United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R06-87/019
March 1987
3 EPA
Superfund
Record of Decision
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n
.)
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site: Bayou Bonfouca, Slidell, Louisiana
. DOCUMENTS REVIEWED
I have reviewed the following documents describing the analysis of the
cost-effectiveness of the remedial alternatives for the Bayou Bonfouca
site.
- Site Investigation, Bayou Bonfouca, April 1986.
- Feasibility Stu~, Bayou Bonfouca, June 1986.
- Health Assessment, Agency for Toxic Substances and Disease Registry,
September 1986. -.-> .
- Technical Assistance for Response to Public Comment, September 1986.
- First Technical Assistance Memorandum for Development of Record of
D~cision, January 1987.
- Second Technical Assistance Memorandum for DeveJopment of Record of
Decision, Black and Veatch, January 1987. '
- Report of Public Hearing, July 1986.
(
- Report of Public Hearing, February 1987.
DESCRIPTION OF SELECTED REMEDY
- Excavation and onsite incineration of creosote waste piles and
heavily contaminated bayou sediment
- RCRA cap
- Pump and treat groundwater
DECLARATION
Consistent with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA) as amended by Superfuod Amendments
Reauthorization Act of 1986 and the National Contingency Plan (40 CFR
Part 300), I have determined that the selected alternative for the
Bayou Bonfouca site is cost-effective and provides adequate protection
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2
continued effectiveness of the remedy. These activities will be
considered part of the approved action and eligible for Trust Fund
monies for a period of one year.
I have also made the determination that the action being taken is
appropriate when balanced against the availability of the Trust Fund
monies for use at other sites.
r3f4-ld... J~ /117
~~&~~~-
Robert. Layton. t P. .
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TECHNICAL REPORT DATA
(Please ,ead Instructions on the revene belOTe com"leting)
1. REPORT NO. I~' 3. RECIPIENT'S ACCESSION NO.
8PA/ROD/R06-87/019
.. TITLE ANO SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION March 31, 1986
Bayou Banfouca, LA 6. PERFORMING ORGANIZATION CODE
Second Remedial Action
7. AUTHOR'S) 8. PERFORMING ORGANIZATION REPORT NO.
St. PERFORMING ORGANIZATION NAME ANO ADDRESS 10. PROGRAM EL.EMENT NO.
". 1;0NTfIIA<;T/tifliAN T 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. 1.. SPONSORING AGENCY CODE
Washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Bayou Bonfouca site is an abandoned creosote works facility that was operational
from 1892 to 1970. It is located north of Lake Pontchartrain in Slidell, Louisiana in a
lOa-year flood plain, and is characterized by standing water and saturated surface
soil. The creosote plant treated pilings for use in railway construction. Over the
years, the plant operated under the ownership of various creosote companies. Present
property ownership is with the Braseman Corporation. Numerous creosote releases
occurred during the years of operation. Since 1976, numerous studies were done to
examine the extent of the problems orginating from the Bayou site and in December 1982,
the site was placed on the NPL. The primary contaminants of concern are polynuclear
aromatic hydrocarbons (PABs) including: benzo(a) pyrene, benzo(a)anthracene,
benzo(b)flouranthene, benzo(k)fluoranthene, indeno(I,2,3-cd) pyrene, and chrysene. In
August 1985, excavation and offsite landfilling on creosote waste piles was addressed in
a source control operable unit ROD. The determination of the extent of soil
contamination was the focus of this second operable unit. Currently, ground water and
surface water are the primary natural resources affected. Additionally, 20,000 yds3
of soils and 46,500 yds3 of sediments lining the bayou, a creek, and a drainage
channel are contaminated.
(See Attached Sheet)
17. - KEY WOROS ANO DOCUMENT ANAL YSIS
I. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Bayou Banfouca, LA .
Contaminated Media: soil, SW, GW, sediments
Key contaminants: PABs
18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (TI." Report, 21. NO. OF PAGES
None 69
I 20. SECURITY CLASS (Tllis pagel 22. PRICE
None
!'A 'orlll 2220-1 (R... "-77)
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"
"
EPA/ROD/R06-87/0l9
Bayou Banfouca, LA
16.
ABSTRACT (continued)
The selected remedial action includes: incineration in a mobile unit of
creosote accumulations (5000 yds3) present on the surface; incineration of
contaminated sediment (46,500 yds3) from the bayou, creek and channel
bottoms; isolation followed by drainage and dredging of one half of the
bayou; excavation of sediment to about 5 feet or to a depth that will ensure
mitigation of the source of ground water contamination by creosote; routing
of the flow through the clean area upon completion of excavation and then,
drainage and dredging of the opposite side of the bayou; dewatering of bayou
sediments prior to offsite transportation; onsite treatment and discharge to
the bayou of water drainage from the dewatered side of the bayou, alone with
drainage associated with the dewatering activities; capping of contaminated
soil (20,000 yds3 34 acres) with a RCRA cap: and remediation of ground
water through a pump-treat reinjection process. The estimated capital cost
for the remedial action is $59,594,534 with annual O&M costs estimated to be
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site: Ba.you ~onf~ca, Slidell, Louisiana
DOCUMENTS REVIEWED
'--
1 have reviewed the following documents describing the analysis 01 the
cost-effectiveness 01 the remedial alternatives for the Bi10u Bon10uca
site.
- Site Investigation, Bayou Bonfouca, April 1986.
- Feasibility Stu~, Bayou Bonfouca, June 1986.
- Health Assessment, Agency for Toxic Substances and Disease Registry,
September 1986.
- Technical Assistance for Response to Public Comment, Sept88ber 1986.
- First Technical Assistance Memorandum for Development 01 Record 01
Dec1510n, January 1987.
.- Second Technical Assistance Memorandum for Development of Record of
Decision, Black and Veatch, January 1987.
- Report of Public Hearing, July 1986.
- Report of Public Hearing, February 1987.
DESCRIPTION OF SELECTED REMEDY
- Excavation and onsite incineration 01 creosote waste piles and
heavily contaminated bayou sediment
- RCRA cap
- Pump and treat groundwater
DECLARATION
Consistent with the Comprehensive Environmental Response, Compensation,
and Liability Act 01 1980 (CERCLA) as amended by Superfund Amendments
Reauthorization Act of 1986 and the National Contingency Plan (40 CFR
Part 300), I have determined tnat the selected alternative for the
Bayou Bonfouca site is cost-effect ive and provides adequate protect fon
of public health, welfare, and the environment. The State of Louisiana
SYMBOL
~
.... ....e.............. ................. ....-............. ......'....."".
................. .................
.................. .........".......
DATE
OFFICIAL FILE COpy
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2
has been consulted and agrees with the approved remedy.
will require future operation and maintenance activities
continued effectiveness of the remedy. These activities
part of the approved action, and eligible for Trust Fund
period up to one year.
The action
to ensure the
are considered
monies for a
The remedial plan will also include long-term groundwater pumping and
treatment. The costs associated with these activities are eligible for
Trust Fund for a period of up to ten years. I have also determined
that the action being taken is appropriate when ba1anced against the
availability of Trust Fund monies for use at other site.
DATE
Robert E. Layton Jr., P.E.
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. .
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
BAYOU BONFOUCA
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EXEaJTIVE SlMMARY
SITE DESCRIPl'ICN
'!be Bayou Bonfouca Superfund Site is an abandcr1ed creosote 'NOtXs facility
that was cperational fran 1892 to 1970. ~d-shaped accurrulatioos of
creosote are present an the surface and asphaltic material oovers nuch
.of the surface. Polynuclear araratic hydrocarbons (PAH~s) fran the
creosote oarpounds have CX'I'1taminated soil, bayou, creek and channel
bottan sed:inents, surface water, and gra.JncMter. GramcMter is
caltaninated in a surficial aquifer and in a shallcw artesian aquifer.
PRJPa;E[) REHDIATICN
Prc::posed renediatian at the Bayou Bonfouca site includes incineration
in a ncbile unit of creosote accunulatioos ( 5000 yas3) present 00 the
surface and incineratioo of contaminated sediment fran the ba}'OU, creek,
and channel OOttarB ( 46,500 yds3). One half of the bayou will be
isolated, it will ~en be drained and dredged. Sediment will be excavated
to about 5 feet or to a depth that. will ensure that the source of
grQmcWater contamination by creosote is mitigated and the threat to
aquatic biota is minimized. Upcn carpletioo of excavation, the flew will
be routed thrcugh the clean area and the Cip!X)8ite.side of .the bayou will
be drained and dredged. '!be ba}'OU sediments will be dewatered prior to
offsite transportation. Water draining into the &!watered side of the
bayol, along with the drainage associated with the dewatering activities
will be treated by an oosite treatment plant. ana d:i.sc:harged to the
ba}'OU. OXltaminated soil (tlOO ppn PAH) will be ~ with a RCRA cap
(20,000 yas3: 34 acres). Gra.1l'1d4t.er will be ~t.ed through a
p,JIp-treatreinjectian process. 'the I41i.siana Department of EnviraJDental
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SUMMARY OF REMEDIAL
ALTERNATIVE SELECTION
BAYOU BONFOUCA
SLIDELL. LOUISIANA
Table of Contents
Enforcement .................................................
Alternatives Evaluation .....................................
Objectives
Groundwater Alternatives
Source Control Alternat ;-ves
Consistency with Other Environmental Laws ...................
Recommended Alternative .....................................
Operation and Maintenance ...................................
Planned Schedule ............................................
Future Actions ..............................................
Executive Summary........................................... i
Site Location and Description ............................... 1
Site History ................................................ 6
Current Status .............................................. 7
Stratigraphic Setting ....................................... 7
Surficial Creosote Waste Deposits ........................... 8
Groundwater Investigation ................................... 9
Surficial Aquifer ...................................... 10
Shallow Artesian Aquifer ............................... 10
Deep Artesian Aquifer .................................. 11
Existing Area Wells .................................... 13
Surface Water ............................................... 13
Sediment [[[ 13
Soils [[[ 14
14
15
............................................. 15.
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List of Figures
1. Site location map showing areal extent of contamination ........... 2
2. Site map showing sample locations, locations for cross-section A-AI,
B-B'....................................'....~...................... 3
.3. Stratigraphic cross-section A-AI................................... 4
. .
4. North-south hydrologic cross-section B-BI.......................... 5
5. Hydrogeologic relationships - Bayou Bonfouca ...................... 12
List of Tables
Table 1, Description:
Volume of Contaminated Sediments .............. 9
Table 2, Summary of Remedial Alternatives............................. 18
Table 3, Summary of Applicable Standards and Regulations.............. 25
Appendices
Appendix A - Community Relations
................................ .'.... 31
Appendix B - Summary of Remedial
Alternatives......................... 38
. .
Appendix C - Cost estimates summaries................................. 40
Appendix D - ATSDR Health Assessment, September 11, 1986, Creosote
.Contamination........................................... 49
Appendix E - ATSDR Health Assessment of RemeQy........................ 50
Appendix F - Letter of concurrence from Louisiana Department of
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SUMMARY OF RE1-1EDIAL ALTERNATIVE SELECrION
Bayoo Bonfouca
Slidell, Louisiana
SITE WCATION AND DESCRIPTION
''n'\e Bayou Bonfooca is located aboot 7 miles north of Lake Pontchartrain
in Slidell, Iarisiana. It is at the soothwest corner of West Hall
Avenue and Bayou Lane (Figure 1). 'n'\e site has an area of aboot 55
acres. Land use east of the site is primarily cxmnercial: to the north
it is heavily ~. To the scut:1Ywest., across the Bayou Bonfooca,
is a residential subdivision. About 750 residents live within ooe mile
of the site.
'!be site is an abandoned and disnantled creosote woJ:ks facility that
lies 00 a flat, mostly overgrONl'l parcel and is'within the designated
lOO-year flood plain of the bayou. 'n'\e site is bomded on the east by
a drainage channel and a'1 the west by Western Creek. 'n'\e area is
characterized by standing water and saturated surface soil. 'n'\e
ca1taminants of OCX1cem at the site are potentially carcinogenic
polynuclear araratic hydroca.rbons (PAHos) that are U,A1.1_1 in creosote
,"""",,~ds: ~(a)pyrene, benzo(a) anthracene, benzo(b)fluoranthene,
benzo(k)fluorantnene, indeno(1,2,3-o:i)pyrene, ar„i du:ysene. Figure 1
depicts the extent '0£ contamination. Figure 2 sh~ sanple locations,
the locations for stratiqraphic cross-sectioo A-A ° and hydrcgeologic
croes-section aOao are the same am are also shCX1 in Figure 2.
Morphologically the bayou is asyrmet.rically U-shaped in cross sectioo.
Stratigraphy of the site is shONl'l in Figure 3. 'n'\e bayou has incised
thra.1gh a thin layer of surficial silt and man-nade fill into a fractured,
but a:i1esi ve clay layer. 'n'\is 'Clay layer has a RBXinun thic1cness of 25
ft. and forms the sides and 1:xJttan of the bayou. Beneath the deepest
part of the bayou, this clay layer is CX11y 3 feet thick. 'n'\ere are be
significant clay layers present in the stratigraprlc interval of interest,
an upper cchesive layer and a lOller cohesive layer. 'n'\e bayou has
dissected the upper cohesive layer. 'n'\e upper ochesive layer is the
upper bamding surface of sam am silt that grades d~ to an interval
of silty and sandy clay. 'n'\ese sand, silt am clay intervals are
called the granular layer (appx. 3 feet in thickness) am the interbedded
granular and oohesive layer (aboot 6 feet thidc), respectively. 'n'\e
lOller bamding surface of this interval is the lOller oohesive clay.
'n'\e lGller oohesive layer is alxut 20 feet thick and is W1derlain by a
sand unit that was not fully penetrated.
