United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R06-93/086
April 1993
Superlund
Record of
American Creosote Works
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50272-101
REPORT DOCUMENTATION 11. REPORT NO. 2. 3. R8c:lplent'. Ace..... No.
PAGE EPA/ROD/R06-93/086
4. TItle and Subtitle & Report Date
SUPERFUND RECORD OF DECISION 04/28/93
American Creosote Works (Winnfield Plant), LA 6.
First Remedial Action - Final
7. AWhor(l) a. Performing Organization Repr. No.
9. Perlannlng Organization Name Ind Address 10 Project TaaklWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Addr81s 13. Type of Report & PerIod Cov8r8d
U.S. Environmental Protection Agency
401 M Street, S.W. 800/800
Washington, D.C. 20460 14.
15. Supplementary Not..
PB94-964208
1&. Abstract (UmJt: 200 warda)
The 34-acre American Creosote Works site is an inactive timber treatment facility
located in the southern portion of Winnfield, Winn Parish, Louisiana. Land use in the
area is mixed agricultural, residential, and recreational, with forests and wetland
areas located in the vicinity of the site. The site borders the Creosote Branch, 'a
perennial creek which flows into the Pont de Luce Creek and later empties into the
Dugdemona River, on two sides. An estimated 7,000 residents of the City of Winnfield
use the Sparta Aquifer that underlies Winn 'parish for their drinking water supply.
From 1901 to 1910, the Bodcaw Lumber Company used the site for wood treatment and
utilized creosote and pentachlorophenol (PCP) in the process. From 1910 until 1938,
Louisiana Creosoting Company operated the wood treatment facility. In 1938, American
Creosote Works of Louisiana, Inc. purchased the facility and operated it until 1977,
when Dickson Lumber Company purchased the land. All onsite operations ceased in 1979.
As a result of the threatened release of hazardous substances from two weakened storage
tanks, a number of EPA investigations conducted in 1987 and 1988 resulted in the
implementation of' an emergency removal action. This removal action consisted of
'draining the tanks and constructing a berm around the process area in order to contain
and stabilize the heavily-contaminated soil. When heavy rain threatened to overflow
(See Attached Page)
17. Document AnaIyIIa L Descriptors
Record of Decision - American Creosote Works (Winnfield Plant), LA
First Remedial Action - Final
Contaminated Media: soil, sludge, debris
Key Contaminants: organics (PAHs, phenols)
b. IdantlfiaralOpanoEndad Terms
Co COSATI FleldlGroup
1& Availability Statement 19. Security Class (This Report) 21. No. of Pa..
None 174
31. Security Clasl (ThIs Page) 2Z. PrIc:8
None
(SM ANSl-Z39,1B)
s.. Instructions on Rall-
OPTIONAL FORM 272 (4-77)
~rty NTJS.35)
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EPA/ROD/R06-93/086
American Creosote Works (Winnfield Plant), LA
First Remedial Action - Final
Abstract (Continued)
and erode the berm, its height was increased and an overflow filtration system was
installed. In 1989, a second EPA removal action was conducted and included consolidating
fluids from all storage tanks into a single tank; constructing a drainage ditch to
redirect surface water away from heavily-contaminated areas; backfilling a drainage ditch
which ran through a contaminated area; filtering and discharging contaminated water from
holding ponds, lagoons, storage tanks, and containment basins to the Creosote Branch;
transferring and solidifying waste wood treating fluids and sludge from onsite storage
tanks and containment areas; and dismantling, decontaminating, and piling building and
process equipment. This ROD addresses contaminated soil, debris, surface sludge, and
NAPLs as the source of onsite hazardous substances. The primary contaminants of concern
affecting the soil, sludge, debris, and NAPLs are organics, including PARs and phenols.
The selected remedial action for this site includes treating 250,000 yd3 of contaminated
soil onsite using in-situ biological treatment; backfilling, capping, and revegetating all
soil treated for organics; capping contaminated surface soil; excavating and incinerating
onsite 25,000 yd3 of contaminated tars and sludge from the tar mat area, which contain
greater than 3,000 ug/kg benzo(a)pyrene equivalents and/or greater than 50,000 ug/kg PCP;
landfilling incinerator ash from the sludge remediation process onsite; decontaminating
and landfilling all process equipment and debris onsite; pumping ground water to remove
light and dense NAPLs; separating the NAPLs using an oil/water separator, followed by
onsite or offsite treatment using thermal destruction; and utilizing the ground water
extraction system for NAPL recovery to hydraulically control any offsite migration of
ground water contamination. The estimated present worth cost for this remedial action is
$46,000,000, which includes an estimated annual O&M cost of $750,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific cleanup goals are based on health-risk criteria and SDWA MCLs, and
include benzo(a)pyrene 3,000 ug/kg for soil and sludge; pcp. 7,400 ug/kg for sludge; and
benzene 5 ug/l and benzo(a)pyrene 0.2 ug/l for NAPLs. Chemical- specific debris cleanup
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-~ . --- .
RECORD OF DECISION
AMERICAN CREOSOTE WORKS, INC. SITE
WINNFIELD, LOUISIANA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
-------
DECLARATION FOR THE RECORD OF DECISION
AMERICAN CREOSOTE WORKS INC. SITE
Statutory Prtference for 7Teatment
as a Principal Element
is Met and Fwe-Year Reviews ~ Required
SITE NAME AND LOCATION
American Creosote Works, Inc. site
Winnfield, Louisiana
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the American Creosote Works, Inc., in Winnfield, Louisiana, which
was chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended by the superfund Amendments and Reauthorization Act of 1986
(SARA), and, to the extent practicable, the National contingency
Plan (NCP). This decision is based on the Administrative Record
for this site.
The united states Environmental Protection Agency (EPA), Region 6,
has consulted the Louisiana Department of Environmental Quality
(LDEQ) on the proposed remedy, and LDEQ has written confirming
agreement with the proposed remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
si te, if not addressed by implementing the response action selected
in this Record of Decision, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
This Record of Decision (ROD) addresses the ,source of hazardous
substances, as defined at section 101(14) of CERCLA, 42 V.S.C.
S 9601(14) and further defined at 40 CFR S 302.4, which includes
surface sludges, subsurface pooled creosote and pentachlorophenol
liquids defined as nonaqueous phased liquids (NAPLs), and
contaminated soil and debris. This is the final remedy and
addresses remediation of the source of shallow ground water
. contamination and contaminated soils at the American Creosote
Works, Inc. site. The principal threats posed by the site will be
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RECORD OF DECISION
AMERICAN CREOSOTE WORKS, INC. SITE
WINNFIELD, LOUISIANA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
-------
~, :.4;;.. ----~-- n-
"
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable and satisfies the statutory preference for
remedies that employ treatment that reduces toxicity, mobility, or
volume as a principal element.
Because this remedy will result in hazardous substances remaining
on site for potentially several decades, a review will be conducted
within five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of public
health, welfare, and the environment.
~ .~...~
C"", Joe D. Winkle
~ Acting Regional Administrator
u.S. EPA - Region 6
~q3-
-------
This ROD addresses the principal threat at the site by thermal
destruction (incineration) of the contaminated sludges and in-situ
bioremediation of contaminated soils, thereby eliminating the
potential for contaminant migration to surface waters and ground
. waters. The principal threat at the American creosote Works, Inc.,
site is posed by NAPLs and contaminated soils which are
contaminating the shallow ground water. Additional threats are
from direct contact with creosote and pentachlorophenol sludges and
soils at the surface of the American creosote Works, Inc., site.
The remedial objectives are to minimize potential exposure by
direct contact and to reduce the potential for migration of
contaminants into the surface waters and ground waters.
The major components of the selected remedy include:
(l) Pum'D. seDarate and treat liauid contaminants. Light nonaqueous
phased liquids (LNAPLs) and dense nonaqueous phased liquids
(DNAPLs) would be pumped from the zones of pooled product
beneath the site, separated from the water, and destroyed by
on- or off- site incineration.
(2) On-site incineration of 25.000 cubic yards of hiahly
contaminated tars and sludaes. 25,000 cubic yards of tars and
sludges located in the "sludge overflow area" of the site,
which is the most hiqhly contaminated material, would be.
excavated and thermally treated on-site. The incinerator ash
would be landfilled on-site. .
(3) In-situ bioloaical treatment of 250.000 cubic vards of
contaminated soils. The remainder of the site's contaminated
soils/sludges from process areas and buried pits would be
addressed in-situ by injecting, via wells, nutrients, microbes
and oxygen as is necessary to attain stated treatment goals.
The ground water extraction system used for NAPL recovery
would also be used to hydraulically control any off-site
migration of ground water contamination and allow for
potential recirculation of the bacteria for efficient
treatment.
Because of the expected pace of remediation, the EPA would
categorize this site remediation as a Long Term Remedial
Action. What this means is that the implementation of this
.alternative is expected to take several years. The EPA will
be responsible for 90% funding beyond the customary 1 year
time associated with the operational and functional period of
the completed remedy. 90% fundinq will continue until such
time as the established remediation goals are met. The state
of Louisiana will be responsible for 10% of the costs. This
component is innovative and is expected to provide permanent
treatment.
(4) Ca'D'Dina of surface contaminated soils. decontamination and on-
site landfillina of 'Drocess eauiDment and scra'D. Grading and
capping would be done to complement the. above remedial
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AHBRJ:CAH CRBOSOTB WORKS, DC.
SUPBRFmm SITE
DECISIOH SUMHARY
"
1.0
SIH LOCATIO. AND DESCRIPrION
The American Creosote Works Inc., site, hereinafter referred to as
American Creosote, is located in the southern portion of the City
of Winnfield, in Winn Parish, Louisiana (See Figure 1). The
property consists of approximately 34 acres east of Front Street
and north of Watts and Grove streets as depicted in Figure 2. The
facility is bounded on two sides by Creosote Branch, a perennial
creek which flows. in a 10-12 foot deep valley. Surface drainage is
predominantly via three man-made ditches and a single natural
drainage pathway which flow into Creosote Branch. East of the
former facility is a denuded area containing a mat of tar-like
material, and further east is a densely vegetated area surrounding
the City's sewage treatment plant.
2.0
SITE HISTORY AND ENFORCEMENT ACTIVYTIES
2.1
SITE OPERATIONS HISTORY
The facility was used for treating timber with. creosote and
pentachlorophenol (PCP) for over 80 years. Both creosote and PCP
have been identified as hazardous substances as defined at section
101(14) of the Comprehensive Environmental Response, compensation,
and Liability Act (CERCLA), 42 U.S.C. 5 9601(14) and further
defined at 40 Code of Federal Regulations (CPR) i 302.4. The
American Creosote site began operations in 1901 under the direction
of the Bodcaw Lumber Company. This firm owned 61 acres of land in
the area of the site. In 1910, Bodcaw Lumber sold 22 acres of the
property to the Louisiana creosoting Company. Records of site
operations for the period of ownership by either of these two
companies are unavailable. In 1938, American Creosote Works of
Louisiana, Inc., purchased the property from Louisiana creosoting.
American Creosote Works ran the facility from 1938 until 1977,
during which time it acquired an additional 12 acres of adjoining
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.'
RECORD OF DECISION
CONCURRENCE DOCmlENTATION
FOR '1'BB
AMERICAN CREOSOTB WOlUtS, INC. SUPERFtmD SITE
MNNPIELD, LOUZSIAD
r:ifl~$1~3
site Remedial project Manager
Jo n D dale
Office of Regional Counsel
site Attorney
~~ "'-\C(-~3
stephen Gilrein, chief
~:~-SA
,. e,.......--........
.. -----...
carl Edlund, Chief
Superf d ogram Branch 6H-S
Hark Peycke, ct 9 Chief
Office of'Regional Counsel
Hazardous Waste Branch 6C-W
George Alexanaer, Jr.
Regional Counsel 6C
~~.
Al n M. Davis
Hazardous Waste Management
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POST-REMOVAL
SITE MAP
AMERICAN CREOSOTE
WINNFIELD LOUISIANA
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American Creosote
Winnfleld, Louisiana
Site Location Map
Figure No.:
1
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PRE-REMOVAL
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. UISIANA
-------
property. In 1977, the facility was purchased by the Dickson
Lumber Company which was later declared bankrupt and seized by the
City of Winnfield for taxes. The property was then purchased by
stallworth Timber Company in 1980. : b -
Aerial photographs were utilized to interpret site conditions over
the operational history, as reported below and shown on Figure 3.
Aerial photographs provide evidence that the facility was well
established by 1940. An office building was present west of
Creosote Branch along Front street and just south of the main
entrance. Wood-treating operations were concentrated in the
north-central portion of the site (the process area). The process
area consisted of a boiler building flanked by pressure chambers,
or retorts. A tank farm consisting of several vertical tanks
lacking secondary containment was present immediately east of the
boiler building. The southern half of the property was used
primarily for debarking, cutting, and staging timbers prior to
treatment.
Several sets of railroad tracks, used to transport treated and
untreated lumber around the facility, ran from the sout1:lwest corner
of the site north and northeast through the process area to the
northeast portion of the site. The railroad tracks crossed
Creosote Branch on three trestles north of the process area.
Stacks of untreated lumber were present during plant operations in
the southwest and western portions of the site. Stacks of treated
lumber were evident in the central and north-central (north of
Creosote Branch) portions of the site. In the 1940 photographs an
unnamed drainage pathway in the northeast portion of the site
follows a meandering path from the process area north and east
(through an area later referred to as the "tar mat") to a
confluence with Creosote Branch.
Between late 1950 and mid 1952, two impoundments were constructed
east of the process area (Impoundments land 2 on Figure 3). These
impoundments probably received liquid wastes from the wood treating
. process including water, tree sap ~ creosote, petroleum distillates,
and PCP. A third impoundment was constructed east of a new retort
in the early to mid 1960's (Impoundment 3 on Figure 3). Based on
-------
Judging from the quantity of treated and untreated wood stockpiled
onsite, operations were taking place on a much smaller scale after
1980, than during the period of ownership by American Creosote
Works, Inc. By 1983, Impoundments 2 and 4 had been backfilled,
presumably with wood chips and soil, and the impoundment retaining
walls had been demolished. Impoundment 3 was apparently still
active. Evidence of continuing wood treating operations is present
in photographs taken in 1983 and 1984.
In summary, the facili ty was used for over 80 years as a wood
treating operation that utilized creosote and PCP in the treatment
process. The facility also incorporated petroleum products as a
carrier fluid for the creosote and/or PCP. Based on a review of
available records and site sampling activities there is no reason
to believe this facility used inorganic compounds (i.e.. chromated
copper arsenate, ammoniacal copper arsenate, etc.) in the treatment
process.
2.2
ENFORCEMENT ACTIVITIES
The Lo~isiana Department of Environmental Quality (LDEQ) issued a
. -
letter of warning to stallworth Timber Company in January 1983, in
response to releases of contaminants to the environment. In
December 1984, LDEQ found no environmental improvements and issued
a Compliance Order the next month. In June 1985, LDEQ inspectors
found the site abandoned. In March 1987, LDEQ referred the matter
to the Environmental Protection Agency (EPA) Region 6, requesting
it to take action. Under EPA'S direction, several investigations
of the site were conducted in 1987 and 1988. In 1989, the EPA
Emergency Response Branch conducted a removal action pursuant to
section 106 CERCLA , 42 U.S.C. ~ 9606, having determined that
actual or threatened releases of hazardous substances from the site
posed an imminent and substantial endangerment to the human health
or the environment. This response action at the American Creosote
site included source control and contaminant migration control
actions. At the time the site was found abandoned, it consisted of
15 tanks, four pressure vessels or retorts, a boiler building, a
tool and die shop, offices and other administrative buildings, and
several unlined waste impoundments. .
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the aerial photographs, the mid- to late- 1960's appear to be the
period of maximum acti vi ty or production at the American creosote
site. Records discovered in a shed on site provide information
regarding the maqnitude of the American creosote operation during
that time. According to these records, for a seven-month period
ending July 31, 1966, more than 750,000 gallons of petroleum
distillate, 40,000 gallons of creosote, and 54,000 pounds of pcP
were used to treat approximately 7.5 million board-feet of wood.
Impoundment 1 was apparently backfilled with soil and wood chips
between 1967 and 1970. Apparent in the 1973 photographs is the
development of the tar mat area, perhaps resulting from a single
spill event. Located approximately 500 feet east of the process
area, the tar mat is a large, flat, asphalt-like layer which
extends over a marshy portion of the site. A number of mature pine
trees located within the tar mat appear to have died shortly before
the 1973 photographs were taken. Between 1973 and 1976, extensive
earth moving operations north and east of the process area covered
up most of the darkly stained soils and obliterated the remains of
Impoundment 1. Impoundment 4 (Figure 3) was built immediately
north of Imp~undment 2 and may have been used to contain drainage
. from Impoundment 2. A pond was constructed just. south of
Impoundment 2 to collect and store water for emergency fire
. fighting purposes. Based on the volume of treated and untreated
wood present onsi te, wood treating operations may have been
declining during this period.
By 1979, wood treating operations at the American creosote site
appear to have ceased. No untreated wood and very little treated
wood are present in aerial photographs taken at that time. All
railroad tracks had been removed from the site. This roughly
coincides with the time at which the site owner, Dickson Lumber
Company, was declared bankrUpt and seized by the city of Winnfield.
Aerial photographs taken in 1981, short1y after the site was
purchased by Stallworth Timber Company, provide evidence of the
resumption of wood treating activities at the site. A large
drainage ditch was excavated from the south-central portion of the
site north and east between the process area and Impoundment 2.
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....
conducted an emergency removal action at the site pursuant to
section 106 of CERCLA, 42 U.S.C. S 9606. The following steps were
taken to stabilize the site.
3.0
.
Fluids from all storage tanks were consolidated into a
single tank (approximately 10,000 gallons of creosote and
PCP treating fluids, 51,000 gallons of contaminated
water, and 56,000 gallons of sludge).
.
An east-west drainage ditch was constructed to redirect
surface water originating from the southern portion of
the site away from the heavily contaminated northern
portion.
.
The largest north-south drainage ditch running through
the most contaminated area was backfilled.
.
contaminated water from holding ponds, lagoons, storage
tanks, and containment basins was filtered and discharged
to Creosote Branch.
.
Waste wood treating fluids and sludges from storage tanks
and contaminant areas were transferred to a former
impoundment (Impoundment 3), solidified with fly ash and
rice hulls, and capped.
.
Building and process equipment were dismantled and an
attempt was made to decontaminate the debris. This
debris was placed in a scrap pile immediately northwest
of the process area.
OOMMUNXTY PARTICIPATXON
EPA'S community relations activities started during the removal
action with door-to-door interviews with residents surrounding the
site. During the 1989 removal action residents of the community
were also sent an information bulletin and regular meetings were
held with the Mayor and police Chief of Winnfield. The site was
proposed for inclusion on the National Priorities List (NPL) in
February 1992 and placed on the NPL in October 1992. Compilation
-------
In December 1991, representatives of EPA, the united states
Department of Justice, and the Stallworth Timber Company met. The
purpose of the meeting was to discuss reimbursement to the United
States Government for past response costs incurred and future costs
to be incurred at the site by the United states. During the course
of this meeting the United states learned that the stallworth.
Timber Company had sold the property in 1990 to Reinhardt
Investments located in the Netherlands Antilles. In addition,
during this meeting the Stallworth Timber Company was provided the
opportunity to conduct the Remedial Investigation (RI) and future
activities (~, Feasibility Study (FS), Remedial Design (RD),
Remedial Action (RA» associated with the site. The Stallworth
Timber Company indicated in the meeting and subsequently by letter
dated December 12, 1992, its reluctance to conduct this work due to
financial inability. Further inquires to Reinhardt Investments
have provided no response.
2.3
RESPONSE ACTION
The results from EPA' s investigative efforts provided evidence that
the site posed a significant human health and environmental threat.
In May 1988, the EPA issued an Administrative Order to Stallworth
Timber Company to fence and post warning signs around the most
contaminated portions of the site. In July 1988, the fencing of
the site was completed by stallworth Timber Company. During
oversight monitoring of this action, an EPA's Emergency Response
Cleanup Services (ERCS) contractor noticed that two storage tanks
were in imminent danger of rupturing. Stallworth Timber Company
was verbally notified by EPA of this threat and declined the
opportunity to respond. This prompted immediate mobilization of an
ERCS team to drain the tanks and construct a berm around the
process area in order to contain and stabilize the heavily
contaminated soils. Following this work, heavy rain threatened to
overflow and erode the berm. Consequently, ERCS was remobilized to
extend the berm height and install an overflow filtration system.
In February 1989, the EPA issued a Unilateral Administrative Order
to the Stallworth Timber company for a removal action to address
the immediate threats posed by the site that were found during the
previous investigations. Stallworth Timber company declined to
take action, and between March 17 and August 31, 1989, EPA
-------
EPA and LDEQ evaluated written and verbal comments recorded during
the aforementioned comment period and considered the cost for full-
scale incineration at approximately $185 million. In March 1993,
LDEQ and EPA released a new proposed remedy for the American
Creosote site which combined elements of remedies previously
proposed and added in-situ biological treatment for the bulk of the
buried contaminated soils. The suggested remedy consisted of the
following components:
(1) Pumn. se-oarate and treat liauid contaminants. LNAPLs and
DNAPLs would be pumped from the zones of pooled product
- beneath the site, separated from the water, and destroyed by
on- or off- site incineration. (Proposed in July, 1992.)
(2) On site incineration of 25.000 cubic yards of hiahlv
contaminated tars and sludaes. 25,000 cubic yards of tars and
sludges located in the "sludge overflow area" of the site,
which is the most highly contaminated material, would be
excavated and thermally treated on-site. Ash would be
landfilled on-site. (Proposed in August, 1992.)
(3) In-situ bioloaical treatment of 250.000 cubic vards of
contaminated soils. The remainder of the site's contaminated
soils/sludges from process areas and buried pits would be
addressed in-situ by injecting, via wells, nutrients, microbes
and oxygen as is necessary to attain stated treatment goals.
The ground water extraction system used for NAPL recovery
would also be used to hydraulically control any off site
migration of ground water contamination and allow for
recirculation of the bacteria for efficient treatment.
Because of the expected pace of remediation, the EPA
would categorize this si te remediation as a Long Term
Remedial Action. What this means is the EPA will be
responsible for 90% funding beyond the customary 1 year
time period; 90% funding will continue until such time as
the established remediation goals are met. The state of
Louisiana will be responsible for 10% of the costs. This
component is innovative and is expected to provide
permanent treatment. (Based on comments/ information
received during the public comment period.)
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of the administrative record for the remedial action also began in
February 1992 along with a public open house to notify the public
of planned activities. A subsequent open house was held in July
1992, to discuss the RJ:, FS, and the administrative record for the
project. During and subsequent to the RI numerous contacts were
made by EPA representatives with the Mayor of winnfield.
A Proposed Plan for the American Creosote site was released to the
public on July 29, 1992, after discussions with LDEQ. The proposed
Plan was sent to individuals on the mailing list for the project
and to the administrative record repository locations at the
Winnfield Public Library and at the offices of LDEQ in Baton Rouge,
Louisiana and EPA Region 6 in Dallas, Texas. The notice for
availability of the RIfFS, Proposed Plan, and Administrative
Record, and the announcement for the public meeting was advertised
on July 29, 1992 in the winnfield Entercrise-News-American. On
August 3, 1992, EPA held a public meeting with transcripts taken
and subsequently added to the Administrative Record. The public
meeting was attended by representatives from LDEQ and Louisiana's
Office of Public Health. On August 26, 1992, EPA received a
written re~est from the Mayor of Winnfield requesting an extension
to the comment period and the need for an additional meeting. The
public comment period was subsequently extended for an additional
30 days and a second public meeting was held on September 15, 1992.
Based on preliminary discussions between EPA and the State of
Louisiana, EPA had issued a recommendation in the July 29 proposed
plan for capping surface wastes and pumping and treatment of
contaminated ground water and subsurface oils. Subsequent
evaluations within EPA, and discussions with the State and the
community (based on the August 3, 1992, public meeting) had shown
that incineration of the wastes was more acceptable to the public
in meeting goals to remediate the site. In response to this, EPA
issued a notice and the local news media published articles about
the possible use of onsite incineration in early september 1992.
During the public meeting of September 15, 1992, the city council
and mayor, and over 50 individuals from the local area, responded
to EPA's proposed alternatives to remediate the site. The number
of people at this meeting was significantly greater than the
previous one that was attended only by 4 individuals.
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- .,.
A moderate risk is present primarily from direct contact of the
surface materials in the tar mat area and to a lesser degree the
surface soils from the process areas of the site. The obj~ctives
for remediation of this site are to prevent direct contact and/or
ingestion of hazardous substances, pollutants, or contaminants that
pose a significant human heal th or environmental risk. The
sediments within Creosote Branch are below criteria that represent
a threat to human health, but do represent some environmental
threats when disturbed. However, the environmental threats posed
by removal of these sediments both to wetlands and possible
releases during excavation provides a greater threat than leaving
the materials undisturbed. The remedy outlined in this ROD
represents the final remedial action at the site.
5.0
SITE CHARACTERISTICS
5.1
DEMOGRAPHY AND LAND USE IN THE AREA OF THE SITE
Land in the Winnfield area supports agricultural, residential, and
-recreational uses. Agricultural uses are localized in a few small
areas between forested lands and residential housing. The crop
land is cultivated for several different types of crops including
soybeans, wheat, cotton, and corn. The forests within the area are
used for lumber production and several lumber mills exist in the
surrounding area of Winnfield. A large lumbermill which produces
fence posts and other forestry products is located immediately
north of Creosote Branch adjacent to the Kansas-Missouri Railroad.
Production of lumber has been a primary industry in the area for
several decades. Lumber produced includes wood from trees such as
the white pine, cypress, hickory, and oak.
Residential neighborhoods are present in all directions from the
site. The city of Winnfield has a population of approximately
7,000 residents. Numerous businesses and private residences are
located within the city, which covers approximately two square
miles. A housing development lies to the south of the American
Creosote si te along McLeod and Watts - Streets. Based on the
location of this site with respect to these surrounding properties,
a residential rather than industrial scenario appears to be
appropriate for considering potential future land usage.
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(4) Caonina of surface contaminated soils. decontamination and on-
site landfillina of nrocess eauioment and scrao. Grading and
capping would be done to complement the above remedial
actions. (Proposed in July, 1992.)
The net cost of this set of remedies was estimated between $40-$50
million which is significantly less than the total cost of the
incineration remedial option (approximately $185 million) and more
environmentally protective than the original pumping/capping
proposal. Biological treatment of creosote-contaminated soils is
being attempted at numerous wood treater sites nation~ide.
Although biological treatment for the site was initially screened
from consideration early in the Feasibility study, in light of the
comments received and considering the extreme cost of complete on-
site incineration, the EPA and LDEQ reconsidered bioremediation.
A response to the comments received during the comment period is
-included in the Responsiveness Summary which is part of this Record
of Decision (ROD). This decision document presents the selected
remedial action which was chosen in accordance with the CERCLA, th~
administratiye record, and to the extent practicable, the National
contingency Plan (NCP), 40 CFR Part 300.
4.0
SCOPBAND ROLE OJ' RESPONSE ACTION
The primary focus of the American Creosote RI/FS and this ROD was
to evaluate findings of previous investigations, to collect
additional information that would assist in characterizing current
and future risks, and to develop and evaluate long term and
permanent remedial action alternatives. This is the only planned
operable unit for this site.
Based on the evaluation of the wood treating process, findings of
previous investigations and the results of the RI field
investigation, the sources and the areas of environmental
contamination at the American Creosote site have been delineated.
The principal risks to the residents is from creosote and PCP that
is found in subsurface soils and in pooled layers wi thin the
subsurface, together these sources are contaminating ground water.
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5.3
GEOLOGY
The Cockfield Formation is the only bedrock unit outcropping at the
American creosote site. It is nonmarine in origin, derived from
predominantly continental sediments, and consists of interbedded
silty sands and lignitic shales. The presence of lignite within
the formation is an identifying characteristic. The individual
beds are very thin, ranging from less than an inch to a few feet
thick. The Cockfield Formation is approximately 150 feet thick in
the Winnfield area.
The process area at the American Creosote site is underlain by .
prairie Terrace deposits. These unconsolidated and poorly bedded
deposits are up to 100 feet thick and are composed of gravels,
sands, and silts. The grading within the terrace deposits show a
fining upward sequence with gravels common at the base. The
Pleistocene deposits lie unconformable on th~Cockfield Formation
in the northern portion of the site, and form a wedge which thins
to the south. This relationship is illustrated in plan view and
in cross-section presented on Figures 4 and 5.
5.4
HYDROGEOLOGY
Potable water is found primarily in the confined aquifers within
the sparta Sand and Cockfield Formation. Fresh water is present in
the upper portion of the Sparta Aquifer underlying north-central
Louisiana. A saline layer is preseht at depth. The Cockfield
Aquifer consists of interbedded silty sands and produces lower
yields of potable water than that of the sparta Sand.
Underlying Winn Parish, the more permeable sparta Aquifer is found
at depths of 180 to 300 feet and yields large quantities of fresh
water. The Cockfield Aquifer, which lies on top of the sparta
Sand, has pockets of interbedded silty sands that have lower yields
in this area and is not economical for municipal well withdrawal.
Heavy withdrawal from municipal and industrial wells in OUachita
Parish, northeast of winn Parish, has changed the Winn Parish
regional ground water flow direction from east-southeast to
north-northeast. The fresh/saline water interface is found at
depths of approximately 600 feet. The increase in the amount of
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5.2 SURFACE WATER HYDROLOGY
Surface water from the American Creosote site drains into Creosote
Branch, which crosses the western and northern portions of the
site. Creosote Branch is a small creek with banks 10 to 12 feet
high. Approximately two miles east to southeast of the site, the
Creosote Branch joins with the Port de Luce Creek, which flows for
another three miles to the southeast and then joins Cedar Creek
before emptying into the Dugdemona River.
The southern part of the site is topographically higher than the
northern part of the site due to outcrops of bedrock in this area.
A manmade drai;nage ditch runs north-south through the middle of the
southern portion of the site. In the southeast portion of the site
the land is dissected to about one to three feet deep in many
places exposing the bedrock. Rapid runoff in this area was
observed several times during the RI. The southwestern portion of
the site is characterized by more recent alluvial sediments of low
relief draining by overland flow to the north. This portion of the
site drains very slowly and is commonly the location of large
standing pools of water. Drainage from the southern part of the
site is intercepted by the east-west drainage ditch excavated by
the EPA in 1989. These drainage ditches are approximately five
feet deep and drain west towards Creosote Branch.
Surface water flow in the process and impoundment areas of the site
is best described by dividing this portion into three areas. The
northwestern third is drained primarily by overland flow. This
water enters Creosote Branch west and northwest of the process
area. The topography in this portion of the site has very little
relief and water tends to pool or stand following heavy rains. One
large area where water tends to pond is located at the south end of
the existing waste cell. Durinq the RI, water in this area was
approximately two to three feet deep. The north-central portion of
the site is drained by several manmade ditches. These drainaqe
ditches run northward into Creosote Branch. Surface waters in the
north-east portion of the site flow into an unnamed natural
drainage pathway running eastward and northward then enter Creosote
Branch just upstream of the sewage treatment plant. This creek is
the site of a large tar mat which formed as a result of site runoff
and/or discharges from the process area.
-------
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AMERICAN CREOSOTE
WINNFIEUJ. LOUISIANA
F~gure No:
4
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ground water usage from municipal and industrial wells has lowered
the water table up to 120 feet in Winn Parish which has caused a
rise in the underlying saline water as reported in the RI.
Ground water within the Prairie Terrace deposits appears to be
under confined conditions. During drilling, saturated materials
were first encountered at a depth of eight to ten feet. OVer a
period of several hours, water would rise in the borehole to wi thin
a few feet of the surface. Saturated conditions continued downward
throughout the alluvial deposits. In some instances, interbedded
sil t of the Cockfield Formation encountered between the shallow and
deep aquifer zones was found to be unsaturated. Potentiometric
contours indicate the shallow aquifer zone discharges to creosote
Branch along the northern and southern boundaries. Flow direction
within most of the site is to the north, towards Creosote Branch.
The presence of an upward vertical gradient suggests ground water
flow may exist from the deep to the shallow aquifer zone. This
flow would be impeded by the interbedded silts and sandy silts
present between these aquifer zones.
