United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R06-87/020
March 1987
£EPA Superfund
Record of Decision:
-------
TECHNICAL REPORT DATA
(Please ,ead flUlructions on the ,evene befOfe co",pleting)
,. F!lE'ORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R06-87/020
.. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION March 31, 1987
Cleve Reber, LA e. PERFORMING ORGANIZATION CODE
First Remedial Action
7. AUTHORISI 8. PERFORMING ORGANIZATION REPORT NO.
,. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Report
401 M Street, S.W. 1.. SPONSORING AGENCY CODE
Washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
1e. AB5TRACT
The Cleve Reber site is located in Ascension Parish between Baton Rouge and New
Orleans, Louisiana. Originally a burrow pit for the construction of a local highway, it
was sUbsequently used as a landfill for both municipal and industrial waste. There _are
an estimated 6,400 drums buried at shallow depths on this 24.6 acre site. The site ties
within a 100 year flood plain and the area surrounding the site may fall within the
wetlands classification. The site currently contains four surface water ponds. Between
1970 and 1974, it was used as a landfill for both municipal and industrial waste. No
records of the waste received at the site are available. The wastes were reportedly
segregated into municipals, chemical waste piles and landfilled. Numerous drums
containing chemical wastes were buried onsite. Volatile chemical wastes during handling
and disposal reportedly resulted in nausea and illness to the landfill employees. In
1974, the site was abandoned and in 1979 declared an abandoned hazardous waste site by
the State. In 1983, the State fenced in the site due to local concern; and in July
1983, EPA conducted an emergency removal. Approximately 1,100 surface barrels were
removed in addition to surface waste piles. A thin clay cap was placed over the areas
thought to contain buried drums/wastes. After two comprehensive field investigation
efforts, starting in July 1984 and January 1986 respectively, EPA determined that all
significant contamination was restricted to the site. The primary hazard of concern is
(See Attached Sheet)
17. KEY WORDS AND DOCUMENT ANAL YSIS
a. DISCRI~TO"'S b.IDENTIFIERS/O'EN ENDED TERMS C. COSATI Field/Group
Record of Decision
Cleve Reber, LA
First Remedial Action
Contaminated Media: gw, sw, soil,
sediment
Key contaminants: hexachlorobenzene,
organics
18. DISTRIBUTION STATEMENT ". SECURITY CLASS (Tllis Report) 21. NO. OF PAGES
None 65
20. SECURITY CLASS (Tllis page) 22. PRICE
.
e,. 'CHili 2220-1 (R....4-77)
-------
EPA/ROD/R06-87/020
Cleve Reber, LA
16.
ABSTRACT (continued)
associated with the buried drums and bulk sludges with as the primary
contaminant of concern. It has a high affinity for the local days. This
coupled with a small ground water gradient, are reasons to believe that to
date, contaminant migration has not spread beyond the site boundaries.
However, the potential exists for future migrations and contamination. The
contaminated media includes: the ground water, surface water, soil and
sediments.
The selected remedial action includes: excavation and onsite
incineration of buried drums and sludges; drainage and backfilling of onsite
ponds (with solidification of nonincinerable wastes, notably mercuric
sulfide); capping the portion of the site that was used for the disposal of
industrial/hazardous waste; ground water monitoring (remediation is not
considered necessary). The estimated capital cost is '25,000,000 with
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,.
v
"
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CLEVE REBER
ASCENSION PARISH, LOUISIANA
-------
TABLE OF CONTENTS
EXECUTIVE SUMMARY
...... ............ .... ...... ...... .........
i
oj
SITE LOCATION AND DESCRIPTION ...............................
1
SITE HISTORY
...........................................-.....
1
CURRENT SITE STATUS .;.......................................
7
ENFORCEMENT ................................................. 21
ALTERNATIYES EVALUATION ..................................... 21
COMMUNITY RELATIONS ......................................... 29
CONSISTENCY WITH THE PROVISIONS OF SARA ..................... 29
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS ................... 30
RECOMMENDED ALTERNATIVE ..................................... 33
OPERATION AND MAINTENANCE ................................... 35
SCHEDULE ...............................................~.... 36
FUTURE ACTIONS .............................................. 36
~.
APPENDIX A - Agency for Toxic Substances Disease Registry/
Centers for Disease Control (CDC) Evaluation(s)
APPENDIX B - Community Relations Responsiveness Summary
APPENDIX C - ARARs
-------
.
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
.4
Site: Cleve Reber. Ascension Parish. Louisiana.
DOCUMENTS REVIEWED
I have reviewed the following documents describing the analysis of cost-
effectiveness of remedial alternatives for the Cleve Reber Site:
- Remedial Investigation Report (RI); Cleve Reber. May 1985.
- Feasibility Stu~ Report (FS); Cleve Reber. M~ 1985.
- Supplemental Report to the Cleve Reber Site; Remedial Investigation
and Feasibility Stu~. September 1986.
- Public Health Evaluation; Cleve Reber Site. September 1986.
- Summary of Remedial Alternative Selection. Cleve Reber. March 1987.
- Community Relations Responsiveness Summary. March 1987.
- Staff summaries and recommendations.
DESCRIPTION OF SELECTED REMEDY
- Excavation and onsite incineration of buried drums and sludges.
- Drain and backfill onsite ponds.
o Nonincinerable waste will be solidified.
~ RCRA cap.
- Groundwater monitoring (remediation not considered necessary).
DECLARATION
Consistent .nth the Comprehensive Environmental Response. Compensation.
and Liability Act of 1980 (CERCLA) as amended by the Superfund Amendments
Reauthorization Act of 1986 (SARA) and the National Contingency Plan
(40 CFR Part 300). I have determined that the selected reme~ for the
Cleve Reber Site is cost-effective and provides adequate protection of
public health. welfare. and the environment. The State of Louisiana
has been consulted and agrees with the approved remedy. . The action
-------
2
'.
has been consulted and agrees with the approved remedy. .The action
will require future operation and maintenance activities to ensure the
continued effectiveness of the remeqy. These activities are considered
part of the approved action, and eligible for Trust Fund monies for a
periOd up to one year.
The remedial plan will also include long-tenm 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.detenmined
that the action being taken is appropriate when balanced against the
availability of Trust Fund monies for use at other site.
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i
EXECUTIVE SUMMARY
f
The Cleve Reber Superfund Site is located in Ascension Parish, Louisiana.
Originally a borrow pit for the construction of a local highway, it was
subsequently used as a landfill for both municipal and i~dustrial waste.
After citizen's compliants about the site and follow up inspections by
the State of Louisiana the EPA conducted an emergency removal of
approximately 1,100 surface drums and chemical ~ste piles in July
1983. According to records received from the potentially responsible
parties, there are an estimated 6,400 buried drums of hazardous substances
buried onsite.
After two comprehensive field investigation efforts, starting in July
1984 and January 1986. respectively, the EPA has detenmined that all
significant contamination is restricted to the site. The primary hazard
of concern is associated with the buried drums and bulk sludges.
Although the area drinking water aquifer (Norco) has been found to be
free of contamination. contaminant migration has occurried in a thin
water bearing sand zone located at approximately 30 feet below the surface.
Contamination has not. however, spread beyond the site boundaries.
Hexachlorobenzene. the primary contaminant of concern has a high affinity
for the local clays. This was estab1isbed during the field investigation
and supported by literature. This coup1ed with a very small groundwater
gradient. are the reasons it is believed that contaminant migration has
not s,read beyond the site boundaries th,"; fa~. The potential exists,
however, for future migration.
After reviewing numerous remedial alternatives. the EPA has proposed
complete excavation and thenmal destruction of all buried drums and
bulk sludges. The thenmal destruction unit envisioned would be mobile.
Included as part of the remedial action would be the draining and
backfilling of all site ponds and ultimately a multilayered clay and
-------
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CLEVE REBER
..
SITE LOCATION AND DESCRIPTION
The Cleve Reber site is located in Ascension Parish between Baton Rouge
and New Orleans, Louisiana. It is one mile south of Highway 22 on the
east side of Highway 70. Reference Figures 1 and 2. The site is
rectangu1ar in shape with an area of approximately 24.6 acres. The
adjoining land areas to the east and south are covered by swamps and
dense vegetation. The areas to the north and west are primarily
residential with some agricultural uses. The residential areas are
sparsely populated.
The site contains four surface water ponds as shown on Figure 3, and an
estimated 6400 buried drums at shallow depths. The site and surrounding
area is relatively flat and exhibits the characteristics of high-water
areas prone to periOdic flooding and poor drainage. According to the
U. S. Army Corps. of Engineers, the site is within the theoretical 100
year floodplain of both Lake Maurepas and Lake Pontchartrain, located
approximately 15 and 26 miles respectively, to the east.
The primary natural resources in the area that could potentially be
adversely affected by the Cleve Reber site contaminants are the
groundwater and surface water. The site is underlain by approximately
220 feet of very plastic clays. Within this clay formation is a clayey
silt/silty sand strata of varying thickness located 30 to 50 feet below
the ground surface (Shallow Sand). This zone can be categorized as a
thin aquifer, tut its groundwater is not known to Le u$ed ~ any area
residents. Located approximately 170 feet below this zone of higher
permeability is another sand strata that is approximately 10-15 feet
thick (Deep Sand). Below this and separated by a 10 foot thick clay is
the Norco Aquifer (See Figure 4). The Norco Aquifer is the natural
resource of major concern. This aquifer is a surface flowing artesian
aquifer and is the primary source of fresh water in the vicinity of the
site, as well as a major source of water within Ascension Parish for
both industria. and private use.
Surface wAter and sediments may also be affected by contaminant run-off
from the site. Surface drainage from the site is from east to southeast
to the Panana Canal, which flows east and drains into a swamp that
empties into the Blind River. The Blind River discharges into Lake
Maurepas and then to Lake Pontchartrain.
SITE HISTORY
The Cleve Reber site, previously referred to as the Ascension Parish
Sanitary Landfill during its operation, was used as a source of borrow
material in the construction of the embankments for the Sunshine Bridge
and portions of Interstate Highway 10 prior to its use as a disposal
-------
2
CLEVE REBE
SITE
JACKSON
...
,.
of
SITE
---*
LOU ISIANA
MISSISSIPPI
RIVP
MISSISSIPPI
LOUiS I AiiAJ
I
,
-
~} {l
~. ) ...,.
~) ).. " . . }. .
'... , .. ,) . J). "
f,,),)_,.. ~
.\,:),",, )),..1\; .If
.Jt
~
SMa: (1) Elite". Stites South
"'p, _rte." AutOlllltlt 1.
Asloct.tton, ICI1e: 1-.30
tit Ie..
@,
o
30
I~
SCALE IN MILES
45
FIGURE 1
SITE LOCATION MAP
-------
of
o 0 0
)
-
ItE8EIt SIT!
\
.J\
/ \
.,
/
-------------------~
STAT! HIGHWAY
r.' .....,-....."
.
.. _0
~-
-... - -
10 -- - -
- ..
- -
I
~.)1 "
/"
SOURCE:
(1) U.S.G.S. 7.5' Topogr,phfc ",ps, Goftz.1es Ou.dr.ft,1e.
Loutsf'ft'. D.tld: 1961. 'hotorevfsed 1980 .ftd
Sorreftto OuIdrIft91.. Loutsf'ft', D.t.d: 1962.
PNCort'IisM: 1_. Se...: 1-. 2.000"
@
0 ..
..
IeALI ,-. 2IDaD'
FIGURE 2
SITE VICINIT'
CLEVE REBER ~
-------
. .
...
4
'.
" "-, "
" ;v .~:~ :.
,'..." l ~ ;', ' --
.J I;, '---
~.J"'" C. ::.. -: c - - ~
~::::---- -',', - - -~ r-> ",
.- .' '-----
,~t.~ ,. --, \ '
rr- .' :-~.~ I
I _. . ..---'
. -. -.. -1,
~ -'
~\ 'I
POND A ,', ...I"
.
~ -
r
~
.
:;
:
!
....
..
~
..
.
~
B
c
..
!
~
..
..
c:
(\.
."'"
- .~~~.~~. ..----,,-
--==..~..:.-. It.
SOURCE:
(1) ..."" .... -'
...,...
lat. of PttofIPfltf '"d I
Se.,., ,. t09r.~..' ..,1".'.""
. . 100' ,. ~r11 l ~
3. 1984
.
WASTE
PIT
@
o
2S0
125
SCALE IN
FEET
~
FIGURE 3
EXISTING S
ITE C
CLEVE "£IE ONDIT IONS
-------
5
~
DEPTH (FT.)
o
50
10C
..
1'0
~cc
2S0
260
. .
CLAY AND SILTy CL.AY
C~A"'£Y SIL.T A~O
SILTY SA~O (Shallow Sand;
CU,y A~: SIL.TY C~AY
SA~~ (Deep Sand)
CLAY
NORCO AQUIFER
FIGURE 4
GENERALIZED GEOLOGIC S£CTIO
-------
,
6
t
The site was originally used as a landfill for municipal waste but was
later used for industrial waste. During the period of 1970 and 1974,
both municipal and industrial wastes were received at the site. No
records of the waste received at the site are available. The wastes
were reportedly segregated into municipal and ~hemical ~ste piles and
hndfil1ed. Numerous drums containing chemical 'wastes were reported by
employees of the site and waste generators to have been buried on site.
