United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA'ROD'R0684.'003
September 1984
xvEPA
Superfund
Record of Decision:
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~
-
TECHNICAL REPORT DATA
(Please read Instructions on the rl!~ene before com"leting)
1. REPORT NO. \2. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R06-84/003
4. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION: 09/25/84
Old Inger Site, LA 6. PERFORMING ORGANIZATION CODE
7. AUTHOR.S) 8. PERFORMING ORGANIZATION REPORT NO.
II. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD
14. SPONSORING AGENCY CODE
401 M Street, S.W.
Washington, D.C. 20460 800/00
1a. SUPPLEMENTARY NOTES
16. ABSTRACT
The Old Inger hazardous waste site is located midway between the cities of
~aton Rouge and New Orleans in Ascension Parish, Louisiana. The site was utilized
as an oil refinery and oil reclamation plant from 1967 to 1978. Approximately 41,600
cubic yards of waste oils, and heavily contaminated soils, sludges, and sediments
plus 2.5 million gallons of highly contaminated surface water and 7.5 million gallons
of slightly contaminated swamp water remain on-site. The waste materials include oil
contaminated with hazardous petrochemicals, various oil additives, and oil combustion
products. In addition, ten million gallons of slightly contaminated ground water con-
taining hazardous constituents are present in the shallow aquifer.
The cost-effective remedy includes: closing and sealing of an on-site well;
pumping and treatment of the shallow ground water aquifer via carbon adsorption; car-
bon adsorption treatment and discharge offsite of contaminated water; in-situ con-
.tainment and capping of slightly contaminated soils; and on-site land treatment of
heavily contaminated soils and sludges. Decisions on the need for corrective action
for the intermediate aquifer, the level of cleanup for the shallow aquifer and the
contaminated wood remedy were deferred. The capital cost for the selected alterna-
tive is $3,174,000 and annual O&M costs are estimated to be $10,000.
(Key Words are on attached page.)
17. KEY WORDS AND DOCUMENT ANALVSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS. C. COSATI Field/Group-
Record of Decision
Old Inger Site, LA
Contaminated media: gw, sw, soil, sludge,
wood,
Key contaminants: oils, sludges, VOCs, sol-
vents, pesticides, metals
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None "-R
20. SECURITV CLASS IT/lis page} 22. PRICE
None
EPA Form 2220-1 (Rn. '-77)
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11. ABSTRACT
Include a brief (200 words o,ltss) factual summary of the most signifinnl informalinn ,'unlain,',11II tl,,' "'.""1. II "", r"l'"'' """I'..", a
sipif'icant bibliography or lilerature survey, mention it here.
Prepared in \:oopcra1ion with. I r.II\,lalloli of, PrL",,'llh....1 011 ,,"ll1k"'lh l' III.
17. KEY WORDS AND DOCUMENT ANALYSIS
(a) DESCRIPTORS - Select from the Thesaurus of Engineerin{! and Scicntifk Terms Ihe proper aulh"rt/,'d I<'.IIIS thai Identify Ih,' majm
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ended terms written in descriptor form for those subjects for which no descriplor exists,
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jority of documenls are multidisciplinary in nature, Ihe Primary Held/Group assignmcnU,' will be 'I"" Ilk di""l'linc, area nf human
endeavor. or type of physical object. The application(5) will be eron-referenced with ",,'ondary I idll/( ;1\)111' a"l~nmcnl' Iha' ...,11 1'..11",.
the primary postingU).
18. DISTRIBUTION STATEMENT ,
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Old Inger Site, LA
Key Words:
Land Treatment, RCRA Part 264, Treatability Studies, Discharge Standards,
CERCLA Sections 101(14) and 104(a)2, Petroleum Wastes, Clean Water Act
Section 404, CaE, Wetlands, Excavation, Levees, Capping, Institutional
Controls, ACL, Background Level, Carbon Adsorption, Ground Water
Contamination, Maximum Concentration Limit, CERCLA Hazardous Waste
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ROD ISSUES 'ABSTRACT
Site:
Old Inger, Louisiana
Region
VI
AA, OSWER
Briefing:
August 17, 1984
SITE DESCRIPTION
The Old Inger hazardous waste site is located midway between the
cities of Baton Rouge and New Orleans in Ascension Parish,
Louisiana. The site was utilized as an oil refinery and oil recla-
mation plant from 1967 to 1978. Approximately 41,600 cubic yards of
waste oils, and heavily contaminated soils, sludges, and sediments
plus 2.5 million gallons of highly contaminated surface water and
7.5 million gallons of slightly contaminated swamp water remain
on-site. The waste materials include oil contaminated with hazard-
ous petrochemicals, various oil additives, and oil combustion pro-
ducts. In addition, ten million gallons of slightly contaminated
ground water containing hazardous constituents are present in the
shallow aquifer.
SELECTED ALTERNATIVE
The cost-effective remedy includes: closing and sealing of an
on-site well: pumping and treatment of the shallow ground water
aquifer via carbon adsorption: carbon adsorption treatment and
discharge offsite of contaminated water: in-situ containment and
capping of slightly contaminated soils: and on-site land treatment
of heavily contaminated soils and sludges. Decisions on the need
for corrective action for the intermediate aquifer, the level of
cleanup for the shallow aquifer and the contaminated'wood remedy
were deferred. The capital cost for the selected alternative is
$3,174,000 and annual O&M costs are estimated to be $10,000.
ISSUES AND RESOLUTION
KEY WORDS
1.
On-site land treatment was selected as
the cost-effective remedial alternative
for the heavily contaminated soils and
sludges. The land treatment system will
be designed, constructed and operated
in compliance with RCRA Part 264,
Subpart M. Treatability studies will be
conducted during the design phase as speci-
fied in Subpart M to assure proper degrada-
tion. The feasioility of land treatment
Land Treatment
RCRA Part 264,
Subpart M
Treatability
Studies .
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Old Inger, Louisiana
August 17, 1984
Continued
ISSUES AND RESOLUTION
must be approved by the Regional Administra-
tor before the remedial alternative is
implemented.
2.
Final guidelines from OSW for land treatment
treatability studies were not available at
the time the ROD was signed. Therefore, tne
studies conducted at the Old Inger site will
be performed in accordance with information
available at the time of design.
The proposed State water discharge
standards for the on-site treatment sys-
tem were determined from other hazardous
waste facilities in Louisiana, not from
site-specific conditions. In the future,
more focused water quality requirements
should be considered.
3 .
Petroleum materials found onsite are
not excluded under CERCLA Sections 101(14)
and 104(a)2 because such materials are
inter-mixed with various hazardous
substances.
4.
The selected remedial action will require
filling of on-site wetland area (swamp).
In general, Section 404 permits are not
required for response actions under
CERCLA. In addition, the Corps of
Engineers determined that discharge into
this wetland would be authorized by the
nationwide permit established in 33 CFR
330.4(a) (2). An assessment of the wetlands
by EPA found that filling will result in
eliminating these areas but will improve
the general environment of the site.
Because of the site's proximity to the
Mississippi River levee, excavation would
be restricted to prevent levee failure dur-
ing cleanup. Although excavation of the
heavily contaminated soils and sludges is
not expected to affect the stability of the
levee, the COE will monitor excavation
activities.
5.
-2-
KEY WORDS
Discharge
Standards
CERCLA Sections
101(14) and
104(a)2
Petroleum
Wastes
Clean Water Act
Section 404
COE
Wetlands
COE
Excavation
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Old Inger, Louisiana
August 17, 1984
Continued
ISSUES AND RESOLUTION
6.
The selected remedy provides that
excavated areas containing slightly
contaminated soils be capped with
river silt dredged near the site,
an impermeable clay layer and vegetative
cover. This is in compliance with the
technical requirements of RCRA Part
264.310. Institutional controls will also
be used to assure against any potential for
direct contact.
7.
A carbon adsorption system will be used to
treat the contaminated shallow ground
water. Data from treatability studies
will be used to optimize the treatment
process. Decisions on the level of cleanup
for this shallow aquifer are being deferred.
However, treatment of the shallow ground
water aquifer is projected to reach back-
ground levels or maximum concentration
limits (MCL) unless an alternate concentra-
tion limit (ACL) is granted. Also, the
decision concerning the necessity of cleanup
of the intermediate aquifer has been
deferred.
8.
The wood on-site may be considered to be a
hazardous substance. If it is determined
to be hazardous it may be sent to a
RCRA incinerator. Otherwise, the Assistant
Administrator will make a determination
concerning the wood's final disposal.
-3-
KEY WORDS
Capping
Institutional
Controls
RCRA Part 264
Alternate
Concentration
Limit
Background
Level
Carbon
Adsorption
Ground Water
Contamination
Maximum Concen-
tration Limit
Treatabili ty
Studies
CERCLA Hazardous
Waste Definition
Contaminated
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u
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site:
Old Inger, Ascen~ion Parish, Louisiana
DOCUMENTS REVIEWED
I am basing my determination primarily on the following
documents describing the analysis of cost-effectiveness of
remedial alternatives for the Old Inger site:
Old Inger Remedial Investigation, D'Appolonia,
October, 1983
Old Inger Feasibility Study, D'Appolonia, May, 1984
Summary of Remedial Alternatives Selection, August, 1984
Staff summaries and recommendations
DESCRIPTION OF SELECTED REMEDY
Closing and sealing of an ungrouted onsite well
- .Pumping and treatment of the shallow ground water aquifer
via carbon adsorption.
Carbon adsorption treatment and discharge offsite of
contaminated fluids (onsite surface water).
In situ containment and capping of slightly contaminated
soils.
Onsite land treatment of heavily contaminated soils and
sludges.
-
DECLARATIONS
Consistent with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA) and the National
Contingency Plan (40 CFR part 300), I have determined that the
onsite carbon adsorption treatment of contaminated liquids and
onsite land treatment of heavily contaminated soils and sludges,
and other measures described above, as an interim remedy effec-
tively mitigates and minimizes the most significant risks to
public health and the environment and limits future risks of
migration of contaminated ground water. Decisions on the need
for corrective action for the intermediate aquifer, the level
of cleanup for the shallow aquifer, and on disposal of the
contaminated. wood are being deferred. The State of Louisiana
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The selection of the land treatment alternative is conditioned
upon a final determination by the Regional Administrator, based
on the design phase pilot studies, that the waste can be completely
degraded, transformed, or immobilized in the treatment zone.
In addition, I have made the following determinations
concerning the enactment .?f the selected remedy:
o
The action being taken is appropriate when balanced against
the availability of Trust Fund monies for use at other sites.
o
The cost-effective remedy does comply with other environ-
mental regulations, except to the extent that final decisions
on certain aspects of the remedy are being deferred.
9/') 0 /;'1
{Date '
~ '-'-- ~k-£ ..