5.5
FIELD INVESTIGATIONS
A field investigation was conducted from February 10, 1992, to
March 15, 1992. The investigation was conducted according to plans
and procedures described in the Field Sampling Plan that is part of
the administrative record. The field investigation included the
following tasks:
.
site survey and mapping
Surface soil investigation
Surface water and sediment investigation
Subsurface soil investigation
Ground water investigation
Waste characterization sampling
.
.
.
.
.
Extensive perimeter air sampling was not considered to be necessary
during the RI since previous investigations found no air emissions
at the site perimeter caused by the investigative efforts.
During these investigations it was noted that approximately 2,500
cubic yards of debris are present on the surface and buried at the
-------
American Creosote site. Limited alternative approaches are
available for addressinq debris at the site. Based on findinqs
made during the removal action, it is assumed that the debris on
the surface (~., retort vessels, tanks, concrete, etc.) has been
decontaminated to the maximum extent practicable. This debris
alonq with any additional debris discovered durinq excavations will
be buried in an acceptable location wi thin the site boundaries that
does not affect any selected remedy as described elsewhere within
this ROD.
Table 1 provides a listing of previous investiqations at the
American Creosote site. The data from these previous
investigations, as presented in Appendix A, were utilized to
supplement the RI data where appropriate. The sampling locations
from these investiqations are presented in Fiqure 6, and are
referenced in the followinq discussions. soil data from previous
investigations are most useful for those areas not disturbed during
the 1989 removal action at the site. soil samplinq in the current
investigation focused on providinq information in those areas
modified durinq the removal action or not covered by previous
sampling.
The following discussion on samplinq results relate primarily to
creosote, PCP, and the contaminated petroleum carrier fluids that
were utilized at the site and that constitute hazardous substances
as defined at CERCLA Section 101(14), 42 U.S.C. i 9601(14), and
further defined at 40 CFR S 302.4. The risk assessment evaluated
all ,compounds that were detected and the results of these analyses
are presented elsewhere in this ROD. Creosote, which is made up of
polynuclear aromatic hydrocarbons (PARs), consists of over 300
compounds. Some of these compounds have been identified as
potential carcinogens, the most potent of which is benzo(a)pyrene
(B(a) P). The carcinoqenic PAR compounds have been equated to B(a) P
by multiplyinq the concentration of the compound by a correlation
factor (~, chrysene concentrations are multiplied by 0.01 to
qive B(a)P equivalent). This calculation is conducted because
creosote compounds other than B(a)P present significantly less risk
and it would be overly conservative to assume they were as potent
as B(a)P.
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Figure No: 6
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-------
~
TABLE 1
SUMMARY OF PREVIOUS INVESTIGATIONS
AT THE AMERICAN CREOSOTE SITE
Investigative Team
Technical Assistance Team (TAT)
Emergency Response Team (ER1)
Emergency Response Team (ERl)
Emergency Response Team (ER1)
Field Investigative Team (FIT)
Technical Assistance Team (TAT)
Date
March 1987
August 1987
September 1987
November 1987
Februal}' 1988
Activities
. Visual inspection to detennine nature and extent of contamination
. Multi-media environmental sampling program to assess contamination
. Asbestos analysis of fibers on retorts
. Subsurface soil samples collected and analyzed from 23 borings drilled
along 4 transect lines - soil samples collected and analyzed for priority
pollutants
. Waste volume estimates calculated
. Funher sample collection undenaken - emphasis on surface soil,
sediments and air samples .
. Demographic and geophysical survey undenaken
June - July 1988 . Seismic refraction survey and slug test undertaken to detennine
subsurface features and hydraulic conductivity, respectively
. Detennination of soil textures from sieve and hydrometer tests
. Collection of additional subsurface soil samples from new boreholes
-------
UCEND
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SURFACE SOIL. SURFACE
WATER, AND SEDIMENT
SAMPLING LOCATIONS
AMERICAN CREOSOTE
WINNFIElD, LOUISIANA
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5.5.1
SURFACE SOIL INVESTIGATION
The aim of the surface soil sampling program was to define the
extent and magnitude of surface soil contamination at the site.
Twenty-one surface soil samples were collected during February and
March 1992, for the RI/FS at the American Creosote site. Figures
6 and 7 illustrate surface soil sampling locations from the
previous removal action and RI investigations, respectively. Data
for surface soil samples collected during the previous and RI
investigations are presented in Appendices A and B, respectively.
Surface soils with the highest concentrations of organic compound
contamination are located in the former process area. The former
process area consists of approximately five acres in the northwest
portion of the site, south of Creosote Branch. organic compounds
detected in surface soils of this area consist primarily of PARs
with lesser concentrations of phenols. No volatile compounds were
.detected in any surface soil samples collected during the current
: investigation. sampling locations in the former process area
. included SS-l, SS-2, SS-4 through SS-9, SS-13, and SS-lS. Soil
samples fr~m most of these locations showed visible signs of
contamination, including black stains, pieces of hardened creosote,
and a creosote odor. All of these compounds are hazardous
substances as defined by CERCLA section 101(14), 42 U.S.C.
~ 9601(14), and further defined at 40 CFR ~ 302.4.
Concentrations of individual PAR compounds in the former process
area are typically in the thousands or tens of thousands of
micrograms per kilogram (~g/kg). B(a)P equivalent concentrations
are present in concentrations ranging from 2,400 ~g/kg (SS-6) to
30, 000 ~g/kg (SS-3). Pentachlorophenol (PCP) concentrations
similarly vary from less than 1 ~g/kq (SS-2) to 2,100 ~q/kq (SS-5).
At 88-5, which was among the most contaminated surface soil
samples, the soil was also analyzed for dioxin concentrations. A
calculated 2,3,7,S-tetrachlorodibenzo-p-dioxin (2,3,7,S-TCDD)
equivalent concentration for this sample is 5.32 ~q/kq.
-------
the site had 27~600 ,sg/kg of B(a)P and less than 1.0 ,sg/kg of PCP.
This last sample was collected in a location used briefly for
treated wood storage based on historical aerial photographs.
Subsequent resampling of the same area in July 1992 showed a
maximum concentration 2,900 ,sg/kg for B(a)P out of six samples.
The previous data from this sampling location is considered invalid
and, therefore, is being replaced with this new maximum value.
Lack of significant concentrations in this area is supported by the
sampling efforts prior to the 1989 removal action.
Surface soil data for three samples collected north of Creosote
Branch demonstrate slight levels of contaminants in stained soils
at the railroad bridge crossing (SS-19) and lower levels further to
the north (SS-21, SS-22). The B(a)P equivalent concentration for
SS-19 is 1,399 ,sg/kg and PCP was detected at 1,400 ,sg/kg. Samples
SS-21 and S5-22 contained 2,312 ,sg/kg and 5 ,sg/kg B(a)P equivalents
respectively, and no PCP was detected in either sample. Also of
~ote, subsurface soil data for this portion of the site suggest
that PAR concentrations decrease rapidly with depth. Samples BH-12
and BH-13 were collected at a depth of 5 feet at the same locations
'as SS-22 and SS-21, respectively. Analytical results for these
samples indicate no detectable PAHs at these depths, implying
minimal potential for downward migration of PARs from surface soils
in this area.
Three surface soil samples were collected from the office area
during previous investigations. These data provide information
about contaminant levels west of Creosote Branch. The three
samples, 55, 56, and 57, contained low contaminant concentrations
that were less than 300 p.g/kg B(a)P equivalents.
In summary, the most heavily contaminated surface soils are located
in the former process and impoundment areas, and the tar mat and
its related drainage area to the northeast portion of the site.
Surface soils in the southern and northern (north of Creosote
Branch) do not appear to have any significant concentrations of
contamination as discussed in the risk portion of this document.
-------
The impoundment and drainage areas (including the tar mat) are
located north and east of the former process area. Two samples
were collected in the former impoundment area during the current
investigation (88-14 and 15). Degree of contamination noted in
these samples is somewhat lower than that found in most process
area soils. Values for B(a) P equivalent concentration and PCP
ranged from 4,500 to 2,900 ~g/kg and 1,400 to 320 ~g/kg for S8-14
and 88-15, respectively. contamination detected at 88-16 included
a PCP concentration of 2,300 pg/kg, and a B(a)P equivalent
concentration of 3,688 pg/kg. Data from previous investigations
(69, 72, and 73, TAT 1988) provide information for the area which
lies between Creosote Branch and the stream which drains the tar
mat (Figure 6). Levels of contamination whic~ exist in this area
are evidenced by B(a)P concentrations ranging from 3,593 to
.7,522 pg/kg and undetected PCP. This area has been determined to
be a wetlands area as discussed elsewhere in this document.
, A single sample was collected during a previous investigation of
the tar mat materials (31, TAT 1988) with a B(a) P equivalent
concentration of 506,000 J.'g/kg and 6,000,000 JJg/kg PCP. These
values are greater than any other sample collected on site during
the current investigation. In addition, the drainage from the tar
mat areas was also previously sampled (samples 70 and 74) and
showed concentrations of B(a)P equivalents of 51,520 ~g/kg and
6,199 pg/kg and PCP at a maximum of 31,000 JJg/kg.
Concentrations of PAHs and phenols decrease slightly in samples
collected west and south of the process area. B(a)P equivalent
concentrations at 85-8 and 85-9 are 5,601 and 10,320 ",q/kg,
respectively, while B(a)P equivalent concentrations range from
864 ~g/kq in 88-4 to 677 ~q/kg in 88-13. Concentrations of PCP
range from less than 1 to 890 ~9/kg in 8S-8 and 88-7, respectively.
Three surface soil samples were collected from the southern portion
of the site durinq the current investigation (88-10, 55-11, and 55-
12), none of these were visibly contaminated. Samples 58-10 and
S8-11 showed less than 200 J.'9/kg B(a)P equivalents and less than
1.0 P9/kq for PCP. Sample 8S-12 from the southeastern portion of
-------
A sample of surface water and sediment was collected immediately
downstream of the confluence of the stream which drains the tar mat
area into Creosote Branch. The surface water sample (SW-4)
contained no volatiles, PCP, or PABs. Results for the sediment
sample (SD-4) showed a B(a)P equivalent of 1,549 #q/kq and PCP
concentration of 69 #g/kg.
Several sediment samples were collected downstream from the site to
evaluate off-site miqration of contaminants (Figure 8). Location
SD-7 was approximately 5,000 feet downstream of the site boundary
(at the junction of Route 167 and Creosote Branch). B(a) P
equivalent concentration is 6,818 #g/kg for SD-7, and no other
contaminants were detected in this sample. Sediment samples SD-9
and SD-I0, collected from Creosote Branch approximately 6,300 feet
and 10,000 feet downstream of the site, respectively, contained
lower concentrations B(a)P than SD-7 but did have detectable levels
of phenols. The B(a)P equivalent concentration for SD-9 was 785
and SD-I0 was 1,053 #g/kg. For SD-9, a concentration of 1,100
~g/kg PCP was reported, although PCP was not detected in SD-I0.
The pond located in the east-central portion of the site was the
samp1i~g location for Sw-s and SD-s. This pond was reportedly
constructed as a reservoir. for the storage of fire protection
water. Both the surface water and sediment samples from the pond
contained no detectable levels of PABs or PCP. A single sediment
.sample was collected from the pond during a previous investigation
of the site. This sample was analyzed for PAHs only and no
contaminants were detected.
Observation of a film or sheen on water in the McLeod street ditch
upstream of the si te prompted the collection of surface water
sample SW-6. No organic contaminants were detected in this sample.
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5.5.2
SURFACE WATER AND SEDIMENT INVESTIGATION
The purpose of the surface water and sediment sampling program was
to delineate the extent and magnitude of surface water and sediment
contamination resulting from downstream migration of site-related
contaminants. Seven surface water and ten sediment samples were
collected during February and March, 1.992, for the RI at the
American Creosote site. The sampling locations near the site are
shown in Figure 7, and results are presented in Appendix C.
Surface water and sediment samples SW-1. and SD-1. were collected
from Creosote Branch as background samples approximately 500 feet
upstream of the site. No volatile compounds, PCP, or PARs were
detected in either sample.
Surface water and sediment samples SW-2 and >"SD-2 were collected
from Creosote Branch in the northwest portion of the site.
upstream of this point, the stream receives the discharge of the
drainage ditch which carries nearly all runoff from the southern
portion of the site and a limited amount from the central portion
, ,of the sit&-e No contaminants were detected in the surface water
sample (SW-2) and no PCP was detected in the sediments. However,
, some contaminants were detected in the sediment sample, including
a B(a) P equivalent concentration of 217 p.g/kg. These data suggest
some minimal impact on Creosote Branch from a source or sources
along the western portion of the site.
Samples of surface water and sediment were collected along Creosote
Branch downstream of two ditches which drain the former process and
impoundment areas (SW-3/SD-3 and SW-8/SD-8). These samples were
also downstream of the onsite creosote seep (Figure 7). Surface
water sample SW-3 contained 68 micrograms per liter (~q/l) of PCP,
no other contaminants were detected in either SW-3 or SW-8. SD-3
and SD-8 had B(a) P equivalent concentrations of 580 and 1,061 p.g/kg
with PCP concentrations of 17 and 160 p.g/kg, respectively. SD-3
was analyzed for dioxin wi th a 2, 3 , 7 , 8-TCDD equivalent
concentration of 0.01. ",g/kg for this sample. All of these
compounds are hazardous substances as defined at CERCLA Section
101(14), 42 U.S.C. S 9601(14) and further defined at 40 CFR
S 302.4.
-------
In summary, surface water entering the site appears to be
relatively free of organic contaminants analyzed for during the
current investigation. Sediment samples collected at SD-3, SD-4,
and SD-8 show the impact of site drainage on sediments in Creosote
Branch within site boundaries. Surface water samples collected in
locations of measured sediment contamination showed little, if any,
evidence of organic compound contamination. These data suggest
that adsorption of contaminants to sediments and dilution of
surface water by running streams combine to minimize site impacts
on surface water itself. As detailed later in this ROD the levels
of contamination of the sediments in Creosote Branch do not
represent a significant human health threat.
5.5.3
SUBSURFACE INVESTIGATION
The location of boreholes, monitor wells, and trench lines are
shown in Figures 9 and 10, respectively. No samples for laboratory
analysis were collected during trenching activities. However,
subsurface soil samples were collected from 18 boreholes and during
the installation of 11 monitor wells. Shallow boreholes and
monitor wells were typically about 20 feet deep with grab samples
taken at about 5 and 20 feet and a composite from 0-12 feet. Two
to five grab samples were collected in deep boreholes and monitor
wells. Grab samples were typically collected at about 5 and
10 feet in the hand auger boreholes.
Nine trench lines were located across the site in a northwest-
southeast orientation. Initially, excavation locations were spaced
at intervals of 35 feet and later changed to 50 feet. During
trenching activities, elevated readings on the Photoionization
Detector (PID) were accompanied by visual evidence of hazardous
substance contamination in nearly all cases. Information collected
during these activities is summarized on Table 2. Heavily
contaminated soils were very dark in color and PID readings above
100 ppm were commonly obtained. Hydrocarbon-based fluids
encountered in these zones had the appearance of used motor oil.
-------
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American Creosote
Winnfieldl Louisiana
F'lQure No.:
8
Offslte Surface Water,
Sediment Sampling and
Groundwater Locations
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TRENCH EXCAVATION
LOCATIONS
AMERICAN CREOSOTE
WJNNFIELD. LOUISIANA
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SUBSURFACE SOIL
SAMPIJNG LOCATIONS
AMERICAN CREOSOTE
WJNNFIELD, LOUISIANA
-------
TABLE 2 (continued)
SUMMARY OF TRENCHING OBSERVATIONS
PlD Peak 0'-8'01
TolIl 0'-10' Debris
Tnnsect . LoaolioD Depth 0'-5' 5'.10' a"8- PI~ Deplh VIsual Extenl or CoDlamlnatloD Remarb"
Peak D"'lh Peak Death
1'3 ON 8' 101 2' 0 - 20.7 0.3' H- /Ii) 0-4'. none below Debris: woocIchJm. v- 2-4' w/lheen
CON lOB 11' 0 . 45 8' 15.6 . Mod. /Ii) 8.11' none above v-n' wIDrocIuct
lOON 10' 0 . 0 . 0 . None obsaved v-6 & 10'
150N 10' 0 . 32 10' 14.8 . Mod. /Ii) 6.10' DOne above v-608'
250N 10' 30 4' 45 6' 26.8 0.6' Mod.. Heavy 0.10' ~:ris: collCl'ete. pipe, _III net. V-7'
w rocIuct
400N 2' 0 . . . . 0.2' Heavy @ 0.2' Debris: rice 1111111, mud, wood, COIICIeIe
-d
450N 10' 84 4' 55 6' 42.8 1).4' Heavy @ 0-4', DOne below Debris: wood, pipe. v-4'& 6-8'
';~tOduct
500N 10' U 4' 40 7' 25.0 . HI''''''' iii) 0.7' mod. /Ii) 8.10' v-.3' w",""""ct
550N 10' 75 3' 140 5' 64.0 - Mod. . H- /Ii) 0.10'
S90N 10' 55 S' 120 5' 59.0 - SII.hl /Ii) 3.7' PosItive PJD aU d-lhI
ON lSOW 10' 0 . 0 . 0 . None observed
105. l00W 10' 0 . 0 . 0 . None obsaved
T4 ON a' 5 l' 23 a' 13.3 0.2' Mod. tii) 0.2' Debris: wood.. roots 3.5'. v-4'
60N 4' 0.4 2' . . . 0-4' Heaw /Ii) 0-4' Debris: lreated wood """"11De
lOON 10' 1.0 2' 75 8' 28.2 408' Sliml .m 0.6' mod. /Ii) 6.10' Debris: IIIcb. "- wood
150N 4' 35 4' . . . 0-4' Heaw /Ii) 3-4' Debris: ........ able. V-" w~rocIuct
200N a' 93 " 120 7' 95.3 2-8' H- /Ii) 0-8' Debril: brim. rice hulk. ab1el.. elc.
250N 4' 35 I' . . . 2-4' Heavv /Ii) (),4' EJavalloD 11- due 10 debril
SOON 2' 55 I' . - . 0-2' Heaw /Ii) 0.2' EmcavalloD 11-....1 due 10 debril
350N 10' 320 " 2'70 7' 272.2 0.1' H"""".m 0-4' mod. tIi) 4-10' V-nrocluct 2'
400N 10' 428 3' 454 5' 362.4 . Heaw /Ii) 1).4' mod. @ 4-10' V-nmdDd 2'
-------
TABLE Z
SUMMARY OF TRENCHING OBSERVATIONS
PlD Peak O'-I'or
Total 0'-10' Debn.
Tnnsed LocadoD Depth 0'.5' D....'b 5'.10' "-'b ... PID' Depth VD.I EJleDt of CoDtamiDadoD Remarb'
Peak Peak
T1 ON 10' 0 . 0 . 0 . NOlie observed v-6-S'
lOON 10' 0 . 0 . 0 0.2' NOlie observed . Debris: w""" mud b . -~ Lv-"
lSON, lOW 10" '13 2' 76 6' 55 0.2' Heavy PID @ 0.2', mod, @ 2-10' Debris: lop. _till. pipe, cable. v-S'
wlaheeD
200N 10' 51 I.' 0 . 10.2 0.5' Mod. PID fii1 3-4' Debris: _tilL wood. bricb. v-3' ~ 8'
250N 10' 0 . 0 . 0 0.3' Heavy @ 0.3' Debris: IDOItIy _U pIeca 01 wood.
VOl]'
T'l ON 2' 20 2' . , . 0.2' H".aw iii) 0.2' nMris: wood dIlnL mud. coaaete DId
SON ]' 22 2' . . . 0.3' H-Iii) 0.3' Debris:.1- A:- ..... _till
lOON 10" 30 4' 19 " 15.1 0-4' Heavy @ 0-4', mod. @ 4-1' ~.m: _till. wooddllpa. VOl 4'
w rocIuet
lSON 10" 0.5 2' 0 . 0.1 2'-4' Upper 2' Debris: wooddIIpa. clay. VOl 4-6' w/aUahI
.heeD
200N 10' 0 - 0 . 0 . SUe' UDOer 2' or fill VOl 10' w/v..Ue. .heeD
250N 10' 21 4' ]7 10' 23.1 0.1' Mod. (ii) 1-10' Debris: cable. VOl 7' wlDrocIuet
300N 10' 0 . 30 8' 10.0 . Mod. fj'J 6-10' v..4.t 10' w!n""'uet fj'J 6'
-------
TABLE 2 (continued)
SUMMARY OF TRENCHING OBSERVATIONS
PID Peak 0'-8' or I
Totll 0'.10' Debris
Tnascct l.ocItloD Deplh 0'.5' n-Ih ".10' n-Ih avs- PI~ Deplh Vlaual Exteat of CoDtlmlaallon RetD8rb"
Peak Peak
1"7 ON 5' 33 4' . . . 5' Heaw@ 2." Debris: loft. tl- V-]' w/nroduct. .
SON U' 90 4' " U' 4'.0 2'." Mod. (ii) 1).4' Debris: nDroad Ilea. V.". Deat @ ]'
lOON U' 1 4' ] 6' 2.2 . SUtht /Ii) U' v-4-6'- -t @ 4'
lSON 10' 30 4' 4 6' 6.8 . Moel. /81 ,...' Pe8t Ilb 4'
200N 10' SO 4' 229 6' 136,8 . SU_hl.Mod. @ 3.1' v-"" Ou" IheeD OD IOU iii) 6'
2SON l' 0 . . . . . None observed &caftllon II"""'"" due to cavin-
. 50S 2' 0 . - . . . None obtervecI Haocl lUReI' 1f0llll8Cl1w toc:b
655 105' 15" ,. 70 6' 19.8 . Moel. {Ii) 4-5'. ,llabt mI 5-705' 01" ,been on IOU IiJ) 5-705'
1305 10' 0 . 1.6 " 03 . SU_ht (ii) " SUaht lIIlv IheeD iii) "
1'8 200N to' 0 . 0 . 0 1.3' None obtervecI Debris: nllrold tIeL v-9'
SOON 10' 0 - 0 . 0 . None obterved
1'9 lOON 10' 0 . 0 . 0 l' None observed Debris: wood. v-9'
200N 10' 0 . 0 . 0 . None obIervecI v-9'
SOON 10' 0 . 0 . 0 l' None obIervecI Debris: treatee! wood. v-9'
400N 10' 0 . 0 . 0 . None obIervecI v-9'
SOON 10' 0 . 0 . 0 I' None obIervecI v-29'
TB-l l8O'N 210£ 10' 0 . 0 . 0 l' None obIervecI Materials atunted at "
ofT6 410N
tE-2 73'SVI of I' 0 . 0 . 0 . None obIervecI Water depth l'
MW7
TB-3 B of tar l' t 3 II l' . . SUaht @ 1).6', beavy g 6-1' CoIItamlaatloD IDcnued with depth
mat
TB-4 3O'SB of " . . . . . . None obtervecI HaoclauaerIDIllopped @ I' due to blnI
m:~ ,Ulltone
I PhotoloaizatloD deleclor (PID) readlap -- obtained Ia the field by pladaa tbe IIIItrument'l ptdJewldlia a f- mllllmeten of a fftlhIy apoIed portion of lOlL
II Awn.. were tabla oaIJ In thole _vado8l whlcla ac:laleved cleptha puler thin I feet aocl4 or -- PID readlap were _nled,
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TABLE 2 (continued) ,
SUMMARY OF TRENCHING OBSERVATIONS
PID Peat 0'-8' or
Total 0'.10' Debris
Traased I,oQtioa Depth 0'.5' 5'.10' IV. PIU Deplb Vllual Ell_I o( ConlamiDallon Remarb'
Peak "-Ib Peat Denlb
T5 ON 10' 200 4' 235 a' 145.% ()16' H-1Ii> ()..6' DOne below Debris: woodehim. v-6' .t: 8' wllMeD
SON a' 269 4' 250 a' . ()..6' H-I6I()..6' Debris: wood_LL .- . v-6'w"'beea
lOON 10' 15 2' 215 a' 100.0 0.5' Heaw 161 0.5' Debris: woodclllnL allv .beea OD £111M
150N 10' 4 4' 29 6' 7.9 0.2' Sliobl Iii) 4-8' Debris: toB. lies. v.5'
200N 8' 75 5' 145 7' 60.5 . !tli_hl uadiDl! 10 beaw (rom 0-8'
250N 10' 30 4' 175 10' a3.4 . Mod. Iii) 4.10' V8Inrodud 6'.t: 9'
300N 10' 8 4' 225 8' 110.4 . Mod. Iii) 4-10' tImer 2' fill DIII'L. v-lIrocIud 6'
'50N 10' 14 4' 2S 8' a: 14.6 0.4' Heavy @ 0.4', mod. 4-7' Debris: melll, woodthuab. V.'Z
10'
400N 10' 158 3' 160 7' 141.6 . Mod. iii> W'
450N 10' 215 3' 230 7' 191.0 . H-ow /Ii) 0.10'
SOON 2' az I' . . . o.Z' Heaw o.Z' I!D:avalloD .1""""" due 10 debris
T6 ON. 5W '2' 0 2' . . . 2' None observed Debris: boulden IIwodroct'J\
35M 4' 0.2 4' . . . 4' None observed Debris: boulden IIwodroct1\
70N a' . . . . . . None observed
100N 4' . . . . . . Helw Iii) 4'
140N 8' . . . . . . None observed
175M 11' . . 96 9' . 0.1' H- 1&1 0.11' Debris: wood
210N 11' . . 200 10' . . Sliobl uadlDl! 10 heaw 161 0.11' 3 bI_h PID fiI 6-11'. Ollv.beea OD IOU..
245N 11' 220 4' Z4's 10' 177.8 0-3' H-'- 161 0-11' Debris: woodclllnL Free nrodud a',
280N 11' . . . . . . H- Iii) 0-11' No IoI! _nled due 10 raID
31,SN 11' 161 4' 100 10' . 0-2' Heaw Iii) 0-3'. mod. /1i) 3.11' Debris: railroad Ilea. ete.
360N 11' ZO 4' 79 10' 4,S.8 Z' Havy@4'U' ~ris: RICb, V-4' w/product. Sou. bid
o sbeeD
410N 8' 11 4' 32 6' 16.1 0-3' H"'- /Ii) 0-3' mod. /1i) 3..' Debris: railroad lies. V.2' w/llrodud
5a'> 8' 0 . 0 . 0 . Sliobl @ 6-8' v-Z.5'
1005 10' 19 3' 0 . 17.0 o.Z' Heaw@ 0-10' Debris: woodclllll8
-------
selected as representative of this area. B(a)P equivalent values
vary from 8,800 to 52,000 ",g/kg in BH-8 (10 feet) and MW-6 . (1-
10 feet), respectively. Reported PCP concentrations for these
samples are 83,000 and 450,000 ",g/kg. Volatile compounds were also
detected in samples from this area with benzene concentrations of
100 and 120 ",g/kg in the two samples discussed above.
contamination in subsurface soils of the tar mat area can be
characterized by samples BH-9 (9.5 feet) and BH-10 (5 feet).
Visually, the BH-9 sample appeared only slightly contaminated
(i. e., sheen observed on soil surface) whereas the sample. collected
at BH-10 could be described as moderately contaminated (~, gray
color with dark streaks). B(a)P equivalent concentrations of 3,200
and 4,500 ",g/kg were recorded for BH-9 and BH-10, respectively and
the PCP concentrations for these two samples were 820 and 1,700
",g/kg. Benzene was not detected in the BH-9 sample although total
BTEX present was 200 ",g/kg. Total BTEX in the BH-10 sample was
2, 600 ",g/kg but benzene was reported to be only 24 ",g/kg. The only
dioxin analyses conducted on samples from this area were for BH-9
(5 feet). The calculated 2,3,7,S-TCDD equivalent for this ~ample
was 0.~9 ",q/kg. Concentrations of PABs and phenols in this sample
were several orders of magni tude less than those detected in
obviously contaminated samples collected in the area. As reported
previously, the materials of the tar mat have provided the highest
concentrations of PABs and PCP.
Three subsurface soil samples were collected to determine
contaminant concentrations for material in the waste cell
constructed during the 1989 removal action. The first sample
collected in borehole BH-1 (1-12 feet) was a composite representing
the stabilized waste present in the cell. The second sample from
this boring (20 feet) was collected below the waste and liner to
provide information regarding contaminant concentrations below the
cell. A second sample of the waste material was collected from
BH-3 at a depth of 0.5 to 6 feet. Maximum B(a)P equivalent and PCP
concentrations reported for the waste cell were 36,600 and
170,000 ",g/kg, respectively. Volatile compounds were present in
all three samples with a maximum reported benzene value of
240 ",g/kg from stabilized waste materials. The single sample from
BH-3 was analyzed for dioxin. The calculated 2,3,7,8-TCDD
equivalent value for this sample is 3.23 ",g/kg.
-------
Soils with moderate visual contamination were usually gray in color
with occasional .black streaking, had an oily sheen, and PID
readings were generally less than 1.00 ppm. Some elevated PID
readings were also found in soils with no outward evidence of
contamination other than a slight sheen. In all cases, positive
visual evidence was accompanied by a characteristic creosote odor.
Appendix D presents the subsurface sampling data results. Some of
the highest concentrations of contaminants found at the site are
located within the former process area. Samples which provide
examples of these high levels of contamination include MW-4
(5 feet), MW-5 (0-1.0 feet), BH-14 (0-1.0 feet). The sample
collected at BH-1.4 (0-1.0 feet) had the highest B(a)P equivalent and
PCP concentration of the three samples at 53,400 ~g/kg and
200,000 ~g/kg, respectively. The levels of PCP were 1.3,000 and
1.1.0,000 ~g/kg in MW-4 and MW-5 and B(a)P equivalent concentrations
were 52,960 and 4S,S40 ~g/kg, respectively. Volatile organic
compounds, consisting of benzene, toluene, ethylbenzene, and xylene
(BTEX), were detected in most subsurface soil samples from the
former proc~ss area. Benzene concentrations for MW-4 (5 feet), MW-
5 (0-1.0 feet), and BH-1.4 (0-1.0 feet) are 21 ~g/kg, 29" ~g/kg, and
1.50 ~g/kg, respectively. All of these compounds are hazardous
substances as defined at CERCLA section 1.01.(1.4), 42 U.S.C. !
9601(1.4) and further defined at 40 CFR S 302.4.
Four samples were collected for dioxin analysis from various depths
during the drilling of MW-2A and MW-2. Calculated 2,3,7,S-TCDD
equivalent concentrations were relatively low and decreased with
increasing depth of the sampling interval. TCDD equivalent
concentrations were 0.49 ~g/kg at 0-1.0 feet, 0.01 ~g/kg at the
13-16 feet and 31-35 feet depths, and undetected at 51 feet.
Concentrations of contaminants in subsurface soils of the former
impoundment and drainage areas are similar to those found in the
process area. However, the areal extent and depth of contamination
in this area are not as great as that of the process area. As with
subsurface soils in the process area, analytical data correlate
well with evidence from visual observations and field screening
methods employed during trenching and borehole drilling. Samples
collected from BH-S (1.0 feet) and MW-6 (1.-10 feet), have been
-------
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ESTIMATED EXTENT
OF SUBSURFACE
SOIL CONTAMINATION
AMERICAN CREOSOTE
WINNFlELD. LOUISIANA
-mlnlaY
Figure No: 11
ODD
-------
...
Results for subsurface soil samples collected in the southern
portion of the site indicate significantly less contamination
exists in this area relative to other portions of the site such as
the process area. Sample MW-1A (0-10 feet) contained 82 p.g/kg of
PCP but no PABs or volatile compounds were detected. Conversely,
MW-1 (51 feet) reported no PCP, but had 2,300 p.g/kg total phenols,
1,050 p.g/kg total PABs, and 320 p.g/kg ethylbenzene. B(a) P and
B(a)P equivalents concentrations were undetected in these samples.
Sample MW-lA (0-10 feet) was also analyzed for dioxin and a
2,3,7,8-TCDD equivalent value of 0.002 p.g/kg was calculated.
North of Creosote Branch, contaminant levels were detected at
similar concentrations as were found in the southern portion of the
site. A sample collected at MW-7 (0-10 feet) had a B(a)P
equivalent concentration of 145 p.g/kg. No volatile compounds were
detected, but 92 p.g/kg PCP were reported.