Spillage of volatile chemical wastes during handling and disposal
reportedly resulted in nausea and illness to the landfiH employees.
The site was abandoned in 1974.
After many site inspections and sampling efforts, the site was declared
an abandoned hazardous waste site by the State, in October 1979. The
state fenced the site in 1983 due to local concern, and in July 1983,
the EPA conducted an eaergency removal. Over 1,100 surface barrels
were removed in addition to surface waste piles. A thin clay cap was
placed over the areas thought to contain buried drums/wastes.
In July 1984, a Remedial Investigation (RI) was initiated by the EPA.
An additional field investigation was undertaken in February 1985 to
better characterize the site. I The RI/FS was completed May 30, 1985,
and a public meeting was held on June 26, 1985.
During the week of June 10, 1985, additional groundwater samples were
collected at the site in an effort to analyze for certain contaminants -
at a concentration level consistent with their 10-6 lifetime carcinogenic
-health risk factor.
The primary compound of concern ;s hexachlorobenzene (HCB). It has a
10-6 carcinogenic health risk factor of 21 parts per trillion (opt).
The standard C')ntract Lab Program (CLP) detection limit is only 10
parts per billion (ppb). The Region became aware of this discrepancy
in May 1985 when the Feasibility Study guidance document was finalized.
The 10-6 cancer risk for HCB was publiShed in this guidance report. In
order to ensure that the site related risks were adequately defined, the
Region lowered the analytical detection limit for HCB to 5 ppt and
resampled select onsite and offsite wells. The onsite wells sampled
were both shallow (approximately 30') and deep (200') and the offsite
wells were residential (approximately 300 feet).
The additional groundwater results were not received until July and,
therefore. were not known prior to the public meeting. At the time it
was decided to hold the already scheduled public meeting since sampling
efforts to date had not shown any contaminant migration, the area
clays were considered very impenmeable, and because a computer model
had predicted that it would take in excess of 1500 years before
contaminants would reach the Shallow Sand. Considering the site a
secure natural "vault", the Agency proposed a cipping-in-place remedy
during the public meeting.
As stated, the sample results from the June 10, 1985, sampling effort
were received in July 1985. Contrary to what was expected, HCB
-------
7
'f
however, placed in the Norco were clean). Because of thi~ the Agency
decided to postpone a final decision on a preferred alternative remedial
action until the extent of, and health risks associated with, the
groundwater could be more definitively characterized.
Workplan development for the new ppt groundwater investigation began in
August 1985 and field work began in January 1986. This supplemental
investigation was completed in April 1986 and a final report was issued
on September 30, 1986, (Supplemental RI/FS). Included in this report
is an expanded analysis of innovative remedial technologies for
implementation. A ris~ assessment report was also written (Public
Health Evaluation, September 30, 1986).
CURRENT SITE STATUS
General
The results .of the laboratory testing of the field samples collected
during the original and supplemental RI indicate that all significant
conta.fnation is restricted to the site. Onsite media including the
surface water, waste pit leachate, surface soils, subsurface soil/material
and pond sediments were contaminated with organic pollutants. Groundwater
in the Shallow Sand beneath the site showed elevated levels of HeB,
Hexachlorobutadiene (HCBD) and hexachloroethane (HCE). Although HCB is
the primary contaminant of concern, HCBD and HCE were also analyzed
since they are related compounds and are believed to come from the sam~
waste sources. HCBD and HCE are also thought to be more mobile than HCB.
With respect to air, the ambient air quality of the site is within
background levels and elevated concentrations of organic vapors are
encountered only when the surface of the site is disturbed.
Inorganic ana1yses indicated a wide range of concentration levels in the
onsite media and in background samples. No consistently high concentrations
were observed. This made qualitative evaluations of any inorganic
concentrations found very difficult and impractical; therefore inorganics
were not considered for use as indicators of contaminant migration.
(Based on infonmation supplied by the potentially responsible parties,
however, mercuric sulfide was disposed of at the site).
. The primary organic pollutants of concern include hexachlorobenzene.
hexachlorobutadiene. N-nitrosOdipheny1am1ne, hexachloroethane and
tetrachloroethene. All of these cont..1nants are considered to be
carcinogens by the Cancer Assessment Group of the U.S. Public Health
Service. Table 1 indfcates the health standards and criteria that are
potentially applicable to the Cleve Reber site. (The primary contaminants
of concern during the supplemental RI were HCB. HCBD and HCE; HCB is
considered the most carcinogenic of the site contaminants and HCBD and
HCE are indicators). It is important to note that these criteria are
based on the ingestion of water and/or aquatic organisms. The approach
used to evaluate soil and sediment contamination was to compare the
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8
Table 1
CLEVE REBER SITE
STANDARDS AND CRITERIA POTENTIALLY APPLICABLE TO UNCONTROLLED
HAZARDOUS WASTE SITES
"
Semi-Volatile Parameters
Clean Water Act
Water Quality Criteria
for Human Health 1
JCarcinogenic Risk-10-6
Safe Drinking
Water Act
MCLS
2,4,6-trichlorophenol
pentachlorophenol
phenol
hexach'orobenzene
hexachloroethane
1,2-dichlorobenzene
1,3-dich1orobenzene
1,4-dichlorobenzene
fluoranthene
hexachlorobutadiene
hexachlorocyclopentadiene
N-nitrosodiphenylamine
diethyl phthalate
Volatile Para.eters
(1.8)
1,010
3,500
(21.0 ng/l)
(2.4)
400
400
400
188'
(0.45)
206
(4.9)
434 mg/l
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
benzene
carbon tetrachloride
ct'lorobenzene
1,Z-dichlo,oethane
1,1,I-trichloroethane
1,1,2-trichloroethane
1,1,2,2-tetrachloroethane
chlorofonn
1,1-dichloroethene
1,2-trans-dichloroethane
ethyl benzene
methylene chloride
fluorotrichloromethane
tetrachloroethene
toluene
trichloroethene
vinyl chloride
o-xylene
Inorganic Parameters
(0.67)
(0.42)
488
(0.94)
(1. 9 mg/l )
(0.6)
( 0.17)
(0.19)
(0.033)
NA
2.4 mg/l
(0.19)
(0.19)
(0.8)
14.3 mg/l
( 2.8)
(2.0)
NA
NA
NA
NA
NA
NA
NA
NA
100
NA
2,700*
NA
NA
NA
NA
NA
NA
NA
12,000*
"antimony
arsenic
barium
beryl 1 i um
(14.6)
(2.5 ng/l)
NA
(3.9 ng/l)
NA
NA
NA
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9
Table 1 Continued
CLEVE REBER SITE
STANDARDS AND CRITERIA POTENTIALLY APPLICABLE TO UNCONTROLLED
HAZARDOUS WASTE SITES, , .
.,.
Inorganic Parameters
cadmiull
chromium
copper
iron
lead
manganese
mercury
nickel
seleniwn
silver
thall i um
zinc
Clean Water Act
Water Quality Criteria
for Human Health 1
JCarcinogenic Risk-l0-6
(1.2)
50
1,000 (organoleptic)
NA
50
NA
10
15.4
10
50
17.8
5,000 (organoleptic)
Pesticide Parameters
endosulfan II
PCB 1260
138
(>6.2,ng/1)
Units: ug/l unless otherwise specified
* value represents suggested no-adverse
for one day exposure
NA not available
1 ingestion of water and organisms
organoleptic - taste and odor properties
. Safe Drinking
Water Act
MCLS
NA
NA
1,000
300
NA
50
NA
NA
NA
NA
NA
5,000
NA
NA
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10
..
background samples. The Agency for Toxic Substances Disease Registry
also helped in the evaluation/assessment of the soil.
The major volume of waste dispoSed of at the Cleve Reber site was
municipal waste. Industrial wastes with hazardous constituents were
also disposed onsite. Industrial wastes we're dfspoSed in both drums
and in bulk fonm. The laboratory test results presented in the RI and
data obtained from the PRPs indicate that hazardous organic compounds,
including solvents, were disposed onsite. Based upon test results from
the sampling of four leachate wells and results from two waste samples
within the waste pit, it appears that the hazardous substances have
migrated throughout the Maste pit and have mixed with the municipal
waste by way 0' the leachate.
Waste Pit
The limits and depth of the waste pit at the site have been investigated
using the results of onsite drilling and test pit excavations. The data
indicates that the depth of the waste pit varies from about 6 to 20
ft., with an average depth of about 10 ft. The limits and depths of
the pit, based on the test borings and test pits, are shown on Figure
5. (The potentially responsible parties, using historical photography
of the site have challenged the pit delineation - this is being reviewed).
The volume of hazardous waste reaaining onsite within the pit is calculAted
to be about 220,000 cubic yards. This includes drums and bulk sludges.
6,400 drums may remain buried onsite based on information provided by
the PRPs. The test pits excavated onsite suggest that the drums are
located along the northern and northeastern portions of the ~ste pit
south of Pond A. This is supported by a study of historic aerial
photographs conducteo by '.:he I RPs. The drums observed in the test pits
were rusted and leaking. Generally those drums above the water table
were in poor shape, and those below, in satisfactory condition. The
water table onsite is approximately 3-5 feet below grade.
The contents of the drums are not exactly known. Their relative hazard
has been assumed based upon leachate sample results (Table 2) and also
records/infonmation obtained from cooperating PRPs. The tenm leachate
refers to that liquid phase that is present at the bottom of the waste
pit. Leachate samples were obtained by drilling through the waste pit.
Onsite Ponds/Sediments
The volUie of onsite surface water in the ponds, based on depth soundings,
is calculated to be about 22,000,000 gallons. Of this volume only
500,000 gallons is considered contaminated. 21,500,000 gallons is
located in Ponds A and C - and has been found not to be contaminated.
Onsite surface water samples were taken during both the original and
supplemental field investigations. The results of the original
investigation are give" in Table 3. Ignoring lab contaminants, the
water in Ponds Band D is slightly contaminated and that in ponds A,
-------
of
-
w
:
w
..
.
I
i )
~I
\(!,
'. '\
,
, ,
,
.
-'
POND A
.
...
..
!
I
POND B
POND C
..
..
..
=
. POND D
..
..
~
.
~Ff..
SOURCE: (1) MartiMI Mlppift' Md (lI,tftHrtft9
Det. of PfIOt09rl"",: Apr11 U. 1984.
Se.1.: 1-. 100'
--
ESTIMATED DEPTH OF WASTE
ESTIMATED LIMITS OF WASTE ,IT
@
LEGEND
10'
o
250
12S
SCALE IN FEET
FIGURE 5
ESTIMATED DEPTH OF WASTE
-------
12
TABLE 2
SUMMARY LIST OF PARAMETERS IDENTIFIED
ONSITE LEACHATE
Number of Times.
Identified1
Range
...
Semi-Volatile Parameters
hexachloroethane
l,3-dichlorobenzene
hexachlorobutadiene
2
2
3
. .230-350
35-38
1,200-2,900
Volatile Parameters
benzene
chlorobenzene
l,2-dichloroethane
l,l,l-trichloroethane
l,l-dichloroethane
chloroethane
l,2-trans-dich~oroethene
tetrachloroethene
2
3
3
2
4
4
5
3
12-170
LT-l,OOO
49-800
150-150
85-4,900
LT-22,OOO
8.3-6,600
2,300-3,700
Notes:
1-5 samples taken
units: ug/1,
LT below detection limit, but greater than 1/2 detection limit
TABLE 3
CLEVE REBER SITE
SUMMA~Y LIST OF PARAMETERS IDENTIFIED
ONSITE SURFALE WATER
NlJ1Iber to T;mes
Identifhdl
Range
Semi-Volatile Parameters
2,4,6-trichlorophenol
hexachlorobenzene
, l,3-dichlorobenzene
1
2
2
20
57-80
26-31
Volatile Parameters
toluene
acetone
2
2
5.1-5.5
610-1,500
Notes
1 - Ten samples taken
-------
13
Two additional samples were collected from Pond A as part of the supple-
mental RI to see if it may be serving as a Source of low level ppt
contamination for the Shallow Sand since the pond's southern edge is
hydraulically connected with the northern face of the waste pit. The
results of analyses of these samples are shown below:
'II
. Sample 1
2
~
4
NO
~
.64
.41
~
28500*. .
71
* This sample is apparently affected by sediments based on the reported
sOlubility of HCB in water of 6000 ppt.
These results support the original Rl's findings that Pond A is not
significant1y contaminated with respect to existing surface water
quality criteria. The levels of contaminants detected are significant.
however. considering the 10-6 carcinogenic health risk factor for
drinking water of 21 ppt.
The likely reason for Pond A not exhibiting higher concentrations of
contaminants considering its location are that its volume is large so
as to dilute any pollutant concentrations and that it is flushed by
frequent rains and area flooding.
Site sediments were sampled during the original RI. Sediment samples
in all four ponds showed contamination well above background. The
sampling results are given in Table 4.
Surface So i 1 s
Surface so;ls were analyzed during both RI investigations. Onsite
surface soil concentrations are given in Table 5 and perimeter sample
concentrations are given in Table 6. The onsite soil contamination
is primarily located in the northern and northeastern portions of the
site. just south of Pond A. The offsite soil sampling results from the
Supplemental investigation are as follows:
Hexach1orobutadiene
Hexachlorobenzene
Hexachloroethane
Beta-BHC
220J
5100
+50 ft. +50 ft. +100 ft.
East East Dup. East +200 ft.
