United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R06-85/008
August 1985
EPA
Superfund
Record of Decision
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TECHNICAL REPORT DATA
(Please read Instructions on the re~'erse before completing)
1. REPORT NO. r 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R06-85/008
4. TITLE AND SUBTITLE 5. REPORT DATE
RECORD OF DECISION Auaust 15 1985
Bayou Bonfouca, Ll\:: 6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S) 8. PERFORMING ORGANIZATION REPORT "'C
9. 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 Report
401 M Street, S.W. 14. SPONSORING AGENCY CODE
Washington, D.C. 20460
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Bayou Bonfouca site, a 55-acre abandoned creosote works facility, is located off
of West Hall Avenue and Bayou Lane in Slidell, Louisiana. The site is a flat, mostly
overgrown parcel and is located primarily within a designated 100-year floodplain. The
earliest records of the Bayou Bonfouca site date back to 1904. The creosote plant
treated pilings for use in the construction of a railway across Lake Ponchartrain. Over
the years, the plant operated under the ownership of various creosote companies, \"ith
the last property owner being the Braselman Corporation. On-site creosote waste deposit
have contaminated the floor of the bayou, two drainage pathways through the si te, the
creek bottom, on- and off-site soil and upper groundwater zones.
The selected remedial action for this site includes: excavation, transportation and
disposal of creosote waste and the upper six inches of contaminated soil beneath the
creosote piles and debri s at a RCRA landfill facility; and transportation and disposal
of contaminated water by deep-well injection at an approved RCRA facility. Additional
investigations will be undertaken to examine the contaminated drainage pathways, ground-;
and bayou sediment. These areas will be addressed in second remedial I
water zones, a I
action. Total capital cost for the selected remedial alternative is estimated to be I
I
$903,000. I
,
,
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,
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17. KEY WORDS AND DOCUMENT ANALYSIS \
b.IDENTIFIERS.OPEN ENDED TERMS C. COSATI held.Gr,..:' ,
a. DESCRIPTORS I
Record of Decision I
Bayou Bonfouca, LA 1
!
Contaminated Media: gw, soil, sediments i
Key contaminants: creosote :
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None 31';
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None
EPA Fo,m 2220-1 (Rev. .-77)
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17. KEY WORDS AND DOCUMENT ANALYSIS
(a) DESCRIPTORS - Selc,t from the The,auru, of Lng,"eerir.~ alld 5c"'11 II I " lerllh the pruper autlll'rli,'d "'"11' II'JIIUelllll\ 1/1,. 111,'1"r
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Record of Decision
Remedial Alternative Selection
SITE: Bayou Bonfouca, S'ide", Louisiana
DOCUMENTS REVIEWED
1 am basing my decision on the following documents describing the analysis
of cost effectiveness of remedial alter~atives for the Bayou Bonfouca site:
- Bayou Bonfouca Task Memoranda Investigation Report
- Bayou Bonfouca Focused Feasibility Study.
- Summary of Remedial Alternative Selection
- Responsiveness Summary.
DESCRIPTION OF SELECTED REMEDY
o Creosote Waste - Offsite Landfill
o Contaminated Water - Injection Well
DECLARATIONS
Consistent with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), and the National Contingency Plan (40 CFR
Part 300),1 have determined that the selected remedy at the Bayou Bonfouca
site is a cost effective remedy and provides adequate protection of public
health, welfare, and the environment. The State of Louisiana has been
consulted and agrees with the approved remedy.
1 have also determined that the action being taken is appropriate when
balanced against the availability of Trust Fund monies for use at other
sites. In addition, the off-site transport, and secure disposition is more
cost effective than other remedial actions, and is necessary to protect
public health. welfare. and the environment.
The EPA is undertaking an additional Remedial Investigation/Feasibility
Study to evaluate potential groundwater contamination and bayou contamination
remedies. .
()'H_~A III( J(J.P5
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
BAYOU BONFOUCA
SLIDELL, LOUISIANA
AUGUST 1985
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TABLE OF CONTENTS
SITE LOCATION AND DESCRIPTION.
......
. . . .
. . .. 1
SITE HISTORY. . . . . . .
........
. . .... . .
. . . 2
CURRENT SITE STATUS. .
. . . . . . . . .
.....
....3
ENFORCEMENT. . . . . . ~
ALTERNATIVES EVALUATION.
. . . . . . ." . .
. . . .
....5
. . . .
. . . . ... .
. . . .
.. 6
COMMUNITY RELATIONS. . . . .
......
. . . . . . . . . 12
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS. .
. . . . ". . . 13
RECOMMENDED ALTERNATIVE.
. . . . . . . . .
. . . . . . . . 14
SCHEDULE. . . . .
FUTURE ACTIONS.
. . . . . . . . .
. . . .
. . . . . . . . 16
. . . . . . .
. . . . . . . . . .
. . . . . 16
/
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
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Bayou Bonfouca
Slidell, Louisiana
SITE LOCATION AND DESCRIPTION
The Bayou Bonfouca site, a 55 acre abandoned creosote works facility,
is located off of West Hall Avenue and Bayou Lane in Slidell, Louisiana
(Figure 1). The site, a flat, mostly overgrown parcel. is located
primarily within a designated 100 year floodplain. Adjacent land uses
include a cement works plant east of the site, residential/commercial
areas to the north, and a subdivision west across the Bayou Bonfouca.
The Bayou Bonfouca. a navigable waterwayy flows south from the site
seven miles to Lake Ponchartrain. Between 1970 and 1972, the plant was
dismantled, leaving a few building shells and foundation slabs. Ground-
water resources include two low-yield water-bearing. sands within the
top 50 feet of the surface that are not used at thi s time. A regionally
significant aquifer named the Shallow aquifer begins at 60 feet and is
some 100 - 150 feet thick. The principal aquifer of use is the Pontchatoula,
at 1500 feet, which supplies water to the 26,000 residents of Slidell, of
whom 10,000 live within one mile of the site.
