RODR069409
PB94-964213
EPA/ROD/R06-94/090
February 1995
EPA Superfund
Record of Decision:
D.L. Mud, Inc. (O.U.I),
Abbeville, LA
9/22/1994
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RECORD OF DECISION
D.L. MUD, INC. SUPERFUND SITE
VERMILION PARISH, LOUISIANA
SEPTEMBER 1994
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D.L. MUD, INC. SUPERFUND SITE
RECORD OF DECISION
STATUTORY PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT HAS
BEEN MET AND FIVE-YEAR REVIEW IS REQUIRED
SITE NAME AND LOCATION
D.L. Mud, Inc. Superfund Site
Vermilion Parish, Louisiana
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action
for the D.L. Mud, Inc. Superfund Site (hereinafter D.L. Mud Site
or the site), in Vermilion Parish, Louisiana, which was chosen in
accordance with the Comprehensive Environmental Response, Compen-
sation, and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), 42
U.S.C. §9601 et seer. , and to the extent practicable, the National
Contingency Plan (NCP). This decision is based on the Adminis-
trative Record for this site.
The State of Louisiana concurs on the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from
this site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE REMEDY
The site is being addressed as one operable unit. The
principal concerns to be addressed at the site are from surface
soils contaminated with residual barium and contaminated
subsurface sludges associated with former impoundments. The
major components of the selected remedy include:
- Imposition of institutional controls to address the low
level threats posed by the residual barium contamination in
the surface soils. Controls to be implemented include
fencing and. deed notices/restrictions to ensure that future
residential use of the property does not occur.
- Excavation and offsite disposal of contaminated sludges
and subsurface soils.
- Limited ground water monitoring to ensure that residual
barium contaminants left onsite do not migrate into usable
drinking water sources.
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STATUTORY DETERMINATIONS
The-selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are lega.lly applicable or relevant and appropriate to the
remedial action, and is cost effective. This remedy utilizes
permanent solutions to the maximum extent practicable for this
site.
To address the principal threats to human health and the
environment that were present at this site, a State-lead cleanup
action was conducted at this site in 1987. This cleanup action
included the removal and offsite incineration of wastes from
onsite storage tanks and surface soils. Although treatment of
the surface soils contaminated with residual barium is not being
conducted as part of this ROD due to the limited threats posed by
these residual materials, the overall remedial action (including
the 1987 State-lead cleanup) for this site does meet the
statutory preference for treatment as a principal element of the
remedy.
Because the remedy will result in hazardous substances
remaining onsite above health-based concentration levels, a
review will be conducted within five years of commencement of the
remedial action to enfure that the remedy continues to provide
ad«
late projection of human health and the environment.
Saginaw Date
Regional Administrator
U.S. Environmental Protection Agency
Region 6
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D.L. MUD, INC. SUPERFUKD SITE
9/94 RECORD OF DECISION
CONCURRENCE PAGE-.
Jamie VanBusTcirk, RPM
D.L. Mud Superfund Site
Bill Ldthans, Chief
AR/LA Superfund Enforcement
George Malone, ORC
Assistant Regional Counsel
i, Chairman
ROD Peer Review Committee
Sam Becker, Chief
Superfund Enforcement Branch
Mark Peycke, Acting Chief
Superfund Branch, ORC
^.Walter Sutton
Regional Counsel
Xllyn Davis, Director
Haz. Waste Management Division
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TABLE OF CONTENTS
RECORD OF DECISION
D.L. MUD, INC. SUPERFOND SITE
VERMILION PARISH, LOUISIANA
LIST OF ACRONYMS i
LIST OF FIGURES ii
LIST OF APPENDICES iii
I. SITE NAME, LOCATION AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 4
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 7
IV. SCOPE AND ROLE OF RESPONSE ACTION 8
V. SUMMARY OF SITE CHARACTERISTICS 9
VI. SUMMARY OF SITE RISKS 40
VII. DESCRIPTION OF ALTERNATIVES 56
VIII. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES . . 66
IX. THE SELECTED REMEDY 72
X. STATUTORY DETERMINATIONS 76
XI. DOCUMENTATION OF SIGNIFICANT CHANGES 81
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LIST OF ACRONYMS
ACLs - ALTERNATE CONCENTRATION LIMITS
AOC ' - ADMINISTRATIVE ORDER ON CONSENT
ARARS - APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
AWR - ACRE WEIGHTED RISK
BRA - BASELINE RISK ASSESSME T
CERCLA - COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION
AND LIABILITY ACT
COCS - CHEMICALS OF CONCERN
CTE - CENTRAL TENDENCY EXPOSURE
DOW - DOW CHEMICAL COMPANY
DSI - DOWELL SCHLUMBERGER, INC.
EPA - THE ENVIRONMENTAL PROTECTION AGENCY
ESI - EXPANDED SITE ASSESSMENT
FIT - FIELD INVESTIGATION TEAM
FS - FEASIBILITY STUDY
GCVS - GULF COAST VACUUM SERVICES
HI - HAZARD INDEX
HO. - HAZARD QUOTIENT
HRS - HAZARDOUS RANKING SCORE
IOCS - INORGANIC AND ORGANIC CHEMICAL CONSTITUENTS
LDEQ - THE LOUISIANA DEPARTMENT OF ENVIRONMENTAL QUALITY
LDNR - THE LOUISIANA DEPARTMENT OF NATURAL RESOURCES
MCLS - MAXIMUM CONTAMINANT LEVELS
MCLGs - MAXIMUM CONTAMINANT LEVEL GOALS
MSL - MEAN SEA LEVEL
NCP - NATION CONTINGENCY PIAN
NOW - NON-HAZARDOUS OILFxZLD WASTE
NPL - NATIONAL PRIORITIES LIST
O&M - OPERATION AND MAINTENANCE
OVA - ORGANIC VAPOR ANALYZER
OVM - ORGANIC VAPOR MONITOR
PRPs - POTENTIALLY RESPONSIBLE PARTIES
RAOS - REMEDIAL ACTION OBJECTIVES
RCRA - RESOURCE CONSERVATION AND RECOVERY ACT
RfD - REFERENCE DOSE
RI - REMEDIAL INVESTIGATION
RME - REASONABLE MAXIMUM EXPC3URE
ROD - RECORD OF DECISION
SARA - SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT
SFS - SLOPE FACTORS
S/S - SOLIDIFICATION/STABILIZATION
TCLP - TOXICITY CHARACTERISTIC LEACHATE PROCEDURE
TICS - TENTATIVELY IDENTIFIED COMPOUNDS
UBK - UPTAKE/BIOKINETIC
UCL95 - UPPER 95th CONFIDENCE LIMIT
DSGS - UNITED STATES GEOLOGIC* ~j SURVEY
VAPE - VERMILION ASSOCIATION TO PROTECT THE ENVIRONMENT
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LIST OF FIGURES
Page
FIGURE #1
FIGURE #2
FIGURE #3
FIGURE #4
FIGURE #5
FIGURE #6
FIGURE #7
FIGURE #8
FIGURE #9
FIGURE #10
FIGURE #11
FIGURE #12
FIGURE #13
FIGURE #14
FIGURE #15
FIGURE #16
FIGURE #17
FIGURL #18
- SITE LOCATION MAP
- SITE DESCRIPTION MAP
- SITE DRAINAGE PATTERNS
- SURFACE SOIL SAMPLE LOCATIONS
- BACKGROUND SAMPLE LOCATIONS (SURFACE
SOILS, SEDIMENTS, AND SURFACE WATER) ....
- CONTOUR INTERVALS OF BARIUM IN SURFACE
SOIL
- SUBSURFACE SOIL SAMPLING LOCATIONS ....
- SUBSURFACE SOIL BORING LOCATIONS NEAR
WELL D-7
- SUBSURFACE SOIL BORING LOCATIONS NEAR
WELL G-22
- SUBSURFACE SOIL BORING LOCATIONS NEAR
WELL G-23
- SUBSURFACE SOIL BORING LOCATIONS NEAR
WELL SB-30
- AREA OF VISUAL CONTAMINATION IN THE
FORMER IMPOUNDMENT AREA
- AERIAL PHOTOGRAPH SHOWING FORMER
IMPOUNDMENTS
- AREA OF ELEVATED VOLATILE ORGANIC
READINGS NEAR WELL G-22
- AREA OF DISCOLORED SOIL NEAR G-23
- AREA OF DISCOLORED SOIL NEAR
BORING SB-30
- GROUND WATER MONITORING WELL LOCATIONS . .
- ONSITE SURFACE WATER/SEDIMENT SAMPLE
LOCATIONS
11
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LIST OF APPENDICES
APPENDIX #1
APPENDIX #2
APPENDIX #3
APPENDIX #4
APPENDIX #5
APPENDIX #6
APPENDIX #7
- RESPONSIVENESS SUMMARY
- ADMINISTRATIVE RECORD INDEX
- STATE OF LOUISIANA LETTER OF CONCURRENCE ON THE
SELECTED REMEDY
- SELECTED ALTERNATIVE COST ESTIMATE
- JUNE 27, 1994 MEMO FROM ECAO REGARDING
SUBCHRONIC AND CHRONIC RfD FOR BARIUM
- INFORMATION ON BARIUM BIOAVAILABILITY
- TABLES
111
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THE DECISION SUMMARY
X. SITE NAME, LOCATION AND DESCRIPTION
The D.L. Mud site is located in a rural area of southern Louisiana,
approximately 20 miles north of the Gulf of Mexico and
approximately 3 miles southwest of Abbeville, Louisiana. The site
comprises approximately 12.8 acres in Range 3 East, Township 12
South, Sections 60, 58, 38, and 32 in Vermilion Parish (Figure #1).
The property is located in a generally rural area with the
surrounding property being chiefly agricultural with livestock
grazing, crawfish farming, and crop production. Residences are
located near the site on Parish Road P-7-31 and Louisiana Highway
335 with a population of approximately 116 people within a one-mile
radius of the site.
The site was originally part of a general acquisition comprised of
several parcels of land in which this parcel was included. The
portion of land that later became the site was originally part of
a 25.56-acre parcel of land that was used as a drilling mud
facility until 1980. In 1981, the Dowell Division of The Dow
Chemical Company (Dow) purchased a 12.8-acre portion of the larger
tract that contained the barium sulfate based drilling mud blending
operation. The remaining portion of the tract, which included
impoundments used for disposal of oilfield exploration and
production wastes, was purchased by Gulf Coast Vacuum Services,
Inc. (GCVS), to support a commercial waste vacuum truck operation.
This property is also a Superfund Site (GCVS site) and is located
adjacent to the north and west sides of the D.L. Mud site (Figure
#2).
The site is presently unused, with the exception of one small shed
in which a local farmer stores equipment. The site is typical of
ungrazed pastureland, with sporadic tree rows along fences and
former irrigation channels. The site is graded to drain and,
except for the former irrigation channels, does not contain any
standing water. Other than periodic mowing, there are no ongoing
maintenance activities at the site.
The site is situated on the Gulf of Mexico coastal plain and is
generally flat. Topographic relief is less than 5 feet, at an
approximate elevation of 10 feet above mean sea level (MSL). The
site is divided into northern and southern portions by the
abandoned, leveed irrigation canal that transects the D.L. Mud site
south of the GCVS site. The northern portion of the D.L. Mud site
is the former drilling mud blending area. This area is bounded on
its eastern and southern sides by the levees associated with the
former irrigation canal network and the GCVS site on its northern
and western sides.
The area surface soils (0-1 feet) consist of silt loam underlain by
layers of clay, silty clay and sand. A clay layer approximately 10
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Figure #1
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Figure # 2
MONITORING WELL LOCATION
0 100 200
APPROX SCALE IN FEET
sobRCE MODi?iLi FROM CH3M HILL 1990
D.L MUD. INC , SITE
ABBEVILLE, LOUISIANA
SITE LAYOUT MAP
Environmental Management. Inc
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to 15 feet thick is located directly beneath the surface soils.
Soils under this clay layer consist of silty clay materials to a
depth of 30 feet. Below 30 feet are beds of fine quartz sand
interbedded with silt and clay. Ground water beneath the site was
encountered at approximately 20 feet below the ground surface in
the upper Chicot Aquifer system.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Relevant site history dates back to 1969 when the site was a part
of a 25.56-acre parcel of land that was sold to Lafayette Highway
Equipment Sales and Services, Inc. On May 1, 1975, Lafayette
Highway Equipment Sales and Services, Inc., sold the property to
Gulf Coast Pre-Mix Trucking, Inc. On January 11, 1979, G.H.
Drilling Fluid Services, Inc. (later G.H. Fluid Services, Inc.)
became the owner of the property when Gulf Coast Pre-Mix Mud
Service, Inc., merged with Gulf Coast Pre-Mix Trucking, Inc.
The site took its present form on October 1, 1980, when G.H. Fluid
Services, Inc., sold 12.78 acres of the 25.56-acre parcel to Gulf
Coast Vacuum Services, Inc. (this later became the GCVS site). On
February 11, 1981, G.H. Fluid Services, Inc., sold the remaining
12.78 acres to Dowell, a division of The Dow Chemical Company.
Ownership of the site was transferred to Dowell Schlumberger, Inc.
(DSI) in April 1984. The site was sold to D.L. Mud, Inc., in March
1985 by DSI.
The 25.56-acre parcel was used for agricultural purposes prior to
1969. From 1969 to 1980 (prior to the division of the property),
the portion of the property that later became the D.L. Mud site was
used as a barium sulfate based drilling mud storage and formulating
facility.
During operations of the facility prior to division of the
property, the overall 25.56 acre facility consisted of three
impoundments located on the northwest portion of the property now
referred to as the GCVS site and 16 vertical drilling mud storage
tanks located on the portion of the property now referred to as the
D.L. Mud site. The tanks mostly contained drilling mud solids that
had settled from oil-based and water-based drilling mud. Solids
were primarily montmorillonite, barite, hematite, and rust from the
tank walls. In addition, there were several buildings, including
storage buildings, a residence, and a vehicle maintenance building,
as well as three underground fuel storage tanks on the portion of
the property that is now referred to as the GCVS site.
Following the division and sale of the property in 1980, GCVS
operated its portion until 1984, mainly as a vacuum tank truck
facility servicing the local oil and gas exploration and production
industry. The D.L. Mud site remained relatively inactive after
1980. A citizen's complaint through the Vermilion Association to
Protect the Environment (VAPE) led to site identification by the
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U.S. Environmental Protection Agency (EPA) on June 27, 1980. As a- '
result, an EPA Field Investigation Team (FIT) conducted a prelim-
inary assessment and preliminary sampling inspection in July and j
September of 1980. This inspection concentrated on areas of {
concern that are now most associated with the GCVS site, however,
at this time, the property was still operated as one facility. j
On August 18, 1980, G.H. Fluid Services, inc., then owner and
operator of the 25.56 acre parcel which contained the D.L. Mud
site, sent its first Notification of Hazardous Waste Activity to I
EPA. It reported the generation, transportation, treatment, '
storage and disposal of nonlisted hazardous wastes which were
ignitable, corrosive and toxic. On February 21, 1983, Dow filed a I
Hazardous Waste Notification Form for the site property with the I
Louisiana Department of Natural Resources (LDNR) indicating it was
a generator with no onsite disposal. Hazardous wastes generated /
were listed as diesel contaminated dirt and rubble, contaminated I
diesel liquid, contaminated diesel sludge and empty drums '
containing wallcote, fatty acids and tars. No permit was required
to operate the facility, however, manifests were required for any J
offsite transportation or disposal of wastes.
On April 29, 1983, the site was inspected by the LDNR and a letter
of warning was issued to Dow informing it that it was out of
compliance with Louisiana Waste Management Program Rules and
Regulations. Dow took steps to rectify the problems and on May 18,
1983, LDNR observed that all drums of waste had been removed and
manifested, spills had been picked up and drummed for disposal, and
the site had been regraded with a levee system installed around the
tank area.
In October 1983, Dow submitted to the LDNR a certification of
inactivity for the site. On May 23, 1984, the Louisiana Department
of Environmental Quality (LDEQ) notified Dow that, based on its
certification of inactivity, the facility would be classified as a
non-handler of hazardous waste. On June 6, 1985, in response to
citizen complaints, an EPA Potential Hazardous Waste Site Form was
prepared for the site which was now under the ownership of D.L.
Mud, Inc. It was noted on this form that there may have been some
activities going on after the site had been declared inactive. On
July 9 and 10, 1985, EPA conducted an inspection with sampling and
on August 16, 1985, a EPA Identification and Preliminary Assessment
Report was prepared. The Report indicates that D.L. Mud, Inc. was
using the site to salvage equipment and tanks for its operations
elsewhere in Louisiana. Midnight dumping was also indicated to
have occurred on the site.
Based on the results from the July 9 and 10, 1985, sampling
inspection and on a non-sampling inspection conducted on September
27, 1985, it was decided that final disposition of the site should
be evaluated through the Hazardous Ranking Score (HRS) process. An
Expanded Site Inspection (ESI) was performed during several site
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inspections in 1987. The site information and sampling data
collected during the ESI was used to determine that the site posed
a significant environmental and human health risk. The site was
proposed for inclusion on the National Priorities List (NPL) in
June 1988 and was finalized on October 4, 1989, pursuant to Section
105 of CERCLA, as amended, qualifying the site for investigation
and remediation under CERCLA.
At some point in 1985 or 1986, Dow/DSI, by way of agreement with
D.L. Mud, Inc., agreed to take responsibility for the cleanup of
the site in cooperation with LDEQ. Between April 18, 1986, and
August 18, 1986, under the supervision of LDEQ, Dow/DSI constructed
a security fence around the majority of the site. At the same
time, Dow/DSI began development of a tank sampling, analysis, and
disposal plan for the 16 onsite tanks.
From April 14, 1987, through July 11, 1987, Dow/DSI performed a
remediation of the drilling mud storage tank farm under the
supervision of LDEQ by completing the following tasks:
• Removal of the tank contents and associated soils,
destruction by incineration, and disposal of ash in a
hazardous waste landfill.
• Decontamination and demolition of the tanks, supports,
and piping.
• Removal and disposal of approximately 800 cubic yards of
contaminated soil from eight onsite areas, including tank
pads, one "bare" area, and two areas identified by EPA in
the southern portion of the site.
• Placement of clean offsite fill material onsite in the
excavated areas.
The limits of excavation for the removal action were determined by
an LDEQ representative using an HNu photoionization meter.
Verification soil samples were collected from the eight excavated
areas. On December 17, 1987, Dow/DSI submitted a Report of
Decommissioning and Restoration of the D.L. Mud site which was
approved by LDEQ on February 29, 1988. It should be noted that the
information used by EPA to list the site on the NPL was gathered
before the 1987 cleanup activities were completed.
In 1988, EPA identified over 200 potentially responsible parties
(PRPs) for the site. In August of 1989, EPA Region 6 issued a
General Notice Letter to these PRPs regarding their potential
liability and a request for information. Special Notice letters
were then issued to the PRPs in December 1989. The Special Notice
Letter requested that the PRPs voluntarily perform or finance a
Remedial Investigation/Feasibility Study (RI/FS). In response,
Dow/DSI conducted the RI/FS pursuant to an Administrative Order on
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Consent (AOC) signed on June 20, 1990. The objectives of the RI,
completed in December 1992, were to: 1) confirm the efficacy of
prior remedial actions performed at the site by Dow/DSl; and 2)
determine the nature of residual site contamination (if any) and
associated human health and environmental risks. The objectives of
the FS, completed in November 1993, were to determine and evaluate
alternatives for remedial action (if any) to prevent, mitigate or
otherwise respond to or remedy any release or threatened release of
hazardous substances, pollutants, or contaminants from the site.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The requirements of CERCLA Sections 113(k)(2)(B)(i-v) and 177, 42
U.S.C. §§9613(k)(2)(B)(i-v) and 9617, were met during the remedy
selection process, as illustrated in the following discussion.
A series of community interviews near the site were conducted in
May 1990. The interviews included a cross-section of the area
residents and landowners, as well as the Abbeville-Vermilion
Chamber of Commerce, Mayor Broussard of Abbeville, Louisiana,
members of VAPE, and other civic groups. A site mailing list was
developed through the community interview process and is continu-
ally updated as the site activities progress.
In October 1993, an informal Open House was held at the Abbeville
General Hospital to discuss the findings of the RI/FS. Fact sheets
summarizing the RI were mailed out to all individuals on the site
mailing list in December 1993.
The RI/FS Reports and Proposed Plan for the D.L. Mud site were
released to the Public on April 26, 1994. The documents were made
available to the public in the Administrative Record File in the
noted information repositories: Vermilion Parish Public Library,
Abbeville, 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 these documents
and Administrative Record File was published in the Abbeville
Meridional and the Kaplan Herald. In addition, a. fact sheet
summarizing the Proposed Plan of Action for the D.L. Mud site was
mailed to the site mailing list on April 26, 1994.
The EPA held a public comment period regarding the RI/FS, Proposed
Plan and Administrative Record from April 29, 1994, through May 28,
1994. During this initial public comment period, a formal public
meeting was held on May 10, 1994, at the Abbeville General
Hospital. Representatives from the EPA presented the remedial
alternatives, the EPA preferred alternative, and answered
questions. All questions and comments were recorded to be included
in the Responsiveness Summary.
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A response to all comments received during this 30 day public
comment period, either written or verbally expressed at the public
meeting, is included in the Responsiveness Summary. The
Responsiveness Summary is included as part of the ROD (Appendix
#1).
This decision document presents the selected remedial action for
the D.L. Mud site, in Vermilion Parish, Louisiana, chosen in
accordance with CERCLA, as amended by SARA and, to the extent
practicable, the NCP. The decision for this site is based on the
Administrative Record. An index for the Administrative Record is
included as Appendix #2 to the ROD.
IV. SCOPE AND ROLE OF RESPONSE ACTION
The remedy to address the identified threats at the D.L. Mud site
under this ROD is addressed as one operable unit. This is the only
and final operable unit planned for this site. As mentioned
earlier, a State-lead removal action was completed in 1987 which
addressed the majority of problems identified during the NPL
listing process.
The studies undertaken at the D.L. Mud site have identified low
level risks which require remedial actions to address. Low level
risk materials are sources of contamination that could be kept in
place by capping and pose a low risk. For example, the surface
soils identified onsite with residual elevated levels of barium
contamination are considered a low level risk because the associ-
ated risk is relatively low (less than an order of magnitude in
comparison to accepted action levels) and because these residual
contaminants could be kept in place with a capping remedy, thus
eliminating the potential for migration or ingestion.
In addition, EPA has determined that there is an unknown potential
risk related to the source materials identified in the subsurface
soils in the former impoundment areas. This potential risk is
related to the unknown capacity for these contaminants to migrate
into the ground water and the unknown impact these contaminants
would have on the quality of the ground water.
The remedial objective determined to be necessary at the Site is to
preserve human health and the environment by eliminating or
reducing identified and/or potential risks by preventing the
ingestion of barium contaminated soils and by reducing the
potential for migration of contaminants from both surface and
subsurface soils to the ground water. Additional specific remedial
objectives determined to be necessary at the D.L. Mud Site are:
* Primary: Preserving the Site for non~residential uses
and reducing the potential for migration to
ground water of site-specific contaminants.
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* Secondary: Restoring the Site for unrestricted uses.
Future land use assumptions used to formulate the primary and
secondary remedial objectives were based in part on two important
factors. First, because the Site is presently an abandoned, light
industrial use facility, with no human inhabitants and located next
to the GCVS Superfund Site, it seems reasonable that this type of
land use will continue. Second, because there currently are no
land use restrictions affecting this property and residential areas
are located nearby, it is possible that the property could be used
as a residential location in the future.
V. SUMMARY OF SITE CHARACTERISTICS
The D.L. Mud site is situated on the Gulf of Mexico coastal plain
and is generally flat. Topographic relief is less than 5 feet, at
an approximate elevation of 10 feet above MSL. The site is divided
into northern and southern portions by the abandoned, leveed
irrigation canal that transects the D.L. Mud site south of the GCVS
site. The northern portion of the D.L. Mud site is the former
drilling mud blending area. This area is bounded on its eastern
and southern sides by the levees associated with the former
irrigation canal network.
The southern portion of the site is poorly drained, with slopes of
one-half percent or less toward the south, and is bounded by a
perimeter levee system. Grading in this portion of the site still
reflects its former use as a rice field. The northern portion of
the site contains three structures: one shed with a concrete slab,
one concrete slab associated with a former shed, and one small
concrete slab that was formerly a pump pad within the drilling mud
blending tank building.
Features that have been added in the vicinity of the D.L. Mud site
include two berms across the drainage ditch located on the western
edge of the GCVS site. These berms were constructed during a 1990
EPA Interim Remedial Measure to provide a secondary impoundment to
collect overflows from GCVS site impoundments. A six foot tall
chain link fence was also added around the southwestern portion of
the GCVS site during the 1991 EPA RI that was conducted at that
site.
Vermilion Parish has a humid, subtropical climate. The mean annual
precipitation is approximately 60 inches. Pan evaporation is
approximately 60 inches per year. Potential evapotranspiration is
reported to be between 45 and 48 inches per year and actual
evapotranspiration is reported to be between 40 and 43 inches. The
annual mean relative humidity is 75 percent. Although no
temperature data were found for Abbeville, the mean temperature in
nearby New Iberia was 69.4°F in 1990. Wind data collected at the
Lafayette, Louisiana airport show winds to be predominantly
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northerly or southerly. The highest wind speeds are typically
reported-from the south.
In 1990,. Abbeville received approximately 47 inches of rainfall,
which is about 14 inches below normal. Much of this variation can
be attributed to below average rainfalls from late spring to late
fall for the area. Although the area experiences extreme rainfall
events, the entire D.L. Mud site has been determined to be above
the 100-year floodplain.
SURFACE WATER
Regionally, surface drainage is from north to south. Because of
low relief, this area is poorly drained, and ditches are used to
promote drainage from agricultural land. These ditches eventually
interconnect with major tidally influenced waterways such as the
Vermilion River. Canals were also built in the Abbeville area and
operated commercially for irrigation water transmission from the
Vermilion River, which is a little over one mile east of the site.
The canal located along the eastern site boundary was fed by the
Vermilion River and used for commercial irrigation until the late
1970s. The canals have been replaced by wells as a source of
irrigation water. In some areas, especially south of Abbeville,
the Chicot Aquifer, which is the principal source of drinking and
irrigation water in the area, is recharged by the Vermilion River.
This recharge occurs during the summer and fall, with discharge of
ground water to the river occurring during the spring. Aquifer
recharge typically exceeds discharge to the river. Seepage from
the Vermilion River along a ten mile section south of Abbeville is
reported to be about 25 cubic feet per second.
There are no surface water monitoring stations between the D.L. Mud
site and the Vermilion River. The United States Geological Survey
(USGS) operates a gaging station on the Vermilion River at the town
of Perry, approximately two miles east of the site. USGS records
show that this gaging station is tidally influenced. Recorded
discharges have ranged from a maximum positive flow of 15,800 cubic
feet per second to a maximum negative flow of 2,800 cubic feet per
second. Periods of little or no flow are also recorded.
The LDEQ lists the Vermilion River as not meeting its designated
water quality uses for primary (swimming, skiing, and prolonged
body contact) and secondary (fishing, wading, boating, and
incidental/accidental body contact) recreation or for fish and
wildlife support from its headwaters to the Intracoastal Waterway.
From the Intracoastal Waterway to Vermilion Bay, the river
partially supports fish and wildlife use. According to LDEQ, the
Vermilion River suffers from dissolved oxygen depletion, elevated
fecal coliform levels, and high turbidity.
Surface runoff from the northern portion of the D.L. Mud site
collects in the unnamed drainage ditch that transects the GCVS site
10
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and proceeds to the northeast where the ditch merges with Coulee
Galleque. The Coulee Galleque continues east until it forms a
confluence with Coulee Kenny, which flows southeasterly to the
Vermilion River above the town of Perry. The southern portion of
the site drains southward, eventually joining a highway ditch south
of the site and ultimately flowing through the Noel Canal to the
Vermilion River below the town of Perry. Figure #3 shows general
drainage patterns from the D.L. Mud site.
REGIONAL GEOLOGY
The D.L. Mud site is located within the Gulf Coastal Plain
physiographic province. The area is west of the axis of the
Mississippi structural trough and north of the Miocene Axis Gulf
Coastal Geosyncline. Underlying the site are overlapping, coastal-
thickening wedges of fluvial, deltaic, and marine sediments. These
sediments are of the Pleistocene age and were deposited by the
ancestral Mississippi River that derived sediment and flow from the
central part of the North American Continent. These deposits
consist of extensive beds of clay, sand, or sand and gravel
extending to depths of greater than 2,000 feet offshore in the Gulf
of Mexico. In the Abbeville area, these deposits extend to depths
of about 1,000 feet.
Generally, the Pleistocene deposits have massive lenticular sands
separated by laminated clays. These deposits have been intersected
and reworked by the meander-belt streams which have formed relic
channels, and point-bar deposits, which are overlain by back swamp
clays. The back swamp clay (hardpan) typical of the near surface
deposits of the rice field areas of southwest Louisiana forms a
laterally extensive blanket from Lake Charles to Lafayette and
southward. These low-permeability clays are generally 50 feet
thick or less and may be overlain by topsoils.
The area topsoils (0-1 feet) are largely Patoutville silt loam
formed from deposits of the Pleistocene Prairie Formation and are
underlain by layers of clay, silty clay and sand. This nearly
level to very gently sloping loamy soil (0 to 3 percent slope) has
a medium acid, dark, grayish brown silt loam surface of five to
eight inches. The subsurface layer is a strongly acid, grayish
brown silt loam. The subsoil is a medium, acid dark grayish brown,
silty clay loam. This soil is somewhat poorly drained, and runoff
is medium. Because of poor drainage and engineering properties,
use of the Patoutville soils is generally limited to agriculture.
The United States Soil Conservation Service lists the potential for
pasture, crop, and pine forest lands as high.
Geotechnical testing indicate that soils underlying the site are of
low permeability. Of the six samples tested for permeability, five
have values less than lxlO"7cm/sec, which is the maximum perme-
ability acceptable for Resource Conservation and Recovery Act
(RCRA) cap and cover systems. Soils examined during the drilling
11
-------
Figure //
APPROXIMATE SCALE: 1'= 1425' PHOTO DATE 2/24/90
-------
of subsurface borings and wells indicate that alluvial deposits"
consisting of clay, silt, and sand exist to depths of at least 50
feet -across the site. The shallow soils (to a depth of approxi-
mately 30 feet) were primarily clay and silty clay classified
visually as CH under the Unified Soil Classification System. Below
30 feet are beds of fine quartz sand interbedded with silt and
clay. The subsurface is generally saturated below approximately 20
feet.
REGIONAL HYDROGEOLOGY
The major hydrogeologic unit in the site vicinity is the Chicot
Aquifer System. This aquifer has an areal extent of approximately
2000 square miles and is the principal source of ground water
supply within the Abbeville area. The shallow sands of the upper
Chicot Aquifer are generally considered unconfined, with a perched
water table near land surface. The base of fresh water in the
Chicot aquifer varies from 400 to 600 feet beneath ground level in
the Abbeville area.
Ground water beneath the site was encountered at approximately 20
feet below the ground surface (-10.0 feet MSL) which is typical of
conditions in the upper sand unit of the Chicot Aquifer in the
Abbeville area. The direction of flow in the Abbeville area is
toward the northwest at a gradient of approximately 0.0002 ft/ft
resulting from the large cone of depression created by aquifer
withdrawals from large pumping centers such as the cities of
Lafayette and Lake Charles. Regional annual fluctuations in water
levels for the upper sand of the Chicot aquifer range from one to
two feet in the Abbeville area. In some areas, especially south of
Abbeville, aquifer recharge by the Vermilion River occurs during
the summer and fall, with discharge to the river during the spring.
Assuming a hydraulic conductivity of 112 ft/day, a hydraulic
gradient of 0.0002 ft/ft, and an intergranular porosity of 0.30,
the estimated regional flow velocity in the vicinity of Abbeville
would be 0.07 ft/day.
Water level measurements taken at D.L. Mud and GCVS site ground
water monitoring wells show that ground water flow in the shallow
sand is toward the north at a gradient of approximately 0.0002
ft/ft, which is typical for the Chicot aquifer in the Abbeville
area. Small variations in water levels indicate that there may be
some localized flow of ground water between the GCVS and D.L. Mud
sites. This mounding/depression may be associated with the
variability of permeabilities and recharge rates for the alluvial
deposits and could potentially be influenced by the surface
impoundments located on the GCVS site.
In accordance with EPA's Guidelines for Ground Water Classification
under the EPA Ground Water Protection Strategy, (December 1986) .
the ground water beneath the site is classified as a Class IIB
13
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ground water because the ground water is currently used or is
potentially available for drinking water or other beneficial uses.
Ground water in the area is used for drinking water purposes (there
are at least 25 residential wells within one mile of the site) as
well as for agricultural purposes (irrigation and crawfish ponds).
The ground water found at shallow depths (i.e., RI monitoring wells
screened at 20 feet) is turbid from the clays and silts in the
formation and would be inappropriate for drinking or irrigation
because of the potential for plugging of pipes and fittings. While
there is no impermeable barrier between the upper and lower reaches
of the aquifer, ground water supply wells completed to deeper
depths in this aquifer (i.e., 80 feet to 120 feet) are capable of
producing water virtually free of visible solids.
KNOWN OR SUSPECTED SOURCES OF CONTAMINATION
The sources for the contamination that has been identified at this
site are mostly related to the nature of the business that operated
on the site. As mentioned earlier, this location was used as an
oil field drilling mud formulation and restoration facility
servicing the local oil and gas exploration and production
industry, including operations conducted offshore in the Gulf of
Mexico. Operations involved the use of numerous large tanks and
pits used for mixing and storage of raw materials and wastes. In
addition, the neighboring GCVS facility was a service facility for
the oil and gas industry, concentrating on vacuum tank truck
transportation operations. It is also known that illegal dumping
at both Superfund sites occurred during the active life of the D.L.
Mud and GCVS facilities.
The type of materials and wastes that were generated, stored or
disposed of at this site are generally defined as "non-hazardous
oilfield wastes" (NOW wastes) which are exempt from regulation
under RCRA, the current federal law that regulates hazardous
wastes. These wastes are generally regulated by the individual
States in which they are generated. However, because these wastes
contain hazardous substances, they can also be evaluated as
potential problems and addressed under the Superfund program.
All known contaminant sources were removed from the site during the
1987 site remediation under the direction of the LDEQ. This action
included:
* The removal and offsite incineration of any remaining
drilling muds being stored in any of the 16 then existing
product storage tanks and associated soils.
* The removal and offsite disposal of the 16 storage tanks,
their bases and any associated roof, piping, etc.
14
-------
* The removal and off site disposal of areas of contaminated
soils, located on the site, but associated with suspected
fugitive dumping by undisclosed parties.
* The backfilling and grading of all excavations to conform
to the natural lie of the land.
At the initiation of the RI in 1990, it was assumed that only
residual contamination would remain at the site. During the RI,
several subsurface areas were identified as potential "source
areas" based on either visual and/or vapor identification of
obviously contaminated materials not indicative of native soils.
