however, it does
not provide a means to determine if conditions worsen. If the
concentration or areal extent of contaminants in ground water
increases over time, Alternative 1 is less able to meet the goals
of long-term effectiveness and permanence than Alternative 2, since
Alternative 2 provides for contingency measures to be implemented,
if contaminant concentrations or areal extent increase over time.
Alternatives 4A, 4B, and 4D meet the criterion for long-term
effectiveness and permanence since all of the alternatives will
actively treat the waste to reduce the contaminant concentration.
The long-term effectiveness of Alternatives 4A, 4B, and 4D would be
dependent on the effectiveness of the extraction system to be able
to remove the contaminated ground water and the effectiveness of
the treatment systems to remove the contaminants. Alternatives'4A,
4B, 4C, and 4D will reduce the concentration of contaminants in the
ground water more rapidly than Alternatives 1, 2, or 3 since they
involve physical removal of the contaminants.
Alternative 3 meets the criterion for long-term effectiveness and
permanence since the goal of this procedure is to biotreat all of
the contaminants of concern in the shallow ground water aquifer.
The long-term effectiveness of Alternative 3 would be dependent on
the .effectiveness of the in-situ biotreatment in lowering the
contaminant concentrations.
Reduction of Toxicity, Mobility and Volume Through Treatment
While Alternative 2 does not provide for active treatment of
contaminated ground water for reduction in toxicity, mobility or
volume, it will ultimately result in a reduced volume, toxicity and
mobility of waste at the site through natural biodegradation.
Monitoring will detect any movement of the waste volume laterally
or vertically. If monitoring indicates any movement of the waste
volume, a contingency plan (described below) will be implemented so
that there is not an increase in risk to human health or the
environment.
58
-------
Alternatives 3, 4A, 4B, and 4D include active treatment to reduce
toxicity, mobility or volume. Alternative 4C simply relocates the
waste, thus reducing its mobility, but not its toxicity or volume.
Alternative 1 does not provide reduction in toxicity, mobility or
volume because there is no active treatment.
Short Term Effectiveness
When evaluating short term effectiveness, the focus is on the risk
to workers and the risk to the community during the implementation
of the remedy. Risks to the community during construction and
operation of any of the remedial alternatives would be negligible.
Risks to the community during implementation of the alternatives
include potential emission of contaminants during treatment.
The natural attenuation (Alternative 2) and "No Action"
(Alternative 1) alternatives present a clear advantage with respect
to short-term effectiveness since they have little or no onsite
activity which could increase risk to workers and the community
The ground water recovery (Alternatives 4A - 4D) and in-situ
biological treatment (Alternative 3) alternatives do contain an
incremental element of risk due to such possibilities as spills of
contaminated ground water or chemicals necessary for treatment, air
emissions, and transportation accidents.
With respect to the speed with which a remedy achieves protection,
active ground water recovery should reach the remedial objectives
sooner than natural attenuation alone since the active recovery
methods can be adjusted to control the rate of ground water
recovered. Increasing the ground water recovery rate will
generally decrease the length, of time required to achieve
remediation goals. However, active ground water recovery
alternatives must still be considered long-term solutions (30
years) because of the low conductivity soils at the site.
Implementability
The "No Action" alterative (Alternative 1) and natural attenuation
alternative (Alternative 2) are the most readily implemented
options. The installation of additional monitoring wells, closeout
of one residential well, and replacement of the residential well
are easily implemented. Alternative 1, the "No Action"
alternative, does not include further actions at the site.
Although Alternative 3 is implementable, it is an untested
technique which results in a number of unknowns which increases the
difficulty in implementing this option.
59
-------
Due to the low conductivity soils found at the site, the technical
practicality of pump and treat technology (Alternative 4) is
questionable.
Cost
The estimated costs for the remedial alternatives range from
$28,808 for the No Action Alternative (Alternative 1) to
$16,764,211 for the In-Situ Biological Treatment alternative
(Alternative 3). The natural attenuation alternative (Alternative
2) has an estimated cost of $760,197.
State Agency Acceptance
The Louisiana Department of Environmental Quality concurs with the
selection of Alternative 2 as the preferred remedy for the site
(see Appendix #3). No comments regarding the other alternatives
were provided.
Community Acceptance
EPA solicited input from, the community on the remediation
alternatives proposed to the ground water contamination at the
site. The comments received from the public, indicate that the
community is supportive of the proposed remedy. All comments
received during the public comment period and the EPA responses are
in the attached Responsiveness Summary.
IX. THE SELECTED REMEDY
Based on consideration of the requirements of CERCLA, the
comparative analysis of alternatives, and public comments, the EPA
has determined that Alternative 2 (Natural Attenuation) will best
provide a remedy that is protective of human health and the
environment.
As discussed in Section IV of this ROD, the remedial objectives for
the site are:
Prevent human exposure to contaminated water,
Prevent contamination of the underlying 150-foot drinking
water aquifer, and
Restore contaminated shallow ground water, based on its
classification, for future use.
60
-------
The selected remedy (Alternative 2) will meet these objectives by:
Monitoring ground water to determine if current conditions
improve through time, remain constant, or worsen. This
includes installation and monitoring of both onsite and
adjacent private wells;
Implementing contingency measures (which include active
treatment) at the site if the ground water monitoring
indicates an increase in contaminant concentrations (either
vertically or horizontally). The contingency measures are
described later in this section of the ROD.
Implementing institutional controls in the form of access
restrictions, including installation of signs, restrictions on
future use of the property, fencing, and deed notices and/or
restrictions on use of ground water from site water wells;
Installing additional monitoring wells to provide additional
data on plume movement towards any drinking water wells and/or
beneath 1-10;
Maintaining the existing cap and fence; and
Closing out the residential well on the Watt's property and
drilling of a replacement well. An agreement to close out
the well on the Watt's property was reached by EPA and the
responsible parties following completion of the feasibility
study, therefore, the costs associated with closing out the
residential well and the drilling of a replacement well are
not included in the cost estimate presented above. It is
believed that the costs associated with these activities will
not substantially change the PW cost of this alternative.
Since the remedial action objectives are met through the above
actions, the long-term effectiveness and permanence of the selected
remedy is expected to be excellent. There are not expected to be
any unmanageable short-term risks associated with this remedy, and
this remedy complies with all ARARs. The selected remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable, and will be cost effective. However,
because treatment of the contaminated shallow ground water was not
found to be warranted at this time, this remedy does not satisfy
the statutory preference for treatment as a principal element of
the remedy. Also, the selected remedy does not call for treatment
of contaminated soils, because soil remediation was addressed
during the ERA, and the risk assessment conducted as part of the
61
-------
RI/FS, did not show a need for additional soils remediation. In
addition, both the public and State have indicated acceptance of
the selected remedy. Therefore, the selected remedy provides the
best balance among alternatives with respect to the criteria used
to evaluate remedies.
Because the selected remedy will result in hazardous substances
remaining onsite above health based levels (in the shallow ground
water), a review will be conducted within five years after
commencement of remedial action to ensure that the remedy continues
to provide adequate protection of human health and the environment.
The primary balancing criteria that weighed heaviest and
contributed most to the selection of Alternative 2 over the other
evaluated alternatives were the long-term effectiveness and
permanence criteria and cost criteria. All of the r .'oposed
alternatives, with the exception of No Action, could provide a
significant and adequate degree of reduction of toxicity, mobility,
or volume as well as short-term effectiveness and implementability.