Creosote contamination exists on the site surface, in the groundwater and
on the bayou bottom. The purpose of this document is to outline the
selection of the remedial alternative for the surface cleanup. This
action will involve 5000 cubic yards of creosote waste 800 cubic yards
of contaminated soil, 500 cubic yards of debris; and approximately
200,000 ga110ns of contaminated water. The creosote contamination in
the groundwater and on the bayou bottom is the subject of a second
operable unit and separate feasibility study.
Figure 1
BAYOU BONFOUCA SITE
FORMER LOCATION OF AMERICAN
CREOSOTE WORKS PLANT
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BAYOU BONFOUCA SITE
SLiOELL. LOUISIANA
FIG. 2
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2
SITE HISTORY
The earliest records of the Bayou Bonfouca site date back to 1904. The
creosote plant treated pilings for use in the construction of a railway
across Lake Ponchartrain. Over the years, the plant operated under
the ownership of various creosote cOmpanies including Southern Creosoting
Company, Hattiesburg Creosoting Co., Gulf States Creosoting and American
Creosote Works, with property ownership resting finally with the Braselman
Corporation. Numerous releases of creosote occurred during the years
of operation.
In 1976, the U.S. Coast Guard undertook an investigation of the Bayou
Bonfouca waterway. This was supplemented by another study conducted by
the EPA, the Coast Guard, and the National Oceanic and Atmospheric
Administration in 1978. In 1979, a Regional Response Team agreed that
dredging the Bayou Bonfouca and landfarming that waste along with the
onsite creosote piles was a good cleanup solution. However, methods
for dredging the Bayou Bonfouca were felt to be environmentally dangerous
and merited more study. A cleanup proposal for the on-site contamination
proposed by Braselman Corporation in 1981 was rejected as inadequate by
the State of Louisiana. The site was included on the National Priority
List in December 1982. The Remedial Investigation/Feasibility Study
was initiated in late 1983 with the first phase of the field work.
completed in the summer of 1984. In late 1984, the EPA determined the
need for an operable unit approach to the site. The surface contamination
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CURRENT SITE STATUS.
Since 1976, numerous studies have been undertaken to examine the extent
of the problems originating from the Bayou Bonfouca site. These studies
indicate four areas of major creosote contamination. The greatest amount of
creosote is at the bottom of the Bayou Bonfouca. This deposit contains an
estimated 24,000 yards of creosote extending 1400 feet downstream from the
~ite with a thickness of one-to-three feet. A second area of concern is the
two drainage paths through the site. The creek bottom and creek floodplain
along the western side of the site contain 800 cubic yards of creosote, while
the drainage ditch on the eastern portion of the site contains only minor
creosote contamination. The third area of identified creosote contamination
includes the seven locations of known on-site creosote waste deposits (Figure 2).
Approximately 5000 cubic yards of creosote are cont~ined in these deposits.
The fourth area of creosote contamination is in the upper groundwater
zones beneath the site.
Prior to the EPA remedial investigation of 1984, no groundwater contami-
f.ation attributed to the si te had been reported, and Hmi ted character-
ization of the hydrogeology of the site had been performed. It was known
that the native clay soils had permeabilities in the 10-6 em/sec range and
shallow core borings were reported as uncontaminated. The EPA decided to
install three monitoring well nests to verify the previous studies and
enhance knowledge on the hydrogeology of the site. The investigation
revealed two water-bearing zones above the regionally significant
Shallow aquifer. The first zone is just below the surface. The second
zone is a narrow confined silt layer approximately 30 feet below the
site. The Shallow aquifer was determined to begin at 60 feet below
the site. Well nests installed in the vicinity of the large creosote
deposits were found to be contaminated in the first and second zone,
but clean in the Shallow aquifer. The well nests installed in the
northern portion of the site were found to be clean in both upper zones
and in the Shallow aquifer.
The creosote material in the bayou, groundwater and on the site has
been veri fied to be typical .of most creosote, composed primarily of
aromatic hydrocarbons, but containing many compounds. Results of
sampling during the EPA remedial investigation (Table 1) revealed
that the creosote in the on-site waste deposits contain percent range
concentrations of base neutral organic compounds. Depending on the
length of contact time and sensitivity of the individual, various
health effects from mild rashes to severe burns could occur from direct
contact with creosote. Additionally, some of the individual compounds,
such as phenanthrene have been specifically identified as potential
carcinogens (Table 2). Because of the real and potential harm that
this creosote material could have on the public health, the EPA must
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4
Th~ results.of the investigations performed to date at the Bayou Bonfouca
site has prompted the EPA to phase the cleanup of the site into two
operable units; a groundwater/bayou unit and a source control unit.
The source control operable unit, the subject of this document, will
include the on-site creosote waste deposits. A focused feasibility study
(FFS) to identify cleanup alternatives to handle this material was
completed in May 1985. The drainage path/groundwater/bayou unit is still
under study.
The results of the analysis of the waste deposits reveal a distinct
demarcation between the creosote deposits and the underlying native
clays. Comparing Table 1 with Table 3, it is apparent that a sharp
decrease in creosote constituents occurs in the soil at a depth of
about six inches beneath the creosote deposits. Field observations
further verify that the creosote deposits are easily distinguishable
from the underlying clay. It is the intent of this operable unit to
treat and dispose of, as appropriate, the creosote material. The
quantity of this material is approximately 5000 cubic yards (Table 4).