In summary, grossly contaminated subsurface soils are present
throughout the former process area, the impoundment area, and the
tar mat area. Significantly lesser concentrations of' some
contaminant~ are present at depth in the southern a~d northern
portions of the site. Concentrations of contaminants in these
locations decline rapidly with depth. All of these compounds are
hazardous substances as defined ar CERCLA section 101(14), 42
U.S.C. S 9601(14) and further defined at 40 CFR S 302.4.
5.5.4
AREAL AND VERTICAL EXTENT OF CONTAMINATION
The estimated areal and vertical extent of subsurface s01l
contamination at American Creosote is shown in Figure 11. This
figure was prepared using data and information from a variety of
sources. Visual evidence and PID readings recorded during
trenching excavations and hand auger borings provided data critical
to the determination of the extent of contamination in the upper
-------
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EXTENT OF GROSS VISUAL
CONTAMINATION 0'-5'
AMERICAN CREOSOTE
WlNNFIELD, LOUISIANA
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10 feet of the subsurface. Generally, as shown in Figure 11, the
area outside the 10 foot contour line represents those areas where
there is no visual or PIn evidence of contamination. Information
at depths qreater than 10 feet was obtained from borehole
litholoqic descriptions, laboratory results of samples collected
durinq monitor well installation and boreholes, and to a lesser
extent, PIn readinqs. In preparing Fiqure 11, subsurface soil
samples containinq more than approximately 10,000 ",q/kg total
orqanic compounds were included within the extent of contamination
shown. In areas where data were 1ackinq (~, depths greater than
10 feet in the tar mat area), professional judgment was used to
estimate the areal and vertical extent of contamination.
The largest volume of contaminated soils is located in the former
process area. Contaminated soils in this area occupy approximately
five acres and extend to a maximum identified depth of 40 feet.
The deepest contamination appears to be centered in an area north
of the former tank farm and boiler building. Based on a review of
historical aerial photoqraphs, this portion of the site received
spills, runoff and possibly discharges over much of the operating
life of the plant (80 years). An exploratory soil boring, BH-16,
was advanced near the center of this contaminated area. stained
subsurface soil was observed to a depth of 40 feet. Analytical
data from samples collected in this borehole corroborated visual
evidence of qross contamination to a depth of at least 38 feet but
no more than 47 feet in this area.
Fiqures 12 and 13 depict the extent of qross1y contaminated soils
at two different intervals based strictly on visual evidence
obtained during trenching activities. For these fiqures, gross
visual contamination is defined as those soils darkened in
appearance by creosote contamination with very little or none of
the oriqinal soil coloration remaininq.
Based on the results of the RI the contaminated areas at the
American Creosote site are shown in Fiqure 14. . These contaminated
areas are shown as qeometric shapes to facilitate volume
calculations. Some of the characteristics of these areas are
presented in Table 3. The total volume of contaminated soil is
estimated at approximately 273,000 cubic yards. Volume estimates
were also calculated for 5-foot and 10-foot excavation depths, so
-------
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EsnllATED EXTENT
Of' SUBSURFACE
SOIL CONTAMINATION
AMERICAN CREOSO'rE
WINKFIELD. U)UISIANA
-------
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EXTENT OF GROSS VISUAL
CONTAMINATION 5'-10'
AMERICAN CREOSOTE
WJNNFIELD, LOUISIANA
Figure No: 13
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-------
that these partial source control actions could be evaluated. The
5-foot and 10-foot excavations would occur in the most heavily
contaminated portions of the site as shown in Figures 12 and 13
respectively. Assuming the 5-foot excavation is conducted, the
total volume of soil removed is 59,000 cubic yards. Assuming the
10-foot excavation is conducted, the total volume is 106,000 cubic
yards.
5.5.5
GROUND WATER INVESTIGATION
Ground water investigations began with the installation of
piezometers throughout the site. Piezometers were installed to
confirm ground water flow directions so monitor wells could be
optimally located. A total of 12 piezometers, as shown in Figure
15, were installed onsi te to characterize the hydraulic gradient of
the shallow aquifer in the contaminated area. Eleven of the twelve
piezometers were positioned within the portion of the site area
bounded by Creosote Branch. One piezometer was installed on the
west side of the CreosDte Branch, in the former American Creosote
office yard, to evaluate the hydraulic effects of the stream on the
shallQ.w aquifer.
The piezometric water levels were used to strategically place four
deep and seven shallow monitor wells up- and down-gradient of the
contaminated portions of the site. The shallow monitor well
boreholes were screened within fine to medium sand and gravel in
the top ten feet of aquifer and ranged from 20 to 25 feet in total
depth. Deep monitor wells were screened in a fine sand and silty
zone approximately sixty feet below grade.
Twelve ground water samples were collected between March 10-13,
1992, for the American Creosote site RIfFS. Eleven of these
samples were collected from monitoring wells, which are shown in
Figure 15. One sample was also collected from the Red Hill
drinking water supply well. The location of this well is shown in
! .
~ '
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TABLE 3
CHARACfERlSTICS OF CONTAMINATED AREAS
1 24ft. 6,800 Post-Removal Mound
2 20 ft. 50,400 Southwest Process Area
3 30 ft. 45,000 Process Area
4 15ft. 54,700 Treated Wood Storage Area
5 20ft. 16,600 Northeast Process Area
6 10 ft. 31,900 Process/Impoundment Area
7 20 ft. 42,200 Impoundment Area
8 20ft. 15,300 Tar Mat Area
9 10 It. 10,100 Tar Mat Drainage Area
-------
Figure 8. On June 1 and 2, 1992, monitor wells MW 1, 3, 6 and 7
were re-sampled for PABs and phenols. Laboratory data reports for
all these samples are included in Appendix E.
Analytical data for ground water are available from current and
previous investigations. Ground water data from previous
investigations are most useful for those areas not sampled during
the current investigation. Monitor well installation and ground
water sampling in the current investigation focused on providing
information up-gradient and down-gradient of known or potential
source areas.
Shallow monitor well MW-1A and deep monitor well MW-1 were
installed on the southern portion of the site to provide data on
ground water quality upgradient of contaminant sources present on
site. The only organic compound detected in ground water from
MW-lA was fluorene at a concentration of less than 1 ",g/l. Several
PAH compounds were reportedly detected in the sample from HW-l but
each was present at less than 1 #Jog/l. Data fro~ the April 1992
resampling of MW-l indicated no PAH compounds or phenols above
detection limits. These data document that ground water entering
the site is essentially free of the organic compounds associated
with site contamination.
Based on available data and professional judgment, the areas of
greatest ground water contamination by site-related organic
compounds are the former process area, impoundment area, and
portions of the site which lie hydraulically down-gradient of these
locations. Phase-separated liquids have been identified in at
least two shallow wells representing these portions of the site,
MW-4 and MW-6. Phase-separated liquids are identified as
Non-Aqueous Phase Liquids (NAPL) and further defined as "floating"
low density phased LNAPL or "sinking" dense phased DNAPL. Xn the
course of this text reference will be made to "product" which is
considered to be the same as NAPLs. All of these contaminants are
hazardous substances as defined at CERCLA Section 101(14), 42
U.S.C. S 9601(14), and further defined at 40 CFR S 302.4.
-------
UCBND
- smr.-u CIWML
- OMIIAGE DIItIt
- TAU UIt
- f[NC[
+ . SlWLOW MOIIII'OR IIEU.S
+ DaP ~ WElLS
6 PIEZOIIf:IER
N
i
t:> SCALE IN TEEr
- ~ s1IIID CJ 0 235 410
MONITOR WELL AND
PIEZOMETER LOCATIONS
AMERICAN CREOSOTE
WlNNFIEW, LOUISIANA
tans StIUf
OODOc:J
-------
. -
from the shallow monitor well MW-8 west of the zone of subsurface
soil contamination. No volatile organic compounds or phenols were
detected in the ground water at this location. .
Deep monitor wells were installed to the east (MW-3) , west (MW-2),
and north (MW-7) of the former process area. Analytical data for
ground water from these wells reported no detectable organic
compounds with the exception of extremely low levels of PABs (less
than 1 #£g/l). However, subsurface soil samples collected from the
intervals screened by MW-2 and MW-3 document the presence of
adsorbed contaminants, particularly phenols, at that depth. The
resampling of MW-3 and MW-7 indicated that no PABs or phenols were
present in deep ground water at these locations above detection
limits.
Based on lithologic information, it appears unlikely that there is
significant interaction between the zones in which the shallow and
deep monitor wells are screened. Relatively dry, interbedded silty
sands and silty clays were encountered between 30 and 50 feet
during the drilling of all deep monitor wells and deep boreholes.
These interbedded layers in combination with the upward vertical
hydraulic gradient appear to prevent or least retard the migration
of dissolved contaminants from the upper zone to the lower zone
data. Data collected from deep borehole BH-16 suggest a maximum
depth of migration for NAPLs of 40 feet.
A ground water sample was also collected from a nearby public water
supply well belonging to the Red Hill Water Cooperative (Figure 8)
during both sampling events. This well is screened from
approximately 550 to 600 feet in the Sparta Sand. The only organic
compounds detected in the sample from this well are acenaphthene
(3.29 ~g/l) and fluorene (0.11 ~g/l). A resample of this well,
however, indicated no PAHs or phenols present above detection
limits.
Based on data currently available, samples collected from deep
monitor wells (approximate depth 55-65 feet) contained no
detectable contamination. The presence of low concentrations of
organic contaminants in subsurface soil samples collected from the
intervals screened by these wells suggest that any contaminants
-------
Observations of monitor well MW-4, located north of the former
process area and screened from 11 to 21 feet, have found both LNAPL
and DNAPL product phases. The sinking product phase has been
determined to be approximately 1 foot thick at the bottom of this
well. Floating product is also present in MW-4 and its thickness
has been estimated at approximately 2 inches. A thin layer of
floating product as well as traces of sinking product has been
observed in MW-6, which is screened from 5 to 20 feet.
Additionally, during the field investigation, product was observed
seeping directly from the bank of Creosote Branch to the stream
surface, particularly in the location depicted on Figure 7.
Ground water samples collected from monitor wells MW-4 and MW-6
contain the highest concentrations of dissolved contaminants
detected in site ground water samples. B(a)P equivalent
concentrations in ground water from MW-4 and MW-6 are 868 and
369 ~g/l, respectively. concentrations of many of the individual
compounds are just above or just below maximum solubility for these
compounds. Benzene is also present in ground water samples from
these wells with reported concentrations of 162 and 146 I-'g/l,
respectivel~. No phenols were detected in MW-4 and MW-6 in these
earlier results. However, the resampling of MW-6 indicates total
phenols of 154,400 I-'g/l and no PCP. All of these contaminants are
hazardous substances as defined at CERCLA Section 101(14), 42
U.S.C. S 9601(14), and further defined at 40 CFR S 302.4.
Shallow monitor wells MW-3A and MW-5, screened from 5 to 20 and 17
to 27 feet, respectively, are also located within the area of
contaminated soils surrounding the process and impoundment areas.
Analytical data for ground water samples from these wells
demonstrate ground water contamination exists in these areas but at
lower concentrations than those in MW-4 and MW-6. No LNAPLs or
DNAPLs were observed. Sea) P equivalents reported for MW-3A and MW-
5 were both 0 I-'g/l. Benzene was present in these samples at
concentrations of 12 and 18 I-'g/1. Phenols were not detected.
Ground water from shallow monitor well MW-2A, located near the
western limit of the contaminated subsurface soils, exhibits
significantly lower concentrations of contaminants than MW-3A and
MW-5. No evidence of LNAPLs or DNAPLs was observed at this
location. No phenols were reported. Similar results were obtained
-------
UC8N1J
- ~o-.
- IIRANC( DIfCII
- _PC
- 1ICIS11NO-
. SIW10W ~ IIDLS
. caP IIOIITOII _us
A PCOIImR
,-
/' ~~~~SI4IU.I*
fP m='~1XIOIT or
HOYt: fiW"'~ PIIOOUCf
N
i
SCAU IN 'In
C:J . ,. .,.
ESTIUATED EXTENT 0'
SHALLOW GROUNDWATER
CONTAMINATION
AMERICAN CREOSOTB
WINNFIELD. LOUISIANA
Figure No: 16
..
-------
present are strongly adsorbed to the matrix material and are not
available for 9,round water transport.
In summary, sampling data from shallow monitor wells (approximate
depth 15-25 feet) indicates that the extent of ground water
contamination closely follows the pattern of contaminated
subsurface soils illustrated in Fiqure 11. Estimated extent of
shallow qround water contamination and NAPLs are depicted in Fiqure
16. Creosote Branch appears to be effectively intercepting the
northward miqrating contamination from the former process and
impoundments areas. Based on an estimated average contaminated
thickness of 25 feet, and assuming a porosity (amount of void space
in the subsurface soils) of 0.3, the contaminated ground water
volume has been calculated to be approximately 24 million gallons.
Evidence exists that DNAPLs are present at several intervals within
areas of greatest contamination (areas surrounding BH-16 and HW-4).
Presence of these DNAPLs roughly coincides with the 3D-foot contour
': of subsurface soil contamination shown in Fiqure 11. DNAPLs may
also be present in the former impoundment area (MW-6 and BH-S).
.'
'.
6.0
-
SUMMARY OF SITE RISKS
6.1
RJ:SK OVERVIEW AND EXPOSURE ASSESSMENT
A risk assessment is a procedure that uses a combination of facts
and assumptions to estimate the potential for adverse effects on
human heal th or the environment from exposure to hazardous
substances, pollutants, or contaminants found at a site. Risks are
determined by comparing actual chemical concentrations at a site
versus chemical exposure limits known to have an adverse impact on
human health or the environment. carcinogenic risks are expressed
in terms of the chance of developing cancer over a given period of
exposure. Toxicity assessments of non-carcinogenic risks are based
on comparing site contaminant concentrations to reference
concentrations known to have an adverse non-cancerous impact.
conservative assumptions are used in calculating risks that weigh
in favor of protecting human health.
-------
industrial and trespassing is available in the administrative
record.
6.2
TOXICITY ASSESSMENT
'!'he objective of the toxicity assessment is to weigh available
evidence regarding the potential for particular contaminants to
cause adverse effects in exposed individuals. Also, the toxicity
assessment provides, where possible, an estimate of the
relationship between the extent of exposure to a contaminant and
the increased likelihood and/or severity of adverse effects. The
types of toxicity information considered in this assessment include
the reference dose (RfD) used to evaluate non-carcinogenic effects
and the slope factor which is used to evaluate carcinogenic
potential.
RfDs have been developed by EPA for indicating the potential for
adverse health effects from exposure to contaminants of concern
exhibiting non-carcinogenic effects. RfDs, which are expressed in
units of milligrams per kilogram per day (mg/kg-day), are estimates
of acceptable lifetime daily exposure levels for~umans, including
sensitive individuals. Estimated intakes of contaminants of
concern from environmental media (~, the amount of a
contaminated drinking water) can be compared to the RfD. RfDs are
derived from human epidemiological studies or animal studies to
which uncertainty factors have been applied (~, to account for
the use of animal data to predict effects on humans and to protect
sensitive subpopulations) to ensure that it is unlikely to
underestimate the potential for adverse non-carcinogenic effects to
occur. The purpose of the RfD is to provide a benchmark against
which the sum of the other doses (Le., those projected from human
exposure to various environmental conditions) might be compared.
Doses that are significantly higher than the RfD may indicate that
an inadequate margin of safety could exist for exposure to that
substance and that an adverse health effect might occur.
No RfD or slope factors are available for the dermal route of
exposure. In some cases, however, non-carcinogenic or carcinogenic
risks associated with dermal exposure can be evaluated using an
oral RfD or an oral slope factor. Exposures via the dermal route
generally are calculated and expressed as absorbed doses. These
-------
'10.
The national incidence of risk, or probability, that an individual
may develop some form of cancer from everyday sources, over a
70-year life span, is estimated at a probability of three-in-ten.
Activities such as too much exposure to the sun, occupational
exposures, or dietary or smoking habits contribute to this high
risk. This three-in-ten probability is considered the "natural
incidence" of cancer in the united states. To protect human
health, the EPA has set the range from one in ten-thousand to one
in one-million excess cancer incidents as the remedial goal for
superfund sites. A risk of one in one-million means that one
person out of one-million people could develop cancer as a result
of a lifetime exposure to the site. This risk is above and beyond
the "natural incidence-- of three in ten. This range may also be
expressed as 1x10.4 to 1x10-8. The NCP considers 1x10.8 as the point
of departure when no chemical specific requirements have been
established.
". The level of concern for non-carcinogenic contaminants is
determined by calculating a hazard index. The hazard index
,reflects the level that chemical contaminants might cause
poisoning, organ damage, and/or other health problems. If the
hazard index exceeds one (1), there may be concern for potential
non-cancer health effects from a extended exposure to the site
. contaminants.
The risk assessment process evaluated the current site risk, also
called the baseline risk, posed to human health or the environment
by the site if left alone. The calculation of risk was based on
using the values as established in EPA's Supplemental Guidance on
standard Default Exposure Factors of the Human Health Evaluation
Manual. The environmental risks were calculated based on EPA's
Environmental Evaluation Manual of March 1989. The risks to human
health for the sediments, soils and ground water were calculated
based on three separate scenarios: a lifetime exposure for a
future residential population living on the site for 30 years, on
individuals visiting the site on a casual basis (trespassing) or
wading in Creosote Branch, and on an industrial basis. Because the
site is surrounded by residential areas, this ROD is based on the
residential scenario which is the most conservative risk
assumption. The discussions that follow will only present the data
from a lifetime exposure. The other exposure information for
-------
Slope factors (SFs) have been developed for estimating excess
lifetime cancer risks associated with exposure to potentially
carcinogenic contaminants of concern. SFs, which are expressed in
units of (mg/kg-day)01 , are multiplied by the estimated intake of
a potential carcinogen, in mg/kg-day, to provide an upper-bound
estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The term "upper bound" reflects the
conservative estimate of the risks calculated from the SF. Use of
this approach makes underestimation of the actual cancer risk
highly unlikely. Slope factors are derived from the results of
human epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied (~, to account for the use of animal data to predict
effects on humans).
There are varying degrees of confidence in the weight-of-evidence
for carcinogenicity of a given chemical. The EPA system involves
characterizing the overall weight of evidence for a chemical's
carcinogenicity based on the availability of animal, human, and
other supportive data. The weight-of-evidence classification is an
attempt to determine the likelihood that the .gent is a human
carcinogen, and thus qualitatively affects the estimation of
potential health risks. Three maj or factors are considered in
characterizing the overall weight of evidence for carcinogenicity:
(1) the quality of evidence from human studies: (2) the quality of
evidence from animal studies, which are combined into a
characterization of the overall weight-of-evidence for human
carcinogenicity: and (3), other supporting information that is
assessed to determine whether the overall weight-of-evidence
should be modified. EPA uses the weight-of-evidence classification
system to categorize carcinogenicity of contamination as one of the
following five groups:
Group A - Human carcinogen: This category indicates that there
is sufficient evidence from epidemiological studies to support
an association between the compound and cancer.
-------
~oi";;: ,
. ~,-
absorbed doses are compared to an oral toxicity value that is also
expressed as an absorbed dose. Toxicity information used in the
toxicity assessment for the site was obtained from EPA's Inteqrated
Risk Information system (IlUS). If values were not available from
IRIS, then EPA's Health Effects Assessment summary Tables (BEAST)
were consulted. The toxicity factors used in this evaluation for
non-carcinogenic effects and carcinogenic effects are summarized in
the tables outlined in the following pages.
For chemicals that exhibit non-carcinogenic health effects, it is
assumed that organisms have repair and detoxification capabilities
that must be exceeded by some critical concentration (threshold)
before the health is adversely affected. For example, an organ can
have a large number of cells performing the same or similar
functions. To lose organ function, a significant number of those
cells must be depleted or impacted. This threshold view holds that
exposure to some amount of a contaminant is tolerated without an
appreciable risk of adverse effects.
For chemicals that exhibit carcinogenic effects, most authorities
recognize that one or more molecular events can evoke changes in a.
single cell or a small number of cells that can lead to tumor
formation. This is the non-threshold theory of carcinogenesis
.- which purports that any level of exposure to a carcinogen can
result in some finite possibility of generating the disease.
EPA's Carcinogenic Risk Assessment Verification Endeavor (CRAVE)
has developed slope factors (Le., dose-response values) for
estimating excess lifetime cancer' risks associated with various
levels of lifetime exposure to potential human carcinogens. The
carcinogenic slope factors can be used to estimate the lifetime
excess cancer risk associated with exposure to a potential
carcinoqen. Risks estimated usinq slope factors are considered
unlikely to underestimate actual risks, but they may overestimate
actual risks. Excess lifetime cancer risks are generally
expressed in scientific notation and are probabilities. An excess
lifetime cancer risk of 1 x 10-8 (one-in-one-million), for example,
represents the probability that one additional individual in a
population of one million will develop cancer as a resul t of
exposure to a carcinogenic chemical over a 70-year lifetime under
specific exposure conditions.
-------
TABLE .4
SUMMARY OF CHEMICALS OF POTENTIAL CONCERN FOR THE AMERICAN CREOSOTE SITE
SURFACE GROUND SURFACE
SOILS WATER WATER SEDIMENlS
- VOAANALYTES (pgIkg) (pgIl) (IJgIl) (pgIkg)
-VINYL CHLORIDE
-1,1-DICHLOROETHENE
-TRANS-1.2-DICHLOROETHENE
-1,1-DICHLOROETHANE
-cIS-1.2-DICHLOROETHENE
-CHLOROFORM
-1,1,1- TRICHLOROETHANE
-CARBON TETRACHLORIDE
-BENZENE 0.162
-1.2-DICHLOROETHANE
-TRICHLOROETHENE
-BROMODICHLOROMETHANE
-TOLUENE 0.598
-TETRACHLOROETHENE
-cHLOROBENZENE
-1,1.2.2-TETRACHLOROETHANE
-ETHYLBENZENE 0-51
-BROMOFORM
-M.P.XYLENE
-o-XYLENE-
-XYlENES . 0.371
-1,2-DICHLOROBENZENE
-1,3-DICHLOROBENZENE
-1,4.DICHLOROBENZENE ..
- PAHANALYTES (JIg/kg) (pgIL) (pgIL) (IIgIIcg)
-NAPHTHALENE 0-860 0 - 20800 0-300
-ACENAPHTHYLENE 0-2DOO 0.419
-ACENAPHTHENE 0-1700 0-2730 0-1100
-FlUORENE 0-6700 0-8980 0-1200
-PHENAN11iRENE 0-13000 0-922 0-3300'
-ANTHRACENE 0-29000 0-922 0-770
-FLUORANTHENE 0-38046 0 - 2710 0-4300
-PYRENE 0-55000 0-2060 0-4000
-BENZ(A)AN'THRACENE 0 - 28973 0 -1060 0 -1800
-cHRYSENE 0.37000 0-4340 0 -1800
-8ENZO(B)f(K)FLUORANTHENE 0-47469 0.487 0-3000
-8ENZO(A)PYRENE 0-24001) 0-658 0 -1600
"NDENO(1.2.3-CD)PYRENE 0-11858 0-1200
-DIBENZ(A,H)ANTHRACENE 0 -16000 0-4600
.-BENZO(G,H,I)PERYLENE 0-15000 0-45 0 -1000
- PHENOL ANAL YTES (&IgIIcg) QIgII.) (pgIL) C5R)
-PHENOL 0-530 0.001 0-460
-2:.cHLOROPHENOL 0-0.3 0-60
eO-CRESOL 0-0.1 0-7.1
oMIP.cRESOL 0-0.1 0-290
-2-NITROPHENOL 0-65
-2,4-0IMETHYLPHENOL 0-6.3 0-40
-2,4-0ICHLOROPHENOL 0-110 0-430
04-CHLORQ.3.METHYLPHENOL 0-12
-2,4.516- TRlCHLOROPHENOL 0-0.1 0-3
-2,4-DINITROPHENOL 0-0.8 0-32
o4-NlTROPHENOL 0-0.6
-2,3,4,~TETRACHLOROPHENOL 0-230 .Q-14O 0-321)
..,~INlTRo-2-METHYLPHENOL 0-1.0
-------
Group B - Probable Human carcinogen: This category generally
indicates that there is at least limi ted evidence from
epidemiological studies of carcinogenicity to humans (Group
B1) or that, in the absence of adequate data on humans, there
is sufficient evidence of carcinogenicity in animals (Group
B2)
Group C - possible Human carcinogen: This category indicates
that there is limited evidence of carcinogenicity in animals
in the absence of data on humans.
Group D - Not Classified: This category indicates that the
evidence for carcinogenicity in animals is inadequate.
Group E - No Evidence of Carcinogenici ty to Humans: This
category indicates that there is no evidence for
carcinogenicity in at least two adequate animal tests in
different species, or in both epidemiological and animal
studies.
6.3
SITE RISKS AND CONTAMINANTS OF CONCERN
Table 4 presents a summary of all compounds analyzed and a range of
the constituents found in each medium. This data was used in the
baseline risk assessment which was divided into two parts: The
human health evaluation and the ecological evaluation. The
bas~line risk assessment was based on reasonable maximum exposure
values for hazardous substances found on site as presented in Table
5. The human health evaluation considered potentially contaminated
media such as surface soils, ground water, surface water, and
sediments. Contaminant migration via an air pathway was evaluated
in the risk assessment. Air monitoring from previous actions and
throughout the remedial investigation activities showed no
significant breathing hazards to the nearby populations or
terrestrial wildlife.
-------
TABLE 5
SUMMARY OF EXPOSURE CONCENTRATIONS
AMERICAN CREOSOTE
- . . . -
.,. -
.
2-chlorophenol 0.13 0.16 0.16 NA 2.3 x 1~
Dichlorophenol 0.36 0.64 0.64 NA 9.0 x 1~
Dimethylphenol 0.06 0.09 0.09 NA 1.2 x 1~
Dinitrophenol 8.3 x 10-4 NA 8.3 x 1~ NA 1.2 x 1~
m-Ip-cresol 0.2 0.39 0.39 NA 50S x 1~
o-cresol 8.0 x 10"' NA 8.0 x 10"' NA 1.1 x 10"
Tettacblorophenol 0.2 0.4 0.4 NA 5.7 x 1~
Phenol 0.49 0.69 0.69 NA 9.7 x 1~
Pentachlorophenol 0.6 0.92 0,92 1.4 x 1~ 1.3 x 10"'
Tetrachlorophenol 0.21 0.4 0.4 NA 5.7 x 1~
Trichlorophenol 0.11 0.19 0.19 3.0 x 10"' 2.7 x 104
B(a)P equivalents 11 15 15 2.4 x 10"' NA
-------
TABLE 4 (CanIInued)
SURFACE GROUND SURFACE
SOILS WATER WATER SEDIMENTS
METALS (pgIl) (pgIL.) (pgIkg)
-ALUMINUM 0 - 27700 340 321-1150
-ANTIMONY 50
-ARSENIC 9.7 - 84
-BARIUM 79 - 485 82 90 - 268
-BERYWUM 3 2 0.61 - 2
-CADMIUM 0-21
-CALCIUM 4340 -113000 49200 2760 - 70800
-CHROMIUM 0-31 8 0-6
-COBALT 0-133 0-2
-COPPER 5-30 8 3-3.1
-IRON 2500 - 2SOO 743 1220 - 2450
-LEAD 0-79 0 - 29.4
-MAGNESIUM 1860 - 80900 2300 103-4360
-MANGANESE 59 - 3280 102 52.7 - 208
-NICKEL 0-15 0-5.3
-POTASSIUM 3150 - 6000 1760 69.2 - 2220
-SELENIUM 126 0 - 143
-SILVER
-SODIUM 24300- 281000 7050 88.9 - 20100
-THAWUM 0-107 152 98.8 - 181
-VANADIUM 0-91 4.5-7
-ZINC 16-300 42 26-49
-MOLYBDENUM
-PHOSPHORUS 15-323 83 83 -141
-STRONTIUM 213-1670 276 13.2-485
DIOXINS (pgIkg)
-2378- TCDD
-2378- TCOF
-12378-PeCDF
-12378-PeCDD
-23478-PeCDF
-123478-HxCDF
-123678-HxCDF
-123478-HxCDD
-123678-HxCDD
-123789-HxCOD
-234678-HxCDF
-123~CDF
-123467&HpCDF 0.1072
-1234678-HpCOD 0.4358
o1234789-HpCDF
oQCDD 5.3465
-------
TABLE 5 (continued)
SUMMARY OF EXPOSURE CONCENTRATIONS
AMERICAN CREOSOm
Pentachlorophenol 0.6 0.92 0.92 3.4 x 10C 2.1 x 10"'
Phenol 0.49 0.69 0.69 NA 1.6 x 10"'
Tctrachlorophenol 0.2 0.4 0.4 NA 9.2 x 10C
Trichlorophenol 0.11 0.19 0.19 7.1 x 10"' 4.4 x IOC
2.3,7,8-TCDD equivalent
S.4 ]t 10"
NA
50S ]t 10"'
1.0 X 10"
NA
Trichlorophenol
B(a)P equivalents
0.11
0.19
0.19
5.0 x 100u
NA
11
5.4 x 10"
15
15
3.9 X 10'10
NA
NA
NA
2-chlorophenol
1.2
NA
1.2
NA
NA
m-/p-crcsol
0.29
NA
0.29
NA
-------
TABLE 5 (continued)
SUMMARY OF EXPOSURE CONCENTRATIONS
AMERICAN CREOSOTE
I
,,~
2.3.7,8-TCDD equivalent 5.4 x 1~
i::I'llililllllil~IIIIIII::<~::!~.".:.:.::
2-cbloropbenol 0.13 0.16 0.16 NA 3.7 x 104
Dichlorophenol 0.36 0.64 0.64 NA 105 x 10"'
Dimethylphenol 0.06 0.09 0.09 NA 2.0 J: 104
Dinitrophenol 8.3 11: 1~ NA 8.3 11: 10-4 NA 1.9 x lot
m-/p-cresol 0.2 0.39 .0.39 NA 8.8 x 104
o-cresol 8.0 11: 1~ NA 8.0 11: IO-s NA 1.8 x 10-'
16 16 NA 2.3 X 104
1.9 1.9 NA 2.6 x IO-s
0.3 0.3 NA 4.3 x 10"
23 23 NA 3.3 x 1~
NA 505 x 10"' 8.6 x 10"' NA
F1uoranthene 12
Fluorene 1.2
Naphthalene 0.2
Pyrene 15
-------
;;;:;.c_~-,
TABLE 5 (continued)
SUMMARY OF EXPOSURE CONCENTRATIONS
AMERICAN CREOSOTE
@!!:::I:iii:\irl:\lIlll!IIII!\\!!:\:I!!I\lli:!I:I:::~!!':!!!:::::!!::!I,!:::!:!li!::[II\il:!:litil:ill!lll!I!liIllil:!111
2-chlorophenol 1.2 NA 1.2
m-/p-cresol 0.29 NA 0.29
Pentachlorophenol 0.069 NA 0.069
0.21 NA 038
NA
1.3 ]( to"'
NA
3.2 ]t 10'
9.8 ]t l()"IO
7/) ]t 10"'
NA
4.2 ]t 10'
B(a)P equivalents 0.3 NA O.8S
Acenapbthene 0,S6 0.12 0.12
Anthraceno 0.21 0.48 0.48
Ruoranthene 0,S9 0.48 0.48
Fluoreno 2.0 4.3 4.3
PyJene 03 0.73 0.73
Napthalene 4.8 11 11
1.3 X to"2
NA
NA
1.1 ]t 10,1
NA
4.4 ]t 10'2
NA
1.4 ]t 1()"1
NA
4.1 ]t 1()"1
NA
6.7]t 10'2
NA
-------
TABLE S (continued)
SUMMARY OF EXPOSURE CONCENTRATIONS
AMERICAN CREOSOm
0.38
.. 'Illf':'" ";'II~!I'lt(ifi~f;lllltllrt~!11!ti!I!!IIII!!I!III!II:I:11111!:llllf;.1!!i:liJIIIIIII.