0".6" 0"-6" 0"-6" 0"-6"
300J 280J 220J 330J
Location
East De th
Site Perim.
0"-6"
Notes
All values in parts-per-billion (ppb)
-------
14
TABLE 4
oj
CLEVE REBER SITE
SUMMARY LIST OF PARAMETERS IDENTIFIED
ONS ITE SED IHENT
Number of Times
Identifiedl
Semi-Volatile Parameters
2,4,6-trich10ropheno1
pentachlorophenol
benzoic acid
l,2,4-trich10robenzene
hexach10robenzene
l,3-dich10robenzene
l,4-dich10robenzene
hexach1orobutadiene
N-nitrosodipheny1amine
benzo(b) f1uoranthene
dibenzo(a,h) anthra~ene
anil ine
dibenzofuran
1
1
1
1
7
3
2
5
1
1
1
1
1
Ran ge
1,500
2,800
11 ,000
1,200
1,800-640,000
10-15,000
15-880
25-5,400
5,100
1,600
1,400
1,400
4,100
Volatile Parameters
ch1orobenzene
toluene
3
3
22-21,OOU
LT-9,700
Notes:
1 - ten samp1 es taken
1 units: ug/kg
LT below detection limit, but greater than 1/2 detection limit
TABLE 5
SUMMARY lIST OF PARAMETERS IDENTIFIED
ONSITE SURFACE SOIL
Number of Times
Identifiedl
Range
Semi-Volatile Parameters
phenol
hexach10robenzene
l,2-dich1orobenzene
1,3-dich10robenzene
N-nitrosodipheny1amine
aniline
1
6
1
1
2
3
550
. L T -110,000
1,100
11, 000
740-7,600
3,900-47,OOU
Notes
1 - six samples taken
un its: ug/kg
-------
15
T AS LE 6
CLEVE REBER SITE
SUMMARY LIST OF PARAMETERS IDENTIFIED
PER IMETER SURFACE SOIL'
..
Semi-Volatile Parameters
hexachlorobenzene2
Volatile Parameters
l.l.l-tr;chloroethane
Notes:
1 - four samples taken
2 units: ug/kg
Q quantitated using seCOndary ion
2 QA prob1em data
NLlllber of Times
Identifiedl
1
3
Range
1.300
-------
16
The general findings are that significant soil contamination exists
onsite but not offsite. The residential yard samples showed no site
related contamination. Although samples taken east of the site indicated
contamination as far out as 200' the levels are not significant from a
health risk basis. ATSDR representatives have reviewed this data.
Groundwater
The subject of most concern and that which was investigated most
thoroughly was groundwater contamination. A generalized geologic cross
section of the Cleve Reber Site is shown in Figure 4.
The three major hydrogeologic units investigated were the Shallow Sand,
the Deep Sand and the Norco Aquifer. According to the data collected
there does not exist any contamination in either the Deep Sand or the
Norco Aquifer. The Shallow Sand is, however, contaminated immediately
beneath the site.
The objective of the supplemental investigation was to characterize
contamination in the Shallow Sand. The concern was not that site
contaminants were thought capable of migrating to the Norco, but that
either of two other exposure scenarios might occur: 1) An individual
could screen a well in this shallow zone sometime in the future and be
exposed to contaminated groundwater, or 2) A poorly cased well through
this zone to a deeper zone could allow contamination to enter the well -
through cracks. etc. and migrate downward to the deeper zone.
The supplemental groundwater investigation is described briefly in the
following paragraphs: .
This was thp. first time an attempt was made to collect and a,lalyze
field samples of these hexachloro compounds at the low ppt level.
Positive readings were found to result from any of a number of QA/QC
problems or actual contamination or a combination of both. In order to
interpret the sampling results one must understand both the ubiquitous
nature of the HCB compounds and the sensitivity of the ppt groundwater
investigation.
As discussed in the Supplementa1 RI/FS Report. all of the contaminant
concentrations found offsite could be attributed to either well
installation procedures. well materials. decontamination methods etc.
The Supplemental RI also brought into question the quantitative
reliability of the June 10, 1985, sampling results. Not only were
these taken without benefit of a comprehensive QA/QC program, the wells
themselves are thought to have leached low ppt concentrations of hexachloro
compounds. The table below shows a comparison between the new stainless
steel ultra clean wells (P-)(instal1ed for the .ppt investigation) and the
standard PVC wells (W-) used for the original investigation (pre-January
86). Notice that, although these wells were placed side by side and
also screened in the same zone, the concentrations in samples from the
-------
17
Well Well Year HCE HCBD HCB
Pai r No. Installed (ppt) (PPt) (PPt)
1 W-14 1985 ND 20 140
P-6 1986 ND ND 13
.of
2 W-I0 1985 42 400 490
P-9 1986 16 70 20
The supplemental investigation indicated that no significant groundwater
contamination migrated beyond the site boundaries. All concentrations
of HCB detected in the ultra-clean wells, except for two samples, were
below the 10-6 (21 ppt) risk criteria set, even considering the artifact
contamination likely generated during the field work. The samples for P-7
(30 ppt) and P-8 (28 ppt) although above 21 ppt are also not considered
significant. Taking into account their associated analytical QA/QC
baseline concentrations (36 & 13 ppt respectively) both of these can be
considered to be within the 10-6 health range. (Table 7)
The samples taken from the original PVCwells are suspect with regard
to the magnitude of the detected concentrations. The high levels
detected for some of the onsite samples suggest, that although not
quantifiable, conta.;nation from the site has migrated into the shallow
sand.
Well
B-14
HCE CH!)
670
HCBD (Hl)
2,100
HCB le2tl
1,700
8-22
3,400,000
1,300,000
110,000
The conclusion that the Shallow Sand is contaminated beneath the site is
substantiated by the subsurface soil investigation conducted during the
Supplemental RI. Table 8 gives the concentrations of HCB, HCBD and HCE
from the base of the waste pit to 30 feet (top of the Shallow Sand).
The analyses of these two borings (locations sho~ in Figure 6) coupled
. with the sampling results of the onsite PVC wells, indicate that the
contaminants have migrated to the ShalJow Sand aquifer.
Where ear1ier tests had indicated that the clay formation immediately
underlying the ~ste pit was very impenmeable, these analytical results
show differently. Close visual inspection of the borings show root
holes slickensides, sand lenses, and other secondary penmeab1l1ty
features. In-place and lab permeability test gave erroneous results to
the extent that they did not adequately identify the c1ay's mass
permeability.
Summary
The primary hazards to human health are associated with direct contact I
ingestion of onsite surface soils, sediments, onsite surface water
(Ponds B & D). onsite leachate and groundwater within the Shallow Sand
-------
TABLE 7
CLEVE REBER SITE
SHAlLOW SAND SAMPLE RESULTS
HC~
Baseline
... Monitoring teE te8D teB Concentration
Well Date (ppt) <22li (ppt ) (PPt )
P-1 1/29 1U lU 18 14
P-l 2/05 1U lU 14 14
Pel 4/09 lU lU 9 13
P-2 2/03 lU lU 10 14
P-3 2/02 lU lU 10 14
P-4 2/02 lU lU 10 14
PeS 2/04 lU .IU 7 14
P-6 2/04 1U lU 13 14
P-7 4/13 2 2 30 36
P-8 4/11 3 . 16 28 13
P-8 4/20 3 6 12 SO
P-9 4/15 16 70 20 12
P-9 4/15 (dup) 33 113 20 12
P-I0 4/17 3 11 13 12
-
W-IO 1/19 lU 160 890 1U
W-10 1/19 (dup) 1 520 800 lU
W-I0 4/15 42 400 490 12
W-IO 4/15 (dup) 44 390 470 12
W-12 1/19 lU 100 1.100 lU
"-14 1/20 lU 25 440 lU
W .. 1/20 (dup) lU 19 340 lU
-.
W-14 2/04 lU 20 140 14
W-16 1120 lU 7 69 lU
Notes:
U - Compound was analyzed for but not detected. Reported with the detection
limit value.
HCE - hexachloroethane
HCBD - hlxachlorobutad1ene
HCB - hexachlorobenzene
,'.,
~
-------
0&
19
TABLE 8
CLEVE REBER
CONTAMINANTS DETECTED IN SOIL
BENEATH WASTE PIT
Scnple No.
Location
De th
201
0--1
18...20 ft.
4400
202
0--1
20-22 ft.
3200
203
0--1
22-24 ft.
1,2-Dichloroethane
1,l,2,2-Tetrachloroethane
Trichloroethene
Tetrachloroethene
Hexachlorobenzene
Hexachloroethane
Hexachlorobutadiene
Hexachlorocyclopentad1ene
2900
204
0--1
24-26 ft.
2700
205
0--1
26-28 ft.
Sample No. 209 210 211 212 213 214
location 0--2 0--2 0--2 0--2 0--2 0--2
De th IH-20 ft. 20-22 ft. 22-24 ft. 24-26 ft. 26-2H ft. 28-30 ft.
l,2-D1chloroethane
1,I,2,2-Tetrachloroethane 1600J
Trichloroethene 1600J
Tetrachloroethene 8400 7500 9100 28000 . 1400 53000
Hexachlorobenzene 3200 8600J 33000 2700 60000J
Hexachloroethane 29000 3HOOO 196000 7900 23000 470000
Hexachlorobutad1ene 2900 1100000 100000 170000 5600000
Hexachlorocyclopentad1ene 26000 4HOOO 21000 630000
Notes
All values reported in parts per billion (ppb)
-- Not detected
-------
..
~
. I
.
.
~
:
.
I
.
!
I
.
I
POND .
POND C
.
:
~
-
.
.
POND. D I
SGUICI: (1) "''''.181' ""'t"l ... ."It.......,
lite If "-'OV....,: "'1 13. ....
Selle: '8. 100'
LEGEND
.0-1 CNSITI .:NtING fUll... .
201 lOlL SAM~LE NUMIU
@
o
250
lIS
SCALI IN 'IET
..,
..
20
FIGURE 6
ONSITE TES T BORING AND
SUBSURFACE SOIL SAMPLE
LOCATIONS
-------
21
4
The exposure route of most concern is the Shallow Sand. Although
hazardous substances have reached this zone, they have not migrated
beyond the general facility boundaries. The reason contamination is
not quickly spreading in the groundwater is due to the low mobility of
the Compounds of concern (HCB, HCBD, HCE) have in the local geologic
fonnations. .
The reason for concern with the Shallow Sand, as stated earlier, has to
do with potential future exposure scenarios. Continued cQntaminant
migration Coupled with the installation of a shallow or poorly cased
Nater well adjacent to the site could cause an unacceptable exposure.
ENFORCEMENT
The s1te was originally a disposal facility for municipal wastes.
Environmental Controls Company (E.C.C.), with Cleve Reber as president,
initially leased the property from Elmyra Landry Bishop, C. J. Bishop,
and Lydia Landry St. Amant, the landowners, in August 1970. On the
same date E.C.C. intered into a contract with Ascension Parish to
operate the site as a Santiary landfill. The contract allowed for the
disposal of both municipal and industrial wastes. During the period
from 1970 to 1974, both municipal and industrial Nastes were received
at the site. The site was abandoned in 1974, leaving behind various
buried hazardous substances, surface drums, and chemical Naste piles
and contaminated soil and surface water~
Vernon Schexnaydre purcha5ed the property from the previous owners on
November 12, 1976. On April 19, 1979, after sampling efforts by the
Louisiana Department of Natural Resources, Louisiana Governor Edwards
requested immediate steps be taken to secure the Cleve Reber site.
On March 14, 1980, a suit was filed Dl the State of Louisiana against
Environmental Controls Company of Louisiana, Inc., Elma Landry Bishop,
C. J. Bishop, Lydia Landry St. Amant, Vernon J. Schexnaydre, Cleve
Reber and the generators of hazardous and toxic wastes.
In Marcn 1983~ the EPA issued notice letters to all known potentially
responsible parties (PRPs). Vulcan Materials, Uniroyal and Mono Chem
(Subsidiary of Borden) identified themselves as waste generators for
the Cleve Reber site. These PRPs participated in the EPA emergency
removal of July 1983. During this removal action the surface drums and
chemica1 waste piles were removed and disposed of and a thin, temporary
clay cap ~s placed over much of the site.
The above mentioned PRPs retained IT-D'Appolonia for technical assistance
and oversight during the RI/FS (both original and supplemental). In a
meeting held on MIrch 18, 1987 they further expresSed an interest in
participating in remediation measures at the sit~.
ALTERNATIVES EVALUATION
The following are the remedial objectives developed during the RI
-------
22
'.
- Protect the Norco Aquifer from contamination from the site.
- Ensure that water users affected by potential contaminant migration
from the site have a potable water supply.
- Minimize adverse effects from contaminated shallow groundwater.
- Minimize the effects of contaminated surface water run-off from the
si te.
- Prevent human or animal contact with contaminated onsite surface
water.
- Prevent human or animal contact with contaminated soil and sediment
and with onsite wastes.
- Minimize the potential of an air discharge that would adversely
affect humans - during either investigative or remedial activities.
Under the Superfund Amendments and Reauthorization Act of 1986 (SARA)
there are new requirements to be considered in addition to the requirements
of CERCLA for selecting the most appropriate remedial action for implementation.
The major new provisions added to the law include a strong preference
for permanent solutions and a requirement that all onsite remedial
actions attain legally applicable or relevant and appropriate Federal
and state standards, requirements, criteria or limitations (ARARs).