Alternative 2 meets the remedial action objectives through natural
attenuation and should be as effective in the long term as the
active treatment alternatives since natural attenuation will result
in the lowering of contaminants of concern to the same levels as
would be achieved with active ground water treatment in
approximately the same time frame. Since the ground water
contamination is in a Class III aquifer, natural attenuation is
acceptable when ground water restoration is not warranted. In
addition, the selected remedy requires the close out of the Watt's
well, which is the closest pathway to the "150-foot" aquifer.
Finally, the selected remedy provides that contingency measures be
implemented if contaminant concentrations, or extent of
contamination increase over time. While the natural attenuation
remedy provides a similar degree of long-term effectiveness when
compared to the other alternatives, the estimated cost of the
natural attenuation alternative, which is $760,000, is
significantly lower than the estimated $2,220,000 - $16,000,000
costs associated with the other alternatives.
A more detailed description of the selected remedy follows. It
should be noted that certain engineering considerations of the
remedy may change during the remedial design.
Monitoring wells near the Waste Pit/Tank Area contamination plume,
and the french drain, will be tested for benzene, ethylbenzene,
toluene and xylene. In addition to sampling the monitoring wells,
water level readings will be collected from piezometers P-l and P-2
near the waste pit. The monitoring will be quarterly for the first
62
-------
year, semiannually for the next four years and annually thereafter.
The existing french drain will be maintained for possible future
activation in the event monitoring shows that natural attenuation
is not adequate.
Monitor wells near the Holding Pond contamination plume will also
be tested for benzene, ethylbenzene, toluene and xylene. The
monitoring will also be quarterly for the first year, semiannually
for the next four years and annually thereafter. An additional
monitoring well is recommended near the edge of the plume near
Interstate 10. This well is needed in order to monitor possible
plume migration beneath the Interstate.
In addition, the two Ascension Parish School Board wells (DOTD
Wells 179 and 427), located at the Dutchtown Middle School, should
be included in the monitoring program.
The monitoring program will detect any movement of the contaminant
plumes before any complete exposure pathway could be formed. The
ground water monitoring would monitor both vertical and horizontal
extent of the two ground water'plumes.
Contingency measures:
The remedial action objectives are to prevent human exposure to
contaminated ground water, prevent contamination of the underlying
150-foot drinking water aquifer, and restoration of contaminated
shallow ground water, based on its classification, for future use.
Since exposure to surface and subsurface soils at the site are not
expected to result in any excess risk/hazard to human health and
the environment under current and no action conditions, and since
no current or future exposure pathway was identified for the
contaminated shallow aquifer, there are no numerical cleanup
standards for ground water. The area of attainment is defined as
the entire area of the two plumes as defined by the existing
monitor wells. The two plumes are shown on Figure 4. The area of
attainment will be applied throughout the depth of the shallow
water-bearing unit (e.g. 0-14 feet). Based on the information
obtained during the remedial investigation, the feasibility study
and analysis of the seven remedial alternatives, EPA believes that
the alternative selected will achieve the remedial action
objectives. Ground water contamination may be especially
persistent in the immediate vicinity of the former sources (holding
pond, waste pit, storage tanks), where concentrations are
relatively high. The ability to achieve cleanup goals throughout
the area of attainment cannot be determined until the selected
remedial action has been implemented, and plume response monitored
63
-------
over time. If the selected remedy cannot meet the remedial action
objectives, at any or all of the monitoring points during
implementation, contingency measures and goals may replace the
selected remedy and goals. These contingency measures will be
protective of human health and the environment, and are technically
practicable under the corresponding circumstances.
To determine if contingency measures are necessary, the selected
alternative provides for ground water monitoring to determine if
natural attenuation is working to reduce the contamination level in
the ground water plumes, and to monitor whether the contamination
has migrated vertically or horizontally. If during the monitoring
of the shallow ground water (both vertically and horizontally),
contaminant concentrations increase 30 percent in any of the
onsite or offsite monitoring wells, the well which showed the
increase in concentration will be resampled. If the second
analysis confirms that there has been a 30 percent increase in
contaminant concentration, EPA may require implementation of any or
all of the following actions:
Installation of additional monitoring wells to determine
if the contamination is increasing in concentration or
migrating.
Increasing the frequency of sampling to assure that a
complete exposure pathway does not develop.
Construction of a containment measure such as a slurry
wall.
Implementation of a remedial action for treatment of
contaminated ground water which could include extraction
of contaminated ground water or in-situ treatment. The
remedial action could include any of the alternatives
described in this Record of Decision or other
alternatives not yet discussed.
X. STATUTORY DETERMINATIONS
EPA's primary responsibility at Superfund sites is to select
remedial actions that are protective of human health and the
environment. Section 121 of CERCLA also requires that the selected
remedial action for the site comply with applicable or relevant and
appropriate environmental standards established under Federal and
State environmental laws, unless a waiver is granted. The selected
remedy must also, be cost effective and utilize treatment or
64
-------
resource recovery technologies to the maximum extent practicable.
The statute also contains a preference for remedies that include
treatment as a principal element. The following sections discuss
how the selected remedy for the site meets the statutory
requirements.
Protection of Human Health and the Environment
The selected remedy protects human health and the environment by
reducing levels of contaminants through natural attenuation and
monitoring. Of all the alternatives evaluated for the contaminated
media at the site, the selected remedy provides the best, most cost
effective protection human health and the environment. No
unacceptable short-term risks will be caused by implementing this
remedy.
In order to protect human health and the environment, the
contaminated ground water will be monitored quarterly during the
first year, semiannually during the next four years, and annually
thereafter. If the ground water monitoring indicates that the
contamination plume is expanding either vertically or horizontally,
a contingency plan may be implemented. In addition, the closest
residential well, which presents a possible exposure pathway to the
150-foot aquifer, will be closed out.
Compliance With ARARs
Since the ground water in the contaminated shallow aquifer is
considered a Class III aquifer, remediation to .MCLs is not
required. In addition, since ground water will not be treated and
discharged to surface water, the NPDES, Federal and State water
quality requirements do not apply for the selected remedy. There
are no location-specific ARARs that are applicable or relevant and
appropriate for the site.
The State of Louisiana's Title 33 Part V (Hazardous Waste and
Hazardous Materials Subpart 1, Department of Environmental Quality-
Hazardous Waste Chapter 33. Ground Water Protection) establishes
regulations dealing with the monitoring, control, remediation,
concentration, well installation, well abandonment, plugging of
borings, point of compliance, and other requirements concerning
hazardous constituents in ground water.
Cost Effectiveness
EPA believes that the selected remedy is cost effective in
preventing human exposure to contaminate ground water and
65
-------
preventing contamination of the underlying 150-foot drinking water
aquifer. Section 300.430(f)(ii)(D) of the NCP requires EPA to
determine cost effectiveness by evaluating the following three of
the five balancing criteria to determine overall effectiveness:
long-term effectiveness and permanence, reduction of toxicity,
mobility or volume through treatment/ and short-term effectiveness.
Overall effectiveness is then compared to cost to ensure that the
remedy is cost effective.
The estimated present worth cost for the selected remedy is
$760,000. This alternative costs almost $1,500,000 less than the
least expensive ground water extraction alternative, yet the
selected remedy is as effective and protective of human health and
the environment.
Utilization of Permanent Solutions and Treatment or Resource
Recovery Technologies to the Maximum Extent Practicable
EPA believes the selected remedy represents the maximum extent to
which permanent solutions and treatment/resource recovery
technologies can be utilized in a cost effective manner for the
site.