2-chlorophenol
m-tp-cresol
1.2
NA
3.1 x 10&
0.29
NA
0.29
NA
7.4]1: la'
Pentachlorophenol
Tetrachlorophenol 0.21 NA 0.38 NA 9.7 x la'
1.2 NA 1.2 NA NA
0.069
NA
0.069
2.3 X to-10
1.8 X 10'
2-chlorophenol
m-/p-cresol
0.29
NA
'0.29
NA
NA
Pentachlorophenol
Tetrachlorophenol
0.069
NA
0.069
NA
NA
0.21
NA
0.38
NA
-------
Based on the results of previous field sampling and historical site
activities, polynuclear aromatic hydrocarbons (PABs), expressed as
benzo(a)pyrene equivalents, and pentachlorophenol (PCP), were
tentatively selected as the major hazardous substance
contaminantsof concern prior to the RI field sampling. In addition
to these contaminants, the volatile compounds associated with the
use of petroleum as a carrier fluid were identified as potential
contaminants of concern. These volatile compounds are benzene,
toluene, ethylbenzene and xylenes (BTEX), and are also hazardous
substances as defined at CERCLA Section 101(14), 42 U.S.C.
~ 9601 (14), and further defined at 40 CFR S 302.4. As shown in the
following analyses, these assumptions were verified by the RI.
6.3.1
HUMAN HEALTH RISKS
A summary of site risks from contaminants at the American Creosote
site is presented in Tables 6 and 7. The risks shown in these
tables were calculated based on standard default assumptions that
often overestimate potential risks. The human health risk from
potential exposure to ground water is based on the conservative
assumption that exposure would occur at the site. . Such exposure is
unlikely to occur since no domestic wells currently exist on the
site, however, it is assumed that future generations may tap into
the ground water at the site. The information gathered at the site
indi~ates that the salt-water interface is rising in this Parish
due to excessive withdrawal from aquifers below 600 feet. The
potential remains that in the future shallower aquifers may be used
even though they do not yield as much water as the deeper aquifers.
In addition, the standard default assumptions as previously noted
are included in Table 9 at the end of this section of the ROD.
-------
TABLE 5 (continued)
SUMMARY OF EXPOSURE CONCENTRATIONS
AMERICAN CREOSOTE
.:i\!ii::m;IIID.~lllt::iit~lllllllliii:rllll~llillllll[i!;t.t1Iill[t(fj:1illil:[r~r':::'::::::::...
Xylenes 0.055 0.13
.iiiii:'iIIIII!li!i:\lt:::llillilllli811Ii1illlllilii'j!11;"iiiliii:~tli!ii[:."[[[
7.9 X 10"2 1.2 x 10"' NA
2.1 x 10"2 NA 1.9 :It 10"'
0.2 NA 1.8 x 10"2
0.13 NA 1.2 x 10"2
Benzene
3.8 :It 10-2
7.9 X 10"2
Ethylbenzene
9.9 :It 10"
2.1 :It 10"2
Toluene
0.075
0.2
Benzene 3.8 x 10-2 7.9 X 10"2 7.9 X 10"2 1.8:1t 1
-------
TABLE 6 (Continued)
CANCER RISK ESTIMATES FOR FUTURE LAND USE
RESIDENTIAL LIFB11MB EXPOSURE
-------
.\::;:~.i~I\\:gJ.~liit:!II@.ij:~:~!:.IIt$.1.tl~i.~fii.:t!r~1mi~It:;\~;:~~i~:~~~~:;.......
1.4 x 1~
3.0 X 10"'
2.4 x 10"
8.6 x 10--
::::::::f.«iI.!:gj!ilii\::i.' t:;i~[j[;~i:\~i;;:[;:::::::::m;m:i:~::i;f:B.l1~:;;:fiii~Th1~~ill[~!!:fi\\\1~:::j::::j::if:tt::Mi\\:;;~::t1[*;:t;:iM:::::;:;:i!::::~::::~::ili:!::~1i:r;;;::;:::m::j:i£mtfMMW""
:\:I!:t:'~:::::::::!I!~j~:l.imliI1111i1i.i(::;~::~'~.:~..."'.'.' .;[IJIII~I.i.i!!li:~:...:[...,
3.4 x 1~ Yes 0.12
0.011
1.5 x 10'
Pentachlorophenol
2.4,5/6 Trichlorophenol
2,3,7,S-TCDD equivalents
:::;tr.mh"lin~H[i~J.!_iiili.i.U.itiH1:!~giii::\1Iif~~\*il~ii1\l:::~...........AHM:\I:~:i::iiil:mK
2.4 x 10"" No 0.12 B2 NA
S.O x 10"12 No 0.011 B2 NA
3.9 x 10"10 No S.79 B2 NA
1.4 x 10"12 No 1.5 x 10' B2 NA
Pentachlorophenol
2,4,5/6 Tricbloropbenol
B(a)P equivalents
2,3,7,s-TCDD equivalents
Pentachlorophenol
2.4,S/6 Trichlorophenol
B(a)P equivalents
2,3,7,S-TCDD equivalents
TABLE 6
CANCER RISK ESTIMATES FOR FUTURE LAND USE
RESIDENTIAL LIFETIME EXPOSURE
AMERICAN CREOSOTE
No
No
3.3 x 10"
1.4 x lcr
1.3 x 10"'
No
No
Yes
Yes
B2
NA
EPA (1992)
EPA (1992)
EPA (1992)
EPA (1992)
Food
Food
Food
Food
2.9 X 10"12
SoS X 10"14
2.3 x 10"
2.1 x 10"
-~-
-------
TABLE 7 (Continued)
FU11JRE LAND USE
RESIDENTIAL (LIFETIME)
CHRONIC HAZARD INDEX ESTIMATES
AMERICAN CREOSOTE
- . ;\\:;1;:t:fjtii:\~\::::l:: . \;:.u~II:\i. - . - . . .
. .
Fluorene 2.6 x lU' No 0.04 low decreased red blood EPA, 1992 gavage 3.000 6.5 x 1~
ceDs
Naphthalene 4.3 x 10" No 0.04 - reduced body weight EPA, 1991 gavage 10.000 1.1 x 10"
Pyrene 3.3 x 1~ No 0.03 low kidney EPA. 1992 gavage 3.000 1.1 x lUI
~~~fjt~~r~j~~~jj~~f:~~~1j~jf~~~f:~~~~~\ 2.3 x lUI
....'" .::i:!r!:il!!!\~lr~1~ii:~;!j!;I!~i!l'~!:!!\j\!!:il\~;!:!:I:'t.;:!i:~I;liiiri;~~I[:~'~:if!;!li::i
2~h1orophenol 3.7 x 1~ Yes O.OOS low reproduction EPA, 1992 water 1.000 7.4 x 1~
m!p-:eresol 8.8 x 10" Yes O.OS medium weight loss, EPA, 1992 food 1.000 1.8 x 1~
neurotoxicity
o~resol 1.8 x 10"' Yes O.OS medium neurotoxicity EPA, 1992 gavage 1,000 3.6 x 10"'
2,4-Dichloropheno1 1.5 x 10"' Yes 0.003 - immune system. EPA, 1991 - 100 S.O x 10"'
2,4-Dimethylphenol 2.0 x 10' Yes 0.01 .. CNS EPA, 1991 .. 1,000 1.0 x 1~
2,4-Dinitrophenol 1.9 x 10"' Yes 0.002 -- cataracts EPA, 1991 - 1.000 9.5 ]E 104
Pentachlorophenol 2.1 x 10"' Yes 0.03 medium liver, kidney EPA, 1992 food 100 7.0 x 10"
Phenol 1.6 x lU' Yes 0.6 low reduced fetal body EPA. 1992 gavage 100 7..7 x lU'
weight
-------
TABLE 7
FUTURE LAND USE
RESIDENTIAL (LIFETIME)
CHRONIC HAZARD INDEX ESTIMATES
AMERICAN CREOSOTE
No low reproduction EPA. 1992 water 1,000 4.6 x 1()'4
No medium weight loss, EPA.I992 food 1,000 1.1 x 1()'4
neurotalicity
o-cresol 1.1 x 10" No 0.05 medium neurotalicity EPA. 1992 gavage 1,000 2.2 x 10"
2,4.Dicblorophenol 9.0 1 10" No 0.003 immwo system EPA. 1991 100 3.0 x 10"'
2,4-Dimethylphenol 1.2 ]I; 10" No 0.02 CNS EPA,I991 1,000 6.0 x 10"'
2,4.Dinitrophenol 1.2]1; 10" No 0.002 cataracts EPA.I991 1,000 6.0 x 10-
Pentachlorophenol 1.3 ]I; 10"' No 0.03 medium liver,kidney EPA. 1992 food 100 4.3 x 1()'4
Phenol 9.7 x 10- No 0.6 low reduced fetal body ErA.I992 gavago 100 1.6 1 10"'
weight
2.3,4,6. '.7110- No 0.03 medium liver EPA.I992 gavage 1,000 1.9 x 10"
Tetrachlorophenol
2,4,5 2.7]1; 10- No 0.1 low liver, kidney. ErA. 1992 food 1,000 2.7 x 10"'
Trichlorophenol
Acenaphthene 9.3]1; 10' No 0.06 low liver ErA. 1992 gavage 3,000 1.6 x 10"
Anthracene 1.9 I 10" No 0.3 low EPA. 1992 gavage 3,000 6.3 x 1()'4
-------
TABLE 7 (Continued)
FUTURE LAND USE
RESIDENTIAL (LIFETIME)
CHRONIC HAZARD INDEX ESTIMATES
AMERICAN CREOSOTE
:(})\\I;:lj:!.ilfi:;]t11111;1:;lfi~1:~:;;if.;liil:li~l;r;:1:lllil:::illl:I;:!ii:ti:I:;:;~:ftl::i::II;lr!:~i;;:::Ii::i::i:ii:
Toluene
0.571
1,000
100
3.9 X 1
-------
TABLE 7 (Continued)
FUTURE LAND USE
RESIDENTIAL (LIFETIME)
CHRONIC HAZARD INDEX ESTIMATES
AMERICAN C~EOSOm
_rJ...".._U.
.
2.3,4,6- 9.2 J: 10" Yes 0.03 medium liver EPA. 1992 gavage 1,000 3.1 J: 1()'4
TetraehlolOphenoi
2,4,s 4.4 x 10" Yes 0.1 low liver, kidney EPA. 1992 food 1,000 4.4 x 10"
Trichlorophenol
7.3 J: 10"
:i:i:_~9.JUr~:~\iIJI!~yt~mIID~g1tili\Bilimlilji[:lr9YIU:~;:.. ,~:::~,~:;~~::;:tl!:i~tl'tl:!:~lli11!il~i!frir~:liiiri.~iii!:!f~~[1:ii!!III\!~11;fi,li~lii!:lriii1!i=1fl.it, "... . ..~j!\f:t:\MI:\!:I![!I!![I~);~:~:;' .'. ..
.'''.'.'.'," ~~:~: ,:$*: .''',
Acenaphthene 1.1 x 10'1 No 0.06 low liver EPA, 1992 gavage 3,000 1.8
Anthracene 4.4 J: 10"2 No 0.03 low .. BPA. 1992 gavago 3,000 1.5
FIuoranthene 1.4 :1 10'1 No 0.04 low neuropathy, liver EPA. 1992 pvage 3,000 3.5
Fluorene 4.0 J: 10'1 No 0.04 low decreased red blood EPA. 1992 gavage 3,000 10.0
cells
Naphthalene 9.6 x 10"1 No 0.04 .. reduced body weight EPA. 1991 gavage 10,000 24
Pyrone 6.7 X 10'2 No 0.03 low kidney EPA. 1992 gavage 3,000 2.2
Ethylbenzene 1.9 :1 10" No 0.1 low liver, kidney EPA, 1992 gavage 1,000 1.9 x 10'2
Toluene 1.8 x 10"2 No 0.2 low CNS BPA, 1991 - 1,000 9.0 J: 10"2
Xylenes 1.2 :1 10'2 No 2 medium hyperactivity EPA. 1992 gavage 100 6.0 x IO-S
-------
As shown, the potential risks to human health are from surface
soils and contaminated ground water, while sediments within
Creosote Branch are below established health-based goals for
remediation. currently, carcinogenic threats to human health via
exposure to ground water and surface soils are above EPA's target
risk range for taking actions at CERCLA sites. For the aquifer,
the upper-bound estimate of carcinogenic health risks associated
with potential lifetime exposure was reported as 8x10.2. The
majority of risk associated with this exposure is from drinking the
carcinogenic PARs (expressed as B(a)P) from contaminated ground
water. For surface soils the ingestion and direct contact (dermal
contact) exposures from carcinogenic PARs and dioxins are
represented as 2x10.2. Both contaminated surface soils and ground
water greatly exceed the lower bound of EPA's target risk range of
lx10.4 and represents a significant carcinogenic health risk.
The non-cancer health risks reported as the hazard quotient was as
high as 43 for potential exposure to ground water. This value is
. substantially greater than the established NCP goal of less than 1.
The r~sk from this aquifer is driven primarily by the individual
.PAR compounds such as naphthalene and fluorene. 'The contaminated
ground water presents an unacceptable noncarcinogenic health risk.
6.3.2
IMPACTS TO THE ENVIRONMENT
.'
A detailed ecological assessment was conducted using worm studies
of surface soils, and bioassays of the surface waters and sediments
of Creosote Branch. Knowledge of site ecology is based on site
reconnaissances and a compilation of existing ecological
information. Surveys were conducted of terrestrial vegetation and
wildlife, aquatic and wetland habitats, and aquatic life. The
ecological risk assessment was conducted in accordance with the
Risk Assessment Guidance for superfund: Volume II, Environmental
Evaluation Manual (EPA, 1989b), and Ecological Assessment of
Hazardous Waste sites: A Field and Laboratory Reference (EPA,
1989c).
"
72
I:.:
-------
Risks to the following media were evaluated as part of that risk
assessment:
terrestrial vegetation:
terrestrial wildlife:
aquatic life: and
wetlands.
6.3.2.1
Field Ecological Investigations
A field investigation of the site and adj acent properties was
conduc~ed on March 18, 1992. Wetlands were identified using the
three parameter approach of the 1989 Federal Manual for Identifying
and Delineating Jurisdictional Wetlands (Fed. Interagency Comm. for
Wetland Delineation 1989). This approach identifies wetlands based
on the presence of the following criteria: (1) a periodic
predominance of hydrophytic vegetation, (2) a substrate of
predominantly undrained hydric soil and (3) a substrate saturated
or inundated during at least part of the growing season.
- .
During the investigation, data were collected on vegetation, soils
and hydrological characteristics of the site. A qualitative
assessment was made of vegetative communities on-site by noting the
distribution and extent of different plant species in each of three
general vegetative strata: the canopy, the understory, and the
herbaceous layer. The extent of each species was estimated by
direct observation. The u.s. Fish and Wildlife Service (FWS) has
assigned a wetland indicator classification to plant species, based
on the growth requirements of each species. This classification
was used concurrently with field observations to determine the
approximate extent of wetland plant communities on site.
soil was evaluated to determine the upper limit of the wetland
boundary. However, in this study, soil sampling was relied upon to
a lesser extent, given the highly disturbed and contaminated nature
,of the soil. Soil profiles were investigated visually for color,
organic content, general texture, mottling or streaking and
evidence of past disturbance. Hydrologic indicators were used in
conjunction with soils and vegetation to establish the upper
wetlands boundary. These indicators included topographic and
-------
surface water features, soil saturation and evidence of past
inundation or surface flow, such as tree buttressing, watermarks,
darkened leaves, sediment deposition and/or driftlines.
Most of the site previously has been utilized for various wood
treating activities and consequently is denuded of most vegetation.
This is particularly true of the former process area where various
buildings, wood treating apparatus and storage tanks were located.
This activity has resulted in highly disturbed vegetation and bare
soil mosaic composed of a variety of disturbance species, with
little discernible pattern. Wetland tree species such as black
willow were observed growing alongside upland species such as black
locust, with escaped cultivars including scattered crabapple trees.
Patches of grasses, such as quackgrass and cheatgrass were common
throughout this area. Most of this area is covered by weedy
herbaceous species, such as ragweed, goldenroci~ panic-grass, India
lovegrass, and numerous other invaders. This former process area
,thus offers little habitat value for wildlife.
;1
. The west-central and southern portion of the site was used for wood
. . storage and debarking. This area has been subj ect to less frequent
and vigorous disturbance and is presently in an early successional
stage dominated by knee-high saplings of red maple and willow and
shrubs such as alder and elderberry. Rushes, sedges, rough-stemmed
goldenrod, tick-seed sunflower, pokeberry, and a variety of other
weedy herbaceous species are present.
A relatively undisturbed wetland-upland complex is located along
the east and west peripheries of the site and the northern third of
the property. Three relatively intact wetland types exist within
this undisturbed area including a palustrine forested wetland, a
palustrine emergent wetland, and an open water wetland.
"
"
.,'
A palustrine forested wetland covers much of the northern portion
of the site. This palustrine forested wetlands consists of a
canopy dominated by several oaks including willow oak, overcup oak,
and water oak, American elm and sweet gum. Sweetbay magnolia, red
maple and black gum represented a minor proportion of the canopy
trees. Understory vegetation consists of green ash, water locust,
stiff dogwood, hybrid oak species and hornbean. Due to seasonal
factors, herbaceous vegetation was uncommon at the time of the
-------
study
White
black
but greenbrier, poison ivy, and supplej ack were
oak, swamp chestnut oak, American beech, loblolly
gum were noted in areas of slightly higher ground.
present.
.pine and
Small pockets of emergent wetlands were noted in disturbed portions
of the palustrine forested wetland. These areas exist along the
western and northern site boundary and have formed in canopy
openings and historic road beds. These wetlands are dominated by
swamp leucothoe, sweet pepperbush, elderberry, arrowleaf tearthumb,
rush, sedge, and in some areas by cattails and other emergents.
A open water wetland is present along the east central corner of
the site. :It is situated in an upland area dominated by shortleaf
pine, sweet gum, white ash, mockernut hickory, southern red oak,
and others. As suggested by the shape and size of the basin, it is
likely that this pond is man-induced and may have been the site of
a former borrow pit or lagoon.
Numerous small upland inclusions were identified within the
northern forested wetland and are associated with railroad track
beds and dredge spoils along the northern edge of th~ property.
These areas are higher in elevation than the surrounding forest,
and are dominated by white oak, sassafras, white ash, loblolly
pine, and red maple saplings. Mayapple and trumpet honeysuckle
were present in the herbaceous layer.
Most of the eastern fringes of the property as well as the parcels
adj acent to the sewage treatment plant consist of a upland
community dominated by loblolly pine, shortleaf pine, American
beech and white oak. The understory is comprised of a variety of
sapling and shrub species, including scrub oak, black locust, black
cherry, sassafras, prickly dewberry, winged sumac and dangleberry.
Typical herbaceous species include bracken fern and goldenrod.
6.3.2.2
Wetlands Determination
portions of the American Creosote site possess the three criteria
necessary to meet the regulatory definition of a wetland. These
areas are presented on Figure 17. Approximately 28.3 acres of
wetland, and 1.6 acres of open water were identified on the site
and adjacent parcels. These wetlands cover most of the northern
-------
"
~
(j)
~
~
bl
';
f':
I .
....J
r-,
- ~
+ :y
,/
tJl'
VI
0 --
~~ 18 D [:::1[::3 !:J CIa
D
I
/-EGEND
WETWIII YRET~TION
_n EIITEIIJ Of
WIIUIIII COMI'\D
SIIIEAIoI - I SIIOIIDJII[
DRADIA« lIITeM
- ftlEUNt
-
11ft ~
'"
GIW'JDC SCALE
--
C18-1
,...--..
i
WETLAND MAP
AIlERICAN CREOSOTE SITE
WINNFIELD. LA
MARCH 17. 1992
US BfA ENVIRONMENTAL RISPONSE 'I'IWl
-- ---....-.--
--
--
-------
~ -. <'.-
portion of the site, as well as the eastern and western
peripheries. Wetlands present on and adjacent to the site have
become degraded to some extent as a consequence of human
activities. Nevertheless, the wetlands identified in this study,
while deqraded from erosion and exposure to si te contaminants,
still offer some habitat value, as evidenced by siqhtinqs of
wildlife species includinq birds, reptiles, and amphibians.
Amphibians are typically sensitive to chanqes in habitat
characteristics, supportinq the premise that these wetlands are not
severely deqraded. Further, these wetlands are of hiqh quality
from the perspective of flood control, aquifer recharqe and, in
particular, sediment, nutrient, and contaminant trappinq. In
contrast, wetlands in the western portion of the site are qenerally
highly disturbed and degraded.
6.3.2.3
Toxicity Testing
Earthworm and aquatic toxicity testing were conducted to evaluate
the potential environmental risks associated with site
contaminants. These studies as outlined below and presented on
Table 8 wer~ performed on samples collected in 1987 and February
1992, from the American Creosote site.
The EPA Environmental Research Laboratory-corvallis tested 7 soil
samples using earthworm bioassays. In addition to mortality data,
qualitative observations were recorded to evaluate potential
sublethal effects. Earthworms exposed to soil samples (test sample
ID AE-14 and 15 on Table 8) which were visibly stained and oiled
from the former process area exhibited complete mortality with
observations of decomposed earthworms on the surface of the test
containers. This observation suggests that the earthworms did not
burrow or burrowed and returned to the surface, and thus may have
been severely effected without soil ingestion and with reduced
dermal exposure. These observations, coupled with visual
observations of those particular soil samples (dark, slimy, oily)
clearly indicate soil toxicity.
-------
TABlE 8
SUMMARY OF TOXICITY TESTS FOR
AMERICAN CREOSOTE SITE
.
:::::::'::::::::;:::~::_;I1\l;j:::::::j:~:' -
~lj!'I.r;\'!I:I~lrJlI.II,\:\i!!\III:
100 TOX NT NT
101 NT TOX NT
103 NT TOX NT
104 NT NT TOX
109 NT TOX NT
.'\.:I,llllIlllllii[:I: lii;I:::j".~t':I\II\\:::I'~ \~l\I\~.I~j"\I\' 111'''t;.'I\I\i~1 11:\1_11:
AWl 0 NO 0 NO
AW2 0 NO 0 NO
AW2a 0 NO 0 NO
AW3 0 NO 0 NO
\\I:\."".\~!..\!'\:'I&I.:I'I\\\\II':~\~ 1.."\'!\I,:~'.~il\'\\'I':.II:\ l\.[::i;llPrdI\\.:i'.il \t~'\\\\\\'\\.I'\li~'I\j\t \\ij~".~'\1\
AWl 0 NO 0 NO
AW2 0 NO 100 YES
AW2a 30 YES 100 YES
AW3 0 NO 100 YES
:;::::::i:;:;:::::::.j~:$.m::ti.&lji;:\:::::::::\\:::::: :j::~:::::j\~::\::;::..$m::I::I~I~t,j::t::::::::~:\::j~ ;:;:::\~;:;:;!~..~mi$"-\;:::;~::;;;:
AE-01 0 YES
AE-l0 0 YES
AE-11 0 NO
AE.12 0 NO
AE.14 100 (DECOMPOSED ON SURFACE)
AE-1S 100 (DECOMPOSED ON SURFACE)
AE-19 3 YES
TOX = Toxicity Significantly Different From Controls
NT = NODtOIio-Not Significantly Different From Controls
CERlO -= Ceriodaphnia Dubia
MINNOW = Fathead Minnow
-------
samples from the debarking area in the southern portion of the site
and an off-site area (adjacent to Creosote Branch approximately 300
feet upstream from the site) exhibited no earthworm mortality.
These samples are presented as AE-Ol, AE-10, AE-11, and AE-12 on
Table 8. Earthworms exposed to the off-site soil sample produced
several earthworms with segmental constrictions and lesions.
Earthworms exposed to soils from one of the three samples from the
debarking area appeared clumped together as a potential avoidance
mechanism, whereas earthworms exposed to soils from the other
samples exhibited no sublethal effects. These resul ts indicate
minimal, if any, impacts of these surface soils to the environment.
Several earthworms exposed to soil from the former treated wood
storage area to the north of Creosote Branch exhibited segmental
constrictions and restricted movement. These sublethal effects may
not be related to site contaminants, but could be related to the
high moisture content of the soil. A soil sample from the former
treated wood storage area wooded area north of Creosote Branch
exhibited a single mortality out of 30 earthworms. These results
also indicate that the area to the north of Creosote Branch do not
represent a si~ificant threat to the environment.
Chronic toxicity testing was conducted in February, 1992 on
sediment eluate and water samples (site and reference samples) by
EPA Region 6, Houston Laboratory using water fleas (ceriodanhnia)
and fathead minnows test organisms. All tests as presented on
Table 8 were conducted for up to 7 days to evaluate the exposure of
water fleas and fathead minnows to ambient water site samples and
to sediment eluate. There was no significant effect, based on
mortality or reproduction, from any of the surface water samples
taken upstream at the site, or downstream from the site.
No significant adverse effects were observed in organisms exposed
to the eluate from a sediment sample (AWl) taken approximately 300
feet upstream of the site. A sample of sediment eluate from a
tributary of Creosote Branch (AW2a), not directly impacted by the
American creosote site, showed water fleas were significantly
affected based on reduced reproductive capacity. However, fathead
minnows showed no adverse effects. Sample AW2 of the sediments
adj acent to the process area showed no effects to water fleas while
-------
fathead minnows were significantly affected. Fathead minnows
exposed to an eluate from a sediment sample (AW3) further
downstream of the site were significantly affected, whereas no
significant effect was observed in water fleas at the same
location.
. J
In summary, the surface waters in the Creosote Branch do not appear
to represent a significant threat to the environment as indicated
by chemical analyses and toxicity tests of these waters. However,
the sediments near the site represent a threat to the environment
as indicated the detection of contaminants of concern in chemical
analyses and by significant toxicity in the aquatic toxicity tests.
Further consideration of these threats shows removal of these
sediments could greatly impact the wetlands by excavation
operations on and within the area adjacent to creosote Branch.
Based on this consideration, disturbance of the sediments in the
Creosote Branch may pose a greater threat to the environment than
leaving the sediments in place. Remediation of the process area
will eliminate the source of c~ntamination to the sediments in
Creosote Branch. Furthermore, earthworm toxicity tests indicate
that surface soils in the process area represent a significant
threa~ to the environment. Earthworm toxicity tests conducted on
surface soils outside the process area indicate minimal, if any,
impacts of these soils to the environment.
6.3.2.4
Quantitative Ecological Risk Assessment
As presented in the administrative record and briefly summarized
below, quantitative ecological risk assessment also indicates that
the site poses an environmental threat. As documented in the
toxicity tests, the sediments pose a threat to fish as indicated by
observed effects on fathead minnows. Risk calculations show a
potential threat to aquatic life as indicated by observed effects
on algae, fathead minnows and bluegills. Ecological risk
calculations show that site-related contaminants have potential
adverse effects on small mammals such as deer mice from PCP, PABs
and dioxins. For instance, reported ecological hazard quotients
for small mammals are as high as 3,980 for PAR exposure, 800 for
dioxin exposure, and 2.2 for PCP exposure. Ecological hazard
quotients based on low observable adverse effect levels that exceed
1 indicate potentially significant ecological risks. For a more
-------
detailed explanation of the quantitative ecological risk assessment
assumptions and equations refer to the Ecological Risk Assessment
in the Administrative Record.
6.4
UNCERTAINTIES ASSOCIATED WITH RISK CALCULATIONS
Risk assessment is a scientific activity subject to uncertainty~
In addition to the uncertainty and the use of conservative
assumptions to calculate slope factors and RfDS, the analysis of
environmental conditions is difficult and inexact. The American
Creosote risk assessment is subject to uncertainty from a variety
of sources including:
- sampling and analysis:
- toxicological data:
- exposure estimation:
- fate and transport estimation: and
- risk characterization.
These uncertainties in the American Creosote baseline risk
assessment are a function of risk assessments in general and a
function of the uncertainties specific to the American Creosote in
particular. A1. though all risk assessments contain a certain amount
of uncertainty, an attempt to reduce the uncertainty in the
American Creosote baseline risk assessment was made whenever
possible.
Based on a February 26, 1992, memorandum from EPA Deputy
Administrator F. Henry Habicht, EPA is required to evaluate both
"reasonable maximum exposure" (RME) and "central tendency" in the
risk assessment at Superfund si tes. The exposure assumptions
associated with the RME have been used to estimate the baseline
risks and ultimately the remedial action goals at the sites. The
"central tendency" scenario represents the risk from more of an
"average" exposure, compared to a "reasonable maximum" exposure.
A comparison of RME and "central tendencies" is presented in
Table 9.
-------
!lULB ,
COIIPAR%80B OP CBII'~kAL TB1O)JDtC:IB8 TO RBASODBLB JlUDIUJI BXP08URB
. A.
General Eauation for Estimatina EXDosure
CR x EF x ED
Intake (mg/kg-day) = C x
------------
BW x AT
ComDarison of Central Tendencv and RME
Average or
Central Tendencv
B.
Concentration Term (C)
Site-specific value
Contact Rates (CR)
Water Ingestion Rates
Children (1 - 6 yrs)
Adults
Workers
Soil Ingestion Rates
Children (1 - 6 yrs)
Adul:ts
Workers
Fish Ingestion Rates
Adults
Air Inhalation Rates
Children (1 - 6 yrs)
Adults
Dermal EX'Dosure
Adherence factor (AP)
Absorption factor (ABS)
Total Surface Area (SA)
Children
Adults
Reasonable
Maximum ExDosure
95% UCL
95% UCL
0.7 L/day 1 L/day
1.4 L/day 2 L/day
0.7 1 L/day
200 mg/day 200 mg/day
100 mg/day 100 mg/day
50 mg/day 50 mg/day
6.5 g/day 54 g/day
5 cu. m/day 5 cu.m/day (50%)
20 cu.m/day 20 cu.1D/day (50%)
0.2 mg/cm2 1 mg/cm2
Chemical-specific Chemical-specific
7,200 cm2/event 7,200 cm2/event
20,000 cm2/event 20,000 cm2/event
-------
TOLB 9 (oon1:inue4)
COKPDZSOIt 01' CBB'rUL TBltDBBCXBS TO RBASONABLB MAXXKOX BXPOSURB
Bodv Weiahts (BW)
Children (1 - 6 yrs)
Adult
Workers
Excosure Duration (ED)
Residential
Industrial
Excosure Freauencv (EF)
Residential -
Industrial
Averaaina Time (AT)
Carcinogenic effects
Noncarcinogenic effects
Average or
Central Tendencv
Reasonable
Maximum ExDosure
16 kg
70 kg
70 kg
16 kg
70 kg
70 kg
(50%)
(50%)
(50%)
9 years
9 years
30 years
25 years
350 days/year
250 days/year
350 days/year
250 days/year
70 years
ED
70 years
ED
c.
References For Central Tendencv Exnosure Parameters
Central Tendency
Basis/Reference
concentl:W.on Term (gl
site-specific value
Contact Rates (CR}
Water Ingestion Rates
Children (1 - 6 yrs)
Adults
Workers
95% UCL
US EPA, 1992a
0.7 L/day
1.4 L/day
0.7
US EPA, 1989a
US EPA, 1989b
50% Adults
-------
TABLB , (continue4)
COHPU%8011 OP CD1TUL TBIlDBJlCIB8 TO RBASODBLB KUIHUK BXP080RB
Soil Ingestion Rates
Children (1 - 6 yrs)
Adults
Workers
Fish Ingestion Rates
Adults
. Air Inhalation Rates
Children (1 - 6 yrs)
Adults
Dermal EXDosure
Adherence factor (AP)
Abso;ption factor (ABS)
Total Surface Area (SA)
Children (1 - 6 yrs)
Adults
Bodv Weiahts (BW)
Children (1 - 6 yrs)
Adult
Workers
EXDosure Duration (ED)
Residential
Industrial
EXDosure Freauencv (EF)
Residential
Industrial
Central Tendencv
Basis/Reference
200 mg/day
100 mg/day
50 mg/day
US EPA, 1989c
US EPA, 1989c
US EPA, 1991
6.5 qjday
US EPA, 1989b
5 cu. m/day
20 cu.m/day
US EPA, 1989a
US EPA, 1989a;
US EPA, 1989b
0.2 mg/cm2
Chemical-specific
US EPA, 1992b
7,200 cm2/event
US EPA, 1989a;
US EPA, 1989b
US EPA, 1992b
20,000 cm2jevent
16 kg
70 kg
US EPA, 1989b
US EPA, 1989b;
US EPA, 1991
70 kg
US EPA, 1991
9 years
9 years
US EPA, 1989b
= to residential
350 days/year
250 days/year
US EPA, 1991
-------
TADLB , (con1:inue4)
COJIPDXSOB O. CBHUL !'BImDlC%B8 ~ BBASODBLB JIAXDIOK BXP08URB
Averaaina Time (AT)
carcinogenic effects
Noncarcinogenic effects
Central Tendencv
Basis/Reference
70 years
ED
US EPA, 1989b
US EPA, 1989b
D.