Lee M. Thomas
Assistant Administrator
Office of Solid Waste and Emergency
Response
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
OLD INGER
AUGUST, 1984
SITE LOCATION AND DESCRIPTION
The Old Inger hazardous waste site is located about 4.5 miles
north of Darrow, Louisi~na, between Louisiana Highway 75 and the
Mississippi River levee. It is approximately midway between
Baton Rouge and New Orleans, Louisiana (Figure 1). The site is
within the Mississippi River floodplain but is protected by the
levee system.
The land near the site is devoted to agricultural uses and
therefore is sparsely populated. The population within a one
mile radius is approximately 200 people. The closest residence
is approximately 0.3 mile south of the site, on the east side
of Highway 75. The major drinking water aquifer for the local
area lies approximately 120 feet below the site.
There are four distinct features or areas to the Old Inger
site. They are the surface tankage, the waste lagoons, the
swamp and the buried waste area (Figure 2). The surface tankage
includes nine oil storage tanks ranging in capacity from 37,500
to-225,000 gallons, a cracking tower, a separating tower and - ;..-.
their respective containment areas. There are two lagoons, one
0.8 acre and the other 0.07 acre. The swamp is approximately 7.5.
acres in size. Approximately one-half acre of the southeastern
corner of the swamp has been filled in with solid refuse and
construction debris. The buried waste oil pit occupies the
south central portion of the site.
'SITE HISTORY
The Old Inger site began operations in 1967 as an oil refinery
and was obtained by Old Inger Oil Refinery in 1976 to be used as
an oil reclamation plant for refinery wastes.
It remained active in this function until March 1978 when a
large spill occurred, contaminating the surrounding area. The
facility was purchased shortly thereafter with the intention of
cleaning up the site. However, the new owners of the equipment
found it to be uneconomical and abandoned the site in 19ijO. The
Louisiana Environmental Control Commission formally declared the
site abandoned in 1981.
When the site was operated, waste oils were brought to the
site by barge and by truck. Waste oils were processed in the
largest cracking tower and then stored on the site. Final products
were generally removed by truck. The lagoons were used for
disposal of waste sludges, oils, and surface water. Occasionall~,
liquid from Lagoon 1 would be siphoned into the swamp to help
maintain storage capacity of the lagoon. The liquid was siphoned
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2
and the bottom .sludges. Some oily materials were discharged
into the 8wamp during the siphoning process. On at least one
occasion, a feedstock line broke and discharged a substantial
quantity of oil into the swamp.
Storage tanks were used for the following purposes:
Tanks
Use
9 & 10
6,7, & 8
5
Feedstock
Bottom products (fuel oil)
Surface water, unusable (heavy)
feedstock, etc.
Top products (light oil)
Top products (lightest oil)
2 & 3
11
Tanks 1 and 4 either never existed or were removed prior to
site abandonment in 1980. Interviews with people familiar with
operations at " the Old Inger site indicate that the waste oils
were processed by:
o
Heating the heavier oils to decrease viscosity and
breakdown emulsions and,
-
Mixing them with used lubrication oils, light oils,
and perhaps spent solvents.
The reprocessed oils were shipped by truck or barge and sol(
for fuel oil. Some oils may have been received from or shipped
to other oil reclamation plants in Texas or Florida.
o
EPA Lead Activities
An emergency action was completed in July 1983 by EPA to
prevent Lagoon 1 from overtopping its levee. The contaminated
water, 330,000 ga110ns i~ all, was pumped into Tanks 5, 6, and 9.
There was also some stabilization work done on the lagoon dike
in this action. An IRM was obligated September 14, 1984 to
remove the liquid in these tanks and pump down lagoon 1. This
will allow storage capacity in the case there is another emergency,
and allows storage for remedial actions.
CURRENT SITE STATUS
The Old Inger site investigation was a multi-disciplined
approach consisting of soil borings, ground water sampling, .
surface water sampling (tanks, lagoons, streams) and air monitoring.
Stratigraphy
Subsurface soils consist mainly of clayey silts and sandy
silts that range in permeability between 1.3x10-4 cmlsec to
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. (' . I
I
I ..1\ t . , "J
~.,~~ , -~, " o' :'-: ~.,~f"., !.~ ., :~.
I , .,' '~~ .t- .-._.....!_..,.~, .:..J.;J'
I-- ",". .1 . .. ............ ~"' ~ ....
t.
I ' ,~
!~.) -..n,.,.
L
FIGURE
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'.
LEGEND
@ STORAGE TANK
~
=~@j
SWAMP
SOLID
REFUSE
LAGOON 2
FENCE
A
MISSISSIPPI
RIVER
lEVEE
o
"--
100
200
- SCALE !~ FEET
FIGURE 2
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5
clay than the deeper strata: hpwever, layers of clay and sand
were encountered throughout the geological cross-section. A
high variability in the lateral ~nd vertical distribution of
soil types vas observed. This is a common characteristic for
fluvi~l-derived sediments.
The swamp overlies a.relatively impermeable substratum.
A shallow silty lens, starting at about six feet below surface,
pinches out to the north and south. This lens contains the
shallow aquifer. This lens underlies the buried waste area,
lagoon, and portions of the swamp. A deeper sandy silt stratum,
starting at approximately 45 feet below surface, is 60 to 70
feet thick and contains the intermediate aquifer. The next
aquifer below this intermediate aquifer is the alluvial aquifer,
which starts at approximately 120 feet below the surface. Several
wells in the area use this aquifer as a drinking water source.
The next aquifer below the alluvial is the Gonzales formation,
a major drinking water source for the regional area. Lagoon 1
and the swamp presently induce a significant downward vertical
gradient on these aquifers.. The river has a slight influence
on ground water movement.
Wells
-
An inventory of wells within about three miles of the site, .
as compiled by the Louisiana Geological survey, indicates the
existence of 40 wells. The depth of these wells' average intake
is approximately 300 feet.
Hazardous Compounds Present
Table 1 shows the hazardou~ substance quantity estimate for
the site. There are 41,600 cubic yards (cy) of heavily contami-
nated soils (visibly contaminated) and sludges. There are 70,000
cy of slightly contaminated soils. There are 2.5 million gallons
of heavily contaminated (suspended solids) surface water in the
tanks and lagoons and 7.5 million gallons of slightly contaminated
surface water in the swamp area. The shallow aquifer contains
ten million gallons of slightly contaminated ground water.
An IRM was obligated September 14, 1984. This IRM will
remove approximately 330,000 gallons of contaminated water
from the tanks and 260,000 gallons from the lagoon.
The contaminants found on the site include hazardous
substances which are not petroleum (including crude oil or its
- fractions) and thus are not subject to the Superfund exclusions
under CERCLA 5101(14) and 104(a)(2). These substances are believea
to result largely from the presence of oil additives and products
of combustion. To the extent that material onsite includes
petroleum and petroleum fractions, they are contaminated with.
the hazardous substances described above, and those hazardous
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6
Table 2.giv~s the predominant organic and inorganic
contaminants that are found in the various waste streams with
the concentration ranges discovered. These constituents are
common to .11 the wastes found in each of the four critical site
areas.
The waste at the site contains
constituents which poten~ially have
or teratogenic effects on humans or
include:
quantities of hazardous
toxic, carcinogenic, mutagenic
other life forms. These
o
Trace heavy metals
Napthalene class of hydrocarbons
Phenols
Benzene
Benz (a) anthracene, and
Benzo (a) pyrene
o
o
o
o
o
Table 3 compares concentration ranges of selected hazardous
compounds found onsite with USEPA ambient water quality criteria.
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. ,
TABLE 1
TOTAL WASTE ESTIMATES
OLD INGER, LOUISIANA
....WILf - .&.Iron",
"WIL'I AIClln.'I ' alCll1\.'I GIft..I.... _"I.'.
.U8CI. C88fMlllAfU lOlLS COIfIMI"'" tOILS alftUl...m IMrn ClllllTUlIIIA ,.. IMftI .. c;- ..n. -
1UIIL ',1M "," "," J.' .., '8.' ',"
WOI.W8 c.. ,... c... ,... c... ,... .1.. i... ._11... .1111- ..11- .1116- ..11- .-
. ..a'. .. .. ... ...,
.
....... ',- ',800 .0 ','" .8 '.8'
.,....
a,_.ic. '8,- ",'" .00 '0,"" " I
"-o.J
......
C,. a'II.- ... ... .0 .08 .8 ...
........ 11.- '." .0 ','" .....
...11.'.,,, '0,- ',000 .0 '.808 ....
11- '.- ','" ','" ','" .1
.Ic'.' '.- '.'" ','" ... .1
01,_1_ '" .00 .. ... ...
.... Ie I... ... .00 10 .01 .....
... c_...,01'- .,. I. ..,.. ..' .1111- ep..t. fte.. ,.p'...., e_.,....i.. ellllll) ...1..... ror .........i., ........
,.. ...... .r ...... ...... .,. - .,.., .. -..it... .....
. .
I
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Table 2
8
TABLE 2
WASTE CHARACTERIZATION
OLD INGER
Oily(4)
Water
Volatiles
Benzene
Chlorobenzene
Ethylbenzene
Tetrachloroethylene
Toluene
Trans-l,2-dichloroethylene
l,l,l-Trichloroethane
Trichloroethylene
Metals
Cadmium
Chromium
Copper
Lead
Silver
Acid Compounds
4-nitrophenol
phenol
Base' Neutral Compounds
Acenapthene
Anthracene
,Benzo (a) anthracene
Benzo (a) pyrene
3,4-Renzo fluoranthene
Benzo (ghi) perylene
Ris (2-ethy1hexy1) phthalate
Chrysene
Fluoranthene
Fluorene
Naphthalene
Phenanthrene
Pyrene
1 )
2 )
3)
4)
Waste (1)
'Oils
Oily (2)
Sludges
Oily Soils (3)
and Sediments
(mg/kg)
(mg/U
(mg/kg)
(mg/kg)
*
*
0-2
*
2-175
0-75
0.2-350
0-30
0.2-20
0-600
0-20
0-10
0-2
*
0-15
*
0-2
0-0.03
*
*
0.02
*
.002-4
*-.004
.002-1
0.2
*
25
125
50
2
15
15
40
30
1
10
0.05
*
*
*
0-0.04
*
*
50
*
1
5-30
10
20
0.8
0.01
0-5
- 0..,.5
2
*
0-50
1-275
0-40
0-50
'*
*
0-30
0-6
*
*
0-10
0-4
0-25
0-50
0-40
0-65
0-130
0-175
0-40
*
*
*
0.05
1-20
1-140
0-250
1-175
0-275
2-1,000
1-250
*
0.1
0.4
*
*
10-80
0-25
*
*
*
*
*
0-50
0-50
10-70
0-50
*
*
*
0.2
0.3
0.5
0.8
0.2
15-175
10-80
Waste oils are primarily restricted to tanks and lagoons.
Oily sludges refer to buried waste and lagoon waste.
Pertains to swamp wastes and buried waste area.
Water contained within lagoons and swamps.