In addressing permanence and long-term effectiveness of remedial actions
EPA must consider the following:
- long-term uncertainties of land disposal;
. goa\5 and requirements of the Resource Conservation and Recovery
Ac t ( RC RA) ;
- persistance, toxicity, mobility and bioaccumulation of the hazardous
substances of concern;
- short and long-term potential for adverse human health effects;
- ~ong-term maintenance costs;
- potential threat to human health and the environment from the excavation,
transportation, and redisposal, or containment of hazardous substances
or pollutants or contaminants.
SARA establishes a preference for remedial actions that utilize treatment
to permanently and significantly reduce the volume, toxicity, or mobility
of hazardous substances. Offsite transport and disposal without
. treatment is the least preferred option where practicable treatment
technologies are available.
The original RI/FS (May 1985) predated SARA. Although the Supplemental
RI/FS also predated SARA, efforts were made to conform the FS to the
anticipated language of SARA. Because of this, the supplemental FS
succeeds in adequately reviewing and considering innovative and
permanent technologies.
A number of potentially applicable remedial actions were studied for
the Cleve Reber site. Combinations of technologies were identified and
developed into alternative remedial actions. Treatment alternatives
-------
23
1
that would eliminate the need for long-term management (including
monitoring) at the site, to an alternative using, as a principal element,
treatment that would reduce the toxicity, mobility, or volume of site
waste as a principal element. A number of reasonable alternatives were
considered within this range. In addition, two other alternatives were
reviewed. . .
1) An alternative that involves containment of waste with little or no
treatment, but provides protection of human health and the environment
primarily by preventing potential exposure or by reducing the mobility
of the wastes. .
2) A no-action alternative.
The actuaJ screening process for technology/alternative review was
divided into two steps; initial screening and detailed screening. The
initial screening or alternatives was conducted with the intent of:
1) preserving the most promising alternatives as determined by their
likely effectiveness and impJementability.
2) preserving for further analysis a range of alternatives consistent
with the new SARA provisions.
Those technologies surviving the initial screening were further screened
utilizing the following criteria:
1) Effectiveness. Alternatives were evaluated to detenmine whether they
adequately protect human health and the environment; attain Federal
and state ARARs or other criteria, advisories or guidance; significantly
and pe~1nently reduce the toxicitJ, mobilit " o~ v~~ume of hazardous
constituents; were technically reliable, or were effective in other
respects.
2) Implementability. Alternatives were evaluated as to the technical
feasibility and availablity of the technologies each alternative wou1d
employ; the technical and institutional ability to monitor, maintain,
and replace technologies over time; and the administrative feasibility
of impJementing the alternative.
3) Cost. The costs of construction and any long-term costs to operate
ana-maintain the alternatives were evaluated.
The technology screening process was consistent with 40 CFR Part 300.68
(g) and draft guidance distributed pursuant to SARA.
Seven remedial alternatives were developed for detailed analysis and
are summarized in Table 9. The table presents a review of the technical,
. environmental, public health, and institutional evaluations. The
-------
24
Rating
Definition
1
o
+
++
Extremely negative
Moderately negative
Neutral effect
Positive
Very positive
The remedial alternatives are discussed below.
- Groundwater
Remedial alternatives to address groundwater were not analyzed in
detail because no offsite groundwater contamination is thought to
exist. Field study tests and literature reviews indicate that the
contaminants of concern have a high affinity for the local organic
clays. Considering a permanent source control remedial action.
contamination currently beneath the site should disperse and attenuate
below the 10-6 cancer risk factor. The goal of the groundwater evaluation
was to ensure that the 10-6 cancer risk value was not exceeded down-gradient
from the site. This will not occur if the source of contamination is
properly addressed; pumping and treating would not be necessary.
The source of potential future groundwater contamination is the buried
drummed and bulk wastes. The information provided by the PRPs indicater
that as many as 6,400 buried drums exist on site. Test pit excavations
during the RI noted that some still appear intact. If left in place,
these will likely corrode and leak sa.et1me 1n the future.
Although action alternatives were reviewed for possible groundwater
remediation, none al'e justified if a source control remed al ,-ctL 1 is
to be implemented.
If. however. the wastes are left in place, some type of long-term
comprehensive slurry wall system including groundwater monitoring and
pumping will likely have to be implemented.
- Source Control
Alternative No.1 is a no-action alternative. It involves no additional
work or monitoring at the site. There would be no mitigation of the
hazards currently associated with the site as addressed earlier under
Current Site Status. This is not consistent with the requirements of
RCRA or SARA. .
Alternative No.2 involves the complete removal of all contaminated
materials and returning the site to predisposa1 conditions. This
alternative was developed to comply with the Resource Conservation and
Recovery Act (RCRA). The RCRA land ban may affect the implementation
of this remedy. Soil, sediment and waste cleanup levels would be health
-------
I..
25
TABLE 9
CLEVE REBER SITE
SUMMARY OF REMEDIAL ALTERNATIVES
Alt. No.1 A 1t. No.3 Alt. No.4 Alt. No.5 A 1t. No.7
No Action Ons I te Onsite Offs ite Onsite
Vault Incineration Incineration Incineration
Orum/Slud es Orum/Slud es Orum/Slud es
Evaluation Criteria
Performance + + .. .... ++
Rellabil ity .. .. .. .. ++ ++
Implementability/ 0 ... + + 0
Constructab i 1 ity
Publ ic Health + + + + ++ ++
Envi ronmental + + + + ++ ++
Cost (Mill ions t
Capitol 0 80 10 25 30 290 85
O&M Cost (Annual) 0 0 .1 .1 .1 2.7- 6.9
-------
26
.
The first step of this remedial alternative would involve draining Pond
A. Water currently in this pond contains no contaminants at levels
requiring treatment and can be discharged directly into the Panama
Canal. Direct discharge of the water would require the construction of
a slurry wall along the southern edge of PQnd A,to hydraulically separate
the pond from the waste and leachate in the pit to prevent water quality
degradation. (This hydraulic connection has been verified by test pit
excavations). However, if leachate were found to be ad~ersely affecting
the water quality of Pond A during pumping. the water would be treated
in an onsite treatment plant prior to discharge. Pond C is also considered
uncontaminated and its contents would be discharged directly to the
Panama Canal. The quality of these discharges would be monitored to
assure that Clean Water Act (CWA) dicharge standards are not exceeded.
The other onsite liquids to be disposed of include the water in Ponds B
and D. the 1eachate that would drain from the excavated wastes, and the
leachate remaining in the pit after the wastes were removed. These
liquids would be treated and discharged in compliance with the Clean
Water Act (CWA). Once the site is dewatered the old borrow pit and
drum disposal area would be excavated.
The drummed wastes and bulk sludges buried onsite would be incinerated
onsite in a mobile incinerator. (As part of this process the excavated
wastes would have to be characterized. If a significant volume of
inorganic material were found, this would have to be treated (solidifie~)
and then transported offsite). The landfilled materials and contaminated
soil including sediments would be excavated and transported to an
appropriate disposal facility. The excavated areas would be backfilled
with clean, uncontaminated soil and graded to provide drainage that
would approximate pre-development conditions. The entire site would
also be revegetated.
The majority of the waste and soils excavated would be saturated based
on the water level data obtained at the test boring locations and
observations during test pit excavations. These materials would be
allowed to drain and would be stabilized and solidified prior to
transporting them offsite. As with the water in the ponds, the drained
leachate would be treated to remove organic contaminants and discharged
to the Panama Canal.
This alternative is protective of both public health and the environment.
All ingestion and direct contact hazards would be eliminated, and the
source of potential future groundwater contamination would be removed.
This corrective action could allow for significant future development
due to the removal of the site contaminants. The estimated cost of
this alternative is $80 million.
Alternative No.3 is an onsite closure intended 'to minimize or eliminate
the migration of contaminants from the site. No wastes are removed,
treated or destroyed. This alternative attains all applicable Federal
-------
27
The first stage of the remedial action would be the elimination of Pond
A. Again, it is necessary to remove Pond A because it is hydraulically
connected to the waste and leachate within the waste pit, providing an
outlet for contamination to enter the environment. It would be drained
as previously discussed.
~
. .
Whereas it is not anticipated to treat the surface water from ponds A
and C, the water from Ponds Band D would be treated (Sed1~ntation and
precipitation'. including aeration and carbon absorptio~) and discharged
to the Panama Canal in accordance with the CWA. Once thfs was completed
ponds (A~ B, C and D) would be backfilled with uncontaminated fill.
The interior of the site would be graded, crowned at the center and
sloped to drain toward the perimeter at a minimum gradient of 11. The
grading would maintain drainage while allowing for settlement due to
the c08p~ession of the underlying waste. The grading would prevent
offsite surface water from coming onto the site and rainfall falling on
site would drain off with only short onsite contact times.
The site would be cloSed by installing a multilayer cap with gas venting
pipes. The cap would be constructed of 24 in. of topsoil overlying a
filter geotextile which over1ies a 12 in. drainage layer overlying 24
in. of compacted clay. The Z ft. thick clay layer would not be placed
over the backfilled Pond A since the pond would be backfilled with up
to 15 ft. of clay. The placement of this cap would result in the top of
the cap being above the 100 year flood level. This type of. cap was
se1ected to satisfy RCRA specifications. The topsoil would be revegetated
with grass for erosion protection. The topsoil is provided to reduce
the intrusion of roots into the underlying layers of the cap. (Since
information on the 1andfi11ing operation indicates that the hazardous
wastes were segregated from the municipal wastes ~ cap over the whole
site may not be necessary, but only over the area known to contain
buried wastes).
The soil cap would reduce the risks associated with contact with
contaminated surface soils and Sediments. Additionally, the cap would
reduce the amount of water infiltration into the waste pit as compared
to the existing soil cover. Passive gas vent pipes would be installed
through the cap to reduce the build up of gas beneath the cap. Vented
. gases wou\d be treated with carbon canisters, and periOdic air sampling
would be perfonmed to evaluate the need for continued or additional
treatment.
All wastes would be left in place and capped. This alternative minimizes
the direct contact and ingestion threat associated with the site. The
potential for future groundwater contamination would continue. however.
A new fence would be constructed around the site and maintained to
reduce unauthorized site access. Additionally, both deep and shallow
groundwater would be monitored for 30 years after site closure. This
alternative would limit site development since contaminated materials
would remain on site. The estimated cost of this alternative is $10
-------
28
Alternative No.4 incorporates all of the actions of alternative no. 3
with the additional measure that the buried drums and bulk sludges would
be excavated and their incinerable contents destroyed in an onsite
mobile incinerator (mobile thermal destruction unit). Nonincinerables
(notably mercuric sulfide) would be solidified and likely landfilled
onsite. The drums and sludges would be excavated to prevent them from
contributing to future ground~ter contamination. By r~oving the
source of groundwater contamination, the future exposure impacts associated
with the site would be minimized. Considering the slow.ground~ter
movement and the high affinity that HeB has for the native organic
clays, ground~ter pumping and treatment would not be necessary.
Remnant contamination will not create a problem as long as the source
of additional contamination is reloved.
Conta.inated soils and sediments would remain onsite. All of the
surface ponds (A, B, C and DJ would be eliminated and backfilled, the
site would be graded, and the same multi-layer cap system proposed for
alternative no. 3 would be installed. A fence would be installed to
prevent unrestricted site access and groundwater 8Onitoring would be
perfOrmed for a 30 year period following closure. Direct contact
hazards and ingestion risks are addressed with the RCRC cap. The'
potential for future groundwater contamination is mitigated by the
excavation and destruction of the drums and bulk sludges. This alter-
native complies with applicable Federal standards and guidance and
with RCRA c10sure requirements. Future site development would be
restricted to ensure the integrity of the remedial actjon. The cost of
this alternative ;s estimated to be S2S million.
Alternative No.5; As part of alternative,no. 4-both onsite and offsite
inc1nerat10n of the drums and bulk sludges was reviewed. Alternative
no. 4 is onsite incineration and alternative no. 5 is offsite incineration.
All pathway. of exposure are handled as for alternative 4. This alternative
is considered a 10ng-term and penmanent remedy. Although site development
would be restricted due to the remnant contamination left onsite, no
significant migration of contaminants is expected. The estimated cost
of this alternative is $30 million.
Alternative No.6 and No.7 were developed as part of the Supplemental
RifFS (September 1986). The intent was to develop a high end cost of
complete and pennanent alternatives. Both entail complete excavation
of all buried and JandfiJJed wastes. and either onsite or offsite
incineratton.
Alternative no. 6 includes offsite incineration; alternative no. 7,
onsite incineration of all site ~stes including contaminated soils,
sedi.ents, Municipal refuge, drummed wastes and bulk wastes. Both
include all relevant components 0' alternative 2. All ponds would be
discharged (treated in accordance with the CWA) and backfilled, the pit
would be backfilled and the site ultimately returned to predisposal
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29
.
and ingestion threat would be eliminated and since the source of ground-
water contamination is destroyed, no future threat would exist. 80th
alternatives were designed to comply with RCRA.
All of the alternatives discussed are presented in tabular form in Table
9. As discussed earlier, all ~re reviewed with regard to effectiveness,
reliability, permanence and cost effectiveness. Time to achieve was
also considered.