'n'\ree distinct water-bearing zones are identified at the Bayou Bonfooca
site: the surficial aquifer, the shallOii artesian aquifer, am the deep
artesian aquifer. The aquifer systan is depicted in Figure 4. 'n'\e
surficial aquifer (+2 to -8 MSL) is located within the upper oc:hesive
layer and extends upward into the surficial fill and silt layers. The
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LEGEND
CONTAMINATED SOIL
CONTAMINATED SEDIMENT
.:.:::
- - SITE IOUNDA"Y
Figure 1
SITE MAP;
CeNT AMINATED SOILS
AND SEDIMENTS
LIGIND
~::::::::::~ CONTAMINATED a"OUND WAn..
figure 1 A
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6
granular layer and the interbedded granular and cohesive layer; it is
confined above and below by the upper and lower cohesive layers. The
lower cohesive layer forms the upper confining layer of the deep artesian
aquifer (-40 to ?MSL); this aquifer is located within the lower granular
layer. The principal aquifer for the 26,000 residents of Slidell is
the Pontchatoula, at 1500 feet (-1490 MSL) below the ground surface.
The primary natural resources that are adversely affected by the Bayou
. Bonfouca PAH contaminants are groundwater and surface w~ter. Creosote
also contaminated soil and sediments at the site surface (Figures 1, 4)
and in the subsurface. PAH migration probably occurred through fractures
observed in the upper cohesive layer. The highest PAH"concentrations
are found on the ground surface in the areas of the creosote waste
deposits. These deposits constitute about 5000 yds3 of waste. Conta-
minated soil near the surface shows a rapid decrease in concentration,
from 15,680 ppm at the surface to 1 ppm within 9 feet 3f the surface.
Significantly contaminated soils form about 20,000 yds of material.
In the surficial aquifer, soil and groundwater are contaminated. No
contamination of near surface soil deposits was found offsite. Conta-
mination was detected in soil at only one location below 10 feet. The
soil was otherwise uncontaminated until the shallow artesian aquifer
was encountered; soil and groundwater are contaminated in this aquifer.
Contamination is also present in the sediments lining the bayou, the
Western Creek, and eastern drainage channel. These sediments form
about 46,500 yds3 .of contaminated material.
SITE HISTORY
The earliest records of the Bayou Bonfouca site date back to 1892. 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. Present property ownership rests 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. At the time, methods for dredging the Bayou
Bonfouca were felt to be environmentally unsafe 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
t~ the site. The surface contamination was the subject of the Focused
Feasibility Study completed in May 1985. The Phase I (Source Control)
Record of Decision, which specified excavation and off-site landfilling
of creosote waste pi'les, was signed August 15, 1985. The remedial
design (RD) and remeQial action (RA) activities associated with this
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7
A &1pplemental Phase II Rerneaial Investigation was performed in March
1986 to detennine the extent of soil ccntaminaticn beyond that of the
Phase I investigation. Final Phase II Remedial Investigatioo and
Supplemental Rerredial Investigation Reports were received in April
1986. 'the Phase II Feasibility Study was carpleted in June 1986.
aJRREN1' SITE STMUS
.In July 1986, a public meeting was held in ~ch ci~ requested a 3
DD1th extensial of the public cc:mtent period to end October 31, 1986.
During this tjme the Superfund Amendments and Reauthorizatioo Act was
signed and the prGpOSed selected remedy for Bayou ED1fouca did not fully
CXIIply with the provisions of the Act. '!he new law sets stricter
clean-up standards ar.d has a stra1g preference for pexmment teChnologies
that either treat or destroy wastes.
Since 1976, n1.J'RerOUS st\Xiies have been \mdertaken to examine the extent
of the problE118 originating fran the Ba}Q1 Bcmfouca site. During the
rElJlerlial investigations (Phase I and II), surface and subsurface
exploratioo encatpaSsed data fran surface water, ground-water naUtoring
wells and their borings, hand-augered borings, a test pit, and bathymetric
and geophysical surveys (Figure 3). '!hese data were used to evaluate
sectiJtlmts at and beneath the surface and the h}'drogeologic ccnditioos
at the site. SUrface water, g~ter and sectiment scmples were
chemi.cally evaluated to detezmine the extent of Oontamination.
'lhese studies indicate four areas .of major creosote Oontaminatioo,
generally in the south half of the site area. 'the greatest voluae of
creoeot.e is at the bottan of the Ba}Q1 Bonfcuca. 'lhia deposit CD1tains
an estinated 46,500 cubic yards of creosote extending 1400 feet downstream
fran the site. '!hic1cness of the deposits ranges fran 1 foot to 3 feet.
'lhe sec:a1d area of ccncern is the creek and drainage path ~ch border
the site. '!he creek bottan and creek floodplain ala1g the western side
of the site oontain approximately 1600 cubic yards of creosote a:I1t.ami.nated
s~il"ent ~le the drainage ditch 00 the eastern partioo of the site
ocntains approximately 400 cubic yards of creosote a:I1t.ami.nated sediments.
'!he third area of identified oontaminatioo includes the eight locatioos
of JcnOlNn on-site creosote waste deposit.s. Approx:inately 5000 cubic
yards of creosote wastes are contained in these deposits. '!he fourth
area of creoeot.e oontaminaticn is in the upper grQma-ater ZCI1e8 beneath
the sit.e.
Prior to the EPA remedial investigatioo of 1984, no gramd-water
ocnt.aminaticn at.triblted to the site had been. r~t.ecl, and l.imi.ted
hydrogeologic site characterizatioo had been perfcmDed. '!he results
and findings of the EPA investigatioo are dis018Sed in the folladng
pages. '!hese findings are grouped ~ ocnt.aminated media.
STATIGRAPHIC ~t;Tl'!N3
'the rraxirrun depth of exPloration at. the Bayou Bonfouca site was 73
feet. Seven sectirnentary layers were described, consisting of sand,
silt, and clay layers, sare of ~ch are interbedded. Included
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8
Figure 3 is a sc.'I1E1tBtic representation of the stratigraphy at the site.
At the surface, the layer of man-made fill is surramded as well as
underlain by silt. '!he fill ranges in thida1ess fran 0.3 to 10 feet
and is foJ:rned by cinders, bride, 'NOOd, sand, silty clay, and shells.
'!he silt. layer contains ab.mdant. clay and sane sand and ranges in
thidcness £ran 0.5 to 3 feet. '!he surficial aquifer, locat.ed primarily
in the tmderlying cohesive silt.y clay layer, extends upward into the
surficial material.
'n'ie upper cohesive layer is a fractured, silt.y clay that contains
traces of sand. '!he upper reaches of this layer £Om the mjorit.y of
the surficial aquifer b.1t the l.a.Ier reaches f\mctioo as the uppemI08t
confining layer of the shallew artesian aquifer. '!he upper cohesive
layer ranges in thidcness fran 3.0 feet under the deepest. part of the
ba}Q1 to 24.5 feet. at. the sides of the bayou. ~ and closed fractures
that 'NIBre observed in the upper confining layer dJring drilling increase
the peJ:Ireability of this layer, ncre app%q)rlately described as an
aquitard. Laborat:ory t.ests reveal that the ~lity of this layer
ranges £ran 3.4 x 10-8 to 2.8 x 10-9 centimeters per secxnd. Because
of the presence of fractures, which generally increase peJ:Ireability,
this la1:Jorat:ory estimate is probably lew. La}:)oratory analyses are
quite localized and cannot. be expected to accomt for a ltDre regiaml
phenanena, such as fractures. Bathymetric and geoptysical surveys shew
that the upper cohesive layer is CXI'1t.incus acxoss the site.
- .
'!he upper granular layer is CCIIpOsed of sand and overlies the interbedded
granular and cohesive layer, a za18 -of sand and clay. 'lhese units are
about 8 feet. thide and are confined above and ~ by the upper and
lower cohesive layers. 'lhaSe layers foxm the shallew artesian aquifer
and appear to be continous across the site.
'lbe lower cohesive layer, a zcne of clay and silty clay, ranges in
thidcness fran 12.5 feet to 29.0 feet.. It also acts as the upper
confining layer for the deepest. unit explored in this study, the lower
granular layer.
Thin lenses of sand and silt are present in the upper parts of the
lcwer granular unit and grade oot with depth. '!he layer is contincus
acxoss the site and no fractures 'Nere observed. Results of laboratory
pemeaDility analyses ir„ti.cate that pe~lity l'mJes £ran 3.8 x 10::.s
to 2.7 x 10-7 centimeters per seo:md. '!he lcwer granular layer is OOO\.;)Sed
of sand8t:a1e, ncme of the 'NIBIls fully penetrated this layer. '!his
layer ftmaI the deep artesian aquifer.
SURFICIAL ~ WASTE DEPCSITS
surficial concentrations of waste creosote and debris have aCXUlLll.ated
in eicj1t areas on the site. O::ntamination fran the freshly treated
lmaber that was stored at the site. Figure 1 shews the locatioo of the
cont.aminated areas on the sit.e. 'lhe Ptysical d1aracteristics, dimensions,
and vohrnes of the eight areas are s\.ll1tBrized in Table 1, their vol\m! is
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9
'these deposits are up to 2 feet in height and have visually contaminated
the underlying. soils to as ItUch as 1 foot belcw the surface. 'the waste
deposits ccntain about 10% total PAa (polyaranatic hydrocarbons) I as
shGm by analytical results and range in ccncentratial fran not detected
to 120,000 ppn, no dioxin was detected in dioxin analyses (2,3, 7, 8-'I'a)D) .
In general, the CCI1taminated areas have a surface layer of bladt,
asphaltic rraterial. Standing water partially cxwers ncst of the creosote
ca1CentratialS and boreholes ~1"Ullly filled with water during excavatial,
. indicating ~turated surface soil.
TABLE 1
DESCRIPl'ICN AND VCLtJo1E OF a:Nl'AMINATED AREAS
AREA
VCI1JME (c.Y) *
1
4,250
DESCRIPI'ICN
Approximately 1200 feet2 between 2 CCZ1crete
slabs is covered by narshy areas, standing
water and debris. Visually ocntaminated
soils to 91t belcw surface.
2
70
COvered by surface water. . Visually
contaminated soils to 2 It, leaching to 6.5 It
belG17 surface..
3 120
4 100
5 120
6 185
7 125
Surface water ~B SOt of area. Visually
oattaminated to 3" belcw surface.
o:ntains numd of solidified creosote and
debris approximately 28 high.
SOils visually ccntaminated to clay at 11.6 It
belcw surface.
Hard, asphltic surface, exntaminated to 6.6 It
belcw surface.
~ and narshy area, adjacent to
exntcninated stream. o:mtami.natial to 6 It
in~, 18 near stream.
18
75
Surficial ccntaminatial to 2".
* Volune estJmate inclOOes creosote III!Lterial, soi18 belcw visual
contamination, and debris.
~ INVESTIGATICN
'l\oJenty ground-water rrcni.toring wells were installed at the site during
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10
and to evaluate gromd water contamination. Weil sites and sanpling
locatioos for Phase I and II are shaNn in Figure 2. The 'Nells 'Nere
installed either separately or in nests, each nest consisting of ~
to three 'Nells. Each individual 'Nell within a nest narltors a specific
gramdwater zone.
Water level readings in the ncni toring wells am ohservatiCX1S during
drilling indicate that there are three discrete gcJUI1d-water aquifers
. (Figure 4). These are identified as: 1) the surficial aquifer (+2
M;L): 2) the shall~ artesian aquifer (-11 to -27 M;L); "arm 3) the
deep artesian aquifer (-40 to ?). The shallai am deep artesian BqUifers
~ classified as such because the gramd water is under sufficient
pressure to rise akIove the base of the upper ocnfining layer.
*ter level readings obtained througha.tt the investigatiaw indicate
that the shall~ and deep artesian aquifers are discrete aquifers and
not. directly oamected h~ulically. If the aquifers ~ ccnnected,
„rograpus for a given point in tJme sbould shew the .... pot.entianet.ric
surface. 'lbe potentianetric surface elevatiaw of the individual -.lls
wi thin a nest at the Ba:z'OU Bonfouca site were not. the same, therefore
the aquifers are not. directly oamected.
. .
Field observation of soil sanples 00tained during drilling revealed the
existence of <:pen and closed fractures in the upper cchesive layer. If
intercc:.rmected, these fractures CD1ld represent ocna.tits £or cx:ntaminant
migratial £ran the surficial aquifer to the shall~ artesian aquifer.
The existence of these fractures does not. necessitate a direct CXI'U1eCtial
between the tw:) aquifers, however, their existence creates the potential
£or ccntaainant migration.
Surficial AQuifer
The surficial aquifer is located in the ~i~ upper cx:hesive layer
am the in fill and silt layers (Figures 3 and 4). Potent.iaaetric
ccatour DII!I.p8 of the surficial aquifer indicate that the ground-water
flow gradient of this aquifer is 1 x 10-2 feet per foot to the east and
scuth.
The surficial aquifer is locally cxmt.ami.nated with organic ocnpounds.
'!he total PAH (polyaratBtic h~) cxncent.rati.cm identified in
surficial gra.md,.rater are sham in Figure 4. Results of the organic
chemlcal analyses sh~ that PAR ccntaminatia'l ranges £ran ND to 112 ppn.
The surficial aquifer is also ca1t.ami.nated with inorganic ~.'loQUI'lds.
Prina~ drinking \1IIIater standards for arsenic, buian, OBdmi.an, chraai.an,
lead and seleni\.ID are exceeded and seoondaxy drinking water standards
for
-------
11
confined above ~ the upper cohesive layer and belew ~ the lONer
cci1esive layer. Potentianetric exnto..1r naps of this aquifer shew that
the gro.mdwater flew gradient is 1 x 10-3 feet per foot and generally
to the soot.hwest. .
'!he shallcw artesian aquifer is present. beneath. the bayou. 'l11e presence
of fract.ures in the upper ccnfining layer creat.es the potential for
fluid migratioo between the bayou and the shallOl7 artesian aquifer.
. Migratial nay occur if a head differential (a difference. bebieen the
surface water elevation of the bayou and the potent.ianetric surface of
the shallOl7 artesian aquifer) is created betAeen the bayou and the.
shallOl7 artesian aquifer. Migratial 'oIIiOUld occur £ran that water Ba.1rce
with a greater head to tnat of a lesser head. Based upon the elevatial
data obtained, the direct.ial of potential migratial nay altemate
bet\J8en surface water fladng £ran the Bayou into the shaJ.l0lil artesian
aquifer and ~ter flodDJ fran the ~'l '011 artesian aquifer into
the Bayou. Although the Bayou elevatial fluctuates with tidal effects,
there is no apparent. short-t.am di.rect.ia1 relat.ia18hip between the
Bayou surface water elevatialB and the potentiaaetric surface of the
shallOl7 artesian aquifer (Figure 5).