For added protection to the public health and the environment, the
upper six inches of soil beneath the creosote piles will also be treated
and disposed of, as appropriate. This quantity of material is approximately
800 cubic yards (Table 5) [Note: This material was not considered in
the Focused Feasibility Study.] The treatment/disposal of this soil
material along with the creosote waste will thus involve all major
creosote constituent contamination. Additionally, the creosote waste
piles contain water which will require treatment or disposal, as will
the water needed to clean the concrete pads under parts of area 1.
Finally, this operable unit will include the storage or disposal of 500
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.0
TABLE 1
- . CREOSOTE WASTE ANALYSIS
1
Location'
1 2 3 4 5
VOLATILE CmiPOUNDS, ug/kg
2 - Butanone2. 38,000 38,000 38 ,000 41,000 38,000
Styrene 7,000 U U U U
Benzene U U U 5,800 U
Toluene U U U 16,000 U
Ethylbenzene U U U 16,000 U
Total Xylenes U 1,800 U 27,000 2,400
SEMIVOLATILE COMPO~~S, ug/g
Naphthalene 2,500 1,700 480 11,000 4,200
2 - Methylnaphthalene 2,000 800 480 5,400 2,300
Acenaphthene 5,400 1,500 2,500 8,000 7,040
Dibenzofuran 3,800 1,700 2,300 10,000 6,400
Fluorene 5,800 2,400 4,400 11 ,000 10,000
Phenanthrene 28,000 16,000 26,000 52,000 48,000
Anthracene 7,500 3,300 8,200 120,000 16,000
Fluorantbene 16,000 14,000 19,000 18,000 28,000
pyrene 8,800 7 ,800 8,800 9,800 15,000
Benzo(a)Antbracene 1,700 2,000 2,200 2,500 3,700
Cbrysene 2,000 2,400 2,300 2,90Q 4,000
Benzo(b)Fluoranthene 1,000 1,800 1,400 U 1,100
Benzo(a)Pyrene U 860 600 U 1,100
U . Undetected at analysis
~: Refer to Figure 2. detection limits
to be a potential laboratory contaminant
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TABLE 2
HEALTH HAZARDS OF WASTE CONSTITUENTS
1
Hazard Code
1 2 3 4 5
VOLATILE COMPOUNDS
2 - Butanone 0 0 0
Styrene 0 0 0
Benzene 0 0 0 0 0
Toluene 0 0 0 0
Ethylbenzene 0 0 0 0
Total Xylenes 0 0 0
SEMI VOLATILE COMPOUNDS
Naphthalene 0 0 0
2 - Methylnaphthalene*
Acenaphthene 0
Dibenzofuran*
Fluorene 0 0
Phenanthrene 0 0
Anthracene 0 0
Fluoranthene 0 0 0
Pyrene 0 0
Benzo(a)Anthracene 0 0
Chrysene 0 0
Benzo(b) Fluoranthene 0 0
Benzo(a)Pyrene 0
*Toxic Effects Unkknown
IHazard Code Sources:
1. Possible Carcinogen 1. Merck Index
2. Irritant 2. Dangerous Properties of Industrial Materials
3. Toxic by Ingestion 3. Priority Toxic Pollutants
4. Toxic by Inhalation
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TABLE 3
- CREOSOTE CONSTITUENTS1. IN SHALLOW SOILS (ug/g)
- .
Sampling Borin~ Location2.
Depth (ft) B-1 B-2 B-3 8-4 8-5 Test Pit
0-0. 5 2.684 15.680 5.310 253 638 56
0.5-2.5 1 404 21 213 1
2.5-5.0 1 161 1 47 1 118
5.0-7.5 18 89 31 39 7 3
7.5-10.0 7 1 8 8 1
~. Creosote constituents represented by total semi-volatile compounds.
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TABLE 4
. SURFACE CREOSOTE WASTE VOLUMES
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3
Volume (ft )
Surface2 Creosote Contaminated
Area Number (See Note 1) Area (ft ) Depth (ft) Waste Water
1.A. Concrete 16,400 0.25 4,100
B. Waste 34,800 3.0 104,400
C. Standing Water 6,000 0.50 3,000
D. Cleaning Water 16,400 0.02(See 328
Note 2)
Area 1 Subtotal 108,500 3,328
2.A. 1,290 1.5 1,935
B. 129 0.5 65
Area 2 Subtotal 2,000
3. 1,800 0.5 900
4.A. 840 2.5 2,100
B. 1,260 1.5 1,890
Area 4 Subtotal 3,990
5. 750 1.0 750
6. 707 1.0 707
7. 1,500 3.0 4,500
Area 1-7 Subtotal 121,347 3,328
Contingency (10%) 12,135 333
Total 3 135,000 3,675
ft (Rounded)
Total yd3 5,000
Total gallons 27,500
Note
~Refer to Figure 2.
2. Assumed to be 0.02 feet of contaminated water
concrete area following steam cleaning.
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TABLE 5
SURFACE CREOSOTE WASTE VOLUMES - SOILS CONTAMINATION
Area Surface Area (ft2) Vol ume1 (ft3)
1 34,800 17,400
2 1,419 710
3 1 ,800 900
4 2,100 1,050
5 750 375
6 707 353
7 1 , 500 750
Total 21,538
Cubic yards 798
use 800
Previous Total = 5000 cubic yards
New Total = 5800 cubic yards
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ENFORCEMENT
To date, two Potentially Responsible Parties (PRPs) have been identified
at the Bayou Bonfouca site. These two PRPs are Braselman Corporation.
the present property owner. and American Cresote Works. Incorporated
(ACW). the last wood treating company to own/operate the facility.
ACW. a Texas corporation. owned/operated the facility from 1958 until
1972 when economic problems forced the closure of the operation. In
1975 ACW was sold to new owners. The fonmer stockholders of ACW fonmed
Braselman Corporation which retained the Bayou Bonfouca property.