CONTAMINATION CHARACTERIZATION
This section describes the nature and extent of residual
contamination at the D.L. Mud site for the following media: surface
soil and subsurface soil, ground water, surface water, and
sediment. Subsurface soils have been subgrouped to include five
distinct categories: four "source area" sample groups and a fifth
"non-source area" sample group. Three source areas were identified
during subsurface boring activities near monitor wells G-22 and G-
23 and soil boring SB-30. The fourth source area was identified as
a former impoundment area in April 1992 from a 1974 aerial
photograph.
The nature of site residual related contamination was evaluated by
a statistical comparison of onsite media analytical data to of f site
(background) analytical data. A summary of the evaluation of the
various media is presented in more detail in following subsections.
In general, inorganic parameters were detected in much greater
frequency than organic parameters for both onsite and background
samples. Typically, organic compounds were detected in one or two
samples per media grouping for both onsite and background samples.
The exceptions of this generality are for common laboratory
(acetone, methylene chloride) and sampling (phthalates)
contaminants. These data indicate that the nature of residual
contamination is generally limited to inorganics, although organic
residual contamination may exist at localized areas. The
determination of the presence of chemical specific residual
contamination was made by statistically comparing background sample
sets to the onsite sample sets for each media evaluated at the
site. If that chemical was found to be significantly higher onsite
than in background, it was considered to be indicative of onsite
residual contamination of that media. Not all contaminants of
concern are contaminants that drive the risk or the need to conduct
remedial actions at the site. The contaminants most critical to
risk are discussed in detail in Section VI of this ROD.
15
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Surface -Soils
A total of 30 composite surface soil samples (0-1 feet) were
collected to evaluate potential residual contamination during the
RI (Figure #4). Sample locations were determined based on
historical uses of the site and on c random, grid basis. Eight of
these samples were background samples collected from soils of
similar nature at privately owned farms north and northwest of the
site (Figure #5).
The onsite surface soil evaluation concentrated on two areas: the
southern portion, which is the area below the bisecting canal that
was generally not used during the operations at the site but which
might have been the location of indiscriminate dumping; and the
northern portion, which is above the bisecting canal and was the
location of the operations area, storage tanks and focus of the
1987, State-lead cleanup.
Table #1 summarizes surface soil residual contaminant sample
results above background values by sample location. Surface soil
samples G-23 and HA-1 through HA-7 were used to evaluate the
southern portion of the property. Ten inorganic compounds were
reported above maximum background in this area. The results show
that the number and concentration of inorganics generally decreased
with distance from the canal that transects the property. The
highest concentrations of inorganics are located near HA-4, HA-5
and HA-6 and decrease to background levels further south. In
general, -chese data indicate that residual inorganics are located
in the portion of the property closest to previous site activities.
Surface soil samples HA-8 through HA-14 and G-20 through G-22 were
used to evaluate the impacts of D.L. Mud and GCVS operations on the
northern portion of the property. Table #1 shows that a total of
10 inorgp.nic compounds were detected in this area. Samples located
within the former process area that was not excavated during the
1987 remedial activities at the site (HA-8, HA-10, HA-ll, G-20, G-
21, and G-22) show highest residual concentrations. Lower
concentrations of inorganics were reported in the remaining
samples.
The analytical data for surface soils indicate that residual
inorganic contamination appears to be centered near the former
storage tank area and also downstream of surface runoff from the
GCVS site, with lesser concentrations occurring at a distance. In
keeping with the former use of this area as a barium sulfate based
drilling mud blending facility, barium is the most widespread
residual contaminant. Figure #6 graphically illustrate! the
lessening of barium concentration at greater distances from the
former storage tank area and the reported rodeo area located in the
northeast portion of the GCVS site. In addition, testing was done
to speciate the form of barium present in the surface soils.
16
-------
Figure # 4
PARiSr ROAD &-7-31
HA-6 HA-7
NORTHERN SITE FENCE
D.L MUD,
INC.. SITE
SiTE BOUNDARY
LEGEND
MONITORING WELL LOCATIONS
SAMPLE LOCATIONS
NOTES: LOCA J10NS ARE APPROXIMA IE.
SURF1C1AL SOIL SAMPLING LOCATIONS
3.L. MUD, INC., SITE, Abbeville, Louisiana
-------
Figure # 5
APPROXIMATE SCALE: 1'= 1425'
PHOTO DATE 2/24/90
-------
Figure // 6
W.OOOppm
0 300 FEET
APPRO*. SCALE
502
SOS
506
ST6A
507
5C£
SOS
HA;
HA 2
HA 3
*->A4
HAS
HAS
HA 7
HAS
HA 9
HA1C
HAn
HA',2
HA13
HA14
G-20
C-21
C-22
C-23
:ssoo
zee
! J70
! 272
, 270
! 6900
i 8300
6930
7150
72200
9120
7S90
HJOO
7630
Hi JO
10100
1.3500
l.OOOppm
\
HA-1
/
i.OOCpprn
/
I
I
J
/ SD2
/ °
/
- MONITORING WELL LOCATIONS
- HAND AUGER SAMPLE LOCA TiONS
o - SEDIMEN T SAMPLE LOCA TIONS
NOTES: 1. LOCATIONS ARE APPROXIMATE.
2 CONTOUR INTERVALS ARE BASED ON ANALYTIC*L
DATA GENERATED FROM S'JRFICAL AND SEDIMENT
SAMPLES.
}UR INTERVALS OF BARIUM IN SURFIC1AL SOIL rJ
D.L MUD. INC., SITE, Abbeville, Louisiana
-------
Samples ..collected from the site showed that barium sulfate
accounted for approximately 92 percent of the total barium present.
No organic contaminants were detected at concentrations above
background in any of the surface soil samples.
Subsurface Soils
Numerous subsurface soil samples and soil borings were taken during
the RI. The locations of these samples and borings were chosen
based on several factors as discussed below. No subsurface soil
background samples were collected. Comparisons with background
were made using surface soil background results.
Five soil boring locations (SB-1, 2, 3,4 and 5) and six trenching
locations (TR-1, 2, 3, 4, 5, and 6) were established at the
approximate points shown on Figures #7 and #12 to evaluate the risk
associated with potential subsurface soil contamination in the
former site process areas. Four of these locations (SB-1, SB-3,
SB-4 and SB-5) were established to confirm soil excavation limits
for the 1987 site remediation effort. The fifth soil boring (SB-2)
was located to coincide with the approximate center of a potential
surface impoundment tentatively identified by a 1975 EPA aerial
photograph. The six locations for trenching were located to
coincide with the approximate centers of six impoundments identi-
fied in an aerial photograph dated 1974 (Figure #13).
Eleven additional hand auger soil borings (D-7A through D-7G and
SB-6 through SB-9) were completed to depths of approximately 10
feet at the approximate locations shown on Figure #8. These
borings were completed to visually evaluate the extent of subsur-
face contamination under the adjacent GCVS site near the D.L. Mud
site property line. No visual contamination was noted beneath the
D.L. Mud property. No samples were collected for chemical
analysis.
In addition, seventy three subsurface soil borings were completed
to depths ranging from 3 to 15 feet deep. The borings were cored
using the vibracore technique near wells G-22 (Figure #9) and G-23
(Figure #10) to evaluate the extent of two potentially contaminated
areas identified by an EPA contractor and to address concern over
the potential existence of other non-identified source areas
onsite. The subsurface soils near well G-22 were investigated by
the completion of fifteen borings. Eight borings were placed
equidistantly around the well pad. Seven other boring locations
were located based on field readings of organic vapors. The
subsurface near well G-23 was investigated by a total of fifteen
borings. Eight of the borings were located equidistantly around
the well pad, and the remaining seven were located based on visual
observations of darkened soil since no organic vapors were noted.
Soil borings SB-10 through SB-37 were completed on a grid system at
approximate 100 foot centers to supplement previous site soil
20
-------
Figure # 7
SCALE
--- 5- ?3AD P-7-31
SEE FIGURE
SE&flGURE * 12
E FIGURED 8
SEE FIGURED 10
SEE FIGURED 9
NORTHERN SITE FENCE
SB15 S816 SB%
D.L ML/D.
., S/7F
APPROXIMATE
SITE BOUNDARY
LEflENP
- SAMPLE LOCATION
NOTE: LOCATIONS ARE APPROXIMATE
SUBSURFACE SOIL BORING LOCATIONS
D.L. MUD, INC., SITE, Abbeville, Louisiana
-------
Figure g 8
GULF COAST
VACUUM SERVICES SITE
25 FEET
SCALE
D-7C
SB-9
D-73
D.L. MUD.
INC., SITE
D-7D
SB-B
D-7E
S3-6
F.D. 1/2" IRON ROD
N 9,592.17
E 9817.06
LEGEND
© - SUBSURFACE SOIL BORING LOCATION
- MONITORING WELL LOCATION
NOTE: LOCATIONS ARE APPROXIMATE
SUBSURFACE SOIL BORING LOCATIONS NEAR WELL D-7
D.L. MUD, INC., SITE, Abbeville, Louisiana
-------
Figure // 9
S-5
LEGEND
- AUGER/V1BRACORE LOCATION
SOIL BORING w/LABORATORY
SAMPLE
- MONITORING WELL LOCATION
NOTE: LOCATIONS ARE APPROXIMATE.
SUBSURFACE SOIL BORING LOCATIONS NEAR WELL G-22 ryr^i
D.L. MUD. INC., SITE, Abbeville, Louisiana
-------
Figure t 10
W FEET
SCALE
CONCRETE
WELL PAD
x E5
E4
x
LEGEND
E3
x
- BORING (POSTHOLE) LOCATIONS
- VIBRACORE LOCATION
SOIL BORING w/LABORATORY
SAMPLE
- MONITORING WELL LOCATION
NOTE: LOCATIONS ARE APPROXIMATE
SUBSURFACE SOIL BORING LOCATIONS NEAR WELL G-23
D.L MUD, INC., SITE, Abbeville, Louisiana
-------
Figure # 11
0 15 JO FEET
SCALE
SS-JJ •
H'
G* F
SS-J2-
©C
SB-30
K
•J
•S8-31
VISIBLE DISCOLORATION
AT LAND SURFACE
LEGEND
- AUGER/V18RACORE LOCATION
_ SO/L BORING w/LABORATORY
SAMPLE
/VOTES: 1. VD=V!sto/e Disco/oration
2. LOCATIONS ARE APPROXIMATE
SUBSURFACE SOIL BORING LOCATIONS NEAR BORING SB-30 f-'.'f',/.'/III
D.L MUD, INC., SITE, Abbeville, Louisiana ^———
-------
Figure // 12
-------
Figure ill3
-------
borings. An additional fifteen borings were placed near the
location" of SB-30 (Figure #11) in response to low level organic
vapor readings and visual observations of darkened soil.
The following sections summarize subsurface soil results reported
above background values for each sample location. Determination of
the potential presence and extent of subsurface soil contamination
is presented in six groupings according to the purposes of each
investigation.
1) Confirmatory Samples Collected Beneath Areas of Historical Use.
Subsurface soil samples SB-1, SB-3, SB-4, and SB-5 were analyzed to
evaluate residual subsurface contamination beneath areas excavated
during the 1987 site remediation. A comparison between the
shallower and deeper samples from borings SB-1, SB-2, SB-3, SB-4,
and SB-5 shows little difference between the analytical results
with depth (see Table #2) . This finding tends to indicate that the
soils sampled are indicative of native materials.
Sample SB-2 was collected to determine the presence of residual
subsurface contamination from a surface impoundment tentatively
identified from an EPA aerial photograph. No visible indication of
waste material was noted during placement of this boring. However,
the trenching activities discussed later did locate discolored soil
near this boring.
Samples HA-3, HD-1 and HD-3 were collected from beneath the surface
of an area in the southern portion of the site. It was felt that
this area could have been used for waste disposal in the past.
Table #2 shows that residual contaminants in deeper samples are
approximately the same or decrease with depth. Therefore, it
appears that there has been little impact on the subsurface of this
portion of the site from historical operations.
2} Samples collected From Monitor Well Installation. Results
presented in Table #3 for subsurface soil samples collected from
wells D-6, D-7, G-20 and G-21 while constructing new site
monitoring wells show the presence of six residual inorganics above
background concentrations. The wells with multiple samples with
depth show a general trend of decreasing inorganics with depth.
3) Area Near Well G-22. Fifteen soil borings were completed near
well G-22 (see Figure #9 and #14) to evaluate the extent of
apparent subsurface contamination noted while installing the well.
Field results show that the highest organic vapor monitor (OVM)
reading was detected at boring G-22B. A concentration of 268 ppm
was detected by OVM at a depth interval of 11.5 to 12.0 feet. The
potentially contaminated soil did not display visible signs of
contamination, but did have an odor similar to that of a petroleum
product. A second round of borings extending to depths of 15 feet
were augered/vibracored centered around boring G-22B to determine
the lateral extent of contamination. The potentially contaminated
28
-------
// 14
n.o
8-8.5'
- AUGER/V! BRA CORE LOCATION
HIGHEST OVM READING (ppm)
and DEPTH INTERVAL (FEET)
SOIL BORING w/LABORATORY
SAMPLE
AREA OF ELEVATED VOLATILE
ORGANICS READINGS
NOTE: ALL LOCATIONS ARE APPROXIMATE.
AREA OF ELEVATED VOLATILE ORGANICS READINGS NEAR WELL G-22
D.L MUD, INC., SITE, Abbeville, Louisiana -
-------
area was found to be bounded laterally within an area of
approximately 3200 square feet. The potential contamination within
this area was found between the depth interval of 3.0 to 14.0 feet
with the highest organic vapor readings occurring between the depth
interval of 6.5 to 12.5 feet.
Table #4 shows that "source" samples, collected from depth
intervals of highest organic vapor readings, tend to show the
presence of inorganics and organics above background concentra-
tions. Five organics (2-methylnaphthalene, dibenzofuran, fluorene,
naphthalene, and total xylenes) and two inorganics (beryllium and
zinc) are reported above background for all source samples.
Samples collected to bound the vertical and horizontal extent of
contamination were generally found to have concentrations less than
source area sample values for residual inorganics and without the
presence of organic residual contaminants.
4) Area Near Well G-23. Field results indicate that of the fifteen
borings completed near well G-23, the highest OVM reading was
detected at boring G-23E (see Figures #10 and #15). A concentra-
tion of 0.4 ppm was detected by OVM at a depth interval of 2.0 to
2.5 feet. The potentially contaminated soil has a dark brown
appearance. The potentially contaminated area was found to be
bounded laterally within an area of approximately 1000 square feet
and had a peaty nature. Due to the peaty nature of this material,
organic vapor analyzer (OVA) readings could not be used to evaluate
the extent of residual contamination since this instrument
registered the presence of naturally occurring methane. The
vertical extent of the potentially contaminated area was found
between the depth interval of 2.0 to 3.0 feet.
Table #5 shows "source" samples collected from discolored soils
near well G-23 to contain only inorganic residual contaminants
above background values. Of the inorganics, only lead and mercury
were reported above background for all source samples. Antimony,
arsenic, and selenium were reported above background for one or
more samples. Those samples collected to bound the vertical and
horizontal extent of contamination show concentrations of residual
contaminants below source sample values.
5) Area Near SB-30. Fifteen borings were augered/vibracored near
SB-30 to determine the lateral and vertical extent of visible
contamination (see Figures #11 and #16). OVA readings were
detected in all borings near SB-30, with the exception of SB-30.
There were no organic vapors detected by the OVM with the exception
of SB-30.
SB-30 was found to have visible contamination as well as OVA and
OVM readings as high as 660 and 0.9 ppm, respectively. The
potentially contaminated area was found to be bounded laterally
within an area of approximately 7000 square feet. The vertical
extent of the potential contamination was found to range to a depth
30
-------
10 FEET
SCALE
CONCRETE
WELL PAD
Figure ff 15
E4
x
x E5
LEGEND
AREA OF DISCOLORED SOIL
£3
x
- BORING (POSTHOLE) LOCATIONS
E1 _
VI3RACORE LOCATION
© -
SOIL BORING w /LAB ORATORY
SAMPLE
MONITORING WELL LOCATION
NOTE: LOCATIONS ARE APPROXIMATE
AREA OF DISCOLORED SOIL NEAR WELL C-23
D.L. MUD, INC., SITE, Abbeville, Louisiana
-------
Ib
15 30 FEET
SCALE
S8-30
0.9
1-1.5'
VC at 20'
SS-JJ •
o
0-10'
/
0
VC at 10',
P
0
0-3' •
NVC
Ys>
v\
Xj
H
LEGEND
- AUGER/VIBRACORE LOCATION
• SB-31
VISIBLE DISCOLORATION
AT LAND SURFACE
0.4
0-6'
SOIL BORING ^/LABORATORY
SAMPLE
HIGHEST OVM READING (ppm)
and DEPTH INTERVAL (FEET).
NOTES: 1. VD=Visible Discoloration.
2. NVC=No Visible Contamination.
3. LOCATIONS ARE APPROXIMATE.
AREA OF DISCOLORED SOIL NEAR BORING SB-30
D.L. MUD, INC., SITE, Abbeville, Louisiana
-------
of 3.5 feet, with an outcrop of the substance located at land
surface approximately 70 feet southeast of SB-30.
Table #6 shows that selenium and zinc are the only inorganics
reported above background values for all "source" samples. Lead
and mercury are also reported above background values but at lesser r
frequencies. Of the samples collected to bound the vertical and 1
horizontal extent of contamination, reported concentrations of
residual contaminants generally are below those for "source"
samples. [
6) Former Impoundment Area. Six trenches were completed in the
area where six former impoundments were identified by EPA in April j
1992 on an aerial photograph dated 1974 (Figure #13). The approx- |
imate centers of the former impoundments were field located to
coincide with the approximate centers of the impoundments identi- ,
fied on the 1974 photograph. Discolored soil, OVA and OVM readings I
were detected in Trenches 1, 2, and 3. OVA readings ranged to 160 '
ppm in Trench 1, 320 ppra in Trench 2, and greater than 1000 ppm in
Trench 3. OVM readings ranged to 16 ppm in Trench 1, 44 ppm in :
Trench 2 and 43 ppm in Trench 3. Trenches 3, 4 and 5 showed no '
signs of discolored soil.
Based on the 1974 aerial photograph and the results of trenching
and boring activities in and around the impoundment area, the
potentially contaminated area is estimated to be bounded laterally
within an area of approximately 9600 square feet (see Figure #12).
The vertical extent of the potential contamination was found to
range from 3 to 8 feet.
Table #7 shows that the three trench "source" samples have residual
contaminants that include three organics (2-methylnaphthalene,
phenanthrene and total xylenes) and four inorganics (lead, mercury,
sodium and zinc) reported above background values for all source
samples. Lead, mercury and zinc were reported above background
values for all source samples. The vertical extent of
contamination in these three former impoundments was bounded by
deeper soil samples that generally have reported values below
background and source sample concentrations.
The above sampling results for this area were based on samples
collected by Dow/DSI. During this sampling effort, EPA also
collected samples from the trenched former impoundments. Almost
exclusively, all results from EPA's sampling contained higher
results than those reported above. In addition, EPA identified
numerous Tentatively Identified Compounds (TICs) with
concentrations as high as 762,300 ppb. Due to the disparate
sampling results, it has been determined that a full and accurate
characterization of the contamination in this area has not been
completed.
33
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Composite samples collected from Trenches 4, 5, and 6 show that
subsurface samples from these areas do not exceed background
concentrations for any residual contaminant.
Ground Water
A total of twelve onsite ground water monitoring wells were sampled
as part of the RI (Figure #17). There were five existing wells (D-
1,2,3,4,5), three new wells installed by Dow/DSI in 1990 (D-6,7,8),
and four new wells installed by EPA in 1991 as part of the RI
activities for the GCVS site (G-20,21,22, 23). Monitoring well D-8
was placed in the lower portion of the site and was used as the
background well.
The statistical analysis of onsite and background ground water data
did not identify any residual contaminants. However, certain
samples were found to contain parameters above maximum contaminant
levels for drinking water (MCLs). Table #8 shows that 3 inorganics
(chromium, lead, selenium) and two organics (bis(2-
ethylhexyl)phthalate, methylene chloride) were reported above MCLs.
The presence of the organic compound bis(2-ethylhexyl)phthalate is
attributed to field contamination. This compound is typically
introduced from protective gloves used by sampling personnel. This
determination is consistent with the analytical data that show that
this compound was not detected above background concentrations
consistently over multiple sampling episodes.
The presence of total chromium above background concentrations and
MCLs was shown to be the result of collection and analysis of
turbid ground water samples. This was shown by the use of a low
disturbance sampling methodology employed to collect samples
considered representative of the aquifer. The low chromium concen-
trations obtained using this more representative sampling method
are directly related to low total suspended solids and turbidity
measurements that result when using a low disturbance sampling
procedure.
In addition to total chromium and bis(2-ethylhexyl)phthalate, lead,
selenium, and methylene chloride were reported to be above MCLs.
As discussed previously, the presence of total chromium and bis(2-
ethylhexyl) phthalate are attributable to turbid samples and field
contamination, respectively. All detections of methylene chloride
have associated contamination of the laboratory sample blanks. All
lead and selenium data (with the exception of lead in background
well D-8) were generated from only one sampling episode (four
samples out of a total of sixteen) conducted by EPA as part of the
GCVS investigation. These data were estimated at low
concentrations and also had laboratory quality assurance qualifiers
attached to the data due to control limit problems with the
analysis of associated matrix spike samples. Therefore, the
34
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3-6-92
MGM28796.DO
Figure #17
0 300'
APPROX. SCALE
APPROXIMATE
SITE BOUNDARY
NORTHERN SITE FENCE
PARISH ROAD P-7-31
NOTE: LOCA TIONS ARE APPROX1MA 7E
LEGEND
• - WELL LOCATION
MONITORING WELL LOCATIONS
D.L.1 MUD, INC.. SITE, Abbeville, Louisiana
£»••;?,', KIHt
-------
presenceof lead, selenium and methylene chloride above MCLs is not
considered to be indicative of ground water contamination.
Surface Water and Sediment
Surface water and sediment sampling activities were conducted to
evaluate potential impacts of the site on surface water quality and
sediment characteristics. Both onsite and background samples were
collected to assess these impacts. Onsite surface water samples
were collected during or soon after rainfalls in December 1990 and
January 1991. During the RI, onsite surface water was present only
after heavy rains.
Nine surface water and nine sediment samples were collected in
December, 1990 at the general locations shown on Figures #5 and
#18. Four of these sample pairs (SW/SD-1, 2, 3, and 4} were
initially considered background samples. However, the use of
sample location SW/SD-2 was later changed from background to onsite
due to the proximity of the GCVS site to this location.
Five onsite surface water samples (SW-5, 6, 7, 8, and 9) were
resampled in January 1991. An additional onsite sediment sample
(SD-6A) was collected during this period. In April 1991, four
additional background sediment samples were collected (SD-10, 11,
12 and 13).
The background locations were coordinated with the local Agricul-
tural Stabilization and Conservation Service (ASCS) representative
to locate areas with similar soil types and land uses. Samples
SW/SD-l and SW/SD-2 were collected from abandoned irrigation
canals. Background sample pairs (SW/SD-3 and 4) and background
sediment samples (SD-10, 11, 12 and 13) were collected from a
nearby drainage ditch located upstream of surface runoff from the
site.
Sample pairs SW/SD-5 and 7 were collected from the abandoned
irrigation canal that crosses the D.L. Mud site. Sediment sample
SD-6A was also collected from this abandoned canal. The impact of
the GCVS discharge on existing site drainage was evaluated with
sample pairs SW/SD-6 and SW/SD-8 which are located upstream and
downstream, respectively, of the GCVS discharge. Sample pair
SW/SD-9 was collected from the abandoned irrigation canal southeast
of the former facility process area.
During the ninth sampling event, EPA's oversight contractor
identified a drum in the onsite canal. Figure #18 shows the
location of the drum. In March, 1992, one sediment sample was
collected from the drum. This sample was collected only to
characterize a potential waste for disposal. Therefore, EPA
Contract Lab Program protocol was not utilized and no duplicates,
spikes or equipment rinsate samples were collected. The contents
36
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Figure #18
PARISH ROAD P-7-31
GULF COAST
VACUUM SERVICE
SW/SD1
=^l
20' CANAL
NORTHERN SITE FENCE.
DRUM LOCA TION
D.L MUD,
INC., SITE
APPROXIMA TE
SITE BOUNDARY
/S77E SURFACE WA TER/ SEDIMENT SAMPLES
D.L. MUD, INC., SITE. Abbeville, Louisiana
-------
of the drum were found to be non-hazardous. The drum was later
disposed-of as a non-hazardous solid waste.
Surface water sampling results indicate that calcium in onsite
surface water was determined to be the lone residual contaminant
(significantly above background values), while barium, lead, and
bis(2-ethylhexyl)phthalate were reported above MCLs. Seven
inorganics (arsenic, chromium, copper, lead, nickel, silver and
zinc) were reported at concentrations above federal ambient water
quality criteria (AWQC). Table #9 presents a summary of these
onsite surface water results. The organic compound bis(2-ethylh-
exyl)phthalate is a common sampling and laboratory contaminant and
was not used at the site during its operational history. The three
samples noted to contain this compound were also noted as having
data qualifiers since this compound was also detected in the
laboratory blank and the laboratory had instrument calibration
problems during analysis of these samples.
Both barium and lead were detected above MCLs on one occasion at
each of two locations (SW-6 and SW-8). Concentrations reported at
SW-8 are greater than those reported at SW-6. Resampling showed
both compounds at both locations to be below MCLs. Both locations
that were affected are located in a drainage swale downstream of
the former facility process area, with SW-8 located downstream of
SW-6. The presence of calcium above background values is more
widespread and tends to repeat for sequential sampling events.
Acute freshwater AWQC for copper and zinc were exceeded at all
onsite sample locations except SW-2 and by the maximum measured
background concentration. Acute AWQC for lead was exceeded only at
SW-8; while the AWQC for silver was exceeded at SW-5, SW-8 and SW-
9. Chronic freshwater AWQC for copper and zinc were exceeded for
all onsite locations except SW-2 and by background. All locations
and background exceeded the chronic AWQC standards for lead.
Comparison of onsite data to background and MCL values indicates
that there may be some residual inorganic impact on surface waters
originating in the former process area and that the GCVS discharge,
located upstream of the SW-8 location, may also have contributed to
this contamination. Exceedances of AWQC standards are more wide-
spread, but in general, similar impacts are shown by the acute AWQC
standards. Chronic AWQC exceedances are typical for all (onsite
and background) values.
Table #10 shows that analytical results for sediment residual
contaminants are similar to those presented earlier for surface
water. Residual contamination appears limited to inorganics; no
organics were noted above background. No concentrations above
background were noted for sample SD-7 for any analyte.
The extent of residual contamination at SD-5 and SD-6A is limited
because of their location within diked areas. Results for SD-6 and
SD-8 may reflect the impacts of previous facility operations, or
38
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the impact of the GCVS site discharge, since these samples were
collected from a drainage pathway downstream of the former location"
of storage and blending tanks and the GCVS discharge is located I
upstream of location SD-8. Concentrations of residual contaminants I
are higher at SD-8 than at the upstream location SD-6. The value
reported at SD-9 for copper is marginally above the maximum i
background value of 22.6 mg/kg. j
EXPOSURE ROUTES
The potential migration routes of residual contamination are ground '
water, surface water, and air. Airborne contaminants are not
expected to be of concern for this site because of the nature of
residual contaminants and the relatively low concentrations. In
addition, the site cover, lack of disturbance, and relatively high
moisture of the area help to minimize soil disturbance and the
creation of aerosols.
The potential for migration of contaminants from the site is
affected by two important hydrogeologic factors:
• The site soils are generally very low in permeability,
and have medium values of organic content and cationic
exchange capacity.
• The general ground water flow direction is to the north,
with a low gradient and localized mounding resulting from
large impoundments on the GCVS site.
Although the ground water pathway is considered to be a potential
route of contaminant migration (such a situation already apparently
exists at the adjacent GCVS Superfund Site), the low permeability
of the soils tends to minimize vertical migration of contaminants
from surface soil, subsurface soils, sediment, and surface water
into the underlying ground water. These soils typically extend to
depths of 30 feet, although a lens of silty sand was identified
along the D.L. Mud and GCVS site property line at depths of
approximately 20 feet below ground surface. Since the greatest
soil depth noted to contain residual contaminants is approximately
ten feet, a minimum of ten feet of native soil is present to
mitigate contaminant transport to ground water. The relatively
insoluble nature of the main residual contaminant in surface soils
(barium sulfate) minimizes its potential for transport while the
soil characteristics (medium cation exchange capacity and organic
contents) tend to induce adsorption of other residual contaminants,
thereby further retarding migration potential. It is more
difficult to predict the potential for migration of contaminants
identified in the former impoundment areas because the types and
concentrations of these contaminants has not been fully
characterized.
39
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Since the ground water flow is northerly, contaminants, if intro-
duced into the aquifer, could be transported in that direction.
With a relatively low potentiometric gradient and flow rate of only
22 feet per year, site contaminants would take over one hundred
years to reach the closest receptor, since the nearest active
ground water well north of the D.L. Mud site is approximately one-
half mile away. In that period of time, contaminants could be
expected to be diluted by ground water dispersion, adsorbed to soil
structure, or degraded by physicochemical or biological activity to
a large extent. Both the D.L. Mud RI report and the GCVS RI report
(EPA, 1992) show ground water mounding beneath the GCVS site that
results in ground water flow from the GCVS impoundments toward the
D.L. Mud site. This mounding further retards the movement of
ground water from the D.L. Mud property to potential receptors.
The surface water pathway is also considered to be a potential
route of contaminant migration. Site surface water runoff is to
localized ditches, which is indicated by the presence of site-
related contaminants in sediments in these ditches. However, the
ditches are contained by levees that limit lateral migration of
water and sediment borne contaminants. In addition, the evapot-
ranspiration rate approximates rainfall, which prevents buildup of
surface water, as evidenced by intermittent water in the ditches
during the RI. Further, the residual contaminant and soil
characteristics described above (insoluble nature, low permeabil-
ity, medium cation exchange capacity and total organic carbon
values and soil depth) assist in impeding the vertical migration of
potential contaminants from the sediments and surface water to
ground water.
Under current site conditions, there are no people who live or work
onsite. Therefore, a trespasser is the most representative of the
population most likely to be exposed onsite under current
conditions. Potential exposure would be from direct contact,
ingestion, and inhalation of site contaminants.
Future land use assumptions are based on two important factors.
First, because the site is presently an abandoned light-industrial
use facility, with no human inhabitants and located next to the
GCVS Superfund Site, it seems reasonable that this type of land use
will continue. Second, because there are currently no land use
restrictions affecting this property and residential areas are
located nearby, it is possible that the property could be used as
a residential location in the future.
VI. SUMMARY OF SITE RISKS
A baseline risk assessment (BRA) was conducted to analyze the
potential adverse health effects (both current and future)
resulting from human exposure to hazardous substances in surface
soil, subsurface soils, sediment, ground water and surface water at
40
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the D.L. Mud site. The BRA provides the basis for taking action
and indicates the exposure pathways that need to be addressed by
the remedial action. It serves as the baseline indicating what J
risks could exist if no action were taken at the site. This '
section of the ROD reports the results of the BRA conducted for
this site. (
By definition, a BRA evaluates risk under the no-action alternative
(that is, in the absence of any remedial actions to control or ,
mitigate releases or exposures). The BRA for this site was J
prepared utilizing data from the RI. The methods used in the '
development of the risk assessment are based on general EPA
guidance (Office of Emergency and Remedial Response. Risk J
Assessment Guidance for Superfund. Vol. I. Human Health Evalua- J
tion Manual (Part A). 1989. also known as "RAGS"), the NCP, and in
accordance with site-specific guidance developed by Region VI. In i
addition, an environmental risk assessment was conducted to j
evaluate risks to environmental species. These reports can be
found in the Administrative Record.
CHEMICALS OF POTENTIAL CONCERN
The nature and extent of inorganic and organic chemical constitu-
ents (lOCs) identified in the site media are discussed in Section
V. of this ROD. Chemicals detected in low frequency were not
considered to be representative of the nature and extent of
residual contamination at the site. However, all lOCs identified
in the site media were used to assess total site risk. Factors
such as frequency of detection as well as nutritional benefit and
comparisons with background concentrations were not initially
considered when developing the list of chemicals of concern (COCs)
for use in the BRA. The influence of these factors on the
assessment of total site risk is discussed in the uncertainty
section. Since risks associated with identified TICs are difficult
to evaluate, they are not included in the quantitative assessment
of total site risk. However, a qualitative discussion of TICs
identified at the D.L. Mud site is presented below in the
uncertainty subsection.
Table #11 presents the descriptive statistics (e.g., minimum and
maximum detected value, mean estimation, upper confidence limit) of
the lOCs detected on the site and in the background for the
following media:
Onsite ground water
Onsite surface water
Onsite surface soil
Onsite sediment
Onsite subsurface soil (non-"source" areas)
Onsite source area near Well G-22 (subsurface soil)
Onsite source area near Well G-23 (subsurface soil)
Onsite source area near boring SB-30 (subsurface soil)
41
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.. Onsite impoundment area (subsurface soil)
Background ground water
Background surface water
Background surface soil
Background sediment
An exposure point concentration (used for risk calculations) is the
arithmetic mean concentration of a chemical in a medium, averaged
over the area in which exposure is expected to occur. Because of
the uncertainty associated with the exposure point concentrations,
the upper 95th confidence limit of the arithmetic mean (UCL95) is
generally used to provide a degree of conservatism. If the
calculated value of the UCL95 exceeded the maximum value used to
calculate the UCL95 at an exposure point, then the maximum value
(rather than the UCL95) was used. Chemicals which were analyzed
for but not detected in a sample at a level higher than the normal
detection limit were labeled as "undetected". For purposes of
calculating exposure point concentrations, if a chemical was
detected at least once in a medium, the chemical was assumed to be
present in all samples of that medium, and non-detects were
evaluated using one-half the "undetected" value.
EXPOSURE SCENARIOS EVALUATED
The D.L. Mud site exposure assessment (and subsequent baseline risk
assessment) is based on the assumption that no further response
actions are performed at the site and on the conservative
assumption that unrestricted use of the site and its resources by
adults and children is permitted. A potential current use exposure
involving a trespasser is evaluated. Future use scenarios
involving residential (includes agricultural use) and occupational
use of the site are evaluated.
The D.L. Mud site is located in a rural area. Surrounding land use
is generally agricultural, although residences are located within
one mile of the site. It is estimated that up to 116 people live
within the one mile study area surrounding the site. No threatened
or endangered species have been reported in the study area.
Exposure pathway evaluations were made on the basis of site
history, analytical results of the onsite and background samples,
and exposure setting. These evaluations are presented in Table
#12. Ground water, surface water, surface soil, sediment, and
subsurface soil are considered the five potential secondary sources
of exposure to residual contaminants. Subsurface soil is evaluated
based on division into five areas of assessment: (a) four
subsurface soil "source areas" which are areas of visible
contamination and/or positive organic vapor readings (1. located
near Well G-22; 2. located near Well G-23; 3. located near boring
SB-30; 4. located in the former impoundment area) and (b) other
subsurface soil samples without source area characteristics. A
tertiary source of exposure to residual contaminants considered is
42
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agricultural products (root and leafy vegetables, beef, and milk '
potentially contaminated by ground water and soil).