NOTE:
* Not detected
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. '
Table 3:
Comparison of Onsite Concentration Ranges
wit~ Ambient Water Quality criteria
Compound
USEPA Ambient
Water Quali ty
Cri teri a A
Onsite Ground Water
Concentration Range
(Shallow aquifer)
Onsite Surface Water
Concentration Range
(Lagoon 1 and Swamp)
Benzene (carci nogen)B 0.66 ug/l 3.0 180 ug/l
Ethylbenzene 1.4 mg/l 1.1 4.4 ug/l
Toluene 14.3 mg/l * *
Chromium III 170 mg/l
o - 2,000 ug/l
2 - 4,000 ug/l
2 - 1,000 ug/l
* 0.02 ug/l(CrT) 0 - 5,000 ug/l(CrT)
Chromium VI
(carcinogen)C 50 ug/l
TetrachloroethKlene
(carci nogen) 0.8 ug/l 1.5 8.7 ug/l * - 4 ug/l
'"
NOTE:
*
Not detectpd
All zero values refer to compounds discovered but
below detection limits
A/
B/
November 28, 1980, Federal Register
Values based on 10-6 cancer risk
~/
Drinking water standard
\.
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10
Contaminated' Fluids
The geohydrological investigation showed that the shallow
ground water aquifer is most contaminated in the vicinity of the
buried waste area and the large lagoon. Levels of volatile
organics approach 500 ppb in the ground water zone immediately
above the shallow aquifer in this area. With regards to lateral
migration in the shallow'~quifer, the main direction of flow is
to the east. At the eastern boundary benzene was detected at a
concentration of 0.18 ppm.
The intermediate aquifer is very slightly contaminated with
concentrations ranging from 1.8 ppb to the maximum concentration
level of 10 ppb (volatile organics). Lateral contamination is
restricted to the site boundaries within this water bearing
strata.
The deeper alluvial aquifer is a local drinking water source.
Ground water samples taken at wells from nearby residences found
. no contamination. This aquifer was not sampled within the lateral
limits of the site. There is no reason to suspect that any
contaminants have reached the lower aquifer, the Gonzales for-
mation.
From a surface water aspect, the lagoons are the most cont~'
inated. The levels of volatile organics within the swamp water'
do not exceed 20 ppb of volatile organics. These low concentrations
can be attributed to dilution, volatilization and biodegradation.
Analyses of surface water sampled offsite in a culvert near Louisi~
Highway 75 indicated non-hazardous organics near detection limits.
The priority pollutant analytical testing results indicate
that all of the onsite tanks, except Tank 11, contain oily water,
oil, or a solvent-water mixture characterized by hazardous consti-
tuents generally in excess of ambient water quality criteria.
Benzene, chlorobenzene, ethylbenzene, toluene, and chlorinated
ethanes and ethylenes were the primary volatile hazardous
petrochemicals detected. In addition to these compounds, some
pesticides, to include endrine aldehyde and 4,4 DDT, with concen-
trations less than 50 ppm were detected in the tanks (highest
concentrations) and containment areas.
Heavily Contaminated Soil, Sludges and Sediments
The greatest subsurface contamination that is soil related
is near the lagoons and buried waste areas. A layer of oily
material underlies portions of these areas to a depth of one to
-three feet. Visible contamination extends as far down as six.
feet near the buried waste oil cell.
Lagoon 1 contains sludge layers. Portions of the swamp
are covered by approximately an inch or so of oil residue and
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11
swamp sediments and offsite stream sediments contain
trace concentrations (near detection limits) of hazardous
constituents.
Other Contaminated Material
The northern six acres of the swamp contain trees that have
waste residue exposed on the lower three feet of their trunks.
More data must be collected to determine the appropriate method
for treating or disposing of this wood. There are approxi-
mately 5,000 tons of contaminated wood present onsite.
The southeastern corner of the swamp contains up to twenty-
five 55 gallon drums. All of these drums are partially buried
and the contents have been released.
The northeast end of the lagoon contains solid refuse including
at least forty-seven 55 gallon drums. All of the drums discovered
onsite were empty. The buried waste area contains exposed pilings
and buried construction material.
Air
. Organic vapor measurements showed that volati le wastes are ..--
contained in the onsite tanks and the buried waste area. While-
concentrations in excess of 10,000 pprn of volatile organics were
measured at some boreholes and tank inlets, no significant levels
(in excess of five ppm) were ever measured in the breathing zone
except in the immediate vicinity of the boreholes and tank inlets
(benzene and toluene).
Mississippi River Levee
The Remedial Investigation documented that the site's
proximity to the Mississippi River levee could restrict excavation
depths. The initial findings indicated that slopes no steeper
than two horizontal to one vertical have a satisfactory factor
of safety against failure during a cleanup period.
Another concern caused by proximity to the river is the
long-term (100 year) stability of the bank. A bank failure one
and one-half miles downstream occurred in August 1983, resulting
in a levee setback. A review of the circumstances leading to
that failure was undertaken by the u.s. Army Corps of Engineers
(Corps) and. was to be completed in August 1984. Discussions
with the project officer in the Vicksburg, Mississippi, office
- and bank stabilization engineers in the New Orleans office have
confirmed that the forces which acted to produce the downstream
failure are not present at the Old Inger site.
Figure 3 shows the segment in question and clearly
illustrates that the river is cutting a severe channel at the
downstream location, extending over 100 feet deeper than the
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12
river traversing ~ relatively str~ight course to just below
Qld Inger where, upon turning, it narrows and deepens, producing
heavy 8couring during peak floods. The scouring of the cutbank
in turn re8ults in unstable slopes. The bank at the downstream
site had been the subject of Corps revetment work since the
early 1970's. Several ~evetment failures occurred during the
1970's.
As Figure 3 shows, the channel at the Old Inger site is
fairly wide, shallow and straight with the deepest portion being
on the opposite side (west bank). No bank revetment projects
are being considered for the east bank. The Corps of Engineers
has stated that this east bank section will continue to be stable
for the next 50 to 100 years: however any future upstream or
downstream changes could conceivably produce channel cutting at
the Old Inger location. Stability of the site in relation to
the river is important to any technology for long-term onsite
disposal. .
POTENTIAL PATHWAYS
o
The offsite migration of onsite contaminated surface
water through natural drainage
o
The offsite migration of contaminated shallow ground
water.
-
o
The vertical migration of contamination to the
substratum aquifers and subsequent movement offsite.
o
Direct contact (human or animal) with onsite waste
oils sludges, heavily contaminated soils, water, or
vegetation.
The eventual receptors for surface water runoff is Lake
Maurepas. Runoff from the site moves by natural drainage until
it ultimately intercepts Bayou Conway then Bayou Manchac and.
finally Lake Maurepas. None of these bodies of water supply
drinking water but can be considered important natural resource
areas.
The surface of the lagoon is slightly elevated (less than
5 feet) above the surrounding land and the swamp to the west.
Protection berms surround the swamp area east of the tanks and
the onsite tanks and lagoons, which contain oil-contaminated
waters. The-berms are not considered adequate for long-term
containment of the rainfall associated with a storm of lO-year
-frequency. Consequently, the site is considered to pose the
risk of contaminating offsite drainageways in the event of berm
failures or overtopping.
As recently as February 1984, waste oils sheens have been
-------
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SECTION A-AI 8ANK FAILURE SiTE
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14
. .
the western drai~age ditch alongside of Highway 75. These
overflows result from heavy rainfall and the degradation of the
dikes. Low levels of contaminant migration have been documented
with the sampling of soils in the drainage ditch to the east of
the, site. A few priority pollutants were found near detection
limits, and heavy metals (chromium, nickel, zinc) were found in
the 10 to 100 ppm range.. These levels indicate the potential
for greater contamination if preventive action is not taken.
The receiving drainage water directly across Highway 75 to the
east is used by cattle.
The receptors for ground water contamination are the
Mississippi River, the alluvial aquifer and the Gonzales aquifer,
all of which are important drinking water sources. The Mississippi
is a drinking water source for New Orleans. The alluvial aquifer
and the deeper Gonzales aquifer are used by residents near the
site. The Gonzales is almost exclusively used by the larger
cities within the immediate vicinity of the site such as Baton
Rouge.
A shallow permeable silty lens intercepts the waste in the
lagoon and the buried waste cell. The ground water flow under-
neath this strata as with the deeper strata is slightly dependent
on the Mississippi River stage and more due to mounding caused -..
by surface water in lagoon 1 and the swamp. During low flow
stages of the river, lateral ground water flow is towards the
Mississippi, during high stages the flow reverses to the east.
The lateral gradients in the deeper water bearing strata are
even more dependent on river stage because of better connection
with the river. The lower strata also consist of more permeable
material.
Ground water flow is not just restricted to the lateral
direction at the Old Inger sitei vertical flow exists as evidenced
by the introduction of contaminants in the intermediate aquifer.
Like the lateral gradient, the vertical gradient between upper
and lower aquifers is slightly dependent on the river stage and
more due to lagoon and swamp mounding. Sometimes the gradient
is upward (high river level) but for the better part of the year
the water flows downward.
The Remedial Investigation determined that volatile organics,
(benzene and ethylbenzene) at the part per billion level, have
migrated downward to a depth of 75 feet within the deposits
underlying ~he site. The shallow aquifer and intermediate aquiter
are the predominant potential pathways for further migration.
- While neither of these aquifers are used as drinking water sources
they do serve as pathways for downward migration, either through
direct connection to the alluvial aquifer or through man-made
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15
An abandoned water well was identified as a possible pathway
for contamination between the shallow and deeper aquifers at the
site. It i8 believed that the annular space around the water
well casing was never grouted. If such is the case, there would
be enhancement for flow along the sidewall.
The presence onsite.of systems of tree roots systems, burrow
holes and pilings (buried waste are~) extending into the upper
sand lens, and the non-grouted water well annular space extending
down to the alluvial aquifer, indicate vertical pathways exist
for the migration of surficial and lagoon wastes.
The Remedial Investigation established that hazardous priority
pollutants are present at dangerous levels in site waste, oils,
and sludges, as well as in heavily contaminated soils water, and
vegetation. Contact with these waste streams poses a definite risk
to human health, as does ingestion of contaminants by wandering
cattle. The presence of hazardous substances also threatens the
. local ecology and indigenous wildlife species and the typical
rural uses of adjacent lands such as ranching and farming.
Upon disturbance, volatile organic compounds such as benzene
and toluene have been detected in breathing zones at levels
whicn pose a significant health risk.
-
The greatest exposure potential to the public and environment.
from hazardous substances at Old Inger would occur if the site were-
to flood and spread contamination over a large area. Even though
the site is protected by the levee system a failure in the levee
is possible. Such was the case with the previously mentioned
bank failure one and one-half miles downstream the from site.
The river was at low river stages then or the site would have
flooded. Assurance cannot be given by the Corps that this will
not happen again. .