ACW underwent several internal changes after 1975 and emerged as ACW. a
Delaware corporation. Currently ACW is in Chapter 11 bankruptcy and is
negotiating with EPA. Region 4. for liability on at least two other
CERCLA sites. Some settlements have been made with ACW in Region 4;
however. continued enforcement may force a Chapter 7 liquidation.
Braselman Corp., beginning in 1980. negotiated with the State of
Louisiana to develop a mutually agreeable cleanup plan. These negotiations
were unsuccessful. EPA and Brase1man have also discussed the cleanup
and the company has verbally indicated that it is interested in cleaning
up the land portion of the property. but that it may not have the
resources to undertake a CERCLA-approved cleanup.
EPA, Region 6. mailed "Notice Letters" to ACW and Braselman for the
source control Remedial Design/Remedial Action. In a letter received
by EPA on June 14, 1985. ACW declined involvement with the site cleanup.
In a letter received on July 22. 1985. Brase1man Corporation declared
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6
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AlTERNATIVES EVALUATION
A Source Control Focused Feasibility Study (FFS) was perfonmed to determine
what remedial action, if any, would be appropriate at the Bayou Bonfouca
site. The purpose of the study was.to propose source control remedial
~ction to cost effectively mitigate and minimize damage to, and provide
adequate protection of, public health, welfare, and the environment,
resulting from the presence and release of hazardous substances from the
surface of the Bayou Bonfouca site.
A source control remedial action is necessary at the Bayou Bonfouca
site in accordance with the National Contingency Plan (NCP), 40 CFR
Part 300.68 (e)(2), which states: .Source control remedial actions may
be appropriate if a substantial concentration of hazardous substances
remain at or near the area where they were originally located and
inadequate barriers exist to retard migration of substances into the
envi ronment" .
The primary threats that the Bayou Bonfouca site poses to the public
health and safety are: . .
(1) Direct contamination of groundwater supplies in the area;
(2) transportation of the onsite waste material into a navigable
waterway during flooding; and
potential for direct contact with the concentrated hazardous
(3)
material located on an unsecured site.
Remedial Objectives
The specific objective of the Bayou Bonfouca FFS is to develop and
evaluate remedial action alternatives for the cleanup of creosote wastes
and contaminated debris on the land surface in order to:
1. Minimize public exposure to creosote contamination existing on
the surface of the site;
2. reduce the potential for continued contaminant releases to the
Bayou from waste existing on the surface of the site;
3. mitigate the potential for contaminant migration due to site flooding;
4. minimize continuing contamination in the surficial and upper
artesian aquifers at the site; and.
5. Close the site in a manner that will minimize contaminant migration
resulting from surface runoff, minimize surface water ponding,
and minimize continued contamination from residual creosote
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7
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Cleanup criteria associated with each objective were not established
since the goal of this action is source control; that is. to contain or
remove the material from the uncontrolled condition in which it now
exists. This would mean containing or removing the creosote wastes in
bulk. In accordance with 40 CFR 300.68(e)(3). the contamination caused
by the present waste is the subject'of an ongoing remedial investigation
study. That project will gather the necessary information to better
ascertain what is needed to determine the level of cleanup for the
bayou and groundwater contamination at Bayou Bonfouca. Meanwhile. the
hazardous materials causing the shallow groundwater pollution and
posing a threat to the pUblic health. welfare. and the environment
through potential surface water releases'must be mitigated. To this
end. nine source-control alternatives were considered. including a "no
action" alternative.
Initial Screening of Alternatives
According to Section 300.68 (h) of the NCP.three broad criteria should
be used in the initial screening of alternatives:
(1) Cost. For each alternative. the cost of installing or implementing
~remedial action must be considered. including operation and
maintenance costs. An alternative that far exceeds the cost of
other alternatives (i.e.. order of magnitude) evaluated. and that
does not provide substantially greater public health or environmental
benefit should usuall.y be excluded from further consideration.
(2) Effects of the Alternative. The effects of each alternative
should be evaluated 1n two ways: (a) Whether the alternative
itself or its implementation has any adverse environmental
effects; and (b) for source-control remedial actions. whether
the alternative is likely to achieve adequate control of source
material. or for off-site remedial actions. whether the alternative
is likely to effectively mitigate and minimize the threat of
harm to public health. welfare or the environment. If an
alternative has significant adverse effects. it should be excluded
from further consideration. Only those alternatives that
effectively contribute to protection of public health. welfare.
or the environment should be considered further.
(3) ~table Engineering Practices. Alternatives must be feasible
or the location and conditions of the release. applicable to
the problem. and represent a reliable means of addressing the
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. .. - -
8
-
Nine alternatives were screened in terms of the criteria of the NCP, as
summarized in Table 6. The rationale for rejecting or selecting each
alternative for further detailed evaluation follows.
Alternative 1 - No Action: 40 CFR 300.68(h)(2)(ii) sets forth one
criteria for the rejection of a remedial alternative and one criteria
for the acceptance of a remedial alternative. The criteria for the
rejection of an alternative is that adverse effects would be caused by
implementation of the alternative. As documented previously, past
releases of hazardous contaminants into the surface water and groundwater
have occurred and are still occurring. The no action alternative would allow
this to continue.
The continued release of hazardous contaminants demonstrates inadquate
isolation and control of the wastes at the Bayou Bonfouca site. Therefore,
the no action alternative would not meet the criteria for alternatives
under the NCP. Resulting risks to the public health and the environment
caused by the no action alternative would be unacceptable and the no
action alternative is rejected.
The rationale for retaining or rejecting the remaining alternatives is
briefly summarized:
Alternative 2 - Fencing with Run-on and Run-off Control (Construction
of fences and berms around the creosote piles) - Resected
Rationale:
No groundwater protection
Excessive maintenance requirements
~~:~~:~~v~a~d~,~~R~t- t~~m~~~~~tB~~~~~~: ~~~~~i~lR~~~~~~~uction of a RCRA-
Rationale:
Waste isolated from the environment and public
Alternative 4 - Capping with Consolidation (Placement of the creosote piles
into one area and construction of a clay cap over that area.) - Rejected.