The routes of exposure considered are ingestion, dermal absorption, I
and inhalation. Under the current use scenario, incidental
ingestion of surface soil and sediment by a trespasser is r
evaluated. Dermal absorption of contaminants from surface water, j
surface soil, and sediment by the trespasser receptor is also
quantitatively assessed.
Ingestion of ground water, surface soil, sediment, and subsurface '
soil is quantitatively assessed for the residential adult,
residential child, and occupational adult receptors. Ingestion of I
agricultural food products is quantitatively assessed for the j
residential receptor. Incidental ingestion of surface water is not
considered because it was assumed that surface water conditions ,
(mainly lack of water depth) preclude swimming. Dermal absorption j
of contaminants from ground water, surface water, surface soil, '
sediment, and subsurface soil by the residential and occupational
receptors is also quantitatively assessed. {
The magnitude of human exposures to the contaminants at the D.L.
Mud site is described as the potential dose or intakes by each
receptor. In general, standard exposure factors, as defined in the
Human Health Evaluation Manual. Supplemental Guidance; Standard
Default Exposure Factors fOSWER Directive 9285.6-03). were used for
this determination. In addition, variability among individuals
usually leads to a wide distribution of intake values. In most
cases, input variables in the risk equation were chosen so that the
resulting intake is about equal to the 95th percentile of the dose
distribution curve. This is referred to as the Reasonable Maximum
Exposure (RME). For future residential populations, the variables
were also chosen to estimate the average (AVG) intake (about the
50th percentile of the distribution). This approach, commonly re-
ferred to as the "central tendency", provides a range of risk
estimates, AVG to RME, for future residential exposures.
A central tendency exposure (CTE) is required for risk assessments
and was to be included in the assessment of the hypothetical future
residential child. However, using Region 6 exposure variables, the
CTE and RME would be identical for soil ingestion by a child. Both
the RME and CTE are the same for a child because both exposure
assessments utilize a soil ingestion rate of 200 mg/day due to a
lack of information indicating more appropriate values.
TOXICITY ASSESSMENT
The purpose of the toxicity assessment was to weigh available
evidence regarding the potential for contaminants to cause adverse
effects in exposed individuals. The toxicity assessment involved
two steps: hazard identification and dose-response assessment. The
hazard identification determined whether exposure to a chemical
43
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could cause an increase in the incidence of a particular adverse
health effect (carcinogenic or noncarcinogenic) and whether an
adverse health effect would likely occur in humans. The second
step, dose-response assessment, quantitatively evaluated the
toxicity information and characterized the relationship between the
dose of the chemical received and the incidence of adverse health
effects in the exposed population.
Toxicity values (i.e.. reference doses for non-carcinogens and
slope factors for carcinogens) are used in the risk characteriza-
tion to estimate the likelihood of adverse effects occurring in
humans at different exposure levels and are specific to exposure
routes. The EPA has established a weight-of-evidence classifica-
tion system for carcinogens as follows:
* Group A - Human carcinogen
* Group Bl or B2 - Probable human carcinogen; Bl indicates that
limited data are available and B2 indicates sufficient
evidence in animals and inadequate or no evidence in humans
* Group C - Possible human carcinogen
* Group D - Not classifiable as to human carcinogenicity
* Group E - Evidence of noncarcinogenicity for humans
Slope factors ("SFs") have been developed by EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risks
associated with exposure to potentially carcinogenic contaminant (s)
of concern. SFs, which are expressed in units of (mg/kg-day)"', are
multiplied by the estimated intake of a potential carcinogen, in
mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake level.
The term "upper bound", reflects the conservative estimate of the
risks calculated from the SF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely. SFs are
derived from the results of human epidemiological studies or
chronic animal bioassays to which animal-to-human extrapolation and
uncertainty factors have been applied (e.g. . to account for the use
of animal data to predict effects on humans).
Reference doses ("RfDs") have been developed by EPA for indicating
the potential for adverse health effects from exposure to
contaminant(s) of concern exhibiting noncarcinogenic effects.
RfDs, which are expressed in units of mg/kg-day, are estimates of
lifetime daily exposure levels for humans, including sensitive
individuals. Estimated intakes of contaminant(s) of concern from
environmental media (e.g.. the amount of a contaminant(s) of
concern ingested from contaminated drinking water) can be compared
to the RfD. RfDs are derived from human epidemiological studies or
animal studies to which uncertainty factors have been applied
(e.g. . to account for the use of animal data to predict effects on
humans).
44
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Of the-residual contaminants identified in one or more samples '
collected from the D.L. Mud site, eleven are considered carcinogens
when exposed orally and twelve are considered carcinogens when j
exposed through inhalation. Table #13 lists the chemical |
carcinogens for the oral and inhalation exposure routes and
provides their weight-of-evidence classification. i
Noncarcinogenic health effects include a variety of toxic effects
on body systems ranging from renal toxicity (toxicity to the
kidney) to central nervous system disorders. Noncarcinogenic I
health effects fall into two basic categories: acute toxicity and '
subchronic and chronic toxicity. Acute toxicity occurs after a
single exposure (usually at high doses) , and the effect is seen I
immediately. Chronic toxicity occurs after repeated exposure ]
(usually at low doses), and the effect is seen weeks, months, or
years after the initial exposure.
Chemicals causing noncarcinogenic effects (e.g., systemic toxins)
also exhibit levels of exposure that can be tolerated by organisms
without causing an observed health effect. It is believed that
organisms have adaptive mechanisms that must be overcome before a
toxic effect is manifested. Table #14 provides a summary of the
characteristic noncarcinogenic effects and lists available RfD
values and confidence categories for all verified RfDs for all of
the chemicals of concern at the D.L. Mud site.
RISK CHARACTERIZATION
Human Health Risk
The risk of cancer from exposure to a chemical is described in
terms of the probability that an individual exposed for his or her
lifetime will develop cancer. Typically, cancer risks of IxlO"6
(one in a million) or lower are considered to be so small that they
are of no practical concern. Higher cancer risk levels may be
cause for concern, and EPA typically requires site remediation if
risks exceed IxlO"4.
Evaluation of noncarcinogenic risk is accomplished by comparing a
calculated intake with an acceptable intake for each chemical and
for each pathway that contributes to a population's exposure. The
ratio of the calculated intake versus the acceptable intake is
termed the Hazard Index (HI). The HI is calculated by adding
chemical-specific Hazard Quotients (HQs). An HI of 1.0 or more
shows an intake greater than the acceptable level and indicates the
need for remedial action.
The likely effect of exposures to lead contamination was estimated
using EPA's Uptake/Biokinetic model (UBK). The UBK model predicts
mean blood levels associated with multimedia exposure levels that
are defined as site-specifically as possible. A significant amount
of information is present in the scientific literature that
45
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provides evidence of exposure-effect relationships extending to
blood levels of 10 to 15 Mg/dL in infants and young children.
Using 10 M9/dL as a cutoff value, EPA has determined that it is
desirable to have no more than five percent of the exposed
population exceeding this level of concern. The UBK model used to
assess risk from lead is restricted to the evaluation of a child in
a residential setting, since a child is significantly more
sensitive to the toxic effects of lead than an adult.
The following discussions summarize potential site risks by medium.
Table #15 presents the carcinogenic risks and lists the chemicals
primarily responsible for the risks for onsite and background
exposures. Tables #16 presents potential noncarcinogenic health
hazards and lists the chemicals (and their HQs) primarily
responsible for the His.
Risks from Surface Soil - Health risks related to direct contact
(or dermal absorption) of contaminants from surface soil adhering
to exposed body surfaces were assessed. The excess lifetime cancer
risks for onsite and background dermal exposures are similar for
all receptors evaluated. The His for onsite and background dermal
exposures are less than 1.0 for all receptors.
Incidental ingestion of surface soil was assessed for residential
adults and children based on soil ingestion rates of 0.1 and 0.2
grams per day, respectively, and for a trespasser and occupational
adults based on a rate of 0.05 grams per day. The conservative
assumption is made in assessing total site risk that soil residual
contaminants ingested by the human receptors are absorbed by the
body with the same efficiency as chemicals dissolved in aqueous
solution. The excess lifetime cancer risks related to incidental
ingestion of surface soil are similar for onsite and background
exposures for all receptors evaluated. The HI estimated for
incidental ingestion of surface soil exceeds 1.0 for the
residential child (3.8) and adult (4.2) onsite exposures. These
His are dominated by the barium HQ calculated for the residential
child exposure. The HI for incidental ingestion of soil by a
trespasser and an occupational laborer is less than 1.0.
Risks from Subsurface Soils - Subsurface soil was evaluated based
on division of the site into five areas for assessment: four
subsurface soil contaminant "source areas" ("source area 1" or G-22
samples, "source area 2" or G-23 samples, "source area 3" or SB-30
samples, and "source area 4" or former impoundment area samples),
which are areas of visible contamination and/or positive organic
vapor readings (Figure #7) and all other subsurface soil (those
samples without source area characteristics). Risks from sub-
surface source areas were based on the ratio of the source area to
a typical rural residential lot size in the general area of the
Site, such as the small subdivision located southeast of the D.L.
Mud Site. Lots in this subdivision are approximately one acre in
size. Therefore, an acre weighted risk (AWR) method is employed to
46
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characterize risk associated with exposures to the source areas.
Risk is weighted according to square footage of the source area and
its area percentage to a typical one acre residential plot in the
area of the Site.
The AWR cancer risks for incidental ingestion and dermal absorption
of contaminants ranged from 3xlO"5 to 3xlO"6 for all the source areas
for all three receptors evaluated. Cancer risks in subsurface soil
source areas 1 through 4 exist primarily because of low levels of
arsenic and beryllium. Cancer risks for incidental ingestion and
dermal absorption of contaminants in nonsource area subsurface
soils range from 3xlO"5 to 3xlO"6 for all three receptors evaluated.
Non-cancer His for incidental ingestion and dermal absorption of
contaminants from nonsource area subsurface soil are less than 1.0
for all three receptors evaluated. The non-cancer AWRs for
incidental ingestion and dermal absorption of contaminants by the
residential child and the occupational adult are less than 1.0 for
all source areas. For the residential adult, the non-cancer AWRs
for incidental ingestion and dermal absorption of contaminants are
less than 1.0 for source areas 1, 2, and 3; however, for source
area 4 the non-cancer AWR is equal to 1.0 for an ingestion
exposure. In this instance, the residential adult's non-cancer AWR
is primarily due to 6-year ingestion exposure to barium during the
adult's childhood, which results in an HQ of 0.9.
It should be noted that the risk calculation for the former
impoundment area (source area 4) was calculated using data
collected by Dow/DSI during the RI. As mentioned earlier, EPA
split data from this area differed significantly and it is expected
that the use of this data would result in higher overall potential
risk than calculated. In addition, the fact that no specific risks
were quantified in any of the obviously contaminated subsurface
areas related to the former impoundment areas or near SB-30 is
further questioned due mainly to the lack of specific information
regarding the nature and concentration of individual contaminants
that are present. For example, the TICs identified in these areas
are reportedly high molecular weight aliphatic hydrocarbons that
may be associated with crude oil, but individual compounds could
not be identified with the routine chemical analysis methods that
were used during the remedial investigation. The TIC concentra-
tions of most concern are located in the area associated with the
former impoundments. The number, concentration, and depth of these
hydrocarbons pose a greater potential risk to the ground water than
those found near SB-30.
Risks from Ground Water - Excess lifetime cancer risks from ground
water ingestion and dermal absorption were the same for onsite and
background exposures for the adult residential receptors. The
cancer risks for ground water ingestion and dermal absorption by
the residential child onsite are equal to the background risk.
Excess lifetime cancer risks from ground water ingestion and dermal
47
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absorption were the same for onsite and background exposures for
the adult occupational receptors. In all ground water ingestion
scenarios, both onsite and background, the cancer risk exists
because of low levels of arsenic.
The HI exceed 1.0 for onsite and background ground water ingestion
exposures for all receptors evaluated (residential adult, resi-
dential child, occupational laborer). The HQs of antimony,
arsenic, and thallium are the major contributors to the HI for both
onsite and background ground water ingestion by a residential adult
and to the HI for both onsite and background ground water ingestion
by an occupational adult. The HQ of antimony, arsenic, manganese,
thallium, and barium are the major contributors to the HI for both
onsite and background ground water ingestion by a residential
child. The noncarcinogenic HI is significantly less than 1.0 for
onsite and background exposures related to dermal absorption from
ground water for all receptors evaluated.
Risks from Sediments - Health risks related to dermal absorption of
contaminants from sediment adhering to exposed body surfaces were
assessed. Excess lifetime cancer risks are less than 10"6 for
onsite and background exposures for all receptors evaluated. The
noncarcinogenic hazard index is significantly less than 1.0 for all
dermal absorption of contaminants in sediment scenarios.
Incidental ingestion of sediment is assessed for adults and
children based on soil ingestion rates of 0.1 and 0.2 grams per
day, and for a trespasser and occupational adults based on a rate
of 0.05 grams/day. Excess lifetime cancer risks are less than 10"6
for onsite and background exposures for all receptors evaluated.
The noncarcinogenic hazard index is significantly less than 1.0 for
all incidental ingestion of residual contaminants in sediment
scenarios.
Cumulative Carcinogenic And Noncarcinoqenic Risks - The excess
lifetime cancer risks and hazard indices are summed across pathways
to provide an estimate of total carcinogenic and noncarcinogenic
risks at the site based on current trespasser exposures (Table
#17) , future residential exposures (Table #18) and future
occupational exposures (Table #19). When totaling the residential
and occupational scenarios, the greatest subsurface soil risk
values were chosen from among the source and nonsource areas for
the summation.
The cumulative cancer risk for trespasser exposures onsite is equal
to the cumulative cancer risk from background exposures. The
cumulative HI for occupational laborer exposures onsite is equal to
the cumulative HI for background exposures. The cumulative cancer
risk for residential adult exposures onsite is equal to the
cumulative cancer risk from background exposures.
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The cumulative HI for residential adult exposures onsite is greater-
than the cumulative HI for background exposures. Both onsite and
offsite cumulative His are dominated by potential risks associated
with the ingestion of ground water and surface soil. The onsite
ground water risk was associated with a single detection of
antimony and the surface soil risk is associated with the presence
of residual barium.
Cumulative cancer risk for the child receptor is the same onsite as
for background exposures, at an estimate of 10'4. The child
receptor's cumulative HI exceeds the background cumulative HI. The
cumulative HI estimated for the onsite exposures potentially
incurred by a child receptor is dominated by the ground water
ingestion exposure route (due to the single antimony detection) and
is influenced to a lesser extent by the incidental ingestion of
surface soil exposure route (due to elevated residual barium
concentrations).
The cumulative cancer risk for occupational exposures onsite is
equal to the cumulative cancer risk from background exposures. The
cumulative HI for occupational laborer exposures onsite is greater
than the cumulative HI for background exposures. Both cumulative
His are dominated by ingestion of ground water (due to the single
antimony detection).
Uncertainties Associated With The Human Health Risk Calculation
There are a number of stages in the risk assessment process where
precise evaluations are not possible. These include uncertainties
regarding the true concentrations of chemicals in environmental
media, the amount of contaminants taken in by humans and the likely
health consequences of the resulting exposure. Risk assessment as
a scientific activity is subject to general and site-specific
uncertainty. General uncertainty is related to the discipline of
risk assessment. Site-specific uncertainty is related to the area
being assessed. Table #20 lists general and site-specific
uncertainties, respectively, for D.L. Mud site risk assessment.
This assessment was also subject to uncertainties related to the
following items:
TICs
Identification of substances used to assess risk.
Toxicological assessment
Bioavailability
Exposure estimation
Risk characterization
Split sampling results from the former impoundment area indicated
the presence of a large concentration of TICs. The majority of the
TICs are substituted benzenes and naphthalenes which are generally
eye and skin irritants. Because the identities and concentrations
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of the TICs are uncertain and the fact that they do not have
associated toxicity factors (such as slope factors and RfDs),
inclusion of these compounds in the quantitative risk assessment is
not possible.
Other specific uncertainties that have significantly impacted the
D.L. Mud risk assessment center on the use of the subchronic RfD
for barium. Scientific debate continues regarding the merit of the
existing subchronic RfD. For the purposes of this risk assessment,
it has been decided to use the existing value in HEAST until such
time that a final determination is rendered on the use of a
different value if appropriate.
As noted in Table #20, some of these limitations may lead to an
underestimate of risk, some are more likely to overestimate than
underestimate risk and some introduce uncertainty that may either
overestimate or underestimate risk. Consequently, the quantitative
risk estimates derived for this site should be considered
approximate, with a significant range of uncertainty and should be
considered in risk management decisions.
Environmental Assessment
The ecological assessment was limited because of existing land use
patterns and because the Environmental Assessment at the
neighboring GCVS site estimated a minimal impact on the environment
while possessing significantly worse contamination problems.
The site is coastal prairie with some mixed hardwoods near the
canals. It is considered "prior converted cropland" and is not a
jurisdictional wetland. The site is industrial, and the surround-
ing area is a mixture of residential, agricultural, and industrial
development. Aquatic and terrestrial organisms would experience
minimal exposure, because they avoid highly developed areas and
because more suitable habitat is abundant nearby.
No listed or proposed threatened or endangered species have been
found within one mile of the site. Aquatic and terrestrial organ-
isms could be affected by direct contact with or ingestion of soil
and sediment in isolated areas. There could be impacts to biota
exposed to site surface water. However, the impacts would probably
be minimal because site surface waters are intermittent and would
produce limited exposures.
Risk Assessment Summary
The results of the Risk Assessment indicate that actual or
threatened releases of hazardous substances from the D.L. Mud Site,
if not addressed by the preferred alternative or one of the other
active measures considered, may present a current or potential
threat to public health, welfare, or the environment. These
50
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threats are identified as the calculated noncarcinogenic risk to
future residents from total barium in surface soils and to unknown
risks potentially associated with the visually contaminated
subsurface soils.
REMEDIAL ACTION OBJECTIVES AND GOALS
CERCLA and the NCP define remedial action objectives (RAOs) that
are applicable to all Superfund sites. They relate to the
statutory requirements for development of the remedy. Site-
specific remediation goals relate to specific contaminated media
and potential exposure routes and are used to identify target areas
of remediation and contaminant concentrations. Site-specific
remediation goals require an understanding of the contaminants in
their respective media and are based upon the evaluation of risk to
the public health and the environment and applicable or relevant
and appropriate requirements (ARARs). These remediation goals are
as specific as possible without unduly limiting the range of
alternatives that can be developed for detailed feasibility
evaluation.
The statutory scope of CERCLA was amended by SARA in 1986 to
include:
• Refinement of goals for the degree of remedial action
cleanup in that remedial actions "shall obtain a degree
of cleanup of hazardous substances, pollutants, and
contaminants released into the environment and of control
of further releases at a minimum which assures protection
of human health and the environment" (Section 121 (d)).
• Preference for remedial actions "in which treatment that
permanently and significantly reduces the volume,
toxicity, or mobility of the hazardous substances,
pollutants, and contaminants is a principal element"
(Section 121(b)). The lead agency must publish an
explanation if a permanent solution using treatment or
recovery technologies to the maximum extent practicable
is not selected.
• Requirements that the selected remedy comply with or
attain the level of any "standard, requirement, criteria,
or limitation under any Federal environmental law or any
promulgated standard, requirement, criteria, or
limitation under a State environmental or facility citing
law that is more stringent than any Federal Standard,
requirement, criteria, or limitation" (Sec-
tion 121(d)(2) (A)) .
In the NCP, 40 C.F.R. §300.430(a)(1)i, EPA explicitly defines the
national objective, management principles, and expectations of the
CERCLA program. The national objective of the CERCLA remedy
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selection process is to "select remedies that are protective of
human health and the environment, that maintain protection over
time, and that minimize untreated waste."
EPA identified six general expectations to be considered in
developing appropriate remedial alternatives in the CERCLA program:
• The use of treatment wherever practicable to address
principal threats.
• The use of engineering controls (e.g., containment) for
waste that poses a relatively low long-term threat or
where treatment is impracticable.
• The use of the appropriate combination of treatment with
engineering and institutional controls to achieve
protection of human health and the environment.
• The appropriate use of institutional controls to sup-
plement engineering controls for short- and long-term
management to prevent or limit exposures.
• The use of innovative treatment technologies when such
technologies offer potential for comparable or superior
performance, lesser adverse effects, or lower cost.
• The return of ground water to usable, beneficial use
wherever practicable within a reasonable period. Where
restoration of ground water is impracticable, prevention
of further plume migration, prevention of exposure, and
further evaluation of risk reduction will be expected.
The studies undertaken at the D.L. Mud Site have identified low
level risks which require remedial actions. Low level risk
materials are sources of contamination that could be kept in place
by capping and pose a low risk. For example, the surface soils
identified onsite with residual elevated levels of barium
contamination are considered a low level risk because the associ-
ated risk is relatively low (less than an order of magnitude in
comparison to accepted action levels) and because these residual
contaminants could be kept in place with a capping remedy, thus
eliminating the potential for migration or ingestion.
In addition, EPA has determined that there is an unknown potential
risk -related to the source materials identified in the subsurface
soils in the former impoundment areas. This potential risk is
related to the unknown capacity for these contaminants to migrate
into the ground water and the unknown impact these contaminants
would have on the quality of the ground water.
The remedial objective determined to be necessary at the Site is to
preserve human health and the environment by eliminating or
52
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reducing, identified and/or potential risks by preventing the
ingestion of barium-contaminated soils and by reducing the
potential for migration of contaminants from both surface and
subsurface soils to the ground water. Additional specific remedial
objectives determined to be necessary at the D.L. Mud Site are:
* Primary: Preserving the Site for non-residential uses
and reducing the potential for migration to
ground water of site-specific contaminants.
* Secondary: Restoring the Site for unrestricted uses.
The risk assessment conducted as part of the RI showed that future
occupational and trespasser land use scenarios result in acceptable
risk for surface and subsurface soils. Only a residential land use
scenario results in future risks exceeding EPA's acceptance
criteria. The potential residential pathway of concern is limited
to surface soil ingestion.
The remediation goals, according to 40 C.F.R. §300.430 (e)(2)(i)
"shall establish acceptable exposure levels that are protective of
human health and the environment". The following requirements must
be considered during the development of the remediation goals:
• Applicable or relevant and appropriate requirements (ARARs)
related to:
- acceptable exposure levels for systemic toxicants,
acceptable exposure levels for carcinogens,
technical limitations and
uncertainty factors.
• Maximum Contaminant Level Goals (MCLGs) established under the
Safe Drinking Water Act that are set at levels above zero.
• MCLs when the MCLGs are set at zero or are not relevant and
appropriate.
• When the attainment of chemical-specific ARARs will result in
a cumulative risk in excess of IxlO'4.
• Water quality criteria established under the Clean Water Act.
• Alternate concentration limits (ACLs) may be established in
accordance with CERCLA Section 121(d)(2)(B)(ii).
• Sensitive habitats of species protected under the Endangered
Species Act.
As required by Section 121 of CERCLA, as amended, remedial actions
must attain the levels or standards of control for hazardous
substances, pollutants, or contaminants specified by the ARARs of
federal environmental laws and state environmental and facility
citing laws, unless waivers are obtained. According to EPA
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guidance, remedial actions must also take into account non-
promulgated- "to be considered" criteria or guidelines if the ARARs
do not address a particular situation.
ARARs are distinguished by the EPA as being either applicable to a
situation or relevant and appropriate to it. Applicable
requirements are standards, standards of control, and other
substantive environmental protection requirements, criteria, or
limitations promulgated under federal or state law that specifi-
cally address a hazardous substance, pollutant, contaminant,
remedial action, or other circumstance as defined in the NCP.
For a requirement to be applicable, the remedial action or the
circumstances at the site must satisfy all the jurisdictional
prerequisites of that requirement. For example, the minimum
technology requirements for hazardous waste landfills under RCRA
would be applicable if a new hazardous waste landfill were to be
built.
Relevant and appropriate requirements are standards, standards of
control, and other substantive environmental protection require-
ments, criteria, or limitations promulgated under federal or state
law that, while not applicable to a hazardous substance, pollutant,
contaminant, remedial action, or other circumstances at a CERCLA
site, address problems or situations sufficiently similar to those
encountered at the CERCLA site so that their use is well suited to
that particular site. Relevant and appropriate requirements are
defined in the NCP, 40 C.F.R. §300.5. For example, while RCRA
regulations are not applicable to closing in-place hazardous waste
that was disposed of before 1980, RCRA regulations for landfill
closure with hazardous substances in-place may be deemed relevant
and appropriate.
The NCP, 40 C.F.R. §300.400(g)(2), specifies factors to consider in
determining what requirements of other environmental laws are
relevant and appropriate:
• The purpose of the requirement relative to the purpose of
CERCLA
• The media regulated by the requirement
• The substance regulated by the requirement
• The actions or activities regulated by the requirement
• Variations, waivers, or exemptions of the requirement
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• The type of place regulated and the type of place
affected by the release or CERCLA action
• The type and size of facility or structure regulated by
the requirement or affected by the release or contem-
plated by the CERCLA action
• Consideration of use or potential use of affected
resources in the requirement
In some circumstances, a requirement nay be relevant to the
particular site-specific situation but not be appropriate because
of differences in the purpose of the requirement, the duration of
the regulated activity, or the physical size or characteristic of
the situation it is intended to address. There is more discretion
in the judgment of relevant and appropriate requirements than in
the determination of applicable requirements.
As mentioned earlier in this section, the only identified concern
at the D.L. Mud site is from ingestion of barium contaminated
surface soil under the future residential exposure scenario.
Barium has been identified as the only chemical of concern for
surface soils as summarized in Table #21. The remediation goal for
total barium in surface soils is 5,400 ppm. This is a risk based
value which equates to an HI - 1 for potential residential
receptors exposed to surface soils. At this concentration,
approximately 19,350 cubic yards of surface soils (which have total
barium concentrations above 5,400 ppm) need to be addressed.
A comparable media-specific remediation goal for the subsurface
soil that has not been fully characterized but is obviously
contaminated with the high molecular weight hydrocarbon TICs cannot
be calculated using established risk assessment procedures.
Through the use of modified risk assessment procedures, including
additional sampling and analysis, it would be possible to better
define the potential risks posed by the TICs and other contaminants
contained in this area. The costs of conducting this additional
evaluation is not deemed appropriate in comparison to the assumed
volumes present at the site and estimated remediation costs.
Therefore, remediation goals for the subsurface media will be based
on visual observation and confirmatory sampling comparisons with
pit closure requirements contained in Louisiana Statewide Order 29-
B, Section 129.B.7. as specified below. It is estimated that
approximately 1,100 cubic yards of subsurface soils may need to be
addressed.
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Louisiana 29-B Pit Closure Requirements
pH 6-9
Arsenic 10 ppm
Barium 40,000 ppm
Cadmium 10 ppm
Chromium 500 ppm
Lead 500 ppm
Mercury 10 ppm
Selenium 10 ppm
Silver 200 ppm
Zinc 500 ppm
Oil & Grease < 1% dry weight
Although adverse impacts on the Site's ground water due to site-
related contamination have not been identified, the remedial
objective requires that the potential for migration of hazardous
substances into the ground water should be eliminated. Therefore,
no remedial goals are necessary for ground water, however,
comparisons with applicable MCLs will be made as part of ground
water monitoring activities conducted for purposes of ensuring that
contaminants are not migrating into the ground water.
It is important to note that because the wastes found at the Site
after the 1987 cleanup are not, by definition or characterization,
"hazardous wastes" as defined by the RCRA, then RCRA is not an
"applicable" ARAR. Therefore, there are no RCRA chemical-specific
requirements and none of the alternatives evaluated during the FS
will have to meet the RCRA Land Disposal Restrictions which only
apply to "hazardous wastes" (this would change if RCRA hazardous
wastes are identified or produced at the Site in the future) .
Several "action-specific" requirements of RCRA would be considered
"relevant and appropriate" ARARs and are discussed individually
with each affected alternative or in the comparative analysis and
selected remedy sections of this ROD.
According to historical records regarding past operations, the
wastes found at the Site consist mostly of NOW wastes presently
regulated by the State of Louisiana under Louisiana Statewide Order
No. 29-B. All of the following alternatives will have to meet
appropriate provisions of this Statewide Order.
VII. DESCRIPTION OF ALTERNATIVES
A FS was conducted to develop and evaluate alternatives to meet the
RAOs for the D.L. Mud site. Remedial alternatives were assembled
from applicable remedial technology process options and were
initially evaluated for effectiveness, implementability, and cost
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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 point of comparison for the other
alternatives.
The following alternatives to address site contamination were
evaluated in detail in the FS. The descriptions and evaluations of
remedial alternatives included in this ROD address the surface
soils contaminated with total barium and subsurface soils contain-
ing visual contamination. As described below, the remedial
alternatives for each of these effected media are presented
separately with the exception of the No Action and Institutional
Controls Alternatives (Alts. #1 and #2). Alts. #3 and #4 address
the surface soil barium problem and Alts. #5 and #6 address the
subsurface visual contamination.
List of Evaluated Remedial Alternatives and Media Addressed
Alternative Evaluated Area of Concern Addressed
Alt. #1 - No Action Surface and Subsurface
Soil Contamination
Alt. #2 - Institutional Controls Surface and Subsurface
Soil Contamination
Alt. #3 - Soil Capping Surface Soil Contamination
Alt. #4 - Barium Treatment Surface Soil Contamination
Alt. #5 - Biological Landfarming Subsurface Soil
Contamination
Alt. #6 - Excavation and Subsurface Soil
Offsite Disposal Contamination
For the reasons discussed in previous sections, the treatment of
ground water is not being considered as an implementable response
action and was not carried forward through the detailed development
of alternatives. However, because some inorganic contaminants were
detected in the ground water and several potential alternatives
will result in wastes being left onsite in a disposal unit, a
ground water monitoring program will be implemented in all of the
evaluated aIternat ives.
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As part of the ground water monitoring program that is included in
each of the_. following alternatives (with the exception of the "No
Action" alternative) , use of existing ground water monitoring wells
is planned. The possibility exists that the final design of an
alternative's remedy will adversely impact the existing ground
water monitoring system and will thus require a reevaluation of the
need for additional wells. If future monitoring indicates the
selected remedy does not prevent the potential for ingestion of
contaminated ground water, EPA will investigate the need for active
remediation of the ground water and would address resulting actions
in another Operable Unit and ROD.
Finally, all alternatives that result in waste remaining onsite at
levels that prohibit the future, unrestricted use of the property
will trigger the statutory requirement for a 5-Year Review. This
review is conducted every five years as a check to ensure that the
implemented remedy is still protective and performing as designed.
A brief description of the six alternatives evaluated to address
the contamination at the site follows.
Alternative #1 No Action
Capital Cost: $0
Operation and Maintenance: $0
Total Cost (1993 dollars): $0
Time of Implementation:
Design/Remedial Action: 0 months
Operation & Maintenance: 0 months
DESCRIPTION
Consideration of the No Action alternative is a requirement of the
NCP. Under this alternative, no remedial measures would be taken
to address the risks associated with the elevated barium concentra-
tions in the surface soils or the unknown potential risks associat-
ed with the waste materials found in the subsurface soils. No
provisions would be made to restrict Site access or restrict future
use of the land or ground water. Because there would be no active
remediation under this alternative, no action-specific ARARs are
relevant and appropriate. Because hazardous substances would be
left on site at levels potentially harmful to human health,
statutory 5-Year Reviews [as required by the NCP §300.430(f) (5) (ii-
i)(C)] will be conducted. This alternative will not meet either
the primary or secondary remedial objective.
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Alternative #2 Institutional Controls
Capital Cost: $17,000
Operation and Maintenance: $170,000
Total Cost (1993 dollars): $190,000
Time of Implementation:
Design/Remedial Action: 6 months
Operation & Maintenance: 30 years
DESCRIPTION
Institutional controls are a frequently considered alternative to
"no-action" because the implementation of relatively simple
restrictions may adequately reduce the threat of low-risk sites to
an acceptable level. This alternative consists of access and use
restrictions which will eliminate the possibility that the only
exposure that has been identified as a potential risk at this Site,
future residential, can occur. Alternative #2 would also provide
ground water use restrictions and long-term ground water monitoring
using existing wells to provide an early warning of any migration
of substances from the soils to the ground water.
Assumptions for this alternative that were used to formulate the
cost estimate are:
• Access restriction fence exists and only minor upgrading
and future maintenance is needed.
• Ground water monitoring will be required.
• Notice in deed would be required to restrict future uses
The access and use restrictions described above would apply for
both the barium contaminated surface soil and the contaminated
subsurface soils presently found at the Site. The alternative
could be implemented almost immediately, including fence upgrading
and sign posting. Ongoing ground water monitoring and a 5-year
review and reassessment of the adequacy of institutional controls
would be elements of this alternative. Because there would be no
active remediation under this alternative, no action-specific ARARs
are relevant and appropriate. This alternative would meet the
primary remediation objective but not the secondary remediation
objective.
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Alternative #3 Soil Capping
Capital Cost: $380,000
Operations and Maintenance: $157,000
Total Cost (1993 dollars): $540,000
Time of Implementation:
Design/Remedial Action: 24 months
Operation & Maintenance: 30 years
DESCRIPTION
The potential for contact with barium contaminated soil would be
reduced below that for preceding alternatives by isolation with a
protective soil cover. A 12-inch soil cap over the areas contami-
nated with total barium concentrations above 5,400 ppm (approxi-
mately 8 acres) is a cover system that would allow oxygen migration
to the underlying barium contamination while reducing the potential
for inadvertent contact with barium contaminated soil. The 12-inch
thick soil cover would be revegetated with plants that are native
to the area or suited to local growing conditions to control soil
erosion and dust formation. Along with continued access to oxygen,
gypsum (calcium sulfate) would be added to the soil to effect the
gradual conversion of more soluble forms of barium into the less
soluble form, barium sulfate, to lessen the potential for migration
into the ground water.
This alternative would have a relatively low implementation cost
and require a recurring cost for ground water monitoring to ensure
that no migration of barium occurs. Monitoring would continue for
a duration sufficient to confirm that barium remained immobile
and/or that the soluble forms of barium were undergoing conversion
to less soluble forms, a period at least 5 years beyond the 1-year
implementation period. At the 5-year milestone, the effectiveness
of the alternative would be reevaluated, and monitoring would
continue for a suitable period. Additional institutional controls
such as property deed notices/restrictions would be necessary to
ensure that residential development at the Site does not occur.
Action-specific ARARs such as RCRA capping requirements and
Louisiana Statewide Order 29-B would be evaluated during the design
process. This objective would meet the primary remediation
objective but not the secondary remediation objective.
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Alternative #4 surface Soil Barium Treatment
Capital Cost: $430,000 - $11,220,000
Operation and Maintenance: $60,000 - $400,000
Total Cost (1993 dollars): $830,000 - $11,300,000
Time of Implementation:
Design/Remedial Action: 2-5 Years
Operation & Maintenance: 5-30 years
DESCRIPTION
Under this alternative, several treatment options were evaluated to
eliminate the potential for exposure to barium contaminated surface
soils and lesson the potential for barium migration into the ground
water. The various treatment options evaluated included: Ex-situ
Froth Flotation, In-situ Chemical Fixation, and Solidification/Sta-
bilization.