ENFORCEMENT
The Inger Oil Site was leased in 1967 as a location for a
small oil reclaiming operation which was eventually abandoned in
1978. It is known that there were three owners/operators prior
to Inger Oil, with some other owners possibly existing. There
is some confusion concerning ownership of the refinery when the
overland contaminated water release occurred. Based on results
of a June 16, 1981, Environmental Control Commission hearing,
notice letters were sent to the owners of land actually leased
by Inger Oil and to heirs of the property not leased to Inger
- Oil, but affected by spills. Prior owners and operators were
also notified along with parties that may have been involved.
with activities at Inger Oil. Region 6 has identified 14 poten-
tially responsible parties. As of August 1984, Region 6 has
determined that none of the potentially responsible parties are
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16
ALTERNATIVES EVALUATION
Remedial Objectives
. The following objectives were developed following the data
evaluation collected during the Remedial Investigation:
Pathway
Onsite heavily contaminated
surface water
Objective
Prevent/minimize migration
Onsite slightly contaminated
surface water
Prevent/minimize migration
Onsite ground water
(shallow aquifer)
Prevent/minimize migration
Offsite ground water (intermediate
aquifer, alluvial aquifer)
Prevent/minimize impact
Onsite heavily contaminated
so~ls and sludges
Onsite slightly. contaminated
soils
Prevent/minimize migration
-
Prevent/minimize migration
As previously mentioned, air measurements indicated no
significant concentration levels of hazardous compounds exist
except in a few areas, therefore, no ~emedial action is required
for the air.
Alternative Considered
The following procedures, prescribed by the National
Contingency Plan (NCP), were followed to develop and evaluate
applicable alternatives.
o Identification of potentially applicable technologies or
remedial response actions [40 CFR 300.68 (d»)
o Screening of technologies to identify viable response
actions [40 CFR 300.68 (g)]
o Compiling of complementary technologies and actions into
alternative remedial plans [40 CFR 300.68 (g)]
o Screening the resultant alternative plans [in accordance
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17
Initial Screening
Subsequent.to their identification, the potential technologies
were screened to identify response actions by applying the following
criteria:'
o Capability of satisfying remedial objectives
o Environmental Performance
o Technical Performance
Contaminated Fluids
Contaminated fluids include the heavily (2.5 million gallons)
and slightly (7.5 million gallons in swamp) contaminated surface
water and the ten million gallons of contaminated ground water in
the shallow aquifer. Although not highly contaminated, the swamp
water was included because all of the remedies for disposing of
the heavily contaminated soils and sludges involve excavation
(thus drainage) in the swamp area.
Based upon the screening process the following three
alternatives were considered for the contaminated fluids:
o Activated Sludge
o Carbon Adsorption
o Deep Well Disposal
-
A no action alternative was also considered.
The activated sludge was eliminated from further consideration
based on the inability of the method to deal efficiently with
waste variability. At Old Inger there is a nonuniformity of
waste waters in regard to chemical constituents. A small-scale
system could be seriously disrupted by microbial intolerance to
variations.
Heavily Contaminated Soil and Sludges
Heavily contaminated soil and sludges include all heavily
contaminated soil, sludges, and buried oil layers. The decision
was also made to include the offsite ditch 5~diments, based on
the fact they may become more contaminated during future remedial
actions, even though they were classified as slightly contaminated
during the Remedial Investigation.
Based'upon the screening process the following four alternatives
were considered for the heavily contaminated soil and sludges:
o
o
In situ treatment (stabilization/solidification, capping)
Onsite landfill
Offsite disposal
Onsite land treatment
o
o
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18
The in situ .treatment was eliminated from the above list
because of its inability to meet the environmental performance
criteria baaed on laboratory tests performed. The solidification
process may be adequate in fixing the heavy metals but would not
imm~~ilize all of the organics and, therefore, would not prevent
leachate formation. A collection system could be installed to
intercept the leachate, but to be totally effective the wastes
would have to be excavat~d to prepare the grade. A slurry wall
could be used in lieu of a leachate collection system to prevent
horizontal offsite migration. It would not, however, eliminate
the threat of downward contaminant migration. Excavation depths
required for the slurry wall may cause a problem with levee
stability. For these reasons a slurry wall was not considered.
DETAILED DESCRIPTION OF REMAINING ALTERNATIVES
After the initial screening process, the following
alternatives were evaluated in greater detail:
Contaminated Fluid Remedy
o Carbon adsorption
o Deep well disposal
Heavily Contaminated Soils and Sludges
o Onsite landfill
o Onsite land treatment
o Offsite disposal
-
The no action alternatives were also evaluated further.
The following is a description of each alternative.
Treatment Alternatives for Contaminated Fluids
Carbon Adsorption
The carbon adsorption system will consist of the following
unit processes:
o Pretreatment
- neutralization
- equilization
- bulk filtering
o Primary treatment
- reduction of suspended solids
o Secondary treatment
- reduction of dissolved contaminant
Treatability studies on collected contaminated fluid samples,
performed during the Feasbility Study, concluded that the waste
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v
19
The design ~f an activated carbon system, including pretreat-
ment and priaary treatment, has been discussed with several
suppliers. However, several existing uncertainties in the waste
profile prevent some design specifications from being developed
at tpis time. The handling of the granular activated carbon has
not been addressed: however, recycling, landfill, or land treat-
ment are viable options.
..
In order to adequately protect public health and the
environment, all water discharged from the site will meet, at a
minimum, the following standards:
Biochemical Oxygen Demand <30 ppm
Total Suspended Solids <30 ppm
Chemical Oxygen De~and <150 ppm
Oil and Grease <15 ppm
Total organic Priority Pollutant <100 ppb
These limits have been utilized by the State water quality
agency in issuance of an NPDES permit for a hazardous waste
treatment facility, and as limitations on discharge from other
hazardous waste sites. These limits are consistent with Clean
Water Act requirements. Discharge of this level of contaminants
is not expected to interfere with maintenance of adequate water
quality. - ~-
The primary waste sources that poses a threat to the public
health and the environment are in lagoon 1, the swamp, and the
shallow aquifer. Because of the high concentrations of hazardous
compounds detected in the shallow aquifer, some level of treatment.
must be provided to reduce this contamination source. The degree
of contaminant reduction required in this aquifer is not yet
completely resolved. In the course of evaluating whether an
alternate concentration limit (ACL) is appropriate for the less
contaminated intermediate aquifer, EPA will determine whether
some level of cleanup other than background or maximum concentra-
tion levels (MCL) levels is appropriate for the shallow aquifer.
Fifty million gallons of contaminated fluid may need to
be treated due to all remedial action activities (including the
slightly contaminated water in the swamp, runoff, etc.). Treated
water can be directly discharged to the east, via existing
drainage to Bayou Conway, Bayou Manchac, and into Lake Maurepas,
or to the west, over the levee to the Mississippi River. Discharge
rates are estimated to be about 200 gallons per minute: Considering
the site configuration, a discharge to the natural drainage is
preferrable. From initial discussions with the Louisiana.
- Department of Environmental Quality (LDEQ) Water Pollution Control
Division personnel, it has been determined that such a discharge
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20
Deep Well Disposal System
A deep well disposal system would consist of the following
processes:
'0 Collection
o Storage
o Transportation
o Disposal
to'permitted facility
The disposal facility would be required to have an underground
injection permit.
Treatment Alternatives for Heavily Contaminated Soils and Sludges
The following elements are cornmon for each of the remaining
alternatives (except for no action):
o Contaminated fluid cleanup
o Collection of heavily contaminated waste
o In situ containment of waste remaining onsite
o Well seallng
o Long term ground water monitoring
o Land use restrictions
-
Contaminated Fluid Cleanup
The method for this element has been presented under the
contaminated fluid remedy described previously.
Waste Collection
Heavily contaminated soils, sludges, and contaminated fluias
must be collected. These waste can be readily collected through
conventional, cost-effective means such as excavation and pumping.
Section 6.1 of the Feasibility Study described the collection
mechanisms for each waste area. A further determination will be
made by the AA whether the contaminated wood will be collected
and burned in an onsite air curtain, recycled, recovered, disposed
or otherwise treated in a manner consistent with Subtitle C of
RCRA. The empty drums will be transported offsite.
In situ Containment
Collecting the heavily contaminated 80ils will expose the
slightly contaminated soils. Excavated areas where slightly
contaminated soils remain will be backfilled with river silt
-that is dredged from an adjacent area. These excavated areas
onsite will be covered with a relatively impermeable clay cap
(minimum permeability of 1.0 X 10-5 ern/see). A vegetative
soil cover would overlie the clay cap. This cap will meet the
technical requirement of 40 CFR Part 264.310 and will eliminate
the threat of direct contact and will reduce infiltration thus
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21
/
The onsite.landfill and onsite land treatment alternatives
involve the construction of an operable unit above an excavated
area. The closure requirements for these alternatives will be
discussed 1n the following description sections.
Well plugging
To further secure the site it will be necessary to close
and seal the onsite waterwell and plug all nonessential monitor
wells to eliminate possible pathways for vertical migration.
The pilings in the buried waste area will be cut and properly
sealed or removed and the remaining space sealed, depending on
field conditions. .
Long Term Ground Water Monitoring
There are twelve monitoring wells presently onsite which
could be used for long-term ground water monitoring. The wells
selected for monitoring will be sampled semi-annually for tne
contaminants of concern to assure against offsite ground water
migration. The onsite landfill and onsite land treatment
alternatives will require additional monitoring.
Land Use Restrictions
-
To assure against any potential for future waste migration
or direct contact, land use restrictions will be placed on the
site. The State of Louisiana will assure the enforcement of
these restructions in the operation and maintenance special
conditions.
onsite Landfill
This alternative involves the design of an onsite landfill
in full compliance with RCRA technical requirements (40 CFR
Part 264 Subpart N).
Due to the high water table at the site, a secure landfill
would have to be constructed above the present surface elevation
in order to meet RCRA requirements. The location (swamp area)
chosen for the landfill overlies a relatively impermeable sub-
stratum. The final elevation of the landfill would be four feet
higher than the levee. The landfill will incorporate the following
requirements of RCRA:
o Cap
o Gas collection system
o Leachate cOllection/monitoring
o Dual liner
o Post-closure
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22
Onsite Land Treatment
The land treatment system will be designed according to
RCRA technical requirements (40 CFR Part 264 subpart H). These
regulations require three major criteria be met. The following
describes each criteria separately:
The first requirements is that"studies must be done to show
that the waste is biodegradable in a land treatment environment.
Bench studies were conducted in the feasibility phase whereby
sludge from Lagoon 1 was added to soil at a 10% loading rate.
After two months the waste had biodegraded 60% or to a 4% rate
of loading. Hore degradation studies are planned in the design
phase that will be used to define the dimensions of the treatment
zone and project the total degradation amounts.
The next requirement specified by the regulations is that
at least three feet of unsaturated zone must exist between the
bottom of the treatment zone and the seasonal high water table.
This stipulation cannot be met for the proposed swamp and location
unless fill material is utilized. A minimum of eight feet of
fill would be required. It is proposed to drain the swamp and
remove and stockpile the heavily contaminated soil and sludges.
Runoff from the treatment area wi 11 be di verted to collection - ....
ponds at the south end of the site. Run on to the site will be.
diverted around the treatment area into collection ditches.