. .
Rationale:
Insufficient groundwater protection due to free liquids in waste
Waste not destroyed or isolated
Alternative 5 - On-site Biological Degradation (Construction of a bio-
logical treatment process on the Bayou Bonfouca site) - Rejected
Rationale:
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-
Alternative
1.
No Action
2.
Fencing w/Run-on
Control
*3.
On-site RCRA
Landfill
4.
Cap & Consolidate
5.
Onsite Biological
Degredation
*6.
Onsite
Incineration
7.
Offsite
Incineration
*8.
Offsite Landfill
9.
Offsite
Biological
Degredation
tABLE 6
INITIAL SCREENING FACTORS
Present Worth
Cost
°
200,000
1,000,000
500,000
NA
4,000,000
5,500,000
750,000
NA
Public Health
& Environmental
Effects
Waste migration,
direct contact
Continued ground
water contamin-
ation
Waste migration
direct contact
Continued ground
water contamina-
tion
No significant
effects if liner,
etc. intact
Continued ground
water contamina-
tion
NA
No significant
effects
No significant
effects
No significant
effects if con-
tainment intact
NA
<.
Engineering Practice
Not Accepted
Practice
Not Accepted
Practice
Excessive
Maintenance
Requirements
Accepted and Proven
Practice
Accepted and Provr
Practice
Not Historically
Proven or Accepted
Practice
Accepted and Proven
Practice
Accepted and Proven
Practice
Accepted and Proven
Practice
Not Historically
Proven or Accepted
Practice
* - Retained for Detailed Evaluation
NA - Insufficient Information Available
to Perform Adequate Screening
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9
Alternativ~.6 : On-site Incineration (Use of a mobile incinerator on
the site to burn the. creosote.) - Retained
Rationale:
Waste destroyed
Alternative 7 - Off-site Incineration (Transport of the creosote to
~xist1ng RCRA incineration facilit1es for burning.) - Rejected
Rationale:
Costs significantly greater than all other alternatives
Does not provide advantage over on-site incineration
Alternative 8 - Off-site landfill (Transport of the creosote to existing
RCRA-compliant landfill facility.) - Retained
Rationale:
Low cost alternative
Waste isolated from the environment and public
Alternative 9 - Off-site Biological Degradation (Transport of the creosote
to existing biological treatment facilities) - Rejected
Rationale:
Few existing facilities
Not historically proven for degradation of creosote waste.
Description of Retained Alternative
The three retained alternatives were analyzed (Table 7,8) in detail,
in accordance with the NCP, 40 CFR Part 300.68 (i). Common to all
three alternatives is the disposal of washwater and rainwater. An
estimated 28,000 gallons of ~ater will be used to clean the concrete
pads and a quantity of rainwater will be contained during construction.
I lie washwater and rainwater, the quantity dependent on the length of
1mplementation of each alternative, will be disposed of by deep-well
injection at an approved facility. There are also approximately 500
cubic yards of debris, barrels, pipes, etc., which will be disposed of at
a landfill onsite or offsite, as appropriate. The cost for disposal of
the debris and the water i5 included in each alternative. Following
excavation of the waste areas and cleaning of the concrete slabs,
samples of the soil beneath the concrete and in the excavated areas
will be collected and analyzed to detenmine the level of contaminants
in the 50ils for consideration of subsurface contaminant migration and
the need for additional remedial action. Excavated areas will be
backfilled and compacted with a minimum of two feet of clay, one foot
of sand, and two feet of topsoil. The surface of each area will be
vegetated and graded to promote positive drainage and minimize erosion.
Table 9 summarizes the cost of the retain~d alternatives. A summary of
the full discussion of the three retained alternatives contained in the
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TABLE 7
-
COMPARISON OF PUBLIC HEALTH AND
ENVIRONMENTAL EFFECTS
Alternative
PUBL IC REAL TH
Beneficial Adverse
1 2 1 234
-- ----
ENVIRONMENTAL
Beneficial Adverse
...L 2.....L .! ~ 1 ~
No Action
8 8 . .
8 8 . . . .
. . . . . . . .
.8 8 8 8 8 .
Onsite Landfill
Onsite Incineration
Offsite Landfill
PUBLIC HEALTH EFFECTS
ENVIRONMENTAL EFFECTS
Beneficial
Beneficial
1.
2.
Removal of direct contact hazard
Destruction of wastes
1-
2.
3.
Isolation of wastes
Eliminates migration pathwa'
Destruction of wastes
Adverse
Adverse
1.
2.
Continued direct contact potential
Potential exposure to combustion
air emissions
Site worker exposure during
implementation
Potential for spills during
transport offs1te.
1.
Continued potential for surface
water pollution
Pre-empts alternate land use
Potential for waste migration
Potential for air pollution
during implementation.
3.
2.
3.
4.
4.
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TABLE !3
COMPARISON OF INSTITUTIONAL ISSUES
Alternative
1.
2
INSTITUTIONAL ISSUES
3 4 5
. .
. .
.
,-
.
No Action
Onsite Landfill
.
.
Onsite Incineration
Offsite Landfill
Issues
1.
Precludes beneficial land use.
Requires continued maintenance and monitoring.
Requires compliance with air quality regulations.
Wastes located near residential areas.
Requires deed restrictions on property.
Requires monitoring of RCRA permit compliance.
2.
3.
4.
5.
6.
6
.