Option A. The Ex-situ Froth Flotation process would be used to
remove barium from the soil by adding various chemical reagents to
finely screened, barium contaminated soils and passing it through
a stream of fine bubbles to separate barium from more common soil
constituents. The alternative involves the following steps:
• Construction of soil stockpile areas, treatment plant
installation, with process monitoring facilities, and a
personnel shelter
• Excavation of 18 inches of barium contaminated soils
(approx. 39,000 cubic yards), screening to discard the
oversize fraction, slurring and conditioning the remain-
ing fines with flotation chemicals, soil flotation
separation and cleaning, soil and barite dewatering and
drying, oversize material disposal, cleaned soil place-
ment, and recovered barium disposal
• Testing, .monitoring, and cleanup verification
• Plant dismantling
The froth produced during this treatment process could possibly be
a characteristic RCRA hazardous waste due to the high concentration
of barium and other metals that would be collected. As such,
several RCRA ARARs would be applicable including those that
regulate storage, transportation, and disposal of characteristic
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hazardous wastes. This option would meet the primary remediation
objective and possibly the secondary remediation objective,
depending on the final disposition of the recovered barium.
Option B. In-situ Chemical Fixation would be used to transform the
more soluble forms of barium (e.g. barium carbonate) present in the
surface soils into barium sulfate which is relatively insoluble.
The potentially bioavailable barium carbonate may be converted into
the inert barium sulfate using the innovative approach of irrigat-
ing the affected surface soils with a buffered sulfate solution
that has a pH adjusted with dilute sulfuric acid in the 4.0 to
5.0 range. Only the top 18 inches would need to be treated.
Application of the solution would convert barium carbonate into
barium sulfate. The pH range of 4.0 to 5.0 is well within the
tolerance range of most acid-tolerant crops, and these would be
planted to control runoff, provide soil stability, and prevent dust
generation between periodic applications of buffered sulfate.
The equipment that would be used includes readily available
construction and agricultural machinery. Equipment requirements
would include:
• Excavation equipment
• Rotary tiller or disc plow
• Crawler-type tractor
• Tractor-mounted spray equipment
• Buffering chemical(s)
In order to achieve barium carbonate/buffer solution contact,
tractor and soil tilling equipment would be required because of the
low permeability of the contaminated soil. Bench-scale treatabili-
ty tests would be conducted to select the proper buffering
solutions and to determine the reaction time required to set the
waste. Leaching tests may be needed to verify the reduction in
mobility of total barium.
This innovative technology involves sowing acid-tolerant crops
(e.g., grasses), preparing and spray-irrigating buffered sulfate
solution at a rate consistent with requirements of the crop, soil,
and locale. The buffered sulfate solution may also contain
supplemental trace nutrients. Leachable barium would be monitored
in treated soil until the barium became biologically and environ-
mentally unavailable to such a degree that the application of
buffered sulfate solution could be discontinued. It is estimated
the implementation time may be anywhere from three to five years,
depending on local growing conditions. The Site could be converted
to suitable uses consistent with protection of public health and
the environment because the barium originally present as barium
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carbonate would have been converted to insoluble barium sulfate.
An extended ground water monitoring program would be implemented,
and the effectiveness of the remedy would be assessed after
5 years. Chemical fixation would continue to meet the primary
remediation goal of preserving the Site for industrial use.
However, although the bioavailable barium carbonate will have been
changed to nonbioavailable barium sulfate, the total amount of
barium on site would remain the same; so this alternative would not
meet the more conservative secondary remediation goal of unre-
stricted residential use.
Option C. The Solidification/Stabilization (S/S) treatment
alternatives would reduce the potential for barium leaching because
the barium contaminated soil would be bound in an aggregated matrix
that reduces permeability to rain and applied water. The concen-
tration of leachable barium would be reduced only slightly from the
original soil concentration by virtue of the dilution effect of the
binder (a pozzolanic portland cement).
Ex-situ stabilization is similar to the in-situ alternative except
that the mixing of soil and binder is carried out in a mechanical
device such as a pug mill or cement mixer as opposed to the in-
place spreading of bulk cement and cement-soil tillage with disc
harrows. The in-situ alternative would involve deep discing to mix
the cement with the top 18 inches of soil where most of the barium
is located. Mobile construction equipment would be used to deliver
and spread the pozzolanic binder and moisten it after it is blended
with the soil. Unlike in-situ stabilization, however, the ex-
situ option requires preparation of a foundation; a stockpiling pad
for the collected soil; mobile equipment to excavate the barium
contaminated soil; stationary equipment to screen, mix, and
transfer the soil and cement; and irrigation equipment to apply
water for curing. The treated matrix would be placed back on the
ground and moistened to initiate curing.
Bench-scale treatability tests would be conducted to select the
proper additives and their ratios and to determine the curing time
required to set the waste adequately. Leaching tests and compres-
sive strength tests would be conducted to determine the integrity
of the solid end product and verify the reduction in mobility of
total barium. Critical parameters in stabilization treatment
include the selection of stabilizing agents and other additives,
the waste-to-additive ratio, mixing time, and curing conditions.
All of these parameters are dependent on the chemical and physical
characteristics of the hazardous substance.
Post-remedial ground water monitoring would be implemented, with an
effectiveness review at five years after completion of the remedy.
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Solidification/stabilization of the soils would continue to meet
the primary remediation goal of preserving the Site for industrial
use. Although the barite will have been stabilized, the total
amount of barium onsite would remain the same, therefore this
alternative would not meet the more conservative secondary
remediation goal of unrestricted residential use. Appropriate
action-specific ARARs contained in RCRA and/or Louisiana Statewide
Order 29-B would be evaluated during the design process.
Note: as stated earlier, the next two Alternatives address the
visually contaminated subsurface soils.
Alternative #5 Biological Landfarming
Capital Cost: $340,000
Operation and Maintenance: $69,700
Total Cost (1993 dollars): $410,000
Time of Implementation:
Design/Remedial Action: 2-5 years
Operation and Maintenance: 5 Years
DESCRIPTION
Although the subsurface soils associated with the former
impoundments were not fully characterized, it is known that these
materials contain a large amount of organic TICs. This alternative
was evaluated to address the potential threats these TICs could
pose on human health and the environment.
Nearly all organic compounds will undergo biologically induced
decomposition under favorable conditions. An economical method of
promoting biodegradation is through landfarming, in which hydrocar-
bon-containing soil is spread in a thin layer, nutrients are
applied, and a vegetative cover is grown both to control wind and
water erosion and to enhance the microhabitat to encourage
microorganism growth and biodegradation of organic contaminants.
In this alternative, 1,100 cubic yards of hydrocarbon-containing
subsoil would be excavated from its current location, mixed with
gypsum to improve porosity and workability, spread onto a suitable
surface, supplemented with essential nutrients, seeded with a crop,
and irrigated. Periodically (at about four to six week intervals),
the crop would be tilled with conventional farming equipment, and
the soil would be replanted. The process would be repeated until
hydrocarbon compound concentrations fell below yet-unspecified
levels, at which time the treated soil would be replaced with a new
charge of untreated soil, and the process would be repeated. (The
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soil would be biotreated until it is proven that residual contami-
nants do not pose an actual and/or potential risk to future
residents.) Excavation would be required for the construction of
a lined storm water collection pond to store surface runoff from
the land farm area. Water stored in the pond would be reapplied as
irrigation water. It is anticipated that two soil turnovers would
be required for adequate aeration and nutrient contact.
Land farming would be carried out in an area of at least 1/2 acre,
and the time to treat 1,100 cubic yards probably would not exceed
about four growing seasons, provided Site soil (silts and clays)
proves workable. The use of larger plots would reduce the cleanup
time, but the effort probably would require at least two years,
irrespective of the area used. Ground water beneath the Site would
be monitored, and the effectiveness would be evaluated after
five years.
Equipment requirements would include:
• Excavation equipment
• Rotary tiller or disc plow
• Crawler-type tractor
• Irrigation pump, piping, and spray heads
• Nutrient injection pump, storage tank, and mixer
As with other biological processes, land farming would destroy the
organic compounds, eliminating the perceived risk of these
substances at the Site. Land farming requires a moderate capital
and operating cost expenditure but carries no significant mainte-
nance costs. No 5-year review would be required. Action-specific
ARARs contained in Louisiana Statewide Order 29-B would apply to
this alternative. This alternative would meet both the primary and
secondary remediation objective.
Alternative #6 Excavation and Offsite Disposal
Capital Cost: $220,000
Operation & Maintenance: $0
Total Cost: $220,000
Time of Implementation:
Design/Remedial Action: 12 months
Operation and maintenance: 0 months
DESCRIPTION
Constituents that are consolidated in small areas lend themselves
to excavation and placement in a suitable landfill if the volumes
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and site conditions are favorable. Visually contaminated
subsurface soils at the D.L. Mud Site appear to be consolidated in
a relatively small area, making this alternative technically
feasible. The total volume is estimated to be 1,100 cubic yards.
Assumptions used to develop the cost estimate are:
• A suitable landfill complying with EPA's CERCLA Offsite
Policy is within 125 miles of the Site.
• Sampling is required to verify all contamination is
removed.
• No operation or maintenance (O&M) costs are involved.
This alternative consists of providing access roads, locating a
suitable landfill, obtaining the necessary mobile equipment,
removing the soil from the Site, and placing it in the impoundment.
Cleanup of the visually contaminated areas could be accomplished in
less than one year at moderate capital and operating cost. The
remedy would be permanent at the Site, but it would relocate the
contaminated soils to another repository rather than eliminate the
objectionable constituent(s) from the soil. No 5-year review would
be required. This alternative meets both the primary and secondary
remediation objectives.
Based on present information, the waste under this alternative to
be excavated and disposed off site is "non-hazardous", therefore, it
is assumed that this material is suitable for, and will be disposed
at, a RCRA, Subtitle D disposal facility. Such disposal facilities
are not permitted to receive RCRA "hazardous wastes." In the event
that a suitable RCRA, Subtitle D facility is not located within a
125 mile radius, then disposal at a RCRA, Subtitle C facility will
be evaluated. If pre-disposal testing on this waste indicates that
all or potions of the waste are RCRA "hazardous wastes," then
disposal at a suitable Subtitle C facility, permitted to receive
such wastes, will be required.
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.
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NINE 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 may 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 ARARs. 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.
Reduction of Toxicitv. 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 implemen-
tation. 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.
Implementability 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 O&M costs) is
considered and compared to the benefit that will result from
implementing the alternative.
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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 alterna-
tives, in relation to each specific evaluation criterion.
4 Based on the RAOs, the no action (Alternative #1) alter-
native does not meet the protectiveness of human health
and the environment criterion for risks to residential
children, however, existing land use is protective of
children's health. Institutional controls (Alterna-
tive #2) would control exposure through fencing and deed
notices/restrictions to ensure that future residential
use of the property does not occur. The froth flotation
alternative (#4A) is somewhat more protective than the
other alternatives because the barite is actually removed
from the soil and taken off of the site. Soil capping is
slightly less protective than froth flotation because,
although the exposure pathway is blocked, the small
amount of bioavailable barium is still in the
bioavailable form at the end of the remedial action. The
other three alternatives would treat the barium and
reduce the mobility and potential for exposure; however,
the total barium on the site would remain constant and so
would not meet the RAO.
For subsurface soils, the no action (#1) and
institutional controls (#2) alternatives do not meet this
criterion because the unknown risks will still be present
and uncontrolled. The institutional controls could
provide a limited level of protectiveness, however, the
unknown nature of the contaminates make it difficult to
ensure that appropriate controls are imposed to monitor
this protectiveness. Both alternative #5 and #6 will
provide a high level of protectiveness to human health
and the environment.
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Based on the RAOs, all of the alternatives meet the
compliance with ARARs criterion. The froth flotation
alternative (#4A) has more restrictions and ARARs to meet
than the other treatment alternatives because the froth
created will probably classify as a RCRA "hazardous
waste" and will need to be managed as such.
Existing data (and perhaps new data) would need to be
compared to the standards to see that the no action (#1)
and institutional controls (#2) alternatives meet the
criterion for subsurface soils. At present there is a
State ARAR that lists limitations for pit closure that
may not be met for the subsurface material in the former
impoundment area.
The no action alternative (#1) does not meet the long-
term effectiveness and permanence criterion. Alternative
#2, institutional controls, will meet this criterion by
ensuring that future residential use of the property does
not occur through the imposition of deed notices and
restrictions. Soil capping (#3) is not as effective in
the long-term as chemical fixation (#4B), or S/S (#4C)
because soil capping leaves the bioavailable barium in
the bioavailable state until the gypsum added as an
amendment to the contaminated site soils converts barium
carbonate into acid-insoluble barium sulfate. Chemical
fixation (#4B) would chemically convert the bioavailable
barium carbonate to a nonbioavailable state (barium
sulfate); this conversion is essentially permanent. The
S/S alternatives would immobilize the barium in the soil,
but the long-term effectiveness is unknown due to
potentially adverse effects from future environmental
changes on the remaining solidified mass. The total mass
of barium onsite remains constant for these three
alternatives. Froth flotation (#4A) also treats the
barium carbonate and removes it from the site so that no
long-term maintenance or monitoring would be needed.
For the subsurface soils the no action (#1) and
institutional controls (#2) alternatives do not meet this
criterion. Institutional controls will not necessarily
meet this criterion because long-term effectiveness is
difficult to evaluate given the unknown nature of the
contaminants and associated risks that this subsurface
soil possesses. Both landfarming (#5) and offsite
disposal (#6) alternatives will meet this criterion.
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The previous remedial actions conducted by the State in
1987 removed and treated contaminated soils, reducing the
toxicity and volume of the majority of contamination that
was present at this site. For this ROD, the no action
(#1) and institutional controls (#2) alternatives do not
meet the reduction of toxicity. mobility, or volume
criterion through additional treatment. Soil capping
(#3) may reduce the mobility because the barite would not
be on the surface of the soils, however, it would not
affect toxicity or volume. The S/S alternative (#4C)
would decrease the mobility and the toxicity, but would
increase the volume by an estimated 25 percent. Froth
flotation (#4A) would decrease the mobility, toxicity,
and volume of the soils at the site over the long term;
in the short term, this alternative will create a much
more highly concentrated but low volume waste (froth)
during soil treatment. Chemical fixation (#4B) would
decrease the toxicity and mobility of the soils by
converting the barium carbonate to barium sulfate;
although the total mass of barium would remain the same,
the mass of the toxic barium carbonate would be reduced.
For subsurface soils, the no action (#1) and
institutional controls (#2) alternatives do not meet this
criterion. The offsite disposal alternative (#6) does
not address toxicity, mobility, or volume of contaminants
but rather moves the contaminants to another location
without modification. Landfarming (#5) addresses
toxicity, mobility, and volume by destroying the
contaminants through biodegradation.
Through proper controls processes during implementation,
all of the alternatives meet the short-term effectiveness
criterion through the use of fencing and other site
access controls. The no action (#1) and institutional
controls (#2) alternatives do not pose potential short-
term risk to the community or workers during implemen-
tation. Of the active remedial alternatives, froth
flotation (#4A) and ex situ S/S (#4C) would have the most
risk to workers since the barium-containing soils would
be excavated, treated ex situ, and then replaced in the
excavation. A smaller risk to workers would be posed by
the in situ treatment alternatives (#4B and #4C) since
the soils would not be excavated. Soil capping (#3)
would pose the least risk to workers and offsite
residents since the soils would not be disturbed except
by the placement of the clean soil on top.
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All alternatives meet the this criterion for the
subsurface source areas, although the landfarming (#5)
and offsite disposal (#6) alternatives would pose a more
potential risk since contaminated soils would be handled.
The offsite disposal alternative would also pose a more
potential risk to the community because contaminated
soils would be moved through the community to the
disposal facility.
The no action (#1)/ institutional controls (#2), and
capping (#3) alternatives are the most implementable and
have the most proven technologies of the alternatives.
Chemical fixation (#4B) is the next most implementable
alternative; the equipment used for this, treatment is
that which is used for general agricultural farming. The
S/S alternative (#4C) is slightly more difficult to
implement; compared to chemical fixation, this
alternative will require a fairly extensive treatability
study to demonstrate stabilization effectiveness. The
least implementable is froth flotation (#4A) which is a
novel application of this technology.
For subsurface soils, all of the alternatives are
implementable. For landfarming (#5), treatability
studies would need to be performed to ensure that
effective and timely biodegradation of organic
contaminants is possible. For offsite disposal (#6), a
suitable disposal facility will need to be located to
accept the contaminated soils.
The no action (#1) and institutional controls (#2)
alternatives are the least expensive alternatives. The
next alternative in cost is soil capping (#3) . After
soil capping, the costs increase from chemical
fixation (#4C) to in situ solidification (#4C) to ex situ
solidification (#4C). Froth flotation (#4A) is by far
the most expensive.
For subsurface soils, the cost comparison from least to
most expensive is as follows: no action (#1),
institutional controls (#2), offsite disposal (#6),
landfarming (#5).
The Louisiana Department of Environmental Quality is in
agreement with the selection of Alternative #2 and
Alternative #6 as the preferred remedy for the D.L. Mud
site (see Appendix #3).
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EPA solicited input from the community on the remediation
alternatives proposed to address the contamination at the
site. Input was received from both the local citizens
and from Dow/DSI. Although not opposed to the preferred
alternative, the local citizens expressed a preference
for a more conservative alternative (Alternative #3) to
address the residual barium in surface soils. Dow/DSI
commented that the preferred alternatives (Alternative #2
& #6) were too conservative. A full listing of the
comments received from the public on the Proposed Plan
and EPA's responses is contained in the Responsiveness
Summary section of this ROD (See Appendix #1).
IX. TEE SELECTED REMEDY
Based on consideration of the requirements of CERCLA, the compara-
tive analysis of alternatives, and public comments, the EPA has
determined that a combination of Alternative #2 (Institutional
Controls, Ground Water Monitoring) and Alternative #6 (Excavation
and Offsite Disposal of Visually Contaminated Subsurface Soils)
will best provide a cost effective remedy that is protective of
human health and the environment.
As discussed in Section IV of this ROD, the specific RAOs deter-
mined to be necessary at the D.L. Mud site are to eliminate or
reduce identified and/or potential risks by preventing the
ingestion of barium-contaminated soils and by reducing the
potential for migration of contaminants from both surface and
subsurface soils to the ground water. The selected remedy will
meet these objectives by:
establishing and enforcing land use and deed
notices/restrictions on the property to eliminate the
potential for ingestion of barium contaminated surface soils
by hypothetical future residents.
excavating and disposing visually contaminated subsurface
soils at an offsite disposal facility to eliminate the
potential for migration of the contaminants into the ground
water.
monitoring ground water to ensure that waste excavation
actions are successful and potential ground water degradation
from residual surface soil contaminants does not occur.
Based on information currently available with respect to the
evaluation criteria and the other alternatives, EPA believes the
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preferred alternative provides the best approach to achieve the
remedial objectives. This alternative will significantly reduce
the risks from direct contact with site contaminants and eliminate
the potential for future ground water contamination from existing
subsurface contaminants by removing and disposing these contami-
nants offsite. The preferred alternative will provide long-term
effectiveness as long as the land use and deed restrictions are in
place to ensure that residential exposure scenarios are not
realized. Although no risks were identified to trespassers, the
existing fence that encloses the highest areas of site
contamination will be mended and repaired, as needed, during O&M
activities. This will ensure site security and discourage illegal
disposal of wastes onsite such as has happened in the past.
Fencing needs may change in the future depending upon activities at
the adjacent GCVS site and on future non-residential uses at the
D.L. Mud site.
Long-term ground water monitoring will be conducted to evaluate
contaminant existence and movement and, if determined to be
necessary, implement appropriate remedial response. There are no
expected unmanageable short-term risks associated with this
alternative. This alternative will also comply with all ARARs for
excavation and offsite disposal of CERCLA hazardous substances.
The institutional controls alternative is considered more cost
effective because the same degree of protectiveness to human health
and the environment is realized at a much lower cost. Potential,
low level risks from site contaminants were only identified under
the hypothetical future onsite residential scenario. No risks were
identified to existing offsite residents or hypothetical workers
and trespassers. The active treatment alternatives are much less
cost effective than the preferred alternative because, even after
conducting the treatment processes, each would still require post-
treatment remedial actions, monitoring and/or land use restric-
tions. EPA has concluded that these alternatives do not offer
additional protection in line with the additional costs necessary
to implement them.
In addition, some question remains as to the actual level of risk
posed by the residual barium in the surface soils'^ to hypothetical
future residents. EPA is presently reviewing risk issues related
to barium that could have a direct bearing on the volume of surface
soils that need to be addressed and/or even on the need for
remedial action. Imposing an Institutional Control/Ground Water
Monitoring remedy provides flexibility in the event that changes
are made in barium toxicity factors that would support a lower,
acceptable risk from the residual barium in the surface soils.
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The active measures (excavation and offsite disposal) proposed to
address the unknown risks associated with the contaminated
subsurface soils were deemed more appropriate than delaying the
remedial 'decision so that additional, costly risk assessment
efforts could be conducted in an effort to quantify the unknown
risk. This course of action also meets the goal of the 1987 State-
lead cleanup which called for the removal of visually contaminated
soils.
As mentioned earlier, the majority of potential concerns identified
by EPA during the NPL ranking of this site were addressed during
the State-lead cleanup in 1987, employing treatment technologies
that permanently and significantly reduced the volume, toxicity and
mobility of site contaminants. This 1987 cleanup action included
the offsite incineration of over 685 tons of contaminated liquids,
wastes and contaminated soils at the Dow Chemical U.S.A. permitted
hazardous waste facility in Plaquimine, Louisiana.
Although the selected alternative in this ROD does not in itself
satisfy CERCLA's preference for remedies that employ treatment that
permanently and significantly reduces the volume, toxicity or
mobility of the hazardous substances, the overall remedial action
for this site (including the actions conducted in 1987) does meet
this preference. It is not appropriate nor practicable to use
treatment technologies that will permanently and significantly
reduce the volume, toxicity or mobility of the relatively low
levels of residual hazardous substances that remain at the site
because they will not provide a greater overall, cost effective
benefit to human health and the environment. CERCLA's program
goals and expectations, as stated in §300.430 of the NCP, recogniz-
es that institutional controls should be used for relatively low,
long-term threats when more active treatment remedies are deter-
mined not to be practicable. The residual, low-level risks that
will remain upon completion of this ROD'S preferred remedy are
minimal in comparison to the risks that existed at the site before
the 1987 State-lead cleanup.
A more detailed description of the selected remedy follows with
major cost assumptions provided in Appendix #4. It should be noted
that certain engineering considerations of the remedy may change
during the remedial design. Areas that are subject to change
involve ground water monitoring locations and frequencies,
subsurface soil excavation volumes and disposal locations, and
fencing activities.
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Engineering Remedial Design
4 The engineering remedial action plans will include: Work Plan,
Health and Safety Plan, Sampling and Analysis Plan, Quality
Assurance Project Plan, and Operation and Maintenance Plan.
4 The engineering remedial design will not include intermediate
plans due to the simplistic nature of the remedial actions.
Site Preparation
• Limited site preparation activities will be necessary to complete
the remedial action. Steps to be taken include minor vegetation
clearing to assist in excavation and waste hauling activities,
construction of decontamination facilities adequate to handle
excavation and sampling equipment, and existing fence and gate
repairs.
Subsurface Soil Excavation and Disposal
• The estimated volume of contaminated subsurface soils that will
require excavation is 1,000 cubic yards. This volume may change
during the remedial action based on confirmation sampling results.
All visual contamination will be removed and confirmatory samples
will be evaluated based on the State Pit Closure limitations as
established in Table #22. The volumes required for backfill
include the volumes of material necessary to fill the excavated
areas up to existing ground levels.
Operation and Maintenance
4 O&M costs assume an annual engineer's inspection and report of
the condition of the site. Issues to be investigated concern the
integrity of land-use restrictions, fencing, and ground water
monitoring wells for a period of at least 30 years.
* The annual inspection will include ground water monitoring for
TCL volatile organics, TCL base neutral/extractables and total and
dissolved TAL metals. The monitoring will utilize existing wells.
Results from the ground water monitoring will be included in the
annual report with an additional ground water statistics report
every five years. This report will analyze ground water monitoring
results during the preceding five years, evaluating statistical
trends and relationships with background data.
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TREATMENT GOALS
Since active, onsite treatment of site contaminants is not a part
of the selected remedy, media-specific treatment goals are not
warranted. Excavation goals, as expressed in Table #22, for the
visually contaminated subsurface soils will be monitored during and
after excavation as part of confirmation sampling. In addition,
the excavated material will be characterized to ensure disposal at
an appropriate offsite facility. At present, the toxicity
characteristic leachate procedure (TCLP) waste characterization is
the most important parameter. RI sampling indicated that the
contaminated subsurface soils were not RCRA hazardous wastes as
defined by TCLP criteria which would allow the excavated material
to be disposed at Subtitle D landfill. The selected disposal
facility may impose additional waste characterization sampling
before accepting the waste.
As mentioned earlier, ground water will be monitored annually for
at least 30 years after completion of the remedial action as part
of the OfitM and 5-Year Review activities at this site. If at any
time during this monitoring EPA determines that source treatment
actions were ineffective in preventing ground water quality
degradation which poses a risk to existing or future users, then
additional investigative and treatment alternative actions will be
implemented. These additional actions would be implemented under
a separate Operable Unit and ROD.
Criteria to be evaluated will include statistical changes in ground
water contaminant concentrations, the identification and character-
ization (including risk assessments) of contaminant plume(s)
attributed to the site, and comparisons with appropriate drinking
water standards. The ground water monitoring program will be
developed during the Remedial Design and contained in the Operation
and Maintenance Plan.
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
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
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how the selected remedy for the D.L. Mud site meets the statutory
requirements.
Protection of Human Health and the Environment
In order to protect human health and the environment from the
actual and/or potential threats identified at the site, the
potential for harmful exposures that create those threats will be
eliminated. The land use and deed restrictions will eliminate the
potential for residential exposure to the low level risks associat-
ed with the residual barium in the surface soils. The visually
contaminated subsurface soils will be removed and disposed of at an
offsite facility eliminating the potential for these contaminants
to migrate into the ground water or surrounding environment. Along
with ground water monitoring and continuous 5-Year Reviews, these
actions will provide long-term, permanent protection of human
health and the environment.
Compliance With ARARs
Each component of the selected remedy will meet all applicable or
relevant and appropriate requirements. The ARARs evaluated during
the RI/FS as potentially applicable or relevant and appropriate are
presented below. It is important to note that several of these
ARARs are included in this discussion only because waste character-
ization activities may reveal that wastes to be excavated and
disposed offsite are indeed RCRA characteristic hazardous wastes.
At present, none of the wastes identified at the site are either a
listed or characteristic RCRA hazardous waste.
Chemical-Specific ARARs
Chemical-specific ARARs regulate the release to the environment of
hazardous substances having certain chemical or physical character-
istics or materials containing specified chemical compounds. They
are important in determining the extent of soil, sediment, and
ground water requiring remediation as well as determining the
residual levels of hazardous substances allowable after treatment.
Chemical-specific ARARs do not exist for soil for the contaminants
at the site. The risk assessment evaluated to-be-considered
criteria for soil and sediment including reference doses and
potency factors; Noncarcinogenic residential risk due to ingestion
of soil by a child was found to be 3.8. Because this value is
above the 1.0 point of departure, target concentrations for soil,
using risk-based criteria, are included as site-specific remedial
goals.
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Location-Specific ARARs
Location-specific ARARs are requirements that relate to the
geographical position of the site. The primary location-specific
ARARs relative to remedial action pertain to floodplain and
wetlands. The entire site is outside the boundary of the 100-year
floodplain and does not contain wetlands. Therefore, the require-
ments of RCRA 40 C.F.R. §264.18(b) and Executive Order 11988,
Protection of Flood Plains, are not applicable or relevant and
appropriate to actions on the site. These regulations, if
applicable, would, for example, affect the citing of remedial
facilities.
Action-Specific ARARs
Action-specific ARARs are requirements that define acceptable
treatment and disposal procedures for hazardous substances.
Important action-specific ARARs that may affect the development and
conceptual arrangement of remedial alternatives are discussed
below.
The definition of hazardous waste is critical in determining the
status of RCRA requirements that apply to the residually contami-
nated soils at the D. L. Mud site. Since portions of the
residually contaminated soils were generated and managed before the
effective date of RCRA (November 1980), RCRA is not applicable
unless waste material is excavated. RCRA requirements may be
relevant and appropriate if wastes disposed of before November 1980
are defined as RCRA hazardous waste or are sufficiently similar to
RCRA hazardous waste.
Based on review of the site history, EPA has not identified any
RCRA listed hazardous wastes at the site. Since contaminated soils
did not result from disposal of a listed hazardous waste, the RCRA
mixture rule [40 C.F.R. §261.3(c)(2)(i)] does not apply. Soil
samples from locations with the highest total barium concentrations
detected were collected and analyzed during the RI; these samples
did not exceed TCLP limits. Therefore, this regulation is not
considered applicable.
RCRA land disposal restrictions (LDRs), 40 C.F.R. §268.41, prohibit
land disposal of characteristic wastes unless constituents in the
TCLP extract are below the concentration limits. Soil samples
collected and analyzed during the RI did not exceed TCLP limits.
Therefore, this regulation is not considered applicable.
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Relevant and Appropriate State Standards
The following ARARs from the State of Louisiana are considered
relevant and appropriate to the D. L. Mud site because of
consideration of the specific factors listed in
40 C.F.R. §300.400(g)(a).
Louisiana Hazardous Waste Management Regulations. These regula-
tions state standards for management of hazardous wastes. Since
TCLP testing shows that residually contaminated soils do not exceed
TCLP limits, these regulations are not considered relevant or
appropriate.
Louisiana Statewide Order No. 29-B (LAC Title 43:Part XIX). These
regulations govern the storage, treatment, and disposal of
nonhazardous oil field wastes (NOW) generated from the drilling and
production of oil and gas wells. The residually contaminated soils
associated with former surface impoundments at the D. L. Mud site
were generated as NOW, and the facility was not a disposal
facility. Therefore, this regulation is not considered applicable.
The closure requirements and of f site treatment and use requirements
of these regulations are relevant and appropriate for the
subsurface soils associated with the former surface impoundments.
Louisiana Discharge Air Pollution Control Standards. These
regulations establish air quality standards and emissions limita-
tions for any source of air emissions within the state. These
regulations are relevant and appropriate for those alternatives
where excavation could result in dust or other discharges to the
air.
As discussed in EPA's August 1988 CERCLA Compliance with Other Laws
Manual fEPA/540/G-89/006). action-specific ARARs should be refined
as appropriate during remedial design.
Cost Effectiveness
EPA believes that the selected remedy is cost effective in
mitigating the threat of direct contact and reducing the potential
for ground water contamination from site wastes. 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.
With the exception of the No Action Alternative (Alternative #1),
all of the alternatives that address barium contaminated surface
soils provide long-term effectiveness and permanence, if properly
implemented and maintained. The selected alternative can be easily
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implemented and effective in the shortest time period. Although
the selected remedy does not provide a reduction of toxicity,
mobility or volume through treatment, all of the other alterna-
tives, with the exception of Alternative #4A (Ex-Situ Froth Flota-
tion) , will still require some form of post-RA land use restric-
tions and long-term monitoring because wastes will be left onsite.
Alternative #4A is estimated to cost almost sixty times the
selected remedy ($11,280,000 as compared to $190,000 for the
selected remedy). This major increase in cost is not considered
appropriate given the low level risks associated with the residual
barium in the surface soils.
For the contaminated subsurface soils, only the selected remedy
(Alternative #6, Excavation and Offsite Disposal) and Alternative
#5 (Landfarming) provide long-term effectiveness and permanence.
Alternatives #1 and #2 (No Action and Institutional Controls) do
not provide long-term effectiveness because risks from the
subsurface soil contamination has not been adequately
characterized. Comparing the selected remedy with Alternative #5
shows that the selected remedy is much more implementable and
effective in the short term and at a lower cost ($410,000 vs.
$220,000).
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 technolo-
gies can be utilized in a cost effective manner for the D.L. Mud
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 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 surface and subsurface soils was not
found to be required or warranted at this time based on the low
level risks associated with the residual barium contamination and
on the unknown risks associated with the relatively small volume of
localized contaminated subsurface soils. Although treatment is not
warranted at this time, the overall 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, a
State-lead cleanup was conducted at the site in 1987 as discussed
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in Section V. This cleanup action included the removal and offsite
incineration of wastes from several areas of the site.
Because the selected remedy 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 April 1994.
The Proposed Plan identified Alternative #2 and #6 , Institutional
Controls, Subsurface Soil Excavation and Offsite Disposal and
Ground Water Monitoring as the preferred alternative for the D.L.
Mud 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.
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Appendix #1
RESPONSIVENESS SUMMARY
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f • t -' •
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THE RESPONSIVENESS SUMMARY
The Responsiveness Summary has been prepared to provide written
responses to comments submitted regarding the Proposed Plan of
Action for the D.L. Mud Superfund 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 O.L. Mud
site.
Section II. smrnngrv of Manor Comments Received. The comments (both
oral and written) are summarized and EPA's responses provided.
I. BACKGROUND OF COMMUNITY INVOLVEMENT AND CONCERNS
Overall interest in the D.L. Mud site on the part of the local
residents, local government officials, and the potentially
responsible parties (PRPs) has been moderate.
Local citizen interest has been limited. The citizens are quite
aware that the majority of concerns in the area can be traced to
the neighboring Gulf Coast Vacuum Superfund Site. They also are
aware that the 1987 State-lead cleanup of the site addressed most
of the contamination problems at the site. The concerns about the
D.L. Mud site appear to center on the desire to see that a full
investigation of the site's condition is made before decisions are
made to walk away from it. This concern is based on the fact that
if EPA would rank the site on the NPL, then there must be grave
environmental threats associated with it. Great care has been
taken throughout the investigative process to ensure that all
potential environmental threats are investigated.
Local government official interest has been limited as well.
Although the site is not in the city of Abbeville, the Mayor has
been kept abreast of ongoing activities. Several representatives
of the Parish Police Jury have been both interested and helpful in
planning activities and have attended several of the various
community relations functions held in the area. The major concern
that these local government officials have expressed through this
process have concerned consistency with the other Superfund sites
in the area and with the desire to see that EPA and its contractors
use local services whenever possible.
A technical assistance grant (TAG) was awarded to the citizen's
group called the Vermilion Association to Protect the Environment
(VAPE) in 1990. Both VAPE and TAG technical advisor have been
involved and helpful during the remedial planning activities.
Recent concerns have been expressed regarding the opening of a
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children's camp in the area and any impacts site activities might
have on the camp and/or wandering campers might have on the site.
Written comments received from VAPE during the public comment
period are addressed in the next section.
PRP interest and involvement in the site has been much greater than
the local citizens. Although there were over 100 PRPs identified
at this site, only two former owner/operators have been directly
involved with remedial planning activities, Dow Chemical and Dowell
Schlumberger, Inc. (Dow/DSI). These two PRPs voluntarily conducted
the Remedial Investigation and Feasibility Study (RI/FS) activities
under the terms of a June 1990 Administrative Order on Consent.