Of those alternatives that are protective of human health and the
environment, and comply with ARARs, EPA has determined that the
selected remedy provides the best balance of trade-offs in terms of
long-term effectiveness and permanence, reduction in toxicity,
mobility, or volume achieved through treatment, short-term
effectiveness, implementability, costs, the statutory preference
for treatment as a principal element, and taking into consideration
State and community acceptance.
Preference for Treatment as a Principal Element
Treatment of the contaminated ground water was not found to be
required or warranted at this time based on the contaminated
aquifer's classification as a Class III aquifer, and the lack of an
exposure pathway between the aquifer and any potential receptor
population. Although treatment of ground water contamination is
not warranted at this time, the remedial action for this site does
meet the statutory preference for treatment as a principal element
of the remedy. To address the source of contamination and remove
the principal threat to human health and the environment, an
expedited response action (EPA) was conducted at the site. The ERA
included offsite incineration of wastes from several sources,
66'
-------
treatment of stormwater, and treatment of contaminated soils
associated with the sources.
Because the selected alternative will result in hazardous
substances remaining onsite above health based levels, a review
will be conducted within five years after commencement of the
remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
XI. DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan was released for public comment in October 1993.
The Proposed Plan identified Alternative 2, natural attenuation
with monitoring as the preferred alternative for the site. EPA
reviewed all written and verbal comments submitted during the
public comment period. Upon review of these comments, no
significant changes to the remedy, as originally identified in the
proposed plan, were necessary.
67
-------
APPENDIX 1
RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
The Responsiveness Summary has been prepared to provide written
responses to comments submitted regarding the Proposed Plan of
Action at the site. The summary is divided into two sections.
Section I: Background of Community Involvement and Concerns. This
section provides a brief history of community interest and concerns
raised during the remedial planning activities at the site.
Section II: Summary of Manor Comments Received. The comments
(both oral and written) are summarized and EPA's responses
provided.
J. Background of Comip""T*y Involvement and Concerns
Interest in the site has been moderate due in part to the close
proximity of the site to area residents. Following completion of
the Expedited Response Action in 1991, public interest in the site
has not been as great.
The RI/FS Reports and Proposed Plan for the site were released to
the Public on October 15, 1993. The documents were made available
to the public in the Administrative Record File in the following
information repositories: Ascension Parish Library, Gonzales
Branch, Gonzales, Louisiana; Louisiana Department of Environmental
Quality, Baton Rouge, Louisiana; and the U.S. Environmental
Protection Agency Region 6 Library, Dallas, Texas. A summary of
the Proposed Plan and the notice of availability of the these
documents and Administrative Record File was published in the Baton
Rouge Daily Advocate and Gonzales Weekly. In addition, a fact
sheet summarizing the Proposed Plan of Action for the site was
mailed to the site mailing list on October 15, 1993. An open house
to present the findings of the Proposed Plan of Action was held on
October 14, 1993 at the Dutchtown Primary School.
II.
The EPA held a public comment period regarding the RI/FS, Proposed
Plan and Administrative Record from October 15, 1993, through
November 13, 1993. During this public comment period, a formal
public meeting was held on October 28, 1993, at the Dutchtown
Primary School. Comments and questions received during the comment
period or during the public meeting and EPA's responses are
summarized below.
-------
Comments And Questions Received During Public Meeting
(1) The president of the Ascension Parish Residents Against Toxic
Pollution wanted to know the depth of the deepest core
sampling that took place, the number of deep core samples and
the results of the sampling.
EPA Response: The deepest core sampling that took place at
the site is 30 feet below ground surface. Four deep core
samples were drilled during the Remedial Investigation, and no
contamination was detected in any of the samples.
(2) A local resident noted that the french drain which was
installed around May 1991 is not being pumped any longer and
wanted to know why the French Drain was not being pumped. In
addition, the resident noted that EPA's preferred alternative
does not mention the use of the existing french drain and
wanted to know if pumping of the french drain was no longer
necessary or not worth the expense.
EPA Response: The PRPs and EPA agreed to modify the ERA
workplan for the installation of a french drain as an interim
measure during the completion of the RI/FS to address 'the
visibly contaminated ground water that was observed to be
seeping into the waste pit. Following the completion of the
Remedial Investigation, pumping of the french drain was
stopped.
Since the remedial action objectives for the ground water are
to prevent human exposure to contaminated ground water and
prevent contamination of the 150 foot drinking water aquifer,
the selected remedy meets these goals through natural
attenuation and monitoring. In addition, there is a
contingency plan in case the natural attenuation is not
effective in reducing the levels and extent of contamination.
A possible contingency action could be to go-out immediately
and begin pumping the currently installed french drain.
(3) A student from a local university requested a discussion on
EPA's justification for selection of natural attenuation as
the preferred alternative.
EPA Response: The remedial action objectives for ground water
are to prevent human exposure to contaminated ground water and
to prevent exceeding Maximum Contaminant Levels (MCLs) for the
contaminants of concern in the 150 foot drinking water
aquifer.
-------
Natural attenuation meets these goals because, by the time any
of the contaminants of concern reach the 150 foot aquifer,
their concentrations will be below MCLs. Also, in evaluating
the various alternatives for the site, the primary balancing
criteria that weighed heaviest and contributed most to the
selection of natural attenuation over the other evaluated
alternatives were the long-term effectiveness and permanence
criteria and cost criteria. All of the proposed alternatives,
with the exception of No Action, could provide a significant
and adequate degree of reduction of toxicity, mobility, or
volume as well as short-term effectiveness and
implementability.
The selected remedy (natural attenuation) should be as
effective in the long term as the active treatment
alternatives since natural attenuation will result in the
lowering of contaminants of concern to the same levels as
would be achieved with active ground water treatment. The
ground water contamination is in a Class III aquifer, and this
ground water is not suitable as a drinking water source
because the yield is insufficient. Natural attenuation is
acceptable since ground water restoration of the Class III
aquifer is not warranted at this time, and contamination is
not expected to migrate beyond the Class III aquifer to the
150 foot aquifer.
Finally, the selected remedy provides that contingency
measures be implemented if contaminant concentration, or
extent of contamination increase over time. While the natural
attenuation remedy provides a similar degree of long-term
effectiveness when compared to the ..other alternatives, the
estimated cost of the natural attenuation alternative, which
is $760,000, is significantly lower than the estimated
$2,200,000 to $16,000,000 costs associated with the other
alternatives.
(4) One commentor wanted to know if there would be a risk to
people who could eventually hunt animals that could inhabit
the site once the site grows up with vegetation.
EPA Response: The operation and maintenance (O & M) plan will
require that the site be mowed to prevent overgrowth and that
a fence be maintained around the site. These actions will
prevent animals from wanting to reside on the site. In
addition, there is a clay cap over the areas that were treated
during the ERA which will also be checked as part of the O&M
plan. The clay caps will prevent animals from being exposed
-------
to any type of remaining contaminants. Although an assessment
of the risk associated with people hunting animals that might
inhabit the site was not performed, the O & M actions and clay
caps should prevent animals from being exposed to any
contaminants, thereby minimizing risks to people hunting
animals.
(5) An individual wanted to know how long it will take for the
chemicals to break down by natural attenuation/ and how long
will the monitoring program last.
EPA Response: The concentrations of chemicals in the ground
water will decrease over time in at least two ways. As the
ground water migrates, the contamination becomes more dilute
from mixing with other ground water. Chemicals in ground
water may also be physically broken down by chemical or
biological processes. The ground water contamination was
modeled to simulate the vertical movement of benzene,
ethylbenzene and styrene, and to evaluate their potential for
impacting the aquifer in which water wells are installed in
the area. The shallowest drinking water aquifer is at an
approximate depth of 150 feet. A series of ground water
models were run for time periods of 20, 50, and 100 years.