Heavily contaminated soils, sludges, and primary wastewater
treatment residuals will be applied to the land treatment area.
Application will take place approximately every six months. The
whole process will take from two to four years depending upon
climatic conditions.
The last requirement as stated in the regulations is
monitoring of the unsaturated zone (both soil and soil pore
liquid monitoring). The unsaturated zone is monitored to ensure
that the waste is being properly degraded in the treatment zone
and that unacceptable levels of leachate are not migrating downward.
Additional monitoring will be required on the following elements:
waste, ground water, runoff water, and air.
After the treatment operations have been succesfully con-
cluded, further closure and post-closure activities will be
implemented. These include ground water monitoring, remedying
any metal Qverload, preparation of a final surface, and a vegetative
covering of the land treatment area. Post-closure care will be
necessary for 30 years unless it is demonstrated that hazardous
constituents in the treatment zone are not significantly increasea
over background levels.
The storage of collected waste will be in accordance with
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23
Offsite Disp6sal..
Contaminated soils and sludges can be transported offsite
for disposal at a RCRA permitted commercial hazardous waste
landfill facility. There are two such facilities within 50 miles
of the site, Rollins Environmental in North Baton Rouge, and BFI
in Livingston. These facilities are not lined. If this alternative
was selected, lined landfills would also be evaluated for disposal.
The transfer of waste will involve prior solidification, loading
and hauling to the facility.
Hazardous waste transportation regulations require that
sludges and semi-solids be solidified, so that there are no
liquids present, and covered before being transporting in a
trailer. Testing completed during the Feasibility Study examined
several possible solidification agents for use in achieving a
cost-effective workable or -haulable- state. Based upon test
data, kiln dust is the recommended agent.
A loca1 trucking firm will be contracted to transport
solidified wastes to the RCRA facility. Routes will be predeter-
mined and drivers will be required to check back once they have
arrived. Once at the site drivers will follow procedures
established in conjunction with the facility for determining
waste quantity and bringing it to the appropriate discharge
point.
-
All wastes transferred to the offsite landfill will meet
the requirements for manifesting set forth in 40 CFR Part 262,
Subpart B for generators and 40 CFR Part 263, Subpart B, for
transporters.
A contingency plan will be established for possible emergencies
which may occur during transit. The plan will include responses
for truck breakdowns, accidents, and spills.
DETAILED EVALUATION OF REMAINING ALTERNATIVES
The alternatives remaining and common components were evaluated
in detail according to the following criteria:
o Technical
o Environmental
o Cost
Treatment Alternatives for Contaminated Fluids
From a technical and environmental standpoint, the contami-
nated water treatment using carbon adsorption and deep well
disposal alternatives are essentially equal. Both technologies
are proven. Less design work would be required for deep well
disposal as compared to a carbon adsorption system. The carbon
adsorption system would dictate that careful consideration be
given the capacity limits and system loading factors. Once
operating, properly treated water leaving the site will be below
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24
In respect' to scheduling, the carbon adsorption is more
flexible 8ince transportation and injection disposal facilities
may not always be available on short notice or during times that
disposal may be required unless adequate storage is provided.
The carbon adsorption unit will be onsite during the cleanup and
can be used on an -as 'needed- basis.
'.
Both the carbon adsorption and deep well disposal meet the
remedial objectives established for long-term and short-term
surface discharges from the site. For carbon adsorption, reduction
of temporary site discharges to effluent standards and long term
discharges to background should produce no added risk to human
health or the environment. This effluent will follow natural
drainage ultimately to Bayou Conway, Bayou Manchac, and Lake
Maurepas, none of which supplies drinking water. Concentrations
at Bayou Conway during cleanup could conceivably reach the 1 to
10 ppb range of volatile organics during temporary periods of
continuos discharge if stream flows are low. Institutional
constraints are comparable for both methods chosen for the
cleanup of contaminated liquids. The deep well disposal would
require that the facility in which the water is taken be permitted
according to underground injection regulations. Discharge of
treated water would meet the effluent discharge standards.
-
A substantial cost difference exists between the carbon
adsorption and deep well injection alternatives. On a per unit
cost basis, deep well injection is $.20/gal (based on local
, transportation and disposal cost) and carbon adsorption is
$.IO/gal (proposed system cost). Different quantities of water
to be disposed will vary with the remedial alternatives selected
for disposing of sludges and contaminated soils. The following
is the cost comparison for each such alternative.
Carbon Adsorption
Deep Well Disposal
Onsite landfill
Offsite landfill
Onsite land treatment
$ 431,000
$ 381,000
$ 481,000
$ 862,000
$ 762,000
$ 962,000
Treatment Alternatives for Heavily Contaminated Soils and Sludges
The environmental and technical criteria as applied to the
alternatives for disposing of contaminated solid waste are much
more complicated than those for the contaminated fluid cleanup.
Because of the complexity, discussion will be limited to
only those criteria where substantial differences exist between
the three alternatives. The common components applicable to'
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25
Technical Criteria Comparison
For technical reasons, the offsite landfill alternative is
less difficult to implement compared to the other alternatives
because of limited design requirements. The land treatment
alternative would prove the most difficult to implement since
careful attention would-have to be given to each waste application.
Scheduling is critical to all three alternatives because of
climatic factors. Excavation can only proceed during low river
stages. All earth moving would be done during dry weather.
Again, because of the critical manner in which waste must be
applied, the land treatment is most restricted in this regard.
The onsite landfill and onsite land treatment system will
require ground water monitoring during operation and other post
closure activities. The offsite disposal remedy will require
only long-term ground water monitoring.
. Environmental Criteria Comparison
In regard to the environmental criteria, the three alter-
natives are comparable. All will accomplish the short-term
reductions in offsite migration. A major difference between the
three alternatives pertains to the design life criteria. The
land treatment system is a more permanent remedy that degrades
the organic waste, although metals may remain immobilized in the
soil. Recycling and/or recovery was not considered for the metals
because of the low concentrations (background or detection level)
and amounts discovered onsite. The landfill systems are contain-
ment units which must be maintained indefinitely if they are to
operate properly. For the onsite landfill the Mississippi river
becomes a major concern due to levee stability.
-
Neither direct contact nor air emissions are perceived to b~
a problem for any of the alternatives. Direct contact potential
for all alternatives will be minimized with a clay cap and land
use restrictions. An air monitoring program will be implemented
during operation of the land treatment system to assure safety.
Except as noted in the .Consistency with Other Environmental
Laws and Regulations. section, all the alternatives would meet
the relevant RCRA technical requirements and, therefore institu-
tional constraints are comparable in this respect.
Cost Criteria Comparison
- Table 4 gives detailed costs for waste collection activities
and Table 5 gives detailed costs for in situ containment, both
common to each of the three heavily contaminated soils and sludge
alternatives. The in situ containment costs are based upon filling
all site areas, including excavation areas, to an elevation of 25
foot mean sea level (MSL) with fill material brought to the site.
The waste collection cost assumes the contaminated wood will be
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26
TABLE 4
w.&.STE CDUECfION CDSTS
OID IN:>ER, I.a.JISIAAA
~IPMENT LAB'JR 'IOTAL CDST
AREA DESCRIPTION (lJANTI'IY ($1,000) ($1,000) ($1,000)
Lagoon 1 Top Sludge 4,800 c.y. . 28.8 14.4 43.2
Liquid 1.5 M gal 7.2 3.6 10.8
Bottan Sludge 2,400 c.y. 14.4 7.2 21.6
Soil 3,600 c.y. 3.6 1.8 5.4
Dewatering (6 JOOs) 1.0 MM gals. 4.8 2.4 7.2
Drums 10.0 5.0 15.0
Subtotal 68.8 34.4 103.2
Buri ed Waste Surface Fi 11 4,700 c.y. 7.1 4.7 11.8
Area Buri ad Oi 1 4,900 c.y. 29.4 14.7 44.1
Soil 5,700 c.y. 8.6 5.7 14.3
Dewatering (3 JOOs) 0.5 M gals. 3.6 1.8 5.4
Pilings 1,000 ft 1.0 1.0 2.0
Subtotal 49.7 27.9 77.6
SwCDlp Water 7.4 M gals. 36.0 18.0 54;0
Dewatering (1 mo) 1.5 M gals. 7.2 3.6 10.8
Soil (1 ft) 12,000 c.y. 12.0 6.0 18.0
Trees (inc1. burn.) 5,000 tons 112 . 5 25.0 137.5
Subtotal 167.7 52.6 220.3
S. E ~ Swarrp Dewateri ng (1 mo) 200,000 gals. 1.0 0.5 1.5
Soil 4,000 c.y. 4.0 2.0 6.0
Drums 10.0 5.0 15.0
Subtotal 15.0 7.5 22.5
S. Boundary Soil 300 c.y. 0.3 0.1 0.4
Faci li ti es ? tons 10.3 8.0 18.0
Subtotal 10.3 8.1 18.4
Frontage Soil 600 c.y. 0.6 0.3 0.9
Tanks Water 600,000 ga1s. 4.0 4.0 8.0
Tanks ? tons 36.0 18.0 54.0
Soil 1,000 c.y. 1.0 0.5 1.5
Subtotal 41.0 22.5 63.5
Qffsi te Di tch Soi 1 1,000 c.y. 1.0 0.5 1.5
Ground water Water 10 MM gals. 12.0 6.0 18.0
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27
TABLE 5
IN SI'IU CDNTAINP£NT CDSTS
OLD IN:;ER, LaJISIANA
OJANTI1Y Of FILL MTERIAL E1,)lJ IP P£NT IAB:>R 'IOTAL CDST
(C.Y.) ($1,000) ($1,000) ($1,000) ($1,000)
AREA
Lagoon 1 40,000 (1) 140.0 60.0 30.0 230.0
Burl ed Waste Area 20,000 (1) 70.0 30.0 15.0 115.0
SW2Itp 200,000 (1) 700.0 160.0 40.0 900.0
SC1Itheast Swamp 10,000 (1) 35.0 15.0 7.5 57.5
Soothern Boondary 10 ,000 (1) 35.0 15.0 7.5 57.5
and Frontage
Subtotal 280,000 980.0 280.0 100.0 1,360.0
Clay Cap 20,000 90.0 40.0 20.0 150.0
-. ' .
COller 15,000 3.0 12.0 3.0 18~0
Vegetation 5.0. 5.0 2.0 12.0
Well Seali NJ 1.5 3.0 1.5 ~
Subtotal 32.0 20.0 11.5 73.5
'IDTAL 1,079.5 340.0 126.5 1,546.0
(1) Usi ng River Silt dredged near the si te, Calpacted up to an elevation of
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28
The onsitelandfill and offsite disposal alternative would
require additional costs for waste stabilization/solidification
activities prior to disposal in a landfill.
. Table 6 summarizes the cost associated with each alternative
as well as public health considerations, environmental considera-
tions, technical considerations, and public comments due to
implementation. The capital cost for each alternative includes
all operation and maintenance cost (labor, energy, etc) performed
during the construction and operational period. The operational
and maintenance cost listed in Table 6 includes long term monitoring
and other post-closure requirements.