Correspondence between and meetings with Dow/DSI during this
process generated several concerns to which EPA has appropriately
responded. Official written comments received from Dow/DSI during
the public comment period are addressed in the next section.
II. SUMMARY OF MAJOR COMMENTS RECEIVED
Public notice announcing the public comment period and opportunity
for a public meeting was printed in the Abbeville Meridional and
Kaplan Herald. The public comment period began on April 29, 1994,
and ended on May 28, 1994. The formal public meeting was held on
May 10, 1994, during which EPA answered questions about development
of the RI/FS and remedial alternatives under consideration. A full
account of the public meeting can be found in the public meeting
transcript which is documented in the D.L. Mud Administrative
Record.
The public comments received during the public comment period and
EPA responses are summarized below.
ORAL COMMENTS RECEIVED DURING MAY 10. 1994 PUBLIC MEETING
1. COMMENT; What cleanup activities occurred in 1987 and how much
did it cost?
RESPONSE; As summarized in Section II of the ROD, the 1987
cleanup activities conducted under the oversight of the State of
Louisiana consisted of the following:
• Removal of the tank contents, destruction by incinera-
tion, and disposal of ash in a hazardous waste landfill.
• Decontamination and demolition of the tanks, supports,
and piping.
• Removal and disposal of approximately 800 cubic yards of
contaminated soil from eight onsite areas, including tank
pads, one "bare" area, and two areas identified by EPA in
the southern portion of the site.
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Placement of clean offsite fill material onsite in the
excavated areas.
On December 17, 1987, Dow/DSI submitted a Report of Decommissioning
and Restoration of the D.L. Mud site which was approved by LDEQ on
February 29, 1988. A copy of this report can be found in the D.L.
Mud Administrative Record. Information regarding the actual cost
of these activities is not presently available to EPA.
2. COMMENT; It was mentioned during the public Meeting that
offsite contaminants were identified but this was not EPA's
responsibility to address.
RESPONSE: Although EPA conducts a "baseline" risk assessment,
remedial action decisions must also include an evaluation of onsite
and offsite contaminant concentrations to help the risk manager
determine the additional impact that onsite contamination is
presently or potentially having on human health and the environ-
ment. As part of this evaluation, background samples are taken
from locations that best describe the natural surrounding area. At
times, common, naturally occurring contaminants are identified at
these locations. It is beyond the scope of CERCLA to address
contamination that is not a result of site activities or releases.
No significant offsite contamination was observed during the D.L.
Mud investigation. If there were, this information would be
transmitted to the local and State health officials.
3. COMMENT; what is the visually contaminated material that was
found in the former impoundment area and what is the volume of this
material?
RESPONSE; As mentioned in the ROD, this material has not been
fully characterized although it is estimated that there is
approximately 1,100 cubic yards of visually contaminated material
and associated soils. No indications from historical records
indicate what these pits were actually used for. Analytical
results using standard methods have been inconsistent in its
attempt to characterize the material, although it is apparent that
the material is similar to other oilfield exploration and produc-
tion wastes and products that have been identified at the neighbor-
ing Gulf Coast Vacuum and PAB Oil Superfund sites.
4. COMMENT: It is mentioned that the high ground water results
for several inorganics is due to high turbidity and that when the
sediments are removed, the high concentrations are eliminated. How
does that effect drinking water for people that can not filter
their ground water?
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RESPONSE; After EPA conducted standard ground water sampling
that indicated elevated levels of total chromium, additional
sampling was conducted to try and identify the nature of this
contamination. This additional sampling utilized a dedicated
sampling procedure that would more replicate actual ground water
conditions and pumping activities. Unfiltered results from this
sampling method indicated that the chromium was part of the
sediments that were analyzed with the ground water using the cruder
sampling method and not an accurate description of ground water
quality. It is believed that the dedicated sampling procedure is
more representative of local drinking water scenarios.
No drinking water wells would be placed in the upper reaches of the
Chicot Aquifer where the ground water samples were taken for the
D.L. Hud site characterization. Samples taken from the deeper
depths where surrounding citizens get there drinking water do not
have the high turbidity that is associated with the D.L. Mud wells.
5. COMMENT: Could the chromium in th« ground water come from
material that was removed from the site during the 1987 cleanup
activities?
RESPONSE: It is possible that the materials removed during the
1987 cleanup contained chromium because chromium is a constituent
of common materials associated with the oilfield exploration
industry. However, no relationship has been identified between any
of the former source areas and the chromium in the ground water
sediments.
6. COMMENT: After implementation of th« remedy, what can the
property be used for?
RESPONSE; The land use restrictions will prohibit residential
and agricultural use of the property. The only potential risk that
was identified during the risk assessment was to future residential
children. Potential risks associated with agricultural use of the
property was not quantified, therefore, the property will not be
used for farming or grazing purposes either. This means that the
property could only be used for industrial uses.
7. COMMENT: What type of offait* disposal facility will the
excavated subsurface soils go to?
RESPONSE; Because the waste is not classified as a RCRA
"hazardous waste", this material is subjected to the RCRA Subtitle
D requirements as well as EPA's CERCLA Offsite Policy. If an
appropriate Subtitle D landfill facility can not be found with a
125 mile radius of the site, then consideration will be given to
use of a Subtitle C landfill. The use of any other off site
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treatment or disposal options could also be considered (such as
offsite-incineration at an approved facility) during the Remedial-
Design but the final decision would have to comply with the Offsite
Policy.
The State of Louisiana will have an important role in determining
the appropriate landfill to accept this waste. During the Remedial
Design, the State will have to approve the proposed disposal
facility before any material will be disposed offsite.
8. COMMENT! Will the site be de-listed from the HPL after the
monitoring of the ground water and will the PRP« still be liable
after it is?
RESPONSE; To de-list a site from the NPL, all remedial actions
must be completed to ensure protection of human health and the
environment. This site will be eligible for de-listing upon
successful completion of the excavation and of fsite disposal of the
contaminated subsurface soils and institution of the land use and
deed restrictions.
Ground water monitoring activities are to be conducted as part of
Operation and Maintenance activities for at least 30 years. In
addition, 5-Year Reviews will be conducted every five years to
ensure that the remedial actions and institutional controls are
still protective of human health and the environment. If at any
time it is determined that the remedial actions implemented to
protect human health and the environment are not successful, EPA
has the discretion to place the site back on the NPL without having
to re-rank it.
The NPL status of a site does not have any bearing on a PRP's
liability. Therefore, if the site is de-listed and problems arise
at a later time, EPA can pursue the PRPs to address these problems
if appropriate.
9. COMMENT; Who will be conducting the Remedial Design and
Remedial Action?
RESPONSE; EPA is going to make every effort to have the PRPs
conduct the remedial activities at this site. In the event that
voluntary conductance of the remedial activities is not obtained,
several alternate enforcement options are available for consider-
ation. EPA also has the authority to conduct the remedial actions
using fund monies in the event PRPs fail to commit to conducting
the remedial activities in a timely manner.
10. COMMENT i Will local services be used to conduct the remedial
activities?
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RESPONSE; Any and all inquiries for work at the site will be
forwarded- to the PRPs under the assumption that any future work
will be let out under their direction if an agreement is reached
whereby the they conduct the Remedial Design and Remedial Action.
If EPA conducts the work using fund monies, then official Federal
Acquisition regulations will be followed including formal bidding
procedures .
The following comments were received in written form during the 30-
day public comment period.
11. gnMUBMT* what happens after 30 years vhen the ground water is
no longer monitored?
RESPONSE ; The need for ground water monitoring is based on the
concern that the potential exists for contaminants remaining onsite
after the remedial action to migrate into the ground water. This
monitoring will also be used to reassert that the initial determi-
nation that no ground water concerns exist that require remediation
was correct. As stated in the ROD, the monitoring of ground water
will be conducted at least for 30 years. The results of initial
ground water monitoring will establish the need for additional
ground water monitoring after 30 years. If it is determined that
additional ground water monitoring is needed after 30 years then
the O&M Plan will be amended to reflect this need. The time period
for this monitoring of 30 years is established more for cost
estimation purposes than on a scientific basis.
12. COMMEHT; The Proposed Plan contains plans for long tent ground
water monitoring that would detect any changes in the current level
of constituents in the ground water. The Plan should include
provisions that would provide a mechanism for initiation of ground
water remediation if the groundwater is impacted by the contami-
nants remaining onsite. In addition, sediment in the ground water
was determined to cause the ground water to exceed MCL. If
additional problems result from the sediment containing heavy
metals, a mechanism should be included to address these problems.
RESPONSE: The ROD contains statements that will require the
investigation and remediation, if appropriate, of any identified
problems with ground water that arises as part of the post-RA
ground water monitoring program. The need to conduct these
additional activities will be based on the review of ground water
data as it is developed. The review process will be developed as
part of the O&M Plan and will look at contaminant concentrations
and statistical changes over time as well as drinking water
criteria. It is not necessary at this time to state what the
remedial mechanism would be. This will be decided based on the
particular circumstances that surround the decision to address
newly identified ground water concerns.
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13. COMMENT; According to the Proposed Plan, the preferred
alternative will leave final barium levels on the D.L. Mud site at
a much higher level than the final levels after treatment at the
Gulf coast Vacuum and PAB oil sites. TAPE would like to encourage
EPA to require Alternative #3, soil capping as the preferred
alternative to address the barium contaminated surface soil.
RESPONSE; Although it is true that residual surface soil
barium concentrations will be higher in certain locations than at
the Gulf Coast Vacuum and PAB Oil Super fund Sites after treatment,
the need to implement the soil capping remedy in lieu of institu-
tional controls is not warranted.
First, the levels that will be left at D.L. Mud are not at
concentrations that pose a high significant or principal threat to
human health or the environment. The decision to implement S/S
treatment at Gulf Coast Vacuum and PAB Oil on contaminated soils
was not just based on the need to address barium but to address
other contaminants as well, which taken together, pose a much more
significant risk that the residual barium does at D.L. Mud. The
implementation of institutional controls provides just as good a
level of protectiveness to human health and the environment as does
the soil capping alternative.
Second, even after treatment, the treated waste will be left onsite
and institutional controls will be established at both Gulf Coast
Vacuum and PAB Oil. These controls will prohibit every kind of
future use in the areas of the site that contain the treated waste,
including industrial uses, which will be possible at D.L. Mud under
the land use restrictions presently considered. In addition, even
after implementing the soil capping remedy, institutional controls
would have to be established prohibiting future disturbances of the
cap. Thus we would be conducting treatment for treatment sake, and
not generating any additional protectiveness.
Finally, there remains some debate regarding the actual risk posed
by the residual barium. This issue is presently being reviewed by
EPA. If in the future, it is decided that existing risk assessment
factors need to be adjusted which result in the lowering of
potential risk calculations to below EPA action levels (i.e.,
Hazard Quotient <1.0), then the selected remedy will provide the
most flexibility to react to this change, if appropriate.
14. COMMENT; The fencing at the D.L. Mud site does not currently
extend to the northern property boundary. The area on the site
north of the existing fence contains surface soil contaminated with
barium above the action level of 5,400 ppm. This area should be
surrounded by a fence and an alternative access road (vhioh
currently transverses this area unimpeded) should be provided.
RESPONSE; The fencing component of the remedy is included for
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site security reasons and not risk abatement reasons. The site
fence presently discourages site access to the former process area
for trespassers and potential illegal dumping. As has been
mentioned earlier, no potential risks have been identified to
hypothetical trespassers or users of the property under any other
scenario other than the future residential scenario. The decision
to fence the northern area of the site is one which the current
owners of the property must decide. If the decision is made to
fence this area, then provisions for access to the neighboring
property which presently transverses this area will be provided
for.
15. COMMENT; The Proposed Plan calls for site access restrictions.
When developing the appropriate restrictions, please remember to
take into consideration tne Woodmen of the World camp located vest
of the site. The restrictions must be adequate to prevent site
access by the campers.
RESPONSE; The proposed plan and selected remedy call for land
use restrictions which will be memorialized in deed restrictions.
Although access restrictions are desirable for site security
reasons, nothing on the site poses a potential risk to humans under
any exposure scenario other than for hypothetical residents.
During the excavation activities, all care will be taken to
eliminate potential risks to trespassers which might come into
contact with temporarily exposed contaminants or physical hazards
(i.e., open excavations). The existing fence is adequate to
discourage trespassing in the excavation area. The cost of
installing site access controls that will ensure the prevention of
trespassers is not warranted given the lack of potential risks
posed by site contaminants on these potential receptors.
16. COMMENT; A procedure should be established to monitor an;
onsite impacts to the D.L. Mud site caused by the remedial
activities at the Gulf Coast Vacuum site. If contamination is
detected, a process should be in place to provide site remediation.
RESPONSE; It is beyond the scope of this ROD to address
contamination or releases that emanate from the Gulf Coast Vacuum
site. The Gulf Coast Vacuum RODs adequately address the need to
monitor their remedial activities to identify potential offsite
migration of contaminants. If during ground water monitoring, 5-
Year Reviews, or other O&M activities, it becomes obvious that
additional contamination concerns exist at D.L. Hud, then source
investigations of this contamination will be a part of the
evaluation into the need for additional site remediation.
17. COMMENTt EPA should: implement a program to monitor the
surrounding agricultural fields, grasing lands and aqua culture for
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potential contamination from air emissions and surface water runoff
from the site, establish continuous offsite monitoring stations to
monitor the quality of the air during organic contaminant removal,
and establish an ongoing program to monitor the quality of the
vater in individual water veils surrounding the sit* and provide
the analytical results to the citizens on a timely basis.
RESPONSE; Nothing in the past investigations at this site
indicate the need to conduct these suggested monitoring activities.
Based on this collected data, the potential for offsite migration
of site contaminants in levels that could be harmful to human
health or the environment is limited at best. Onsite air monitor-
ing will be conducted during the excavation of the organically
contaminated subsurface soils.
18. COMMENT; The citizens should be provided with opportunities to
participate in the decision making process during the design and
implementation phases of the remedial process.
RESPONSE; The public will be kept abreast of all remedial
design and remedial action activities through the use of public
open houses and periodic updates. Input on remedial design and
action specifics will be gathered on an as-needed-basis.
The following comments were received from Dow/DSI.
19. COMMENT; The uncertainties associated with the barium hazard
quotients calculated for the site make them overly conservative to
be the sole basis for a risk management decision. These uncertain-
ties include: l) the use of a chronic RfD for short-term exposures/
2) use of an RfD derived from a NOAEL where no higher concentra-
tions were tested, 3) use of the lifetime RfD for child exposures,
when "the population most at risk is the adult male", 4) the use of
an exposure approach that is not universally accepted within EPA
Regions, and 5) the assumption that all barium in soil is equally
as bioavailable as barium chloride in water.
RESPONSE; In choosing the remedy for the D.L. Mud site, EPA
considered all pertinent information that relates to the actual or'
potential risks associated with the site contaminants. The ROD
acknowledges that uncertainties exist with the risk assessment
(most notably the fact that the chronic and subchornic RfD for
barium are the same) and the choice of institutional controls as
the selected remedy is based partially on an evaluation of these
uncertainties.
In response to the five general comments:
1) Risk Assessment Guidance for Superfund (RAGS), Part A, states
that toxicological data from IRIS and HEAST should be used in
conducting a risk assessment. HEAST contains a subchronic RfD for
barium which was used for the short-term exposure assessment.
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2) This comment relates to the specific approach EPA used in
establishing the RfD values contained in IRIS and HEAST. EPA
Region 6 does not establish the RfD values contained in IRIS and
HEAST. The Region requested assistance from EPA's Environmental
Criteria and Assessment Office (ECAO) to provide guidance on the
use of the existing values in HEAST and the possibility of using an
alternative value as proposed by the commentor. This request has
been forwarded to the RfD Work Group whose function is to official-
ly establish the values to be contained in these references. Until
such time that an official response is acted upon by the RfD Work
Group, ECAO recommended that the existing subchronic RfD for barium
be used in the risk calculations at D.L. Mud (see Appendix #5 of
the ROD).
3) As stated earlier, EPA used the existing subchronic RfD for the
child, or short-term, risk exposure. This is in compliance with
RAGS, Part A. It is not true that EPA used the chronic RfD value
because "no subchronic RfD exists" as was stated in the comment
letter. A subchronic RfD does exists and was used in the assess-
ment. The merits of the subchronic RfD will be determined by the
RfD Work Group.
4) The exposure approach employed by the Region in conducting the
D.L. Mud risk assessment is in compliance with national guidance
and with the spirit and intent of the June 1990, RI/FS Administra-
tive Order on Consent (AOC). The agreed upon purpose of the AOC
was to determine the threat to the public health, welfare, or
environment caused by the release or threatened release of
hazardous substances from the site. To do this, a baseline risk
assessment was conducted which calculated a potential risk to
hypothetical children residents due mainly to the potential
ingestion of surface soils contaminated with residual barium. In
calculating the baseline risk, RAGs, Part A, Section 8.2.2,
discusses the importance of calculating the hazard index separately
for chronic and subchronic exposure periods. The use of the
integrated formula to determine "lifetime risks" for the purposes
of establishing remediation goals is a separate function from
conducting the baseline risk. As stated in the comment letter, the
use of the integrated formula is not directly intended to calculate
baseline risk.
Once it is established that a unacceptable potential risk exists to
a hypothetical receptor (the future residential child), the process
of developing the remediation goal is undertaken. The establish-
ment of the 5,400 ppm remediation goal for barium in surface soils
is based on a conservative approach using existing RfD values. The
acceptable barium concentration under the lifetime exposure
scenario (for oral ingestion only) is 19,000 ppm. Because there is
an unknown additional risk due to the intake of barium through the
agricultural uptake scenario, the actual acceptable barium
concentration would be lower than 19,000 ppm. This lower value is
unknown, therefore, the use of the more conservative value of 5,400
10
-------
(which is the acceptable concentration for future residential child
scenario) ppm is used. This will ensure protection of the lifetime
residential adult under the agricultural scenario as well as the
future residential child.
5) EPA has evaluated the concerns expressed by the commentor
regarding bioavaliability of barium in its different forms. It has
been determined that the bioavariability of barium from barium
sulfate contaminated soil is likely to be substantially less than
100%, but the site specific study (ChemRisk, 1992) does not provide
data adequate to define an absorption value for adjusting the RfD
value (see Appendix /6 of the ROD). In addition, the RfD Work
Group will evaluate the recent decision to exempt barium sulfate
from the reporting requirements of the Emergency Planning and
Community Right-to-Know Act of 1986, and any impact this decision
has regarding the issue of barium bioavailability.
20. COMMENT; in a recent OBITER Directive (9284.7-16, December
21, 1993), EPA states that ..."toxicological information other than
that in IRIS may be brought to the Agency by outside parties. Such
information should b« considered along with data in IRIS in
selecting toxieological values; ultimately, the Agency should
evaluate risk based upon the best scientific judgement and consider
all credible and relevant information available to it". During
formulation of the proposed plan of action for toe D.L. Mud site,
new toxieological information regarding the subchronic toxicity of
barium was made available to EPA. This new information is not
reflected in the Proposed Plan of Action.
RESPONSE; All information that was submitted to EPA during the
course of the RI/FS has been considered in selecting the remedy at
the D.L. Mud site. All information submitted by Dow/DSI regarding
the subchronic toxicity of barium was evaluated by not only the
Region but also -by ECAO. This review determined that although some
uncertainty exists as to the merits of the existing subchronic RfD
for barium, the continued use of this RfD is appropriate. Issues
regarding the merits of the subchronic RfD are continuing to be
evaluated by EPA. The selection of institutional controls has been
partly influenced by the existence of this uncertainty and is
direct evidence that the additional information submitted by
Dow/DSI has been considered.
21. COMMENT; The cost of the selected remedy (excavation and
offsite disposal to address the visually contaminated subsurface
soils) is not adequately justified as far as the derived benefits
to human health and the environment. The subsurface nature of this
material and its nonmobil nature exclude pathways of exposure and
potential resulting risks. The us* of institutional controls is
more appropriate for the perceived risks assumed to be posed by
these subsurface materials.
11
-------
EPA's proposed remedy for subsurface soils was based on the
findings of the RI/F8 process summarized in the Proposed Plan of
Action. EPA's proposed remedy includes the incorporation of
Alternative #« which is the excavation and offsite disposal of the
subsurface soils in question. This choice is based on the proposed
plan which states the "No specific risks vere quantified in any of
the obviously contaminated subsurface areas...". In addition, the
Proposed states that "A comparison of shallow and deep samples from
the borings indicates that the residual impacts of former site
operations on subsurface soils are limited to shallow depths..."
and that Discrete EPA samples collected from beneath the former
impoundment area generally indicate similar results...". The
Proposed Plan also shows that the D.L. Mud site has not impacted
ground water quality.
RESPONSE; The comment suggests that there is no risk from this
material and thus no benefit in cleaning it up. As discussed in
the ROD, the visually contaminated materials identified in the
subsurface soils in the former impoundment area have not been
adequately characterized so it is difficult to determine "the
derived benefits to human health and the environment" resulting
from the selected remedy. Although the sampling conducted on this
material and on the site as a whole support the general statements
regarding quantified risks and limited existing impacts on the
surrounding soils and ground water, the lack of information
regarding the nature of this material prohibits a determination on
the future impacts these contaminants would have. In addition, the
lack of quantified risks is due to the fact that this material
contains a large amount of tentatively identified compounds that
prohibit the quantification of their potential risk. EPA therefore
strongly disagrees with this comment.
It vas determined that the effort of investigating this material
further to better ascertain the potential risks associated with it
were not cost effective when considering the limited and localized
volumes of visually contaminated materials that would need to be
addressed by the selected remedy. This determination is also
consistent with one of the goals of the 1987 cleanup action which
was to remove all areas of visual contamination. The use of
institutional controls to address the obviously contaminated
subsurface soils was not chosen based on the evaluation of the nine
criteria. Program goals as stated in the NCP expect EPA to use
treatment to address principal threat or source areas in lieu of
engineering or institutional control measures wherever practicable.
Based on the unknown potential that this source material has, the
high expected costs of further investigation and on the relatively
low expected costs to implement the selected remedy, the selected
remedy provides the most appropriate and practicable approach to
address these materials.
12
-------
FOR YOUR INFORMATION
The following is a list of maps not included in the administrative record due to the size of the
documents (larger than 11"X 17"). The maps may be reviewed at U.S. EPA Region 6 upon
request. Contact Mr. Jamie VanBuskirk (Enforcement Officer) at (214) 655-6767 for additional
information.
"Survey Showing Monitoring Well Locations, Surface Soil Sampling Locations, Surface
Water/Sediment Sample Locations and Subsurface Soil Sample Locations at the D.L. Mud
and Gulf Coast Vacuum Sites", March 25, 1991 - Preliminary Site Characterization
Summary
The following maps are located in LAD 981058019 Superfund Site File - SFSA Volume
2;
"Abbeville, LA 1978 Water Record Map - Section 36"
"Abbeville, LA Water Record Map - Section 20"
"Abbeville. LA 1978 Water Record Map - Section 19"
"City of Abbeville, LA - Corporate Limit Boundaries
as of August 25, 1982"
"Abbeville, LA 1958 Water Record Map - Section 21"
"Abbeville, LA 1958 Water Record Map - Section 34"
"Abbeville, LA 1958 Water Record Map - Section 35"
"Abbeville. LA 1958 Water Record Map - Section 38"
"Abbeville, LA 1970 Water Record Map - Section 16"
"Abbeville, LA 1973 Water Record Map - Section 17"
"Abbeville. LA 1973 Water Record Map - Section 53"
"Abbeville. LA 1973 Water Record Map - Section 56"
-------
I. CHRONOLOGICAL LISTING
-------
Appendix #2
ADMINISTRATIVE RECORD INDEX
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME: D.L. MOD SUPERFUND SITE
SITE NUMBER: LAD 981058019
INDEX DATE: 02/08/94
-------
SPECIAL NOTE TO THE READER
The potentially responsible parties' (PRPs) responses to the July 20, 1989 General Notice Letter
and October 20, 1989 Special Notice Letter are located at the U.S. EPA Region 6 office, Dallas,
TX due to the voluminous number of responses received from the PRPs. The notice letters may
be found in the February 25, 1991 D.L. Mud Administrative Record (Document Nos. 000561-
00634). Included as attachments to the letters are the names of PRPs receiving the notice letters.
Due to the circumstances related to the site, most of the response letters do not necessarily affect
the selection of remedy. The PRPs' responses are in correlation to specific questions presented
by EPA in the general and special notice letters.
Please contact Mr. Jamie VanBuskirk, Enforcement Officer, at (214) 655-6767, if you wish to
view the response documents. If the reader wishes to learn more about the D.L. Mud Superfund
Site, they may refer to the Gulf Coast Vacuum Administrative Record, the Gulf Coast Vacuum
Remedial Investigation/Feasibility Study, and the Record of Decision for the Gulf Coast Vacuum
Site. These documents are provided in microfiche form and paper copy and are located at the
Vermilion Parish Library - Abbeville, LA and Louisiana Department of Environmental Quality -
Baton Rouge, LA.
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MOD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000907 - 000937
09/16/80
031
Hillol Ray, Environmental Engineer
Ecology & Environment,. Inc.
U.S. EPA Region 6 Superfund Site File
Site Inspection Report
"Potential Hazardous Waste Site Site Inspection Report"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000938 - 000938
10/04/85
001
Martha McKee, Chief, Superfund Site Assessment Section
U.S. EPA Region 6
William DeVille, Louisiana Department of Environmental Quality
(LDEQ)
Cover Letter w/o Enclosures
Interim site inspection report from 07/09-10/85 site visit and
sample analyses for Gulf Coast Vacuum and D.L. Mud
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000939 - 000953
11/12/85
025
Andy Goldberg and Bill Corbin
Louisiana State University - Institute for Environmental
Studies
U.S. EPA Region 6 Superfund Site Files
Site Inspection Report
"Potential Hazardous Waste Site Site Inspection Report"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000964 - 000995
12/11/85
032
Jairo Guevara, Field Investigation Team (FIT) Chemical
Engineer
Ecology & Environment, Inc.
Keith Bradley, Region 6 Regional Project Officer (RPO), U.S.
EPA Region 6
Memorandum
Sampling inspection at Gulf Coast Vacuum and D.L. Mud during
07/09-10/85
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MOD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000996 - 000997
12/16/85
002
G.W. Guerra
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site File
Tentative Disposition
"Potential Hazardous Waste Site Tentative Disposition"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000998 - 000998
12/31/85
001
Martha McKee, Chief, Superfund Site Assessment Section
U.S. EPA Region 6
T.B. McDonald, Dowell Schlumberger, Inc.
Corre spondence
Request that split sample results from lab analyses be
forwarded to EPA Region 6 offices
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000999 - 001002
01/07/86
004
G.F. Sievert, Manager of Safety and Loss Prevention and
Materials Control
Dowell Schlumberger, Inc.
Martha McKee, Chief, Superfund Site Assessment Section, U.S.
EPA Region 6
Cover Letter w/Enclosures
Re: 11/12/85 letter sent to LDEQ and results of analytical
work on samples taken during 07/09/85 site visit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001003 - 001004
01/30/86
002
Karen Young
U.S. EPA Region 6
Myron Knudson, U.S. EPA Region 6
Record of Communication (ROC)/Attachment
Information on oilfield waste site near Abbeville,
LA
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
D.L. MUD SUPERFUND SITE
LAD 981058019
001005 - 001005
07/08/86
001
EPA Staff
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site File
Site Log
"Potential Hazardous Waste Site Log"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001006 - 001006
07/08/86
001
Martha McKee, Chief, Superfund Site Assessment Section
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site File
Tentative Disposition
"Potential Hazardous Waste Site Tentative Disposition"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001007 - 001007
07/18/86
001
Martha McKee, Chief, Superfund .Site Assessment Section
U.S. EPA Region 6
D.L. Mud, Inc., Houston, TX
Cover Letter w/o Enclosure
Re: 09/27/85 site inspection report and sample analysis
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001008 - 001027
09/30/86
020
Jairo Guevara, FIT Chemical Engineer
Ecology and Environment, Inc.
Keith Bradley, Region 6 RPO, U.S. EPA Region 6
Memorandum w/Attachments
Re: 06/16/86 sampling inspection
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MOD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001028 - 001054
09/30/86
027
Jairo Guevara, FIT Chemical' Engineer
Ecology and Environment, Inc.
Keith Bradley, Region 6 RPO, U.S. EPA Region 6
Memorandum
Sampling inspection at D.L. Mud on 06/15/86
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001055 - 001200
10/03/86
146
Jairo Guevara, FIT Chemical Engineer
Ecology and Environment, Inc.
Keith Bradley, RPO, U.S. EPA-Region 6
Memorandum w/Attachments
Analytical data from 07/09/85-07/10/85 FIT sampling inspection
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001201 - 001202
02/09/87
002
Presley Hatcher, Acting Chief, Superfund Site Assessment
Section
U.S. EPA Region 6
Robert Lawrence, Inactive and Abandoned Sites Division, LDEQ
ROC
Re: Expanded Site Investigation
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001203 - 001208
02/10/87
006
C.M. Maddin, Materials Control
Dowell Schlumberger, Inc.
William DeVille, Administrator, Inactive and Abandoned Sites
Division, LDEQ
Cover Letter w/Attachment
Changed versions of 02/02/87 and 02/09/87 letters
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001209 - 001277
04/20/87
069
FIT - Region 6
Ecology and Environment, Inc.
U.S. EPA Region 6 Superfund Site File
Final Work Plan
"Expanded Site Inspection - Final Work Plan"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001278 - 001305
07/01/87
028
Environmental Monitoring Systems Laboratory, Office of
Research and Development
U.S. EPA - Las Vegas, NV
U.S. EPA Region 6 Superfund Site File
Aerial Photographic Analysis
"Aerial Photographic Analysis of Gulf Coast Vacuum and D.L.
Mud" (See "For Your Information")
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COM?ANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001306 - 001307
10/12/87
002
William DeVille, Administrator, Inactive and Abandoned Sites
Division
LDEQ
Presley Hatcher, Acting Chief, Superfund Site Assessment
Section, U.S. EPA Region 6
Correspondence
Site work completed to date
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001308 - 001346
12/17/87
039
C.M. Maddin, Materials Control
Dowell Schlumberger
William DeVille, Inactive and Abandoned Sites Division, LDEQ
Report - Volume 2
"Report of Decommissioning and Restoration of D.L. Mud Site"
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001347 - 001347
01/20/88
001
Barry Nash, NPL Coordinator, Superfund Site Assessment Section
O.S. EPA Region 6
Bob Myers, NPL Operations Section, U.S. EPA - Washington, D.C.
Memorandum w/o Attachment
Re: Special Study Waste Review
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001348 - 001348
06/22/88
001
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Honorable Brady Broussard, Mayor of Abbeville, LA
Cover Letter w/o Enclosures
Notification that D.L. Mud, Gulf Coast Vacuum, and Pab Oil
Sites are on the National Priority List of Superfund sites
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001349 - 001349
09/29/88
001
Paul Conzelmann
Subra Company
Robert Layton Jr., P.E., Regional Administrator, U.S. EPA
Region 6
Corre spondence
Requests EPA notify him when they visit Gulf Coast Vacuum, Pab
Oil, or D.L. Mud
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001350 - 001350
10/17/88
001
Presley Hatcher, Acting Chief, Superfund Site Assessment
Section
U.S. EPA Region 6
William DeVille, Administrator, Inactive and Abandoned Sites
Division, LDEQ
Cover Letter w/o Enclosures
Final Expanded Site Inspection Reports for Pab Oil, Gulf Coast
Vacuum, and D.L. Mud
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
D.L. MUD SUPERFUND SITE
LAD 981058019
001351 - 001355
06/26/89
005
Jairo Guevara, FIT Chemical Engineer
Ecology and Environment, Inc.
Ed Sierra, RPO, U.S. EPA Region 6
Memorandum w/Attachments
Water level measurements in monitor wells taken on 06/21/89
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001356 - 001356
10/05/89
001
Deborah Vaughn-Wright, Region 6 NPL Coordinator, Superfund
Site Assessment Section
U.S. EPA Region 6
Unspecified
Correspondence
Re: Final Rule #6 and Final Resource Conservation and Recovery
Act of 1976 Rule
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001357 - 001357
10/13/89
001
Cathy Gilmore
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site File
Memorandum
Summary of 09/21/89 meeting between EPA Region 6 and Vermilion
Parish Police Jury on D.L. Mud, Gulf Coast Vacuum, and Pab Oil
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001358 - 001358
03/07/90
001
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site File
Sign-In Sheet
Sign-In Sheet for Remedial Investigation/Feasibility Study
(RI/FS) negotiations meeting
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
D.L. MUD SUPERFUND SITE
LAD 981058019
001359 - 001361
03/09/90
003
Sydney Rooks, Attorney, Legal Department
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence
Dow Chemical Company requests 30-day extension of time to
complete negotiation of Administrative Order on Consent for
RI/FS
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001362 - 001362
03/15/90
001
Sydney Rooks, Attorney, Legal Department
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence
Re: Negotiation of Administrative Order on Consent for RI/FS
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001363 - 001363
03/22/90
001
Robert Layton Jr., P.E., Regional Administrator
U.S. EPA Region 6
Sydney Rooks, Attorney, Legal Department, Dow Chemical Company
Corre spondence
EPA extends RI/FS negotiation period and moratorium for an
additional 30 days until 04/13/90
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001364 - 001365
05/18/90
002
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site File
Memorandum
Summary of 05/11/90 meeting for Gulf Coast Vacuum, D.L. Mud,
and Pab Oil Sites
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001366 - 001379
05/25/90
014
Mark Ezell, Technical Assistance Team (TAT), Region 6
Ecology & Environment, Inc.
Michael Ryan, On-Scene Coordinator, Emergency Response Branch,
U.S. EPA Region 6
Site Assessment Report
"Site Assessment Report on D.L. Mud, Inc."
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001380 - 001381
07/03/90
002
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Cprre spondence
Notification of EPA Project Coordinator who is responsible for
overseeing the RI/FS
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001382 - 001390
08/02/90
009
Anthony Gardner, Regional TES 9 Manager
PRC Environmental Management, Inc. (PRO
Karen Hartis, Regional Project Officer, Superfund Managment
Branch, U.S. EPA Region 6
Cover Letter w/Attachment
Revised Work Plan for RI/FS Technical Oversight
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001391 - 001419
08/15/90
029
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence w/Attachments
EPA comments on RI Work Plan
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DRAFT
D.L. MUD SUPERFUND SITE
LAD 981058019
001420 - 001462
09/01/90
043
Staff Consultants
CH2M Hill
Dow Chemical Cotnpany/Dowell Schlumberger, Inc.
Response to Review Comments - Volume 4
"Response to EPA Review Comments Dated August 15,
1990"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001463 - 001530
10/01/90
068
Staff Consultants
CH2M Hill
Dow Chemical Cotnpany/Dowell Schlumberger, Inc.
Final Work Plan - Volume 1
"Remedial Investigation Work Plan"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001531 - 001619
10/01/90
089
Staff Consultants
CH2M Hill
Dow Chemical Company/Dowe11 Schlumberger, Inc.