'Ihe shallOlil artesian aquifer is locally cxnt.aminat.ed with organic
~~ds. '!be PAH (polynuclear arazatic~) Ca1CentratialB
identified in the shallOlil artesian graJr1(M.ter are shown in Fi9.1re 4.
Visually, water £ran the shallcw artesian aquifer is dal1c brown and
~ to be oily. Gramd.18ter sarrples taken £ran 20 feet and 27 feet
were deScribed as having an oily sheen. .
'l!1e results of the inorganic c:hemlcal analyses £ran the shaJ.l0lil artesian
aquifer shew that. iron and nanganese exceed the secx:n:1axy c:lrin1ciD;
water standards. BackgraJnd levels for these elements are high, ho.leYer,
and are not exnsidered to be an ilxU.catial of CXI'1tami.natial.
Deep Artesian AQuifer
'!he deep artesian aquifer is aJxut. 50 feet (-40 MSL) belOlil the surface.
Its upper cxnfining surface is the l~ cohesive layer (Figures 3 and
4) . PotentiaDet.ri.c exnto..1r naps of the deep artesian aquifer indicate
that the gramdleter flOi gradient of this aquifer varied £ran 1 x
10-4 to 6 x 104 feet per foot ci1ring the investigatials. '!be permeability
of this aquifer is approximately 2 x 10-2 centJmet.ers per seocnd as
det.emin8i by laboratozy tests.
'!he deep artesian aquifer is not OCX1t.aminated with PAR- s, as shewn
by c:hemlcal analyses. '!be seccI1dazy c:lrin1ciD; water standards for i.ra1
and nanganese are exceeded in the deep aquifer, as they are in the
shallOlil aquifer. H~r, the high levels for i.ra1 and nanganese are
ubiquit.aUJ to the area and are not exnsidered to be an indicatial of
-------
r~-
UPPE"
COHESIVE
LAYER
==
-
...,
UPPER
GRANULAR
LAYE"
INTERBEDDEO
GRANULA"
AND COHE8IV.
,-AYER
w.&.IUI
-
=:
DII,£CTlOII II' aIIIT--T III COIITAMIIlAT£D
WAT[II "_TIOII
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I. UACIIATI C81AfU .. Nl.Clfna,... - ---C8 .,.
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'hI1IO". C8I08OTI 011 80"0. .. ......
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UlfCJIITAMIIIAT£D WU£II
BAYOU BONFOUCA SITE
SLIDELL, LOUISIANA
SCHEMATIC CONTAMINANT SOURCE
AND MIGRATION PATHS
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13
Existing Area Wells
Seven existing water wells were sanpled during the remedial investigations.
'!he wells were between 1,000-2,300 feet in depth with the excepticn of
one lOO-feet well.
The organic chsnical analyses indicated that these wells were not
oontaminated with site-related catpOOl'1ds. '!he prinBry drinking water
- . standard for cadmi1.Jn is exceeded and the secondary drinking water
standards for iron, nanganese, and zinc are exceeded. h::cording to the
Louisiana Department of Envirormmtal Ouality (LDm), g~ter
quality is generally poor in this area of the State with respect to
organics am sulfides.
~ WATER
surface water sanples were taken fran the bayou during the Phase II
rEllled.ial investigation to detexmine if the waters are contaminated.
In order to deteIrnine the effect of sediment turbidity on resuspension
of oontaminants, surface water sanples were taken before and after
disturbing the bayou sediments. Althoogh an oily sheen was observed 00
the water surface, the analytical results did not indicate that the
Bayou water is contaminated b:i creosote constituents. 'this is probably
dle to a phase separation of the sediments and PAS- s £ran the surface
water prior to their analysis, foll~ by analysis of only the water
phase of each sanple.
SEDIMENl'
Bath}metric and geophysical surveys were undertaken to delineate the
ba}'OU IrD~ology am sediment characteristics. 'lbese surveys were also
used to deteIrni.ne sanple locatialS for axe reccvery and chemical
analyses. '!he bathyrretric survey sharns that the Bayou is asyrmetrically
U-shaped in cross-section. It is a1x:ut 10 feet deep in the center of
the ba}'OU, and has a maxinun depth of 11 feet. 'the upper cohesive layer,
a silty clay layer, is a1::xJut 3 feet thic:X beneath the bayou, as sham
by the geqi1ysical survey.
'the bottan of the Bayou is covered by a layer of decaying vegetatiat
and leafy debris that is heavily oontaminated by creosote. 0Jre sauples
shew that a:msolidated blt loosely cci1esi ve sediment :iJmediately
underlies the vegetative debris. '!he \.JI'1Oa18Olidated sediment ... also
visibly streaked with creosote and sane sanples had large creosote
glotW.e8. '!he upper cohesive layer beneath the baya.t is also oontaminated,
based at lal:xJratozy analyses. Analytical results shew that tot:al PARes
range fran ND to 13450 ppn. Figure 1 depicts the extent of sediJrent
contaminatioo.
Hand excavated sanples and probes were used to deter:mine the extent of
sed:inent contamination in Western creek and in the eastern drainage
channel. In the lorer reaches of 00th the creek and channel, creosote
odors were evident ..men the sediments were disturbed, and a surficial
-------
14
that PAa concentrations in the sediIrents range fran ND to 260 ppn. The
sediment thickness in the western creek and eastern drainage channel
varied fran less than 6 inches to ncre than 3 feet. Steep banks en the
drainage channel, canbined with relatively thick contaminated sed:irnents,
mde access for measurement and sanpling difficult. Additional measurement
will be required to verify contaminated sediment quantities.
&>ILS
Laboratory tests indicate soil contaminaticn in essentially b.o zones:
1) the surface and near-surface soils and 2) the shallOi artesian
aquifer a1Site. 'n1e surface and near-surface soils are heavily contaminated
h1t ShOi a rapid decrease in concentrations with depth, £ran 15680 ppn
at the surface to 1 ppn within 9 feet. Except at ate locatioo the soil
was otheIWise uncontaminated until the shallOi artesian aquifer was
encountered. Soil oontaminatioo is thaJght to have been the result
of PAH migratioo through fractures in the q:per CXlhesive layer. PAH
soil oontaminatien ranges fran ND to 2488 ppn in the shallOi artesian
aquifer. CCntaminatien W!S not detected in ar belOi the 1~ oohesi ve
layer.
DUroRCEMENr
Initially b.o Potentially Responsible Parties (PRPs) 1Nere identified:
American creosote W::)ns, Inc., the last \1OJd treating cc:rrpany to am
and cperate the site, and Braselm!m COrporatioo, the present amer of
the site. .
American creosote WJrks, Inc. (ACW), a Texas COrparatioo, amed/operated
the facility fran 1958 until 1972 when eocn;mic problena forced the
closure of the operation. In 1975 AOl was sold, the fotme%' stodcholders
of AOIl foDned Braselman COrporatioo whidt retained the Bayou IDlfouca
property.
Braselm!m Corp., beginning in 1980, negotiated with the State of
Lc:uisiana to develop a nutually agreeable cleanup plan. 'n1ese negotiatioos
were tmSuccessful. EPA and Braselm!m have also discussed the cleanup
and the catpany has verbally indicated that it is interested in cleaning
up the land portien of the property, but that it nay not have the
resoorces to undertake a CERCtA-approved cleanup.
EPA, Regioo 6, mailed "Notice Letters" to ACW and BraseJnan for the
S01rce ocntrol Remedial Design/Remedial Actioo. In a letter received
by EPA CI'1 J\me 14, 1985, ACW declined involvElllmt with the site cleanup.
In a letter received on July 22, 1985, BraseJnan COrporatioo declared
an inability to pay for the site cleanup.
In October 1985 a contractor was hired to perfoIm' a PRP search under a
TES 2 contract. In June 1986, EPA mailed "Notice Letters" far the
bayou!groundtlater Rerredia1 Design/Remedial Actioo. To the American
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15
ALTERNATIVES EVAWATICN
Objectives
'the folloring are the remedial objectives developed for the Bayou
Bonfouca Site:
* Reduce or eliminate the fX)tential for ingesticn of carcinogens in
gromdwater, surface soils, and shellfish.
* Control the migration of PAH contaminaticn in the shallOi artesian
aquifer and other aquifers.
* Reduce or eliminate the direct oontact threat posed 1:„ Bayou sediments
and cnsite surficial creosote waste deposits.
Pursuant to the SUperfund Arnendrrents and Reauthorizaticn Act of 1986
(SARA) there are nSll requirements to be considered in addition to the
requirem:mts of CERCI.A for selecting the most appropriate remedial
actial for inplementation. 'the new provisions incl\.Xle a stra1g preference
for pexnanent solutions and a requirement that all oosite nmedi.al
actions attain legally applicable or relevant and appropriate Federal
and state standards, requirarents, criteria or limitations (ARARs).
IIi addressing pelmmence and long-term effectiveness the follcwin9 itEmS
nust be considered:
- la1g-term uncertainties of land disposal;
- goals and requirements of the Resource OOnservaticn and Recovery
Act (RCRA);
- persistence, toxicity, IOObility, voJJDe, and bioac:c:urulatioo;
- short and long-term potential for adverse h\JlBn health effects;
- latg-term naintenance costs;
- potential threat to h\.ltlaI1 health and the envira1ment fran the
excavation, transpJrtation, arxi redispJSal, or cx:ntaiment of
hazardous substances or pJllutants or cx:ntaminants.
SARA establishes a preference for rEllledial actions that utilize treatment
to pexmmently arxi signific:ant1y reduce the volume, toxicity, or ncbiUty
of hazardoos substances. Remedies should mi.nim:i.ze the requirement for
lcng-te:m n&na9Em!nt and/or nrnitoring. Remedies 'AtUch cx:nsist of offsite
transport and disposal of waste witho.1t treatment are least preferred.
Although the original RI/FS (June 2, 1986) predates SARA, several
peJ:nBnent rsredies (as defined 1:„ SARA) were cx:nsidered aIII:DJ those
analyzed in detail. In additial, three supplsnenta1 ~ developed
1„ the EPA cx:ntractors (September 13, 1986, January 12, 1987, arxi
Jarwary 13, 1987) revieNed in greater detail innovative and peInBnent
technologies. .
Appendix A lists the fX)tential1y applicable remedial actions stOOied for
the Baya.I Bonfouca site. 'It'.e tec1mology screening process was consistent
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16
SARA. O:mbinations of technologies \o\Iere identified and develcped into
alternative ranedial actions. To the extent that it was both feasible
and awropriate, treat:Irent alternatives for SCAlrce centrol actions \o\Iere
developed ranging fran an alternative that would eliminate the need for
long-tenn rranagem:mt (inchrling nmitoring) at the site to an alternative
using as a principal element a treatment that would reduce the toxicity,
rrcbility, or volune of site waste. Nine alternatives 'Nere considered
within this range. In addition, to CX'.I1ply with SARA, b.o other alternatives
. -were revieNed. 'lbese are: .
1) An alternative that involves containment of waste with little or no
treatment, blt provides protectioo of huran health and the envirorment
primarily by preventing potential exposure or reducing the m:>bility
of the wastes. .
2) A no-action alternative.
This screening process ( for technology/alternative reviSli) was divided
into b.o steps: initial screening and detailed screening. '!he initial
screening of alternatives was conducted with the intent of:
1) preserving the rrost pranising al ternati ves as detennined by their
likely effectiveness and mplementability.
2) preserving for futher analysis a range of alternatives consistent
wi th the new SARA provisions. .
Those technologies surviving the initial screening were further screened
utilizing the folloo.ng criteria:
1) Effectiveness. Alternatives 'Nere evaluated as to whether they
adequately protect huran h~th and the enviroment: attain Federal
and State ARARs or other criteria, advisories or guidance: significantly
and pernanently reduce the toxicity, ncbility, or volune of haz.a.rdc:us
ca1Stituents: were technically reliable, or were effective in other
respects.
2) ~lementability. Alternatives were evaluated as to the technical
feasibility and availability of the technologies each alternative
~d Eltploy: the technical and institutia1al. ability to nadtor,
naintain, and replace tec::hnologies over time: and the administrative
feasibility of :iIrplementing the alternative.
3) Cost. '!he costs of oonstructioo and any long-teIm costs to cperate
and mrintain the alternatives were evaluated.
4) carponent neasures of site specific evaluatia1S consideratioos.
'lbose remedial technologies passing through final screening were then
assembled to fonn nine remedial alternatives including the no-action
alternative. The action alternatives are broken dam into br.o categories:
SaJI'ce control and gramdwater. 'lbere -were eight SCAlrce CCXltrol
alternatives stooied in detail and only one groun&iater alternative.
-------
17
ooe groondwater remediation plan was thought capable of adequately
addressing the contaminant plume. '!bis will be discussed in ItOre
detail.
During the developnent of the ROD, the alternatives evaluated in the
RI/FS report W'ere m:xlified to sane degree.. '!bese m:xlified alternatives
and the rerredial technology to be enployed for each specific media are
presented in Table 2. Detailed cost estinBtes appear in Appendix C.
. An explanation for the m:xlifications follcws:
o COnsidering the passage of SARA and the Agency. s reevaluatioo of the
FS alternatives, the excavatioo and offsite disposal of the onsite
creosote waste deposits was viewed as inappropriate. 'Ibe creosote
waste deposits will be addressed as part of the proposed rerredial
actioo for j;i1ase II.
o All revi.&'ed actioo alternatives will CX)I'1Sider ~ter restoration
in that they propose a p\.ItP/treatment/injectioo l'18t\1OIX both 00 and
offsite. Areas where groundwater ocntaminatioo exists will not be
capped with a RCRA cap. 'Ibe soil will be ("~ because there is a
threat of ingestion: the groundwater will be punped and treated.
o 'Ibe ATSDR health assessnent for the site indicated that a1Site soil
ocncentrations with less than 100 ppn carcinoqenic PAH ~d pose no
significant ingestion risk to public health. After close inspectioo,
the Aqenc:y supports ATSDR.s conclusia1s. An earlier study perfoxmed
17:1 !.PA. s contractor suggested an actioo level of 1 ppn. 'Ibis level
-.a derived in the early stages of health assessnent and was based 00
the single nest hazardo.1s oarpound foond in creosote wastes rather
than total PAH.s. Since creosote wastes are not:. cme pure o:.,~d
and are catpOsed of several polynuclear arauatic hydrocarba1s, not
all of Wid\ are carcinogenic, more recent stu:ti.es shOi that total
PAHo s more closely approxinBte a realistic actioo level that is
protective of hunan health and the environnent.