It should be noted that incineration (thenmal destruction) was selected
as the most reliable permanent treatment Method for the drummed and
bulk wastes. During the technology review conducted for both the
original and supplemental FS thermal destruction ~s considered the
only reliable technology for the permanent destruction of the site
~stes.
COMMUNITY RELATIONS
See Appendix 8
CONSISTENCY WITH THE PROVISIONS OF SARA
The selected alternative must be consistent with the provisions of SARA.
The major impacting provisions have been stated earlier in the Alternatire
Evaluation section. The selected remedial action will be permanent
and effective in protecting public health and the environment.
The term permanent is defined as an alternative's ability to significantly
reduce a waste's mobility, toxicity and volume. Treatment technologies
are preferred.
SARA also requires that the selected remedy comply with all Federal and
State ARARs except under specific conditions. This will be discussed
in the next section (Compliance With Other Environmental laws).
The alternatives reviewed that are most impacted by SARA are alternatives
nos. 1 through 3. Alternative no. 1 (no action) does not comply with
SARA in that it is not protective of human health and the environment.
Current onsite exposure risks and more importantly potential future
groundwater exposure r;sks, are not addressed.
Complete offsite disposal of contaminated landfill material and onsite
fncfneration of drummed wastes (alt. no. 2) does comply with SARA.
It 1s a r"edy to be less preferred, however, to one that does not involve
offsfte transportatfon. Although the drUined ~stes would be penBInently
destroyed and the wastes significantly reduced in volume, toxicity and
80btlttYj the offsite transport of the contaMtnated landfill 8Itertal
could result in future problems at another location.
Alternative no. 3, onsite cap and slurry wall, does not meet the
perference for a permanent remedy tn SARA. It does, however, comply
with ARARs. The wastes left in place could leach into the environment
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30
~
and monitored for perpetuity. Wastes would not be reduced in mObility.
toxicity or volume but only encapsulated. Considering the persistence
and toxicity of the onsite wastes, this is not a preferred alternative.
Alternatives 4 through 7 do comply with the intent and the preferences
of SARA. Alternatives 4 and 5 propose the excavation and incineration
(onsite and offsite respectively) of all drummed wastes and bulk sludges,
, the removal of all ponds, and the backfilling and capping of the site.
Both alternatives significantly reduce the waste's mObi}}ty, toxicity
and volu.e. Considering the local hydrogeology and also the high
affinity the hexachloro compounds have shown for the area clays, the
residual contamination left in place (soils, sediment and municipal
refuge) is not expected to migrate and present any significant future
human health or environmental risk.
Comparing alternatives 4 and 5 without regard to cost, (although the
est1~ted cost of alternative 5 is $5 million more than alternative 4)
onsite incineration appears to more suitably comply with SARA considering
the risk involved with the offs1te transportation of the hazardous
materials. This was reviewed because of SARA's requirement to consider
the potential threat to human health and the environment from the
excavation. transportation, and redisposal or containment of hazardous
substances or pollutants or contaminants.
Alternatives 6 and 7 propose the excavation and incineration (offsite
and onsite respectively) of all landfilled wastes, including the
municipa1 refuse that has been contaminated with leachate. Ponds would
be drained and backfilled, but the site would not need a cap. Both
alternatives return the site to predisposa1 conditions., WUtes 'would
be permanently destroyed.
As discussed for alternatives 4 and 5, alternative 7 (onsite incineration)
is preferred to alternative 6 (offsite incineration) because of the
increased public health and environmental risks associated with the
offsite transportation of hazardous contaminants. As stated in the
earlier section, all reviewed alternatives would be designed to attain
ARARs.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS (ARARS)
As part of the FS process, applicable and relevant Federal, state and
local regulations and laws (ARARs) were reviewed (Appendix C). The
final alternative selected will attain ARARs.
During the course of the investigative work, and also during the development
of the RI/FS, the EPA coordinated with both the Army Corps of Engineers
(COE) Kansas City and the Louisiana Department of Environmental Quality.
Jhe United States Geologic Survey (USGS) and the COE out of New Orleans
were also used as sources of information. Coordination with these
groups helped ensure that local, state, and other Federal regulations
and concerns were addressed. The environmental laws that are of most
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4
- Executive Order 11988 - Floodplain Management
The perimeter of the Cleve Reber site is within the 100-year floodplain
of lake Maurepas and Lake Pontchartrain. Considering the vast floodplain
envisioned, none of the remedial works studied will have any adverse
affects on the area floodplain. The site would, be vegetated to prevent
erosion, and any construction designed against washout by the 100-year
flood.
- Executive Order 11990 - Protection of Wetlands
Accordfng to an evaluation given by the New Orleans District of the
COE, the area surrounding the site .ay possibly fall within the .special
case" bottomland hardwood category 0' ~tlands. The site itself,
however, represents a heavily disturbed Irea which does not exhibit the
characteristics of a .etland. It is the COE's detenlination that the
Cleve Reber site does not fall within the category of wetlands regulated
under Section 404 of the Clean Water Act. During site remediation
activities, care will be taken to minimize any adverse affects to
surrounding .etlands.
- Clean Water Act
Another environmental law that impacts site corrective actions will be
the Clean Water Act (CWA). CWA discharge standards will be adhered to-
for any -.ter or leachate discharge.
- Resource Conservation and Recovery Act (RCRA)
The environmental law that impacts the site the MOSt is RCRA. RCRA
require~ [in part] that at the final closure 0' a hazardous ~ste
landfi) I, the s,~e be capped with a fin61 cover designed to provide
long-tenn m;ni"'ization of liquidS through the closed landfill, function
with Mini~um maintenance, to promote dr.inage and to 8inimize errosion,
etc. RCRA guidance documents suggest I multi-layered cap that has a
permeability less than or equal to the bottom of the landfill. RCRA
further requires, assuming that groundwater contamination is not present,
that the groundwater be monitored for. thirty-year period to ensure
the adequacy of the closure.
In addition to the above. RCRA r@quires that groundwater contamination
beyond the point of compliance be cleaned up to background, a maximum
concentration limit ("Cl), or In alternate concentration limit (ACL).
The 'point of compliance' (t264.95) is defined .s . vertic.l surface
located at the hydraulically downgradient limit of the waste management
area that extends do~ into the uppenlOst aquifer underlying the
regulated units. The point of campliance at the Cleve Reber site is
considered the facility property line.
RCRA requirements that have applicability for offsite transportation of
hazardous wastes are the manifesting requirements and the statutory
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32
.
in compliance with Subpart B through 0 of ~62 and Subpart E of ~64
(Manifest System, Pre-Transport Requirements, Record keeping and
Reporting).
- State laws/Regulations
The louisiana Department of Environnental Quality was requested, in a
letter dated January 1987, to infOnl the EPA of any State or local
ARARs that could affect the implementation of the remedfal action.
After numerous Meetings and phone conversations, the state has not
identified any regulatory or statutory concerns other than those already
identified and established by EPA. Their written concurrence with the
proposed remedy, (located in Appendix D) is taken as concurrence on and
acceptance of the ARARs discussion given in this document.
- Offsite Policy
The EPA's Offsite Policy (FR Nov. 5, 1985, pgs. 45933-45937) essentially
requires that any offsite disposal facility selected to receive Superfund
wastes be in compliance with RCRA, have been inspected within 6 months
and not have any significant violations of applicable environmental laws.
SARA reiterates the intent of the Offsite Policy.
Summary:
All of the seven alternatives studied comply with the provisions of the
Federal policies on floodplains and wetlands and also the requirements
of the CWA. (The no action alternative may violate CWA standards due
to surface migration). RCRA appears to be the ~st pertinent law that
needs to be addre~sed.
Each alternative is discussed below with respect to its compliance with
RCRA, SARA and if appropriate, the Offsite POlicy.
1) The no action alternative does not comply with RCRA (nor does it
comply with CERCLA/SARA). The site is not properly closed, and site
contaminants are allowed to migrate.
2) The reMoval of site contaminants/materials and returning the site to
predfsposal conditions Is designed to comply with RCRA. The RCRA
land ban, however, may affect thfs r88edy. This alternative also
does not 8eet the preference, stated in SARA, for not transporting
untr.ated wastes offsite since untreated .aterial would be transported
offsite for disposal. This alternative does, however, significantly
the reduce mObility, toxicity and volume of the wastes.
Offsite disposal (if allowed pursuant to the land ban) would be to a
facility in compliance with the Offsite Policy.
3) The onsite closure alternative complies with all of the closure and
post-closure requirements of RCRA. It does not meet the SARA
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33
and not treated. The necessary long-term/perpetual maintenance
required brings into question the appropriateness of this remedy.
4,5) The onsite closure with drum and bulk sludge incineration complies
with all of the applicable requirements of RCRA and SARA.
..
For offsite incineration, the wastes would be 8anifested to a facility
in compliance with the Offsite.Policy.
. 6,7) Complete incineration of all onsite wastes is also in .full compliance
with the provisions of RCRA and SARA.
Offsite waste transport for alternative 6 will comply with RCRA
regu}atjons and also the Offsite POlicy.
In addition to the above, all Federal and state ARARs would be adhered
to. Specifically, the incinerators will be designed, constructed and
operated to meet all air emission and burn effeciency standards and
regulations.
RECOMMENDED ALTERNATIVE
Section ~121 of SARA adds a new section to CERCLA that establishes a
variety of requirements relating to the level of cleanup for remedial
actions under CERCLA. This section codifies many of the existing
requirements Under the National Contingency Plan (NCP). but also.
estabHshes additional directives for selecting permanent remedies and
for meetings state requirements (ARARs).
The basic requirements for a selected remedy are that the remedial
actions be:
1) Protective i)f human heal th and the envi ronment;
2) Cost effective;
3) In accordance with the NCP;
4) In accordance with new SARA provisions, ie; pennanent
solutions to the maximum extent practicable, ARARs and
least preference for offsite disposal of untreated
wastes and ARARs.
Considering the current and potential site hazards, and also taking
into atcount the SOIewhat un1que hydrogeology 0' the area, the recommended
alternative 1s alternative 4; onsite incineration of dru~ wastes and
bulk sludges, in Combination with the removal and backfilling of all
ponds and f1nll1y a RCRA cap over that portion of the site containing
residual contamination. The cap is not expected to cover the whole
site, but only that area that was used for the disposal of industrial/
hazardous waste.
A specific groundwater remedial plan is not necessary since the source
'of future ground~ter contamination will be removed. In doing so the
mobility of the contaminants and their potential future volume will be
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-3
34
.
An important step in this remedy will be the characterization of those
wastes to be excavated. According to infonmation supplied by the PRPs
a small percentage of the ~ste disposed of at the site was mercuric
sulfide. This material will not be incinerated but will be solidified
and likely landfilled onsite. The solidification process will ensure a
treated waste that will not be identified as hazardous according to
RCRA's characteristic tests, i.e., EP Tox and TCLP.
The site will be monitored for a period of 30 years (post-closure time
period stipulated under RCRA) to ensure that no significint contaminant
concentrations migrate from the site. If however, future 8igration does
occur appropriate remedial actions will be taken.
This alternative is protective and cost-effective, attains ARARs, and
utilizes penmanent solutions and treatment techn010gies to the maximum
extent practicable.
The idea behind this remedy is to remove the source of future groundwater
contamination. By excavating and incinerating the dr~ and bulk
liquid wastes and sludges there would be a significant 'reduction in the
contaminant's mobility, toxicity and v01ume. The residual contamination
left in place will be adequately attenuated and absorbed by the local
organic clays so as to mitigate any potential future i.pact. Both
field tests and literature studies support th1s conclusion.
The onsite incinerator will be state-of-the-art and will meet .11
applicable state and Federal requirement (ARARs).
The reasons for the elimination of the other remedies are as follows:
Alt. No.1; The no-action alternative is not p~otective of public health
and,the environment. It Qoes not ~et the intent of RCRA
or SARA.
Alt. No.2;
Alternative 2 was originally developed to comply with RCRA.
In view of the RCRA land ban requirements, however, this
alternative May violate the ban. This alternative
significantly reduces MObility, toxicity and volume, by
removing untreated ..ste offsite for d;sposal. This does
not meet the preference for not transporting untreated
wlstes offsite under SARA. In addition it is 8uch more
expensive than other alternlt1wes that provide a comparable
level 0' cleanup (alt. 4 and ~).
Alt. No.3; This alternative, although it does c08ply with RCRA, does
not .eet the per.anence preference of SARA. Onsite closure
is not a permanent remedy. The ..stes are not significantly
reduced in mobility, toxicity or volume. '
Alt. No.5; This is the same as alternative 4 except it calls for
offsite incineration of the drummed wastes and bulk sludges.
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35
..
out in favor of alternative 4 due to both potential increased
human exposure (offsite transportation) and cost-effectiveness.
Offsite incineration does not offer any increase in protection
for human health and the environment, yet it costs approximately
$5 .illion more. . '.
Alt. No.6;
Complete excavation and offsite incineration of all wastes
complies with RCRA and aho Meets the definit.ion of a
peMllanent rellledy under SARA. The a 1 ternat i ve, however, 1 s
not cost-effective. Although it theoretically provides
'better' long-tenm protection of hU8an health and the
environment than alt. no. 4, the sfgnificant increase in
estimated cost ($290 million vs $25 Million) fs not commensurate
with the relatively 58111 increase in envfron.ental benefit.
Alternative 4 provides a pen.anent and safe solution to the
hazardous ~ste probleM. To even say that alt. no. 6 is
more protective is misleading. The difference fs that alt.