References For Reasonable Maximum EXDosure Parameters
Reasonable Maximum
Basis/Reference
Concentration Term (C)
Site-specific value
Contact Rates (CR)
Water Ingestion Rates
Children (1 - 6 yrs)
Adults
Workers
Soil Ingestion Rates
Children (1 - 6 yrs)
Adults
Workers
Fish Ingestion Rates
Adults
Air Inhalation Rates
Children (1 - 6 yrs)
Adults
Adults
95' tJCL
US EPA, 1992a
1 L/day
2 L/day
US EPA, 1989a
US EPA, 1989b;
US EPA, 1991
1 L/day
US EPA, 1991
200 mg/day Average value,
US EPA, 1989c
100 mg/day Average value,
US EPA, 1989c
50 mg/day Average value,
US EPA, 1991
54 g/day
US EPA, 1991
5 cu. m/day
20 cu.m/day
US EPA, 1989a
Average value,
US EPA, 1989a;
US EPA, 1989b
30 cu.m/day
Upper bound t,
US EPA, 1989a;
-------
'tABLB , (continued)
COJIPUI80B OP CJU1TDL 't1DlDD1CIBS 'to RBASODBLB HU:DmK BXP08URB
Dermal EXDosure
Adherence factor (AP)
Absorption factor (ABS)
Total Surface Area (SA)
Children (1 - 6 yrs)
Adults
. Bodv Weiahts (BW)
Children (1 - 6 yrs)
'Adult -
Workers
EXDosure Duration (ED)
Residential
Industrial
EXDosure Freauencv (EF)
Residential
Industrial
Averaaina Time (AT)
Carcinogenic effects
Noncarcinogenic effects
Reasonable Maximum
Basis/Reference
1 mg/cm2
Chemical-specific
US EPA, 1992b
7,200 cm2/event
Average value,
US EPA, 1989a:
US EPA, 1989b
Average value,
US EPA, 1992b
20,000 cm2/event
16 kg
Average value,
US EPA, 1989b
Average value,
. US EPA, 19891:1:
US EPA, 1991
70 kg
70 kg
Average value,
US EPA, 1991
30 years
US EPA, 1989b:
US EPA 1991
US EPA 1991
25 years
350 days/year
Average value,
US EPA, 1991
Average value,
US EPA, 1991
US EPA, 1989b
US EPA, 19891:1
250 days/year
70 years
-------
~ABLB , (con1:1nue4)
COXPUISOII 01' CDrrIUU. ~BI1DDlCJ:BS m RBASODBLB D%J:KtJII BXPOSURB
B.
References
US EPA. 1989a. Exposure Factors Handbook. EPA/600/8-89/043.
US EPA. 1989b. Risk Assessment Guidance for superfund, Volume 7,
Human Health Evaluation Manual (Part A). EPA/540/1-89/002.
us EPA. 1989c. 7nterim Final Guidance for Soil 7nqestion Rates.
OSWER Directive 9850.4.
US EPA. 1991. Risk Assessment Guidance for superfund, Volume 7,
Human Health Evaluation Manual, Supplemental Guidance, Standard
Default Exposure Factors. OSWER Directive 9285.6-03.
US EPA. 1992a. Supplemental Guidance to RAGS: calculatinq the
Concentration Term. Publication 9285.7-081.
US EPA. 1992b. Dermal Exposure Assessment:
Applications. EPA/600/8-91/011B.
Principles and
-------
6.5
REMEDIATION GOALS
The selection of appropriate remediation levels is based primarily
on an evaluation of the potential health effects caused by human
exposure to the contaminants, assuming that the future land use
will be residential. The reasoning behind designating the future
land use as residential is that the site is currently surrounded by
residential areas.
~:
The contaminated shallow ground water was determined to represent
the most significant long term threat at the site. This arises out
of the potential exposure of the public to the site contaminants
and because of the potential usage of the aquifer for drinking
purposes or seepage into the Creosote Branch. The deeper ground
water zones are currently used for drinking water purposes.
However, the potential rise of the saline/water interface as based
on recent data in Winn Parish, may require use of shallower
aquifers in the future. The remedial objective for shallow ground
water is to prevent the exposure_of potential receptors to on-site
contamination in amounts above human health-based standards and to
restore ground water quality.
s~ t
The contaminated tar mat materials and subsurface soils and NAPLs
were determined to be a potential threat at the site because of the
potential for direct contact and potential impact on ground water.
One of the most important effects of these subsurface materials is
the presence of NAPLs which will provide a continual source of
contaminants to the ground water if left untreated. Removal of the
tar mat area would also allow restoration of wetlands.
,.
PAHs (primarily expressed as B(a) P equivalents) , phenols (primarily
PCP), and dioxins were found to be the primary contaminants of
concern at the American Creosote site based on risk assessments.
The RI results have shown dioxin/furan analyses with up to 5 pg/kg
2,3,7,8-TCDD equivalents in surface soils. It has been determined
by EPA and the Agency for Toxic Substances and Disease Registry
(ATSDR) as presented in the RI/FS that levels of 2,3,7,8 TCDD
between 1 to 10 ~g/kg do not represent a significant residential
risk provided they are covered with at least 12 inches of clean
soil. Furthermore, ATSDR and EPA have established that levels of
1 ~q/kg or less of 2,3,7,8 TCDD is an acceptable level in surface
-------
soils. Therefore, ~e remediation goal for surface soils ~at does
not involve treatment of dioxins is to ensure that the material is
covered with at least 12 inches of clean cover. For treatment
alternatives of dioxins ~e established remedial goal will be 1
~g/kg or less of 2,3,7,8 TCDD equivalents. :It should also be
recognized ~at no 2,3,7,8-TCDD has actually been found.
For ~is ROD EPA Region 6 has considered an acceptable
concentration of 3,000 ~g/kg for carcinogenic PARs expressed as
B(a)P equivalents, and PCP concentrations less ~an 50,000 ~g/kg
for soils within 2 feet of the surface (for a detailed discussion
of the basis for these levels refer to section 9). These values
represent a level approaching a 1x10.s risk range for carcinogenic
PARs and 1x10.s for PCP, and the 2 feet is believed to represent the
maximum distance below ~e immediate surface to which surface
materials are typically disturbed. Below 2 feet the soils are
determined to represent a ground water threat and will be addressed
as follows. The goals for remediation of ~e ground water are to
reduce the B(a)P value below a concentration of 0.2 ~g/l, which is
~e maximum contaminant level (MCL) for PABs, and benzene below a
concentration of 5 ~g/l which is the MCL for ~is compound. The
goals for the remediation of soils below 2 feet will be ~e same as
the upper 2 feet which are 3,000 "'CJ/kg for carcinogenic PARs
expressed as B(a)P equivalents, and PCP concentrations less than
50,000 ~g/kg. :It is believed that by achieving these soil goals
that the aforementioned goals for the ground water may be attained.
The soils in the area between the tar mat and Creosote Branch are
not being removed as part of this remedy because of the potential
effects on wetlands. The maximum concentration of B(a)P
equivalents in this area is 7, 500 ~q/kg. This concentration is
still below the 1x10.4 goal for remediation. These soils are not
considered a significant threat to ground water or to human health
because of direct contact. However, if the soils between the tar
mat and Creosote Branch were removed the existing wetlands would be
drastically damaged. -
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
to public health, welfare, or the environment.
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7.0
DESCRIPTION OF ALTERNATIVES
7.1
IDENTIFICATION OF APPROPRIATE TECHNOLOGIES
The analyses for remedial alternatives for the American Creosote
site used data generated from previously selected Remedial Actions
. at other woocl treating sites to identify a set of technologies
appropriate for further screening, development, and detailed
analysis. This analysis included evaluation of RODs prepared after
the passage of the Superfund Amendments and Reauthorization Act
(SARA) of 1986. The evaluation was restricted to post-SARA RODs to
reflect SARA's statutory preference for reduction in toxicity,
mobility, or volume through treatment. Additional consideration
was given to Innovative Treatment Technologies to ensure an
adequate evaluation of technologies.
Wood treating sites are known to be of three broad types, depending
on the chemicals used: creosote, -pentachlorophenol (PCP), or metal
compounds such as chromated copper arsenate (CCA), ammoniacal
copper arsenate (ACA), or ammoniacal copper-zinc-arsenate (ACZA).
At the American Creosote site, both creosote and PCP were used,
and, therefore, polycyclic aromatic hydrocarbons (PABs) and phenols
(mainly PCP) are the primary contaminants of concern in addition to
the BTEX from petroleum used as a carrier fluid. The use of metal
compounds have not been documented at the site. Even though the
contaminants of concern have been limited to PCP, PABs and BTEX,
after attempting to review historical records and operations, it
has been determined that the materials at the site do not
constitute a RCRA listed hazardous waste specified at 40 CFR Part
261 for the reasons described below.
The EPA has not been able to identify specific sources or specific
processes that allow adequate determination for listing of this
material due to post-generation commingling of the wood treating
process wastes with soils and debris. Therefore, the material is
not a listed RCRA hazardous waste pursuant to 40 CPR Part 261.
However, the Land Disposal Requirements (LDR) related to waste cocle
U-OSl for spills of creosote is considered to be a relevant and
appropriate requirement for the organic wood treating wastes at the
site because any remediation activity involving treatment will
-------
include contaminated soils wi th creosote wastes. Such
consideration includes the PARs and PCP when establishing treatment
standards. As specified in 40 CFR I 268.43, the treatment
standards expressed as waste concentrations for U-051 nonwastewater
(soils/sludges) are:
Naphthalene
Pentachlorophenol
Pyrene
Toluene
Xylenes
Lead
1,500
7,400
1,500
1,500
28,000
- 33,000
I'g/kg
I'g/kg
I'g/kg
I'g/kg
I'g/kg
I'g/kg
These levels are supplemental to the goals as established in the
remediation goals section of the Summary of site Risks portion of
this ROD. However, the PCP level in the goals for remediation is
stated as 50,000 I'g/kg, as detailed in section 6.5, and presented
as 7,400 I'g/kg above, the lower value will be established as a
criterion for any treatment alternative. In addition, the
remediation goal of 3,000 I'g/kg for B(a)P equivalents will also be
established as a goal for all treatment alternatives of the
soils/sludges as explained in section 6.5.
Tables 10 and 11 were presented in the FS to represent the
technologies that were all or Dart of the selected remedies at NPL
sites that documented wood treating contaminants in soil and ground
water. Also included are the number of sites where the selected
remedy faced technological problems. These comparisons were based
on 38 post-SARA RODs and 2 removal actions. Subsequent evaluations
of these analyses by EPA after the issuance of the FS have shown
that out of these 40 sites, 23 had site contaminants related to
metal process treatment of the timber. It is believed that in
those RODs, the presence of metals had a significant impact on the
selected remedy and, therefore, the tables have been re-evaluated
for those sites in which metals were a controlling factor. The
results of this re-evaluation are presented in Tables 12 and 13 for
sludge/soil. Based on this comp~rison it is believed that Table
'13is most representative of current technologies used to address
PCP and creosote contaminated sludge/soil similar to the American
Creosote site.
-------
TABLE 10
SUMMARY OF SOIL 1REATMENTTECHNOLOGIES SELECIED
AT POST-SARA WOOD-TREATING SITES
Bioremediation 19 4
Dechlorination 1 0
. Low Temperature Thermal Desorption 1 0
RCRA Cap/Landfill 10 0
. Soil Flushing 4 3
. Soil Washing 8 0
Stabilization/Solidification/Fixation 8 1
. Solvent/Critical Fluid Extraction 1 0
Thermal Destruction 7 0
. Based on RODs
b Based on discussions with RPM
-------
TABLE 11
SUMMARY OF GROUNDWAlER TREATMENT lECHNOLOGIES SELEC1ED
AT POST-SARA WOOD-TREATING srms
-~~
Activated Alumina Adsorption 1 0
Activated Carbon Adsorption 13 0
. Air Flotation 1 0
. Air Stripping 1 0
Bioremediation - Ex situ 6 0
Bioremediation - In situ 3 0
EIectrochemical Reduction 2 0
High Pressure Filtration 2 0
. Flocculation/Precipitation 6 0
Hot-Water Flushing 1 1
Ion Exchange 1 0
. Oil/Water Separation 9 0
Sluny WaDlSheet Pile Banier 3 0
. Ultraviolet/Oxidation 3 0
. These technologies are typicalJy implemented in conjunction with another treatment
technology.
. Based OD RODs
-------
. TABLE 12
SUMMARY OF SOIUSLUDGE TREATMENT TECHNOLOGIES
SELECTED AT POST-SARA WOOD TREATING SITES
- . P" '.... ....." ""'''''d''_''''''-''''''''' .
.
PRINCIPLE TREATMENT
Bioremediation 15 4 3.
Thermal Destruction 8 2 2
StabilzatioD/SoUdification 8 0 0
Dechlorination 1 0 0
PRELIMINARY TREATMENT
Low Temperature Desorption 1 0 0
Soil Flushing 4 2 0
Soil Washing 9 0 0
Solvent/Critical Fluid 1 0 0
Extraction
RESIDUAL TREATMENT
Capping 9 2 2
Offsite Recycling 1 0 0
NOTES
1) This table is based on an evaluation of 38 RODS and 2 Removal Actions.
2) This table is based on sites that were classified as wood treaters which includes contaminants of
concern that included both inorganic and organic compounds.
3) Sites that have inorganic:s compounds tend to select stabi1iZation/soUdificationbecause of the
inorganic:s.
. One of these sites had to obtain a treatability waiver because bioremediation could not achieve
the cleanup goals. The other sites had cleanup goals that were an ord:er of magnitude or higher
-------
TABLE 13
SUMMARY OF SOIUSLUDGE TREATMENT TECHNOLOGIES
SELEcrED AT POST-SARA WOOD TREATING SITES THAT HAVE
PREDOMINANTLY ORGANIC COMPOUNDS (pCP and/or Creosote)
ClIii..
PRINCIPLE TREATMENT
15 4
Bioremediation
3.
Thermal Destruction
StabilizatioDlSolidification
8
o
2
o
2
o
Dechlorination
1 0
PRELIMINARY TREATMENT
o
Low Temperature Desorption
SOU Flushing
SOU Washing
1
3
o
1
o
o
SolventJCritica1 Fluid
Extraction
9
1
o
o
o
o
Capping
Offsite Recycling
RESIDUAL TREATMENT
4 0
1
o
o
o
NOTES
. One of these sites had to obtain a treatability waiver because bioremediation could not achieve
the cleanup goals. The other sites had cleanup goals that were an order of magnitude or higher
-------
Table 13 shows that approximately two-thirds of the wood treating
sites that used PCP or creosote processes have selected
bioremediation for principle treatment of soil/sludges, 8 selected
incineration of soil/sludges, and 1 involved dechlorination. Of
the RODs that selected bioremediation or incineration, 9 of the
processes called for soil washing prior to treatment and 1 called
for critical fluid extraction prior to treatment. Based on this
analysis, consideration was given to processes involving phase
separation (L.L., soil washing, critical fluid extraction, low
temperature desorption, etc.) prior to any contaminant destruction.
7.1.1
7NITIAL SCREENING OF S07L AND SLUDGE ALTERNATIVES
Tables 10 and 13 show an initial screening of potential
technologies for remediating contaminated sludges and soils at the
American Creosote site. For the reasons discussed below, low
ctemperature thermal desorption, soil flushing, soil washing, or
solvent/critical fluid extraction have been rejected as effective
" means of separating the organic phased contaminants from the soil
matrix.
Low temperature thermal desorption was eliminated because of
,concerns that it may only be partially successful (demonstrated
removal efficiencies of only 65%) at separating the contaminants.
It is possible that due to the range of size in subsurface
materials (clay to gravel) that low temperature desorption would
not separate a significant portion of PCP and creosote from the
soils.
soil flushing without additional treatment such as in-situ
bioremediation would not be effective because its success relies on
flushing (removal) of contaminants from soil surfaces. Soil
flushing would potentially result in flushing of only the NAPLs
from the more porous sand and gravel lenses where encountered.
However, the other layers (silts and clays) would likely not be
effectively flushed due to the lesser porosity of those layers. In
addition, it is possible that since there is a large potential for
the pCP/creosote to adhere (absorb) to the soil particles that this
process would not treat the adhered contamination thus resulting in
the potential for a source of ground water contamination. However,
-------
it is important to note this technology is an element of in-situ
bioremediation which is addressed in the following pages.
Both soil washing and solvent/critical fluid extraction require
excavation of the soils/sludges and involve contact of the
contaminants on the soil particles with a solvent fluid. The
subsurface areas at American Creosote contain a large range of
particle sizes, and soil washing is more effective on large grained
soils than on silts and clays. Because the contaminated soil at
American Creosote consists largely of silts and clays, soil washing
is not considered to be viable due to the likelihood that a large
volume of contaminants would remain adhered to the clays and silts.
Solvent/critical fluid extraction was eliminated from consideration
due to concerns about the pH of the soil and the heterogeneity of
the subsurface materials. Effective fluid extraction requires a
narrow range of pH in a soil matrix. The range of pHs in the
contaminated soils at American Creosote is relatively broad,
requiring pH adjustment prior to solvent treatment. Because of
that fact, in addition to the heterogeneity of the soil matrix,
sOlvent/critical fluid extraction is considered to be
impracticabli!.
Dechlorination is considered inappropriate for this site due to the
presence of PABs, which are not chlorinated compounds. As such,
PABs are not susceptible to this treatment technology. Although
the process of dechlorination is appropriate for PCP, which is a
chlorinated compound, the majority of the contaminants driving the
risk at the American Creosote Site are carcinogenic PABs.
Therefore, dechlorination would not address the principal threats
to human health or the environment at the site.
In summary, based on initial screening, the only alternatives
considered appropriate for the contaminated sludges and soils at
this site were the treatment of the material through
bioremediation, stabilization, thermal destruction, or capping of
the wastes. These results were further supported by the October
1992, EPA document from the Office of Research and Development
which is entitled "contaminants and Remedial options at Wood
Preserving sites" (EPA/600/R-92/182). These four alternatives were
considered potential treatment alternatives for further evaluation.
-------
Initial screening during preparation of the FS identified potential
difficulties associated with biologically treating soils
contaminated with wood treating chemicals. (particularly
carcinogenic "PAIls, such as benzo[a]pyrene). One of the major
concerns to EPA was the ability to achieve the remediation goals as
previously established. out of the sites where bioremediation was
the selected remedy, problems associated with the presence of
dioxins, which are not remediated by biological activities, were
reported at two sites. For these sites, the selected remedies are
currently being re-evaluated. At another wood treating site for
which biological treatment through land farming was selected as a
remedy, heavy rain resulted in continuously saturated soil
conditions. This saturation reduced the biological growth rates of
the bacteria and thus greatly increased the treatment time.
Cleanup levels could not be achieved at one other site because
bioremediation was not able to reduce the, concentrations to
established health-based action levels (bioremediation is generally
....effective but has difficulty achieving levels for PAIls below 10,000
",g/kg) .
The use of bio-reactors, which are vessels in which contaminated
.media-for accelerated and controlled biotreatment are placed, has
also been considered for this project. However, most bio-reactor
systems are capable of only handling several cubic yards per day.
Given the large volume of wastes at the American Creosote site and
the questionable availability of large volume reactors, this method
of treatment could extend for several decades.
I;
EPA also evaluated a Superfund Site in Libby, Montana, where
bioremediation was selected as a remedy and is discussed in the May
1992 "symposium on Bioremediation of Hazardous Wastes. n That
article describes an estimated period of 8 to 10 years for the
bioremediation of 45,000 cubic yards of creosote- and PCP-
contaminated soils in a 2 acre land treatment unit at the Montana
site. The site's bioremediation system for PCP and PAIls had been
in operation for only a year at the time of the evaluation and,
therefore, the success of the operation is unknown at this time.
However, the information from the Libby site is still useful for
evaluating alternative remedies for the American creosote site.
Based on the assumptions presented for the Montana site, and
-------
assuming that 6 acres of land is available at the American Creosote.
site to use for biological land treatment, the same rate 'of
treatment as at the Libby site would occur, and that excessive
rainfall will not saturate the unit, it would take over 20 years to
remediate the American Creosote site.
The May 1991 EPA document entitled "On-Site Treatment of Creosote
and Penta~lorophenol Sludges and Contaminated Soil" (EPA/600/2-
91/019) reveals that the PCP and carcinogenic PAH compounds such as
B(a)p have half-lifes that exceed 100 days and may be as high as
450 days. In some cases no transformation of the compounds at all
occurred during the time frame of the experiments reported in that
document. Based on this document and the aforementioned
considerations, EPA Region 6 ini tially questioned the overall
effectiveness of biodegradation of the carcinogenic compounds at
the American Creosote site.
Subsequent discussions with EPA's technical staff in Cincinnati,
Ohio at the Risk Reduction Laboratory and the Robert S. Kerr
Environmental Research Laboratory in Ada, Oklahoma indicated that
in-situ bioremediation may be effective in treating the site
contaminants. These individuals concurred with the Region's
concerns regarding extended timeframes as outlined above, but they
also indicated that the information related to the effectiveness of
bioremediation was increasing and it would be beneficial to
consider in-situ bioremediation in more detail. Although
bioremediation was first eliminated from detailed analysis, both
LDEQ and EPA decided to conduct further evaluation of in-situ
bioremediation especially in light of the large volume of
contamination at the site.
The decision to consider bioremediation is further supported by the
October 1992 EPA document entitled "Contaminants and Remedial
Options at Wood Preserving Sites". This document states that in-
situ bioremediation promotes and accelerates natural processes in
undisturbed soil and under appropriate conditions, this technology
can destroy organic contaminants in place without the high costs of
excavation and materials handling. It can also minimize the
release of volatile contaminants into the air.
-------
7.1.2
:IN:IT:IAL SCREEN:ING OF NAPIB AND CONTAM:INATED GROUND WATER
ALTERNATIVES
Table 11 provides an outline of the processes that have been
utilized to remediate contaminated qround water and associated
NAPLs from other wood treating sites. Many of the processes listed
in this table have been eliminated from consideration for the
American Creosote site for the reasons that follow below based upon
an evaluation of information specific to the American Creosote
site.
Activated alumina adsorption, e1ectroch~ica1 reduction,
flocculation, high-pressure filtration, and ion exchange can be
eliminated because of the lack of metals in the contaminated qround
water at American Creosote. These treatment processes are only
effective on metal (inorganic) wastes, which are not present at the
American Creosote site.
Air flotation and air stripping can be removed from consideration
because of the lack of emulsified NAPLs and low concentrations of
..volatiles at the American Creosote site. Air -stripping is not
appropriate because the concentration of volatiles at the American
Creosote site are not present in significant concentrations, and as
such this process is not necessary. Air flotation is not
appropriate because the NAPLs at American Creosote are found in
separate layers (.i..:JL., floating or sinking products) in the
contaminated aquifer and are not homogeneously mixed within the
ground water. For this reason, air flotation is not consider~d a
viable alternative.
Hot water flushing would not be effective due to the heterogeneity
of subsurface materials at the American Creosote site. The
injection of hot water into the subsurface would not be uniformly
spread throughout the aquifer. While hot water can penetrate more
porous soil layers such as sands and gravels, it might not
penetrate the less porous soil layers such as clays and silts.
This could leave significant concentrations of contaminants in the
subsurface soils where the hot water is not as effective.
Additionally, this technology has not proven to be successful at
other wood treating sites having heterogeneous soils.
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ultraviolet/oxidation was eliminated from the list on Table 11.
Both ultraviolet/oxidation and activated carbon treatment are
equally effective at removing organic compounds and act as a
polishing step in the treatment process. However, lower
operational and maintenance costs associated with the use of
activated carbon make ultraviolet/oxidation treatment prohibitively
expensive. Although ultraviolet/oxidation is an effective means of
treatment for the wastes at the American Creosote site, the same
level of achievement of contaminant filtration can be achieved with
activated carbon at a reduced cost.
Therefore, for the reasons that follow, the remaining appropriate
alternatives listed in Table 11 for the remediation of the American
Creosote site ground water and NAPLs are activated carbon
adsorption, oil/water separation, and slurry wall/sheet pile
barrier. All of the treatment processes noted above involve an
extraction procedure that is detailed in the following sections.
7.2
DESCRIPTION OF VIABLE ALTERNATIVES
The remedial-technologies appropriate for the American creosote
site have been combined into remedial alternatives as required by
the NCP. The range of alternatives includes treatment that reduces
the toxicity, mobility, or volume of the contaminants as a
principal element and reduces the need for long term management.
An evaluation was also done of options that vary in the degree of
treatment employed and the amount of residual and untreated waste
that must be managed. In accordance with the NCP, the range of
alternatives also includes no action and alternatives which protect
human health and the environment with little or no treatment of the
wastes, such as institutional controls and containment.
The cost estimates presented in the following comparisons are based
on present worth analyses and are accurate to plus 50 percent and
minus 30 percent as established in EPA's Guidance for Conducting
Remedial Investigations and Feasibility studies Under CERCLA.
These costs will be refined substantially during the remaining
stages of the remedial process, which are the remedial desiqn and
remedial action phases. The operation and Maintenance (O&H) costs
presented in the following pages are based on a 30 year period,
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where actual durations may be more or less depending on future site
. conditions.
7.2.1
SO:IL/SLUDGE REMEDIAL ALTERNATIVES
As presented in section 5. 5 . 4 II Areal and vertical Extent of
. contamination" and shown on Fiqure 11, the total volume of
contaminated soil is estimated to be approximately 273,000 cubic
yards. Fiqure 11 was prepared using subsurface soil samples
containing more than approximately 10, 000 pg/kg total organic
compounds as the indicator cutoff for contamination. The largest
volume of contaminated soils is located in the former process area.
contaminated soils in this area occupy approximately five acres and
extend to a maximum identified depth of 40 feet. The following
analyses are based on the assumption that the total volume of
contaminated material on-si te potentially to be remediated is
273,000 cubic yards.
7.2.1.1
Alternative 1:
No Action
Capital Cost: $0
Annual operation and Maintenance: $25,000 -
Present Worth: $350,000
Implementation Time: Not Applicable
Under the No Action alternative for the contaminated surface areas
at the American Creosote site, no activities to address the risks
identified at the site would be implemented. However, some
sampling would occur to determine if contamination was spreading.
This alternative is being included as a baseline for evaluating
other al ternati ves. The long term risks would be above EPA I slower
target range of 1x10." for carcinogens.
7.2.1.2
Alternative 2 - :Institutional Controls
capital Cost: $150,000
Annual operation and Maintenance:
Present Worth: $500,000
Implementation Time: 6 months
$25,000
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This al~erna~ive would involve minor cons~ruc~ion ac~ivi~ies and
insti~utional controls to limit access to contaminated areas of the
site. Included in the alternative is repairinq and extendinq the
existinq fences and posting warninq signs around the contaminated
areas, placing deed notices on the property, and having the state
of Louisiana perpetually maintain the property.
contaminated material at the site would not be addressed by this
alternative. The risks would be somewhat lower than those of a
residential scenario as discussed in the Summary of Risks.
However, there would remain a potential for trespassers breaking
throuqh the fence and cominq into contact with contaminated surface
materials. The chances of someone installing a ground water well
at the, site would be reduced through maintenance activities, such
as site visits, performed by the State of Louisiana. However, the
contaminated ground water plume would remain uncontrolled and could
migrate both vertically and horizontally. The site would be re-
evaluated as required by the superfund law every five years to
ensure that the action taken remains protective of the human health
or welfare or the environment. Annual sampling would be conducted
of the surface materials as deemed appropriate. The 6 month
implementation period is based on improving and extending the
existing fence. .
7.2.1.3
Alternative 3 - MUlti-layered clay cap
capital Cost: $8 million
Annual Operation and Maintenance:
Present Worth: $13 million
Implementation Time: 2-3 years
$300,000
This alternative would involve the excavation of approximately
25,000 cubic yards of sludges from the tar mat area and its
consolidation with approximately 250,000 cubic yards of wastes from
the impoundment and process areas. The consolidated material would
likely require the addition of lime or cement as a sOlidifying
agent to support the placement of ~ mUlti-layered clay cap 'over the
. existing impoundment and process areas. The cap would consist of
an impermeable clay/membrane layer constructed in compliance with
Subtitle C of the Resource Conservation and Recovery Act (RCRA), 42
U.S.C. S 6901 et sea. The purpose of the cap would be to prevent
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the chances of direct contact with contaminated materials and to
reduce the volume of water which would contact contaminated soils.
The contaminated materials are not treated in this alternative.
Therefore, the only remaining risk would be that stemming for the
ground water contamination.
since contaminated soil would still remain in contact with ground
water, this alternative is protective only in conjunction with
ground water treatment/containment because the subsurface soils
would remain a source of contamination for the ground water.
Implementation of this alternative would result in possible air
emissions associated with excavation and solidifi~ation of
consolidated material. However, these possible emissions can be
adequately controlled during construction to ensure protection of
surrounding residents. The excavated areas would be backfilled
.with clean materials, upon which would be placed topsoil that would
be seeded.
7.2.1.4
Alternative 4 - Excavation, stabilization and On-Site
Disposal
capital Cost: $37 million
Annual operation and Maintenance:
Present Worth: $38 million
Implementation Time: 5 years
$100,000
'..\
"!
This alternative involves stabilization, which is a process
involving the addition of chemical stabilizing agents to
contaminated soil/sludge in order to reduce the mobility of the
hazardous constituents contained in the soil matrix. Mobility is
reduced through the chemical binding of hazardous materials into a
stable form with low permeability and reduced leachate generation
potential. The actual mechanism of binding, which depends on the
stabilization process type, can be categorized by the primary
fixation agent used. These can include cement-based, pozzolanic-
or silicate-based, thermoplastic-based, or organic polymer-based
agents and materials. Techniques may overlap because additives,
such as silicates, are frequently used in conjunction with the
fixation agent to control rate or to enhance properties of the
solid product.
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stabilization can be accomplished in both in-situ and ex-situ
methods depending on specific site characteristics. Due to the
high ground water. table at the American Creosote site, in-situ
stabilization would not be readily implementable. Therefore, ex-
situ stabilization was evaluated in detail. The equipment used for
ex-situ soil stabilization is similar to that used for cement
mixing and handling. It includes a feed system, mixing vessels and
a curing area. Numerous companies offer on-site chemical
stabilization services and provide expertise in selecting critical
parameters, including selection of stabilizing agents and other
additives, the waste-to-additive ratio, mixing, and curing
conditions.
The removal of contaminated soil/sludge can be accomplished by
excavation with conventional equipment such as backhoes, bulldozers
or dredges. Excavation of saturated material (below the water
table or near the creek bed), could require the use of dragline,
backhoe, or clamshell equipment, the dewatering of the subsurface
soils, or a combination of such equipment/methods. Dewatering
activities would require discharge of treated ground water in
compliance the Clean Water Act, 33 U.S.C. S 1251 ~ ug. Excavated
areas will also require restoration activities such as backfilling,
regrading, and planting a vegetative cover. Uncontaminated soils
from an on-site borrow area or from an off-site location may be
used as backfill. containment and treatment of water produced
during excavation may be required.
stabilization is well-demonstrated on inorganic wastes. However,
organic wastes have not been effectively treated in a consistent
manner. A treatability study has been conducted to determine the
effectiveness of stabilization on organic wastes from the American
creosote site. The results from this study have shown some
effectiveness but fell short of regulatory goals (~, less than
a 40% reduction in leachability was achieved versus a preliminary
goal of 90%). Based on this study, the potential would remain for
the soils to leach contaminants to the ground water. The leachate
concentrations would be above the MCL of O. 2 ~q/l as discussed
previously at Section 6.4 (Remediation Goals), and therefore the
ground water would remain a risk to human health. However, the
direct contact threat of the stabilized mass would be mitigated
with the placement of a vegetative cap.