'Ibe areal extent where concentratioo of total PAH are tlOC ppn is
srBller than the area where ocncentrations are 1 ppn. 'Iberefore the
area and volume in need of remediatioo is smaller.
o OOets for both onsi te and offsi te incineration were up2ted.
Alternative No. 1 is a r»-actioo alternative. It involves no additiooal
\1OIX or ncnitoring at the site and is not coosistent with SARA. 'Ibere
\1IOUld be no mi. tigatioo of the hazards currently associated with the
site as addressed earlier under O1r:rent Site Status, and is not protective
of h1.lnan health or the environnent.
Grc:Iundr.1ater Alternatives
Alternatives No.2 throogh No.9 errplC„ identical measures for remediating
groun~ter contamination. To prevent further ocntaminant migration,
contaminated qra.m~ter onsite and in the vicinity of the contaminated
reach of the bayou will be surroonded by slurry walls which will be
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18
Tab I e 2
Summary of RemedTai AlternatTves
Assemb led MedTa 5DecTfTc RemedTatTon Technology To 8e Employed
Alt. No. Bayou SedTment Creosote Waste PlIes Ons 1 te 50 Tis Groundwater
"1 . none none none none
.'
2 permanent d1versTon; ons1te landflll cap slurry wa II.
Tn-place stabTITzatTon around s1te
backfT II and cap and bayou;
pump and trea
contamTnated
Qroundwater
3 bayou partTtTon Off-s T te landfTI'.
0 ff-s He I andf T II " "
4 bayou part T t T on On-s Tte I andf T II
on-s1te I andf 111 " "
. .5 bayou part1t10n ons1te 1nc1nerat10n . ons 1t.a "
on-s1te 1nc1neratTon 1nc1nerat10n
6 bayou part1t10n " cap "
on-sTte TncTneratTon
7 bayou partTt1'On ons1~e b1010g1cal
on-sTte b10log1cal treatment " "
treatment
e bayou part1t10n of fs 1 ta I andf arm1 n9 " "
off-slte s1te
landfarmtng
.
9 bayou part1 t1 on offs1te 1nc1nerat10n " "
off-s1te 1nc1nerat10n
I
t
. Includes sedTments wTthTng Weston Creek and dra1nage channel on
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19
Q)ntaminated gra.mdwater will be extracted, treated, then reinjected.
Gra.md.t/ater reclamation will first occur offsite (easements w::IUld
have to be obtained to install the offsi te gra.mdwater treatment system
offsi te) . If proven successful, the sane technology will also be
enployed bilizing high organic-o::ntent wastes such as those
eJIPeCted in the ba}'Ou sediment. 'Ibe potential for a continuing or
future release 'IO.1ld exist fran the ba}'OU sectiment and also the onsite
creosote waste deposits. 'Ibis alternative can be inplemented rapidly
with oonvent.:i.cnal technology. Present \1IOrth 008t for this altemative
is relatively lcw. FurtheDtCre, institutional CXlnSideratialS w:JUld have
to be re80l ved prior to inplementing this rElledy. 'Ihese ccncems
include the inplications of relocating a navigable watexway, restoration
of equivalent floodwater conveyance to minimize upstream effects, and
the a~ing of land within the affected subdivision. Ia1C]-term site
JtD1itoring and rraintenance 'IO.1ld also be critical 'factors.
'Ibis alternative catplies with the provisi
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20
Alternative No.3 entails the excavation and offsite disposal of the
bayou, creek and channel sediments along with the creosote waste deposits.
'!he rerraining oontaminated soils \!wOuld be capped with a RCRA cover.
'!hese soils are not oonsidered a potential threat to the gram~ter.
Investigative analyses have indicated that the levels present in the
site soils WJuld bind to the area clay and not .mi.grate. '!he- cleanup of
the bayou ~d be acconplished by splitting the bayou into t'-'O sectioos
alladng a portion of the bayou to be dewatered for sediment rem::Mil.
- '!his will be acconplished through the installatioo of s~~ pilings.
One half of the bayou will be isolated, it will then be drained and
dredged. Up:n cacpletion the £lOti is routed through the clean area and
the opposite side of the bayou will be drained and dredged. '!he bayou
sedinents ~d be dewatered prior to offsite transportation. Water
draining into the dewatered side of the bayou, alcDJ with the drainage
associated with the dewatering activities ~d be treated by an oosite
treatment plant and discharged to the bayou. '!here 'NOUld be, no
destruction or detoxificatioo of the wastes. QJsts for inplementing
this alternative are relatively lOti and this alternative can be readily
inp].emented using conventional technology. I.a1g-teJ:m public health and
the envirament in the vicinity of the site ~d be inprcved due to
the relocation of contaminated sediments and waste piles, 'Ahidl pose a
direct
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22
Alternative 7 has yet to be effectively deronstrated. '!he Region was
unable to locate stu:iies that definitively proved that biological
degradation could effectively treat the waste within a reasonable t~
frame. Alternative 7 carplies in theory with the intent of SARA.
A variatiat of alternative No. 7 was considered 'were a1Site biological
treatment w::W.d be perfoIned in high-rate aerobic digestion. Creosote
waste deposits ~d be blended with wet sediment am subjected to
. biological treatment in tanks or lagoons ootfitted with ~eration equipnent.
Daatering w::W.d occur following an appropriate aeratiat period
(Ca1Stituent concentration reduced belo.i. relevant health criteria) and
treated residuals ~d be land applied at the site and covered by a
RCRA cap. 'Ibis approach \roD.1ld presmably afford greater oontrol over
the microbial degrada'tion process am lead to ncre rapid am CCltplete
destruct.iat. 'the wastE! rraterials \roD.1ld be containerized rather than
land applied and, therefore, the t.ed1nol.ogy wcul.d not be subject to the
land ban. Biological treatment experts at EPA8s R.S. Kerr Lab am the
Cincinnati Hazardous Waste Engineering Researd1 Center were contacted
U) obtain infOJ:nB.tion pertaining to the feasibility of this DDiified
biological approach. A cootractor reported to supply such biological
systEmS am a creosote rranufacturer with considerable remedial e!Cperience
'Nere also contacted. '!he consensus of opinioo was that ncre researd'1
is required to be able to guage the effect! veness am appropriate cperatiuld be ncderate to lo.i. It. should ment.ia1ed that a
public health risk associated with spillage of oontaminants during
shiplB1t. w:JUld exist. Altemative 8 also ca1plies with SARA.
Alternative 8 proposes the same t.echnology as Alt. No.7. Biological
degradatiat of wastes shQ\7S pranise, kut is yet I.mproVen.
'!he last alternative considered, No.9, is essentially the same as
Alternative 6 except offsite incineratiat instead of a1Site incineration
w::uld be utilized. 'these wastes \roD.1ld be incinerated at. an offsite
facility qualified to accept and process QJperfund wastes. '!he est:inated
present. '4IIOrth cost for this alternative is relatively high. Although
it was a&8\JDBd that an appropriate facility in Regioo 6 could be utilized,
currently there are no offsite incineratia1 facilities in Regiat 6
pemit.t.ted to accept &Jperfund wastes as per EPA 8 s Offsite Policy. '!he
facilities nearest. the site Wich can process these solid rraterials and
~ch are present.ly catpliant. with the Offsit.e Policy are located in
Illinois and South Carolina. Both these facilities require special
waste "packagingll procedures. If no facility in Region 6 is CCltpliant.
with the offsit.e policy at the time of constructiat contract award, a
substantial cost increase would be associated with using either the
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21
Onsite incineration of these wastes produce a residual ash that would
ITDst likely be delistable and would be disposed of onsite. '!his is the only
alternative which considers removal of the 20,000 cubic yards of onsite
soils contaminated in excess of a concentration of 100 ppn total
carcinogenic PAHs (ATSDROs rnsro dated Septsnber 11, 1986, in ~dix C).
'nle onsi te soils have a significant absorptive capacity for PAHo s. By
rercving the PAHos do,.m to 100 ppn all significant site contamination
\\OUld be removed and a RCRA cap 'NOUld be unnecessaty.
..
Due to the incineration of the relatively large volme of oosite soils,
the present~rth cost of this. al ternati ve is O'1e of the highest of the
alternatives considered. '!he onsite thentBl destructioo system inco%pOrating
incineration ~d be designed and roilt to neat all Federal and state
standards.
Alternative No. 5 carplies with SARA in that it reduces the Debility,
toxicity, and volune of the' creosote wastes. '!he cost-effectiveness
of this remedy is not max:iJnized.
Alternative 6 is identical to Alternative 5 except that the onsite
soils will not be incinerated. 'Ib prevent ingestioo and direct contact
with the soils it will be necessary to construct a RCRA cap on the
site. IDng-term ItBintenance of the site cap \101ld be required to
ensure that onsi te soils would not beoane eJPOsed and there1:7;{ create a
direct contact and ingestioo risk. '!he estinBted cost for this
alternative is nuch less than that estmated for Alternative 5.
Technical feasibility, public health, and institutia1al. cxncems are
almJst. identical to those referenced for Alternative 5.
Alternative No.6 catplies with SARA in that it signficantly reduces
ncbility, toxicity, and volume of the creosote wastes.
Alternative No.7 entails the eXcavatiO'1 and oo.site land treatmmt
(microbiological degradation) of. the contaminated bayou, creek and
Channel sediment along with the creosote -.st.e piles.
'Ibis alternative W)uld partition the bayou with sheet piles as discussed
in alternatives 3-6, to allOi for ba}'CIU sectinent cleanup. 'Iheoretically,
the IIBjority of site wastes would be destroyed. A R:RA cap 'tIOUld be
placed over that partial of the site cxntaining residual ocntamination.
~loyment of such technology 'tIOUld likely result in a certain degree
of hazardals waste destruction with a corresponding benefit to public
health. Ha.lever, the bickinetic rate of reactioo and the efficiency
and resid1a.l. concentratioo.s are not Known. '!his tedmology is potentially
pranising rot is unproven. Also, several site specific- 'conditions exist
'lthich bring the technical feasibility of the landfazmi.ng rEflWlial
scheme into question. Arrang these conditioos are the location of the
site within the 100 year floodplain of the ba}'CIU and the excessive
amount of rainfall received in the vicinity of the site. Due to the
expected slow degradation rate for the creosote calp.AJnds of concern,
this alternative has the longest inplenentation period (estimated 5
years) . Operation and rraintenance requirements would be substantial
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23
Public health benefits fran the proposed action \tiOUld be realized due
to the rem:>val and destruction of the D.1lk of the site waste. Ha-Iever,
a public health risk '#oOuld be associated with possil>le spillage of
contaminants during transport to the offsite incinerator.
'Ibis alternative does catply with SARA. It provides the sane level of
protection as Alternative No.6 yet it is mxe expensive.
. .All rerredies, with the exception of the no-actioo alternative, will be
designed to oarply with all apprcpriate and relevant Federal and State
standards and requirements.
a:tEISTJ!N:.Y WI'IH C1lHER ENVI~ IAWS
As part of the FS process, applicable and relevant Federal, stat.e and
local laws and regulations (ARARs) were revialed. 'the final al.temative
selected, as nentioned, will attain ARARs. Table 3 S\.1'lll1arUes these
standards and requirements and their inpact 00 the rEmedial altematives.
IUring the cc:urse of the investigative ~rk, and duriD;1 the developnent
of the RI/FS, the EPA coordinated with both the Artrrz Oxpe of Engineers
(
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24
bayou has been isolated and drained, a sunp punp system will be
installed to rarove water seeping in fran the bayou and fran the
surficial gra.mdwater aquifer. '!his water will be collected and
treated onsite and discharged in CClIpliance with the CWA.
As part of the d&latering process, the drained water will be collected
and treated onsite and discharged in CClIpliance with the CWA.
.;. Rescurce ~ervation and Recovery Act (RCRA)
.'
'Ibe enviramental law that most inpacts the site is RCRA. RCRA
requires (in part) that at final closure of a hazardous waste landfill,
the site be capped with a final cover designed to minimize looq-tenn
fluid migratioo through the closed landfill, functia1 with mirilira1
mintenance, prarcte drainage and minimize erosial, etc. RCRA guidance
doc:unent.s suggest a nulti-Iayered cap that has a peuaeability less than
or equal to the bottan of the landfill. RCRA further requires,
assuming cc:ntamination does not exist, that the groundwater be naUtored
for a thirty-year period to ensure the adequacy of the closure.
In additioo to the above, RCRA requires that groundNater cc:ntaminatioo
beyond the point of CClIpliance be cleaned up to badcground, a maxiJrum
concentration limit (MCL), or an altemate
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TABLE 3
rAWS, RmJIATIONS, AND srANIY\Rt6 APPLICABLE
AND REVEIANI' 'It) BAYOO 00Nr00CA
. Law/Regulation
FEDERAL
ReSOJrce Conservation
and Recovezy Act (RCRA
Underground Injection
Control (UIC) Program:
criteria and Standards
PeImi t requirE!lents for
Structures in or WJrk
Affecting Navigable Waters
of the U. s. (Section 404
Permit)
Pem t requirenents for
Discharges of Dredged or
Fill Materials Into Waters
of the U. s. (Section 404
Pem t)
Response in a F1CX)dplain
or Wetland
Nat.iO'1al nnissions
Standards for Hazardoos
Air Pollutia1s
National Environmental
Policy Act
Inte~enMe~a1R~i~
of Federal Programs
Soorce of
Regu.latioo
40 CFR 262
(Manifest)
40 CFR 264,
265 (Require-
ments for TSD
facilities)
40 CFR 146
33 CFR 322
33 CFR 323
40 CFR, Part 6,
~dix A
Clean Air Act,
Sectioo 112
State Inple-
mentat.ioo Plan
NEPA SectiCX1
102(2) (C)
40 CFR 29
Altemative Affected
All altematives involving
transportat.ioo of hazardoos
wastes to off-site treatment,
storage, or disposal
facilities (TSIP).