The model indicates that, after 20 years, benzene would
migrate to 28 feet below the former source at the surface,
ethylbenzene to 19 feet, and styrene to 14.5 feet before their
concentrations decreased to their respective Maximum
Contaminant Level. No specific modeling was conducted to
evaluate the lateral movement of the ground water plumes. The
remedy calls for 30 years of monitoring to take place.
Monitoring will be quarterly during the first year,
semiannually during years two through five and annually
thereafter up to year 30.
Comments And Questions Received During Public Comment Period
(1) The commentor stated that based on the information provided in
the Proposed Plan of Action, it appears that the proper remedy
has been selected to a degree. The remedy should include the
reduction of all hazardous waste levels onsite to a level
below health based levels. By doing so, the remedial action
will ensure adequate protection of human health and the
environment.
-------
EPA Response: The risk assessment which was conducted
evaluated dermal, ingestion and inhalation exposure to current
and future area residents as well as site trespassers from
contaminants present in surface soils. Calculated results of
the risk assessment showed that all excess cancer risks and
hazard indices were within limits acceptable by EPA.
Therefore, exposure to site contaminants is expected to result
in no unacceptable risk or hazard to human health under
current or no action conditions. In addition, an extensive ERA
was conducted at the site prior to the RI/FS. During the ERA,
the contents of the holding pond, waste oil pit, and above
ground storage tanks were processed and sent offsite for
incineration, water from the pits and tank cleaning was
treated and disposed, and the soils under the waste pits and
holding pond were excavated, treated to concentrations less
than 4 ppm, put back in place, and capped.
To evaluate whether any chemical of potential concern for
onsite surface soils could exceed EPA's acceptable excess
lifetime cancer risk or non-carcinogenic risk, a comparative
analysis was performed. The comparative analysis evaluated
target remediation goals for potential chemicals of concern in
onsite soils for residential land use, versus the
concentrations of onsite soil contaminants identified-during
the RI* The target remediation goals were calculated for
excess cancer risks of 1 x 10"* (1 in ten thousand) and 1 x
10'6 (1 in one million), and a hazard index of 1 (a hazard
index of less than 1 means that no adverse non-cancer health
effects are expected) . Table 11 of the ROD shows that
concentrations of the potential chemicals of concern for
onsite surface soil fall within the target remediation goals
calculated for EPAfs acceptable excess cancer risk range of 1
x 10.~4 to 1 x 10"6, and are below the non-carcinogenic hazard
index of 1.
The shallow ground water, which has contaminants above health
based levels, did not represent a complete exposure pathway
since: 1) no residential wells currently use this zone in the
vicinity of the site, and 2) this zone is not expected to be
used in the future due to its insufficient yield. In order to
prevent human exposure to contaminated ground water and
contamination of the underlying 150-foot drinking water
aquifer, the selected remedy requires extensive ground water
monitoring to ensure contaminants do not migrate laterally or
vertically. In addition, the residential well on the Watt's
property (which is the closest water well in the area) will be
closed out and a replacement well drilled.
-------
APPENDIX 2
ADMINISTRATIVE RECORD INDEX
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003748 - 003749
03/31/89
2
Office of Emergency and Remedial Response
U.S. EPA - Washington, D.C.
U.S. EPA Region 6 Superfund Site Files
Risk Assessment Guidance - Interim Final
"Risk Assessment Guidance for Superfund: Volume 2 -
Environmental Evaluation Manual"; (EPA/540/1-89/001) (This
document may be reviewed at U.S. EPA Region 6)
003750 - 0037S1
12/31/89
2
Office of Emergency and Remedial Response
U.S. EPA - Washington, D.C.
U.S. EPA Region 6 Superfund Site Files
Risk Assessment Guidance for Superfund - Interim
Volume 1 - "Human Health Evaluation Manual, (Part C, Risk
Evaluation of Remedial Alternatives)"; (Publication
9285.7-01C) (This document may be reviewed at U.S. EPA Region
6)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003752 - 003753
12/31/89
2
Office of Emergency and Remedial Response
U.S. EPA - Washington, D.C.
U.S. EPA Region 6 Superfund Site Files
Risk Assessment Guidance - Interim Final
"Risk Assessment Guidance for Superfund: Volume 1 - Human
Health Evaluation Manual (Part A) "; (EPA/540/1-89/002)
(This document may be reviewed at U.S. EPA Region 6)
003754 - 003755
12/31/89
2
Office of Emergency and Remedial Respon'se
U.S. EPA - Washington, D.C.
U.S. EPA Region 6 Superfund Site Files
Risk Assessment Guidance for Superfund - Interim
Volume 1 - "Human Health Evaluation Manual (Part B,
Development of Risk-based Preliminary Remediation Goals)";
(Publication 9285.7-01B) (This document may be reviewed at
U.S. EPA Region 6)
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADDENDUM 1
DUTCHTOWN SUPERFUND SITE
LAD 980879449
003755 - 003766
11/14/90
11
Thomas B. Keyse, S. Russell Killibrew, Richard D. Karkkainen
Woodward-Clyde Consultants
Brent Truskowski, Remedial Investigation/Feasibility Study
(RI/FS) Project Coordinator, U.S. EPA Region 6
Progress Report
Site activities for the months of October and November 1990;
including sampling results
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003767 - 003767
11/28/90
1
Thomas B. Keyse, Richard D. Karkkainen
Woodward-Clyde Consultants
Brent Truskowski, RI/FS Project Coordinator, U.S. EPA Region 6
Correspondence
RE: Notification that Woodward-Clyde Consultants will sample
the groundwater monitoring wells 12/05/90 - 12/07/90
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003768 - 003783
12/14/90
16
Thomas B. Keyse, S. Russell Killebrew, Richard D. Karkkainen
Woodward-Clyde Consultants
Brent Truskowski, RI/FS Project Coordinator, U.S. EPA Region 6
Progress Report
Site activities for the months of November and December 1990;
including sampling results
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003784 - 003785
12/21/90
2
Thomas B. Keyse, Richard D. Karkkainen
Woodward-Clyde Consultants
Cathy Gilmore, RI/FS Project Coordinator, U.S. EPA Region 6
Correspondence
RE: Notification of Soil Sampling and Soil Boring Activities
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
003786 - 003787
01/11/91
2
Thomas B. Keyse, Richard D. Karkkainen
Woodward-Clyde Consultants
Cathy Gilmore, RI/FS Project Coordinator, U.S. EPA Region 6
Correspondence
RE: Notification that several days of heavy rain and resultant
high water at the site have prevented WCC from completing the
soil borings
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003788 - 003790
01/17/91
3
Thomas B. Keyse, Richard O. Karkkainen
Woodward-Clyde Consultants
Cathy Gilmore, RI/FS Project Coordinator, U.S. EPA Region 6
Correspondence
RE: Confirmation of matters discussed regarding field sampling
program about Phase I of the RI/FS
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003791 - 003792
01/22/91
2
Cathy Gilmore, RI/FS Project Coordinator
U.S. EPA Region 6
Richard D. Karkkainen, Vice President, Woodward-Clyde
Consultants
Corre spondence
RE: Scheduling for surface soil sampling
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003793 - 003793
02/06/91
1
Amanda M. Sullivan, Richard D. Karkkainen
Woodward-Clyde Consultants
Cathy Gilmore, RI/FS Project Coordinator, U.S. EPA Region 6
Corre spondence
RE: Notification of Woodward-Clyde Consultants' personnel
change for the RI/FS
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADDENDUM 1
DUTCHTOWN SUPERFUND SITE
LAD 980879449
003794 003838
02/11/91
45
S. Russell Killebrew, Charlie Caplinger
Woodward-Clyde Consultants
Brent Truskowski, RI/FS Project Coordinator, U.S. EPA Region 6
Sampling Analysis
Revised Field Analysis Sampling Plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003839 - 003843
02/14/91
5
Amanda M. Sullivan, S. Russell Killebrew, Richard D.