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TABLE 9
SUMMARY OF COSTS FOR REMEDIAL ACTION ALTERNATIVES
PRESENT WORTH
Capi ta 1 0 & M Total
Alternative Cost Cost Present Worth
NO ACTION NA NA NA
ONSITE LANDFILL $ 735,000 $207,840 $ 942,840
ONSITE INCINERTION 4,914,180 ° 4,914,180
OFFSITE LANDFILL 903,000 ° 903,000
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10
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RCRA - Compliant On-site Landfill
This alternative entails the construction of an on-site double-lined
landfill that complies with provisions of RCRA. The major components of
the lining system include a 2 foot liner of compacted clay, two synthetic
liners, and a drainage layer of sand containing the leachate collection
and removal piping between each liner. A final cover system consisting
of compacted clay, drainage layer, synthetic membrane, compacted soil,
and topsoil layers will be placed over the landfill. Groundwater
monitoring will be designed to be in compliance with RCRA requirements
for the life of the landfill (i.e., 30 years).
The estimated capital costs of the on-site landfill is $735,000. The
post-closure cost elements for the on-site landfill include groundwater
monitoring,. maintenance, leachate removal and disposal, and site inspection
and security; all at a present worth cost of $207,840. The total
present worth cost is estimated to be $942,840.
Construction of the landfill will be straight forward. No unusual
construction techniques will be required to implement the alternative,
but provisions for siting the landfill in a 100 year floodplain will be
necessary. The possiblility for liner failure does exist due to unfore-
seen reasons, such as burrowing animals and other potential problems.
However, techniques are available to deal with such occurrences.
This alternative will result in some negative public health and
environmental effects resulting mainly from the construction of the
fill. During construction, there will be minor short-term effects on
air quality resulting from vehicle exhaust, particulate emissions and
creosote vapors. On-site workers will be required to maintain
continuous environmental monitoring and use proper personnel protection.
After construction is completed, the wastes will be isolated from the
environment, although not destroyed or rendered harmless.
Adverse environmental impacts due to the implementation of this
alternative are not anticipated.
On-site Incineration
This alternative wil' involve the utilization of a mobile incinerator
to effectively destroy the hazardous organic constituents in the creosote.
wastes. The incinerator system used, rotary kiln or otherwise, will be
expected to fully comply with the technical requirements for incinerators
set by RCRA. Rem~ining ash will be analyzed to determine the presence
of any hazardous waste. Assuming no hazardous waste is present, delisting
procedures will allow the ash to be disposed of in a sanitary landfill.
The estimated capital costs of the on-site incinerator is $4,914,000.
Since the wastes are destroyed, no long-term operation and maintenance
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. .
11
The mobile- incineration of hazardous waste contaminated with creosote is
an advanced treatment technology that is becoming proven. The construct-
ability of the system is more complex than other alternatives, lending
itself to long implementation time. Additionally, comparatively more
engineering expertise during design and implementation is needed to
car~ out the alternative. ~
This alternative has positive long-tenm public health and environmental
effects by destroying the wastes, removing the direct contact hazard,
and eliminating further surface water and groundwater contamination,
Short-tenm effects during the handling and incineration of the creosote
waste will be minimal given proper safety precautions and proper operation
of equipment.
Adverse environmental impacts due to the implementation of this alternative
are not expected.
RCRA Compliant Off-site landfill
This alternative will involve the excavation of 6300 cubic yards of
creosote wastes and creosote contaminated debris which will be transported
off-site by truck to a RCRA-compliant hazardous waste landfill. The
estimated capital cost, based on vendor quotes from existing RCRA facilities,
for this alternative is $903,000. No operation and maintenance costs
exist in this alternative.
Minimal engineering is needed for the implementation of this alternative.
The excavation would be accomplished using backhoes and front-end
loaders. The free liquids within the waste would need to be removed or
chemically fixed prior to transportation and disposal. Since the free
liquids consist mostly of water, a drainage system to separate the
water from the waste could be utilized to reduce the amount of fixation.
By isolating the wastes from the environment, this alternative results
in positive long-tenm pUblic health and environmental effects. This
alternative would entail transportation risks not found in the other
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12
-
COMMUNITY RELATIONS.
The public comment period was from May 31 to June 21, 1985. The public
meeting took place on June 12, 1985, in Slidell, Louisiana. Thirty
people were in attendance, with six..people commenting or asking questions
at the meeting. No written comments were received concerning the
proposed remedies.
tn addition to the public meeting, a briefing for local officials was
neld on June 12, 1985, at the offices of.the City of Slidell. The city
engineer was briefed on the proposed alternatives and the EPA preferred
alternative. No major concerns were voiced by the city engineer about
any of the alternatives.
In the presentation on June 12, 1985, the EPA indicated a preference
for the off-site landfill alternative at a cost of $810,000 (now amended
~ $903,000) as the remedial action. This alternative will consist of
the excavation and removal of the creosote contamination to a RCRA-approved
landfill facility. This alternative was considered acceptable to all
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"
13
-
CONSISTENCY- WITH OTHER ENVIRONMENTAL LAWS
As specified in the.EPA draft policy on compliance with environmental
statutes other than CERCLA, the alternatives were developed to correspond
to one or more of the following categories:
.
1. Alternatives specifying off-site storage, destruction, treatment,
or secure disposal of hazardous substances at a facility approved
under the Resource Conservation and Recovery Act (RCRA). Such a
facility must also be in compliance with all other applicable
EPA standards (i.e., Clean Water Act, Clean Air Act, Toxic
Substances Control Act).
2. Alternatives that attain all applicable or relevant Federal public
health or environmental standards, guidance, ~r advisories.
3. Alternatives that exceed all applicable or relevant Federal public
health and environmental standards, guidance, and advisories.