Not applicable to any
altemative.
All altematives involving
sedJment rEltCVal or per-
rranent diversion of Bayou
Bonfouca.
All altemat.ives invol vi.ng
sed:iment rEltDVal.
All altematives involving
cx:nst.ructi.oo in designated
flood hazard areas.
~icable to altemative
involving incineratioo of
the soil and sedUoent.
CERaA actioos are exenpt.
All altematives requiring
federal and state flmds or
a cxx;perati ve agreEltEI1t
beb.leen the state and
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Law/Regulation
Relocation Assistance
and Property Acquisition
W:>rker Safety and Health
Protectioo
Natiooal Pollutant Dis-
charge Elimination
SystEm
Effluent Guidelines and
Standards .
Federal Standards for
Toxic Pollutant Effluent
Hazardous Materials
Regulatioos
EPA Gromdwater Strategy
O:Inservation of Wildlife
Resources
Preservatioo of Scien-
tific, Historic, or
Archaeological Data
Preservatioo of Rivers
on the National
InventoIY
Source of
Regulation
Uniform Reloca-
tion Assistance
and Real Prop-
erty Acquisitioo
Policies Act of
1979, 40 CFR 4
OSHA
Clean ~ter Act,
'Section 402
40 CFR 122, 125
SUbchapterN
40 CFR 400, SUb-
chapter N,
Federal ~ter
pollutioo
Q:ntrol Act.
40 CFR 129
49 CFR 170 to
179
EPA Policy
Statanent
Fish and Wild-
life Coordi-
nation Act
Archaeology
am Historic
Preservation
Act of 1974
Wild and Scenic
Rivers Act,
40 CFR Part
6.302
Altemati ve Affected
Applicable to alternative
involving construction of
new ba}'01 reach.
"
Cbvers ~rking ocnditioos for
~rker health and safety for
on-site alternatives.
All alternative involving
source discharges to Bayou
Bonfouca.
All alternatives involving
discharge to a publicly .
CW1ed treatment ~rks. Not
awlicable to Bayou Bonfooca.
. All alternatives involving
discharges to BayQ1 Bonfouca.
All alternatives involving
interstate transportation
of hazardous naterials.
Applicable to all alternatives.
Contaminated aquifer classified
as Class B-2 aquifer.
Applicable to all alternatives
except No Actioo. 'n1is act
requires agency CXI'1Sultation
prior to m:xii.fying ar'„ body
of water.
Not applicable.
Not applicable.
"'-""---~-_._' "'-
, .
, - .'. _...- ,......... -
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Law/Regulatioo
Protectioo of 'Ihreatened
or Endangered Species
and '!heir Habitats
Federal Ocean Durt1?ing
. R8:Juirenents
STATE
IaJisiana Hazardous
W!1ste Regulations
I.OCAL
t.and Use, ZOning and/or
aulding requirsrents
Source of
Regulation
Fndangered
Species Act,
50 CFR Part 402
40 CFR 220-224
40 CFR 220-224
Act 449
City of Slidell
Municipal Q:)des,
and St. TanInany
Parish COdes
Al ternati ve Affected
Not applicable.
Not CiA?licable. No alternative
involves ~ dunping.
Applicable to owners and
operators of all facilities
that transport, treat, store,
or dispose of hazardous
waste. peJ:mi t requiJ:Irents
need to be addressed for
nai hazardous waste nBnagement
facility at the site or
rEloot.e £ran the site.
Applicable to all alternatives
involving CXI'1Struction,
deDDlitim or remedy on site,
within nunicipal/parish
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28
'the gramdwater will be treated as closely as technically possible
to MCLs. This will be done both on and offsite.
REXXl+tENDED ALTERNATIVE
Sectiem ~2l of SARA adds a new sect.iem to CERaA that established a
variety of requirements relating to the level of a cleanup for remedial
actions under CERaA. 'nUs sectiem codified rrany of the existing
. requirements under the National CJntingency Plan (N~), 1;:ut also
establishes additional directives for selecting peDtBnent remedies and
. for meeting state requirements (ARMs).
'the basic requiranents for a selected rEl'l1edy are that. the remedial
actialS be:
1) Protective of h\.llBn health and the enviraJaent:
2) Cb3t effective:
3) In accordance with the NO?:
4) In accordance with the new SARA provisialS, ie: pentBnent
SOlutialS to the IrBXimJm extent practicable, ARARs and
least preference for offsi te disposal of \.D'1treat.ed wastes and
ARMs .
Considering the OJrrent and potential site hazards and taking int.o
accamt. the si t.e characteristics, the 1: ~"UI:II&ded rElll!dial actiem is
alternative No.6: onsite theI'm!ll destructiCX1 of the creosote wast.e
deposit.s, and the CXX1taminated bayoo, western creek and drainage channel
sediments in a ncbile incinerator (the t.em incinerat.ia1 is used for
convenience, the exact type of thernal dest.ructia1 system has not
been specified). 'the I.o.1isiana Department. of Envirammtal Quality
exnc:urs with the proposed remedy (letter in Appendix F).
'the Louisiana Department. of Enviramental Quality was request.ed, in a
lett.er dated January 1987, to infom the EPA of any State or local
ARMs that cxW.d affect the mplementatiem of the rsnedial actiem.
After nuneralS meetings and phcI'1e oonversatiaus the State has not
identified ARARS other than those established ~ EPA. 'their written
CXX10JrrenCe with the proposed rElledy, (located in Appendix F) is taken
as CXX1au"rence em and acceptance of the ARARS discussiem given in this
doommt..
~ed sediments will be excavated either to a depth of about 6"
into the upper cohesive layer or until PAR ca1t.aminatiem is less than
1300 ppn. 'lhis level will mitigate further ~ter ca1t.aminatiem
as \\Iell as significantly rewce hazard to aquatic biota accordinq to
t.est. anitcted at the site. 'this plan will also utilize a ~ter
extractia1-treatDent.-reinjectiem process to clean the existing a:ntaminant
plume. Once the site activities have been carpleted, that. portiem of the
site (approxinBtely 34 acres) with contaminated soil above applicable
health based standards (100 ppn total carcinogenic PAHs is ale such
criteria) will be capped with a RCRA cap.
'the resiwal contamination will be adequately attenuated and adsorbed
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29
the gra.mdwater ~
cooclusicn.
Field tests and literature studies support this
The gram&ater extraction process will be designed to achieve ag>licable
ar„i relevant Federal and state standards. '!be Clean W:lter Act drinking
water criteria sU3gests a 3.1 ng/l level for PAH.s. '!be gromdoiater
remediation will in essence be a pilot study. Until specific field
data are collected it is unknam what clean-up levels will be t~
'logically acheivable. '!he target clean-up will be a h~th-based 10-4
or 10-6 level as per FS guidance. .
'!be site will be m:mitored for a period of 3Q-years after site closure.
'!his period is stipulated under RCRA ar„i it is meant to ensure that no
significant oontaminant migration takes place.
'!he alternative is protective and ooet-effective, attains ARARs and
utilizes pexnanent solutions and treatment technologies to the naximJm
extent practicable.
'!be oosite thenral destruction system will be state-of-the-art and will
neet all applicable Federal ar„i state requirements (ARARs). MJbile
incineration has been darcnstrated as an effective destructioo technology
for wastes similar to those foond at the site. '!be ash produced £ran
the site will likely be delisted and left onsite.
OPERATICN AND ~CE
'.
Project operatioo and naintenace will include a nr.I1i.toriD; well sanpling/
analysis program ar„i site cap maintenance. 0:Ists are itemized in
Appendix B. O&M acti vi ties will be oonduct.ed by the State of Louisiana
for a mininun period of 30 years, after ~c:h tim! the need for continued
m:aitoring will be evaluated.
The grounc:Water extractioo and treat:nent system is expected to operate
for several years. '!be EPA, as provided under SARA, will provide
for 100 percent of the costs for this activity within the first 10
years. If this act! vi ty extends be:ia1d this period, the State of
U:W.siana will be responsible for those costs.
SARA also states that if an alternative results in any hazardous
substances, pollutants, or
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30
PLANNED SCHEDULE
- Approve Remedial Action (sign ROD)
March 1987
- Initiate Design - REM COntractor
April 1987
June 1987
- Start Design
. - Catplete Design
- Award Interagency Agreanent
Ccnstruction - OOE oversight
- Start COnstruction/Re!rediation
February 19~
February 1988
- O::Itplete Excavatioo and Incineratioo
(1 yr) .
May 1988
0Ctcber 1990
- Catplete Gromdrlater Remediation
Approximately 1994
Ft11'URE ACrIONS
!\1ture actions will depend up:m the effectiveness of the ~ter
extraction and treatment. If fully successful, no future remedial
activities shOJldbe necessary. If, it is found that cleanup of the
CXI1t.am:inated gramdwater pl\.J'le to the Clean water Act levels is
technically feasible,. other remediatioo activities may have to be
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BAYOU BONFOUCA COMMUNITY RELATION
RESPONSIVENESS SUMMARY.
This community relation responsiveness summary is divided into the
following section:
Section I:
~round on Community Involvement and Concerns. This
section provides a brief history of community interest and
concern raised during the remedial planning ~ctivities at
the Bayou Bonfouca site.
Sect ion II:
Summar of Comment Received durin
Comment are categorized by tOplCS
provided.
Period.
are
I. BACKGROUND ON COMMUNITY INVOLVEMENT
From 1882 until 1970 a wood treating facility operated in Slidell.
Lousisana adjacent to the Bayou Bonfouca.
Community concern regarding the site dates from the mid-1970s when in
reponse to a local newspaper. the U.S. Coastguard began investigating
creosote pollution in Bayou Bonfouca.
'.
In May 1980 the Bayou Bonfouca Environmental Society was formed largely
to express opposition to Champion Shipgard's proposal to locate a ship
building facility on the site. The Chamber of Commerce sponsored a
public meeting to discuss the issues involved. Opposition to ship
building centered on the potential for stirring up creosote that had
settled in the bayou.
Local and state-wide media attention focused on Bayou Bonfouca when
it was placed in 1982 on the Superfund National Priorities List.
EPA began multi-phase remedial investigation feasibility studies in May
1984. A program update fact sheet describing Phase I of the study
results was sent to interested people in April 1985. On June 12. 1985
EPA held a public meeting to discuss alternative remedies for the
surface contamination at the site. Thirty people attended the meeting;
six people commented or asked questions. No written comments were
received.
Local officials including the city engineer were also briefed on
June 12. 1985. They expressed major concern about all the alternatives
EPA presented.
The final plan for the surface remedy was announced August 28. 1985.
It required the removal (excavation) of 5000 cubic yards of creosote
wastes and creosote contaminated debris and the transporting of the
material to an off site landfill. The plan also called for soil back-
filling and compacting. This would provide a minimum of 2 feet of
clay and 18 inches of top soil at the site. The area would be re-vegetated
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2
In June 1986 EPA issued a project update fact sheet reporting an end to
the Phase II remedial investigation feasibility study. It presented
nine alternative remedies for contaminated waste and three options
addressing contaminated groundwater. A public meeting was held on
July 17, 1986 to discuss the remedial alternatives.
At that meeting several requests were made for EPA to extend the public
-comment period beyond the July 23, 1986 dealine. EPA extended the comment
period through October 31, 1986. ?
On November 13, 1986 EPA staff members met with local citizens and the
Chamale Property Owners Association, to discuss the new Superfund
Amendments and Reauthorization Act and also to discuss the concept of
thermal destruction.
In February 1987 EPA issued a project update fact sheet describing
the proposed alternative for overall cleanup of the Bayou Bonfouca
Superfund site. A public meeting was held in Slidell on February 11,
1987 to discuss the cleanup plan with the public, some 250 of whom were
in attendance. The orginally planned remedial action was changed from
essentially a cap-in-place remedy to one that excavated an incinerated
ons ite all heavi ly contami nated. sediment and the creosote waste pi 1 es.
Additionally, EPA staff members met with local officials including the
Mayor, City Attorney and City Council representative.
II. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
Comments received during the January 30 to February 20, 1987 public
comment period along with EPA responses include:
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1) Why was the action level for polynuclear aromatic hydrocarbons
(PAH's) changed from 1 ppm to 100 ppm?
The original number of 1 ppm was estimated value discussed in an
early health assessment. The 1 ppm action level was based on a
single hazardous compound common in creosote wastes. This was a
worst case estimate.
In response to questions concerning the legitimacy of the 1 ppm
figure the EPA requested and obtained an evaluation from the Agency
for Toxic Substances and Disease Registry (ATSOR). ATSOR found the
original risk assessment to be overly conservative and not indicative
at the actual health threat. After careful study an action level
of 100 ppm total PAH's was established. This level is considered
safe for direct contact. This action level is consistent with
Agency cleanup goals and with other Superfund cleanups. A copy of
ATSOR's evaluation is part of the Administrative Record for the site
(Appendix C).
2) Will the RCRA cap actually be five feet high?
There will be an approximate five feet rise over a 34 acre area.
order to maintain a positive offsiteslopet it is possible that
portion of the site may be 1 to 3 feet higher than this. The cap
howevert will likely appear as a very gentle rise although this
aspect will be specifically addressed in the design phase.
3) Since there is very poor drainage in the area and the site lies within
the 100 year flood plain of the Bayout will the RCRA cap be designed
with flood control in mind?
In
Yes. Conceptually, the drainage will be directed towards the bayou
so as not to increase the flooding of neighboring properties. Flood
control and the specific impact on drainage will be addressed in the
design phase. All efforts will be made to minimize any adverse
impacts of site drainage associated with the cap.
4) Will the land be useable after remediation?
Possibly. The EPA cannot consider future land use at a Superfund site.
In remedial planning CERCLA/SARA's focus is on the protection of public
health and environment as a basis for the selection of remediation.
Howevert the land may be utilized as long as the integrity of the
remedy is maintained.
5) Will incineration contribute to air or noise pollution?