-------
, ,
'"
TABLE 6. SUffoV\RY OF fMNI' cmtER
CDNTAMINATED LI~Ia;
(Cost based 00 land
treatJnent system)
1. Carbon Adsorption 481 NA NA No impact Di scharge to Optimi ze Acceptable
(onsite) offsi te treatment
surface water. process to
meet state
permi t re-
quirements.
No inpact Hazardws potenti a1 .
2. Deep well Injectioo 962 NA NA Acceptable
(offsite) liquids in- scheduIi I'YJ
j ected to difficulties.
Class III
grwnd water.
Iv
Degradation Cootami nated \£>
3. No Action NA NA NA NA
of alluvial surface water
aquifer. wi 11 migrate
oUsi te in
future.
CDNTAMINATF.:D roUE
AND SWOOES
1. OO5i te RCRA
Lamfi 11 1574 10 3605 Potential Potential Liquids and Highly Noo permanent
0 waste Collectioo 526 of levee of levee semi -liqui ds cwosed remedy
0 In situ Cootainment 1546 i nstabi Ii ty. i O5tabi Ii ty. nust be solid- (Si te
0 Liquid Treatment . 431 Hied. i O5tabi 1i ty)
(carbon ads.)
0 Moni tori I'YJ wetlams ScheduIi I'YJ
4077 fi 11i I'YJ. difficulties.
. If High grwnd water.
,
Faci Ii ty to be
-------
TABLE 6. RJR OLD IN:;ER (REX; ION VI) (Con It)
AL'i':mATIVE
2. Offsite RCRA
Landfill
o waste Collection
o In situ Containment
o Liquid Treatment
(carbon ads.)
o Moni tori rg
(Cost $1000)
Cap O&M PW
PUBLIC HEAL'm DNIRJN.en'AL
CDNSIDERATIONS IDNSIDERATIONS
2726A
526
1546
381
4671
7
waste IIIJst be
transported
offsite
5179
3. Onsi te Land
Treatment 621
o Waste Collection 526
o In situ Containment 1546
o Liquid Treatment 481
(carbon ads.)
o Moni tori rg
10
2850 Air erndssions
IIIJst be r~
duced.
Di rect contact
p:JSsible.
3174
4. No Action
o Moni tori rg
12
7
77
Degradation
of alluvi al
aquifer.
Di rect contact.
Wetland
fillirg.
Metals
renain
in soils.
'l'EOfiICAL
IDNSIDERATIONS
Liquids and
sernd -liquids
IIIJst be solid-
ified.
Treatability
studies IIIJst
be performed.
Adversely affected
by rainfall.
Scheduli rg di t-
ticulties.
High groond
water.
Land treatment
systsn to be t load
proofed .
2-4 years
duration.
PUHLIC
WfHNI'
O'lHER
Acceptable Non petmanent
r&neCIy
Acceptable More
per:manent
rEmedy
w
o
A. Cost based on transportation and disposal in unlined facility. However it oftsite disposal were chosen,
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31
No Action
The following is an evaluation of the environmental
performance on all site wastes for the no action alternative.
As explained below, this alternative fails to eliminate the
direct contact and migr~tion of waste and therefore poses threats
to public health and the environment in the short and long term.
'.
(1) Lagoons -
No action on the lagoons will cause degradation
of offsite surface waters. Runoff from the lagoons
once full, drains into the swamp and then goes
offsite. Eventually the dikes surrounding the
lagoons will break causing a spill that will
severely affect offsite surface waters.
Since the lagoons are connected to the shallow
aquifer, organics will continue to migrate
into the aquifer at a significant rate. This
contamination may eventually result in high
concentration levels of contaminants offsite
in all of the underlying aquifers since they
may be interconnected.
(2) Buried
Waste Area - The buried waste area and underneath
t~e lagoons are the primary places where large
amounts of contaminated soil are located. There
will continue to be generation of contaminated
leachate. Such leachate will be transported to
the shallow ground water then most probably in
the underlying aquifers.
-
(3) Tanks -
The threat from the waste in the tanks lies
primari ly in di rec.t contact wi th wastes from
people climbing into them or affects to surface
water if leaks should develop. The proposed IRM
should remedy this problem.
(4) Swamp -
Heavily contaminated soil and wood can produce
significant amounts of seepage. Root systems
provide vertical conduits for flow even though
the swamp is underlain by clayey soils. Hydraulic
pressure produced by the swamp can also induce
ground water contamination.
As with the onsite landfill alternative, if the levee fails
a major offsite release of hazardous compounds will occur.
-COMMUNITY RELATIONS
Region 6 and LDEQ issued a joint press release to announce
the public comment period, the public meeting, and the availability
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32
Copies of the Draft Final Report were placed in three repos-
itories in the immediate vicinity of the site and at the offices
of LDEO in Baton Rouge and EPA in Dallas. In addition, telephone
courtesy calls were made by LDEO to State and local elected
officials and to interested citizens. The dates of the public
comment period were from June 18, 1984, to July 9, 1984. A
public meeting was held.on June 21 at the Ascension Parish Courthouse
East in Gonzalez.
A list of meeting attendees and a summary of comments received,
is included in the Responsiveness Summary (Attachment 1).
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS AND REGULATIONS
An onsite landfill would be in full compliance with the
technical requirements of 40 CFR Part 264 Subpart M. An onsite
land treatment would be in full compliance with 40 CFR Part 264
Subpart N. Any material transported offsite would be in compliance
with manifesting requirements for generators (40 CFR Part 262
Subpart B) and transporter regulations (40 CFR Part 263 Subpart B).
The waste would be disposed in a RCRA permitted facility.
Activities that are common for all alternatives will meet the
technical requirements of RCRA. The deep well disposal alter-
native would dispose of the liquids at a permitted facility. ~.
Carbon adsorption discharge would meet the State's requirements.
Because the remedy is considered to be an interim measure,
EPA is not making a final determination at this time with respect
to disposal of the contaminated wood, necessity of treatment of
the intermediate aquifer, or the level of treatment of the shallow
aquifer.
Executive Order 11988, "Floodplain Management," is not
applicable to the Old Inger site. Flooding does not occur due
to protection from the Mississippi River levee system. The
Ascension Parish Flood Insurance Study indicates the Mississippi
River has a flood elevation of 34 feet and 36 feet above mean
sea level for the la-year and lOa-year floods. These levels are
below the elevation of the top of the levee adjacent to the
site. Therefore, flooding in this area is limited to sheet
flooding that is associated with mai, storm events.
The Corps has evaluated the site and determined that a
permit is not necessary for any remedial action (attachments 2,
3 and 4). ~n assessment of the wetland was performed (see attachment
5). Although the wetland will be eliminated with any alternative
- that involves heavily contaminated soils and sludges collection,
no other alternatives exist to adequately protect public health
and the environment. The implementation of any of these alternatives
(except no action) will improve the general environment of an
area that is presently limiting to flora and fauna. The Corps
(New Orleans District) will monitor construction activities onsite
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33
RECOMMENDED ALTE"RNATIVE
Section 300.68 (j) of the NCP states that -The appropriate
extent of remedy shall be determined by the lead agency's
selection of the remedial alternative which the agency determines
is cost-effective (i.e. the lowest cost alternative that is
technologically feasibl~ and reliable and which effectively
mitigates and minimizes damage to and provides adequate protection
of public health, welfare, or the environment)". Based upon the
Remedial Investigation and Feasibility Study, EPA Region 6 and
the State of Louisiana agree that carbon adsorption and discharge
offsite of contaminated fluids and land treatment for heavily
contaminated soils and sludges are the lowest cost alternatives
which effectively mitigate and minimize the most immediate risks
to public health and the environment and limits future risk of
the migration of contaminated ground water. Decisions on the
level of cleanup for the shallow aquifer, whether corrective
action for the intermediate aquifer, and the contaminated wood
remedy are nec~ssary to protect public health and the environment
are being ~eferred.
Contaminated Fluids
- In comparison to the deep well injection method, the carboq..
adsorption provides equal protection for public health and the"
environment but is less costly (Table 6). Therefore, the carbon
adsorption method is the cost-effective alternative.
Heavily Contaminated Soils and Sludges
In regard to the heavily contaminated soils and sludges, the
land treatment and offsite disposal provide equal protection for
the public health and environment. The onsite landfill is rated
below the other two alternatives in this aspect because of the
site's location. Levee failure in the future could lead to the
site being flooded or even removed. Of the three options, the
land treatment secti on is" recommended because it is the lowest
cost and it will more permanently degrade hazardous organic
compounds.
Table 7 is a detailed cost estimate for the onsite land
treatment alternative. Figures 4 and 5 show proposed site
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34
TABLE 7
ONSlTE LAND TREATMENT OOSTS
OLD IK;ER, LaJISIANA
MATERIALS W,JIPMENT LAEDR 'IDTAL
ITEM CUANTI1Y .- ($1,000) ($1,000) ($1,000) ($1,000)
Clay Barn er 24,000 c.y. (2 ft.) 109.0 48.0 24.0 181.0
Transfer Soi 1s 24,000 c.y. (2 ft.) 36.0 18.0 54.0
to Construction
Treatment Zone
Drai nage Control 2.0 10.0 8.0 20.0
Waste Application 12,000 c.y. 72.0 36.0 108.0
Soi 1 Management 10.0 60.0 30.0 1UU.0
Ai r Moni tori ng 30.0 20.0 50.0
Moni tori ng Wells 5.0 3.0 2.0 10.0
- -"
Lysimeters 1.5 2.5 1.0 5.0
Closure 2.0 10.0 5.0 17.0
Mi scellaneOJs 2.0 10.0 8.0 20.
Subtotal 131.5 281.5 152.0 565.0
Contingency (10 percent) 56.5
-------
~
tIWCMtU, .u.O" .0&.01..
A.O II" LI8I, .0.0
0" IITI OlvE..tON DIU
'~~;:';:~1:; :?~..." .:'.: "..0 ':.":"'''.:-'''.=;. ..~.
i:-{.:' ... :..~.~.:..~;~.:~: ~
'. ..
.. >"-.0'
. . .
.'.1"551551".'
'L..
&,IwII allAD
UJ
V
. ," -,.,:
..,~:"':: 0" . ,::,.".~~,,,':':."":.".....,
~ ".: .' .' . .:' :
.,vr.
r-
SCALE
I
...
J
lOG'
"au." 4
LaND'" l Loca"...
. .