Karkkainen
Woodward-Clyde Consultants
Cathy Gilmore, RI/FS Project Coordinator, U.S. EPA Region 6
Progress Report
Site activities for the months of January and February 1991
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003844 - 003901
02/15/91
58
S. Russell. Killebrew, Charles Caplinger
Woodward-Clyde Consultants
Brent Truskowski, RI/FS Project Coordinator, U.S. EPA Region 6
Correspondence and Attachment
RE: Revisions to Volume I of the Field Analysis Sampling Plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003902 - 003904
02/21/91
3
Amanda M. Sullivan, S. Russell Killebrew, Richard D.
Karkkainen
Woodward-Clyde Consultants
Cathy D. Gilmore, RI/FS Project Coordinator, U.S. EPA Region 6
Correspondence and Attachment
RE: Revised schedule due to the staging of the boring program
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
003905 - 003910
02/21/91
6
Amanda M. Sullivan, Richard D. Karkkainen
Woodward-Clyde Consultants
Cathy Gilmore, RI/FS Project Coordinator, U.S. EPA Region 6
Correspondence
RE; Proposed Offset Boring Program/Surface Soil Sampling
Program
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003911 - 003911
03/07/91
1
Cathy Gilmore, RI/FS Project Coordinator
U.S. EPA Region 6
Amanda M. Sullivan, Woodward-Clyde Consultants
Correspondence
RE: Request for a complete schedule for the Dutchtown RI tasks
for Phase I
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT. TYPE:
DOCUMENT TITLE:
003912 - 003914
03/13/91
3
S. Russell Killebrew, Richard D. Karkkainen
Woodward-Clyde Consultants
Brent Truskowski, RI/FS Project Coordinator, U.S. EPA Region 6
Corre spondence
RE: Dutchtown Expedited Response Action (ERA) Work Plan
Addition .
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003915 - 003926
03/15/91
12
Amanda M. Sullivan, S. Russell Killebrew, Richard D.
Karkkainen
Woodward-Clyde Consultants
Cathy Gilmore, RI/FS Project Coordinator, U.S. EPA Region 6
Corre spondence
RE: Schedule for RI/FS and Phase I & II Activities
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
003927 - 004155
03/15/91
229
Amanda M. Sullivan, S. Russell KiHebrew, Richard D.
Karkkainen
Woodward-Clyde Consultants
Brent Truskowski, Dutchtown ERA Manager, and Cathy Gilmore,
Dutchtown RI/FS Manager, U.S. EPA Region 6
Progress Report
Site activities for the months of February and March 1991;
including sampling results from ERA and RI/FS
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT: .
DOCUMENT TYPE:
DOCUMENT TITLE:
004156 - 004161
03/18/91
6
Amanda M. Sullivan, Richard D. Karkkainen
Woodward-Clyde Consultants
Cathy Gilmore, RI/FS Project Coordinator, U.S. EPA Region 6
Correspondence
RE: Revised Proposed Offset Boring Plan/Surface Soil Sampling
Program
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004162 - 004162
03/21/91
1
Cathy Gilmore, RI/FS Project Coordinator
U.S. EPA Region 6
Amanda M. Sullivan, Woodward-Clyde Consultants
Corre spondence
Re: Revised RI/FS schedule
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
CERCLA Enforcement Division
004163 - 004218
03/22/91
56
Sally Mansback, Acting Director,
U.S. EPA - Washington, D.C.
Remedial Administrative Record Coordinators - Regions I-X
CERCLA Administrative Record Compendium Guidance
"CERCLA Administrative Record: First Update of the Compendium
of Documents Used for Selecting CERCLA Response Actions"
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
004219 - 004220
04/01/91
2
Cathy Gilmore, RI/FS Project Coordinator
U.S. EPA Region 6
Amanda M. Sullivan, Woodward-Clyde Consultants
Corre spondence
RE: Comments on the Revised Proposed Offset Boring Plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004221 - 004222
04/01/91
2
Amanda M. Sullivan, Richard D. Karkkainen
Woodward-Clyde Consultants
Cathy Gilmore, RI/FS Project Coordinator, U.S. EPA Region 6
Corre spondence
RE: Revised Proposed Offset Boring Program/Surface Soil
Sampling Program
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004223 - 004223
04/03/91
1
Amanda M. Sullivan, Richard D. Karkkainen
Woodward-Clyde Consultants
Cathy Gilmore, RI/FS Project Coordinator, U.S. EPA Region 6
Correspondence
RE: Notification that WCC will begin the offset boring
sampling activities at the site on 04/08/91
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004224 - 004439
04/15/91
216
Amanda M. Sullivan, S. Russell KiHebrew, Richard D.
Karkkainen
Woodward'Clyde Consultants
Brent Truskowski, Dutchtown ERA Manager, Cathy Gilmore,
Dutchtown RI/FS Manager, U.S. EPA Region 6
Progress Report
Site activities for the month of March 1991; including
sampling results from ERA and RI/FS
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NDMBER:
DOTCHTOWN SUPERFUND SITE
LAD 980879449
DOCDMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004440 - 004441
04/22/91
2
Frank S. Craig III
Breazeale, Sachse & Wilson, Attorneys at Law
Cathy Gilmore, RI/FS Project Coordinator, U.S. EPA Region 6
Correspondence
Re: Impact of combining batches of water by manifolding
smaller storage tanks together into larger tanks on sampling
and testing requirement under consent decree
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004442 - 004443
05/02/91
2
Cathy Gilmore, RI/FS Project Coordinator
U.S. EPA Region 6
Russell Killebrew, WCC
Correspondence
Re: Areas of concern regarding the air monitoring plans for
the removal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004444 - 004924
05/15/91
481
Amanda Sullivan, S. Russell Killebrew, P.E., Richard D.