4. Alternatives that meet the CERCLA goals of preventing or minimizing
present or future migration of hazardous substances and protect
human health and the environment, but do not attain the applicable
or relevant standards. (This category may include an alternative
that closely approaches the levels of protection provided by the
applicable or relevant standards). '
5. No acti on.
As a result of the initial screening, the fOllowing alternatives corres-
ponding to the above categories, except category 4, were retained for
detail ed eval uati on. The al ternatives correspond; ng to category 4,
consolidation with capping and fencing with run-on control, failed to
meet the screening criteria.
Alternative Category
No Action 5
On- si te Landfill 2
On-site Incineration 3
Off-site Landfill 1
In accordance with the May 6, 1985, memorandum "Procedures for Planning
and Implementing Off-site Response Actions," any waste removed from the
Bayou Bonfouca site will be disposed of or treated at RCRA facilities that
are in compliance with all applicable requirements for the facility
type. Additionally, landfill disposal facilities will meet the minimum
technical requirements of the 1984 RCRA amendments. All three of the
alternatives developed for the source-control action at the Bayou
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f
. .
14
-
RECQMMENDED ALTERNATIVE
In accordance with 40 CFR 300.68(j), the lowest cost alternative that
is technologically feasible, reliable, and which effectively mitigates
and minimizes damage to, and provid~s adequate protection of, public
health, welfare, or the environment, has been determined to be excavation
and transportation of the creosote waste material to a fully compliant
RCRA-approved landfill. The cost of this alternative is approximately
$903,000. The off-site landfill alternative will effectively isolate
the waste from the public, eliminating a direct contact hazard, and
will protect the environment by eliminating migration pathways for the
waste material in the creosote piles on the Bayou Bonfouca site.
The on-site landfill alternative and the on-site incineration alternative
do not prove to be cost effective when compared to the off-site landfill
alternative. (See Table 10 for a summary of the comparison of the
oiLernatives). Onsite landfill will cost four percent more and onsite
incineration 540 percent more than the ,off-site landfill alternative.
For these alternatives to be recommended over off-site landfill, an
appropriate increase in protection to the public health and the
environment would have to be achieved. '
The on-site landfill and the off-site landfill options provide equal
long-term protection to the public health and the environm~nt
since both alternatives provide isolation of the waste. Implementation
of the on-site landfill achieves a marginal increase in short-term
protection to the pUblic health and the environment because of the
elimination of the transportation risks inherent in the off-site alter-
native. However, the marginal gain is offset some by the risks associated
with the construction activities needed to build and fill the landfill
and to place the waste. The added long-term operation and maintenance
costs of an on-site landfill do not provide a further increase of protection,
but instead lend to a decrease in the cost effectiveness of an on-site
landfill since the off-site landfill capitol costs include long-term
monitoring performed by the facility operator/owner. The site is not a
good location for a landfi", due to the floodplain and high groundwater
table. The four percent increase in cost for the on-site landfill over
the off-site landfill does not provide for an equivalent increase in
protection to the public health and the environment. Thus the on-site
landfill would not be allowed as the cost effective alternative in
accordance with the National Contingency Plan.
The on-site incineration option provides greater long-term protection
to the public health and the environment by destroying the waste as
opposed to isolating the waste in a landfill. In comparing short-term
protection factors, the elimination of most of the transportation risks
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15
-
of 'incineration of hazardous material in a populated area. Both types
of risk are relatively minimal and can be strictly controlled. Failures
in either transportation or burn efficiency are equally unacceptable.
Weighing these factors, and given the small amount of waste subject to
this particular action, it is more cost effective to isolate the creosote
material in the RCRA-compliant landfill than to destroy the material by
on-site incineration.
In summary, the most cost effective alternative for the source-control
action at the Bayou Bonfouca Superfund site consists of the excavation,
transportation, and disposal of approximately 5000 cubic yards of
creosote waste, 800 cubic yards of contaminated sOi1, and 500 cubic.
yards of contaminated debris at a RCRA-comp1iant landfill facility, and
the transportation and disposal of approximately 242,000 ga110ns of
contaminated water by deep-well injection at an approved RCRA facility.
The estimated cost of the alternative is $903,000 with a construction
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TABLE 10
COMPARISON OF REMEDIAL ALTERNATIVES
Present Worth
Cost (thousands) Publfc Heal th Environnental Technical Pub If c
Alternative Capital Total Considerations Considerations Considerations Connent 0 ther
.
1. No Action NA NA Direct contact Exposures to Periodic emergency No conwnents Requires deed
( not by residents of biota of responses. . restrictions.
retained) carcinogenic, hazardous
volatile con tam i- material.
nants from air
emissions or run-
off. Continued
groundwater
contamination.
2. On-site
Landfill 735 943 Eliminate Wastes isolated. Poor location for Mil dl Y Continued moni-
immediate public 1 andfill. Maximum opposed toring and
heal th risks. on-site construction. maintenance.
Minimizes direct
contact. Minimal
excavation risks.
No transportation
risks. Minimal
hazardous vapor
risks.
3. On-site 4,914 4,914 Sane as 2 but Wastes destroyed. less reliable Mildly Air qualf ty
Incineration added long tenn technology. opposed monitoring.
benefits. longest imple-
mentation time.
4. Off-site
Landfill 903 903 Sane as 2 but Same as 2 Minimum imple- Favored RCM pennit
involves trans- mentation time moni tori ng.
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,
16
-
SCHEDULE
o Source Control Record of Decision (ROD) Signed
o Interagency Agreement for Design Awarded
August 1985
August 1985
o Interagency Agreement for Remedial Action Awarded
o Design Completed
September 1985
November 1986
o Bid Award
J anua ry 1986
February 1986
o Construction Begins
FUTURE ACTIONS
As described previously, the Agency is conducting a remedial investigation
in order to evaluate the need for remedial measures for the groundwater
and bayou contamination. The report on this investigation should be
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~ ,
-
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
Bayou Bonfouca, Louisiana
INTRODUCTION
The responsiveness summary documents for the public record:
- Concerns and issues raised during remedial planning.