Final Sampling/Analysis Plan - Volume 2
"Sampling and Analysis Plan Including Field Sampling Plan and
Quality Assurance Project Plan"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001620 - 001700
10/01/90
081
Staff Consultants
CH2M Hill
Dow Chemical Company/Dowell Schlumberger, Inc.
Final Health and Safety Plan - Volume 3
"Final Health and Safety Plan"
10
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001701 - 001702
10/10/90
002
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator,
Correspondence w/Attachment
Progress Report for September 1990
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001703 - 001705
10/19/90
003
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence
Formal approval of RI Work Plan on condition that minor
changes made and incorporated into final Work Plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001705 - 001707
10/31/90
002
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence
Preliminary field sampling schedule - RI
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001708 - 001709
11/09/90
002
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator,
Correspondence w/Attachment
Progress Report for October 1990
U.S. EPA Region 6
11
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DRAFT
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001710 - 001710
11/29/90
001
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site File
ROC
Phone conversation with Gay Hanks (President - VAPEdisplay
memoryfield activities
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001711 - 001724
11/29/90
014
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachments
Sample locations
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001725 - 001751
11/30/90
027
Brett Padgett, Contractor Project Manager
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Report
"Quality Assurance Project Plan"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001752 - 001754
12/10/90
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachment
Progress Report for November 1990
12
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MOD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001755 - 001763
01/03/91
009
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachment
Identification of potential source area - Gulf Coast Vacuum
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE :
DOCUMENT TITLE:
0017S4 - 001774
01/04/91
Oil
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Enclosures
Outline of Risk Assessment
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COM?ANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001775 - 001775
01/15/91
002
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Corre spondence
Comments on recent activities that have occurred regarding
ongoing RI/FS
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001777 - 001801
01/16/91
025
Brett Padgett, Contractor Project Manager
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Report
"Follow-Up Sampling - Quality Assurance Project Plan"
13
-------
ADMINISTRATIVE RECORD INDEX
DRAFT:
SITE NAME:
SITE NUMBER:
D.L. MOD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001802 - 001807
01/22/91
006
Brett Padgett, Contractor Project Manager
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Enclosure
Technical review on Potentially Responsible Parties (PRPs) RI
Risk Assessment outline
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
001808 - 002010
01/28/91
203
Brett Padgett, Contractor Project Manager
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Report
"Field Oversight Report - Phase 1 Activities"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002011 - 002014
01/29/91
004
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Corre spondence
Outline of Risk Assessment
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002015 - 002017
01/30/91
003
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Corre spondence
Memorandum on completion of field support activities - RI
14
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MOD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002018 - 002020
02/08/91
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator,
Correspondence w/Attachment
Progress Report for January 1991
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002021 - 002109
02/13/91
089
Brett Padgett, Contractor Project Manager
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Report
"Field Oversight Report - Followup Sampling Activities"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002110 - 002125
02/22/91
016
Jacobs Engineering Staff
Jacobs Engineering Group, Inc.
U.S. EPA Region 6 Superfund Site File
Revised Work Plan
"Community Relations"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002126 - 002126
03/07/91
001
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Corre spondence
Notice of additional sample collection
15
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DRAFT
D.L. MUD SUPERFUND SITE
LAD 981058019
002127 - 002129
03/11/91
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator,
Correspondence w/Attachment
Progress Report for February 1991
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002130 - 002246
03/25/91
117
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S
Cover Letter w/Attachment
Preliminary Site Characterization Summary
EPA Region 6
- RI
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002247 - 002265
03/27/91
019
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Attachment
Summary Identification Contaminants and List of Proposed
Indicator Chemicals - RI
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002266 - 002271
04/01/91
006
EPA Staff
U.S. EPA Region 6
Public
Superfund Site Update Fact Sheet
"Remedial Investigations Underway"
16
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME-:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
D.L. MUD SUPERFUND SITE
LAD 981058019
002272 - 002273
04/02/91
002
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Attachment
Additional background sample locations
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMP ANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002274 - 002274
04/04/91
001
Brett Padgett, Contractor Project Manager
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence
Review of "Preliminary Site Characterization Summary and
Summary Identification Contaminants and List of Proposed
Indicator Chemicals"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002275 - 002276
04/04/91
002
Brett Padgett, Contractor Project Manager
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachment
Split sample data request
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002277 - 002279
04/09/91
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachment
Progress Report for March 1991
17
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DRAFT
D.L. MUD SUPERFUND SITE
LAD 981058019
002280 - 002280
04/15/91
001
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
Tim Knight, Inactive and Abandoned Sites Division, LDEQ
Correspondence w/o Enclosure
Request for review and comment on draft copy of PRP
deliverable "Summary Identification Contaminants and List of
Proposed Indicator Chemicals"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002281 - 002284
04/16/91
004
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Corre spondence
Re: Issues pertaining to D.L. Mud Site
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002285 - 002296
04/19/91
012
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Attachment
Exposure Scenarios Technical Memorandum and Notification of
Fate and Transport Models - RI
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002297 - 002298
05/07/91
002
Ronald Ventola, Regulatory Functions Branch, Operations &
Readiness Division
U.S. Army Corps, of Engineers
Dr. John Beaver, Life Systems, Inc.
Correspondence w/Enclosure
D.L. Mud is not in a wetland subject to Corps, of Engineers'
jurisdiction
18
-------
SITE NAME:'
SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
DRAFT
D.L. MOD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002299 - 002307
05/07/91
009
Anthony Gardner, Regional TES 9 Manager
PRC
Karen Hartis, Regional Project Officer, Superfund Management
Branch, U.S. EPA Region 6
Cover Letter w/Attachment
Revised Work Plan for RI/FS Technical Oversight (Cost
documentation contained in the work plan is "Business
Confidential" and is not included. See "Special Note to the
Reader")
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002308 - 002310
05/10/91
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachment
Progress Report for April 1991
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002311 - 002312
05/13/91
002
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence
Comments on "Exposure Scenarios Technical Memorandum and
Notification of Fate and Transport Models"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002313 - 002315
05/31/91
003
Greg Goodman. P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Attachment
Submittal of "Toxicological and Epidemiological Memorandum'
19
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002316 - 002318
06/10/91
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator,
Correspondence w/Attachment
Progress Report for May 1991
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002319 - 002320
06/12/91
002
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence
Approval of "Toxicological and Epidemiology Studies
Memorandum"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002321 - 002321
06/21/91
001
Wilma Subra, President
Subra Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Corre spondence
Request for copies of all information on Pab Oil and D.L. Mud
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002322 - 002352
06/25/91
031
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Enclosure
Background sampling results
20
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME-
SITE NUMBER:
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002353 - 002355
07/10/91
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator,
Correspondence w/Attachment
Progress Report for June 1991
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002356 - 002356
07/11/91
001
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
Wilma Subra, President, Subra Company
Correspondence w/o Enclosure
Data results collected from the site
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002357 - 002358
08/09/91
002
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence
Re: RI
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002359 - 002361
08/12/91
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachment
Progress Report for July 1991
21
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DRAFT
D.L. MOD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002362 - 002367
08/26/91
006
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Facsimile Transmittal and Attachment
Corrected caution exchange capacity (CEC) data for soil
samples
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002368 - 002384
09/09/91
017
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence w/Attachments
Draft RI and Risk Assessment comments
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002385 - 002408
09/09/91
024
Brett Padgett, Contractor Project Manager
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Enclosure
Submittal of "Quality Assurance Project Plan"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002409 - 002411
09/10/91
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachment
Progress Report for August 1991
22
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002412 - 002420
10/08/91
009
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachments
Summary of results from 09/09-10/91 sampling - RI
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COM?ANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002421 - 002421
10/09/91
001
EPA Staff
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site File
Sign-in Sheet
Sign-in sheet for 10/09/91 meeting regarding Draft RI Report
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER Or PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002422 - 002422
10/10/91
001
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator,
Correspondence
Notice of additional sampling - RI
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002423 - 002426
10/10/91
004
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachment
Progress Report for September 1991
23
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DRAFT
D.L. MUD SUPERFUND SITE
LAD 981058019
002427 - 002431
10/28/91
005
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations,
Correspondence w/Attachment
Followup of 10/09/91 meeting about RI
Dow Chemical Company
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002432 - 002432
10/28/91
001
Greg Goodman, P.E.
CH2M Hill
Jamie VanBuskirk,
Correspondence
Notification to EPA that revised RI Report cannot be submitted
in accordance with Administrative Order on Consent, Section
VIII. 23. E
Project Manager
Project Coordinator,
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002433 - 002439
11/11/91
007
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachments
Progress Report for October 1991
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002440 - 002465
11/12/91
026
Nancy Fagan, Geologist
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachments
Oversight activities from 10/24-29/91
24
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002466 - 002466
11/13/91
001
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Corre spondence
Followup on recent phone conversations between EPA and CH2M
Hill about additional work at the site
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002467 - 002168
11/20/91
002
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence
EPA disapproves of proposed work plan for additional field
work submitted to EPA on 11/11/91
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002469 - 002471
11/21/91
003
Ann Schober
U.S. EPA Region 6
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
ROC
Re: Gulf Coast Vacuum/D.L. Mud Sites - Adjacent canal sampling
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002472 - 002484
11/22/91
013
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Enclosure
Revised Work Plan for project completion - RI
25
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
D.L. MUD SUPERFUND SITE
LAD 981058019
002485 - 002497
11/29/91
013
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Enclosure
Work Plan for completion of RI
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002498 - 002498
12/02/91
001
Brett Padgett, Contractor Project Manager
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence
PRC will conduct split-sampling activities from 12/03-08/91
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002499 - 002500
12/05/91
002
Joe Tieger
U.S. EPA
Regional Coordinators, U.S. EPA Regions 1-10
Memorandum w/Attachment
Re: Ecological Risk Assessments: Their Place in Records of
Decision (RODs) and Cost Documentation
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002501 - 002502
12/10/91
002
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Corporation
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachment
Progress report for November 1991
26
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002503 - 002505
12/16/91
003
Brett Padgett, Contractor Project Manager
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Corre spondence
Minutes to 10/09/91 Risk Assessment meeting
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER Or PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002506 - 002507
12/20/91
002
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Corre spondence
Request for data generated from EPA activities and submission
of split sample data
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER CF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002508 - 002509
12/26/91
002
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence
Confirmation of 01/15/92 meeting
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002510 - 002516
12/30/91
007
Nancy Pagan, PRC Geologist
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachments
Re: 12/13/91 visual inspection of canal
27
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DRAFT
D.L. MUD SUPERFUND SITE
LAD 981058019
002517 - 002584
12/31/91
068
Unspecified
Unspecified
U.S. EPA Region 6 Superfund Site File
Guidance Documents
Miscellaneous guidance documents used in the selection of
remedy for D.L. Mud
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002585 - 002585
01/10/92
001
EPA Staff
U.S. EPA Region 6
Public
Superfund Site Update Fact Sheet
"Remedial Investigations Continue1
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002586 - 002587
01/15/92
002
EPA Staff
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site File
Meeting Agenda and Attachment
Agenda and sign-in list for RI meeting
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002588 - 002592
01/15/92
005
EPA Staff
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site File
Meeting Minutes
Minutes to PRP meeting
28
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
D.L. MUD SUPERFUND SITE
LAD 981058019
002593 - 002595
02/10/92
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator,
Correspondence w/Attachment
Progress Report for January 1992
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE :
NUMBER OF PAGES:
AUTHOR:
COM?ANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002596 - 002599
02/21/92
004
Greg Goodman. P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator,
Fax Transmittal w/Attachment
Re: Sampling data
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NTOBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002SOO - 002607
'02/21/92
008
Tom Nelson
Sverdrup Corporation
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Facsimilie Transmittal w/Attachment
Re: Sampling data from Gulf Coast Vacuum
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002608 - 002608
02/25/92
001
Garret Bondy, Chief, AR/LA Superfund Enforcement Section
U.S. EPA Region 6
Don Draper, Director, Technical Support Center, Robert S. Kerr
Research Laboratory, U.S. EPA
Memorandum
Request for technical support
29
-------
SITE NAME:
SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
DRAFT
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY /AGENCY :
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002609 - 002615
02/25/92
007
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence
Summary of discussions held between Dow Chemical Company and
EPA during 01/15/92 meeting
DOCUMENT ^NUMBER:
DOCUMENT ~DATE:
NUMBER OF PAGES::
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002616 - 002620
02/25/92
005
"Jamie VanBuskirJfrr^roject Coordinator
U.s7^EEAR»glon 6
W.J. Witft>vNManager, CERCLA Operations, Dow Chemical Company
C . ^
^ions held between Dow Chemical Company and
01/15/92'Xeeting
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER 0? PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002621 - 002758
02/28/92
138
Brett Padgett, Contractor Project Manager
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Enclosure
Submittal of "Field Oversight Report"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002759 - 002761
02/29/92
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence
Summary of 01/15/92 meeting - RI issues
30
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
D.L. MUD SUPERFUND SITE
LAD 981058019
002762 - 002780
03/02/92
019
Carl Hicham, R.S., Senior Regional Representative
Agency for Toxic Substances and Disease Registry - Region 6
Allyn M. Davis, Director, Hazardous Waste Management Division,
U.S. EPA Region 6
Correspondence w/Attachment
"Interim Preliminary Health Assessment"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002781 - 002781
03/05/92
001
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence w/o Attachment
Procedure for calculating agricultural portion of residential
exposure scenario as discussed in 01/15/92 meeting and EPA's
02/25/92 letter
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002782 - 002884
03/06/92
103
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Enclosure
Data submittal and request for verification of inclusion of
EPA samples
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002885 - 002887
03/10/92
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachment
Progress Report for February 1992
31
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MOD SUPERFDND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002888 - 002888
03/17/92
001
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site File
ROC
Re: Phone conversation with David Price (CH2M Hill) about
collection of additional samples at empty drum area and for
barium specification
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002889 - 002892
03/19/92
004
Harold Underwood
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Fax Transmittal w/Attachment
Notice that Dow Chemical Company plans to collect additional
samples to investigate barium sulfate in soils and drum found
in onsite canal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002893 - 002893
03/24/92
001
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Corre spondence
Acknowledgment of written notice from CH2M Hill about proposal
to collect additional samples on 03/20/92
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002894 - 002894
03/30/92
001
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Corre spondence
Request for copy of Gulf Coast Vacuum RI Report
32
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
D.L. MUD SUPERFUND SITE
LAD 981058019
002895 - 002897
04/10/92
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator,
Correspondence w/Attachment
Progress Raport for March 1992
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002898 - 002908
04/15/92
Oil
Nancy Pagan, Geologist
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence and Attachment
Split-sampling and oversight visit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002909 - 002909
04/16/92
001
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Corre spondence
Oral notice given by CH2M Hill on 03/10/92 to EPA Region 6 and
on 03/11/92 to EPA's contractor (as directed by EPA) about
planned collection of additional samples
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002910 - 002910
04/23/92
001
Brett Padgett, Contractor Project Manager
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence
Split sample data review
33
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
D.L. MUD SUPERFUND SITE
LAD 981058019
002911 - 002914
05/11/92
004
Nancy Fagan, Geologist
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence
Minutes to 05/07/92 Risk Assessment meeting
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002915 - 002917
05/11/92
003
W.j. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator,
Correspondence w/Attachment
Progress Report for April 1992
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002918 - 002924
05/12/92
007
Wanda Hall, Data Package Supervisor
CH2M Hill
Greg Goodman, P.E., Project Manager, CH2M Hill
Correspondence w/Enclosures
Re: Analytical data - LMG Laboratory No. 21501
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002925 - 002932
05/14/92
008
Ghassan Khoury, Regional Toxicologist
U.S. EPA Region 6
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Memorandum
Re: Values of variables in intake equation for different
exposure routes to be used in Risk Assessment
34
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002933 - 002937
05/15/92
005
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator,
Correspondence
Summary of 05/07/92 meeting - RI
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002938 - 002942
05/15/92
005
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence
Summary of 05/07/92 meeting - RI
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002943 - 002944
06/01/92
002
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence
Schedule for completion of RI
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002945 - 002946
06/03/92
002
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachment
Information request from Gulf Coast Vacuum Site - D.L. Mud
Site RI
35
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DRAFT
D.L. MOD SDPERFOND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002947 - 002953
06/03/92
007
Terry O'Bryan, Chemical Assessment Desk, Office of Pollution
Prevention and Toxics
U.S. EPA - Washington, D.C.
Ghassan Khoury, Regional Toxicologist, U.S. EPA Region 6
Memorandum w/Attachment
Re: Bioavailability of barium sulfate
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002954 - 002954
06/03/92
001
Ghassan Khoury, Regional Toxicologist
U.S. EPA Region 6
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Memorandum
Re: Surface soil and sediment data
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002955 - 002963
06/08/92
009
Anthony Gardner, Regional TES 9 Manager
PRC
Karen Hartis, CERCLA Regional Project Officer, Superfund
Management Branch, U.S. EPA Region 6
Cover Letter w/Attachment
Revised Work Plan for RI/FS Technical Oversight (Cost
documentation contained in the work plan is "Business
Confidential and is not included. See "Special Note to the
Reader")
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002964 - 002967
06/08/92
004
Anthony Gardner, Regional TES 9 Manager
PRC
Karen Hartis, CERCLA Regional Project Officer, Superfund
Management Branch, U.S. EPA Region 6
Cover Letter w/Attachment
Revised Work Plan for RI/FS Technical Oversight (Cost
documentation contained in the work plan is "Business
Confidential" and is not included. See "Special Note to the
Reader")
36
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DRAFT
D.L. MUD SUPERFUND SITE
LAD 981058019
002958 - 002970
06/10/92
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator,
Correspondence w/Attachment
Progress Report for May 1992
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002971 - 002976
06/24/92
006
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence w/Attachments
Re: 1) Further investigative activities regarding former
impoundments needed and 2) future schedule of RI/FS
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002977 - 002977
06/29/92
001
Tom Nelson
Sverdrup Corporation
Ann Schober, U.S. EPA Region
Technical Memorandum
Historical aerial photograph
and D.L. Mud Superfund Sites
(02/17/74) of Gulf Coast Vacuum
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002978 - 002980
07/01/92
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Corre spondence
Response to 06/25/92 EPA letter
37
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002981 - 002983
07/10/92
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator,
Cover Letter w/Attachment
Progress report for June 1992
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002984 - 002985
07/10/92
002
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Corre spondence
Response to EPA's 07/01/92 letter
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002986 - 002993
07/17/92
008
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachment
Work Plan for additional EPA requested investigation and
response to EPA's 06/25/92 letter
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002994 - 002995
07/28/92
002
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence
Comments on proposed Work Plan revision
38
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MOD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
00299S - 002996
07/29/92
001
David Price
CH2M Hill.
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/o Enclosure
Former impoundment structure area map
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002997 - 002997
08/10/92
001
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site File
ROC
Phone conversation with CH2M Hill and Dow Chemical regarding
health effects assessment summary tables
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMP ANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
002998 - 003000
08/10/92
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Attachment
Progress report for July 1992
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003001 - 003002
08/12/92
002
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence w/o Attachment
Risk assessment issues
39
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DRAFT
D.L. MUD SUPERFUND SITE
LAD 981058019
003003 - 003006
08/17/92
004
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachment
Revised Work Plan for additional EPA requested investigation
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003007 - 003007
08/27/92
001
Jamie VanBuskirk,
U.S. EPA Region 6
W.J. Witt, Manager,
Correspondence
Formal approval of revised Work Plan for additional trenching
investigation
Project Coordinator
CERCLA Operations, Dow Chemical Company
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003008 - 003010
09/10/92
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Attachment
Progress report for August 1992
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003011 - 003014
09/11/92
004
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/o Attachments
Response to 08/12/92 and 08/27/92 EPA letters
40
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
D.L. MUD SUPERFUND SITE
LAD 931058019
003015 - 003015
09/22/92
001
Ghassan Khoury, Regional Toxicclogist
U.S. EPA Region 6
Jamie VanBuskirk, Project Coordinator,
Memorandum
Re.: Bioavailability of barium sulfate
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003016 - 003017
10/15/92
002
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Corre spondence
Resolution of outstanding risk assessment issues
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003018 - 003048
10/20/92
031
Ghassan Khoury, Regional Toxicologist
U.S. EPA Region 6
Joan Dollarhide, Office of Research and Development, U.S.
- Cincinnati, OH
Memorandum w/Attachment
Bioavailability of barium sulfate
EPA
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003049 - 003061
10/20/92
013
Ghassan Khoury, Regional Toxicologist
U.S. EPA Region 6
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Memorandum w/Attachments
Re: Response to D.L. Mud letter "Resolution of Outstanding
Risk Assessment Issues"
41
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
D.L. MUD SUPERFUND SITE
LAD 981058019
003052 - 003085
10/23/92
024
Mark Ezell, Environmental Scientist
PRC Environmental Management, Inc. (PRO
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachments
Re: 08/31/92 - 09/01/92 site visit to perform split sampling
and oversight of sampling activities
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003086 - 003087
10/23/92
002
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence
Re: Risk Assessment
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003088 - 003093
11/10/92
006
Nancy Fagan, Contractor Project Manager
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Enclosure
"D.L. Mud Former Pit Area Sample Data Differences"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003094 - 003152
11/10/92
059
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator,
Cover Letter w/Attachment
Progress report for October 1992
U.S. EPA Region 6
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
D.L. MUD SUPERFUND SITE
LAD 981058019
003153 - 003153
11/23/92
001
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Corre sp ondence
Submission of RI Report
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003154 - 003160
11/29/92
007
Joan Dollarhide, Office of Research and Development
U.S. EPA - Cincinnati, OH
Ghasson Khoury, Regional Toxicologist, U.S. EPA Region 6
Memorandum w/Attachment
Evaluation of barium desorption pilot study and the relevance
of desorption study to barium risk assessment
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
'003161 - 003354
12/07/92
204
Greg Goodman, P.E., Project Manager
CH2M Hill
U.S. EPA Region 6 Superfund Site File
Cover Letter w/Report
RI Report
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER 0? PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
003365 - 003650
12/07/92
286
Greg Goodman, P.E., Project Manager
CH2M Hill
U.S. EPA Region 6 Superfund Site File
Appendixes
RI Report - Appendixes A-G
43
-------
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
DRAFT
D.L. MUD SUPERFUND SITE
LAD 981058019
003651 - 004104
12/07/92
454
Greg Goodman, P.E., Project Manager
CH2M Hill
U.S. EPA Region 6 Superfund Site File
Appendix
RI Report - Appendix H
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004105 - 004594
12/07/92
490
Greg Goodman, P.E., Project Manager
CH2M Hill
U.S. EPA Region 6 Superfund Site File
Appendixes
RI Report - Appendixes I-K
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004595 - 004597
12/10/92
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Attachment
Progress report for November 1992
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004598 - 004601
01/05/93
004
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Facsimile Transmittal w/Attachments
Re: Subchronic toxicity of barium chloride
44
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SUPERFDND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004602 - 004602
01/11/93
001
Ghassan Khoury, Regional Toxicologist
U.S. EPA Region 6
Joan Dollarhide, Office of Research and Development, U.S. EPA
- Cincinnati, OH
Memorandum
Impact of the new study on the chronic and subchronic toxicity
values of barium
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004603 - 004604
01/11/93
002
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Attachment
Progress report for December 1992
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004605 - 004609
01/22/93
005
Dennis W. Shelton, Toxicologist
CH2M Hill
W.J. Witt, Manager, CERCIA Operations, Dow Chemical Company
Corre spondence
Development of a subchronic oral reference dose value (RfD)
for barium
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004610 - 004615
01/26/93
006
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Attachment
Development of a subchronic oral RfD value for barium
45
-------
SITE NAME:
SITE NUMBER:
ADMINISTRATIVE RECORD INDEX
DRAFT
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004616 - 004616
01/26/93
001
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
Harold Ethridge, Louisiana Department of Environmental Quality
(LDEQ)
Cover Letter w/o Enclosures
Draft F$ Report - Pab Oil and RI Report - D.L. Mud
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004617 - 004625
02/03/93
009
Joan Dollarhide, Office of Research and Development
U.S. EPA - Cincinnati, OH
Ghassan Khoury, Regional Toxicologist, U.S. EPA Region 6
Memorandum w/Attachment
Review of the Dietz et al. (1992) Study for RfD for Barium
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004626 - 004627
02/10/93
002
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Attachment
Progress report for January 1993
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004628 - 004628
02/16/93
001
Ghassan Khoury, Regional Toxicologist
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site File
ROC
Phone conference with Lynn Papa (U.S. EPA - Cincinnati, OH)
about subchronic RfD toxicity value for barium
46
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
D.L. MUD SUPER'FUND SITE
LAD 931058019
004629 - 004629
02/16/93
001
Ghassan Khoury, Regional Toxicologist
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site File
ROC
Subchronic RfD toxicity value for Barium
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004630 - 004630
03/01/93
001
Debra McKean
PRC
Nancy Fagan, Contractor Project Manager,
Facsimilie Transmittal
Requested barium numbers
PRC
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004631 - 004632
03/05/93
002
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Corre spondence
Formal approval of RI Report subject to comments contained in
letter
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004633 - 004633
03/08/93
001
Brent Schindler, Attorney
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Corre spondence
Freedom of Information Act request for EPA Region 6 and EPA
Cincinnati, OH documents dated post-12/08/92 about toxicity
evaluation for barium
47
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004634 - 004635
03/10/93
002
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Attachment
Progress report for February 1993
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004636 - 004636
03/19/93
001
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence
Response to EPA's comments outlined in 03/09/93 letter
regarding RI Report
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004637 - 004638
03/26/93
002
Don Williams, Chief, Texas Superfund Remediation Section
U.S. EPA Region 6
Joan Dollarhide, Office of Research and Development, U.S.
- Cincinnati, OH
Memorandum
Evaluation of Subchronic RfD for Barium
EPA
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004639 - 004644
04/01/93
006
CH2M Hill Staff
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Meeting Agenda and Attachments
"FS Options Meeting"
48
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004645 - 004646
04/05/93
002
Nancy Pagan, Contractor Project Manager
PRC
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Memorandum
Minutes to 04/01/93 meeting with Dow Chemical and CH2M Hill
about proposed FS
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT: '
DOCUMENT TYPE:
DOCUMENT TITLE:
004647 - 004647
04/07/93
001
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site File
ROC
Phone conference between EPA Region 6,
Dow Chemical Company,
and CH2M Hill as followup to 04/01/93 meeting
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004648 - 004649
04/07/93
002
Joe Winkle, Regional Administrator
U.S. EPA Region 6
Bill Luthans, Superfund Enforcement Section, U.S. EPA Region 6
Memorandum
Re: Lifting Recusal from Involvement in Pab Oil and D.L. Mud
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004650 - 004652
04/12/93
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Attachment
Progress report for March 1993
49
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004653 - 004654
04/12/93
002
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Corre epondence
Re: 1) Followup on 04/01/93 meeting and 04/07/93 phone
conversation about conductance of FS and 2) extension of due
date for submittal of FS Work Plan until 04/23/93
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004655 - 004668
04/23/93
014
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator,
Cover Letter w/Attachment
Draft FS Work Plan
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004669 - 004671
04/28/93
003
Greg Goodman, P.E. Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Facsimile Cover Sheet and Attachments
Re: Barium toxicological profiles
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004672 - 004673
04/29/93
002
Brent Schindler, Attorney
Dow Chemical Company
Nellie Shirer, Office of Regional Counsel (ORC), U.S. EPA
Region 6
Correspondence
Comments regarding draft Administrative Order on Consent
50
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004674 - 004691
04/30/93
018
William Ripley, Certified Petroleum Geologist
Consultant
U.S. EPA Region 6 Superfund Site Files
Report
Investigation of barium as a trace element
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004692 - 004695
05/06/93
004
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence
Formal disapproval of the draft FS Work Plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004696 - 004698
05/10/93
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Attachment
Progress report for April 1993
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004699 - 004699
05/14/93
001
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
Harold Ethridge, Administrator, Inactive and Abandoned Sites
Division, LDEQ
Cover Letter w/o Enclosures
Additional information relating to investigation of former
impoundment area found at the site
51
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MOD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004700 - 004700
05/14/93
001
Ghassan Khoury, Regional Toxicologist
U.S. EPA Region 6
Jamie VanBuskirk, Project Coordinator,
Memorandum
Risk Assessment TICs Evaluation
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004701 - 004716
05/19/93
016
Gary Diamond and Elena Mantis-Mercader
Syracuse Research Corporation
Joan Dollarhide, Office of Research and Development, U.S. EPA
- Cincinnati, OH
Memorandum w/Attachment
Review of Subchronic and Chronic RfDs for Barium
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004717 - 004733
05/28/93
017
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Correspondence w/Attachment
Revised FS Work Plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004734 - 004734
06/09/93
001
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site File
ROC
Phone conversation with W.J. Witt (Dow Chemical
regarding FS Work Plan
Company)
52
-------
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
DRAFT
D.L. MUD SUPERFUND SITE
LAD 981058019
004735 - 004736
06/10/93
002
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
James VanBuskirk, Project Coordinator,
Cover Letter w/Attachment
Progress report for May 1993
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004737 - 004738
06/18/93
002
John Rauscher, Regional Toxicologist
U.S. EPA Region 6
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Memorandum
Central tendency exposure and reasonable maxium exposure soil
ingestion rate for residential child scenario used in RI
Report
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004739 - 004742
06/18/93
004
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence
EPA disapproves the revised FS Work Plan dated 05/28/93
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004743 - 004758
06/25/93
016
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Fascimile Cover Sheet and Attachment
Proposed rule exempting barium sulfate from toxic chemical
reporting requirements
53
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SDPERFUND SITE
LAD 991058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004759 - 004759
05/28/93
001
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site File
Meeting Agenda
"D.L. Mud FS Work Plan Meeting"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004760 - 004773
06/30/93
014
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Enclosure
Revised FS Work Plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004774 - 004774
07/09/93
001
Jamie VanBuskirk, Project Manager
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence
EPA formally approves FS Work Plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004775 - 004794
07/23/93
020
Don Williams
U.S. EPA Region 6
Joan Dollarhide, Office of Research and Development, U.S. EPA
- Cincinnati, OH
Memorandum w/Attachments
Review of Subchronic and Chronic RfDs for Barium
54
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MOD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004795 - 004796
08/10/93
002
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Attachment
Progress report for July 1993
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004797 - 004834
08/11/93
038
Greg Goodman,'P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter and Enclosure
"Final Screening Results Memorandum - D.L. Mud Site FS"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004835 - 004836
•08/24/93
002
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Corre spondence
Submittal of EPA comments on "Final Screening Results
Memorandum - FS"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004837 - 004840
08/27/93
004
Joan Dollarhide, Associate Director, Office of Research and
Development
U.S. EPA - Cincinnati, OH
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Memorandum and Attachment
Review of Subchronic and Chronic RfDs for Barium
55
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DRAFT
D.L. MUD SUPERFUND SITE
LAD 981058019
004841 - 004842
09/10/93
002
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
James VanBuskirk, Project Coordinator,
Cover Letter w/Attachment
Progress report for August 1993
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004843 - 004844
09/13/93
002
Linda Papa, Office of Research and Development
U.S. EPA - Cincinnati, OH
Joan Dollarhide, Office of Research and Development, U.S. EPA
- Cincinnati, OH
Memorandum
Review of Subchronic/Chronic RfD for Barium
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004845 - 004848
09/14/93
004
Joan Dollarhide, Office of Research and Development
U.S. EPA - Cincinnati, OH
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Memorandum w/Attachment
Review of Subchronic and Chronic RfDs for Barium
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004849 - 004849
09/29/93
001
Greg Goodman, P.E., Project Manager
CH2M Hill
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/o Attachment
Re: Draft FS Report
56
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MOD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004850 - 004850
10/20/93
001
Kaplan Herald Staff Writer
The Kaplan Herald
Public
Notice
Re: 1) Record of Decision for Pab Oil and 2)' Pab Oil and D.L.
Mud Superfund Sites Open House - 10/26/93
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004851 - 004851
10/21/93
001
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
Tim Knight, Administrator, Inactive and Abandoned Sites
Division, LDEQ
Corre spondence
EPA requests LDEQ's assistance and participation in preparing
the ROD
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF FACES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004852 - 004852
10/24/93
001
Abbeville Meridional Staff Writer
Abbeville Meridional
Public
Notice
Open House for Pab Oil and D.L. Mud - 10/26/93
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004853 - 004853
10/26/93
001
EPA Staff
U.S. EPA Region 6
Public
Sign-In List
Sign-In List for 10/26/93 Open House for Pab Oil and D.L. Mud
57
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DRAFT
D.L. MUD SUPERFUND SITE
LAD 981058019
004854 - 004855
10/27/93
002
Felicia Dugas, Staff Writer
Abbeville Meridional
Public
Newspaper Article
"Pab Oil site remedy, D.L. Mud discussed"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004856 - 004856
10/27/93
001
Janice Macomber, Acadiana Correspondent
Advertiser
Public
Newspaper Article
"Superfund cleanup plan presented for Pab site"
RAX a el)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004857 - 004857
10/27/93
001
Acadiana Bureau Staff Writer
The Adocate
Public
Newspaper Article
"Superfund site cleanup may take 4 years"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004858 - 004858
10/27/93
001
Tim Knight, Administrator, Inactive and Abandoned Sites
Division
LDEQ
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Corre spondence
LDEQ comments on FS Report
58
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMP ANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004859 - 004865
11/04/93
007
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
W.J. Witt, Manager, CERCLA Operations, Dow Chemical Company
Correspondence
EPA comments on the Draft FS Report
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004866 - 004874
11/10/93
009
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator,
Cover Letter w/Attachment
Progress report for October 1993
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004875 - 004877
11/10/93
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator,
Cover Letter w/Attachment
Progress report for October 1993
U.S. EPA Region 6
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMP ANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004878 - 004901
11/10/93
024
Terry 0'Bryan, Chemical Screening and Risk Assessment Division
U.S. EPA - Washington, D.C.
Ghassan Khoury, Regional Toxicologist, U.S. EPA Region 6
Memorandum and Attachments
Re: 1) Request for structure-activity estimates and 2) 1989
"Structural Activity Relationships of Alkanes and Alkenes
Report"
59
-------
ADMINISTRATIVE RECORD INDEX
DRAFT
SITE NAME:
SITE NUMBER:
D.L. MUD SUPERFUND SITE
LAD 981058019
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004902 - 004909
11/15/93
008
Jamie VanBuskirk, Project Coordinator
U.S. EPA Region 6
Joan Dollarhide, Office of Research and Development, U.S. EPA
- Cincinnati, OH
Fascimile Cover Sheet and Attachments
Re: 1} 10/93 October progress report and 2) Memorandum "Review
of the Subchronic RfD for Barium"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004910 - 004911
12/10/93
002
EPA Staff
U.S. EPA Region 6
Public
Site Update Fact Sheet
"Site Investigation Completed"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004912 - 004914
12/10/93
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator, U.S. EPA Region 6
Cover Letter w/Attachment
Progress report for November 1993
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
004915 - 004917
01/10/94
003
W.J. Witt, Manager, CERCLA Operations
Dow Chemical Company
Jamie VanBuskirk, Project Coordinator,
Cover Letter w/Attachment
Progress report for December 1993
U.S. EPA Region 6
60
-------
Appendix #3
STATE OF LOUISIANA LETTER DF CONCURRENCE ON THE
SELECTED REMEDY
-------
-------
State of Louisiana
Department of Environmental Quality
Edwin W. Edwards
Governor
September 1, 1994
William A. Kucharski
Secretary
o
Jamie VanBuskirk
Remedial Project Manager (6H-EA)
Region VI
U.S. Environmental Protection Agency
Dallas, TX 75202-2733
RE: Draft Record of Decision D.L. Mud Superfund Site
Dear Mr. VanBuskirk:
Personnel of the Louisiana Department of Environmental Quality
Inactive and Abandoned Sites Division (LDEQ/IASD) have completed
their review of the Draft Record of Decision dated August 12, 1994.