-------
2 FT. TREATMENT ZONE
TREATMENT AREA
DRAINAGE DITCH
TOP OF LEVEE
EL 40ft. MSL ~
_/
CONTAINMENT
DIKE
---
SEASONAL
HIGH WATER
TABLE
SECTION A-A'
~
o
VERTICAL SCAlE
I
10
1
2(1 FEET
1.0
o
I
o
H
-------
37
OPERATION AND MAINTENANCE
Projected operation and maintenance activities for the
selected alternative will include long-term soil monitoring and
long-term ground water ~onitoring. Other post-closure activities
include maintaining the run on/runoff system, maintaining the
vegetative cover, and continuing operations to enhance degradation
and transformation and sustain immobilization of the hazardous
constituents in the treatment zone. EPA will pay 90% of the
first year (after construction) share then the State will incur
the monitoring costs thereafter. The LDEQ will be responsible
for long-term monitoring. The source of Louisiana's match for
O&M will come from its Hazardous Waste Site Cleanup Fund established
July 16, 1983. This fund presently contains approximately five
hundred thousand dollars.
SCHEDULE
Event
o Approve Remedial Action (ROD)
o IRM Completion
o Complete Enforcement Negotiations
o Award/Amend Cooperative Agreement for Design
o Start Design (Includes pilot studies)
o Complete Design
o Award/Amend Cooperative Agreement for Construction
o Start Construction
o Complete Construction
FUTURE ACTIONS
Date
September 1984
September 1984
October 1984
November-1;S4
December 1984
July 1985
August 19~5
December 1985
December 198ti
Further treatability studies will be performed for the
contaminated fluids. These studies are being performed to
optimize the treatment process, not to ascertain treatability
-------
Attachment 1
-------
-
RESPONSIVENESS SUMMARY
-------
UNITED STATES fHVIRONMENT AL PROTECTION AGENCY1 116
G1 ngerls D1sk
AUG t 8 184 Document '10
-- J-
-
, ,
Old Inger Responsiveness S~ry
Kelcey Yarbrough, Project Officer
Policy' Design Section (6AW-SP)
lind. Garczynski, Zone Manager
State Programs Section (Wij.S48-E)
Thru: Bonnie J. DeVos Chief analne'""", by.
Pottey I Design Sectio~.J~~~
ThiS memo fs to confirm the transmission 0' the written Comments from
the Old Inger comment period on the Alternative Selection. These
comments were discussed in I meeting between the State and SOS. a
citizens group concerned about the site. We have reviewed these and
egree with the resPonses. These were the only written comments received
durtng the comment period., '
to . '. .
Please contact me at FTS 129-9761 l' you have any further Questions.
. '." .
. .'..'.' .
, '.
8Y...OIo -J .. f""" ......... ..,.., .,-" 't.... """'.t ......... . ...... .... ... It' . .... ............. . It' .............
.,,,".... J .........,..,.. .... .,..,.. "'1',"'"
. .... ....... ...... ...... ...... ..... ................. ...... ..,..t. .... ...,. ......,..... . .t. ..... .
.ATI t "'."'.t ........ ..t ,...-t...... ...
6AW.SP:K.YARBROUGH:gr:X7-9761:8/27/84
COHCUU!HCrs
.P.. ,..1120.1 n2-70)
08/28 13:15
7304324
O'''CIAL PIL! COpy
-------
Responsivene"ss Summary
The purpose ot this document is to clarify some of the
responses provided in the course of the July 26, 1984 meeting
on the Feasibility Study for the Old Inger Site.
".
Major Issues
2.
Although EPA may provide for additional opportunity
for comment in certain cases, in commenting on the feasibility
study the public should raise all the issues that can be raised
at that time in order to assure that these comments are taken
into account by EPA in selecting a remedial alternative.
Failure to raise certain issues in commenting on the feasibility
stUGY may foreclose persons f~om raising those issues at a
-
later date.
3.
In accordance with Superfund community relations
guidance, the confi~atory treatability study will be made
available for the purpose of public information, rather than
solicitation of public comment.
4.
While the site is believed to be secure from levee
failure for at least the next 50-100 years, it is difficult to
predict whether changes in the river's course ove~ a longe~
period may endanger the stability of the site.
Specific Is~ues
1.
Under the selected remedial alternative, EPA will
excavate the area near the levee to a sufficient depth to remove
all the heavily contaminated soil.
-------
- 2 -
soil near the levee and elsewhere on the site will be covered
. .
by backf111, and an 1mpe~eable cap.
The decision to leave
s11ghtly contam1nated soil 1n place in various areas of the
-
s1te was based on the be11ef that when such soil 1s covered
..
appropr1ately, 1t will not present a threat to health and the
env1ronment.
F1nancial considerations were not the primary
factor in the determination to leave some slightly contaminated
mater1al nea~ the levee.
3.
The number of borings at the site was determined on
the basis of EPA's belief about what was adequate to assess
condit10ns at the site.
The cost-effectiveness criteria of
Superfund does not directly apply to remedial investigation
projects.
-
9.
While EPA, in fact, considers other public health and
environmental standards in determining what remedy is necessary
to adequately protect public health and the envi~onment, the
cu~rent NCP (promulgated July 18, 1982) does not explicitly
require EPA to consider these other standards.
In addition,
EPA may impose stricter standards at some Superfund sites if
-------
.
50S COnRents--Old Inger Feasibility Study
July 26, 1984
Individuals Present at the Meeting, July 24, 1984:
Ross Vincent (EcOlogy Center, 50S Technical Consultant)
RUby Cointment (SOS) ..
Teresa Robert (SOS)
Bill De Ville (OEQ)
George Cramer (DEQ)
Bob Jacobsen (D'Appolonia)
Press Campbell (D'Appolonia)
Hameed Elnaggar (GDC)
Miles Seifert (WH&A)
Ross Vincent, acting as technical consultant for Save Our Selves ($OS),
presented comments on the Old Inger Feasibility document. Hs. Cointment and
Robert offered supporting statements. Both broad and detaned issues were
mentioned. CQmments made and responses given are summarized below.
MAJOR ISSUES (BROAD)
1. [Comment.. .Not sure whether sufficient data developed about geology anc..'
hydro.'ogy support conclusions shown in report. .
(Response ...Site characterization is more than adequate. Actual'y had 21
boreholes for a 13 acre site. This is conservatively 401 greater borehole
sa tura ti on than other Superfund sites. Further (ii sc;uS$1 ons of these poi nts
wi" be added to the document.
2. [Comment ...Concerned with possible close out of legal options at some
future date through loss of standi ng by not taking compl ete advantage of the
Administrative process at this time. .
[Response.. .Legal options are sti11 open. Explained the four phase.
approach of a Superfund action. Information is conveyed to the public for
their comment throughout each stage. Each site has its own community
relations plan, geared to the needs of the area. This includes open pUblic
meetings, availability of information after it has been compiled, and reviews
for comment by the public. Failure to comment complately at this stage in no
way jeopardizes future rights towards legal action.
3. [Comment.. .Concerned w.hether the document adequately proved that land
farming was the best option. Why wasn't the pilot testing included in the
F~asibi11ty Study?
. [Response... The document makes a tentative land farming reconvnenclat;on
to be verified by further study in Phase III, Engineer.fng Design. Thi s .
testing was beyond the defined scope for Feasibility work. Plans have been
-made to coordinate pilot test design with experts from the LSU Institute for
Environmental Studies. If these tests show landfarming to be unsuitable,
another option will De chosen for definitive design. Aho, after the ",..,
landfarm pi lot tests, II separate document wi 11 be generated and mad~
available to the puDlic for comment, before final implementation begins.
I
4. [Comment ...CcHII."ern expressed about the possibility of levee' failure,
similar to what happened downstream from the site.
- 1 -
n...,..~ ..eo. 4'-.
-------
[Response ...Actually. the Inger site 1s safer now from failure than 30
years Igo. The report shows rher cross sections taken at the failure
location. and at the Old Inger site. These cross sections display totally
different rher flow patterns and depths near the bank. The rher flow
pattern adjacent to Old Inger 1s actually on the other side of the riller
bank. resulting in a sl ight,.bul1d up of the channel on the Old Inger side.
over the last 30 years. It was agreed the probability of failure was very
low. and not a significant concern for the projected period of sHe work.
SPECIFIC ISSUES
1. (Comment ...(Section 3.2.2) Questioned why the document sugguted not
dealing with wastes close to the levee.
(Response ...It is technically feasible to remove wastes in this area.
However, when the orig1nal levee stabi1;ty work began. the depth of
contamination in this region was unknown. Later results indicated required
. e~cavation work would be minor. However. any work within the proximity of tne
levee would be limited by the US Army Corps of Engineers. who have
juriSdiction over the levee. It was felt the greatly added cost to deal with
the levee was not justified considering the level of contamination. Given
the minor levels of contamination. neither environmental concerns nor the cost
effectiveness criterion mandated by the Superfund law would justify major
expenditures for additional levee work. .. -
2. (Comment.. .Questioned the conclusion about the continuity of clay
beneath swamp area. The swamp would be drained and filled for the landfarm
operation. Questioned statement (p 4-3) "...do not pose threat". in reference
to subsurface contamination beneath treatment area.
[Response ...Actually had 10 borehole samples around the perimeter of the
s'wamp. Detailed analysis was made in the Phase I Remedial Investigation
report. Agreed to make additional references to the Phase I report. to
further clarify the reasoning behind the continuous clay layer conclusion.
Further. th~ proposed design of the land treatment area. in any case. would
add a layer of compacted clay beneath the treatment zone as additional
protection from any vertical migration of contaminants.
.L [(,..IIII1I.'nt ...QIW:>1.hl",,'iJ why 41lhJit;Ufwl tJo,'i"y:o WI.,' 1'(' not maoJL'.
[Response. ... The cost effectiveness criterion of Superfund precluded
additional boreholes. As stated previously, this site has a much higher
borehole concentration than other Superfund sites. Based on best
professional Judgment, added borehole samples would not measurably change the
conclusions about the continuity of the clay layer beneath the swamp.
4. [Comment ...Questioned how many firms bid on the project. and what were
their qualifications.
[~esponse ...Six firms submitted proposals for the initial Remedial
- Inv@st1gatfon. Feas;bi 1f ty study work continued .wHh the same contractors to
provide continuity of effort. EPA approved this arrangement. State law
precludes giving information about other bidder propos4ls or costs. Only the
successful firms I proposals are open for public scrutiny. However. the
selected proposal was also the lowest cost responsive proposal.
l
5. [Comment ...The document mentions the sale of scrap metal
will this be handled?
recovered.
How
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[Response ...Superfund law encourages resource recovery whenever possible
to mitigate costs. Any matedals recovered, e.g., metal scrap or fixtures,
would be decontaminated before leaving the site.
6. [Comment ...Concer!,\ed with statements like "probable level of
contamination is insignificant". What does this mean?
[Response... Target revels of con-tamination are defined earHer in
ChaPter 2 of the document.. Therefore, the use of terms such as
"insignificant" is not subjective, but hu a defined Quantitative referrent.
Agreed to further clarify meaning where used later in the study.
7. [Comment ...Didn't understand the meaning of "poor, fair, or good" when
used in for various screening levels in determining the best cleanup strategy.
[Response.. .Superfund Feasibility studies require various levels of
screening, with different criteria being used for each finer level of
discrimination. A technique that was judged good at a coarse level, may be
deemed poor at a finer level, where more factors are used for determination.