Karkkainen
Woodward-Clyde Consultants
Cathy Gilmore, RI/FS Project Coordinator, U.S. EPA Region 6
Progress Report
Site activities for the month of May 1991 including results of
ERA and RI/FS sampling
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004925 - 004937
05/20/91
13
Richard E. Berkley, Research Chemist, Monitoring Methods
Research Section
U.S. EPA - Atmospheric Research and Exposure Assessment
Laboratory - North Carolina
Mark Hansen, U.S. EPA Region 6
Memorandum
RE: Canister Data from Superfund Sites in Region 6
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
004938 - 004938
06/05/91
1
Cathy Gilmore, RPM
U.S. EPA Region 6
Amanda Sullivan, WCC
Correspondence
Locations for fifty (50)
foot offset samplings are approved
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004939 - 004939
06/13/91
1
Amanda M. Sullivan, Richard D. Karkkainen
Woodward-Clyde Consultants
Cathy Gilmore, Dutchtown RI/FS Manager, U.S. EPA Region 6
Correspondence
Notification of second round of offset boring sampling;
required easements from adjacent properties have been
acquired; plan to begin work 06/24/91 - projected completion
date is 06/27/91
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:'
004940 - 004940
06/14/91
1
S. Russell Killebrew, Richard D. Karkkainen
Woodward-Clyde Consultants
Cathy Gilmore, Dutchtown RI/FS Manager, U.S. EPA Region 6
Corre spondence
Re: Mr. Russell Killebrew will replace Mr. Richard Karkkainen
as Project Coordinator for both the Dutchtown ERA and RI/FS
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004941 - 005840
06/15/91
900
Amanda Sullivan
Woodward-Clyde Consultants
Cathy Gilmore, Dutchtown RI/FS Manager, U.S. EPA Region 6
Monthly Progress Report
Summary of site activities from 05/30/91 through 06/14/91
including sampling results from ERA and RI/FS
-------
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
DUTCHTOWN SUPERFUND SITE
LAD 980879449
005841 - 005861
06/19/91
21
Cathy Gilmore, RPM
U.S. EPA Region 6
Ms. Faye Watts, Resident near the site
Correspondence
RE: Sampling results near the resident's water well
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
005862 - 005863
06/24/91
2
William R. Hurdle/ Senior Scientist, S. Russell KiHebrew
Woodward-Clyde Consultants
Cathy Gilmore, RPM, D..S. EPA Region 6
Correspondence
RE: Substitution of a belt press for the centrifuge in
response to a materials handling problem
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
005864 - 005864
07/03/91
1
Amanda M. Sullivan, S. Russell KiHebrew
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence
Notification that WCC will begin the ERA verification pond
sampling activities on 07/11/91
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
005865 - 005866
07/10/91
2
Cathy Gilmore, Dutchtown RI/FS Manager
U.S. EPA Region 6
Russell Ki Hebrew, Woodward-Clyde Consultants
Correspondence
EPA recommends treated soil samples be taken prior to placing
the treated soils in the cells to dry
10
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFDND SITE
LAD 980879449
005867 - 005868
07/11/91
2
William R. Hurdle, Senior Scientist, S. Russell KiHebrew
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence
RE: Air drying the treated soil does not deviate from the
sequence of operations detailed in the Work Plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
005869 - 005958
07/15/91
90
Amanda M. Sullivan, S. Russell Killebrew, Richard D.
Karkkainen
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Progress Report
Report of progress during the period from 06/10/91 through
07/05/91; including sampling results from ERA
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
005959 - 005960
08/01/91
2
S. Russell Killebrew
Woodward-Clyde Consultants
Cathy Gilmore, -RPM, U.S. EPA Region 6
Correspondence
RE: Summary of the sampling done for process control during
soil treatment operations
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
005961 - 005965
08/02/91
5
William R. Hurdle, Senior Scientist, S. Russell Killebrew,
Senior Project Engineer
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence and Attachment
Modification to the Work Plan to add stabilization with fly
ash as an additional soil treatment step
11
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
005966 - 005967
08/08/91
2
Cathy Gilmore, RPM
U.S. EPA Region 6
S. Russell Killebrew, Woodward-Clyde Consultants
Correspondence
RE: Modification to the Work Plan for the Dutchtown ERA
includes the stabilization of the washed soil with fly ash
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
005968 - 005970
08/12/91 l'
3
William R. Hurdle, Senior Scientist, S. Russell Killebrew,
Senior Project Engineer
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence and Attachment
Revised page three (3) of the modification to the Work Plan to
add stabilization with fly ash as an additional soil treatment
step
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
005971 - 005977
08/14/91
7
William R. Hurdle, Senior Scientist, S. Russell Killebrew,
Senior Project Engineer
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence and Attachment
Proposed modification to the ERA Work Plan to include
installation of a french drain
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
005978 -
08/15/91
220
Amanda M.
Engineer,
006197
Sullivan, S. Russell Killebrew, Senior Project
Richard D. Karkkainen
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Progress Report
Progress report for the months of July and August 1991;
including sampling results from ERA
12
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
006198 - 006198
08/20/91
1
Amanda M. Sullivan, S. Russell KiHebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Corre spondence
Notification that WCC will begin the ERA verification sampling
activities
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006199 - 006202
08/29/91
4
Amanda M. Sullivan, S. Russell KiHebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence w/Attachments
Additional offset borings from #226 and #227 are required at
the locations noted in Attachment 2
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006203 - 006400
08/29/91
198
William R. Hurdle, Senior Staff Scientist, S. Russell
Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore', RPM, U.S. EPA Region 6
Correspondence w/Attached Report
Re: Request for approval to backfill excavations;
verification samples for treated soils
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006401 - 006401
09/04/91
1
Cathy Gilmore, RI/FS Project Coordinator
U.S. EPA Region 6
S. Russell Killebrew, P.E., WCC
Corre spondence
Request to begin backfilling the pond areas approved
13
-------
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
DUTCHTOWN SUPERFUND SITE
LAD 980879449
006402 006590
09/13/91
189
Amanda M. Sullivan, S. Russell KiHebrew, P.E., Richard D.
Karkkainen
Woodward-Clyde Consultants
Cathy Gilmore, Dutchtown RI/FS Manager, U.S. EPA Region 6
Progress Report
Progress report for the months of August and September 1991;
including sampling results from ERA and RI/FS
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006591 - 006591
10/01/91
1
Cathy Gilmore, RPM, U.S. EPA Region 6
U.S. EPA Region 6
Amanda M. Sullivan, Woodward-Clyde Consultants
Correspondence
Response to 08/29/91 letter concerning the additional offset
borings and the 03/18/91 letter concerning the surface soil
sampling
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006592 - 006592
10/03/91
1
Cathy Gilmore, RPM
U.S. EPA Region 6
Amanda M. Sullivan, Woodward-Clyde Consultants
Correspondence
Discussion concerning the Agency's decision that pesticides
and PCS analyses should continue for entirety of the first
phase of sampling
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006593 - 006593
10/07/91
1
Amanda M. Sullivan, S. Russell KiHebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, Dutchtown RI/FS Manager, U.S. EPA Region 6
Correspondence
WCC will begin the surface soil sampling activities on
10/14/91
14
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
006594 - 006656
10/15/91
63
Amanda M. Sullivan, S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RI/FS Manager, U.S. EPA Region 6
Progress Report
Progress report for the months of September and October 1991;
including sampling results from ERA
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006657 006658
11/07/91
2
U.S. EPA Region 6
U.S. EPA Region 6
General Public
Superfund Site Update
Dutchtown Superfund Site Open House Thursday, November 7,
1991, 5:30 to 8:30 p.m. at the Dutchtown Elementary School
Cafeteria
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006659 * 006669
11/13/91
11
Amanda M. Sullivan
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Memorandum
Re: Preliminary Well Location Memorandum for the RI/FS
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006670 - 006685
11/15/91
16
Amanda M. Sullivan, S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RI/FS Manager, U.S. EPA Region 6
Progress Report
Progress report for the months of October and November 1991;
including final verification results
15
-------
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
DUTCHTOWN SUPERFUND SITE
LAD 980879449
006686 006689
12/13/91
4
Amanda M. Sullivan, S. Russell KiHebrew, P.E.
Woodward-Clyde Consultants
Cathy D. Gilmbre, RPM, U.S. EPA Region 6
Progress Report
Progress report for the months of November and December 1991
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006690 - 006705
12/24/91
16
Amanda M. Sullivan
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence w/Attachments
Final Well Location Memorandum for the Dutchtown RI/FS
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006706 - 006706
12/31/91
1
Cathy Gilmore, RPM
U.S. EPA Region 6
Amanda M. Sullivan, Woodward-Clyde Consultants
Corre spondence
Agency approves of the Final Well Location Memorandum prepared
by WCC dated 12/24/91
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006707 - 006707
01/10/92
1
Amanda M. Sullivan, S. Russell KiHebrew, P.E.