We are in agreement with the selected remedial actions for the D.L.
Mud, Inc. Superfund Site and have no further comments on the Draft
Record of Decision.
If you have any further questions, please contact Mr. Rich Johnson
of this office at (504) 765-0487.
Sincerely.
Tim B. Knight
Administrator
TBK:RJ:j1
OFFICE OF LEGAL AFFAIRS AND ENFORCEMENT
INACTIVE AND ABANDONED SITES DIVISION P.O. BOX 82282
TELEPHONE (504) 765-0487 FAX (504) 765-0484
AN EQUAL OPPORTUNITY EMPLOYER
BATON ROUGE, LOUISIANA 70884-2282
-------
State of Louisiana
Department of Environmental Quality
'f/, i «•« h I. I.'' ''
Edwin W. Edwards
Governor
May 6, 1994
William A. Kucharski
Secretary
Jamie VanBuskirk
Remedial Project Manager (6H-EA)
U.S. Environmental Protection Agency
1445 Ross Ave. Suite 1200
Dallas, TX 7502-2733
RE: Proposed Plan of Action for D.L. Mud
Superfund Site, Vermilion Parish Louisiana
Dear Mr. VanBuskirk:
Personnel of the Louisiana Department of Environmental Quality
(LDEQ) have completed their review of the Proposed Plan of Action
for the D.L. Mud Superfund Site in Abbeville Louisiana, received on
April 29, 1994.
We support the preferred alternatives for addressing the site
contaminants which will meet the primary remedial objectives by
combining Alternative #2 and Alternative #6. These alternatives
will provide for institutional controls and the excavation and
offsite disposal of contaminated subsurface soils.
If you have any questions, please contact Mr. Rich Johnson of this
office at (504) 765-0487.
Sincerely,
Tim B. Knight
Administrator
Inactive and Abandoned Sites Division
TBK:RJ:
OFFICE OF LEGAL AFFAIRS AND ENFORCEMENT
INACTIVE AND ABANDONED SITES DIVISION P.O BOX 82282 BATON ROUGE. LOUISIANA 70884-2282
TELEPHONE (504) 765-0487 FAX (504) 765-0484
-------
Appendix #4
SELECTED ALTERNATIVE COST ESTIMATE
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Appendix #5
JUNE 27, 1994 MEMO FROM ECAO REGARDING
SUBCHRONIC AND CHRONIC RfD FOR BARIUM
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF RESEARCH AND DEVELOPMENT .. '. •'•_
ENVIRONMENTAL CRITERIA AND ASSESSMENT OFFICE '
CINCINNATI. OHIO 45268
MEMORANDUM
DATES
SUBJECT:
FROM:
TO:
""-- -'I'L -5 pi! 2- I;
£-vi:.~L::.j ERA?:CH
June 27, 1994
Review of Subchronic and Chronic RfDs for Barium
(D.L. Mud Inc., LA)
Joan S. Dollarhide
Director
Superfund Health Risk Technical Support Center
Jamie VanBuskirk
U.S. EPA
Region VI
This memorandum responds to your request for a review of
issues raised in Comments on the Proposed Plan for D.L. Mud Site.
Thank you for your patience while we attempted to resolve the
questions surrounding the appropriate choice of critical study
for the subchronic and chronic RfDs for barium. Although they
have misinterpreted some of our earlier communications with you,
the comments do raise some pertinent questions regarding barium.
We have concluded that because of widely differing scientific
judgement, we cannot resolve these issues in the forum of ECAO
alone. Therefore, we plan to present these issues to the
Agency's RfD/RfC Work Group for resolution. I will let you know
when a date for the presentation has been scheduled.
Until the Work Group has evaluated the new data, I recommend
that you continue using the value that has already been reviewed
and verified by the Work Group: the RfD of 7E-2 mg/kg/day that is
currently on IRIS. This value has also been adopted as the
subchronic value on HEAST. Please let me know if you need
additional information.
cc: L. Papa
J. Konz (5204G)
Printed on Recycled Paper
-------
Appendix #6
INFORMATION ON BARIUM BIOAVAILABILITY
-------
\
,? UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
L Paefi
-------
Attachment
Barium
Evaluation of Barium Desorption Pilot Study
This study was performed and reported by ChemRisk (1992) at
the request of Dow Chemical. The study quantifies desorption of
total barium from soil samples containing low and high
concentrations (510 and 16,000 mg/kg, respectively) of barium
under conditions intended to simulate the human gastric
environment. It is stated that soil material was "...taken from
an area impacted by barium sulfate." Based on this statement it
is possible that the test samples were from the Superfund site,
but this needs to be clarified.
An aqueous HC1 solution of pH ^1.4 (0.04M) was used as the
extraction medium. As indicated in the ChemRisk (1992) report,
this pH is representative of gastric fluid pH (normal = <2.0) as
reported in Appendix 3 of Clinical Diagnosis by Laboratory
Methods (Davidsohn and Henry, 1974). An extraction ratio of 200
mg soil to 50 ml acid solution was chosen to reflect conditions
in children. Although 200 mg/day is the default value for
incidental soil ingestion by children 1-6 years old (U.S. EPA,
1989), it is uncertain whether 50 ml is an appropriate
corresponding fluid volume. ChemRisk (1992) states that "...50
ml is a volume within the range of normal gastric fluid volumes
(under basal conditions) for children (20-100 ml; Clinical
Diagnosis by Laboratory Methods, 1974)." The basis for this
statement appears to be an entry in Appendix 3 reporting that the
normal value for fasting residual gastric fluid volume is 20-100
ml, but no age group is specified. Chapter 16 in the same book
(Davidsohn and Henry, 1974) indicates that the fasting volume of
gastric contents ranges from approximately 50-100 ml, and James
(1957) assumes that the volume of fasting stomach contents is 50
ml. Neither Davidsohn and Henry (1974) or James (1957)
specifically provide age data. Based on discussions related to
these and other gastric data in the aforementioned books,
however, it is more reasonable to assume that the reported
gastric fluid volumes are for adults; 50 ml may or may not be a
reasonable maximum volume in children. Other available reference
sources provided no information on gastric fluid volumes in
children (Oberhelman, 1968; Davenport, 1971; Guyton, 1981; ICRP,
1981; Johnson et al., 1987; Rotterdam and Enterline, 1989).
Ideally, soil ingestion and gastric fluid volumes for children
and for adults should be tested. An extraction ratio of 100 mg
soil (default daily ingestion value for. adults) to 100 ml acid
solution (reasonable maximum adult fasting gastric fluid volume)
may give a higher percentage extraction of barium, and hence
could yield a higher soil ingestion exposure estimate and
therefore a higher hazard quotient.
The soils were extracted with the acid solution for 1 hour
at 37%C with gentle agitation. The extraction time apparently is
intended to represent gastric residence. The basis for the
-------
selection of the 1 hour time is unclear as the only statement in
the ChemRisk (1992) report ["A large meal (comprising a majority
of gastric capacity) is retained in the stomach for up to 4
hours...] cannot be verified using the cited reference (Davidsohn
and Henry, 1974). Studies conducted by Oberhelman (1968) using
food to which barium was added showed emptying times of 4-5 hours
in normal subjects (apparently adult), but no additional
information on these studies was reported. Oberhelman (1968)
also indicates that other studies (no additional information
reported) have showed emptying times ranging from 3-6 hours in
normal adult subjects (i.e., without gastrointestinal disease).
Data discussed by Davenport (1971) indicate that most of a meal
was cleared from the stomach within 1-2 hours. These variations
in emptying time are not surprising because rate of emptying is
influenced by various factors, particularly the volume, osmotic
pressure and chemical composition of the meal (Davenport, 1971).
Fat content, for example, has a pronounced effect on emptying
time and meals composed largely of fat can remain in the stomach
for up to 20 hours (Davenport 1971). Based on the available
information, the 1 hour extraction time appears to be a low
estimate of emptying time. It would have been informative if a
longer extraction time (or times) was tested because it is likely
this would give a more conservative soil ingestion exposure
estimate and hazard quotient for the same reasons as a decrease
in soil/acid extraction ratio as discussed above.
The extraction conditions are obviously a simplistic
simulation of actual gastric conditions. Gastric fluid, for
example, is a complex solution containing digestive and
nondigestive enzymes, mucus, electrolytes, serum proteins and
miscellaneous substances in addition to hydrochloric acid
(Davidsohn and Henry, 1974). Large meals can increase stomach
content volume (e.g., to 1000 ml) and, by a dilution effect, pH
of the gastric content to as high as 5 (James, 1957; Brunton,
1990). In general, however, the approach seems reasonable for a
pilot study, although the specific conditions that were used do
not appear to be conservative as discussed above.
Other aspects of the study are adequate for a pilot study.
The quality control report indicates that the study was carefully
performed and recoveries and precision were good. This was even
true for the high concentration samples where the amounts
desorbed were 2.4 and 2.5%. The reason for 2.4/2.6% desorption
from the high concentration samples compared with 19% from the
low concentration samples is not explained. Little information
is available in the literature on the adsorption and desorption
of barium. However, barium may form specific bonds with soil
components as well as interact through nonspecific columbic or
electrostatic interactions (Rai and Zachara, 1984). Interactions
are particularly strong with iron and manganese oxides. The two
soil samples used in the pilot study may have had very different
properties which could explain why barium was more tightly bound
(lower desorption) in the high concentration sample. Considering
the large difference in desorption from the two soils, it would
have been useful if the study included characterized soils and
-------
more soil samples. However, the results of the study as
performed appear to be valid.
Relevance of the Desorption Study to Barium Risk Assessment
According to the introduction section of the ChemRisk (1992)
report, the intent of the desorption study is to develop the data
necessary to enable adjustment of the soil ingestion exposure
estimate to match the RfD which is based on data from drinking
water ingestion. However, understanding the ChemRisk (1992)
approach in using these data is complicated somewhat by
imprecise, misleading and sometimes synonymous use of the terms
absorption, bioavailability and uptake, as well as some
incomplete reporting of information. For example, ChemRisk
(1992) states that the RfD "...was based on the study conducted
by Wones et al. (1990) that administered barium chloride in
drinking water to 11 male volunteers." In fact, the RfD is based
on both this study and an epidemiology study by Brenniman and
Levy (1984). As discussed in U.S. EPA (1992), Brenniman and Levy
(1984) compared human mortality and morbidity rates in
populations ingesting elevated barium levels in their drinking
water to populations ingesting very little or no barium.
Although the NOAEL on which the RfD is based (10 mg Ba/L or 0.21
mg Ba/kg/day) is the same in both studies, the form of barium in
the drinking water in the Brenniman and Levy (1984) study is not
defined.
ChemRisk (1992) cites only part of the guidelines that
specifically address adjustment for medium of exposure [Appendix
A (Section A.3, pages A-3 and A-4) of RAGS HHEM Part A (U.S. EPA,
1989)]. This part of the guidelines indicates that estimates of
the relative absorption efficiencies of a substance in the
different media are needed for the adjustment. ChemRisk (1992)
fails to acknowledge, however, the rest of these guidelines which
state "In the absence of a strong argument for making this
adjustment or reliable information on relative absorption
efficiencies, assume that the relative absorption efficiency
between food or soil and water is 1.0." ChemRisk (1992) also
does not acknowledge that Chapter 8 (Section 8.1, page 8-5) of
RAGS more strongly states that although adjustment for medium of
exposure is occasionally appropriate, it is "...not generally
recommended unless there is a strong argument for doing so." As
discussed below, the desorption study provides informative
preliminary data but an insufficient basis for deriving actual
adjustment values. '
Adjusting for differences between the RfD based on barium
chloride and other soluble forms of barium in water to water-
insoluble barium sulfate in soil involves considering both
bioavailability and absorption. Bioavailability is an important
concern in this assessment because only the barium sulfate that
desorbs from soil in the gastrointestinal tract will be available
for absorption (i.e., bioavailable). The hazard quotient (ratio
of soil ingestion exposure dose to RfD) therefore has to reflect
relative bioavailabilities as well as relative absorption
-------
efficiencies of the different forms of barium between the media.
The soil desorption values are essentially bioavailability
adjustment factors and are potentially useful for adjusting the
numerator (exposure dose) of the Hazard Quotient. The
denominator (RfD) of the Hazard Quotient needs no adjustment for
bioavailability because bioavailability (particularly of barium
chloride) from drinking water can be assumed to be 100%. This
essentially is the approach taken by ChemRisk (1992) except that
the adjustment is erroneously referred to as an absorption
adjustment. The desorption study provides no data on oral
absorption of barium sulfate from soil, and does not consider
existing data on absorption of barium compounds by oral and other
routes. As mentioned above, the OPPT Bioavailability/Absorption
Review of Barium Sulfate (6/3/92 memo) concluded that there is
little, if any, difference in the gastrointestinal absorption of
barium by rats from oral administration of a solution of barium
chloride or suspension of barium sulfate in water. Based on this
in vivo evidence of similar oral absorption of barium chloride
and sulfate (McCauley and Washington, 1983), no adjustment is
needed for relative absorption of the different forms of barium
in the Hazard Quotient (i.e., the relative absorption is 1J~.
We have taken the position in previous assessments that the
Agency's RfDs and other toxicity values are medium-specific for
water, diet or gavage vehicle only when specified and that
adjustment for ingestion of chemicals in soil is necessary only
when data clearly show a difference between absorption from soil
versus water, diet or gavage scenarios. As for many other
chemicals, the Agency has not explicitly discussed medium
specificity in deriving the RfD for barium. The RfD applies to
total barium,, but its derivation does not consider toxicity from
media other than water or from barium sulfate (or other poorly
water soluble barium compounds) because relevant data were not
available. As discussed above, there is no evidence indicating
that oral absorption of barium from barium chloride or sulfate
substantially differs at the low doses anticipated in
environmental exposure situations. The desorption study provides
information suggesting that bioavailability of barium sulfate
from soil is much less than that from water. However, as
previously discussed, EPA guidelines clearly indicate that
adjustment for medium of exposure is not generally recommended
unless there is a strong argument for doing so. In general,
study limitations as discussed above indicate that, at this time,
although data from the pilot study suggest that adjustment for
medium of exposure may be appropriate, the data are not
conclusive and are not adequate for quantifying an actual
bioavailability factor for barium sulfate in soil.
One of the main problems with the pilot study is the
nonconservative approach taken by ChemRisk (1992) in designing
the experiment, particularly in the selection of extraction ratio
and time, and the lack of information regarding the soil samples
tested. If only one combination of extraction ratio and time
could be tested, it would have been far more appropriate to
select conservative conditions as the basis for possible
-------
adjustment of the exposure dose. The wide range of extraction
efficiencies, 2.4/2.6% and 19%, is problematic because soils with
only two concentrations of barium were tested, only two soil
samples per concentration were tested, and soil types were not
characterized. ChemRisk (1992) concluded that there appears to
be a concentration and/or extractant volume dependence to the
extraction efficiencies, but soil properties could explain the
variation as discussed above. Additionally, it is unclear if the
soil samples were from the actual site.
Additional uncertainties and limitations of the pilot study
include the following: 1) Speciation of the desorbed barium was
not determined. Speciation may be different for barium desorbed
from barium sulfate-contaminated soil than for barium from the
chloride or sulfate in water and bioavailabilities of all species
may not be the same. 2) Desorption was quantified in simulated
gastric fluid, whereas absorption will occur in the small
intestine, which has a very different chemical environment. This
limitation could be addressed by adding a neutralization step to
the extraction procedure to simulate the intestinal environment.
Consideration might be given to using EPA's Metal Speciation
Equilibrium Model (MINTEQ) to explore both of the above
limitations along with the problem of soil type. This model has
been applied to predicting speciation of metals (e.g. lead) in
the gastrointestinal tract. Given certain assumptions about
which barium species would be substrates for transport in the
gastrointestinal epithelium, MINTEQ could be used to estimate
relative bioavailabilities of barium compounds in chemically
characterized soil types.
References
Brenniman, G.R. and P.S. Levy. 1984. Epidemiological study of
barium in Illinois drinking water supplies. In: Advances in
Modern Environmental Toxicology IX, E. J. Calabrese, R.W. Tuthill
and L. Condie, Ed. Princeton Scientific Publications, Princeton,
NJ. pp. 231-240.
Brunton, L.L. 1990. Agents for gastric acidity and peptic
ulcers: Antacids. In; The Pharmacological Basis of
Therapeutics, 8th ed, A. Goodman Gilman, T.W. Rail, A.S. Nies and
P. Taylor, Eds. Pergamon Press, New york. p. 905.
ChemRisk. 1992. Barium desorption study summary. Prepared by
ChemRisk, A division of McLaren/Hart, Cleveland, OH. September
9, 1992.
Davenport, H.W. 1977. Gastric digestion and emptying;
absorption. In: Physiology of the Digestive Tract, 3rd ed.,
Year Book Medial Publishers Inc, Chicago, pp. 165-168.
Davidsohn, I. and J.B. Henry. 1974. Clinical Diagnosis by
Laboratory Methods, 15th ed. W.B. Saunder Co, Philadelphia, pp.
-------
887-904, 1387.
Guyton, A.C. 1981. Textbook of Medical Physiology, 6th ed.
W.B. Saunders Co, Philadelphia.
ICRP. 1981. Report of the Task Group on Reference Man.
International Commission on Radiological Protection Publication
No. 23. Pergamon Press, Oxford.
James, A.H. 1957. The effects of eating on gastric acidity.
In; The Physiology of Gastric Digestion. Edward Arnold
Publishers Ltd., London, pp. 44-46.
Johnson, L.R., J.C. Christensen, M.J. Jackson, E.D. Jacobson and
J.H. Walsh, Eds. 1987. Physiology of the Gastrointestinal
Tract, Second Edition. Volumes 1 and 2. Raven Press, NY.
McCauley, P.T. and I.S. Washington. 1983. Barium
bioavailability as the chloride, sulfate, or carbonate salt in
the rat. Drug Chem. Toxicol. 6(2): 209-217.
Oberhelman, H.A., Jr. 1968. Gastric secretion and motility,
In; Physiological Principles of Gastric Surgery. Charles C
Thomas Publisher, Springfield, IL. pp. 17-20, 40.
Rai, D. and J. M. Zachara. 1984. Chemical Attenuation Rates,
Coefficients, and Constants in Leachate Migration. Volume 1: A
Critical Review. Prepared by Battelle Pacific Northwest
Laboratories, Richland, WA for the Electric Power Research
Institute, Palo Alto, CA. EPRI EA-3356. DE84-009432. pp. 6-1 -
6-6.
Rotterdam, H. and H.T. Enterline. 1989. Physiology. In:
Pathology of the Stomach and Duodenum. Springer-Verlag, London.
U.S. EPA. 1989. Risk Assessment Guidance for Superfund. Volume
I. Human Health Evaluation Manual (Part A). Office of Emergency
and Remedial Response, Washington, DC. EPA/540/1-89/001.
U.S. EPA. 1992. Integrated Risk Information System (IRIS).
Online. Office of Health and Environmental Assessment,
Environmental Criteria and Assessment Office, Cincinnati, OH.
Wones, R.G., B.L. Stadler and L.A. Frohman. 1990. Lack of
effect of drinking water barium on cardiovascular risk factor.
Environ. Health Perspect. 85: 1-13.
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•5 -
I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
*
WASHINGTON, D.C. 20460
3 ,'992
MEMORANDUM OFFICE of
PESTCIDES AND TOXC
SUBSTANCES
SUBJECT: Bioavailability of Barium Sulfate
cP.
FROM: Terry O« Bryan (TS-7T8) /_^
Chemical Assessment Desk ' ~y
Office of Pollution Prevention and Toxics \
TO: Ghassan Khoury (6H-SR) -?.
Hazardous Waste Management Division ~^_
EPA Region 6 .-• ^
7*O
r"r CJ
This is in response to your 5/28/92 inquiry on barium sulfate.
I understand that barium is driving the risk assessment at a Region
6 Superfund site (barium accounts for 92% of the soil contaminants
at the site) . There is an IRIS reference dose (RfD) for barium
chloride, but the PRP questions its applicability to the much less
soluble barium sulfate.
In 1989, Dr. Leonard Keifer of the then Office of Toxic
Substances evaluated the bioavailability of barium sulfate in
response to a petition to delist this chemical from the Toxics
Release Inventory.. The evaluation indicates that there is little^
jLf any, dif ferencej^in absorption at low doses following" oral
administratijQiu^" Barium sulfate is "belieVecl to be~ converted to
barium" chloride in the stomach. Differences would be likely
following massive doses because of the much lower water solubility
of barium sulfate. However, for the doses for which we have data
barium sulfate is absorbed from the GI tract to approximately the
same extent as barium chloride. In the McCauley and Washington
(1983) study which reported similar absorption rates for the two
salts, the administered oral dose was 0.5 mL/lOOg b.w of 10 mg/L of
Ba solution OR 5 M/kg. No comparative oral absorption data exist
for higher doses, but clinical data indicate significant uptake
within four hours. Consequently, the slower absorption rate of
barium sulfate relative to barium chloride would seem to have more
relevance to acute exposure situations rather than chronic
exposures, the basis for the RfD.
Absorption rates differ between the two salts following
inhalation exposure, but measured differences are less than one
order of magnitude. Attached is a copy of Leonard Keifer's
evaluation. He has not done any additional work on this topic, but
you can reach him at (202) 260-1548 if you have questions.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
8 1989
OFFICE OF
PESTICIDES AND TOXC
SUBSTANCES
MEMORANDUM
SUBJECT: Bioavailability/Absorption Review of Barium Sulfate in
Response to a Petition to Delist the Material from the
Toxic Emissions Inventory
FROM: Leonard C. Keifer, Ph.D.
Chemist
Metabolism/Structure Activity Section
Toxic Effects Branch
Health and Environmental
Review Division (TS-796)
TO: Flora Chow
Technical Integrator
Chemical Review and Evaluation Branch
Health and Environmental
Review Division (TS-796)
THRU: Pauline Wagner
Section Chief
Metabolism/Structure Activity Section
Toxic Effects Branch
Health and Environmental
Review Division (TS-796)
I.
INTRODUCTION
Barium sulfate (BaSO<, CAS No. 7727-43-7) is a solid with low
water solubility (2.46 mg/L i 25°C). The molecular weight is 233.
A water-soluble barium (Ba) compound used in several studies
to compare the bioavailability of Ba from its salts is barium
chloride (BaCl2) with water solubility of 375,000 mg/L (375 g/L) €
26°C and molecular weight of 208.
II. CONCLUSIONS
The barium ion from BaS04 is absorbed slowly into the animal
system as the compound dissolves. This bioavailability has been
observed following intramuscular injection, oral dosing, and
inhalation or intratracheal instillation. Following intratracheal
-------
instillation in rats, approximately 1.3% of the Ba from a dose of
2.8 fig of BaS04 was absorbed via solubilization. From in vivo and
in vitro studies with freshly precipitated and heat treated BaSO4
the physical fora of the BaS04 appears to have a profound influence
on the amount of Ba available from the compound. For small doses
of BaSO^jtdministered orally there is little, if any, difference in
the "alnount. of Ba_._ab.s orbed—when.. cpmpjired__to___the much more ~wate~r_
soluble BaCl2. When massive doses of BaS04 (60 to~400~g) were given"
orally to human subjects as a contrast medium for x-ray diagnoses
approximately 10 to 100 ng of Ba above background was excreted in
the urine in 24 hours.
III. BASES FOR.CONCLUSIONS
Thomas et al. (1973) studied the solubility (or more approp-
riately the bioavailability) of Ba from several of its salts in
vivo in the rat using the radioisotope Ba. The compounds of
interest were the chloride, sulfate, and an aluminosilicate clay
containing Ba fused at 1,100°C. The compounds, with the exception
of the chloride, were aerosolized, collected on a membrane filter,
resuspended in distilled water, and 0.5 mL of the suspension was
injected into the right hind leg of rats. The clay was used as an
example of a Ba compound from which Ba was not expected to be
available. The authors measured the rate at which Ba left the
injection site. Ba from BaCl2 was gone from the injection site
within 3 days whereas Ba from the clay migrated from the
injection site with a halflife of approximately 1,390 days (3.8
years) or nearly twice the average lifespan of the rat. Inter-
mediate between these two extremes was BaSO4 with a halflife of 26
days. The authors also calculated the dissolution rate for the
clay and BaSO4 in terms of grams dissolved per cm of surface of the
particles injected per day: BaSO4, 6.9 x 10" g/cm/day, and clay,
2.3 x 10"8 g/cm/day.
Cuddihy et al. (1974) exposed groups of three beagle dogs via
inhalation to aerosols of BaCl2, freshly precipitated BaS04, heat
treated BaSO4, or Ba fused in clay; exposure conditions were not
reported. In addition they collected samples of the aerosols on
membrane filters for use in an in vitro dissolution study. The
collected aerosol particles were placed between two membrane
filters and placed into simulated blood plasma. The samples were
placed into fresh solvent after 4 hours and thereafter at frequent
intervals for 20 days. The clay samples were subsequently placed
into fresh solvent every 10 days from day 20 to day 50 and then
every 50 days to a total of 125 days.
The BaCl2 in the in vitro study dissolved with a halflife of
approximately 1 hour while the clay dissolved with a halflife of
430 days. The BaS04 samples had half lives intermediate between the
BaCl2 and the clay, values were not reported. After 20 days
approximately 40% of the heat treated and 7% of the freshly
precipitated Baso4 remained on the filter. By comparison essen-
U
-------
tially none of the "3Ba from BaCl2 remained of the filter after -1
day and 80% of the Ba from the clay remained on the filter after
125 days (Cuddihy et al., 1974).
In the in vivo portion of the study Cuddihy et al. (1974)
sho^|d that for BaCl2 approximately 50% of the initial body burden
of Ba (amount not reported) was translocated to the skeleton by
day 16. For BaSO4/ approximately 35% of the Ba from freshly
precipitated and 20% from heat treated compound was translocated to
the skeleton by day 16; at the same time approximately 5% of
freshly precipitated and approximately 30% of heat treated compound
remained in the lung. By comparison only approximately 2% of the
Ba from the clay was translocated to the skeleton in 16 days and
approximately 50% remained in the lung. Even at 500 days less than
5% of the Ba from the clay had translocated to the skeleton while
nearly 10% remained in the lung. It should be kept in mind,
especially for the two forms of BaS04, that there is the pos-
sibility that at least some of the Ba in the skeleton may have
been absorbed from the GI tract since we do not know the exact
method of exposure and at least a portion of the initial body
burden could have been swallowed during or immediately after
exposure.
Takahashi and Patrick (1987) administered a suspension of
BaSO4 in mannitol to 26 male Fischer 344 rats via intratracheal
intubation; the average dose was 2.8 fig of BaSOA per rat. Rats
were killed at intervals up to 24 weeks post-administration. The
trachea, in two pieces divided 5 mm below the tracheostomy; the
bronchi including the tracheal bifurcation; the larynx including
the pharynx; the lung lobes; the thoracic and cervical lymph nodes;
and the remaining carcass were collected when each rat was killed.
The halflife for clearance from the lower half (caudal) of the
trachea was 88 days and that from the upper half (cranial,
including the site of the trachec-stomy) was 66 days. The per-
centage of the initial dose of Ba present in the trachea was
highest at week one: caudal, 0.41 ± 0.13%, and cranial, 4.0 + 1.2%.
The percent of the dose present in the larynx, bronchi, and lymph
nodes were also highest (but lower than that present in the
trachea) at week one. In contrast the percent of dose reached a
maximum (1,%^%) in the lung at 4 weeks post-administration. The
amount of Ba in all of these tissues decreased steadily over the
remainder of the study. The percentage of the dose present in the
remaining carcass reached a maximum of approximately 1.3% at 4
weeks post-administration and remained constant throughout the
remainder of the study; the .ffudy authors attributed this to the
translocation of some of the Ba to the skeleton although they did
not specifically analyze bone for the presence of Ba. According
to the authors, clearance from the trachea does not necessarily
indicate solubilization of the BaSO4 since only 0.001 to 0.003% of
the dose was present in the blood of rats at 24 hours and 30 days,
respectively, while greater than 90% of the dose was cleared from
the trachea over the same period. It was, however, pointed out by
-------
the authors that the percentage of the dose translocated to the
bones was via the solubilized Ba ion.
McCauley and Washington (1983) dosed fed ,5>ale Sprague-Dawley
rats with either BaCl2 or BaS04 labeled with Ba and fasted rats
with^ labeled BaCl2; doses were 0.5 mL/lOOg body weight of 10 mg/L
of Ba solution. Within 15 minutes of dosing the blood Ba level
in the fasted rats dosed with BaCl2 was at a maximum (0.35 ex-
pressed as counts per minute(CPM)/mL blood divided by administered
CPM/g body weight; by 4 hours postdosing the Ba level had fallen
to approximately 50% of the maximum level. The blood Ba level in
fed rats dosed with BaCl2 reached a maximum (0.28) at 60 minutes
postdosing. In fed rats dosed with BaS04 the blood Ba level
reached a maximum (0.19) at 60 minutes postdosing and was ap-
proximately 80 - 90% of the levels reached in the BaCl2-dosed rats.
Ba levels in the eye, an organ known to accumulate Ba, were nearly
the same for BaCl2- and BaSO4-dosed rats after 60 minutes (0.48
CPM/g eye/admin. CPM/g body weight); at 120 min the Ba level in
the eye for the BaCl2-dosed rats had increased to a level of 0.68
and that for the BaSO4-dosed rates to 0.52. Although data in terms
of percent of administered dose were not presented, the authors
concluded that BaCl2 and BaS04 at the doses used in this study are
absorbed to approximately the same extent from the rat GI tract,
presumably by conversion of BaS04 to BaCl2 in the stomach.
In the course of conducting GI tract X-ray diagnoses on 10
patients, Mauras et al. (1983) studied the absorption of Ba as
indicated by both increased Ba levels in the blood and increased Ba
levels in 24-hour urine samples. Each patient was given 350 g of
BaSO4 in 220 mL of water (210 g of Ba ion). Blood was drawn prior
to administration of the BaSO4 and at 0.5, 1, 2, 4, 8, and 24 hours
post-administration. In addition a 24-hour urine sample was
collected before and one after administration of the BaSO4.
Statistical significance was determined using the method of
Wilcoxon. The average blood Ba level before administration was
0.76 Mg/L; levels were not significantly increased until 4 (2.53
Mg/L, significance at 1%) and 8 (1.31 M9/L, significance at 5%)
hours after administration. Average pre-administration urine Ba
levels were 4.2 ng/24h; average post-administration levels were
13.4 /*g/24h (significant at 1%).
In a separate study using radio-opaque contrast materials,
Claval et al. (1987) administered six different contrast formula-
tions orally and four were administered rectally to patients.
BaSOA content of the contrast materials ranged from 57.5 g to 400
g per dose. Urine was collected for 24 hours post-administration.
For all of the formulations administered orally the Ba excretion in
the urine, expressed on a per gram of administered Ba basis, was
fairly constant; the range was 0.16 ng/q of Ba administered to 0.26
Mg/g of Ba. For the formulations administered rectally the Ba
excretion in the urine was approximately an order of magnitude less
than for the orally-administered formulations; the range was 0.023
4
-------
/ig/g of Ba to 0.096 /^g/g of Ba. These results suggest that passage
through the stomach increases the bioavailability of Ba, presumably
by conversion of a small amount of BaSO4 to BaCl2.
-------
REFERENCES
Cuddihy RG, Hall RP, Griffith WC. 1974. Inhalation exposures to
barium aerosols: Physical, chemical and mathematical analysis.
Health Phys. 26:405-416.
Claval JP, Lorillot ML, Buthiau D, Gerbet D, Heitz F, Galli A.
1987. Absorption intestinale du baryum lors d1explorations
radiologiques. Therapie 42:239-243.
Mauras Y, Allain P, Rogues MA, Caron C. 1983. Etude de 1'absorp-
tion digestive du baryum apres 1' administration orale du sulfate de
baryum pour exploration radiologique. Therapie 38:107-118.
McCauley PT, Washington IS. 1983. Barium bioavailability as the
chloride, sulfate, or carbonate salt in the rat. Drug Chem.
Toxicol. 6(2):209-217.
Takahashi S, Patrick G. 1987. Long-term retention of 133Ba in the
rat trachea following local administration as barium sulfate
particles. Rad. Res. 110:321-328.
Thomas RG, Ewing WC, Catron DL, McClellan RO. 1973. In vivo
solubility of four forms of barium determined by scanning techni-
ques. Amer. Ind. Hyg. Assoc. J. 34(8):350-359.
-------
Appendix #7
TABLES
-------
LIST OP TABLES
TABLE #1 - SURFACE SOIL SAMPLING RESULTS SUMMARY
TABLE #2 - SUBSURFACE SOIL SAMPLING RESULTS FROM AREAS OF
HISTORICAL USE
TABLE #3 - SUBSURFACE SOIL SAMPLING RESULTS FROM MONITORING WELL
INSTALLATION
TABLE #4 - SUBSURFACE SOIL SAMPLING RESULTS NEAR WELL G-22
TABLE #5 - SUBSURFACE SOIL SAMPLING RESULTS NEAR WELL G-23
TABLE #6 - SUBSURFACE SOIL SAMPLING RESULTS NEAR BORING SB-30
TABLE #7 - SUBSURFACE SOIL SAMPLING RESULTS FROM THE FORMER
IMPOUNDMENT AREA
TABLE #8 - GROUND WATER SAMPLING RESULTS SUMMARY
TABLE #9 - SURFACE WATER SAMPLING RESULTS SUMMARY
TABLE #10 - ONSITE SEDIMENT SAMPLING RESULTS SUMMARY
TABLE #11 - CHEMICALS DETECTED ONSITE USED IN THE RISK ASSESSMENT
TABLE #12 - POTENTIAL EXPOSURE PATHWAYS
TABLE #13 - CARCINOGENIC POTENCIES (ORAL SLOPE FACTORS)
TABLE #14 - NONCARCINOGENIC REFERENCE DOSES
TABLE #15 - SUMMARY OF POTENTIAL CARCINOGENIC RISKS
TABLE #16 - SUMMARY OF POTENTIAL NONCARCINOGENIC RISKS
TABLE #17 - CUMULATIVE POTENTIAL RISKS - TRESPASSER
TABLE #18 - CUMULATIVE POTENTIAL RISKS - FUTURE RESIDENTIAL
TABLE #19 - CUMULATIVE POTENTIAL RISKS - OCCUPATIONAL
TABLE #20 - D.L. MUD RISK ASSESSMENT UNCERTAINTIES
TABLE #21 - CHEMICALS OF CONCERN FOR SURFACE SOILS
-------
Table #1
SURFACE SOIL SAMPLING RESULTS SUMMARY
-------
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-------
Table #2
SUBSURFACE SOIL SAMPLING RESULTS FROM AREAS OF
HISTORICAL USE
-------
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-------
Table #3
SUBSURFACE SOIL SAMPLING RESULTS FROM MONITORING WELL
INSTALLATION
-------
Table # 3
" bsurface Soil Concentrations Above Background Surficial Soil Values
for Monitoring Well Samples
Parameters
Inorganics (mg/kg)
ALUMINUM
BERYLLIUM
CHROMIUM (TOTAL)
IRON
MAGNESIUM
NICKEL
Maximum
Background
14200
0.61B
17.4
22100
1260
10
D-6(17-18)
0.77F
18.6JSD
3120
14.9
0-7(15-18)
14500
IF
19. USD
23000
4780
29.6
G-20(2-3)
21900
0.78F
19.4
1830
16.3
0-20(5-6)
0.65F
1730
11.1
G-2 1(2-3)
22400
0.86F
19.2J
24900J
1910
20. 9 J
G-21(5-6)
14200
0.87F
20.4J
26400
1440
Results prewnted on dr> -weight basis
Blank space indicates parameter was below rr.aximum background value.