4 leaves residual contamination in place and no. 6 does
not. No. 4 utilizes the fortunate hydrogeology and physical I
chemical properties of the site and surrounding soils to
allow residual contaminants to remain in place and not create
a future health or environmental threat. In addition, this
alternative poses an exposure threat due to offsite transpo~-
tation risks.
Alt. No.7;
This is the same alternative as no. 6 except it entails
onsite incineration. The remedy is also not cost-effective
in that it is estimated to cost $85 million. As just
stated, the increase' in cost does r.ot jl.lsti~y its neglible
increase in environmental protection.
OPERATION AND MAINTENANCE ~
Project operation and maintenance will include a monitoring well
sampling and analysis program, and site and cap maintenance including
the maintaining and replacement of the passfve 9as vent filters.
Gas vents are included since the cap is expected to be covering at
least a portion of the old 8unicipal landfill. Municipal landfills
nonaa11y produce gases such as Methane. (The appropriateness of this
will be locked at more closely in the Re8dial Design. Since it is
thought that the hazardous ~stes were segregated from the municipal
wastes during disposal this .ay not be necessary). The site Clp .a1n-
tenanee will entail the inspection of the surface vegetation and cap
and also the periodic repair. of the peri8eter fence. The State of
loufsiana will have the responsibility for 01" for a period of at least
30 years beyond this time.
~he current source of funds for matching remedial actions at Superfund
sites in Louisiana is the Hazardous Waste Site Clean-Up Fund (Section
1149, Title 30). This fund, which currently has a $2 million dollar
cap, is available to the state to match Superfund actions. The Hazardous
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36
efforts.
The LDEQ is lobbying to get the $2 million ceiling raiSed.
SCHEDULE (Planned)
- Approve Remedial A:tion (sign ROD)
March 1987
.
- Co.plete Enforcement Negotiations
- Procure funds for the EPA zone
contractor to conduct the study
(Assuming the PRPs do not take over)
March - May 1987; ongoing
April 1987..
- Start Design
- Complete Design
June - July 1987
February - July 1988
- Procure funds to have EPA contractor
construction oversight
- Start Construction
April - August 1988
- Complete Construction (1.5 yrs)
September - October 1988
November - March 1991
FUTURE ACTIONS
No future re8edial actions are ant1cipated. The selected remedial
action is considered pe~anent. If, however, significant unforeseen
offsite contamination occurs as a result of the site, appropriate
remedial measures will be taken.
As stated under thp. 1&M section, the site will be monitc oed ~or ~t
least 30-years to ensure the reliability of the implemen~ed remedial
action.
SARA also states that if an alternative results in any hazardous
substances, pollutants, or contaminants remaining on site, the remedial
action shatl be reviewed at least every five years to assure that human
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{:J.
.
DEPARTMENT OF HEALTH & HUMAN SERVICES
PubliC Health Service
Agency for Toxic SYbstances
Ind Diselse Registry
Atlanta GA 30333
Mlrch 31, 1987
MEMORANDUM
SUBJECT:
Cleve Reber Remedial Evaluation frOM the
Agency for Toxic Substances and Disease Registry
Carl HiCk~ Senior Public Hellth Advisor
Agency for Toxic Substances and Disease Registry
Stephen A. Gilrein, Chief
AlONM Remedial Section (6H-SA)
FR()4:
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 at the Cleve
Reber Site in Sorrento, Louisiana. After careful review of the data
fran this site the following findings, comments and recommendations
regarding this proposed cleanup alternative are provided by the scientific
staff of the Agency for Toxic Substances and Disease Registry.
During combustion of chlorinated ~rganic compounds the potential
exists for productfon of d10xions and furans, the agency recommends that
some fOnD of control technology needs to be incorporated to minimize
the re'ease of dioxins/furans into the environment. This capability
could be demonstrated by a test burn of contaminants from the Cleve
Reber site. After completion of a trial burn the Agency for Toxic
Substances and Disease Registry will, if requested, review these findings
and provide comments regarding any public health significance.
As the result o( Hydrochloric Acid being produced by Chlorinated
Compounds it is our opinion that control of this acid ..terial would be
necessa~ to protect the pub1ic hellth.
Wit. the above recommendations incorporated and delonstrated ATSDR
agrees .nth Region VIis plan for onsite destruction of the contaminated
material fram the Cleve Reber site.
ATSDR appreciates the opportunity to comment on the proposed
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2
3.
United State. Geolosical Survey 7.5' Toposraphic Map, Sorrento
Quadrausle, Louisiana, dated 1962, photorevi.ed 1980.
4.
Supp1eaenta1 Report to Cleve Reber Site, R...dial Inveatisation and
"..a1bil1ty Study, VolUM I, Sept_ber 30. 1986: CB2M Bill.
Supplaental Report to Cleve Ileber Site. ReMdial Inve.tiaat1on and
"...ibility Study, Voluae 2. Septeaber 30. 1986: CB2M.aill.
5.
6.
Public "alth IYaluation, Cleve Ileber Site. Ascenaion Parish.
Lou1alua. Sept_ber 30. 1986: CB2M 11111.
Site Statua SU888ry. 5 pasea, dated Sept..ber. 1986: provided by
Georle Pett1arw. ATSm. Ilelion VI.
7.
8.
Reaedial Inveatisation Report, Cleve Ileber Site. A.cenaion Pari.h,
Louiaiana, Volumea 1 and 2. May 30. 1985: CB2M aill.
9.
Feaaibi1ity Study Report. Cleve Reber Site, Aacen.ion Pari.h,
Loui.iana, May 30, 1985; CB2M Rill.
MCltGROtJND
The Cleve Reber Site i. an abandoned 24.6 acre landfill. with one
(1) 1arae pond (10-12 acres) and three (3) ...ller pond. (approximately
one acre total). The .ite ia located in AaceD8ion Pariah. Louiaiana,
approximately 30 mile. .outb-8outhe..t of laton Iouae and approximately
2 mile. .outhea.t of SOTTento. The area aurroundina the aite i. .parsely
aettled with 2~ re.idence. located within one-half 811e to the ~orth
and veat of the lite and a canal (Pan... Canal) located within 1000
feet to the .outh and ve.t of the .ite. The .ite haa a .liSht .1ope
from the north to the .outhea.t. The PaD888 Canal drain. into an
exten.ive .vamp located .outhea.t of the .ite.
The site. ori8inally u.ed a. a borrow pit for bridae and hishvay
conatructio~. va. peraitted in 1970 for di.po.al of aun1cipal va.te..
The facility vas 1..a" to !nviroDll8ntal Controls Coapany (Cleve I.eber,
Prelldent) and lubleqaently Vied for dl.po.al of both auDiclpal and
tuu.trial...te. froa 1970 until it ... .bauoned in 1974.
An ...rlency 8urface cleanup vaa conducted by the USIPA during
July 1983, re8Ultlna in the r..oval of ch881cal ..ste pUel and
approx18ately 1000 drual. It Is e.tt8ated that 6500 dru81 r...ln buried
at the .ite. Th. l....dia1 Inv.atl,ation and "eaaibility Study (RI/"S)
vere cOD8idered coap1eted in May 1985: however. .ubaequent diacovery of
cont881natlon beneath the lite re8Ulted in 80re ext8D81ve IrouDdwater
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3
PlUNCIPAL CONTAMINANTS
A total of 61 cODta1UDU ha.e beeD l.deDt1fl" at tbe Cle.e aeber
lite. .ille (9) of tbe.e .ere .elected a. indicator cb881cal. ba.ed OD
frequeDcy of occuTreDce, poteDcy, ch881cal cla.. aDd toZiclty/carclDo.eDicity.
fte.. lDclucle: aniliDe, beueDe, beuch!orobeueDe, baucbloro butadleDe,
hazacbloToethaDe, tolueDe, D-n1tro.odlpbeayla1De, tetrackloroetbyleDe
aDd '91Dyl chloride.
avnolOfDTAL PATIIW& IS
ID'91roD88Dtal .88pllD1 ba. re.ealad oraaD1c aDd lDor..D1c CODta1UDt.
pre.ant, 011 aDd/or off.lte, lD 8urf.e. 8011, 8ub8urfac. 8011, .urfac.
water, ar01lDdwater, all4 111 ..4U~.. 111 addition, CODtaaiUtiOIl va.
pre.uaed to be pre.eDt iD aquatic or.alli... OII8ite, a. e.t188ted from
..a.ured .urface vater contaa1l1&tioll le.e1. alld pub11.b.d biocollceDtrat1011
factor.. Rovever, 110 .ample all&ly.i. of aquatic or.aDi... .a. cOllducted.
CoDtaa1utioD .a. found ill .ub.urface .011. directly beaaatb tbe .a.te
.ite to a depth of 30 feet, the Ire.te.t depth at whicb .88ple. .ere
taken. All four ouite .urface pODda aDd aurface poDd .edl_Du .ere
fouDd to be cont881l1&ted. LGw level .urface .oi1 CODt8ll1UtiOD ...
fOUDd to tbe eaat of tbe .ite.
Pour aquifer. .ere ldeDtified beDeath the .ite: tbe Sbal10w Sand
Aquifer (approzi..tely 25-35 feet), the Deep Saad Aquifer (approZi..tely
200-235 feet), tbe Norco Aquifer (approZi..tely 250-350 feet), aad the
Gouale. Aquifer CapproZiutely 500-650 feet). 'l'be Shallow SaDd Aquifer
beDeatb the .ite va. foaud to be cODt881aated at le.el. esceedina a
10-6 exc... cancer riek (p. 23 aad 60, PRE; p. 5-30, Suppl8Matal
leport, Vol. 1). Low level coataaiutloD .a. reported la the Deep SaDd
Aquifer; hovever, vbether thl. i. real or artifact ll1duced 1. lDcoDclu.ive.
ID either ca.e, the level. reported vere below tbo.e of public health
CODcern.
IroKA.N EXPOStJR! PATINA YS
At preaeDt, the oDly poteatial hU8811 azpo.ure pathway oa.lte are
der88l ab.orptlol1 aDd iDle.tloD of coataaiuted .oil, aDd iDle.tioa of
CODta1Utad aquatic or..IIi.... SiDce the .lte i. IIOt 111 operatioD,
tbe ape.'" populatioa 18 ..11, cou18t1D1 only of nplatory/8DDltoriq.
paT.oDD8l 88k1D1 iDlrequeat .ite .i.it. aDd tre.pea.er. Who intrude oa
the .it. to baDt aDd fi.b.
The oaly off.lte expo.ure pathway. cOll8idered .ilD1f1cant 1a the
report .ere der88l ab8orptlon aDd iaae.tiOD of CODtaa1Utad .oi1.
Bove.er, .urface cODt88tnatloD ... low (e.t18ated 220-330 ppb of
beucblorobeazeDe) aDd ideDtifled oDly lD aD uapopulated area ea.t of
the .ite. Tbere i. DO iDdlcatioD froa the lafor88tion provided that
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4
The Shallow Sand Aquifer, i. felt to be contam1nated in the immediate
vicinity of the lite. Th1l aquifer. 11 not currently known to be u.ed
a. a potable vater .ource. Rowever, the potenUal en.u that at .oae
t18e it could be U8ed for huaan cOUUllptiOD.
DISCUSSION
A review of the PubUc Bealth Evaluation re..ealed ....eral area. of
CODCerD. The.e aru. an 01rt11n8d in Ireater - detail below.
. .
1.
Error. and O81..iona vere DOted 1D the ..arioa. aeference Section..
The entire Reference Section of Appendiz A V&8 O81tted. In addition,
.e..eral literature referencaa cited 1D tbe report Darrati..e vere
Dot li.ted in the corre.pondinl aefeT8Dce Section., thue pr8..entina the
reviewer. froa validatina data, calculatloDl and judl1nl conclu.lon.
ba.ed on cited reference..
2.
RU8erou. ...ple. vere ll.ted a. having QC/~ probl... (p.1S-19,
PBE), and therefore were not ueable.
3.
Selection of Indicator Ch881cal.
Of the 61 different chemical c08poundl identified at the .ite, nine
(9) vere .elected a. indicator chea1cal.. Althoulh AT5DR ha. no
rea.on to doubt the appropriatenel. of the nine ch88ical. .elected,
the report did not provide a clear, under.tandable rationale for
their .election. '.
~urf<:e Water Contamination
App.rently the pond identified a. Pond D (p.S, PRE) i. not located
entirely onlite, but eztend. off.ite for aore than one-half of it.
.urface area. Since Pond D ha. been .hovn to be cODtaa1nated,
off.ite acce.. .hould al.o be re.tricted.
5.
Off.Ite Surface Water, Sedi..nt. aDd Surface Soil
The PRI (,.7) .tat.. that dr.iDa.e of the lite il to the louthe.lt
tann tile 'a~ Caul. The rapoft (p.36) further .tat.. that the
.it. aDd all the cont881aated 8arfaca poDd. tend to o'Y8rflov, al81n
toward tbe louthea.t aftlr hU.., raiuto1'88. Surface 1011 ...,le.