Woodward-Clyde Consultants
Cathy D. Gilmore, RPM, U.S. EPA Region 6
Correspondence
Notification of Well Installation/Sampling for the RI/FS
16
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
006708 - 006710
01/14/92
3
Amanda M. Sullivan, S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Progress Report
Progress report regarding December 1991 activities
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006711 - 006713
01/23/92
3
S. Russell Killebrew, P.E., Brad Droy
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence
Summary of topics discussed at the meeting held on 01/15/92
concerning the Dutchtown Risk Assessment
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006714 - 006715
02/06/92
2
Cathy Gilmore, RPM
U.S. EPA Region 6
Woodward-Clyde Consultants
Correspondence
Agency's comments on Woodward-Clyde Consultants' 01/23/92
letter regarding Site Risk Assessment
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006716 - 006718
02/14/92
3
Amanda M. Sullivan, S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Progress Report
Progress report regarding actions taken during January 1992
17
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
006719 - 006751
03/03/92
33
S. Russell Killebrew, P.E., Amanda M. Sullivan
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S..EPA Region 6
Corre spondence
Request that Rollins Environmental Services of Louisiana be
added to the list of facilities authorized to receive waste
from the Dutchtown site
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT. TYPE:
DOCUMENT TITLE:
006752 - 006753
03/10/92
2
S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Faxed Transmittal
Submittal of the analytical data on the water from the French
Drain
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006754 - 006754
03/13/92
1
Amanda M. Sullivan, S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence
Notice to Agency that slug tests will begin on the newly
installed monitor wells on 03/25/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006755 - 006757
03/13/92
3
Amanda M. Sullivan, S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Progress Report
Progress report regarding actions taken during Februrary 1992
18
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
006758 - 006769
03/17/92
12
S. Russell Killebrew, P.E., Amanda M. Sullivan
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Corre spondence
Re: Sample results from french drain
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006770 - 006771
04/13/92
2
S. Russell Killebrew, P.E., Denise Radaich
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Corre spondence
Report of a groundwater spill from the French drain
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006772 - 006824
04/14/92
53
Amanda'M. Sullivan, S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Progress Report
Progress report regarding actions taken during March 1992;
including results of sampling activities.
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006825 - 006826
04/28/92
2
S. Russell Killebrew, P.E., Amanda M.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence and Attachment
Addendum to April 1992 Monthly Report
Sullivan
19
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
006827 - 006839
05/12/92
13
S. Russell Killebrew, P.E., William R. Hurdle
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence and Attachment
Sampling plan to evaluate nature and extent of groundwater
spill recovered from french drain
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006840 - 006849
05/13/92
10
S. Russell Killebrew, P.E., Brad Droy, Ph.D.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence w/Attachments
Re: U.S. EPA and Woodward-Clyde Consultants meeting to
discuss risk assessment
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT: .
DOCUMENT TYPE:
DOCUMENT TITLE:
006850 - 006866
05/15/92
17
Amanda M. Sullivan, S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Progress Report
Progress report regarding activities for the month of April
1992; including sampling results from ground water recovered
from french drain
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006867 - 006867
05/27/92
1
S. Russell Killebrew, P.E., William R. Hurdle
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence
Acknowledgment of receipt of EPA approval for sampling plan
for area potentially impacted by french drain spill
20
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
006868 - 006870
06/15/92
3
Amanda M. Sullivan, S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Progress Report
Progress report regarding activities for May 1992
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006871 - 006871
06/29/92
1
Cathy Gilmore, RPM
U.S. EPA Region 6
S. Russell Killebrew, P.E., Woodward-Clyde Consultants
Corre spondence
Re: Agency approval of the Memorandum on Toxicological and
Epidemiological Studies
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006872 - 006889
07/02/92
18
S. Russell Killebrew, P.E., Charles A. Caplinger
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence and Attachments
Submittal of the Candidate Technologies and Literature Survey
Memorandum
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006890 - 006890
07/04/92
1
S. Russell Killebrew, P.E., Amanda M. Sullivan
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Transmittal Letter
Submittal of the Draft Dutchtown RI/FS Report; Draft Report
not included in record
21
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADDENDUM 1
DUTCHTOWN SUPERFUND SITE
LAD 980879449
006891 - 006892
07/10/92
2
U.S. EPA Region 6
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Superfund Fact Sheet
Re: Grant information
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006893 - 006895
07/17/92
3
Amanda M. Sullivan, S. Russell KiHebrew, P.E.
Woodward-Clyde Consultant s
Cathy Gilmore, RPM, U:S. EPA Region 6
Progress Report
Progress report regarding activities for June and July 1992
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006896 - 006901
07/30/92
6
David O'Brien
Unspecified
Amanda M. Sullivan, Woodward-Clyde Consultants
Memorandum
Analytical Data Review of Natex, Gulf South Environmental
Laboratory, Episode JNO, Dutchtown RI/FS, Soil Samples (spill)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006902 - 006916
08/04/92
15
S. Russell KiHebrew, P.E., Amanda M. Sullivan
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence and Attachment
Validated results of the soil sampling conducted in the area
of the french drain following the spill of recovered
groundwater
22
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
006917 - 006919
08/14/92
3
Amanda M. Sullivan, S. Russell Killebrev, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Progress Report
Progress report regarding actions for July 1992
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006920 - 006926
08/18/92
7
Jon Rauscher, Ph.D., Toxicologist, Texas Remedy Section
U.S. EPA Region 6
Donald Williams, Section Chief, Texas Remedy Section, U.S. EPA
Region 6
Memorandum
Re: Central Tendency and RME Exposure Parameters
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
'DOCUMENT TYPE:
DOCUMENT TITLE:
006927 - 006928
08/19/92
2
Cathy Gilmore, RPM
U.S. EPA Region 6
S. Russell Killebrew, P.E., Woodward-Clyde Consultants
Corre spondence
Submittal of the Agency's comments on its review of the
Candidate Technologies and Literature Survey Memorandum
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006929 - 006940
08/19/92
12
Cathy Gilmore, RPM
U.S. EPA Region 6
S. Russell Killebrew, P.E., Woodward-Clyde Consultants
Correspondence w/Attached Comments
Submittal of the Agency's comments on the Draft RI and Risk
Assessment
23
-------
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
DUTCHTOWN SUPERFUND SITE
LAD 980879449
006941 - 006944
08/28/92
4
Tim B. Knight, Program Manager, Inactive and Abandoned Sites
Division
Louisiana Department of Environmental Quality (LDEQ)
S. Russell KiHebrew, P.E., Woodward-Clyde Consultants
Correspondence
Submittal of LDEQ's comments on the Draft RI and Risk
Assessment
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006945 - 006945
09/01/92
. 1
Tim B. Knight, Program Manager
LDEQ
S. Russell Killebrew, P.E., Woodward-Clyde Consultants
Correspondence
LDEQ's review of correspondence sent by Woodward-Clyde
Consultants to EPA Region 6 concerning the RI/FS process
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006946 - 006946
09/11/92
1
Cheryl Warren and S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Transmittal Letter