J - Estimated value
S - Matrix spike recoveries - outside control limits
D - Inorganics - Duplicate control limits exceeded
F - I.iorgvjc data below contract required quantitation limit
B - Blink contamination
-------
Table #4
SUBSURFACE SOIL SAMPLING RESULTS NEAR WELL G-22
-------
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-------
Table #5
SUBSURFACE SOIL SAMPLING RESULTS NEAR WELL G-23
-------
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-------
Table #6
SUBSURFACE SOIL SAMPLING RESULTS NEAR BORING SB-30
-------
Table f 6
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LEAD
MERCURY
SELENIUM
ZINC
.»
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ries - outside cont
ite limits cxccedixl
I1 S .3
_ fi "S.
Results presented on
J - Estimated value
S - Matrix spike rec
D - Inorganics - du
-------
Table #7
SUBSURFACE SOIL SAMPLING RESULTS FROM THE FORMER
IMPOUNDMENT AREA
-------
Table t 7
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MERCURY
SODIUM
ZINC
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OrganicsQtg/kg)
2-METHYLNAPHTr
PHENANTHRENE
TOTAL XYLENES
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concentration detected.
1 - Estimated value
1
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-------
Table #8
GROUND WATER SAMPLING RESULTS SUMMARY
-------
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-------
Table #9
SURFACE WATER SAMPLING RESULTS SUMMARY
-------
Table # 9
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-------
Table #10
ONSITE SEDIMENT SAMPLING RESULTS SUMMARY
-------
Table # 10
•
Onsite Sediment Samples Above Maximum Background Sediment Concentrations
Parameters
Inorganics (mg/kg)
ARSENIC
CADMIUM
COPPER
Maximum
Background
5.6
22.6
Station ID
SD-2 . SD-5
1.7F
22.7JBDE
6.7
1.5FJB
24.5JB
SD-6
9.4
2.1
25.3JB
SD-6A
7.2JS
23.4
SD-8
10.5
13.5
56.8
SD-9
23.9JB
Blank space indicates parameter was either below the method detection
limit or the parameter uas belo* the maximum background concentration detected.
B - B!ar.y. contamination
D - Inorgir.ics—duplicate control ami's exceeded
E - Interference problem
F - Inorganic data below contract required quantitation limit
J - Est- mated value
S - Matr.* spike reco^eries-outside control limits
-------
Table #11
CHEMICALS DETECTED ONSITE USED IN THE RISK ASSESSMENT
-------
J
J
J
^
ilJ
(I
HJ
(I
U
U
U
y
u
u
U
D
u
u
Lj
Table # 11
Chemical Constituents Identified in Onsite Groundweter
Inorpanic Parameters
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
THALLIUM
VANADIUM
ZINC
Total Positive Detection
Analyses Detections Freguency
19
19
19
19
19
19
19
52
19
19
19
19
19
19
19
19
19
14
19
19
19
19
18
1
18
19
2
1
19
21
8
18
19
11
19
19
14
19
4
5
19
8
13
14
95%
5%
95%
100%
11%
5%
100%
40%
42%
95%
100%
58%
100%
100%
74%
100%
21%
36%
100%
42%
68%
74%
Minimun
Detected
Value (a)
33
65
1.1
212
1.2
3.6
40800
11
9.0
8.3
98
1.7
9660
170
12
1390
8.2
4.9
74400
1.0
5.4
14
Maximum
Detected
Value
52500
65
43
1430
3.1
3.6
349001
852
43
68
80500
59
145000
4900
412
13200
13
6.6
229999
51
129
81
Mean
Estimation
(b)
10401
20
18
490
^ ., -•- 0-6
1.7
82672
71
8.4
21
9698
14
28967
1303
82
4769
2.7
3.3
114711
13
16
39
UCL 95%
181495
23
59
661
0.8
1.9
109643
275
14
32
32818
69
41610
2140
214
6758
4.8
4.4
134868
89
38
65
Unite
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
Melal parameters art reported as total metals.
(a! Minimum detected velue:Positive detections only.
(b) Estimation of the mean of the log normal distribution.
Total Positive Detection
Organic Parameters Analyses Detections Frequency
ACETONE (2-PROPANONE!
BENZOIC ACID
BIS(2-ETHYLHEXYL)PHTHALATE
BROMOD1CHLOROM5THANE
BROMOFORM
CARBON TETRACHLORIDE
DI-N-BUTYL PHTHALATE
Di-N-OCTYL PHTHALATE
DIBROMOCHLOROMETHANE
DIETHYL PHTHALATE
METHYLENE CHLORIDE
19
19
19
19
19
19
19
19
19
19
19
2
1
6
1
1
1
2
1
2
2
12
11%
5%
32%
5%
5%
5%
11%
5%
11%
11%
63%
Minimun Maximum Mean
Detected Detected Estimation
Value (a) Value (b) UCL 95%
11
2.0
1.0
1.0
5.0
1.0
1.0
0.2
3.0
S.O
1.0
18
2.0
17
1.0
5.0
1.0
1.0
0.2
4.0
11
11
6.8
27
5.8
2.4
2.6
2.4
5.0
5.9
2.6
5.5
2.1
9.1
36
7.8
2.7
2.8
2.7
6.5
8.9
2.7
6.0
3.6
Units
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
-------
Table f 11 (cont'd)
Chemical Counstituents Identified in Onsite Surface Water
Inorganic Parameter!
ALUMINUM
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
SILVER
SODIUM
VANADIUM
ZINC
Total Positive Detection
Analyses Detections Frequency
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
9
11
1
1
11
5
3
11
11
11
11
11
6
11
3
11
7
11
100%
82%
100%
9%
9%
100%
45%
27%
100%
100%
100%
100%
100%
55%
100%
27%
100%
64%
100%
Minimun
Detected
Value (a)
1010
1.9
89
1.7
3.6
7440
8.8
6.2
6.2
810
1.5
2470
40
15
3100
5.3
3760
5.4
19
Maximum
Detected
Value
15100
6.5
6090
1.7
3.6
33900
64
12
31
9230
66
10500
3850
49
23600
6.1
9930
18
705
Mean
Estimation
(b)
4059
2.9
889
0.6
1.7
22073
11
4.6
17
3351
13
4311
881
16
9699
3.0
6298
7.3
241
UC'. 95%
8747
5.7
3963
0.8
2.0
31823
31
6.7
23
5845
47
5641
5563
28
15205
4.2
7518
13
678
Unitt
ug/L
ug/L
ug/L
ue/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ugA.
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
L
U
li
LJ
U
U
hi
Minimun Maximum Mean
Total Positive Detection Detected Detected Estimation
Organic Parameters Analyses Detections Frequency Value (a) Value (b) UCL 95%
BIS (2-ETH YLHiXYUP-'THALATE
OIETHYL PHTHALATE
6
6
4
1
67%
17%
3.0
2.0
7.0
2.0
5.5
5.4
7.4
8.8
Units
ug/L
ug/L
Metal parameters are reported as total metals.
(a) Minimum detected value:Positive detections only.
(b) Estimation of the mean of the log normal distribution.
u
[Jl
d
III
II
I
1
'1
-------
J
J
j
J
J
J
J
Table // 11 (cont'd)
Chemical Constituents Identified in Onsite Surficial Soil
Inorganic Parameters
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
THALLIUM
VANADIUM
ZINC
Total Positive Detection
Analyses Detections Frequency
21
20
18
19
21
21
21
21
21
21
21
18
21
21
18
20
21
18
20
21
18
20
21
21
2
18
19
21
11
21
21
21
21
21
18
21
21
9
20
21
1
14
8
4
20
21
100%
10%
100%
100%
100%
52%
100%
100%
100%
100%
100%
100%
100%
100%
50%
100%
100%
6%
70%
38%
22%
100%
100%
Minimun
Detacted
Value (a)
3360
6.6
4.3
210
0.3
0.8
808
15
6.1
12
10800
14
717
293
0.1
6.3
203
0.6
0.8
181
0.2
14
24
Maximum
Detected
Value
17000
13
19
13500
1.2
6.9
110000
188
26
71
29400
643
1790
1420
1.2
21
1330
0.6
2.8
1010
20
47
1380
Mean
Estimation
(b)
9371
4.4
10
12870
0.6
2.3
43240
53
12
26
17749
265
1296
686
0.3
11
952
0.3
1.5
1268
0.4
26
706
UCL 95%
11073
5.3
12
39626
0.7
4.3
141566
76
14
32
19990
615
1447
805
0.5
13
1175
0.3
2.4
7209
1.0
30
1582
Units
mg/kg
nrtg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/Vg
Oroanic Parameters '
2-METHYLNAPHTHALENE
4-METHYLPHENOL
BENZOIA1PYRENE
BENZOIC ACID
BISI2-ETHYLHEXYUPHTHALATE
DI-N-BUTYL PHTHALATE
DIETHYL PHTHALATE
DIMETHYL PHTHALATE
INDENOI1.2.3-C.DIPYRENE
METHYLENE CHLORIDE
NAPHTHALENE
PHENANTHRENE
PHENOL
PYRENE
Total Positive Detection
Analyses Detections Frequency
18
18
18
14
18
18
18
18
18
4
18
18
18
18
1
1
1
2
15
9
1
1
1
1
3
1
2
1
6%
6%
6%
14%
83%
50%
6%
6%
6%
25%
17%
6%
11%
6%
Minimun Maximum Mean
Detected Detected Estimation
v.i, i« (•) Value
-------
Table # 11 (cont'd)
Chemical Constituents Identified in Onsite Sediment
Inorganic Parameters
ALUMINUM
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SILVER
SODIUM
VANADIUM
ZINC
Total Positive Detection
Analyses Detections Frequency
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
4
7
7
7
7
• 7
7
7
7
1
7
7
4
4
7
7
100%
100%
100%
100%
57%
100%
100%
100%
100%
100%
100%
100%
100%
14%
100%
100%
57%
57%
100%
100%
Minimun
Detected
Value (a)
9360
1.8
355
0.5
1.5
1320
13
6.9
11
10300
15
1090
267
0.7
5.1
948
1.7
1290
19
48
Maximum
Detected
Value
18100
11
18400
0.9
14
12800
97
20
57
22800
390
2150
631
0.7
20
2100
2.7
2210
39
2420
Mean
Estimation
(b)
14118
6.5
21269
0.7
2.8
4165
45
15
27
14953
97
1609
420
0.2
14
1724
1.5
1312
28
521
UCL 95%
17593
13
4.0E + 06
0.8
25
12398
126
21
44
18700
899
2022
584
0.4
21
2180
3.0
3619
36
10354
Units
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kj
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
Tig/kg
I
I
•
i
,
,
Organic Parameters
BENZOIC ACID
BIS12-ETHYLHEXYUPHTHALATE
DI-N-BUTYL PHTHALATE
Total
Analyses
7
7
7
Positiva
Detections
1
6
4
Detection
Frequency
14%
86%
57%
Minimun
Detected
Value (a)
510
240
75
Maximum
Detected
Value
510
790
120
Mean
Estimation
(b)
3103
864
489
UCL 95%
15290
2842
5096
Units
ug/kg
ug/kg
ug/kg
Non-aqueous sample concentrations are based on dry weight.
Metal parameters are reported as total metals.
(a) Minimum detected value:Positive detections only.
(b) Estimation of the mean of the log normal distribution.
i
I
t
t
-------
J
J
J
J
J
II
if
11
if
J
I
1
i
I
1
Table # 11 (cont'd)
Chemical Constituents Identified in Onsite Subsurface Soil Without " Source" Areas
Inorjanic Parameters
ALUM.NUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM (TOTAL)
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
SULFUR
THALLIUM
VANADIUM
ZINC
Total
Analyses
41
36
35
41
41
41
41
41
41
41
41
35
41
41
35
41
41
35
41
41
1
35
41
41
Positive Detection
Detects Frequency
41
5
35
41
, 41
2
41
41
40
40
41
35
41
41
10
41
41
5
13
36
1
4
41
41
100%
14%
100%
100%
100%
5%
100%
100%
98%
98%
100%
100%
100%
100%
29%
100%
100%
14%
32%
88%
100%
11%
100%
100%
Arithmetic
Mean
16272.44
3.81
5.24
484.31
0.86
0.36
3115.12
19.64
7.46
13.27
20515.37
12.94
2263.90
394.62
0.07
16.37
1098.80
0.33
0.60
667.18
17000.00
0.18
30.87
61.82
Minimum
5880.00
5.90
0.39
67.40
0.23
0.41
1070.00
8.50
0.28
4.60
7470.00
4.60
1140.00
19.20
0.02
5.80
295.00
0.37
0.81
304.00
17000.00
0.22
10.80
17.00
Maximum
25700.00
10.90
11.60
5940.00
2.20
3.10
45700.00
45.90
22.20
22.40
40800.00
4O.70
5610.00
1720.00
0.15
35.00
2550.00
1.40
1.70
1420.00
17000.00
0.29
52.90
788.00
Arithmetic
95th UCL
17796.09
4.53
6.07
738.93
0.96
0.48
4918.97
21.43
8.74
14.64
22380.37
15.01
2532.77
486.26
0.08
18.20
1246.52
0.39
0.74
749.12
0.20
33.42
92.73
Uniti
mgfcg
mg/kg
mg/kg
nrtg/kg
mg/kg
nrtg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
ug/kg
mg/kg
mg/kg
ma/kg
Organic Parameters
1.2-DICHLOROETHENE (TOTAL)
2-BUTANONE (MEK)
2-METHYL-,1-(1,1-DIMETHYLETHYL)-2-M
4.8.12-TR1METHYL-3.7.8-TRIDECATRIEN
ACENAPHTHENE
ACETONE (2-PROPANONE)
ANTrRACENE
BENZOIAIANTHRACENE
BENZOIKIFLUORANTHENE
BENZO-IBIFLUORANTHENE
B1SU-ETHYLHEXYL1PHTHALATE
CARSON DISULFIDE
CHRYSENE
CYCLOHEXANE. 1 ,1,2-TRIMETHYL
DI-N-BUTYL PHTHALATE
DI-N-OCTYL PHTHALATE
DIFTALONE
FLUORANTHENE
FLUORENE
INDENO(1,2.3-C.D)PYRENE
METHYLENE CHLORIDE
PHENANTHRENE
PYRENE
TOLUENE
TOTAL XYLENES
Total
Analyses
23
23
1
1
33
30
33
33
33
33
33
22
33
1
37
33
1
33
33
33
31
33
33
23
23
Positive
Detects
2
6
1
1
1
2
1
1
1
1
14
1
1
1
3
2
1
1
1
1
3
2
1
4
3
Detection
Frequency
9%
26%
100%
100%
3%
7%
3%
3%
3%
3%.
42%
5%
3%
100%
8%
6%
100%
3%
3%
3%
10%
6%
3%
17%
13%
Arithmetic
Mean
4.09
25.43
340.00
650.00
196.94
9.27
196.70
197.85
198.58
197.97
303.18
4.23
198.09
7.00
166.72
191.82
3000.00
201.21
196.64
197.39
8.27
194.85
201.52
29.67
4.15
Minimum
1.00
7.00
340.00
650.00
39.00
7.00
31.00
69.00
93.00
73.00
210.00
1.00
77.00
7.00
44.00
27.00
3000.00
180.00
29.00
54.00
5.00
30.00
190.00
110.00
2.00
Maximum
2.00
160.00
340.00
650.00
39.00
9.00
31.00
69.00
93.00
73.00
1200.00
1.00
77.00
7.00
51.00
43.00
3000.00
180.00
29.00
5< DO
48.00
140.00
190.00
200.00
3.00
Arithmetic
95th UCL
4.69
42.38
205.51
11.11
205.67
204.92
204.47
204.84
377.50
4.83
204.77
185.94
203.91
203.39
205.71
205.21
10.79
204.32
203.48
50.54
4.73
Units
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ugAg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug£g
up/kg
-------
Table f 11 (cont'd)
Chemical Constituents Identified in "Source" Samples near Well G-22
Inorganic Parameters
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
SELENIUM
SODIUM
THALLIUM
VANADIUM
ZINC
Total Positive Detection
Analyses Detections Frequency
4
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
3
4
4
4
1
4
4
4
4
4
4
4
4
4
4
1
4
1
4
4
100%
100%
100%
100%
100%
25%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
25%
100%
25%
100%
100%
Minimun
Detected
Value (a)
16100
10
1.7
127
1.0
2.5
2520
17
7.3
12
17900
8.7
3190
208
17
1280
0.4
412
0.2
20
45
Maximum Mean
Detected Estimation
"elue (b) UCL95%
17200
10
4.2
153
1.1
2.5
3170
20
12
14
19800
21
3470
397
22
1450
0.4
586
0.2
24
72
16579
10
3.5
139
1.1
0.8
2716
18
10
13
18829
14
3329
282
19
1353
0.2
531
0.2
23
58
17183
10
7.4
153
1.1
359
3116
20
14
14
19891
28
3479
440
22
1456
0.6
673
0.2
25
77
Uniti
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
I
I
I
I
I
j]
Jj
I
J
I
I
j
Total Positive Detection
Organic Parameters Analyses Detections Frequency
1,1,1-TRICHLOROETHANE
1.1.2.2-TETRACHLOROETHANE
2-METHYLNAPHTHALENE
4-CHLORO-3-METHYLPHENOL(PCMC)
ACENAPHTHENE
BENZENE
CARBON DISULFIDE
DIBENZOFURAN
ETHYLBENZENE
FLUORENE
NAPHTHALENE
PHENANTHRENE
PYRENE
TOTAL XYLENES
4
4
4
4
4
4
4
4
4
4
4
4
3
4
1
1
4
1
1
1
1
4
3
4
4
4
2
4
25%
25%
100%
25%
25%
25%
25%
100%
75%
100%
100%
100%
67%
100%
Minimun Maximum Mean
Detected Detected Estimation
Value (a) Value (b)
3.0
16
1300
110
160
4.0
4.0
220
8.0
340
170
590
53
6.0
3.0
16
5200
110
160
4.0
4.0
1000
260
1400
1700
2100
73
180
7.1
11
2906
181
192
7.3
7.3
534
104
753
1132
1138
117
109
UCL95%
77
136
11584
295
222
51
51
2499
2.4E + 08
3220
56637
4390
1227
668
Units
ufl/Vg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
uj/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
Non-aqueous sample concentrations are based on dry weight.
Metal parameters are reported as total metals.
(a) Minimum detected value:Positive detections only.
(b) Estimation of the mean of the log normal distribution.
-------
li
i
?
ii
tl
ii
i
4
i
4
4
4
4
4
4
4
Table # 11 (cont'd)
Chemical Constituents Identified in "Source" Samples near Well G-23
Inorjanic Parameters
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
THALLIUM
VANADIUM
ZINC
Total Positive Detection
Analyses Detections Frequency
3
1
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
3
1
3
4
2
2
4
3
3
3
4
4
4
4
4
3
3
3
2
1
3
3
4
100%
100%
100%
100%
50%
50%
100%
75%
75%
75%
100%
100%
100%
100%
100%
75%
75%
75%
50%
25%
75%
75%
100%
Minimun
Detected
Value (a)
231
10
12
96
0.2
4.1
76
15
4.2
11
236
35
39
4.4
0.1
13
415
0.5
1.0
927
0.4
15
5.1
Maximum
Detected
Value
15000
10
IB
8920
0.3
8.3
10400
157
7.0
64
22400
608
1790
597
1.6
18
932
1.0
1.8
927
0.8
30
1510
Mean
Estimation
(b)
27305
10
16
13767
0.2
6.4
188 68
364
5.5
90
67308
639
3303
1880
1.0
21
1332
0.6
0.9
550
0.6
74
4235
UCt 95%
6.8E + 21
(0
27
1.1E + 11
161
1.0E + 06
3.7E + 11
2.7E + 12
223
3.4E+08
1.SE+06
393860
6.6E + 08
4.8E + 12
398
97549
2.3E + 08
7.8
13
4.0E + 06
3.7
5.9E + 08
3.2E-M2
Units
mg/kg
ing/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mgfcg
mg/kg
trig/kg
Organic Parameters
1.2-DICHLOROETHENE (TOTAL)
2-BUTANONE (MEK)
ACETONE (2-PROPANONE)
TRlCHLOROETHYLENE '
Total
Analyses
4
4
4
4
Positive
Detections
1
1
1
1
Detection
Frequency
25%
25%
25%
25%
Minimun
Detected
Value
4.0
13
7.0
3.0
Maximum
Mean
Detected Estimation
Value
4.0
13
7.0
3.0
(a)
4.2
8.1
6.3
3.9
UCL 95%
6.7
16
140
6.6
Unitt
ug/kg
ug/kg
ug/Vg
ug/kg
Non-aqueous sample concentrations are based on dry weight.
Metal parameters are reported as total metals.
(a) Minimum detected value:Positive detections only.
(b) Estimation o! the mean of the log normal distribution.
(c) UCL 95% not applicable to a population of 1.
ii
Jl
-------
Table f 11 (cont'd)
Chemical Constituents Identified in "Source" Samples Near Boring SB-30
Inorganic Parameters
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SELENIUM
SODIUM
VANADIUM
ZINC
Total Positive Detection
Analyses Detections Frequency
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
1
3
3
3
2
3
3
3
• 3
3
3
3
3
2
3
3
3
2
3
3
100%
33%
100%
100%
100%
67%
100%
100%
100%
100%
100%
100%
100%
100%
67%
100%
100%
100%
67%
100%
100%
Minimun
Detected
Value (a)
10900
10
5.4
522
0.5
0.5
1880
21
1.7
12
10800
25
859
468
0.2
4.6
864
0.6
482
20
77
Maximum
Detected
Value
16400
10
7.3
4910
0.6
1.4
3310
22
5.6
15
18300
98
1250
1020
0.2
11
1130
1.0
582
34
125
Mean
Estimation
(b)
13836
6.5
6.1
2860
0.6
0.8
2567
21
3.9
14
14956
71
1052
709
0.2
8.9
1015
0.9
462
28
95
UCL 95%
22320
33
9.0
9.1E + 07
0.7
10806
5854
23
108
17
32565
7091
1629
3118
55
80
1325
1.9
1784
60
209
Units
mg/Vg
mg/kg
my/kg
mg/Vg
mg/kg
mg/Vg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg;Vg
mg/kg
mg/kg
mg/kg
mg/kg
nSVg
Total Positive
Organic Parameters
2-BUTANONE (MEK)
CARBON DISUIRDE
PHENANTHRENE
TOLUENE
TOTAL XYLENES
Detection
Analyses Detections Frequency
3
3
1
3
3
1
1
1
1
3
33%
33%
100%
33%
100%
Minimun Maximum Mean
Detected Detected Estimation
Velue (a)
27
6.0
340
4.0
2.0
Value
27
6.0
340
4.0
7.0
(b) UCL 9SS
14
4.1
340
3.3
4.3
205: i
18
(c)
4.9
145
Units
ug/kg
ug/kg
ug/kg
ug/kg
us/kg
i
Non-aqueous sample concentrations are based on dry weight.
Metal parameters are reported as total metals.
(a) Minimum detected value:Positive detections only.
(b) Estimation of the mean of the log normal distribution.
(c) UCL 95% not applicable to a population of 1.
.1
i
i
i
-------
y
M
u
u
u
ilr
4
J
J
Table f 11 (cont'd)
Chemical Constituents Identified in 'Source* Samples from Impoundment Area
Inorganic Parameters
ALUMINUM
ARSENIC
BARIUM
BERYLLIUM
CALCIUM
CHROMIUM (TOTAL)
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SODIUM
VANADIUM
ZINC
Total Positive Detection
Analyses Detects Frequency
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
Arithmetic
Mean
14216.67
9.17
3540.00
0.60
1790.00
29.73
9.97
14.53
16900.00
44.57
1323.33
622.00
0.14
13.33
847.33
1204.00
26.07
60.07
Minimum
6C50
4.40
2440.00
0.42
1610.00
16.50
6.80
11.50
10500.00
34.70
600.00
583.00
0.07
5.10
404.00
892.00
20.20
52.60
Maximum
20300.00
12.00
5140.00
0.74
1910.00
41.00
11.90
16.50
20100.00
58.10
1830.00
679.00
0.19
18.90
1140.00
1460.00
31.30
66.90
Arithmetic
95th UCL
26607.51
16.17
5930.11
0.88
2057.62
50.58
14.63
19.03
26243.95
65.00
2407.32
707.08
0.25
25.60
1505.S7
1689.71
35.47
72.16
Uniti
mg/kg
mrj/kg
Rig/kg
ing/kg
ing/kg
ing/kg
ing/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mo /kg
Organic Parameters
2-BUTANONE (MEK)
2-METHYLNAPHTHALENE
DIBENZOFURAN
ETHYLEENZENE
FLUORENE
NAPHTHALENE
PHENANTHRENE
TOTAL XYLENES
Total Positive Detection Arithmetic
Ana'vses Detects Frequency Mean
1
3
1
1
1
1
3
2
1
3
1
1
1
1
3
2
100%
100%
100%
100%
100%
100%
100%
100%
16.00
476.67
100.00
13.00
100.00
50.00
293.33
6.00
Minimum
16.00
180.00
100.00
13.00
100.00
50.00
180.00
3.00
Arithmetic
Maximum 95th UCL Units
16.00
660.00
100.00
13.00
100.00
50.00
480.00
9.00
ug/kg
913.80 ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
567.94 ug/kg
24.94 ug/kg
4
4
4
-------
Table # 11 (cont'd)
Chemical Constituents Identified in Background Groundwater
Inorganic Pa'.meterg
A-JMINUM
ARSENIC
BARIUM
BERYLLIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
THALLIUM
VANADIUM
ZINC
Total Positive Detection
Analyses Detection* Frequency
4
4
4
4
4
5
4
4
4
4
4
4
4
4
4
3
4
4
4
4
4
4
4
1
4
4
1
3
. 4
2
4
4
2
4
1
1
4
2
1
3
100%
100%
100%
25%
100%
80%
25%
75%
100%
50%
100%
100%
50%
100%
25%
33%
100%
50%
25%
75%
Minimun
Detected
Value (a)
221
4.6
303
1.8
79900
6.2
13
7.5
4540
17
28900
678
16
2350
13
5.1
83400
1.4
47
'5
Maximum
Detected
Value
16700
41
508
1.8
87300
78
13
44
35600
18
34500
1500
35
8550
13
5.1
93800
50
47
109
Mean
Estimation
(b)
6882
16
380
0.8
82603
36
5.4
21
13156
24
30702
937
17
4215
4.3
3.2
90492
23
15
62
UCL 95%
3.1E+10
821
522
4.0
86946
5341
68
S2892
609219
1.3E+08
34091
1818
376
18196
1915
38
97117
3.5E + 08
81086
3.4E + 06
Units
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
h
ll
.V
I
If
If
Minimun Maximum Mean
Total Positive Detection Detected Detected Estimation
Organic Parameters Analyses Detections Frequency Value (a)
ACETONE (2-PROPANONE)
BIS(2-ETHYLHEXYL)PHTHALATE
CARBON DISULFIDE
DIETHYL PHTHALATE
METHYLENE CHLORIDE
4
4
4
4
4
2
3
2
1
2
50%
75%
50%
25%
50%
2.0
1.0
2.0
3.0
2.0
Value
43.0
3.0
2.0
3.0
27.0
(b)
17
3.3
2.3
5.0
11
UCL 95%
893065
21
2.7
8.3
666929
Units
ug/L
ug/L
ug/L
ug/L
ug/L
Metal parameters are reported as total metals.
(a) Minimum detected valueiPositive, detections only.
(b) Estimation of the mean of the log normal distribution.
If
If
If
I
-------
I
I
I
I
1
II
1
I
II
il
I
I
I
I
*
I
I
I
I
1
1
Table # 11 (cont'd)
Chemical Constituents Identified in Background Surface Water
Inorganic Parameters
ALUMINUM
ARSENIC
BARIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
SODIUM
VANADIUM
ZINC
Total Positive Detection
Analyses Detections Frequency
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
1
3
3
2
3
3
3
3
3
1
3
3
3
3
100%
100%
100%
33%
100%
100%
67%
100%
100%
100%
100%
100%
33%
100%
100%
100%
100%
Minimun
Detected
Value (a)
3630
2.3
99
3.7
10500
6.9
8.3
12
3050
1.8
3630
125
13
7820
4610
7.7
15
Maximum
Detected
Value
6670
3.0
150
3.7
13400
8.0
10
15
4790
4.6
4200
2170
13
9470
22600
13
76
Mean
Estimation
(bl
4921
2.6
134
2.3
11829
7.6
7.8
13
3979
3.8
3970
1233
8.5
8491
18578
10
42
UCL 95%
12323
3.4
235
25
15034
8.8
278
16
6751
43
4609
5.4E+12
44
10336
2.7E + 07
22
21939
Unite
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
Metal parameters are reported as total metals.
(a) Minimum detected velue:Positive detections only.
(b) Estimation of the mean of the log normal distribution.
No organic parameters were detected.
-------
Table # 11 (cont'd)
Chemical Constituents Identified in Background Surficial Soil
Inorganic Parameters
ALUMINUM
ARSENIC
BARIUM
BERYLLIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
SILVER
SODIUM
VANADIUM
ZINC
Total Positive Detection
Analyses Dete-'iont Frequency
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
. 8
8
8
8
8
8
3
7
8
8
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
38%
88%
100%
100%
Minimun
Detected
Value (a)
8460
2.6
138
0.4
721
10
4.8
10
12500
12
739
287
4.5
724
1.2
691
24
21
Maximum
Detected
Value
14200
6.6
662
0.6
3540
17
11
14
22100
27
1260
863
10
1170
1.6
1150
41
37
Mean
Estimation
(b)
12131
4.4
290
0.5
1750
14
6.5
12
14907
18
1017
485
6.8
912
0.8
963
31
28
UCL 95%
13835
5.5
446
0.6
2978
16
7.9
13
16999
22
1149
630
8.4
1040
1.4
1467
35
31
Unit*
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
I
U
II
U
Total Positive Detection
Organic Parameters Analyses Detections Frequency
BENZCMB1FLUORANTHENE
BENZOIC ACID
3!S(2-ETHYLHEXYL)PHTHALATE
CHRYSENE
DI-N-BUTYL PHTHALATE
FLUORANTHENE
8
8
8
8
8
8
1
4
8
1
1
1
13%
50%
100%
13%
13%
13%
Minimun Maximum Mean
Detected Detected Estimation
Value !a) Value (b) UCL 95%
59
190
57
51
47
100
59
540
460
51
47
100
187
763
269
188
184
188
269
1538
804
290
289
229
Units
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
u
y
Non-aqueous sample concentrations are based on dry weight.
Metal parameters ere reported as total metals.
(a) Minimum detected valuf.Positive detections only.
tb). Estimation of the mean of the log normal distribution.
y
i1
-------
J
J
J
J
J
Table # 11 (cont'd)
Chemical Constituents Identified in Background Sediments
J
J
u
u
LJ
Inorganic Parameters
ALUMINUM
ARSENIC
BARIUM
BERYLLIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
SILVER
SODIUM
VANADIUM
ZINC
Total Positive Detection
Analyses Detections Frequency
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
2
4
6
6
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
33%
67%
100%
100%
Minimun
Detected
Value (e)
12700
1.4
185
0.7
2270
14
6.7
20
11200
11
1620
303
8.3
1160
1.9
1150
24
34
Maximum
Detected
Value
26000
5.6
851
1.0
3100
32
11
23
25200
33
2420
840
17
2300
2.1
2120
45
86
Mean
Estimation
(b)
17404
3.2
554
0.8
2714
20
8.7
21
15364
20
1878
499
11
1732
1.2
1340
30
62
UCL 95%
22179
5.2
1164
0.9
3016
27
10
22
20359
29
2137
692
14
2251
2.2
3027
37
85
Unite
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kr
mg/kj
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
Total Positive
Detection
Organic Parameters Analyses Detections Frequency
BEMZO(A)PYR£NE
BENZOIC ACID
BIS12-ETHYLHEXYLIPHTHALATE
DI-N-BUTYL PHTHALATE
PYRENE
6
6
6
6
3
2
3
6
3
1
33%
50%
100%
50%
33%
Minimun
Detected
Value (a)
170
230
380
81
71
vlaximum Mean
Detected Estimation
Value
210
1400
830
93
71
(b)
284
1569
628
202
339
UCL 95%
393
5512
813
533
2.3E + 06
Units
ug/kg
ug/kg
ug/kg
ug/kg
ug/kg
Non-aqueous sample concentrations are based on dry weight.
Metal parameters are reported as total metals.
(a) Minimum detected value:Positive detections only.
(b! Estimation o( the mean of the log normal distribution.
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Table #12
POTENTIAL EXPOSURE PATHWAYS
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Table // 12
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Table #13
CARCINOGENIC POTENCIES (ORAL SLOPE FACTORS)
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Table #14
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Table #15
SUMMARY OF POTENTIAL CARCINOGENIC RISKS
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Table #16
SUMMARY OF POTENTIAL NONC1NOGENIC RISKS
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Table # 16
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Table #17
CUMULATIVE POTENTIAL RISKS - TRESPASSER
-------
Table # 17
Tr««p»c«*r Cumulative Carcinogenic and Noncarcmogenic Rick Aero** Pathway*"
Onaita Ba ck ground
Surfaca Wacar
Dermal Absorotion
Surfieial Soil
Dermal Absorotion
Surficial Soil
Ingestion
Sediment
Ingestion
Sadim«nc
Dermal Abaorotion
Cancer
Risk
5E-08
7E-07
1E-06
9E-08
SE-08
HI
0.003
0.06
0.06
0.01
0.01
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Risk
IE-OS
4E-07
8E-07
1E-07
2E-07
HI
0.001
0.01
0.01
0.001
0.001
CUMULATIVE
ACSOSS PATHWAYS
2E-OG
0.1
2E-06
0.02
Notes:
* Risks based on all chemicals with at least one positive detection and a verified toxiciry value.
HI = Hazard Index (Noncarcmogenic Risk)
-------
Table #18
CUMULATIVE POTENTIAL RISKS - FUTURE RESIDENTIAL
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