.ere therefore collected ea.t of the .ite out to 200 feet in a down
drli....e location tovard the Panaa Caul. The reaaltl indicated that
off.ite 8ilration had occurred at .088 ttaa, probably froa .urface
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presently found (estimated values of hezachlorobeuzene of 220-330 ppb)
are not of public health concern. Sedi8lnt and surface .ater samples
collected upstream and dOWDstr... in the Pana.. Canal failed to
identify site related conta8tnants of concern. Surface ..ter salples
taken in a dovo ,radient drainale ditch of loute 70, "It of the lite,
revealed no lilDificant le8tvolatilel or volatiles. Sedi8lnt salples
fro. the ditch identified beoaoic acid (9,200 ppb) aad 1,1,2,2,
-tetrachlorethane (750 ppb) as beinl present. Additionally, leven
(7) IQrface loil samples .ere collected in nearby re.idential yard.
with no conta8tnant of concern beiq found. la.ed on the .alple
re.ult. reported, off.ite conta8tnation .a. not identified a. beioa a
proble. at this ti_.
6.
Groundwlter
There tend. to be conflictioa infor..tion provided in the PRE,
particularly for the Deep Sand Aquifer. The PRE (p.35) .tate. that
the -oeep Sand Aquifer has not been contaltnated by the .ite'. chemlcal,-,
vhile on p.60 it reports that ~evel. of hezachlorobeuzene exceed the
concentration correspoDding to a 10-6 exce.. lifeti.. cancer ri.k in
both the Deep and Shallow Sand Aquifer. off.ite.- table 2-4, p.23,
indicate. the ranle for hexachlorobenzene in the Deep Sand Aquifer i8
from 0.006-0.037 leS/l vb1le the exce.. lifeti.. cancer risk is 0.02
aca/l (p.A-20). The Supplemental Report, Vol. 1 (p.5-29). indicates
that because of artifact. fro. veIl in8tallation, the hezachlorobenzene
level. are lover than reported and -rbe .ite has apparently not
affected vater quality in the Deep Sand. 8 The di.crepancie. above,
aDd po~.1ble in other locations in the docu..nt., .hould be reconciled.
It va. indicated that veIl. initially drilled for arouodvater .ampling
vere, in general. not .uitable to .upport collection of high intelrity
.aaple. for laboratory a..ly.is using part-per-trillion detection
limit.. Thi. va. accounted for, in part, by low level contamination
on the .urface. of the drilling tool. and in ..teriall u.ed to con.truct
the velll that could .how up a. low Inel conta.nation in the .alplea
(p.S-9, Supple..ntal aeport. Vol. 1). The PVC Shallow Sand and W-l
. Deep Sand re.ult. .ere felt to have been influenced by conta.nantl
introduced on well ..terial. or fro..ell conltruction technique., aa
veIl &a, e1l1 aqu1fer coot.a8tnation. Paired lalpliq u81q lteiDlel.
Iteel, ultra clean conetrocted .elll bel ide PVC .ell. tended to
Iupport thi. clai..
Water in four (4) nearby re81dential ..Ill, pren..bly located in
the .orco Aquife~, .ere lalpled. aeuchloro COIpOUOU .ere not detected
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Well. 1-14 and 1-22 through the va.te pit area and into the Shallow
Sand Aquifer .howed high level. of cODCaa1nation. Iven tbou.b PVC pipe
va. u.ed, and tbere va. po.dble cont881'nation a..ociated witb 1D8tallaUon
probl..., tbe level. vere h1.b enou.b to indicate a aroundvater proble.
in tbe Shallow Sand Aquifer under tbe .ice (p.5-32, Suppl...ntal aeport,
Vol. 1). Of the fourteen (14) .taiDle.. .teel peri--ter ..11. in.talled
in the Shallow Sand Aquifer, DiM (9) reflected heucblorobeuene
concentratione equal to or Ie.. than their ba.eline cODcentration and
below health criteria liait.. "ae11ne concentration.. u.ed in the
report i. tbe 81ni8U8 level of bact,round contaa1nation felt to have
been i~troduced into the ...,le ba.ed on the analy.i. of field and ...ple
blank. (p.1-12, Suppl...ntal leport, Vol. 1). Therefore, while
heuchlorobeuene contaa1naUon of the Shallow Sand Aquifer 18 .hown
beneath the .ite, off.ite a1lration va. not identified.
Monitorinl of the Deep Sand Aqu1fer va. prov1ded by vella W-2, W-3,
W-4 aDd W-lA. The rnulu froa thi. 8ODitor1D, are cone1dered
incoDclu.ive. While low level. of cont881nat10D vere reported, th1.
..y be aaaociated vith the vell conetruct10n and 1n.tallat10n ..teriall.
Other featurea of the aite (i.e., the clay layer betweeD the aquifera,
Irad1eDta) vould tend to 8Vpport th1. cODteDtion. S..ple. vere not
taken 1n the Deep Sand Aquifer under the vaate pit, .0 no comment may
be ..de re._rdina th1.a area.
.
7.
Sub.urface Soil Contamination
The PH! (p.32) a:ater tb~: the public health hazr.rd due to aubaurface
a011 1. 81n!..l becauae aub.urface .oil contamination, -i. at a depth
exceed1nl 30 feet.- Th1. .tat...nt i. ai.leadinl in that 30 feet il
not the 81nimum depth at which .ubsurface .011 ...ple. vere fOUDd, but
rather the 8&Xiau. depth at which .ub.urface .oil .-.ple. vere taken.
Moreover, contaa1nat10n va. found throuahout tbe depths ...pled (p. 3-4
and 3-5, Suppl..ental aeport, Vol. 1), with the hilhe.t contaminant
level. o/ten occurrinl at the deepe.t depths ...pled, i.e., 28-30
feet. Th18 aepth corre.pond. to the approzi..te upper l181t of the
Shallow SaDd Aquifer. n.. fiDdinl1 indicate both that tbe clay
.trata waderlylq the lite 11 a .er, poor barrier to cont_DaDt
81.rat1on aDd that the potential for continuiaa cODtaaination of thi.
aquifer 1. relaU.ely arut.
COIfCLUSIOBS
Potential on.ite ezpo.ure route. have been abovu for worker per.oDDel
and tre.pa..er.. Public health threat. to the.e per.ona Ihould be e"11y
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Low level. of bezachlorobanzene in .urface .011 to the ea.t of the
.1te indicate. that 8lsration baa occurred at '0" ti... However, .urface
vater, .edi..nt and/or .urface .oil .alPle. taken in the Pana.. Canal and
re.idential aru. did not indicate a ,re.ent -.ration proble. fro. tha
.ite.
Groundwater conta8lnation of the Shallow Sud Aquifer at the .ite
doe. not repre'8Dt a public hulth thrut .ince it i. not aaed a. a
potable .ater .ource. Hovaver. the po..ibil1ty 8Zi.t. tbat the aquifer
could 'be u.ed .. a potable vater .ource at '0" ti.. in the future.
Monitori. re.ulta for contallhaant. in the Deep Sad Aquifer wera
con.idered 1Dconcluaive.
UCOHKD1uf. TIOHS
1.
Monitor for offlita Itsrat10D of aroundvater in both the Shallow
and Deep Sand Aquiferl on a periodic balil.
Inltitute appropriate ..alurel to a..ure that the Shallow Sand
Aquifer vill not be uled a. a potable vater .ource.
2.
Ve tru.t that thele C08l8nti vill be helpful.
.
REVIEWERS
DenD.1. !.
Georse L.
Concurrence:
cc:
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CLEVE REBER COMMUNITY RELATIONS
RESPONSIVENESS SUMMARY
This com.unity relations responsiveness su..a~ .is divided into the
following sections:
Section I:
Sect i on II:
I. BACKGROUND ON COMMUNITY INVOLVEMENT
From 1970-1974 the site was an active landfill. Superfund involvement
began in 1983 with an emergency removal ofapproxillately 1,100 drums.
At this time, chemical waste piles were also removed and a temporary
clay cap was placed over much of the site.
A press release for the site WIS org1nll11 issued on MIY 31, 1985. This
press release gave a brief description of the site history and hazards
and also identified the EPAls proposed remedial action. At the time
EPA's proposed remedy was a cap-in-place remedial action. A pUblic
meeting was announced for June 26, 1985, and written comments prior to
this meetin~ were to be submitted to EPAls Reginnal Office.
.
A seperate fact sheet, in addition to the RI/FS documents, was placed in
various repositories for public review. The locations of these
repositories was mentioned in the press release. The public meeting
was held on June 26, 1985, at the Gonzales Holiday Inn, in Gonzales,
Louisiana.
Approximate', 120 people attended the pUblic meeting. The EPA conducted
the meeting and the Louisiana Department of Environmental Quality
(LDEQ) had representatives in attendance. In addition to local citizens,
one environmental group was represented. Save Our Selves (S.O.S.) is
an Ascension Parish based group that is actively involved in MOst area
envirOnlentll issues that relate to hazardous waste. The people in
attendance were unanimous in their oPPosition to EPAls proposed remedy.
Everyone wanted to see the complete excavation and r880val of the site
wastes.
Subsequent to this meeting another groundwater sampling effort was
conducted. During this investigation contamination was discovered in a
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the ground surface. Another fact sheet was released on July 1985.
indicating that the Agency would postpone a final decision on the final
remedy until a more comprehensive ground~ter investigation was completed.
The Supplemental Investigation began in January 1987 and fact sheet was
issued indicating the start of the field ~rk~ The investigation ~s
completed in the spring of 1986. The RIfFS report was finalized at the
end of September 1987.
In an effort to solicit public input into the remedy selection process
and also to educate the public on EPA's proposed remedial action, a
technical incineration workshop with those local residents living next
to the site ~s held on December 17, 1986, at the Ascension Parish
Police Jury Offices in Gonzales, Louisiana. The people expressed
interest in EPAls proposal. They were cautiously optiRristic about the
proposal.
The press release for the public 88eting was issued in December 1986;
this announced the proposed remedy and the public comment period. The
public meeting was to be held on January 7, 1986. The meeting was
postponed, however, at the public's request by one 8Onth. A public
meeting was held on February 4, 1987, at the Gonzales Holiday Inn, in
Gonzales, Louisiana. Approximately 400 people attended this meeting.
The EPA conducted the meeting and representatives from LDEQ were in
attendance. Three local environ8ental groups attended the meeting;
S.O.S.; Ascension Parish Residents Against Toxic Pollution (APRATP) and
Ascension Parish Citizens Againsts Toxic Wastes (APCATW). The Sierra
Club was also represented. Most people were in favor of the proposed
remedy of onsite i"cineration ~ the buried Nlstes. Significant concerns
were raised on1y about the actual details to be developed in the Remedial
Design phase.
.
After the public meeting, due to pUblic request, the comment period was
extended one month until March 13, 1987.
II. SUMMARY OF COMMENTS RECEIVED
Summary of the questions asked either during the public meeting or the
public comment period are as follows:
1) Is there any f1nanc;a' assistance Ivailable to help citizens
particIpate in the selection of the remedial action?
SARA provides for up to a $50,000 grant to be made to a citizen
group in order to facilitate public participation and understanding
of technical Superfund data. Not more than one grant 8ay be .ade
with respect to a single Superfund site. Each grant recipient is
required to contribute at least 201 of the total $50,000. The 201
contribution requirement might be waived under certain circumstances.
Currently, it is not known how a determination will be made between
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There are numerous as yet unresolved questions about how EPA should
implement this statutory provision. Questions range from qualifications
and eligibility criteria for interest groups to accounting methodologies.
These issues will be addressed in regulations that EPA will propose
in the Spring of 1987.
2) Will EPA extend the public comment period 3 months to allow citizens
. to further review the documents and make comments?
No. An extension of 30 d~s (until March 13, 1986) was, however,
granted to allow for additional review of the supplemental Remedial
Investigation/Feasibility Study (RIfFS). Prior to the pUblic meeting,
to encourage public involveMent and to attempt to solicit local
input, a technical workshop was conducted for area residents in
December 1986. During t~is meeting copies of the RIfFS were distributed
to interested individuals.
In addition to the above, the public meeting originally scheduled
for early January was postponed until February 4, 1987, in response
to requests from local citizens. EPA has more that fulfilled its
responsibilities to solicit and receive public input in its decision
making process.
3) Has the contamination been clearly defined?
Yes, the extent of the contllination has been defined. Significant
contamination is restricted to the facility boundaries as defined by
the fence l;ne.
To characterize the site. on-~ite and off-site soil and water sam~les
were taken. This included sampling residential wells. Monitorin~
wells were also installed within a one-half mile radius of the site.
Analysis showed all offsite (and residential) wells to be clean.
Testing did not detect any significant offs1te contamination.
Monitoring will be updated to keep data current.
4) Was there, or will there be. any sample splitting by the EPA to
insure the quality of the data?
Yes there WIS. There were splits of selected samples analyzed by
another Jab. which was under contract to a group of companies who
sent wlste to the site. Considering the maintenance of strict
quality assurance and quality controls, confidence is high with
respect to the data quality.
5) How will EPA address health hazards posed to the construction
people associated with cleanup? .
Any potential health hazards posed to the construction people will
be specifically addressed in the design and during implementation of
the remedy. There will be a Site Safety Plan (SSP) which deals
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Health and Safety Officer will be present for all site-related
activities to ensure adherence to the SSP so that all exposed
personnel are protected.
6) How will EPA control dust and noise associated with onsite construction?
The dust and noise from the onsite contruction related activities,
hours of operation at the site, and any other such specifics will be
considered during the Remedial Design. Through best engineering
judgement and continued input fro. the community a design will be
proposed which will be in the best interest of the public. Any
inconveniences will be 8inimized.