No. To ensure proper operation of the incinerator, the design will
specify parameters to be continously monitored. These will include:
carbon monoxide, water feed rate, combustion temperaturet and combustion
gas velocity. The parameters are set during a pilot test and assure
that any effluents present minimal impact on public health and the
environment. .If there is a malfunction, the incinerator will auto-
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2
Site noise will be minimized and will most likely be less than that
of a typical construction site. Any dust, vapors, emission, noise,
or any other factor affecting the community will be considered as
part of the design considerations.
6) Will EPA guarantee that the proposed incinerator will be removed
after cleanup?
Yes. The envisioned incinerator will be a mobile unit. Its only
purpose is to thermally destroy the wastes associated with the Bayou
Bonfouca site. Once this task is completed it will be removed.
7) What will be the hours of operation of the incinerator?
This has not yet been determined. This will be addressed during the
Remedial Design. Before an operating time period is established
citizen input will be solicited and reviewed.
8) Is the full extent of sediment and groundwater contamination defined?
The spatial extent of sediment and groundwater contamination was
investigated during the Remedial Investigation. Although defined to
. the extent necessary to develop and propose a conceptual design,
additional data will be collected for finalization of the detailed
project design. .
9) To what level will the groundwater be cleaned?
At this time it is not known what the lowest, technically feasible
clean-up level is for the water. Groundwater treatment will essentially
be a pilot study so the clean-up level will be defined once treatment
begins and specific data are available. The engineers who developed
the treatment technologies estimated that 901 of the wastes could be
removed from the water. This will be further evaluated during
pumping tests of the contaminated aquifers.
10) Why has E.P.A. changed the proposed remediation from the original
alternative selected in 1986 for the Bayou Bonfouca site?
The original alternative proposed in June 1986 capped all the wastes
in place, including all surface, drainage ditch, and bayou contamination.
The alternative included bayou reclamation and a groundwater recovery
treatment system. Subsequent to this meeting, area residents requested
and received a 3-month extension to the pUblic comment period,
ending October 31, 1986. The new Superfund law was signed during
this time (October 17, 1986) and had a significant impact on the
what the Agency now considers to be acceptable remedial alternatives.
The new law sets stricter cleanup standards and strongly emphasizes
permanent technologies th3t either treat or destroy wastes. Onsite
incineration more ~losely meets these stricter standards, compared
with earlier proposed ca'J-in-place alternative, in that it
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3
waste. Therefore, the EPA has changed the proposed remedial action
to be more consistent with the provisions and preferences of the new
Superfund 1 aw.
11) The Bayou Bonfouca site is within 1/2 mile of two shopping centers,
two elementary schools, one middle school, one jr high school, and a
hospital. Under the DOT Hazardous Incident Response Guidances, the
area surrounding an incinerator should be isolated for 1/2 mile in
all directions. Why is remediation being performed in the middle of
a municipal area and are there contingency plans if the incinerator
malfunctions?
The DOT regulations refers to hazardous incidents, remediation of
the Bayou Bonfouca site through incineration is a controlled situation
and not a hazardous incident. Therefore, gaseous and particulate
emissions are stringently monitored and significant concentrations
of volatiles are not being discharged into the atmosphere as they
would be in an uncontrolled situation.
Any potential health hazards posed to the community will be considered
throughout the design and implementation of the remedy. There will
be a Site Safety Plan which deals specifically with questions of
'safety related to the site. A site Health and Safety Officer will
be present for all site-related activities. In the unlikely event of
a significant volatile release, appropriate steps would be taken.
This is an important concern and specific precautionary measures
will be addressed in, the remedial design.
12) Is there any financial assistance available to help citizens
participate in the selection of the remedial action?
Yes, SARA provides for a $50;000 grant to be made available to citizen
groups in order to facilitate public participation in the selection
of a remedial design. Not more than one grant may be made with
respect to a single facility. Each grant recipient is required to
contribute at least 20~ of the total $50,000. The 20~ contribution
requirement may be waived if the recipient demonstrates financial
need and the waiver is necessary to facilitate public participation
in the selection of a remedial design. An 'in-kind' match may be
allowable, and Federal Procurement Regulations will likely apply.
Currently, it is not known how a determination will be made between
different groups requesting the funds or who will decide this issue.
13) To what depth will contaminated sediments be excavated?
Approximately 46,500 yds3 of sediment will be excavated. The depth
of excavation will be to about 5.0 feet although this will be
specifically addressed in the design phase. The volume to be
excavated will include the significantly contaminated sediment that
acts as a source for continued groundwater contamination and inhibits
-------
4
14) Has dredging the contaminated sediment in the bayou rather than
dewatering the bayou to excavate the sediment been reviewed as an
alternative?
Yes. In dredging the bayou there is a strong' possibility of re-
suspending contamination in the water column. This is seen as
potentially a significant environmental problem. Even with the
newest technique, i.e., clam shell dredging, the cont~ination could
be resuspended.
15) If there is a concern about resuspending contamination doesn't
barge traffic disturb the sediment?
Yes, barge traffic does turbate the sediment but not to the degree
that dredging would cause resuspension.
There is no information to date that shows that barge traffic presents
an environmental concern.
16) If the bayou is to be dewatered one side at a time, how will commercial
operations that use barges continue to function?
. The EPA is aware that there are commercial properties on the bayou
that depend on barge transportation. This will be considered and
evaluated in the design phase.
17) Is there .a potential threat to the food chain because of the
contamination?
No. Aquatic organisms in the bayou have been locally affected, as a
survey of benthic organisms revealed an absence of aquatic organisms
in the site area. This however, does not present a threat to
the food chain per se, it presents a threat to shellfish that may
ingest the sediments. The site is posted to discourage fishing and
swimming in the bayou. Once the site is cleaned up, no significant
long-term effects are anticipated.
18) How will the increased flooding potential due to the bayou remediation
plan be reduced?
Increased flooding potential will be a concern during dewatering
operations. Steps will be taken to minimize any such risk. Specifics
are not available at this time. The Remedial Design will address
-------
.'
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APPENDIX B
BA YOU BONFOUCA
SUMMARY OF REMEDIAL ALTERNATIVES
Alt. No.1 Alt. No. 2 Alt. No.3 Alt. No.4 Alt. No.5 A 1 t. No.6 A 1 t. No . 7 A 1 t. No.8 Alt. No.9
No Action Mu1tHc\yer Mul t i 1 ayer On site Ons ite On site Onsite Offsite Mul t i 1 aye red
Cap Cap Offsite Landf i11 Inc ine- Incineration Landfarming Landfarming Cap. Offsite
Permanent Landf i 11 of of Wastes rat ion of of Wastes. of Wastes of Wastes Incineration
Bayou Sediments Wastes. and So 11 " Cap of Sediments
Eval. Criteria Diversion Onlv Soils
Performance * - - - ++ ++ 0 0 ++
Re 1 i ab 11 ity * - + - ++ ++ 0 0 ++
Imp1ement-
abi1 ity!
Con$truct- * ++ ++ H + + - 0 ++
abi1 itv
Public Health -- - - - ++ ++ + ++ +
Envi ronmental -- - - - ++ ++ + ++ +
Cost (Millions)
Capitol
Mi11 ion $ 0 20 25 20 80 60 20 29 110
O&M Cost
(Annual) 0 120 120 130 110 110 160 ". 110 120
Thousand $
Time to - 1.5 1.5 2.5 1 1 3 2 0.5
Achieve (yrs)
-- Extremely negative impact
- Moderately negative impact
o No iq>act
+ Moderately positive impact
++ Very pos it ive iq>act
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-------
COST ESTIMATE SUMMARY
ALTERNATIVE 2: SLURRY WALL CAP AND TREATMENT SYSTEM FOR
SOIL, SEDIMENT, AND GROUND WATER; WITH PERMANENT SURFACE
WATER DIVERSION
ANNUAL PRESENT
CONSTRUCTION O&M WORTH
COST COMPONENT COSTS COSTS COSTS
$ $ $
1. Permanent Surface Water 1,770,880
Diversion
2. Management of Contaminated 2,807,944 11 ,800
Channel s
3. Installation of Soil and
Ground Water Containment 7,510,100 59,400
Systems
4. Onsite Incineration of
Waste Deposits
5. Groundwater Treatment
6. Site Monitoring 30,000 47,500
7. MObilization, Bonds, and 673,272 0
Insurance (5~)
0
8. Health and Safety (5%) 673,272
CONSTRUCTION SUBTOTAL 13,465,438
Bid Contingencies (15%) 2,019,816
Scope Contingencies (20~) 2,693,088
CONSTRUCTION TOTAL 18,178,342
Permi tt i ng and Legal (5~) 908,917
Services During Construction (8%) 1,454,267
TOTAL IMPLEMENTATION COST 20,541,525
Engineering Design Cost (8%) 1,643,322
TOTAL CAPITAL COST 22,184,847
PRESENT WORTH CAPITAL COST 22,184,847
TOTAL ANNUAL O&M COST 118, 700
PRESENT WORTH O&M COST 1,118,974
-------
COST ESTIMATE SUMMARY
AL TERNATI VE 3: SLURRY WALL CAP AND TREATMENT SYSTEM FOR
SOIL, SEDIMENT, AND GROUND WATER; WITH WASTEPILE AND SEDIMENT
REMOVAL AND DISPOSAL IN AN OFF-SITE. LANDFILL
ANNUAL PRESENT
CONSTR UCTI ON O&M WORTH
COST COMPONENT COSTS COSTS COSTS
$ $ $
1. Sediment Removal With Channel 2,778,504 11,928
and Drainageway Restoration
2. Wastepi1e and Sediment 3,880,000 0
Disposal at Off-site Landfill
3. Installation of Soil and 6, no, 100 59,400
Ground Water Containment
Systems
4. Groundwater Treatment
5. Site Monitoring 30,000 47,500
6. MObilization, Bonds, and 744,367 0
Insurance (5%)
7. Health and Safety (5%) 744,367 0
CONSTRUCTION SUBTOTAL 14,887,338
Bid Contingencies (15%) 2,233,101
Scope Contingencies (20%) 2,977,468
CONSTRUCTION TOTAL 20,097,906
Permitting and Legal (5%) 1,004,895
Services During Construction (8%) 1,607,832
TOTAL IMPLEMENTATION COST 22,710,634
Engineering Design Cost (8%) 1,816,851
TOTAL CAPITAL COST 24,527,484
PRESENT WORTH CAPITAL COST 24,527,484
TOTAL ANNUAL O&M COST 118,828
PRESENT WORTH O&M COST 1,120,181
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COST ESTIMATE SUMMARY
ALTERNATIVE 4: SOIL AND SEDIMENT REMOVAL AND DISPOSAL IN AN
ON-SITE LANDFILL, WASTEPILE REMOVAL AND DISPOSAL IN AN OFF-SITE
LANDFILL, WITH SLURRY WALL CAP, AND TREATMENT SYSTEM FOR GROUND WATER
COST COMPONENT
1. Soil Removal
2. Sediment Removal With Channel
and Drainageway Restoration
3. Wastepile Removal and Disposal
in Off-site Landfill
4. On-site Landfill Construction
and Implementation
5. Installation of Ground Water
Containment Systems
6. Groundwater Treatment
7. Site Monitoring
8. Mobilization, Bonds, and
Insurance (5~)
9. Health and Safety (5~)
CONSTRUCTION SUBTOTAL
Bid Contingencies (15~)
Scope Contingencies (20~)
CONSTRUCTION TOTAL
Permitting and Legal (5~)
Services During Construction (8%)
TOTAL IMPLEMENTATION COST
Engineering Design Cost (8%)
TOTAL CAPITAL COST
PRESENT WORTH CAPITAL COST
TOTAL ANNUAL O&M COST
PRESENT WORTH O&M COST
TOTAL PRESENT WORTH COST
CONSTRUCTION
COSTS
$
252,000
2,778,504
638,460
5,594,100
30,000
516,281
515,281
10,325,627
1,548,844
2,065,125
13,939,596
696,980
1,115,168
15,751,743
1,260,139
17,011,883
ANNUAL
O&M
COSTS
$
o .,
11,928
15,000
57,000
47,500
o
o
131,428
PRESENT
WORTH
COSTS
$
17 , 011 , 883
1,238,960
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COST ESTIMATE SUMMARY
AL TERNAT I VE. 5: WASTEPILE, SOIL AND SEDIMENT REMOVAL AND ON-SITE
INCINERATION; WITH SLURRY WALL CAP, AND TREATMENT SYSTEM FOR GROUND WATER
ANNUAL PRESENT
CONSTRUCTION O&M WORTH
COST COMPONENT COSTS COSTS COSTS
$ $ $
1; Soil and Wastepile Removal 252,000 0
2. Sediment Removal With Channel 2,778,504 11 ,928
and Drainageway Restoration
3. On-site Incineration of 36,869,510 0
Wastepi1es, Containment
Sediment
4. Installation of Ground Water 4,335,100 54,900
Containment Systems
5. Groundwater Treatment
6. Site Monitoring 30,000 47,500
7. Mobilization, Bonds, and 2,460,284 0
Insurance (5%)
8. Health and Safety (5%) 2,460,284 0
CONSTRUCTION SUBTOTAL 49,205,682
Bid Contingencies (15%) 7,380,852
Scope Contingencies (20%) 9,841,136
CONSTRUCTION TOTAL 66,427,671
Permitting and Legal (5%) 3,321,384
Services During Construction (8%) 5,314,214
TOTAL IMPLEMENTATION COST 75,063,268
Engineering Design Cost (8S) 6,005,061
TOTAL CAPITAL COST 81,068.330
PRESENT WORTH CAPITAL COST 81,068,330
TOTAL ANNUAL O&M COST 114,348
PRESENT WORTH O&M COST 1,077 , 948
-------
COST ESTIMATE SUMMARY
ALTERNATIVE 6: WASTEPIlE, SOIL AND SEDIMENT REMOVAL AND ON-SITE
INCINERATION WASTEPIlES AND SEDIMENT WITH SLURRY WAll CAP, AND TREATMENT
SYSTEM FOR GROUND WATER
ANNUAL PRESENT
CONSTRUCTION O&M WORTH
COST COMPONENT COSTS COSTS COSTS
$ $ $
1. Onsite Pile Removal 252,000 0
2. Sediment Removal With Channel 2,778,504 11,928
and Drainageway Restoration
3. On-site Incineration of 19,529,066 0
Wastepi1es, Sediment
4. Installation of Slurry Wall 5,960,100 59,400
and Soil Cap
5. Installation of Ground Water 4,355,100 54,920
Containment Systems
6. Groundwater Treatment
7. Site Monitoring . 30,000 . 47, 500
8. Mobilization, Bonds, and 1,785,173 0
Insurance (5~)
9. Health and Safety (5%) 1,785,173 0
CONSTRUCTION SUBTOTAL 35,703,460
Bid Contingencies (15%) 5,355,519
Scope Contingencies (20%) 7,140,692
CONSTRUCTION TOTAL 48,199,671
Permitting and Legal (5%) 2,409,984
Services During Construction (8%) 3,855,628
TOTAL IMPLEMENTATION COST 54,465,628
Engineering Design Cost (8%) 4,357,250
TOTAL CAPITAL COST 59,594,534
PReSENT WORTH CAPITAL COST 58,822,878
TOTAL ANNUAL O&M COST 173,748
PRESENT WORTH O&M COST 1 ,077 ,948
-------
COST ESTIMATE SUMMARY
ALTERNATIVE 7: WASTEPILE, SOIL AND SEDIMENT REMOVAL AND TREATMENT
AT AN ON-SITE LANDFARM; WITH SLURRY WALL CAP, AND TREATMENT
SYSTEM FOR GROUND WATER
COST COMPONENT
1. Wastepile Removal
2. Sediment Removal With Channel
and Drainageway Restoration
3. On-site Landfarm Construction
and Operation
4. Installation of Ground Water
Containment Systems
5. Groundwater Treatment
6. Site Monitoring
7. Mobilization. Bonds. and
Insurance (5%)
8. Health and Safety (5%)
CONSTRUCTION SUBTOTAL
Bid Contingencies (15%)
Scope Contingencies (20%)
CONSTRUCTION TOTAL
Permitting and Legal (5%)
Services During Construction (8%)
TOTAL IMPLEMENTATION COST
Engineering Design Cost (8%)
TOTAL CAPITAL COST
PRESENT WORTH CAPITAL COST
TOTAL ANNUAL O&M COST
PRESENT WORTH O&M COST
TOTAL PRESENT WORTH COST
CONSTRUCTION
COSTS
$
252.000
2.778.504
5.094.481
3,070.900
30.000
623.660
623,660
12.473.206
1.870.981
2.494,641
16.838.828
841.941
1.347.106
19,027.875
1.522.230
20.550.105
ANNUAL
O&M
COSTS
$
o "
PRESENT
WORTH
COSTS
$
11.928
768.000
57.320
47.500
o
o
20.550.105
116.748
4,011.900
-------
COST ESTIMATE SUMMARY
AL TERNATI VE 8: WASTEPILE, SOIL AND SEDIMENT REMOVAL AND TREATMENT
AT AN ON-SITE LANDFARM; WITH SLURRY WALL CAP, AND TREATMENT
SYSTEM FOR GROUND WATER
ANNUAL PRESENT
CONSTRUCTION O&M WORTH
COST COMPONENT COSTS COSTS COSTS
$ $ $
1..Wastepile Removal 252.000 0
2. Sediment Removal With Channel 2.778.504 11 . 928
and Drainageway Restoration
3. On-site Landfarm Construction 17.989.300 0
and Operat i on
4. Installation of Ground Water 4.355.100 54.920
Containment Systems
5. Groundwater Treatment
6. Site Monitoring 30.000 47.500
7. Mobilization. Bonds, and 1.411 .384 0
Insurance (5~)
8. Health and Safety (5~) 1 .411 ,384 0
CONSTRUCTION SUBTOTAL 28,227.671
Bid Contingencies (15~) 4,234,151
Scope Contingencies (20~) 5.645,534
CONSTRUCTION TOTAL 38,107,356
Permitting and Legal (S~) 1,905,368
Services During Construction (8~) 3,048,588
TOTAL IMPLEMENTATION COST 43.061,312
Engineering Design Cost (8~) 3,444,905
TOTAL CAPITAL COST 46,506,217.