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7.2.1.5
Alternative 5:
Excavation and On-site Incineration
Capital Cost: $185 million
Annual Operation and Maintenance:
Present Worth: $187 million
Implementation Time: 6 years
$100,000
This al ternati ve would involve the excavation of contaminated
soils, screening the large particles/rocks from the soil, and on-
si te thermal destruction in' a transportable incinerator.
Excavation could be conducted as noted for Alternative 4. A
variety of incinerators are commercially available and are capable
of aChieving the temperatures necessary to destroy the organic
compounds found in the soil. Incineration treatability studies as
presented in the administrative record were conducted to further
evaluate the feasibility of this alternative ,and the tests proved
the option to be quite successful. The ash from the incineration
treatability studies has proven to be below the previously
established remediation levels and would not pose a human health
threat. In addition, the remediation levels are at or below the
LDR treatment standards discussed at section 7.1 above. Finally,
because this option calls for excavation and - treatment of the
source of ground water contamination, a majority of the ground
water would also be remediated during the course of dewatering for
excavation of subsurface materials. In those areas where the
ground water plume is already outside the limits of contaminated
soils, the plume would be remediated by natural attenuation.
'.1
i
I
RCRA technical requirements for incinerators found at 40 CFR !i 264,
Subpart a and at 40 CFR S 270, would apply for on-site incineration
of contaminated soils. Those technical requirements include
operating, monitoring, maintaining and inspecting procedures for
the incinerator. The on-site facility would be operated to meet
the substantive technical regulatory standards for incinerator
performance set by the State and federal governments that relate to
air emissions, scrubber liquid treatment and discharge, and the
disposal of incinerator ash, all of which would be established
during trial burn stages. The concentrations of metals at the site
are insignificant and are not considered to represent an air
emissions concern. Ash meeting remediation levels, as previously
noted, from the incineration would be used to backfill the
106
':j
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excavated areas on-site and then will be covered with a vegetative
cap to minimize erosion of the material. However, pursuant to
CERCLA Section 121(e) (1), 42 U.S.C. 59621(e) (1), because the
incineration activities would occur entirely on-site, no State,
federal, or local permits are required, although all substantive
requirements as described above would be met.
The feasibility of transporting contaminated materials from the
site to an off-site incinerator was also evaluated as part of this
remedial alternative. The decision to use this approach is usually
based on the cost-effectiveness compared to the construction of an
on-site incinerator. Discussions with vendors indicated the
disposal costs at an off-site facility would be estimated on the
order of $0.65 per pound or approximatelY $2,000 per cubic yard.
Therefore, disposal at an off-si te incinerator, not including
excavation and transportation costs, would cost over $550 million
for approximately 275,000 cubic yards. This is approximately three
times that associated with on-site incineration.
7.2.1.6
Alternative 6: Partial Excavation and On-site
Incineration with In-situ Bioremediation
capitar Cost: $29 million
Annual Operation and Maintenance: $500,000
Present Worth: $40 million
:tmplementation Time: 30 years
Under this option approximately 25,000 cubic yards of contaminated
sludge from the tar mat area would be incinerated on-site as
discussed in Alternative 5, Excavation and On-site Incineration.
The remaining 250,000 cubic yards of subsurface soils in the
process and impoundment areas would be treated through in-si tu
bioremediation. This process would be a long-term remedial action
in which nutrients and oxygen would be inj ected into the subsurface
to promote biological degradation of PABs and PCP. This
alternative would also involve the removal and treatment of NAPLs
and contaminated ground water as discussed for Alternative C,
Active Treatment, as explained in the following pages.
Bioremediation is a process in which soil microorganisms chemically
degrade organic contaminants into carbon dioxide, water and
harmless cell protein. The reason for adding nutrients and oxygen
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is to promote the growth of microorganisms and increase the rate at
which the degradation of contaminations takes place wi thin the
subsurface. The basis for the combined approach of incineration
and bioremediation is that the tar mat area is a defined area of
highly contaminated materials that can be readily excavated and
treated and represents material that also may be too heavily
concentrated with PABs and PCP to be conducive to bioremediation.
Whereas, while the NAPLs in the subsurface of the process and
impoundment areas are also highly concentrated with PABs and PCP,
these materials can be removed as part of the pumping process
allowing in-situ bioremediation to be effective. One of the
primary concerns with this alternative is the equal dispersion of
nutrients and oxygen and thus the overall rate at which
bioremediation would occur. In the more porous zones (sands and
gravel) the biodegradation is anticipated to occur prior to the
zones of sil ts and clays. Therefore, it is.. expected that this
process will take several decades. During this time the NAPLs and
contaminated ground water would be extracted and treated as
outlined in Alternative C, and this action would ensure hydraulic
control to prevent enlargement of the contaminated plume.
.Ash meeting remediation levels, as previously. noted, from the
incineration of NAPLs and contaminated soils/sludge would be used
to backfill the excavated areas on-site and then would be covered
with a vegetative cap to minimize erosion of the material. The
process and impoundment areas in which in-situ bioremediation would
be implemented would also be covered by a vegetative cap. The best
time for placement of the cap in the impoundment and process areas
would be determined in the design phase of the Superfund process
and would be based on considerations that would optimize the
effectiveness of in-situ bioremediation. The reason this would be
determined during the design is that thorough analyses would be
conducted to determine if rainfall would be more conducive to
infiltration through existing soils or that a vegetative cover
would be more effective for in-situ bioremediation.
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7.2.1.7
Partial Excavation and Treatment Analysis
The treatment alternatives presented below provide three different
levels of cleanup based on excavation of the top 5 feet of gross
contamination, the top 10 feet of gross contamination, or all of
the gross contamination (down to a maximum depth of 40 feet).
These options provide sensitivity analyses for the volumes of
contaminated subsurface materials. The 5 foot excavation
represents 60,000 cubic yards of excavated material, the 10 foot
excavation represents approximately 110,000 cubic yards of
material, and the total gross contamination is estimated at 275,000
cubic yards of material. The rationale for these varying depths of
excavations is to evaluate the comparative reduction in volume of
contamination and the consequential reduction of probabili ty of
direct contact with the contaminated material.
The 5 feet of excavation would still leave approximately 80 percent
of the subsurface waste material, while the 10 foot excavation
would leave 60 percent of the waste volume. The alternatives for
partial excavation and treatment also represent an attempt to
remove the Old impoundment and tar mat areas and sumps-related to
the process area. However, alternatives that involve less than
full removal of subsurface contaminated soils would still leave a
ground water threat while removing the direct contact threat.
Alternative 4:
Excavation, Stabilization and On-site Disposal
4A - The top 5 feet of soils
4B - The top 10 feet of soils
4C - All contaminated soils
(60,000 cubic yards)
(110,000 cubic yards)
(275,000 cubic yards)
4A 4B 4C
capital Cost ($ millions): 12 19 37
Annual Operation and
Maintenance ($ millions): 0.3 0.3 0.1
Present Worth ($ millions): 16 23 38
Implementation Time (years): 4 5 5
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Alternative 5:
Excavation and On-site Incineration
5A - The top 5 feet of soi1s (60,000 cubic yards)
5B - The top 10 feet of soils (110,000 cubic yards)
5C - All contaminated soils (275,000 cubic yards)
5A 5B 5C
capital Cost ($ millions): 49 80 185
Annual Operation and
Maintenance ($ millions): 0.3 0.3 0.1
Present Worth ($ millions): 53 84 187
Implementation Time (years): 4 5 6
7.2.2
NAPLs AND GROUND WATER REMEDIAL ALTERNATIVES
'7.2.2.1
Alternative A - No Action
capital Cost: $0
~ual operation and Maintenance: $25,000
Present Worth: $350,000
Implementation Time: Not applicable
The No Action alternative does not include remedial action but
represents baseline conditions for comparison with other
alternatives. The pool of creosote and oils would remain as a
source of contaminant migration. Monitoring. would be conducted
periodically to assess the risks associated with contaminated
ground water. The long term risks would be above EPA's lower
target range of 1x10.4 for carcinogens and above a hazard quotient
greater than 1 for non-carcinogens. There would also be a chance
that the contaminated ground water plume would increase in size,
creating a larger area of contamination in the future.
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7.2.2.2
Alternative B - Institutional Controls
Capital Cost: $3,000
Annual Operation and Maintenance:
Present Worth: $350,000
Implementation Time: 6 months
$25,000
This alternative will include deed notices to inform future land
owners of subsurface ground water contamination and to notify
individuals on the property that no water wells should be placed in
the contaminated plume. In addition, periodic inspections would be
conducted to ensure that this is the case. As in Alternative A,
the liquid creosote and oils would remain as a source material for
future contamination and the risks from placing a water well would
be above 1X10.4 for carcinogens and above a hazard quotient 1 for
non-carcinogens. The chances of someone installing a ground water
well at the site would possibly be reduced due to site visits by
representatives of the state of Louisiana. However, the
contaminated ground water plume would remain uncontrolled and could
migrate both vertically and horizontally. The site would be re-o
evaluated as required by the superfund law every five years to
ensure that the action taken remains protective of the human health
or welfare or the environment. Annual sampling would be conducted
of the surface materials as deemed appropriate.
7.2.2.3
Alternative C - Active Treatment
Capital Cost: $2 million
Annual Operation and Maintenance:
Present Worth: $6 million
Implementation Time: 30 years
$250,000
This alternative involves extraction and treatment of pooled
product (NAPLs) and contaminated ground water. The primary
objective would be to capture as much pooled product and
contamination as possible while creating a hydraulic containment
barrier to prevent migration of contaminants into creosote Branch
and to impede enlargement of the ground water plume. This
alternative would also be conducive to an in-situ bioremediation
remedy to treat any contamination that is absorbed to subsurface
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soils. A combination of ground water cOllection/extraction options
could be used at the site, including extraction/pumping wells,
interceptor trenches, and subsurface drains. Ground water could be
treated to surface discharge levels established by the Clean Water
Act, 33 V.S.C. S 1251 et sea., and discharged to Creosote Creek.
Alternatively, ground water could be treated and reinjected into
the ground water to enhance recovery of the pooled liquid
contamination and/or to carry oxygen and nutrients for in-situ
bioremediation.
.
Pumping wells/hydraulic barriers can be used at a site in several
different manners to reduce the migration of contaminants from the
site. The primary goal of this alternative would involve the
removal of NAPLs and contaminated ground water for treatment,
followed by reinjection into the aquifer to provide nutrients for
in-situ bioremediation, or discharge to a surface water system.
The goal would be to remove the contaminated pooled product and
~ontaminated ground water in the upper aquifer down to
approximately 35 feet. Interceptor trenches and subsurface drains
can be used to intercept NAPLs and/or contaminated ground water and
transport it to the treatment area. Since trenches and drains
essentially function as a line of extraction - wells, they can
perform many of the same functions as wells. The decision to use
trenches and drains or wells is generally based upon site
hydrogeology, the depth of the water table, and cost-effectiveness,
which is dependent on the site conditions. CUrrent analysis of
geologic and hydrogeologic conditions indicates that a combination
of trenches and extraction wells will be the most effective ground
water collection method.
The extraction of contaminated ground water and NAPLs would include
a detailed analysis of the influence of the Creosote Branch on
extraction processes. If the Creek is found to significantly
affect the pumping of contaminated material by acting as a recharge
source of water to the aquifer, then a slurry wall may be
necessary. By acting as a barrier to prevent infiltration of
surface water into the ground water, the addition of a slurry wall
would reduce the costs associated with pumping and treatment of the
additional water. The details for a slurry wall are addressed in
Alternative D, containment. However, it should be understood that
the need for a slurry wall would be different than as shown in
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Alternative D because in this alternative the slurry wall would
only act as a barrier to prevent infiltration of surface water from
Creosote Branch. For Alternative C, only a partial slurry wall
along the creek would be utilized. The decision for the
installation of a slurry wall would be made during the Remedial
Desiqn phase of the project if this alternative is selected.
Treatment of contaminated ground water and NAPLs can be
accomplished by sedimentation and oil/water separation processes to
remove soluble and insoluble matter from ground water and NAPL
streams. Sedimentation is a purely physical process which uses
gravity to settle suspended particles from solution. Sedimentation
may be required to remove the small amount of silt-sized particles
that sometimes are removed during pumping operations. Oil/water
separation is a process which separates free and/or emulsified oils
from water. Once separated, the 01ls from this process would be
incinerated on-site or transported off-site in accordance with RCRA
hazardous waste transportation requirements found at 40 CFR Part
263 and incinerated off-site at a RCRA hazardous waste facility
deemed acceptable pursuant to the Superfund Off-site Policy
promulgated pursuant to CERCLA section 121(d) (3), 42 U.S.C. S
9621(d) (3). -
Following sedimentation and oil/water separation, the water can be
filtered by a sand filter and run through an activated carbon
treatment unit. Activated carbon adsorption is a technology proven
effective for the treatment of waters containing adsorbable
organics compounds. Once the activated carbon filters have been
used to capacity, they would be transported off-site in accordance
with RCRA hazardous waste transportation requirements found at 40
CFR Part 263 and disposed of at a RCRA hazardous waste facility
deemed acceptable pursuant to the Superfund Off-site Policy
promulgated pursuant to CERCLA Section 121(d) (3), 42 U.S.C.
S 9621(d) (3).
The equipment and technology required to implement this alternative
are readily available. Following on-site treatment, ground water
can be either directly discharged to a surface water area or
reinjected on site. Surface water discharge of treated ground
water would involve discharge to the Creosote Branch. Discharge
limitations for this option would be established under applicable
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federal and state regulations concerning the Clean Water Act, 33
U.S.C. S 1251 ~ ~.
The goal of this ground water al ternati ve is to remove as much of
the source of shallow ground water contaminants as possible.
However, without treatment of the contaminants from the subsurface
soils there will always be the potential for contamination
remaining in the ground water, even if all NAPLs were removed by
pumping. Therefore, to avoid continued ground remediation it would
be necessary to treat the subsurface soils by in-situ
bioremediation or by complete removal of the soils and
incineration. The goal for remediation of the ground water is to
reduce the B(a)P equivalents below a concentration of 0.2 ~g/l,.
which is the maximum contaminant level (MCL) for PABs, and benzene
below a concentration of 5 II-g/l which is the MCL for this compound.
Based on information obtained during the reme.dial investigation,
and the analysis of other ground water remedial alternatives
employed at other wood treating Superfund sites, this remedial
alternative may not achieve this low a goal. The ability to
achieve cleanup levels cannot be determined until the extraction
.and monitorinq system has been implemented.
7.2.2.4
Alternative D - Containment
Capital Cost: $3 million
Annual Operation and Maintenance:
Present Worth: $5 million
Implementation Time: 2-3 years
$200,000
This alternative provides a containment option for site ground
water. Although contamination would still remain at the site,
contaminant migration would be controlled by constructing a barrier
(slurry wall or similar-type structure), both upgradient and
downgradient of the site. Placement of a slurry wall set back from
the edges of Creosote Creek would seek to encompass as much of the
dense liquids and grossly contaminated subsurface soils of the
process areas as possible.. In addition, this alternative would
include some ground water pumping and treatment in order to
maintain an inward flow gradient. The NAPLs and contaminated
ground water would be treated as presented in Alternative C.
However, this gradient pumping and treatment would not treat liquid
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contaminants to the extent proposed in Al ternati ve c. Water from
this alternative would be treated as specified for Alternative C,
Active Treatment.
Isolation technologies that have potential for use at the site to
control contaminant migration include grout curtains, sheet piling,
and slurry trench/walls. An important consideration for any of the
ground water isolation options is the depth to bedrock, or
aquitard. current evaluation of site conditions indicate that an
acceptable aquitard is present within the upper 70 feet of the
surface and this is wi thin the limits of conventional equipment for
implementation of this alternative. Of these alternatives, slurry
walls are expected to be the optimal choice for this site. Grout
curtains are generally more costly and have higher permeabilities
than slurry walls, and are seldom used for containing ground water
flow in unconsolidated materials. Sheetpiling was eliminated from
consideration because of uncertainties with wall integrity over
extended periods of time and potential damage to or deflection of
the piles by rocks during installation.
Slurry trench/walls apply the concept of lateral encapsulation (or
vertical barriers) to provide a relatively impermeable barrier
around impacted soil or ground water to divert ground water flow
around the impacted areas and/or prevent impacted ground water from
migrating. Slurry trench/walls are constructed in a vertical
trench that is excavated under a slurry. The slurry performs in a
similar way to drilling fluid in that it hydraulically shores the
trench to prevent collapse while forming a cake on the trench wall
to reduce fluid losses to the subsurface soil. The most common
types of slurry wall materials include soil-bentonite and cement-
bentonite.
115
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8.0
..
11 -.
SUMMARY OF COMPARATrvE ANALYS:IS OF ALTERNATrvES
EPA uses nine criteria to evaluate the merits of Superfund
remedies. The first two assessments that are directly related to
statutory determinations are:
1)
2)
OVerall protection of human health and the environment, and
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARS) of other Federal and State environmental
statutes.
:If a remedial alternative does not meet the first two criteria it
is not carried over for further analysis. If it meets the first
two criteria, it is then reviewed against five additional measures
which are identified as balancing criteria:
3)
4)
Long-term effectiveness and permanence,
Reduction of contaminant toxicity, mobility, or volume through
treatment,
s~ort-term effectiveness,
:Implementability, and
Cost, including capital and operation and maintenance cost.
5)
6)
7)
The final two criteria are mOdifying criteria and are evaluated
following the public comment period on the R:I/FS Report and the
Proposed Plan:
8)
9)
state Acceptance, and
Community Acceptance.
8.1.
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
OVerall protection of human health and the environment addresses
whether each alternative provides adequate protection of human
health and the environment and describes how risks posed through
each exposure pathway are eliminated, reduced, or controlled
through treatment, engineering controls, and/or institutional
controls.
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.~....,:~. : "':
All of the alternatives, with the exception of the "No Action" and
"Institutional Control" alternatives, would provide protection of
human health and the environment by eliminating, reducing, or
controlling risks through treatment or engineering controls.
A combination of Alternatives 6 and C, Partial Excavation and On-
site Incineration with In-situ Bioremediation and Active Treatment,
or the selection of Alternative 5, Excavation and Incineration,
would provide the greatest degree of overall protection to human
health and the environment. Alternative 5, Excavation and On-Site
Incineration would completely destroy the contaminants and
eliminate direct contact threats and the source of contaminated
ground water. Partial Excavation and On-site Incineration with In-
situ Bioremediation, Alternative 6, in conjunction with Alternative
C, Active Treatment, actively treats all identified wastes.
However, based on other sites utilizing bioremediation, the degree
of contaminant reduction is potentially less than full scale
incineration but would remain protective.
Alternative C, Active Treatment, provides active measures that
would be taken to treat the primary threats from creosote and PCP
liquids and contaminated ground water. This alternative by itself
would not treat the absorbed contamination to the subsurface soil
particles. Therefore, it is necessary to combine this option with
an additional soil treatment alternative to be totally effective.
contaminated pooled product and ground water would be extracted and
treated to the maximum extent practicable and the treated water
would be reinjected with nutrients and oxygen to reduce subsurface
contamination through biodegradation. Any treated water to be
discharged into surface water will meet the water discharge
standards as established under the Clean Water Act 33 U.S.C. 1251
et sea., and found at 40 CFR Part 414. The extraction process
would minimize the migration of contaminated ground water off-site.
oils (MAPLs) recovered from the treatment process would be
incinerated either on-site or off-site at a RCRA hazardous waste
facility deemed acceptable under the Superfund Off-Site POlicy
promulgated pursuant to CERCLA S.ection 121(d) (3), 42 U.S.C. i
'9621 (d) (3) .
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The stabilization alternative, Alternative 4, was initially
expected to provide overall protection above the levels provided by
the capping alternative, Alternative 3. However, treatability
studies have shown stabilization technology to be questionable due
to the oily nature of the waste materials, as presented in the
discussion of this alternative. The potential of stabilized soils
to leach organic contaminants to the ground water would remain,
although the ability of those contaminants to leach would be less
than currently exists. The technology would not sufficiently
stabilize the contaminated material to be considered a permanent
remedy and, therefore, would require NAPL and ground water actions
such as Alternatives C or D.
Consolidation and Multi-Layered cappin9 (Alternative 3) provides
protection by employing measures to isolate contaminants from human
contact and the environment. It is also compatible with options C
and D for the contaminated liquids alternatives. The cap would
reduce the infiltration of surface water and would have to be
maintained on an indefinite basis. Capping, and containment or
.active treatment, do nothing to treat the subsurface soils that act
as a source of ground water contamination. Therefore, this remedy
does not provide as much protection to human health or the
environment as the previously discussed alternatives.
;1
~i
containment, Alternative D, would provide moderate human health and
environmental protection in conjunction with the capping
alternative for soil remediation. contaminated ground water would
be contained by a slurry wall and minimal pump and treat operations
would be conducted indefinitely. However, this alternative is not
expected to provide as much overall protection to human health and
the environment as that of Alternative C, Active Treatment, because
the remaining contamination has the potential to migrate through
the containment wall.
The No Action and the Institutional Control alternatives for both
liquids and soils do not provide overall protection to human
health, welfare, or the environment. As documented in the RI,
contamination is currently continuing to seep from the site into
Creosote Branch, and as such remains a environmental threat. The
tar mat area contains surface contamination that is above health-
based levels and, therefore, warrants action. The institutional
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controls alternative, Alternative B, would not prevent the seepage
of contaminated materials into Creosote Branch, but would only
provide minimal controls against trespassing and future development
in the area. The potential would remain for contaminants to spread
into the ground water and to disperse surface contamination during
flood or rainfall events.
In summary, the no action and institutional controls alternatives
for both liquids and surface materials in the tar mat area do not
protect human health, welfare, or the environment. These
alternatives are not considered appropriate for this site and as
such are not discussed further for the other eight criteria.
8.2
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARS)
Compliance with ARARs addresses whether a remedy will meet all the
applicable or relevant and appropriate requirements of other
Federal and state environmental statutes or provides a basis for
invoking a waiver. Identified ARARs for this project include
provisions of the Clean Water Act, 33 U.S.C. i 1251 gt sea., the
Resource Conservation and Recovery Act, 42 U.S.C. i 6901 gt sea.,
the Safe Drinking Water Act, 33 U.S.C. i 300f et seq., and the
Clean Air Act, 42 U.S.C. i 7401 et sea. All ARARs can be met for
all alternatives and a detailed discussion of ARARs for the
selected remedy is presented in following sections.
8.3
LONG-TERM EFFECTIVENESS AND PERMANENCE
Long term effectiveness and permanence refers to expected residual
risk and the ability of a remedy to maintain reliable protection of
human health and the environment over time, once cleanup levels
have been met. This criterion includes the consideration of
residual risk and the adequacy and reliability of controls.
The alternative remedies for the soils/sludges decrease in
effectiveness as one reviews the options ranging from incineration
to a combination incineration/bioremediation to stabilization and
finally capping. The incineration alternative provides long term
effectiveness by destroying the organic contaminants. A
combination of Alternatives 6 and C, Partial Excavation and On-site
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.'
Incineration with In-situ Bioremediation and Active Treatment,
would offer the second best option with regard to long term
effectiveness. The primary difference between incineration and
bioremediation is that the bioremediation al ternati ve is
anticipated to take approximately 5 times as long as incineration
and may not ultimately achieve as much contamination reduction as
that of incineration. However, it is believed that through long
term treatment the contamination can be reduced to acceptable
concentrations to provide long term protection.
0'
.,
ii
Although the stabilization alternative, Alternative 4, may involve
some chemical fixation of the contaminants, the fixation of wastes
with high concentrations of organic compounds, such as those found
at American Creosote, have not been demonstrated to be effective as
documented by treatability studies and as experienced at other wood
treating Superfund sites. The multi-layer clay cap, Alternative 3,
would address the moderately contaminated surface and subsurface
-..soils, but the soils would remain as a potential source of ground
water contamination. Thus, multi-layer capping is only effective
as long as a continuous ground water control mechanism is in place
.and th~ cap is maintained.
The active treatment alternative for contaminated liquids
(Alternative C) would employ proven technologies for extraction and
treatment of contaminated ground water. However, the contaminated
liquids and ground water pump and treatment system is not
technologically capable of completely removing subsurface
contamination, and so some residual contamination will remain
unless it is combined with a treatment alternative. Contaminants
would be removed to the maximum extent practicable, resulting in
the permanent treatment of the extracted contaminants and the
minimization of the potential migration of contaminants to drinking
water zones below the contaminated aquifer. Alternative D,
containment, is believed to be less effective in the long term than
active treatment because contaminants might eventually migrate
through the barrier into the ground water. .
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8.4
REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH TREATMENT
Reduction of toxicity, mobility, or volume through treatment refers
to the anticipated performance of the treatment technologies a
remedy may employ.
The incineration alternative (Alternative 5) would reduce the
toxicity, mobility, and volume of excavated contaminated material
through the permanent destruction of the organics. Treatability
tests have shown that the incineration ash would be below the
remediation levels established in the Summary of 8i te Risks section
of this ROD. The combination of Incineration with In-situ
Bioremediation (Alternative 6) in conjunction with Active Treatment
(Alternative C) would also reduce mobility, volume and toxicity,
although to a lesser degree than full scale incineration, but it
would still remain protective. It is believed that the reduction
of mobility and volume of contamination for a combination of
Alternatives C and 6 would be comparable to that of full scale
incineration (Alternative 5). However, the reduction of toxicity
is anticipated to be somewhat higher for Alternative 5 than the
aforementioned combination of Alternatives C and 6.
The stabilization alternative (Alternative 4) would reduce the
mobility somewhat (i.e., approximately 40. as determined by
leachability tests), although the potential remains for future
leaching of contaminants into the ground water. For surface and
subsurface soils the capping alternative (Alternative 3) would not
involve any treatment.
Under the active treatment alternative (Alternative C) the
contaminated liquids and ground water would be extracted and
treated. The contaminated oils from this process would be
ultimately destroyed at an acceptable on-site or off-site
incinerator, thereby significantly reducing toxicity, mobility and
volume. The ground water containment alternative (Alternative D)
would reduce mobility of the contaminants through containment.
However, this reduction is not through treatment. In addition,
toxicity and volume would not be reduced for Alternative D.
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8.5
SHORT TERM EFFECTIVENESS
Short term effectiveness refers to the period of time needed to
complete the remedy and address any adverse impacts on human health
and the environment that may be posed during the construction and
implementation of the remedy until cleanup levels are achieved.
Alternative 6, Partial Excavation and Incineration with In-situ
Bioremediation, in conjunction with Alternative C, Active
Treatment, is anticipated to take approximately 30 years.
Alternatives 3 and 4, MUlti-Layered Capping and stabilization,
could be constructed wi thin 4 years. However, as. discussed
previously, these alternatives would have to be conducted in
conjunction with ground water alternatives C or D, active treatment
or containment, which could involve continuous operation and
maintenance (O&M) for 30 years or more. The incineration option
could be completed within 6 years of implementation.
Precautions would be taken in all alternatives involving site
activities to eliminate any risk to the public and site workers.
During the implementation of any ground water, source treatment, or
capping alternative, there would be potential short term risks to
site workers during consolidation and treatment of the contaminated
material. Some increase in air emissions may occur as a result of
excavation during any of the soil/sludge alternatives. However,
engineering controls and air monitoring will reduce the potential
for any adverse impacts during implementation of the remedy. A
contingency plan would be developed to address any potential air
emissions detected during remedial activities.
8.6
IMPLEMENTABILITY
Implementability addresses the ease with which a potential remedy
can be put in place. Factors such as availability of materials and
services and administrative feasibility are considered.
All alternatives have been considered imp 1 ementab le and
administratively feasible, and the materials and services needed
for all proposed alternatives are readily available. The
construction of a multi-layered clay cap over the contaminated
material would be easily implemented. Increased difficulty would
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result from implementing the bioremediation, incineration and
stabilization alternatives as compared with capping, although all
these alternatives can be implemented. The excavation, dewatering
and incineration process would require more specialized equipment
than that for capping. However, this equipment is readily
available in the construction industry. Ground water alternatives
are also easily implemented, although the construction of a slurry
wall would be more difficult than that of a pump and treatment
system.
8.7
COST
The estimated costs are presented in the previous pages and range
from $16 million for a capping alternative to $187 million for an
incineration alternative. The stabilization and incineration
alternatives present options on the amount of treatment of the
contaminated materials and provides options as to the volume of
material to be treated. However, anything less than full
excavation still requires the control or treatment of subsurface
areas to prevent continued contaminant migration. The cost for
active liquid treatment ($6 million) is approximately equal to that
of the cont~inment option ($5 million), with the advantage of the
active liquid treatment option being that it provides actual
treatment and reduction of the human health and environmental
risks. It is believed that the combination of Alternatives 6 and
C meet the same overall goals as that of Alternative 5, full scale
incineration, at a quarter of the cost ($40 million instead of $187
million)
8.8
STATE ACCEPTANCE
The final proposed plan was a joint release by EPA and LDEQ and as
such it reflects LDEQ's views on the selected remedy as outlined
below. For this project LDEQ must contribute 10 percent of the
remedy construction costs and formally concur with the deletion of
the site from the National Priorities List upon completion of the
remediation process.
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8.9
COMMUNITY ACCEPTANCE
EPA recognizes that the community in which a Superfund site is
located is the principal beneficiary of all remedial actions
undertaken. EPA also recognizes that it is its responsibility to
inform interested citizens of the nature of Superfund environmental
problems and solutions, and to learn from the community what its
desires are regarding these sites.
During the 90 days provided for public comment on this site, the
community was requested to comment on proposed remedies which
included a Multi-layered Clay Cap and Active Treatment,
Alternatives 3 and C, fUll-scale incineration, Alternative 5, and
Partial excavation and On-site Incineration in conjunction with
Active Treatment, Alternatives 6 and C. During the public meeting
of september 15, 1992, the city council, mayor and over 50
individuals from the local area responded. to EPA's proposed
alternatives to remediate the site. The number of people at this
meeting was significantly greater than the August 3, 1992, meeting
that was attended only by 4 individuals. Based on the comments
from both meetings, the local community strongly favors a treatment
alternative and strongly opposes any no action or institutional
control alternative. During these meetings no individuals
indicated any opposition to on-site incineration. The community
favors full scale incineration at a cost of approximately $187
million. However, based on comments received during the comment
period, bioremediation may also meet the community's goals at a
substantial savings to the state and Federal Governments.
9.0
THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the
detailed analysis of alternatives using the nine criteria, and
public comments, both EPA and the state. of Louisiana have
determined that Alternative 6, Partial Excavation and On-site
Incineration with In-situ Bioremediation, in conjunction with
Alternative C, Active Treatment, is the most appropriate remedy for
the American Creosote site in winnfield, Louisiana. This
alternative will address the NAPLs and the subsurface source of
ground water contamination and any significant threats from direct
contact of surface contamination.
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The surface soils in the area between the tar mat and Creosote
Branch are not being removed as part of this remedy because of the
potential effects on wetlands. The maximum concentration of B(a)P
equivalents in this area is 7,500 ~g/kg. This concentration is
still below the lxlO.4 goal for remediation and is near the
remediation goal of 3,000 ~g/kg for the other soils. These soils
are not considered a significant threat to ground water or to human
health because of direct contact. Furthermore, if the soils
between the tar mat and Creosote Branch were removed the existing
wetlands would be drastically damaged.
Approximately 25,000 cubic yards of creosote- and PCP- contaminated
sludges will be excavated from the tar mat area. The organic
contaminants will be incinerated on-site and the treated soils will
then be returned to the excavated areas, which will be regraded,
capped, and revegetated. The removal and treatment of the tar mat
materials will allow the function of the wetland to recover in this
distressed area. The remaining 250,000 cubic yards of subsurface
soils in the process and impoundment areas would be treated through
in-situ bioremediation. This process would be a long-term remedial.
action in which nutrients and oxygen would be injected into the
subsurface to promote biological degradation of PAHs and" PCP. This
alternative would also involve the removal and treatment of NAPLs
and contaminated ground water by pumping and treatment. The
estimated cost for this component of the remedy is: capital costs
- $29 million, annual O&M costs - $500,000 , and present worth -
$40 million.