7) Will the incineration emissions or ash be toxic?
No. The incinerator will be designed and operated to ensure safe air
emissions and to ensure a nonhazardous ash. Crucial to this will
be the segregation and processing of all wastes prior to entry into
the thermal destruction unit. Air pollution cont~ol and monitoring
devices in addition to ash testing will ensure the proper operation
of the unit.
8) Are any evacuations (temporary or long term) or relocations planned?
No evacuations are anticipated.
9) Will EPA have a SARA workshop in Ascension Parish, since there are 3
NPl sites in the pariSh?
The EPA held a SARA workshop in ~ew Orieans at the end of February
1987. This was mentioned at the pUblic .eeting and people were
encouraged to attend. The EPA will consider holding another workshop
on SARA if the local citizens can generate enough support.
10) Will EPA have information workshops for the local residents?
Yes. Once a decision is made concerning the remedy the EPA will
continue to inform Ind involve the public through fact sheets and
press reJeases. The next .~or step is fOrlUlltion of design plans
for the selected r~. During the cleanup process EPA will hold
workshops to keep the pUblic informed.
11) Why WIS the reme~ changed to thennal destruction?
The intial remedial proposal involved capping the wastes in place.
This was proposed at the public meeting in June 1985.
Two factors attributed to a change in the proposed remedy: 1) The
.discovery that hexachlorobenzene (HCB), the major site contaminant
of concern, was present in a thin, water bearing zone approximately
30 feet below the ground surface (this data indicated, contrary to
earlier investigative findings, the underlying clays are relatively
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technologies which will significantly mitigate or reduce the toxicity,
mobility, or volume of the Nlste. The SARA provisions Specify a
preference for penmanent remedies. The new remedy addresses earlier
concerns with capping .astes in place, and complies with the provisions
and preferences of SARA by penlanently ~~str~~ing the wastes.
12) How will the thermal destruction unit be IOnitored?
The monitoring will be specified in the design. Methods now in use
include such things as monitoring for various indicator parameters
which will examine the efficiency of the thenlal destruction unit.
The detailed design would list the variables which would be continously
checked. Specific acceptable operating li.its which ~uld be analyzed
include: carbon monoxide in stack exhaust gas, Nlste feed rate,
combustion temperature, appropriate indicators of c08bustion gas
velocity, allowable variations to any design par.-eters, etc. These
variables would be examined in a trial burn performance test. Proper
setting of the operating parameters assures the efficient and
effective destruction of the organic wastes.
13) Has incineration been proven a failure throughout the U.S.?
No. Thermal destruction has been successful at various Superfund
sites, including tNO in Florida. These sites, Peak Oil and Sidney
Mines, and other successful thenmal destruction remedies exhibit the
pragmltic acceptability of this technology.
.
14) Will the incinerator ash be hazardous and have to go to a RCRA Class
1 landfill?
No. The ultimate handling of the ash will be I 'actor of the metal
content of the Ish fro. the thermal destruction unit. The organics
will be oxidized but the inorganics can not be thermally destroyed.
If such compounds are found in significant concentrations the
incinerator ash will be chemically stabilized to reduce the mobility
of the inorganic .aste. This is not anticipated to be a problem.
15) Isn1t it true an EPA advisory board study on incineration said
toxicities of stack emissions and incinerator effluents are largely
unknown?
This question tnco~porates a state8ent from the EPA study taken out
of context. The publitation cited is the April 5, 1985, report by
the agency's Science Advisory Board to the Administrator of the EPA.
The report statesi MTo date only a very small portion of the compounds
found in emissions from incinerators has been identified qualitatively
or quantitively. As a consequence the concept of destruction efficiency
(while valid for comparing the relative operating performance of
incinerators) does not completely address the problem of what is
emitted from the incinerator stack and does not, therefore, constitute
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The report also stated, among other things, -Incineration is a valuable
and potentially safe means for disposing of hazardous chemicals, and
EPA has made progress in developing regulatory strategy.- The
committee .ent on to advise, -Comments, both positive and negative.
should be interpreted by the Agency and the public as a desire to
strengthen already existing incinerationprograns rather than to
discontinue what is already in place.-
The report dealt with 80dular incinerators which did .n~t have any
emission controls. EPAls proposal is for a thermal destruction
syste. which would incorporate contaminant handling, segregation,
and processing. This state-of-the-art incinerator will have air
pollution control devices and a feedback control system. Any
discharges would be monitored and .nalyzed.
16) Are there barrels on the surface of the site?
No drums of hazardous materials exist onsite. All such drums containing
hazardous materials were removed by EPA in July 1983. The existing
barrels on the site contain investigation derived material: drill
cuttings, decontamination water, white tyvek suits, etc. These will
be disposed of as part of the Remedial Action.
17) Is there any danger fram cadmium or cadmiUl oxide?
No. Neither cadmium or cadmiUM oxide are contaminants of concern at
the Cleve Reber Site.
18) EPA uses -cost-effectiveness" as an indicator of feasibi1 ity for a
part;cul~r remedy. What is "cost-effectiveness.?
Cost effectiveness is one of many factors that EPA uses to evaluate
and select a remedy. It refers to the ability of an alternative to
achieve the required performance standards for the least money. If
two alternatives provide an equal level of protection, the preferred
alternative will be the less expensive - all other considerations
being equal. The selected remedy, most importantly, must be protective
of human health and the environment.
19) Why should Ascension Parish accept thennal destruction when the
incinerator in St. Helena Parish is being closed?
The St. Helena Parish incinerator is a ca.mercial incinerator. This
permanent facility would be operated on a -for-profit- basis and as
such would have an economic incenitive to receive Ind treat/destroy
high volumes of ~ste. Such an incinerator is nonnally very large.
The incinerator/thermal destruction unit envisioned for Cleve Reber
is completely different. It will be a temporary, mobile onsite unit.
The motivating factor for operation is destruction efficiency; not
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The EPA is not advocating the use of a permanent onsite incinerator.
The mobile unit will be removed after approximately 1.5 years.
20) In the Feasibility Study describing the site. it was stated that there
could be short tenm affects from discharging water to the Panama
Canal. How dangerous will this be?
This will not be a problem. The discharge will cOlpl~ with existing
regulations and requirements that apply to surface water quality.
The potential exists that low concentrations of contaminants would
be discharged into the canal. but such concentrations are not
envisioned to have any adverse environmental impact.
21) Can EPA contract to a Louisiana business to conduct the remedial
action?
The contracting for the site could be done two ways. If the potentially
responsible parties come forward to do the action. they can use
whatever firm they wish. The only stipulation is that this contractor
or vendor meet the standards set forth by EPA.
If the responsible parties do not elect to do the work. the EPA will
fund the clean-up. Any government contracting must follow Federal
procureMent rtgUlations. Under Federal procurement rules no local
preference can be given. Local companies will. however. have an
opportunity to bid on the project.
22) The most appropriate site remedial action cannot be detenmined until
the quantity of wa~te is characterized and located in better detail
EPA has not defined the extent of the allegedly contaminated area.
This is not true. The quantity and location of waste has been
identified in the detail necessary to identify a suitable remedy and
to proceed to the Remedial Design phase.
23) Why is any action necessary at the site since the wastes are contained
.in an al80st vault-like. protecti~e l~er and there is an absence of
contaminated groundwater?
Groundwater contamination does exist in the Shallow Sand (approximately
30 feet). Action is necessary to eliminate the potential for continued
groundwater contamination migration. Such continued .igration would
further contaminate the groundwater. thereby increasing the risk of
human ingestion if an individual was to place a well through or into
the contaminated zone.
24) The contractor's method of drilling test borings and wells and their
failure to plug all such holes increases the potential for vertical
migration of contaminants.
This is not true. The on-site wells and borings have been installed
to minimize the potential for the vertical migration of contaminants.
The wells and borings will ultimately be plugged as part of the
final remedial action. but not before their usefulness has past. EPA
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25} Is it true the newly announced clean-up plan doesn't comply with the
requirements of SARA because it appears to go for a clean-up remedy
that is too permanent and not cost-effective compared to the previously
suggested remedy?
. ..
No. The original Cleve Reber reme~ which involved capping the waste
in place would require perpetual operation and .aintenance. The
original remedy would not reduce volume or toxicity but would possibly
only slow down contaminant migration.
The currently proposed alternative meets the intent and the preference
of SARA. It is the most cost-effective, permanent remedial action
studied. Hot all site contamination is to be excavated and destroyed,
only that which is considered to pose a potential future health or
environmental risk. Residual contamination left on-site will be
sufficiently attenuated in the local cl~s as to not create a future
threat. The site will be capped.
26} Why do you use the term thermal destruction instead of incineration?
Incineration is just one form of then.al destruction. There are
many forms of thermal destruction that can be applied to the site.
The Remedial Design w;ll not specify a particular type of thermal
destruction system, but will emphasize performance standards.
-
27} Can the EPA organize a citizens advisory committee?
In our continuing efforts to enhance public involvement we will look
into the possibility of forming a task force. Such a task force,
~f e~~ab1ished. would 1itell be charged with keeping the pUblic
informed of the day-to-d~ details and act as liason for continuing
public concerns.
28) Can Ascension Parish have their own inspector, trained at the potentially
responsible parties expense?
If the responsible parties voluntarily acted on such a request it
would be their prerogative. The incinerator would be inspected and
monitored on a regular basis by the EPA and the State. Such monitoring
will be sufficient to ensure the effectiveness of the thenmal destruction
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APPENDIX C
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DEPARTMENT OF HEALTH" HUMAN SERVICES
Public Htllt" Service
Agencv for Toxic Substances
and Di.ase Registry
Atlanta GA 30333
llarch 31, 1987
MDl)IARDUM
SUlJECf:
Cl..e aeber Site, A.cen.iou Pari.h, Sorrento, Loui81ana
SI-87-o16
PIOM:
Bealth A..e...Dt aen..er.
Office of Bealth A..e...nt.
aeaional Office for Bealth ae.pon.e - ae.ion VI
TO:
The aecord
EDCU'l'IVE StJMW.ay
The aelion VI Office of the United State. Innron.Dtal Protection
Alency (US!!A) ba. reque.ted the AleDCY for Tozic Sub.tance. and Di.ea.e
aeli.try (ATSDR) to revi.. the final Public Bealth Ivaluation (PBE). for
the Cle.. aebar Site in A.cen.lon Part.h, Sorrento, Loui.iana. Thi.
.ite i. a landfill with a hi.tory of u.e a. a di.po.al area for both
8I111cipal aDd indu.tdal va.te.. More than 60 conta.nante have been
ideDtified at the .ite with Dine (9) .elected a. indicat~r che8ical..
at.k a..e.."Dt. for hypothetical onaite uae yield ezee.. lifeti.
cancer ri.k e.ti..te. of 10-7 to 10-5 for der..l contact aDd .oil iDle.tiou,
and 10-5 to 10-4 for inle.tion of fi.h. While low level. of cODta.nation
vere identified ea.t of the .ite, there ... DO indication that, at thi. tila,
off.ite conta.nation r.pre..nt. a public health proble.. Indication. are
that the Shallow Sand Aquifer hat been conta8inated beDeath the .it..
Bowever, .ince th. aquifer i. not uaed .. a potable vater .ource, a
ri.k a..e...nt for ..ter iDle.tioD ... not calculated. '1'bi. health
a..e...nt, ba.. on additional infor.tion recei~8cI, auperced.. the one
i..uad on Jaauar,J 15, 1987.
OOCUMDTS bvuwu
1. N8mradu.. dat. 15 October, 1986, fro. Stne Cilrein, IPA le.ion
VI, to Carl Bicka.. ATSDR Bealth Adnaor, nA ...iou VI 'ield Office,
requeatiq r8'ri- and ..aluation of the Public Bealth I.aluatiou for
the Cle"a labar Superfund Site.
2.
United Stat.. Geolopcal Survay 7.5' Topolrapbic Map, Goual..
QuadraDlle, Loui.iaDa, dat.d 1961, photorevi.ed 1980.
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MlrthaA.Mldden
IICU1'AI...
oma 0' SOLID AND 1LUA8DOt1I "4ITI
JOHN KOURY
ASSISTANT SECRETAI'"
March 25, 1987
Mr. Allyn H. Davi.
Director
Ra.ardou. Va.te Manal...nt
US IPA aelion VI
1445 10.. Avenue
Dalla., reu.
D1vidon
75202-2733
D:
IUD Cl8CDllDCI 01 CLDI BID IDIIDW. ACnOi
Dear Mr. Davi.:
Ravinl reveived the Fe..ibility'leport aDd CoDceptU8~ Ia.ldi~. Action
propo.al by IPA for the Cleve Reber Superfund Site, the Depart..nt of
Inv1roD88ntal Quality 1. 1n concurrence vtth the propo.ed lle88dial Action.
DIO anticipate. that we will be fully infor88d of prole.. and vill be
liven opportunity to ..ke nece..ary technical co...nt. durin, the In,ine.r1n,
De.ian pha.e of the Cleve leber project.
I wi.h to thank roa for a..t.tance provided by your .taff in di.cu..ion.
01 technical i.8Ue. with DEQ .ta".
Sincerely,
I/oi ~/AM .r..q~
~ Martha A. IIacIcien
cr- - Secretary
MAN/WID/de
INACTIVE AND ABANDONED HAZARDOUS WASTE SITES DMSJON
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