- Comment raised during the comment period on the Feasibility Study.
- How EPA considered and responded to these concerns.
CONCERNS RAISED PRIOR TO THE FEASIBILITY STUDY COMMENT PERIOD
In response to an April 1976 media request, the U.S. Coast Guard began
investigating creosote pollution of Bayou Bonfouca. Five area residents
filed reports with the U.S. Coast Guard citing damage to boats fram
contact with oily substances in the bayou. Later in 1976, the local
newspaper reported continuous discharges of creosote-derived oils into
the bayou.
A 1978 fish kill in the bayou near S'idel', Louisiana was attributed to
~~oxia. About this time, there were other complaints concerning creosote
odors, oil slicks on properties adjacent to the bayou, and foul-tasting
seafood from the bayou.
More recent press releases covering the site related to a house fire in
the immediate vicinity and to a 1980 proposal to construct a ship-building
facility on the property. The Bayou Bonfouca Environmental Society was
formed in 1980 and actively opposed the sale of the site to the shipyards
company. Champion Shipyards issued a letter to the public identifying
positive impacts of its proposal. The local Chamber of Commerce sponsored
a public meeting to discuss the issues involved. Local opposition
concerned land use incompatibility as well as the potential for the
stirring up of creosote settled into the bayou bed.
City officials first became concerned about the site when they were
considering purchase of the property for a city park in the early 1980s.
There was local, New Orleans, and Baton Rouge press coverage in 1982
concerning the Superfund National Priorities List. This coverage
1nr.luded discussions of the Bayou Bonfouca site.
An extensive article in the New Orleans Times-Picayune appeared in August
1984, based upon the reporter's review of the EPA Bayou Bonfouca files.
The paper later published a letter from the Regional Administrator
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,
2
-
CONCERNS RAISED DURING THE COMMENT PERIOD AND EPA RESPONSE
The public comment period was from May 31 to June 21, 1985. The
public meeting took place on June 12,1985, in Slidell, Louisiana.
Thirty people were in attendance wi~h six people commenting or asking
questions at the meeting. No written comments were received concerning
the proposed remedies.
In addition to the public meeting, a briefing for local officials was
held on June 12, 1985, at the offices of the City of Slidell. The city
engineer was briefed on the proposed alternatives and the EPA preferred
alternative. No major concerns were voiced by the city engineer about
any of the alternatives.
In the presentation on June 12, 1985, the EPA indicated a preference
for the off-site landfill alternative at a cost of $810,000 (now amended
to $903,000) as the remedial action. This alternative will consist of
the excavation and removal of the creosote contamination to a RCRA-approved
landfill facility. This alternative was considered acceptable to all
parties.
COMMUNITY CONCERNS
The following issues were raised at the public meeting. The EPA response
follows the comment.
Comment *1
Richard Van Sandt, Slidell City Councilman, asked for the status of the
bayou in EPA's program and expressed concern that the site's ranking on
the NPL (517) would jeopardize funding of any work. Mr. Van Sandt
indicated support for the preferred alternative.
EPA Response
The study of the bayou will be completed this Summer with a Feasibility
Study completed this Fall. the EPA will hold another public meeting
upon completion of the Feasibility Study. The sfte's ranking will have
no effect on the availability of funding. At this time, funds are
available for the proposed cleanup.
Comment *2
Annand Pichon, fonner St. Tammany Parish councilman, wondered if it
would be possible to consider on-site incineration, with the incinerator
remaining in St. Tammany Parish to handle sludge wastes from wastewater
treatment plants and domestic trash. The incinerator, upon completion
of burning the creosote, could be sold to a private company for operation
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.0
-.. -.------ -. '_0"--- ---.----'''-'- -.----.. 40__--_.--'
. -.'" - - ~....
,
.,
I .
3
-
EPA Response
Two problem areas exist with this proposal. First, technical considerations
preclude the use of mobile incinerators built to handle hazardous waste
from being used to burn domestic wa5te. The mobile incinerators that
~urn hazardous waste are built for low flow rates at temperatures higher
than is practical for domestic use. Second, legally the cost of
an alternative for use at a Superfund site must be justifiable for that
site alone. The cost of this proposal to the Agency would be at least
$35 million exceeding the cost effectiveness requirement of CERCLA.
C01lll\ent *3
Ben Benson, Peterson, Inc., inquired as to the length of cleanup,
destination of the waste, and determination of uhow clean is clean.-
He also asked if samples would be taken after excavation of the creosote,
dnd if any air emissions are expected.
[FA Response
The recommended alternative is expected to take two months once the
cleanup action begins. The waste will be taken to a fully compliant
RCRA facility that has had no significant (Class 1) violations in its
last inspection, which must have occurred less than six months prior to
disposal of the waste. The cleanup action is presently set to remove
the creosote sludge plus six inches of native soils. Additional samples
of the soil will be taken prior to finishing the cleanup to determine
the effectiveness of the removal. Significant air emissions are not
expected due to the excavation. based upon EPA tests performed in the
Sumner of 1984.
COll111ent #4
George Stewart. Slidell resident. asked if the creosote material slated for
removal could be recycled.
~A Response
The quality and quantity of the waste material is such that a recycling
scheme is not practical.
Conwnent 15
John Case. Slidell resident. requested an opinion from George Buynoski
of the Centers for Disease Control (CDC) about the effect of the site
on the public health of the local residents.
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4
EPA (CDC) Response
It is the opinion of the CDC that there is no acute public health
problem due to the site. Receptor pathways are not contaminated, that
is, the drinking water is not contaminated nor are air emissions
occurring. The concern from a health perspective is direct contact
with the waste. While the creosote would not constitute an immediate
threat to anyone, it is advisable from a public health viewpoint to
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