9.1
SENSITIVITY ANALYSIS FOR SELECTED REMEDY
As part of this study, in an effort to more accurately assess the
viability of this remedial action in light of potential waste
volume increases during actual remediation, a sensitivity analysis
was conducted. The intent of this analysis was to determine if
unexpected volume increases would adversely impact the selection of
this particular alternative. (Waste volume was determined to be the
most critical factor affecting cost.)
The evaluation revealed that even if the volume of contaminated
sludge to be incinerated was to double, from 25,000 to 50,000 cubic
yards, the cost for this remedy would only increase to
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approximately $45 million which is well within the range of plus 50
percent for the cost estimate presented in this Record of Decision.
This unanticipated increase would, therefore, not adversely affect
the remedy selection decision.
since the majority of the remedial action involves insitu
bioremediation, and the extent of the area needing treatment is
well defined, volume increases are not expected to impact this
aspect of the cleanup. Also, another advantage of insitu remedial
technologies is that they are generally less susceptible to cost
increases due to changing site conditions such as extensive buried
debris, etc.
9.2
CLEANUP LEVELS
9.2.1
SOILS/SLUDGES
The tar mat area will be removed and incinerated on-site to
eliminate a major potential source for direct contact and a
potential source of surface and ground water contamination. The
residual contamination within the process and impoundment areas
will be remediated through the use of in-situ bioremediation.
During excavation and incineration of the tar mat areas any sludges
within the tar mat area that contain greater than 3,000 ~g/kg for
B(a)P equivalents and/or greater than 50,000 ~g/kg for PCP will be
removed. The soils between the tar mat area and the Creosote
Branch will not be excavated as outlined previously.
The rationale for selection of a lx10.5 (3, 000 ~g/kg for B(a) P
equivalents and 50,000 ~g/kg for PCP) as opposed to the point of
departure stated under the National contingency Plan (lX10's) is
based on technological implementability and cost. EPA determined
that if the 1X10.e point of departure goal was strictly adhered to
at this site all technologies would be precluded from consideration
except for incineration. This was not considered reasonable since
alternatives were available that could treat to the National
contingency Plan risk level.of lxlO.4 to lX10.e, which according to
EPA is protective.
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EPA has found that bioremediation would not achieve the same level
of destruction as incineration, however, by using a 10.5 cleanup
level it was found to be technological achievable at a
substantially lower cost. From a cost basis, bioremediation offers
a substantial cost savings of approximately $150 million as
compared to full scale incineration while achieving a cleanup goal
within the allowable risk range of 1x10-4 to 1x10.8. However, this
does not preclude the use of incineration for the tar mat area as
previously detailed because this material is not appropriate for
bioremediation.
The health-based criteria for the incinerator ash are established
as having the following maximum concentrations for the following
compounds, if'present:
Naphthalene ---------------------- 1,500
Pentachlorophenol ----------------------- 7,400
Pyrene ----------------------- 1,500
Toluene ---------------------- 1,500
Xylenes ---------------------- 28,000
Lead ---------------------- 33,000
Dioxins and furans as 2;3,7,8 TCDD ---------- 1
B(a)p equivalents ----------------------- 3,000
",g/kg
",g/kg
",g/kg
",g/kg
",g/kg
",g/kg
",g/kg
",g/kg
The remediation goals for the subsurface soils that are to be
addressed through in-situ bioremediation are B(a)p concentrations
of less than 3,000 ~g/kq and PCP concentrations less than 50,000
",q/kq. A waiver of these provisions will be considered during the
remedial action if the goals for ground water are achieved as
documented in the following pages.
The selected remedy will include ecological monitorinq for an
estimated period of 5 to 10 years after implementation of the
remedial acti vi ties. The extent of ecological studies will be
determined as part of the Remedial Design efforts and will include
evaluation of wetlands and streams as EPA and LDEQ consider
appropriate.
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9.2.2
GROtJND WATER
The goal of the incineration and in-situ bioremediation phases as
previously described is to remove the source of shallow qround
water contaminants so as to reduce and/or eliminate the potential
threat of contamination impacting deeper drinking water aquifers
and, if technologically achievable, to restore the shallow qround
water to a potential future beneficial use.
The soils in the area between the tar mat and Creosote Branch are
not being removed as part of this remedy. These soils are not
considered a significant threat to ground water and involve an area
defined as a wetlands. The wetlands would be destroyed if these
soils were excavated and as discussed in the Summary of site Risks
section of this ROD the soils are within the EPA's acceptable risk
range. Removal of the source of contamination from the tar mat
area and in-situ bioremediation of the process and impoundment
areas will allow the restoration of the ground water. A
remediation goa1 of 0.2 micrograms per liter (~g/1) for
benzo"(a)pyrene and 5 micrograms per liter (~g/lr for benzene will
be utilized for the shallow ground water in this area. The ability
to achieve cleanup goals at all points throughout the area of
attainment, or plume, cannot be determined until the monitoring
system has been implemented, or modified as necessary based on
engineering design changes.
If the. selected remedy cannot meet the health-based remediation
goals, at any or all of the monitoring points during
implementation, contingency measures and goals as discussed below
may replace the selected remedy and goals. These measures are
still considered to be protective of human health and the
environment, and are technically practicable under the
corresponding circumstances.
The selected remedy will include ground water monitoring for an
estimated period of 5-10 years after completion of on-site remedial
activities, during which time the effectiveness of source
destruction will be carefully monitored on a regular basis. Once
this system has been operating for a 5-10 year period, then an
-------
evaluation of the need for additional pumping and treating will be
conducted. Based on this evaluation the operating system may
include:
a)
discontinuing operation of extraction wells in the area where
cleanup goals have been attained:
b)
alternating pumping at wells to eliminate stagnation points:
and
c)
pulse pumping to allow aquifer equilibration and encourage
adsorbed contaminants to partition into ground water.
d)
other items as necessary to achieve goals of this ROD.
. .
If, in EPA's and LDEQ's judgment, implementation of the selected
remedy clearly demonstrates, in corroboration with strong
hydrogeoloqical and chemical evidence, that it will be technically
impracticable to achieve and maintain remediation goals throughout
the area of attainment, the contingency plan will be implemented.
At a mi~imum, and as a necessary condition for invoking the
contingency plan, it must be demonstrated that contaminant levels
have ceased to decline over time and are remaining constant at some
statistically significant level above remediation goals, in a
discrete portion of the area of attainment, as verified by multiple
monitoring wells.
Where such a contingency situation arises, ground water extraction
and treatment would typically continue as necessary to achieve mass
reduction and remediation goals throughout the rest of the area
attainment.
If it is determined, on the basis of the preceding criteria and the
system performance data, that certain portions of the aquifer
cannot be restored to their beneficial use, all of the following
measures involving long term .management may occur, for an
indefinite period of time, as a modification of the existing
system:
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a)
low level pumping will be implemented as a long-term
gradient control, or containment, measure 1
b)
chemical-specific ARARs will be waived for the cleanup of
those portions of the aquifer based on the technical
impracticability of achieving further contaminant reduction1
and/or
c)
institutional controls will be implemented to restrict access
to those portions of the aquifer which remain above health-
based goals, should this aquifer be proposed for use as a
drinking water source.
The decisions to invoke any or all of these measures may be made
during periodic reviews of the remedial action.
An Explanation of Significant Differences will be issued to inform
the public of the details of these actions should they occur.
10.0
STATUTORY DETERMINATIONS
Under CERCLA Section 121, 42 U.S.C. i 9621, EPA must select
remedies that are protective of human health and the environment,
comply with Applicable or Relevant and Appropriate Requirements
(ARARs), (unless a statutory waiver is justified), are
cost-effective, and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. In addition, CERCLA includes a
preference for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of hazardous
wastes as their principal element. The following sections discuss
how the selected remedy meets these statutory requirements.
10.1
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
{!
}1
The selected remedy protects human health and the environment
through incineration of heavily-contaminated creosote and
pentachlorophenol sludges and in-situ bioremediation of less
contaminated subsurface soils. Incineration and in-situ
bioremediation of the sludges and soils in conjunction with active
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treatment of contaminated NAPLs and ground water will eliminate a
major source and continual threat of ground water contamination.
The current cancer risk associated with these soils is. 3. 8x10.4,
while the ground water cancer risk is 7.5xlO.2. By excavating the
heavily-contaminated sludges and treating them in an incinerator,
and by applying in-situ bioremediation of the contaminated
subsurface soils the source of ground water contamination will be
significantly reduced to within EPA's acceptable risk range of 10.4
to 10.8. There are no short term threats associated with the
selected remedy that cannot be readily controlled. In addition, no
adverse cross-media impacts are expected from the remedy.
10.2
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARS)
The selected remedy of excavation and on site incineration will
comply with all applicable or relevant and appropriate requirements
(ARARs). The ARARs are presented below:
Chemical-Specific ARARs:
Safe Drinking Water Act Maximum Contaminant Levels (HCLa)
(40 CFR Part 141)
Clean Water Act Federal Water Quality criteria (FWQC)
(40 CFR Part 414)
Safe Drinking Water Act Maximum contaminant Level (MCL) of
5 ~g/l for benzene - 40 CFR Part 141
Location-Specific ARARs:
Clean Water Act Section 404
(Wetland Protection)
'0.
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-c ",;.
...
.,
t 0
Action-specific ARARs:
40 CFR Part 264 standards for Owners and Operators of
Hazardous Waste Treatment, storage, and Disposal Facilities.
In particular subparts B, C, D, G,I,J,K,L,O,AA, and BB may be
relevant and appropriate during construction operations.
Clean Water Act for NPDES Discharges - 40 CFR Part 122
and 40 CFR Part 414 for discharges of organic chemicals.
Other criteria, Advisories, or Guidance To Be Considered (TBCs) for
This Remedial Action:
EPA and the state will determine the need to file a deed
notice advising of site hazards
E.O. 11990, Protection of Wetlands, which requires that
Federal agencies conduct an evaluation to assess the impacts
of an action on wetlands
Clean Air Act National Emission standards for Hazardous Air
pollutants (NESHAPS) - 40 CFR Part 61
.0
Clean Air Act National Ambient Air Quality standards (NAAQS) -
40 CPR Part 50
RCRA Land Disposal Restrictions (LDRs) - 40 CPR Part 268 for
U-051 wastes (Creosote)
10.3
COST EFFECTIVENESS
EPA believes this remedy will eliminate the risks to human health
at an estimated cost of $40 million. Therefore, the selected
remedy provides an overall effectiveness proportionate to its
costs, such that it represents a reasonable value for the money
that will be spent. The selected remedy assures a much higher
degree of certainty that the remedy will be effective in the long
. term because of the significant reduction of the toxicity and
mobility of the wastes achieved through the incineration, in-situ
bioremediation and active treatment components.
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10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES (OR RESOURCE RECOVERY TECHNOLOGIES) TO THE
MAXDmM EXTENT PRACTICABLE
EPA and the state of Louisiana have determined that the'selected
remedy represents the maximum extent to which permanent solutions
and treatment technologies can be utilized in a cost effective
manner for the final remedy at the American Creosote site. Of
those alternatives that are protective of human health and the
environment and that comply with ARARs, EPA and the state have
determined that the selected remedy provides the best balance of
trade-offs in terms of long term effectiveness and permanence,
reduction in toxicity, mobility, or volume achieved through
treatment, short term effectiveness, implementability, and
cost, while also considering the statutory preference for treatment
as a principal element and considering State and community
acceptance.
The selected remedy treats the principal threats posed by the
sludges, soils and ground water through achieving significant
creosote and pentachlorophenol reductions. This remedy provides
the most effective treatment of the alternatives considered,
utilizes innovative treatment alternatives were appropriate, and
will cost less than off-site disposal. The selection of treatment
of the contaminated sludges and soils is consistent with program
expectations that indicate that highly toxic and mobile wastes are
a priority for treatment and whose elimination is often necessary
to ensure the long term effectiveness of a remedy.
10.5
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
By treating the contaminated ground water onsite, by utilizing in-
situ bioremediation of the absorbed subsurface contamination, and
treating the heavily contaminated sludges by incineration, the
selected remedy addresses the principal threats posed by the site
through the use of treatment technologies. By utilizing treatment
as a significant portion of the remedy, the statutory preference
for remedies that employ treatment as a principal element is
satisfied.
-------
11.0
DOCUMEN'l'ATION OJ' SIGmFICAN'l' CHANGES
A Proposed Plan was released for public comments on July, 29, 1992.
The Proposed Plan identified Alternatives 3, RCRA Compliant capping
and C, Active Treatment of Contaminated Ground Water and Liquids
(wood treating fluids) as the proposed remedy for the American
Creosote site. On August 3, 1992, EPA held a public meeting with
transcripts taken and subsequently added to the Administrative
Record. The public meeting was attended by representatives from
LDEQ and Louisiana's Office of Public Health.
Subsequent evaluations within EPA and discussions with the state
and the community (based on the AUgust 3, 1992, public meeting)
revealed that incineration of the wastes may be more effective in
meeting goals to remediate the site. On August 26, 1992, EPA
received a written request from the Mayor of Winnfield requesting
an extension to the comment period and an additional meeting. The
public comment period was subsequently extended for an additional
30 days and a second public meeting was held on september 15, 1992.
Due to this reassessment of preferred remedial alternativ~s, EPA
issued- a public notice in the local Wlnnfleld newspaper, which
published articles about the possible use of on-site incineration
in early september, 1992.
During the public meeting of september 15, 1992, the city council
and mayor, and over 50 individuals from the winnfie1d area,
responded to EPA's proposed alternatives to remediate the site.
The number of people at this meeting was significantly greater than
the previous one that was attended only by 4 individuals. Based on
the comments from both meetings, the local community favored on-
site incineration at a cost of $187 million.
In response to comments received during the public comment period
of July 29 to September 29, 1992, continuing discussions within EPA
between technical and managerial personnel, and ongoing discussions
between EPA and LDEQ, it was determined that further consideration
of bioremediation was necessary. On March 1, 1993, LDEQ and EPA
issued a final proposed plan based on an extensive review of all
the comments received during the previous comment period and an
additional review of the state of technologies being used to
remediate wood treating sites.
i\
:n
:1:
-------
The final proposed plan for the American Creosote site combined
elements of remedies previously proposed and added in-situ
bioloqical treatment for the bulk of the buried contaminated soils.
The suggested remedy consisted of the following components:
(1) Pumn. seDarate and treat liauid contaminants. LNAPLs and
DNAPLs would be pumped from the zones of pooled product
beneath the site, separated from the water, and destroyed by
on- or off- site incineration. (Proposed in July, 1992.)
(2) On site incineration of 25.000 cubic vards of hiahly
contaminated tars and sludc:res. 25,000 cubic yards of tars and
sludges located in the "sludge overflow area" of the site,
which is the most highly contaminated material, would be
excavated and thermally treated on-site. Ash, would be
landfilled on-site. (Proposed in August, 1992.)
(3) In-situ bioloaical treatment of 250.000 cubic vards of
contaminated soils. The remainder of the site's contaminated
soils/sludges from process areas and buried pits would be
addressed in-situ by injecting, via wells, nutrients, microbes
and oxygen as is necessary to attain stated treatment goals.
The ground water extraction system used for NAPL recovery
would also be used to hydraulically control any off-site
migration of ground water contamination and allow for
recirculation of the bacteria for efficient treatment.
Because of the expected pace of remediation, the EPA
would categorize this site remediation as a Long Term
Remedial Action. What this means is the EPA will be
responsible for 90% funding beyond the customary 1 year
time period: 90% funding will continue until such time as
the established remediation goals are met. The state of
Louisiana will be responsible for 10% of the costs. This
component is innovative and is expected to provide
permanent treatment. (Based on comments/ information
received during the public comment period.)
-------
(4) CaDtdna of surface contaminated soils. decontamination and on-
site landfillina of Drocess eauiDment and scran. Grading and
capping would be done to complement the above remedial
actions. (Proposed in July, 1992.)
The net cost of this set of remedies was estimated between $40-$50
million which is significantly less than the total cost of the
incineration remedial option (approximately $185 million) and more
environmentally protective than the original pumping/capping
proposal. Biological treatment of creosote-contaminated soils is
being attempted at numerous wood treater sites nationwide.
Although biological treatment for the site was initially screened
from consideration early in the Feasibility study, in light of the
comments received and technical information, and considering the
extreme cost of complete on-site incineration, the EPA and LDEQ
believe this innovative technology warrants implementation.
Based on the comments received during both comment periods and the
aforementioned discussions, EPA and the state of Louisiana have
select~d Alternative 6, Partial Excavation and On-site Incineration
with Xn-situ Bioremediation, in conjunction with Alternative C,
Active Treatment of NAPLs and contaminated Ground water, as the
remedy for addressing contaminated materials at the American
Creosote site.
:-
. .
A response to the comments received during both comment periods is
included in the Responsiveness summary that is part of this ROD.
This decision document presents the selected remedial action that
was chosen in accordance with the CERCLA, the administrative
record, and to the extent practicable, the National contingency
Plan (NCP), 40 CFR part 300.
-------
APPENDIX A
AMERICAN CREOSOTE WORKS, INC.
-------
Annt> dix A: Surflce Soil Slmnle ResullJ from Ptevious IlIYeSlinlloDS II lbe American Creosote Slto
J..oc:8lionlSl8llou , 62 63 64 65 69 70 72 73 74 56 55 52
A~i..to lu.Jb\
I
lceftlnhlhene U U 6700000 3100000 U 99000 U 6300 U U U U
lluonnlhene 380000 590 1 SOOOOOO 5400000 l!OO 2SOOOO 7400 30000 2900 490 180 320
ftlnhlhlleae U U 400000O 2400000 U 71000 U U U U U U
benzol. ualhncoDO 62000 620 nooooo 870000 1900 55000 3400 5700 UOO 190 U 230
belWli.-no 13000 310 U U 2200 36000 2500 6300 3600 180 U U
ben,,,n,\lIuonalhrene 39000 1300 1600000 530000 3400 71000 6300 ..000 7900 470 310 U
'--'It<\lIuonnlhrene 20000 1100 U U 3!OO U U U 5200 3.40 210 260
~h.v.eno 60000 980 3300000 1200000 2300 62000 1900 9200 3900 3SO U 270
lceftlnhl""'- U U U U 690 U 730 U 1300 U U U
Inlhncene 2SOOO U 3100000o 1300000O U 100000 3100 39000 2400 U U U
be no U 470 U U 1800 18000 2200 4700 3300 U U U
lluonme U U 1200000O 5600000 U 140000 860 19000 U U U U
OMftlnlhFene U U 3600000O 1400000O U 320000 2200 U 1300 290 U U
dibe-nli h"'Dlhncene U U U U 310 U U U 730 U U U
ladenoll.U-ed\"""'DO U 510 U U 1800 23000 2000 4100 3600 U U U
"",,no 370000 880 100000oo 400000O 3000 160000 6200 22000 4600 4SO 220 840
WI\pmUIVALENt'S moo 673 413000 152000 '~3 'UlIO 3689 7512 6199 289 52 52
Tol.1 pAIIJ 969000 6760 t21800000 50100000 22400 1405000 38790 160300 43330 2760 920 1920
oonl8chlMonheaol 630000 U U U U 31000 U U U U U U
dibeDZOfuran U U 5700000 U U 94000 U 6600 U U U U
2.melhvlftlohlhaleDO U U 3200000 1800000 U 58000 U 2500 U U U U
ToIllleirachiorofunlll NA NA U U NA NA NA NA NA NA NA NA
nenllchlorofunDl NA NA U U NA NA NA NA NA NA NA. NA
MJllch\orofunDl NA NA U U NA NA NA NA NA NA NA NA
heel8ch1orofunDl NA NA '3 9.9 NA NA NA NA NA NA NA NA
ocIIchlorofunlll NA NA 12 18 NA NA NA NA NA NA NA NA
TotllteillchlorodioJllII NA NA U U NA NA NA NA NA NA NA NA
. 2.3.7 8-lell'lchlorodioxlD NA NA U U NA NA NA NA NA NA NA NA
oonllchlorodloxtDl NA NA U U NA NA NA NA NA NA NA NA
heJIIchlorodiox\nl NA NA ", :u NA NA NA NA NA NA NA NA
heo18ch1orodioJllII NA NA 140 150 NA NA NA NA NA NA NA NA
ocIIchlorodloxlJll NA NA 180 240 NA NA NA NA NA NA NA NA
U . Undeleded ~eelion Umlt unknown\
-------
I;
A....ndk A fCODt.\: Surf.ce Soil Samnle R_III from PrevIou.IJllleltlntIoDl .t the AmericaD CreoIote Site fCODt.\
LocatlonlSlltioD , 68 66 67 71 60 61 51 53 58 57 54
ADaMe (uda\
IGeDlohthene 1600000 U U U U U U U U U U
fluOIiDtheoe 2400000 390000 2200000 92000 1100 320 U U 100 U 760
naohthaleae 880000 U U U 260 U U U U U U
benzol. 'IJIothllcell8 380000 80000 160000 20000 1620 230 U U U U 770
bell2O/'l \twr'ene 120000 35000 U 12000 630 150 U U U U 940
OuollDtluene 160000 100000 260000 31000 1700 500 U U U 3110 2200
IluOIiDtIuene U 67000 U 28000 1800 3110 U U U U 2000
chmell8 380000 150000 410000 38000 1100 400 U U U U 1100
IceDlohthvteoe U U U U 240 U U U U U 250
lothllceoe 510000 77000 130000 U 340 U U U U U U
be III U U U U 1200 1110 U U U U 800
fluorene 1200000 U 100000 U U U U U U U U
nhenaoth~ne 4100000 79000 100000o U 590 U U U U U U
dibeozotl h'lJlnthllcell8 U U U U 170 U U U U U U
lodeooll.2.3-a1\DVleIl8 U 25000 U 11000 1100 210 U U U U 810
DYnIIII 1900000 380000 1300000 19000 1400 380 U 200 120 U 1300
w.\P FnUIVALENTS 171800 63$00 46100 21470 1313 281 . . . 39 1448
TolIIPAHs 13630000 1423000 1560000 311000 12250 2770 U 200 220 390 10990
oeDllchIoroohenol U 790000 500000O U U U U U U U U
dibenzofullD 810000 U U U U U U U U U U
2.methvlnanhthalene 610000 U U U U U U U U U U
Tot.1 tetllchlorofuliDl U NA NA U NA NA NA NA NA NA NA
oeDlldllorofullDl U NA NA 0.068 NA NA NA NA NA NA NA
heuch1orofullDi 16 NA NA 1.7 NA NA NA NA NA NA NA
heDllchIorofullDl 170 NA NA 63 NA NA NA NA NA NA NA
oc:IIc:hIorofullDl 310 NA NA 7.1 NA NA NA NA NA NA NA
Tot.1 tetllchIoroclioJdns U NA NA U NA NA NA NA NA NA NA
2.17.8 .tetrachlorociioDDl U NA NA U NA NA NA NA NA NA NA
oeDllchIorodioxlnl 2.5 NA NA 0.17 NA NA NA NA NA NA NA
heuc:hlorodioDDl 93 NA NA 9 NA NA NA NA NA NA NA
heolldllorodloliDs 2200 NA NA 160 NA NA NA NA NA NA NA
oc:IIc:hIorodioliDs 2700 NA NA 140 NA NA NA NA NA NA NA
U . Undetec:tecl tDeteetioD limit unkoowo\
-------
AM ndlx A (conl,\: Subsurface Soli Sa-Ie Resul1l rrom Previous Invalinllons at the Americ8n Creosote Slle
LocallonlSllllon II 83 8-4 85 88 89 90 82 87
DaJlb (4-6m (4-«1m (4-6(1\ l18-2UI\ l18-2Ut\ l18-2trt\ (4-«1m lI8-2Ut\
ADlMe (uR1b\
lceDlohlhene 10000 150000 U 250000 U U U U
Ruonnlheoe 16000 290000 U 350000 U U U U
Dlohlha!eoe 22000 260000 U 550000 U U U U
benzoll\anlhncene U 66000 U 52000 U U U U
I oe U 40000 U U U U U U
bem
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I< -adil: I< cool.): Subsurface Son Samole Raul.. from Previous 1_111II1101IS allbe Americao Creosote Site
LocallonlStation II Dl Dl Dl WI» D4 WD5 WD6 WEI AS 1<6 WBI
n-tla 6.5 ft 9ft 10ft 10 ft 9ft 9f1 9ft un 3.0 n '7.5 n '7.0 n
ADaMe IU811r8\
aceR.Rhl~ 19000 50000 U 96000 U 3200 U U lmmD U 300000
fluollotbeae 32000 65000 U 200000 WIOO U U U 3700000 U 430000
DI"lathale1le 1~ 120000 U 210000 moo 4600 U U 1600000 U 1400000
be-nta\8othracene U 6700 U 31000 U U U U 630000 U '71000
a De U U U U U U U U 220000 U 25000
beazo(b)Ouoraolhrene U U U 18000 U U U U 330000 U 31000
""n.NIr\OuOliothrene U U U 12000 U U U U U U U
ch......ae U 6'700 U 32000 U U U U 640000 U 62000
acenanlalhvleDe U U U 4300 U U U U U U 18000
aothracene U 28000 U 63000 U U U U 1300000 U 23000
De U U U U U U U U U U U
fluorene 19000 51000 U 120000 moo 3300 U U 1900000 U 360000
nhenaotlarene 58000 150000 U 420000 '74000 8600 U U '700000o U 100000o
djheftmta.la)aothracene U U U U U U U U U U U
lndennll.2.3-a1)pyrellO U U U U U U U U U U U
IIVreIlO 25000 ~ U 130000 24000 U U U 2400000 U 280000
Rla'P s:nUIVAlEN1'S . 7370 . 6420 . . . . 322400 . 358210
Total PAIII 167000 521400 U W6300 180000 19700 U U 21321N3' U 400000O
lleotacbloroobenol U U U U U U U U U U U
dibeozoftlrao
2-methvloaohlha leoe 4900 26000 U 70000 11000 U U U 630000 U 310000
l.methvlPDbtbaleoe 4600 15000 U 40000 U U U U 370000 U 150000
~Imelhvl Dlnhlbalene U U U 11000 U U U U 100000 29000
2.6-d1me11lv1 Dlnhlhalene U U U 23000 U U U U 200000 U 63000
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Anr ndbr A {conl.\: Subsurflce SoU SlmnJe Results from Previous Investlnllons lllbe Americla Creosote Slle
LocalloalSlllioa" WCl wcz C3 C4 C$ C6 C1 CO WAI A2 A3 A4
Denlb 113 n 9n 10 fl 9ft 14,5 n 12 ft 1:1.9 n 10.5 n 9n 3.5 n 3ft 3ft
Aallvte (u~\ I
lceDlnblbeae U U U 160000 U U U U 99000 1300000 U U
1lu000aibene U U U 210000 U U U U 80000 300000O 1200 6400
IIIDbibaJeae U U U 900000 U U U U 580000 940000 U U
'-"nfl"'alhncene U U U 35000 U U U U 14000 430000 U U
'-"nfl-ne U U U 13000 U U U U 6300 120000 U U
~\Ouonnlb- U U U 115000 U U U U 8fiOO 210000 U U
- "-Nk\Ouonalhr- U U U U U U U U U U U U
-;:t;~ne U U U 30000 U U U U 13000 400000 U U
lcelllllhthvlene U U U 12000 U U U U U U U U
Inlhnceae U U U 87000 U U U U 43000 1900000 24000 U
ne U U U U U U U U U U U U
lluorene U U U 170000 U U U U 100000 1100000 U 10000
Dhenanlhrene U U U 490000 U U U U 2AOOOII 6300000 10000 U
dihenmll.b'lnlhncene U U U U U U U U U U U U
IndeDOl'U.3-cd'- U U U U U U U U U U U U
III/I'iI!ne U U U 140000 U U U U '9000' 200000O 6500 '100
BfI'P EOUIVALENTS . . . 18100 . - . - 8490 188000 . .
TolIlPAHI U U U 2263000 U U U U 1242900 l8300W 41700 22100
-allchJoFftfthenol U U U U U U U U U U U U
dlbenzoftJna
2-melJ.uln.nhlbaJene U U U 200000 U U U U 140000 400000 U U
1.melJ.ulnanhlbaJene If U U 94000 U U U U 11000 2SOOOO U U
':L3-dIme'J.uI naDhlbaJeae U U U 17000 U U U U 14000 80000 U U
':LfHllme~ DlDhlbaJene U U U 40000 U U U U. 28000 140000 U U
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A-ndix A (conl.\: Sedlmenl Samnle Results from Previous 1_11-110111 al lho American Creosote 511e
LocailonlSllilon" 16 18 19 23 31 37 38 21 22 24 14
Analvte (ullb\
aeenaDhibeoe U U U 8300 U U U U U 480000 U
fluoranlbeoe U U 1700 220000 5400000 5400 U U U omnnn U
D8DhihaJene U U 330 U U U U U U 830000 U
henzo(a \anlhraeeoe U U U 31000 820000 10000 15000 U U 110000 U
henz"'a \nvMoe U U U U 270000 15000 30000 U U U U
henz"'" \Ruoranlhrene U U 730 23000 1400000 2SOOO 33000 U U 89000 U
he.....nI1r\Ruoranlhreoe U U U U U 13000 41000 U U U U
duwene U U 5110 36000 1400000 14000 34000 U U 120000 U
leenaDhlhvlene U U U U 230000 6400 U U U U U
I nlhraune U U U 52000 12lO000O 6600 U U U 150000 U
he ne U U U U U 8500 18000 U U U U
fluorene U U U 100000 U U U U U 480000 U
Dhenanlhrene U U 1100 240000 800000 U U U U 1800000 U
Indenoi1.2.3-a1\- U U U U U 9400 20000 U U U U
IM'eDe U U 1300 150000 6400000 11000 17000 U U 570000 U
Rla\P J:nUIVALENTS . . 79 5760 506000 19400 39440 . - 21100
Tolal PAHs U U 5750 860300 1'1920000 124300 208000 U U 5529000 U
oenladllol'ODhenol U U 670 29000 600000o U U U U U U
tlihenzofunn U U U 79000 U U U U U 320000 U
2.melhvlnaDblhaleno U U U U U U U U U 230000 U
. Tolal lelneblorofuraDl NA NA NA NA NA NA NA NA NA NA NA
Denladllorofunlll NA NA NA NA NA NA NA NA NA NA NA
beDcbJororunns NA NA NA NA Not. NA NA NA NA NA NA
b-ladllorofunlll NA NA NA NA NA NA NA NA NA NA NA
ocIacblorofunlll NA NA NA NA NA NA NA NA NA NA NA
Tolll lelnchJorodloKiDI NA NA NA NA NA NA NA NA NA NA NA
2.3.18 -lelncbJorodloxina NA NA NA NA NA NA NA NA NA NA NA
Denlachlorodloxina NA NA NA NA NA NA NA NA NA NA NA
beDchlorodioxiu NA NA NA NA NA NA NA NA NA NA NA
beDladlJorodioxilll NA NA NA NA NA NA NA NA NA NA NA
ocIacbloroclioxins NA NA NA NA NA NA NA NA NA NA NA
U . Undetected t'Detectlo" Umll unbowa\
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A ....ndb: A (conl.\: Sedlmenl Sa mle Results from PrevIous 1_llnllom lllbe ~D Creosote Slle
LocallonlSlallon" 26 21 30 32 35 36 13 15
ADaMe (uel...\
I
lcenanhlhene U 3300 37000 U U U U U
lluonnthene 200 2600 57000 3'JOO U U U 210
nanhlhalene U 4900 120000 U U U U U
bcftZo(a 'Inlhncene U 890 17000 2500 U U U U
beMllla-ne U 310 28000 6000 U U U U
henmlb\lIuonnlbmle U 500 35000 12000 U U U U
beMlllk\lIuonnlbr- U 460 U U U U U U
cluwene U 980 20000 4000 U U U U
lcenanhlhvlene U 330 15000 2000 U U U U
Inlhncene U 1600 18000 U U U U U
I lene U U U 5100 U U U U
lluorme U 3200 38000 U U U U U
nhenanlh- U 5900 76000 U U U U 300
Indenoll.2.3-cd\nvrene U U U 5000 U U U U
mrene 220 2500 60000 4200 U U U 240
Wa\P J:l'IUlVALENTS . 545 33400 7990 - ' . .