Submittal of the Draft Feasibility Study Report; draft report
not included in record
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006947 - 006949
09/15/92
3
Amanda M. Sullivan, S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Progress Report
Progress report regarding actions taken August 1992;
24
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
006950 - 006951
09/15/92
2
Denise Radaich and S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence w/o Attachments
Submittal of the revised RI Report that incorporates the
Agency's 08/19/92 comments; draft report not included in
record
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006952 - 006956
09/16/92
5
Denise Radaich, Staff Engineer, S. Russell Killebrew,
Senior Project Engineer
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence and Attachments
Tables inadvertently omitted from the RI Report
P.E.,
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006957 - 006959
09/22/92
3
Cathy Gilmore, RPM ;
U.S. EPA Region 6
Harold Ethridge, Administrator, Inactive and Abandoned Sites
Division, LDEQ
Corre spondence
Agency response to LDEQ's comments on RI and Risk Assessment
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006960 - 006961
10/01/92
2
Tim B. Knight, Program Manager, Inactive and Abandoned Sites
Division
LDEQ
Cathy Gilmore, RPM, U.S. EPA Region
Corre spondence
LDEQ comments on the RI Report
25
-------
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PASES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
DUTCHTOWN SUPERFUND SITE
LAD 980879449
006962 - 006964
10/15/92
3
Amanda M. Sullivan, S. Russell KiHebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Progress Report
Progress report regarding activities for the month of
September 1992
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006965 - 006969
10/19/92
5
Tim B. Knight, Program Manager, Inactive and Abandoned Sites
Division
LDEQ
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence
Comments on the Draft FS Report
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006970 - 006975
11/02/92
6
Cathy Gilmore, RPM
U.S. EPA Region 6
S. Russell Killebrew, P.E., Woodward-Clyde Consultants
Correspondence w/Attachments
Submittal of the Agency's comments on the revised RI Report
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR: '
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006976 - 006981
11/05/92
6
Cathy Gilmore, RPM
U.S. EPA Region 6
Harold Ethridge, Administrator, Inactive and-Abandoned Sites
Division, LDEQ
Correspondence
Agency's response to LDEQ's 10/19/92 letter regarding Draft
Feasibility Study
26
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
006982 - 006983
11/06/92
2
Cathy Gilmore, RPM
U.S. EPA Region 6
Harold Ethridge, Administrator, Inactive and Abandoned Sites
Division, LDEQ
Correspondence
Request that LDEQ provide a listing of potential applicable or
relevant and appropriate requirements
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
006984 - 007004
11/12/92
21
Cathy Gilmore, RPM
U.S. EPA Region 6
S. Russell Killebrew, P.E., Woodward-Clyde Consultants
Correspondence and Attachment
Comments on the Draft FS
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
007005 - 007006
11/16/92
2
Amanda M. Sullivan, S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Progress Report
Progress report regarding activities for the month of October
1992
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
007007 - 007578
11/30/92
572
Charles A. Caplinger, S. Russell Killebrew, P.E.
Woodward-Clyde "Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Report
Revised RI Report, Volume I
27
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
007579 - 008548
11/30/92
970
Charles A. Caplinger, S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Report
Revised RI Report, Volume II
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
008549 - 009500
11/30/92
952
Charles A. Caplinger, S. Russell Killebrew,
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Report
Revised RI Report, Volume III
P.E.
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009501 - 009507
12/08/92
7
Charles A. Caplinger, S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence and Attachments
Corrections to the Revised RI mailed November 30, 1992
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009508 - 009509
12/14/92
2
Amanda M. Sullivan, S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Progress Report
Progress report regarding activities for the month of November
1992
28
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009510 - 009511
12/18/92
2
Tim B. Knight, Program Manager, Inactive and Abandoned Sites
Division
LDEQ
Cathy Gilmore, RPM, U.S. EPA Region 6
Correspondence
State response to EPA's November 6, 1992 request for state
identification of potential applicable or relevant and
appropriate requirements
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009512 - 009512
12/23/92
1
Cathy Gilmore, RPM
U.S. EPA Region 6
S. Russell Killebrew, P.E., Woodward-Clyde Consultants
Correspondence
Approval of RI and Risk Assessment review
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009513 - 009514
01/14/93
2
Amanda M. Sullivan, S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Progress Report
Progress report regarding activities for the month of December
1992
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009515 - 009523
02/11/93
9
Cathy Gilmore, RPM
U.S. EPA Region 6
S. Russell Killebrew, P.E., Woodward-Clyde Consultants
Correspondence and Attachments
Comments on the revised FS
29
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DUTCHTOWN SUPERFUND SITE
LAD 980879449
009524 - 009525
02/15/93
2
S. Russell KiHebrew, P.E, Amanda Sullivan
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Progress Report
Progress report regarding activities for the month of January
1993
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009526 - 009527
03/12/93
2
Amanda M. Sullivan, S. Russell Killebrew, P.E.
Woodward-Clyde Consultants
Cathy Gilmore, RPM, U.S. EPA Region 6
Progress Report
Progress report regarding activities for the month of February
1993
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009528 - 009568
03/29/93
41
Office of Waste Programs Enforcement
U.S. EPA - Washington, D.C.
U.S. EPA Region 6 Superfund Site Files
Updated Compendium of Guidance from EPA Region 9
Compendium of CERCLA Response Selection Guidance Documents
Index
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009569 - 009571
04/27/93
3
Cathy Gilmore, RPM
U.S. EPA Region 6
S. Russell Killebrew, P.E., Woodward-Clyde Consultants
Correspondence and Attachment
Specific comments on the Dutchtown Oil Treatment Facility FS
30
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM 1
SITE NAME: DUTCHTOWN SUPERFUND SITE
SITE NUMBER: LAD 980879449
DOCUMENT NUMBER: 009572 - 009755
DOCUMENT DATE: 05/19/93
NUMBER OF PAGES: 184
AUTHOR: Cheryl C. Warren, Ph.D., S. Russell Killebrew, P.E.
COMPANY/AGENCY: Woodward-Clyde Consultants
RECIPIENT: William Luthens, U.S. EPA Region 6
DOCUMENT TYPE: Revised FS Report
DOCUMENT TITLE: FS Report
DOCUMENT NUMBER: 009756 - 009763
DOCUMENT DATE: 07/01/93
NUMBER OF PAGES: 8
AUTHOR: Cheryl C. Warren, Ph.D., S. Russell Killebrew, P.E.
COMPANY/AGENCY: Woodward-Clyde Consultants
RECIPIENT: William Luthens. U.S. EPA Region 6
DOCUMENT TYPE: Correspondence and Attachments
DOCUMENT TITLE: WCC efforts to identify locations of water supply systems in
the vicinity of the Dutchtown Oil'Treatment Site
31
-------
APPENDIX 3
STATE LETTER OF CONCURRENCE
-------
State of Louisiana
Department of Environmental Quality
Edwin W. Edwards WiKiarn A. Kudupski
Governor ;.""
January 25, 1994
Gary A. Baumgarten
Remedial Project Manager
AR/LA Section (6H-EA)
United States Environmental Protection Agency
Region 6
Dallas, Texas 75202-2733
Re: Dutchtown Record Of Decision
Dear Mr. Baumgarten:
My staff has reviewed the draft Record Of Decision for the
Dutchtown Oil Treatment site dated January 4, 1994.
As we have stated before, we concur with the selected remedy.
Thank you for the opportunity to review this document prior to its
release.
If.you have any questions or comments please contact T. L. Stafford
of my staff at (504) 765-0487 or myself.
Sincerely,
Tim B. Knight
Administrator
TBK/TLS/tls
OFFICE OF LEGAL AFFAIRS AND ENFORCEMENT INACTIVE AND ABANDONED SITES DIVISION P.O. BOX 82282 BATON ROUGE. LOUISIANA 70884-2282
4% TELEPHONE (504) 765-0487 FAX (504) 765-0484
^W AN EQUAL OPPORTUNITY EMPLOYER R&H531
recycled paper reww*
-------