The relative ranking (poor, fair. gOOd) is also a function of the waste
. location and concentration. It was agreed to further clarify this point in
the document.
8.
[Comment ...(pg 4-7) Didn't like wording in text referring to lagoon 1.
[~~5pnn~c .. .J\IJrccd to (.L.II'ify =-t"'t"m~lIt ~I\d 1Inpt'ovE:' wunl1ng.
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9. [Comment ...{p 6-9) Questioned the statement "permitable NPDES levels",
;n reference to treated waters leaving the site.
[Response.. . The Na ti ona 1 Contingency Plan requires relating emission
levels, etc. to other federal laws. such as. in this case. NPDES permitting
standards and criteria. In practice, actual standards used for discharge will
be more stringent than NPDES requirements. especially for toxics. Will
clarify this in document.
10. [ComlTK!nt... (p 6-18)
the site?
[Response ...Carbon adsorption will be used on all aqueous wastes
the site to ensure compliance with applicable discharge standards.
11. [Comment ...(p 6-19) What does the term "excessive odors" mean?
[Response ...The definition will be further clarified in the document.
Is carbon adsorption to be used on all
wastes at
leaving
12. [Comment... (p 6-20) Landfarming is said to have been successfully used
at 011 refineries for years. Where is the data on degree of success,
application rates and residue concentrations?
[Response ...Could not ghe data from indhidual refineries in a PUblic
10cument, because it is confidential information. However, two recent studi~s
(K. Brown and ERT). document the effectiveness of landfarming in the public
4; terature. Wi 11 further document these references, and give more
~nformation about residuAl contAminant levels in final document.
13. [Comment.. .What is the biodegradation process (landfarming) and end
produc ts?
[Response.. .Actual p,'ocess and residual products with be furthel'
analyzed in the upcom1ng pilot study. Complete characterization of the
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.
waste. beyond the presence of priority pol1utant levels. will also be pursued
in the n@xt design phase. This will be clarified ;n the Feasibility document.
14. [Comment... (p 8-3)
nonexistent".
[Response ...See previo~s discussions of target levels and s.~\teyies for
st";,lgent discharge levels to achieve obje.ctives. This approach will result
in II!) meuurab le impact upon the recei vi"9 wa ter.
Didn't like statement "long term impact virtually
4~. [Comment ...(p 8-11) What are the "effluent limits" used?
[Response ...Wi11 cite effluent limits referenced in the document.
to previous discussions of objectives and targets concerning this point.
Refer
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datar81D8cI tbat the atira .a.te 41.'0.&1 .ite 1. a ..t1aDd with the 8Zception
of . urrow border (about 2S f.et wide S88ed1'te1,. adjacent to the bilhv,y). .
!be a1te, bov..er, 1. Dot .ubject to Corp,' Sectioo 404 juri.diction. .
J)epartlleDt of &.be An,. penL1 t would ROt be requirad for the da,ol1 t of 1111
Mterial DD tbe ..ta 41.pot&1 aita.
.,. qua.t1ou coRcera1q tbi. deUr81utioD .bould ... 41rected to Dr. liar)'
1.. 'luab-ltutj.. at (S04) 838-2292.
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DEPARTMENT OF THE ARMY
..w 0-1.&&"'. OISTitICT, COl'~ ~ &NGINCE".
p.o. 801 8Oa.~ ,
... ORLaAHS. LOUI8IAMA 70' 80
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A~or;
June 1. 1984
Surveillence end Enforcement Sect I on
Operetlons Division
Mr. Robert W. Jocobsen
D'Appolonle Weste Manegement Service
8116 One Ce'.11 Avenu.. Suite 20
..ton Rouge. Lou 111.ne 70809., '
O88r Mr. Jecoblen I
"
Th II i I I n response to your le11'.r of May 17 . 1984. d i rect.d to
Dr. L . oyd F. Beehr of our Regu letory Assessment Sect I on . concern I ng the
Old Inger Oil site In sections 23 end 24. T. 10 S.. R. 2 E.. In AscensLon
P.rish. Loulslene.
W. hed exam'i ned th I 5 I'lte In Ju 1 y. 1983 et the r.quest of Keren
So 'er i of th. Env i ronmentel Protect i on Agency. end det.rm i ned at thet ,-
'tl~ 'that It wa$ wetland. but not $ubJect to U. S. Army Corps of Engineers'
regulations beceuse It II Isolated and does not contribute to the river.ntL.,
system. Our determination ..de et that time has been reviewed and still
stands. A copy of our letter,of August. 1983. to Ms. 50lerl Is enclosed.
Shou 1 d you heve any further quest Ions r.gar ding th I smatter. p lea5e
contect Or. Them Davidson et'(504) 838-2270.
Sincere IV.
"
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Ronald J. Ventola
Chief. Regulatory Functions 8ranch
~eretlons Division
Enclosure
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SEP. 17 ' S4 15: 42 NOD LI'Y'iAS
P.01
DavldsonlWB/2270
September 13, "84
SUl'V8l11ance and !nforeernenc Section
Operations Dlvl.lon
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Mr. Clinton B. Spon.
Invlronmenc.l Prot.ctlon A.'ncv
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Dear Mr. Spott.:
Thl. II with reference to our letter of Au,u.t 2, '983 direCted to Mrl. Karon
5oIa,,' of your a.eney concerning U. S. Army Copps of IEn.lneer'a Jurlldlc:tlon at
the .Old I",.r On- location In Mctions 2) and 24, T. 10 S., R. ~ E., In AKenllon
Parlth, Loul.llnl. -
In clarification, the ,Ite i. decermlned to be w.tl.nd.~ Dlteh.,.. Into thl. we eland' .
I.authorlz.d by n.tlonwlde S*'mlt .. fPeclfied In 3S CFR 330.4 (a)(2) of our te.uJaUon.
dated Julv 22, "82.
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Should you haw any additional question. f..ardln. thll mau.r, pl.... COtItact
Or. Thom Davlcilon It (504) 838-2270.
Sincerlly,
Ronald J. Ventola
Chl.f, Re.",Jatory Pwnctlon. Branch
()peratlona Division .
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I.
II.
III.
OLD INGER SI7E, LOUISIANA
ASSESSMENT OF WETLANDS
September, 1984
Purpose
The purpose of this report is to:
1)
Review Executive Order 11990, May 14, 1977,
42 CFR 26961 entitled .protection of Wetlands..
2)
Review the Old Inger Remedial Investigation,
Feasibility Study, and Remedial Alternative
Selection for areas concerning wetlands.
Personal communication with the State and
Region were also utilized.
3)
Review applicable Federal, State and local
statutes involving wetland activities.
4)
5)
Review public comment on the wetland impact.
Summarize the impact on the wetland caused
by remedial activities at the Old Inger site.
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INTRODUCTION
Executive Order 11990, entitled "Protection of
Wetlands. requires Federal agencies to take action to
avoid adversely impacting wetlands wherever possible, to
minimize wetland destruction and to preserve the values of
wetlands. This order also emphasizes the importance of
the evaluation and mitigation of impacts as well as early
public review of plans involving action in public wetlands.
WETLANDS IDENTIFICATION
The Old Inger site has been classified as a wetland
(except for the .twenty-five foot highway border) by the
New Orleans District Corps of Engineers. The following
factors pertain to the site:
Entire site area is 15 acres.
.7.5 acres of site is a swamp.
The wetland is isolated and is not riparian (connected
to the river bank) because of the levee.
Site soils belong to the Commerce silt loam soil
classification.
The typical area climate is humid, subtropical.
The site is not in the 100 year floodplain of the
Mississippi River because it is protected by the
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IV.
2
The .site is not in the IOO-year floodplain of the
Bayou Conway, though sheet flooding does occur
during heavy rainstorms.
Local residents have been reported to
ditch for crayfishing. The bordering
River (separated by a levee) also has
and commerci.fl use.
There are large quantities of hazardous substances
documented onsite. Because of this contamination, the
site is limiting to flora and fauna with only mud turtles,
minnows and wild herbacious weeds found onsite. Most of
the trees onsite have already died probably as a result
of flooding or high concentrations of hazardous substances.
No endangered plant or animal species are found onsite.
The site is not a unique habitat or vital to local populations.
The site is located in the Mississippi fly-way for large
numbers of migratory waterfowl and birds and as such
poses a threat due to direct contact.
use the road
Mississippi
recreational
ASSESSMENT OF ALTERNATIVES IMPACTS ON WETLANDS
..OJ
The no-action alternative will continue to cause.a
threat to public health and the environment. Wastes will._.
continue to leach into the shallow and intermediate aquifers
if the waste source is not removed. A drinking water aqulf~r,
underlying these two aquifers, is threatened by the continued
downward leaching of the waste and could also become
contaminated.
_.
Contaminated surface water
offsite during heavy rainfall.
grazing cattle. Direct contact
onsite is a present threat.
has the potential to migrate
This migration may contaminate
with the exposed waste
No practicable alternative exists to preserve the
existing wetland due to inadequate protection of public
health and the environment. At a minimum, some removal
of contamination must occur. The evaluated alternatives
include excavating heavily contaminated soil and sludges,
backfilling, and capping the site. These activities will
have an adverse effect on the wetland by eliminating the
majority of the wetland area but a positive effect on
the general environment of the area by mitigating the
threat to public health and the environment. Because the
alternatives involve capping with a vegetative cover, a
suitable environment will be created restorating some
flora and fauna to an area that is presently limiting
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VII.
3
APPLICABLE FEDERAL, STATE, AND LOCAL STATUTES
. The following substantive requirements of the Department
of Army's Nationwide Permits Program (33 CFR Part 330.4)
will be met for.each evaluated alternative (except no-
action). These requirements involve the filling (discharge)
in non-tidal wat~~s of the United States that are not part
of a surface tributary system to interstate waters or
navigable waters of the United States.
o
Discharge will not be located in the proximity of
a public water supply. .
It is unlikely that the discharge will destroy
threatened or endangered species or destroy or modify
the critical habitat of such species. The discharge
will protect them from direct contact with hazardous
materials.
o
o
Discharge of material will consist of suitable material
free from toxic pollutants in toxic amounts.
o
Fill created from discharge will be properly maintaiDBd.
Discharge will not occur in a component of the Natural.
Wild and Scenic River System.
o
o
Best management practices will be implemented.
PUBLIC COMMENT
The proposed remedial alternatives, involving filling
of the wetland, were presented to the public during the
public comment period (June 18, 1984 to July 9, 1984). A
public meeting was conducted June 21, 1984, at which time
no public opposition to the wetland filling was made. No
written comment received to date have expressed any negative
comments concerning the filling either.
SUMMARY
Any alternative proposed for Old Inger that will
adequately protect public health and the environment will
cause adverse effects to the wetland by eliminating
most'of the wetland area. Since the wetland also threatens
or is limiting to flora and fauna, the elimination of the
wetland will have a positive affect on the environment by
providing an environment similar to areas located near
the site. A maintained cap over the site will be similar
to grazing lands adjacent to the site and common locally.
The public was not opposed to the alternatives involving
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