PRESENT WORTH CAPITAL COST 46,506.217
TOTAL ANNUAL O&M COST 114,348
PRESENT WORTH O&M COST 1 .077 . 948
-------
. \
COST ESTIMATE SUMMARY
ALTERNATIVE 9: SEDIMENT AND WASTEPILE REMOVAL AND OFF-SITE
INCINERATION; WITH SLURRY WALL, CAP AND TREATMENT
SYSTEM FOR GROUND WATER
ANNUAL PRESENT
CONSTRUCTION O&M WORTH
COST COMPONENT COSTS COSTS COSTS
$ $ $
1. Sediment Removal With Channel 2, 77 8, 504 11,928
and Drainageway Restoration
2. On-site Incineration of 54,655,400 0
Sediment and Waste Piles
3. Installation of Ground Water 6,260,100 59,400
Containment Systems
4. Groundwater Treatment
5. Site Monitoring 30,000 47,500
6. Mobilization, Bonds, and 3,540,222 0
Insurance (5~)
7. Health.and Safety(5~} 3,540,222 0
CONSTRUCTION SUBTOTAL 70,804,449
Bid Contingencies (15%) 10,620,667
Scope Contingencies (20~) 14,160,890
CONSTRUCTION TOTAL 95,586,006
Permitting and Legal (5~) 4,779,300
Services During Construction (8~) 7,646,800
TOTAL IMPLEMENTATION COST 108,012,187
Engineering Design Cost (8%) 8,640,975
TOTAL CAPITAL COST 116,653,162
PRESENT WORTH CAPITAL COST 116,653, 162
TOTAL ANNUAL O&M COST 118,828
1,120,181
PRESENT WORTH O&M COST
117,773,343
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-------
, ' ....."fIt
{4-'
~~
.....
Dlt.
From
DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Agency for Toxic Substanc:es
and Disease Registry
Memorandum
. SEP 1 1 1986
&ot1ll& Direotor
OI't1oe ot Health useaaent
Subiect lQou loDtouoa, S1-86-035B
Sl1d811, Lou1a1&D&
To
"
Mr. Carl R. B1ak..
Publ10 Health &cIY180r
Ir& R811cm VI
KIIItI'"3IT.I.VI!: SUMMARY
fte 18Md1al IDye.t1&at1on vas 8Y8luated tor the poteDt1&1 publ10 health
threat to area rea1dents trom oreosote oont-III.".t1on tJoaa the _ou
loDtouoa Site, Sl1de11, Lou1s1&D&. The po881b1l1tJ ot an acute ady....e
health ett80t trom sed.1m.nt oont-...".t1on to 8188.... throu8b d8l'll&l
abaorpt1OD a1.ta. TJUa .tat__t 18 baaed on an 1Do1dat vbere two Cout
Guard cU.v.... reoe1Yed 8.eoond decree bUl'U8 wWe _pl1Da the
oont-.a.ted aed11D_t in th8 Ba10u. SiDoe that t~. oth8r 8Id.D
1rr1tat1oD ino1d8Dta to area ru1d8Dt. haye b88D reporteet bJ the Publ10
Health &cIY180r, BP& Rel10n VI. SiDoe v. haye DO md_o. to the oontl'U'J
it would be prudent to .:t"...... &DJ UDDeo......, reoNat1ODal act1Y1t1 in
the Y101D1t1 ot the bulkhead area untll adequate .~pli". or NMd1a1
.ttorta ot .1te oontuiD&Dt. are pertol"ll8d.
M'1'l'Dmft' 0,. '!'1m PROBLEM
fte q8DoJ tor Tozio SubtaDoe. and D18...e Re8&18tl'7 (&TSDR) hu b88D
reque.teet bJ the IDY1roD88Dtal Proteot1on q.n01 (BP&) to NY1- 8DcI
o.-_t - the publ10 health oon081'D8 pronded in Cbapter , ot the
l_ed1&1 IDYe.tipt1on (II) Report.
B.&cmRomm
fte .1te 1. looated in St. TUllll&D1 Pariah, Sl1de11, Lou1a1&D&
approz11Date11 25 811ea nortbeut ot Hev Orleau. 8aJou Bonto.a 1a the
a1te vhere a oreosote'treat~~ plant onoe operated aloDS the 84ge ot a
-------
Page 2 - Mr. Carl Hickam
atorage tanka oontam1nat1Dl the aurtaoe ao11, sroundwater (aurt101al
aquifer, ahallov artea1an aquiter), a841menta ot the laJou, veatern oreek,
aDd dra1D8&e oIwmel. The a1te oovera 55 acrea &Ild 1a south ot Veat Ball
Avuue aDd north ot and adjacent to laJou BoDtouoa. laJou BoDtouoa 1a a
Davicable waterval vhich tlowa into Lake Pontollartra1D.
ID ApI"11 1916, the u.s. Cout Guard oolleoted aaplu tra8 the 1&10u.
1fh1le ooUeot1Da aecl1ment _plea, two Cout Guard d1vera auttered
"OODd-dearee oh881cal burna. fte inveatipti- N'f-.1ed tllat ONOsote
- d18Ohars1Dl into the Balou ria 1'UD0tt. III 1982, the BPA placed the
a1te on the Rational Prior1tiea L1at. In 1983, a phued l_ed1al
IDvutiaat10n 'Feaa1b111tl Studl addreaaed on-site sroUDdwater.
Additional data on 8011a to "alate vertical &Dd lateral JI1&ration ot
oont--4 a.ata throush the 8011a - al.o pertOl'lled. fte southern h&U' ot
the propertl 1. h..v111 oontu1nated at the aurtace, aDd the aurtio1al
aquUer &Ild the ahallow artea1&1l aquUer underll1Da the propert)' &N
oODt'~i.ated with oreo.ot..
DOCUMRN'l'S REVIJMm
1. R_ed1al Inve.ticat1on Report, BalOU BoDtouoa tite,
Contraot 10. 68-01-6692, April 25, 1986.
CHat 1111,
2. Pbue II ,...1bl1it7 Stud7, BaJou BoDtouoa Site Dratt, CHat Wl,
Contract 10. 68-01-6692, Ma1 8, 1986 I"8v18ed June 2, 1986.
3. M8OJ"&1ldua, Charlea B. .aUIIU, IDri.roma8Iatal Toz1oolOl1at, Izpoaure
ua.a_ut Group (RD-689), Ottioe ot ..aearoh &Dd DeT810P88Dt, u.s.
BPA, V..h4naton, D.C., to J1m Pvonto, Projeot Ottioer, ALOIN 1_8d1a1
Seotion (6B-8A), re: Review ot the Balou BoDtouoa Publi0 Bealth
-------
...e 3 - Mr. Carl Hiok..
PRI1ICIP1L COH'1'AMnlAHTS
PolJDuol8&l' aromat10 h)'drooarbona (benzo (a)p)'ren~, beao (a) anthraoen.,
b.nzo(b)tluoranthene, benzo(k)tluoranthene, ohrJs..,
d1b8uo(a,h)anthraoen., and 1Ddao( 1,2,3,-ocS)p7Nne) are the ujor
'.
OODt-." a-Gts ot OOD.rD. Other OODtA-" "9ats ot OOD08I'D (b8D.ZeD., ao.ton.,
Z71.., .th71b8D.Z.., st;rrene) V8N eleteoted at the 81t. 1D both sol1 &Del
8I"OUIUIvat.r. lov..er, the II .tat.. that 8a renew ot the qua1.1t1
_unDO. 1DtoNat1on ahoved that beDS.., ..toD., &Del other yolatl1.
orpaio. appeared 1D the aulrtioa1 result. Hoaue ot laboratorr
oODt-."".t1on8.
-
mlVIRORMD'l'.1L PJ.'l'RVJ.YS
IDYUoDII.tal pathvaJs 1Dolude .urtao. and subsurtao. .011, on-ut.
81U'tio1a1 aroUDclvater, ahallov art.81&D aqu1ter arouHvat.r, &Del .8cl1a.t.
tJtaa _au BODtouoa, the vest.I'D oreek, &Del dra1.ua. ohazm.l.
ftPOSDU PJ.'l'RVJ.YS
Pot_t1&1 apG8UN pathva1. 1Dolude 1Da..tion ot OODt-."„ted aroUDclvater
tI'08 the ahallov artea1&D aquiter, 1DaestiOD ot OD-at. 8011., &Del
iDa..tioD ot OODt-."".ted ve.teI'D ore- or ...t8I'D oIIaDD.l 88dDents.
Deru1 OODtaOt .., also b. a apGaure patlnrar.
POPDLJ.'l'IOIi J.'l' RISI'
ft. potat1&1 population at risk 1Dolud.. 1) p8Opl. that .., u. the barou
(bulkhead area) tor reoreat1oD&1 purpo-, 2) p8Opl. liY1Da or vorld.Da
elon-lNd1-t 810lIl the 8ha11ov art..1&D aqu1ter, 3) people l1Y111a
_Jao.Dt to the 81t. .sp.01&111 the V88terD 8d&., aDd .) oWcIr8D U1Da
the v..t8I'D orMk or the _terD cIra1Dap oIIaDDel .. pl&) areaa.
ft. U.S. 08010810 Sune)' caloulated 110 res1d.oes v1th1D 1 1111.. 1D the
aup.otecl direot1on ot trayel ot the oont8ll1natect plUlie 1D the ahallov
art.s1&D aquiter. Baaed on 1980 oenaus data tor this area this aooounts
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. I
Pace - - Mr. Carl Hickam
DISCDSSIOH
!lladfmeDt
%D 1916 tvo Cout Guard d1.v. reoe1.ed ...GOAd d..... bvu. dur1D&
Hcu.a8Dt "'PliD8. 1'h1a 1Do1deDt baa bea oorroborated br the Publ10
B881th &dy180r. BrA RepoD VI. It vaa the oonolua1on ot.'the 1D8ta1laUon
l18d1oa1 autbor1tr that treated the Cout Guard cU"... that vater ad
88d1aeDt OODt-." ftA"t.. ap801t1oal1r. V8N I'88POD81ble tOl' w.a etteot. .&
a1te .1a1t bJ the Pub110 Bealth &dY180r to the area cU8OCW8I'8d other
1IIo1d8Dt. vberebr area ru1d.t. Nported 8k1D 1rr1tat1oD attv ""-4111
01' vad1Da 1D 01' azoouDd the bulkhead area ot the laJou. Parer boat.
oIaurD1Da up the OODt-." "ated .8d1aeat. vh. pua1D& br tIda area 887
apo.e av1ava ua1D& th1a area tor NOreat1on to poaa1ble ob881oa1
buru. 81Doe laborato!'J oODtu1nat1oD ot .01atl1e orpn1o o08J)OUDd
(VOC'.) _plea vaa a poa.1b111tr (doo. 3 pert.-""f"l to ...e --8.
Seot1OD '.3.2 doo. 1). th- Naapl1Da tor VOC'. at the IQou Iolltouoa
Site (bulkhead area) abould be Npeated to rUle out the.. .-poUlUS. ..
a1te oont-."a--ata, aDd u . po.sible oaue tor the reported 8k1D irr1tanta
1D the Cout Guard cU..... ad other area I'881d.t.. !beNtON, a1Doe V8
baye DO erid_o. to Ntut. thi. 1IItorut1on it 887 be prudeDt to retra1D
tI"CII 8DJ UDDeoe888I"J reoreaUoaal aot1rit1.. until Naup11Da 01' 1'888d1a1
ettort. haye be. aatiataoto..l1r OCIIPleted on the IQou Bcmtouoa bulkhead
area.
Potable a~ Vate..
!be III .tat.. that pr18arJ dr4"lri"l vater .hDdvd. tOl' 1Dorp.n.108 ...pled
tJICIII tb8 81II't101a1 aquiter aDd the 8ba11ow artuia aq1d.t.. (ar88D10.
O8d81ua, bar1_, .el8D1U1D, lead, obrcIII1ua) V8I'8 ao88ded at V8l1 ...t B.
fte III turther .tate. that the .t pi N.out ad ueable. aroaD4vater
"'801lI"O" 1D the area do DOt 1DolWSe the aurt101a1 aquit.. 01' the 8Iaa11ow
art881aa aquiter. Mo..eoyer, th..e vatv 801lI'O" &1'8 1"."t.d 1D the
ab111tJ to tranapo..t vate.. and OODt-."".~t.. fteN 1. DO kDovD
OODaUIDpt1oD ot vater trom e1the.. the aurt10181 aquiter 01' the aballov
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Paae 5 - Mr. Carl B10kam
vith1D a one aUe radius ot t.he. a1te have been dr11led throuah the ahallow
artea1an aqu1ter vith no deaonatrated oreo80te oontu1Dat1on.
JQ.U
!be prinoipal on-ate Pd oono8Dtrat1ona l"8II&e t'rc8 lot Deteoted (I»)
to 13."'50 ppl in 88d1a8Dt. JD) to 13.680 PP8 in 8011 and II) to 5 ppa in
JI'OUDdvater. 1'I1e veatern oreek and _tern oJIaDDel 8NU are oODt...4a.teel
vith the Pd'. (lID- 8'0 PP8 and JD) - '96 PI8) reapeot1vel7. and are
1JIIJ"88trioted to ob1ldren. In a publ18hecs art1ole1. the Catera tor
D18..e Control (CDC) derived aD aoUOD level at vh10b to 1Ja1t hu8aD
ap08U1'8 tor 2,3,1,8-tetraohloro- d1beuo-p-41oz1D (2.3.1.8.-TCDD)
oODt...4"ated re.1dent1al 8011. 'fb18 derived value vaa baaed upon
extrapolat1ona troll .,,411..1 toz101tJ aper1a8Dt. (inolud1Da oaro1Doa8lL101tJ
and I'8produot1ve etteot.) to po..1ble bUII8D health eft_ta in order to
..t18at. a .....0D&b1e level ot ri8k tor 2.3. T .e-tCDD. .. 1~-6 80...
l1tet£ae riak 11&8 uaeeS 1D the. developa_t of tb1. ft:DD 8011 level.
1'11. IDv1l'olUlental Proteot1on .&a8DOJ'. Caro1Doa8D _....eAt Group has
derived a relative potenoJ 1DcIa tor 801'8 tbaD 50 obl81oal.2. 1'I1e order
ot up1tude pot8DoJ index tor 2.3.1.8-'l'CDD 18 e1Pt. vb1le that tor
beuo(a)PJNne 1. ODlJ three. 'fIma. 2.3.1.8-TCDD 1. oonaUerecS to be t1ve
order. ot 88&D1tude .ore pot8Dt .. . oaro1Do&8D than baso(a)PJNne.
U81D& th1. order ot aap1tude d1ftereDoe in pot8DoJ betveen the two
ob881oal. and the CDC-der1ved l'881d8Dt1al 801l aot1on level. pv.. 100 ppa
ot beuo(a)PJNDe equivalent to 1 ppb ot 2.3.1.8-TCDD in 8011.
ID th. 8Od81 U88d to derive the 2.3. T . 8-'l'CDD 801l value. the &88U8pt1OD
OODoel'D1Da th. _ount ot 8011 _e.ted has be. aboIID to be 1dCb. 1
NO_t unpub118hecl atudJ bJ CDC has 8hoIID the aaount ot 8011 _..teel bJ
ob11dren ot the ao11-eat1Da aae l"8II&e. troll 0.1 to 1 IN8 per d&J
(S. BiDder peraonal oommUD1oat1on). 1'I1ue. the .odel e.t18&te tor 8011
1Dae.t1on dur1Da the period ot lI1D1mum hJa1ene 1. uoe..1 ve bJ at l_at aD
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,..e 6 - Mr. Carl B10kam
al80 e.t1Jlate.. t.here 1a a Sood likelihood that the1 are al80 111 error.
po881b11 b1 .ore than aD order 01' II8ID1tude~ ~U8. the aodel yeJ8J' like11
OftN8taat.. the total 1itet1ae 8011 1qe.tioza GpOaure b1 at l..t one
order 01' aap1tude.
"
In addition. the lIOdel oonta1D8 a taotol' to aooOUDt 1'01' the 8Irf1I'oD8atal
depoadationot the .1'801110 Gha1oal. fte taotol' tOl' 2,3,1,8-1'CDI) ..818ed
. 12-18&1' hal1'-l1te 111 8011. VlLUe thenuaerG. PAS'. haye a l'8DIe ot
JIalt-lite Yaluea iD 8Ul'taoe 8011, vhiGh v111 be depead8lat upoD the
apeoiti0 .011 &Del oU8atolO&1oal oOlUSitiou _00UDt8Nd, 8ftD the -7:1-.
hal1'-lite tol' the .oat desradation-l'U1atant OC8pOUDd i. 1- than the
Yalu. ".lcDed tOI' 2.3.T.8-TCDD 111 the 1IOd81. BY- vith a aU 18&1' halt-
lit.. a per8On' a 11tet1ae expo.ure would be .ub.tantial11 Nduoed when
o08p8l'8d to that eat1Jlated vith the 1011&81' hal1'-l1t. U88cI iD the 1'CDD I'i8k
,
".--8lat.
III addition, viae oouidel'1I1& the .1l"itioanO. of oont-4...tion at the
a1te, the taot. that all PAB'. are uither oaI'01Doa8D10 nor (t'or tho..
8Up80ted O&I'OiDoS8D8) .. potent.. beuo(a)PJND. ..t be a part ot the
en1uation. A.8 a tuat approz1aatioza ot a a1t., it .., b. Yal1d to ..
the total PAS oono_tration to d.tera1De aD eat18at. of th. .~1J"4'iO&Doe
ot' the 00nt-.411.tion. lovner, vhen deter-tilt", ol88Dup aotiOD, the ~.
ot'i8C8er. and ooapoUDda. vb1Gh aN trulJ huardoua, 1IOU1d be 8O.t
appropriate vba that iDtoruUOI1 18 aft1lable.
!lie applioatiOD ot the 1IOd81 --- that all PAS'. .... u pot8lat ..
b8u0(a)PJNI1., ..vall, 00D81deNd to be the .o.t potat O8I'01I101a ot
tIa8 PAS'.. ft18 1a not Yal1d, .. t!MHI. PAS 0C8p0UDda vb10h aN oou1d8Nd
to b. auapeated 01' probable 0&1'0111018118, OC8pl'i.. 1- tILua ba1t ot the
total PAS oODoentrat1on at &a1 a1te. In add1t1OD, 8U.J ot the.. oe8pOUDd.
deaipated u aU8peoted or probable 0&I'01I101el18. aN IIUOIa le.. potent than
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,..e 7 - Mr. Carl B101eam
!bua. ooaa1d.r1Ds oal7 the.e tvo area. tor 8Od1t1oat10Da to the 8011
Gp08W'8 aod.1 used to deyelop the 2.3.7.8.-TCDD r1ak _...ent. a
N814u. 1- thaD 100 ppa ot PAl'. 1D ru1d_t1a1 8011 doe. DOt pre.ent a
Ia188D b8a1 th huaI"d. S1Doe the v..t.1'D oreek &lid _t8I'D ohama81 are
ooat--4"at8d vith PAl'. hiper thaD 100 ppm it would be adY18&bl. to
rutr10t aoo... to ohUdra who -7 p1., ~ or aromut th... ....... UDtl1
...M1aUcm .tton. are p.l'toN8d.
mIIl!LUSYOII
!be laJou BoIatouoa bu1Jd18&d area 18 ocmt---4 pteeS &Ad ..; po.. 811 aout.
pot_t1a1 pub110 health threat to pvsou ua1Dc thi. MOUcm ot th. BalOU
tor NON&t1OD&1 &Ot1Y1t1... Th. N.1deno.. to th. 80Uth 8IId southw..t ot
tJa. 81t. aN pot8Dt1a117 aft_teeS bl oonta..4".at a1arat1on ott-.1t..
PJII'. oOD08Dtrat1oD8 1D N81dent1a1 8011 80N thaD 100 ppa pN.8Dt. 811
aaaoo.ptabl. pUbU,o health 1'18k throup 8D7 Dor8l rout. ot apoaure.
DCnMWIJftllfI08S
1. ....p1. Barou .8cI1II.nt tor yo1atl1. orpD1o oC8pOuA4..
2. ...tr1ot aoo... to the b~ area tJ'CIIl'8OI'88t1oD8l &ot1rit1..
atl1 N888P11Da tor VOC'. d880D8trat.. that 811 &out. adyv.e health
8ft.ot tJe08 d.rmal .xp08Ul'. doe. Dot ai.t.
3. ...tr1ot aooe.. to the v..t.1'D 0I'88k &Dd _t.1'D ohama81 area.
,. ConUlau. 8OD1tor1q aroUDdvat.r. 8011 8IId .8CI1a8Dt p1_.. that tor
po881bl. ott-81t. a1&rat1on
E~~L
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...e 8 - Mr. Carl lU.akam
RlP'!RDCES
1. I18brouab, R.D., Palk. B., Stehr, P., aDd rr~e., 0., .Health
%IIpl1oat1ona ot 2,3,1, 8-tetzoaohlorod1beuocU.oz1D (!CDD) CoGt--4 -t1OD
ot le.1dent1al Soil,. J. 'fox. . BD'Yu. Bealth, " '1-93, 19M.
2. 1P1, .Iealth "aea.at DooUliat tor 1p1ohlorola7dr1Di' P1Dal leport,.
1P1-600/8-83-032P, pp. 1-62, 198'.
3. "BnluatiOD ot the CaroiDoa8D10 I18k ot Cbl81oa18 to ....,
PolJDuo1ear Arout10 CoapoUDd., Part 1, Cb881oal, 1DY1roD8_tal 8Dd
!Kper1aatal Data,. thC MaDqaPaDU, Vol.. 32, IDt.....UOII81 As-oJ
tor l..-roh OD CaDoer, II1C, LroD, l'NDo8, 1983.
,. BPI, Otti08 ot Dr1Dk1Da Vater, Criteria aDd StaDdarda D1ri.81on, Draft
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(4
DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Agency for Toxic Substances
and Disease Registry
Atlanta GA 30333
March 27, 1987
,"
MEMORANDUM
SUBJECT:
Bayou Bonfouca Remedial Evaluation from the
Agency for Toxic Substances and Disease Regi~strY
Carl Hickam, Senior Public Health Advisor
Agency for Toxic Substances and Disease Regi try
Kathleen O'Reilly, Geologist
ALONM Remedial Section (6H-SA)
FROM:
TO
The Region VI office of the U.S. Environmental Protection Agency
has requested the Agency for Toxic Substances and Disease Registry
(ATSDR) to review and comment on the proposed alternative to be implemented
in Slidell, Louisiana. After careful review of the data from this site
the following comments regarding this proposed cleanup alternative are
provided by the scientific staff of the Agency for Toxic Substances and
Disease Registry.
Onsite incineration of the wastes at this site, using current
technology, would protect public health by destroying the material. It
would also eliminate the requirements for either onsite containment and
monitoring, or offsite transportation and either containment and
monitoring or destruction. ATSDR agrees with Region VI's plan for
onsite destruction of the creosote contaminated waste piles, soil, and
sediment.
The Agency for Toxic Substances and Disease Registry if requested,
will review any data that might be generated from the implementation of
the proposed remedy.
The Agency does appreciate the opportunity to comment on the
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.
Martha A. Madden
SECRETARY
ornCE OF SOLID AND HAZARDOUS WASTE
JOHN KOURY
ASSISTANT SECRETARY
March 11, 1987
Mr. Allyn M. Davis
Director
Hazardous Waste Management
US EPA Region VI
1201 11m Street
Dalla.. Texa.
Division
75270
Dear Mr. Davis:
Based upon a review of the Draft Feasibility Study, the Department of
Environmental Quality concurs with the proposed remedy for :he Bayou Bonfouca
Site with the following comments:
1) It is understood that concerns of local residents as to possible
adverse impacts of the project on local drainage will be fully considered
during the engineering design pha.e.
2) The Department of Environmental Quality will likewise be interested
in any technical issues related to alteration of stream flow and/or
disturbance of sediments to be considered during the engineering design phase.
If this office can be of further assistance, plea.e feel free to contact
us.
HAM/WBD/de
INACTIVE AND ABANDONED HAZARDOUS W i\STE SITES DIVISION
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