Tolll PAHs 420 27530 521000 45100 U U U 810
nenllc:hloroohenol U U U U U U U U
dibenzolUnn U 2300 31000 U U U U U
2-melhvlnanhlhllene U 1700 43000 U U U U U
TolalletnchlorolUnna NA NA NA NA NA NA NA NA
oenlac:hlorolUnna NA NA NA NA NA NA NA NA
heDchlorofunna NA NA NA NA NA NA NA NA
"-lIdilorolUnna NA NA NA NA NA NA NA NA
oc:tIdilorolUnm NA NA NA NA NA NA NA NA
Tolll tetnc:hlorocl\oxlJll NA NA NA NA NA NA NA NA
2.178 .tetnchloroclt.wl- NA NA NA NA NA NA NA NA
Denlac:hlorocllodna NA NA NA NA NA NA NA NA
heDc:hloroclioKina NA NA NA NA NA NA NA NA
t;;.8c:h1orocllodna NA NA NA NA NA NA NA NA
odac:hlorocllOlins NA NA NA NA NA NA NA NA
U . Undetedcd fDetec:llon 0mI1 untnown\
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A.... ondix Alcont.: Sedimeal Sa.... Ie Resulls from Prevlou I_tlntions at the Americaa Creosole Sile
l.oc8lionlSlslioa II 2$ 28 'to 33 34 11 t2 17 39 40 41
ADaMe IuoA-o\
acenanhtheae U U 930000 U 11000t10 U U U U U U
nuonnthcne 2100 5SOOOO 31000t10 71000 :zsooooo U U 460 U U 2300
DlDhlbalene U U U U 27OOOtIO U U U U U U
ben7..taboalhnceae 1500 100000 480000 U I 5SOOOO U U U U U 540
benzofabwlene 3900 3SOOO 140000 U 270000 U U U U U 500
benzofb\OUonnlbmle 8400 130000 4SOOOO U 590000 U U 510 U U 720
benzoik\OUonDlhrene U U U U U U U U U U 6'10
c""""'ne 3400 130000 5000t10 U 580000 U U 300 U U 900
acenaDhlhvlene 8C50 U U U 100000 U U U U U U
anlhncene 1500 4100 410000 U 820000 U U U U U 230
be De 2900 U U U U U U U U U U
nuoreae U U 670000 U 1600000 U U U U U U
nhenanl1ucne 1100 47000 1700000 SOOOO 4800000 U U U U U 310
indenofl.'l.3-oI\IWII!De 2800 U U U 110000 U U U U U U
IWII!ne 2100 470000 2200000 44000 200000O U U 470 U U 1700
Bfa\P FnUIVALENTS 59300 238000 . 400800 . . 54 . - 697
Tolal PAHI 3O$GO 1466100 10580000 165000 17720000 U U 1690 U U 7870
....nlachlorDDheool U U U U U U U U U U U
dibenzofuna U U 320000 U U U U U U U U
2.melhvlnanhlbaleDe U U U U 100000o U U U U U U
Tolallelnchlorofunns NA NA NA NA NA NA U NA U NA NA
-aladllorofunlll NA NA NA NA NA NA U NA U NA NA
he18chlorofunlll NA NA NA NA NA NA U NA U NA NA
heDladJlorofunlll NA NA NA NA NA NA U NA 1.4 NA N,4
odachlorofunns NA NA NA NA NA NA U NA 2.1 NA NA
Total telnchlorodloxlnl NA NA NA NA NA NA U NA U NA NA
2 3 7.8 'lclnchlorodloxlnl NA NA NA NA NA NA U NA U NA NA
-Dladllorodloxlnl NA NA NA NA NA NA U NA U NA NA
he18chlorodimdns NA NA NA NA NA NA U NA U NA NA
heDlachlorodioxilll NA NA NA NA NA NA 033 NA U NA NA
odadJlorodioxilll NA NA NA NA NA NA 2.511 NA 15 NA NA
U. Undetec:ted metediolllimlt uDkacMD\
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A-ndix A fcont.\: Groundwater Sam1lle Results from PrevIouslnvestintionsat the AmericIIn Qeosole Sile
LocationlStation' WBt WCt WCZ WD1 WD5 WEt
ADaMe fuRll\
I
aoenanhthene 6Z40 123 454 533 8160 U
flunnnthene 8830 U 33.0 356 10600 U
nanhlhalene 35100 42 90.2 7040 18300 U
benzola\anlluaoene 1310 113 16.6 64 1310 U
beft7nfa-ne 356 U U U 313 U
.,;.;;;(b)fluonnlluene 626 U 79.0 U "5 U
beft7nl1<\fluonnlhreue U U U U U U
chmene 1280 U 72 1190 1190 U
aoenanhl"""'ne U U U U 802 U
anthncene 3750 U U 304 3540 U
I ue U U U U U U
fluorene 7370 U 468 7690 U U
nbenanlbrene 21800 42.4 172 960 19700 U
dibenzolab\8nlhncene U U U U U U
indenoll.13.cd'l'NI'II!ne U U U U U U
-ne 5500 U 30.6 287 7540 U
Bfa\P 563 1 10 18 515 .
Tolll PAIls 92162 218.7 1415.4 18424 838700 U
I nentacbloraobenol U U U U U U
2.methvlnaohthalene 6430 U 12.0 859 4660 U
1-melhvlnanhlhalene 3150 U 169 U 2520 U
I 'l.!-dimethvl nanhthalene 781 U U U 1880 U
I '!6-dimethvl naohlhalene 1050 U U U 2840 U
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APPENDIX B
AMERICAN CREOSOTE WORKS, INC.
SURFACE SOIL ANALYTICAL SAMPLING
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FIELD SAMPLE NUMBER: 55-11- 5L-00' SS-12'SL'OO' S5-13-SL-OO' 55' 14-SL-OO' 5S"5'5L-00' 55' 16-SL '00' S$'17-SL'oo, ss- '8-51. -00' S$-'9-5L-00, 55-Z'-5L-00,
EPA SAMPLE NUMBER: Of 0170 GF01Tt Of 0216 Of 0217 Of 0218 OfOZ'9 of0Z20 Of 0174 Of022' OfOD8
DEP'H
VOA ANALY'E5 (40) 0 0 0 Q- 0 0 0 0 0 0
jili/KIi - - - ",II/Kg - .- f- ",g/Kg - - ",g/ltll - - - ",,,/KII - - I- ",g/Kg - - - ",g/Kg - - - ",g/ltg - - - ",g/ltg - f- I- jig/Kg - ,.-
VIIIYL CHLORIDE . UJ . UJ - UJ . UJ . UJ - UJ . UJ UJ UJ UJ
'.'-OICHLOROETHEIiE . UJ - UJ . UJ . UJ . UJ - UJ . UJ . UJ . UJ . UJ
TRAN5-,.Z'OICHLOROETKEIiE . UJ . UJ . UJ . UJ J UJ . UJ . UJ . UJ . UJ - UJ
'."OICHLOADE'HANE . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ - UJ - UJ
CIS.,.Z'OICHLOAOETHEIIE . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ
CHLOROfORM . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ - UJ - UJ
'.t.t-'RICHLOROETHANE - UJ . UJ - UJ . UJ . UJ - UJ - UJ - UJ - UJ - UJ
CARBON TETRACHLORIDE . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ
IENZENE . UJ - UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ
1.2-DICHLOAOETNANE . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ - UJ . UJ
TRICHLOROETHENE . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ - UJ - UJ
BROMOOI CHLOAOKETHANE - UJ - UJ . UJ . UJ . UJ - UJ . UJ . UJ . UJ . UJ
TOLUENE - UJ . UJ . UJ . UJ . UJ - UJ - UJ . UJ . UJ . UJ
TETRACMlOROETHENE . UJ - UJ - .UJ . UJ . UJ . UJ . UJ - UJ - UJ - UJ
CHLOA08ENZENE . UJ . UJ . UJ . UJ . UJ - UJ - UJ . UJ . UJ - UJ
'.'.2.2-TETRACHlOADETHANE . UJ . UJ . UJ - UJ - UJ . UJ . UJ . UJ . UJ - UJ
ETHUBENZENE - UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ
BROMOFORM - UJ - UJ - UJ - UJ . UJ - UJ - UJ - UJ . UJ - UJ
".P'IIYlENE - UJ . UJ . UJ . UJ . UJ . UJ - UJ . UJ . UJ . UJ
o.xnENE . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ
PAH AIIALY'ES (330) Of 0170 0 OF017' 0 Of 0216 0 Of 0217 0 OfOZ18 0 oFOZ'9 0 oFOZ20 0 OF0174 0 OF02Z1 0 OF0240 0
,.,/K, - - ILII/KI - - - "II/K' - - f- IllI/Kg - - -IIII/K8 IIIIIK, - - ,.II/KII - f- '" ,.9/KI - - - ,.9/KI - - - ",/KI - -
NAPHTHALENE - UJ . UJ 35.00 J 110.00 01 . UJ 320.00 01 200.00 01 129.00 01 2'0.00 01 - R
ACENAPHTHnENE . UJ . UJ 55.00 01 280.00 01 150.00 01 200.00 01 770.00 01 . UJ 75.00 01 . R
ACENAPHTHENE - UJ 45.00 J 48.00 01 90.00 J 39.00 J 84.00 01 160.00 01 '2'.00 J 430.00 01 110.00 R
FLUORENE . UJ 54.00 01 45.00 01 83.00 01 42.00 01 2400.00 01 810.00 01 980.00 01 650.00 01 - R
PHENANTHRENE 62.00 01 139Z.oo 01 210.00 01 560.00 01 '90.00 01 5300.00 01 3800.00 01 3355.00 01 4900.00 01 '90.00 R
ANTHRACENE . UJ 545.00 01 110.00 01 400.00 01 2600.00 01 24000.00 01 12000.00 01 12831.00 01 370.00 01 80.00 .
FlUORAIiTHENE 441.00 01 23'46.00 01 640.00 01 '000.00 01 1400.00 01 2500.00 01 17000.00 01 20301.00 01 7000.00 01 770.00 R
PYRENE 394.00 J 45648.00 J 680.00 J 1100.00 01 1900.00 J 3100.00 01 17000.00 01 42183.00 01 4900.00 01 860.00 R
BENZCA)AIITHRACEIIE 142.00 01 28973.00 J 470.00 J 2600.00 J 2200.00 J 1100.00 01 9100.00 01 17344.00 01 1500.00 01 1100.00 R
CHRYSEIIE 240.00 01 29904.00 01 . UJ 1300.00 01 1400.00 01 1800.00 01 14000.00 01 24151.00 01 2000.00 01 1200.00 R
IEIIZO(8)/CIt)flUORANTHENE 383.00 01 29112.00 J 1600.00 01 5100.00 01 3700.00 J 5200.00 01 19000.00 01 47469.00 01 2300.00 01 2300.00 R
BEIIZO(A)PTRENE tOZ.OO J 1T0Z6.00 J 450.00 J Z1oo.oo J 1400.00 J 1800.00 J 7800.00 J 13m.OO 01 710.00 J 1600.00 R
INDEIIOC1.2.3'CO)PYRENE 96.00 01 6IK9.00 J 200.00 01 3100.00 J 1900.00 01 2200.00 01 7700.00 01 11858.00 01 590.00 01 1200.00 R
OIIEIIZCA,H)ANTHRAtENE . UJ 3754.00 J . UJ 1300.00 J 110.00 01 960.00 01 3400.00 01 5285.00 J 230.00 01 240.00 R
8ENZO(G.H,I)PERYLEME 154.00 J 5255.00 J 310.00 J 3000.00 J 1900.00 J 2100.00 J 7400.00 01 9151.00 01 500.00 J 650.00 R
leA)p Equlv.lence tone. 167 - 21632 - 677 !- 4493 I-- 2904 - 3688 - 14980 i-- 26966 I-- 1399 - 2312 -
Tot.1 PAMB 2014 - 192103 - 4913 - 22123 i-- '9531 - 53664 - 120740 i-- 208942 i-- 26365 - 10300 -
PHENOl ANAL'TES (1700) OF0170 Q oF0171 Q OF0216RE 0 GFOZ'7RE Q OF021811E Q OF02'9AE Q Of0220RE 0 OFO' 74 0 GF02Z' 0 OF0238RE Q
",,/Kg - - - ,,/Xg - - -,.II/K, - - ,.,/KII - i-- f- IIg/K8 - - - ",/KII - - -IIIIIKII - - I- ,.II/KI - i-- - 1I,/Kg - - - ,.,/KII - -
PHENOL . UJ . UJ 640.00 01 620.00 01 710.00 J 700.00 01 100.00 01 UJ UJ UJ
2. CHLOROPHENOL . UJ . UJ 150.00 J 150.00 J 150.00 J 190.00 J 140.00 J . UJ . UJ . UJ
O'CRESOL 0.04 01 . UJ . UJ . u.I . UJ . UJ . Vol . UJ . UJ . UJ
""'CRESOL . UJ . UJ . UJ . W 130.00 01 120.00 01 110.00 J . UJ 230.00 01 710.00 01
2'lnROPllEIIO&. . UJ . UJ . UJ . UJ 130.00 J . UJ 90.00 J . UJ . UJ . UJ
2.4'0IMETHYLPNEIOL 6.30 01 0.71 01 102.00 01 90.00 J 97.00. J 150.00 01 110.00 01 0.22 J . UJ . UJ
2,4'DICILOROPHEIIO&. . UJ . UJ . Uol . UJ 51.00 01 . UJ . UJ . UJ 500.00 01 no.OO J
4.CMlORO'3'HETHYLPHEIIO&. . UJ . Uol 41.00 oI 110.00 01 . u.I 110.00 01 73.00 01 . UJ . UJ . UJ
2,4,5/6-TRICMLOROPHEIIOL . Uol . UJ . UJ 56.00 J 50.00 .. 41.00 01 240.00 01 . UJ . Vol . Uol
2,4'OIN'TRDPHEIIDL . VJ . UJ . Vol . V" . Vol . Vol . W . UJ . R . VJ
4..nRDPIlEIIQI. . UJ . UJ 66.00 01 57.00 .. 60.00 .. 13.00 01 14.00 oI . UJ . UJ . UJ
2,3,4,6.TEJRACIlOlOPHEIOL 0.12 01 0.04 J . Vol 51.00 J . UJ 110.00 01 180.00 .. 0.28 01 1900.00 J 110.00 01
4,6'D...TRO-Z.RETHYLPHENOl . Vol . U.. 52.00 01 44.00 01 61.00 01 41.00 J 46.00 J . UJ . . 10.00 .
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FIELD SAMPLE NUMBER: SS-O"SL'OO' SS-OZ.SL'OO' SS-O].SL'OO' SS-04-SL'OO' SS.OS'SL'OO' SS-06'SL-OO' SS-07'SL'00' SS-08'SL'OO' SS-09'Sl'OO' SS,'O'Sl-OO'
EPA SAMPLE NUMBEls OFO'75 OF0173 OFO'76 OF0177 OF0213 0'0222 OFO'82 OFO,78 OF0119 OF0169
DEPTH
VOA ANALYTES (40) 0 0 0 0 0 0 0 0 II 0
1'1/"1 - ~ 1&8/"1 - I-- ~ 1'1/"1 - - 1'1/"1 - I-- I- 111/"1 - I-- I- 111/"1 - I-- I- 111/'" - f- I- 111/'" - ~ I- 11111"1 - I-- I- 111.'''" - ~
VINYL CHLORIDE - UJ - UJ - UJ UJ . UJ UJ UJ UJ UJ UJ
'.I'OICHLOROETHEHE . UJ . UJ . UJ - UJ . UJ . UJ . UJ . UJ . UJ . UJ
TRANS-I,2-0ItHLOROETHENE . UJ . UJ . UJ - UJ . UJ - UJ - UJ - UJ . UJ . UJ
'.1-0ICHLOROETHAHE - UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ - UJ
CIS",Z'DltMLOIOETIENE . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ - UJ - UJ
CHLOROFORM - UJ - UJ . UJ - UJ . UJ . UJ . UJ . UJ - UJ . UJ
T.1.1-TRICHLOROETHANE - UJ . UJ . UJ - UJ . UJ . UJ . UJ . UJ - UJ - UJ
CARBON TETRACHLORIDE . UJ . UJ . UJ . UJ . UJ . UJ - UJ . UJ - UJ . UJ
BENZENE . UJ . UJ . UJ . UJ 1. UJ . UJ - UJ" UJ - UJ - UJ
1.2.0ICHlOROETHANE - UJ . UJ . UJ - UJ . UJ . UJ - UJ - UJ - UJ - UJ
TRICHLOROETHENE . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ - UJ . UJ
BROMOOICHLOROMETHANE . UJ . UJ . UJ . UJ . UJ . UJ - UJ . UJ . UJ . UJ
TOlUENE . UJ . UJ . UJ . UJ . UJ . UJ - UJ - UJ - UJ . UJ
TETRACHLOROETHENE - UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ - UJ . UJ
CHLOROSENZENE . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ - UJ. . UJ
1.1.2.2-TETRACHLOROETHANE . UJ . UJ - UJ - UJ . UJ . UJ . .UJ . UJ - UJ . UJ
ETHYL BENZENE - UJ . UJ . UJ . UJ . UJ - UJ . UJ . UJ . UJ . UJ
BROMOFORK . UJ . UJ . UJ . UJ . UJ . UJ . UJ - UJ . UJ . UJ
K.P-XYLENE - UJ . UJ . UJ . UJ . UJ . UJ . UJ - UJ - UJ . UJ
a-XYLENE - UJ . UJ . UJ . UJ . UJ - UJ . UJ . UJ - UJ - UJ
PAH ANAL nES (330,) OFOI75RE a OF0113 a OFD17611E 0 OFo,mE a OF021] II OF0222 a OF0182 0 OFO'78RE 0 OFOI79RE a Of 0169 II
1',,/"" - - I- 1&8/"1 - - 11"1"" - I- I- 119/"1 - I-- I- 111/'" - 1-- "" 119'''1 - - 1191"" - - 1'9'''' - - - 1''''''" - ~ ~ 11111"9 - -
NAPHTHALENE 960.00 J 163.00 J 310.00 J 76.00 J 650.00 J 31.00 J '88.00 J 290.00 J 200.00 J 4'.00 J
ACENAPHTHYlENE '200.00 J . UJ 670.00 J 2000.00 J 700.00 J 95.00 J 615.00 J 110.00 J 140.00 J - UJ
ACENAPHTHENE 570.00 J 681.00 ..I 1700.00 J 1500.00 J 630.00 J 49.00 J 910.00 J 120.00 ..I 240.00 J . UJ
fLUORENE 690.00 J '092.00 ..I 1100.00 J 6700.00 ..I 2300.00 J 38.00 01 2'60.00 01 120.00 J 510.00 ..I . UJ
PHENANTHRENE 1600.00 J 3316.00 J 6300.00 J 13000.00 J 9200.00 J 300.00 J . UJ 1300.00 J 1700.00 J 92.00 J
ANTHRACENE 4600.00 J 27440.00 J 6700.00 J 5300.00 J 20000.00 J 450.00 J . UJ 1200.00 J 29000.00 J - UJ
flUOllANTHENE 24000.00 J 30846.00 J - UJ 16000.00 J '5000.00 J 1200.00 J . UJ ]500.00 J 32000.00 J 202.00 J
"RENE 24000.00 J 28631.00 J - UJ '6000.00 J '6000.00 J 1300.00 01 - UJ 4500.00 J 55000.00 J 215.00 J
BENZ(A)ANTHRACENE 23000.00 J '3094.00 J . UJ 950.00 J '0000.00 J 1400.00 J - UJ 4200.00 J 14000_00 J 161.00 J
CHRYSENE 16000.00 J 14948.00 J 37000.00 J 730.00 J 7600.00 J 840.00 J 41755.00 J 3100.00 J 13000.00 J 241.00 J
BEH20(B)/(")FLUORANTHENE . UJ '9218.00 J - UJ 1700.00 J 19000.00 J 3200.00 J - W 1100.00 J 16000.00 J 490.00 J
BEHZO(A)PYRENE 11000.00 J 7234.00 J 24000.00 J 260.00 J 6900.00 J 1200.00 J 16099.00 J 2800.00 J 5200.00 J 109.110 J
INDENO(1.2,3-CII)PYIENE - UJ 4531.00 J 8800.00 J 720.00 J 8200.00 J 1500.00 J - UJ 3400.00 J 3900.00 J 188.00 J
O.BENZ(A.H)ANTHRAtENE 16000.00 J 1845.00 J 4'00.00 J 260.00 J :st.00.00 J 610.00 J 10193.00 J 1300.00 J 1600.00 J - UJ
BENZO(G.H.I)PERYLENE 15000.00 J 3911.00 J 7600.00 J 750.00 J 7000.00 ,J 1500.00 J 7360.00 J 2900.00 J 3000.00 J 299.00 J
I(A)P Equivalence cone. 29460 i-- 12919 ~ 29650 - 864 I- 14096 I- 2428 I-- 26710 f- 5601 ~ 10320 - 195 -
Tot.' PAH. 144620 i-- '57022 - '98580 - 65946 I-- 126580 I- 13713 I-- 79280 ~ 35940 ~ 175490 ~ 2044 -
PHENOL ANALYTeS (1700) 0'0175 II OF0113 0 OF0176 0 0'0117 Q O,OZ13RE Q 0'0222 Q OF0182RE 0 OF0178 0 0'0119 0 0'0169 Q
118/KI - I-- - 1&8/"8 - ~ ~ 118/KI - - - 118'''1 - I-- r- 118/KII - I-- I- III/KI - I-- I- 1111"8 - f- I- 118/"8 - ~ I- 118/"1 - I-- I- 1111"1 - -
PHENOL UJ . UJ UJ 0.06 J 480.00 J UJ t.O.OO J UJ UJ UJ
2-CHLOROPHENOI. 0.33 J - UJ . UJ . UJ 96.00 J . UJ 130.00 J . UJ - UJ - UJ
O'CiESOL 0.01 R 0.08 J . UJ - UJ . UJ - UJ . UJ . UJ . UJ . UJ
K'P-c:aESOL . UJ . UJ . U.. 0.13 J . UJ 220.00 J . U.. . UJ 0.05 I . UJ
2-IIIT'OPHEIIOl, . UJ . UJ . UJ - UJ . UJ - UJ - UJ - UJ . IiJ - UJ
2,4-0IMETHYLPHENOL 0.13 I 4.40 J 0.01 I 0.06 I 70.00 J . UJ - UJ 0.01 R 0.25 I 0.44 J
2,4-0ICHlOROPHEIIOl . UJ . UJ - Uol . UJ 84.00 J . Uol 460.00 01 . UJ - UJ - UJ
4'CHLORO-]-KETHYLPHfllOl - UJ . U.I . UJ . UJ 97.00 J - U.I - UJ . UJ . UJ - UJ
Z,4,5/6-TIICHLOROPHENOL - UJ . UJ - UJ 0.14 J 68.00 J 300.00 J . UJ . UJ . UJ . UJ
2.4'OIIl.T.OPHENDL - W . UJ . UJ 0.83 .I . Vol . II . UJ . UJ . UJ . UJ
4.IIITIOPHENOL . W - UJ . UJ 0.56 J 83.00 J . UJ 56.00 J . UJ - UJ - UJ
Z,3,4,6-TETIAtftLOIOPHEIIOL 0.11 .I O.U J 1.30 .. 3.00 .. 30.00 .. . UJ 450.00 J 1.00 J 1.00 .. 0.12 J
4,6-DINIT'O-Z-METIIYL'"ENDL . W . U.I 0.21 II 0.98 .I 71.00 .I - II . U.I - U.I - UJ - W
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FJELD SAMPLE NUMBER: 555-55-001 555-55-002 555-55-003 M\I2-55-001 M112-55-002 M\I2A-S5-002 BH9-55-001
EPA SAMPLE NUMBER: SF 2490 SF 2491 SF 2492 SF 2507 SF 2516 SF 2475Dl SF 2514
DEPTH (ft) I
WAs I&O/ICO - j&g/Kg - I&O/ICII A /III/Kg 110/Kg - I&O/K, A IIO/IC, - ..0-
.-
DilUTION FACTOR 1.00 1.00 1.00 1.00 .1.00 10.00 1.00
BENZENE 0.20 U 0.10 U 0.10 U 0.17 U 0.17 U 1.60 U) 0.16 U
CHLOROBENZENE 0.20 U 0.20 U 0.20 U 0.21 U 0.21 U 1.90 U) 0.19 U
1.2-0ICHlOROBENZENE 0.30 U 0.30 U 0.30 u 0.34 U 0.34 U 3.20 U) 0.32 U
1,3-0ICHlOROBENZENE 0.20 U 0.20 U 0.20 U 0.28 U 0.27 U 2.50 UO 0.26 U
1,4-0ICHLOROBENZENE 0.20 U 0.20 U 0.20 U 0.25 U 0.25 U 2.30 UD 0.23 U
ETHYL BENZENE 0.10 U 0.10 U 0.10 U 0.11 U 0.10 U 4.40 D 0.09 U
TOLUENE 0.10 U 0.10 U 0.10 U 0.13 U 0.13 u 4.10 D 0.12 U
XYlENES 0.30 U 0.30 U 0.30 U 0.36 U 0.35 U 29.40 D 0.33 U
EPA 5AMPlE NUMBER: 5F 2490 SF 2491 SF 2492 SF 2507 SF 2516 5F 2475 SF 2514
PHENOLS "'9/Kg - "'e/Ke - jig/Kg - jig/lCg I&g/lCg - jig/lCg - jig/lCg - ..0-
DILUTION FACTOR 0.167 0.167 0.167 0.167 0.167 0.167 0.167
PHENOLS 42.90 U 42.50 U 42.60 U 49.00 U 48.00 U 45.10 U 46.00 U
2-METHYL PHENOL 19.70 U 19.50 U 19.60 U 22.00 U 22.00 U 20.70 U 21.00 U
3-METHYL PHENOL 19.70 U 19.50 U 19.60 U 22.00 U 22.00 U 20.70 U 21.00 U
4-METHYL PHENOL 19.70 U 19.50 U 19.60 U 22.00 U 22.00 U 20.70 U 21.00 U
2,4-DJMETHYL PHENOL 12.70 U 12.60 U 12.70 U 14.00 U 14.00 U 13.40 U 14.00 U
2-CHlORO PHENOL ".60 U 11.50 U ".50 U 13.00 U 13.00 U 12.20 U 12.00 U
2.4-0ICNLORO PHENOl 12.70 U 12.60 U 12.70 U 14.00 U 14.00 U 13.40 U 14.00 U
4'CHLORO-3-METHYL PHENOL 34.80 U 34.40 U 34.50 U 39.00 U 39.00 U 36.50 U 11.00 U
2,4-DINITROPHENOL 19.70 U 19.50 U 19.60 U 22.00 U 22.00 U 20.70 U 21.00 U
2-NITROPHENOl 15.10 U 14.90 U 15.00 U 17.00 U 17.00 U 15.BO U 16.00 U
2.4.6-TRICHLOROPHENOL 11.60 U 11.50 U 11.50 U 13.00 U 13.00 U 12.20 U 12.00 U
4.6-0INITRO-2-METHYL PHENOL 19.70 U 19.50 U 19.60 U 22.00 U 22.00 U 20.70 U 21.00 U
4-NITROPHENOL 13.90 U 13.80 U 13.80 U 16.00 U 16.00 U 14.60 U 15.00 U
PENTACHLOROPHENOL 11.60 U 11.50 U 11.50 U 13.00 U 13.00 U 12.20 U 12.00 U
EPA SAMPLE NUMBER: SF 24900L SF 2491Dl S, 2492Dl SF 2507DL SF 2516 SF 2475DL SF 251"
PAHS jig/K, - I&g/Kg A' IlII/Kg A j&g/Kg ",g/Kg - /111/11:11 A IIII/KII - i-O-
--
DILUTION fACTOR 400.00 400.00 200.00 10.00 1.00 100.00 1.00
ACENAPHTHENE 6234.10 0 4845.00 0 4951.00 D 1680.00 D 3.30 U 3812.40 0 12.70 P
ACENAPHTHYlENE 6952.50 OU 6888.60 DU 3452.20 OU 197.00 OU 19.60 U 1827.00 OU 18.50 U
ANTHRACENE 3997.70 0 10792.20 0 37497.00 D 2520.00 D 26.00 P 803.90 0 50.90 P
BENZO(A)ANTHRACENE 4797.20 0 6755.50 D 3201.00 D 500.00 D 12'.30 814.90 D 50.30 P
BENZO(A)PYRENE 8088.10 D 7590.10 D 4998.00 D 127.00 D 22.10 421.40 D 60.00 P
BENZO(B)FLUORANTHENE 7439.20 0 10420.20 0 6523.00 D 161.00 0 25.00 P 408.00 0 59.20
8ENZO(G,H,I)PERYLENE 3951.30 D 6819.70 0 2612.00 D 19.70 DU 6.10 P 182.70 OU 29.40 P
8ENZO(IC)FlUORANTHENE 3592.10 D 6842.70 D 4566.00 D 117.00 D 17.60 P 281.40 D 59.20 P
CHRYSENE 3661.60 D 471.90 0 2196.00 0 354.00 D 5.90 601.70 D 31.80 P
DIBENZO(A.H)AlTHRACENE 6208.00 D 6370.00 D 3401.00 D 65.80 DU 15.40 609.00 DU 60.90 P
FLUORANTHENI 8377 .BO D 7182.50 D 6301.00 D 2200.00 D 31.90 P 3739.30 D 113.00 ;
FLUORENE 7960.60 0 5970.10 0 6114.00 0 7490.00 D 24.70 12302.10 D 65.30 p
INOENO(I,2,3'CO)PYRENE 6767.10 0 6808.30 0 4757.00 0 19.70 DU 22.10 182.70 DU 39.40 P
NAPHTHALENE 6952.50 OU 6888.60 DU 3452.20 OU 3830.00 0 19.60 U 5215.20 0 18.50 U
PHENANTHRENE 3997.70 D 10792.20 0 37497.00 D 2520.00 0 26.00 P 803.90 D 50.90 P
PYRENE 5110.10 0 4292.80 0 5895.00 D 792.00 0 6.50 U 1012.20 D 92.30 P
Totlt PAils 80182.60 ~ 95953.20 - 130509.00 - 22291.00 -- 235.10 ~ 30214.40 - 775.30 -
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fIELD SAMPLE NUNSEI; SS'ZZ-SL'OO1
EPA SAMPLE IUlBEII OfOZJ7
DEPTH
VOA ANAl'TES (40) Q
I&8/KI - I--
VINYl CHLOItIDE - UJ
1.1'DICHLOROETHENE - UJ
TRANS-1.Z'DICHLOROETHENE - U"
1.1'DICHLOIOETHAIE - u"
CIS-t.Z'DICNlOlOETHINI - u"
CHLOROfORM - U"
1.1.1-TRICHLOROETHANE - U"
CAR80II TE1AAC11lOlIDE - U"
BENZENE - UJ
1.2-DICHlOROETHANE - U..
TRICHlOROETHENE - UJ
BROMOO I CHLOROMETHANE - UJ
TOLUENE - UJ
TETRACHLOROETHENE . U"
CHLOROBENZENE - UJ
1.1.2.Z-TETRACHlOROETHANE - u"
ETHYl BENZENE - UJ
BROMOFORM - UJ
M.P-XYlENE - UJ
O-XYlENE - UJ
PAH ANAl"ES (330) Of 0239 Q
118/K8 - I-
NAPHTHALENE - .
ACENAPHT"YlENE - .
ACENAPHTHENE - I
FLUORENE . It
PHENANTHRENE - It
ANTHRACENE - It
flUORAliTHENE - It
PYRENE - It
BENZ(A)ANTHRACENE 48.00 .
CHRYSENE 53.00 .
BENZO(B)/(K)flUORAlTHENE - .
BENZO(A)PYREIIE - .
INDENO(1.2.3'CD)"RENE - It
DIBENZ(A.H)ANTHRACENE - .
IENZO(G.H.I)PERYLENE - It
B(A)P Equlvalenc. Cone. 5 I--
Total PAH- 101 f--
PHENOL ANAl'TES (1700) Qf0237RE Q
1&8/1:1 - f--
PHENOl. - W
2-CHLOROPIWIOI. 160_00 ..
O'ClESOl - UJ
MIP-CRESOl - UJ
2-NITIOPHENIK. - U.I
Z.4-DIMET"TLPHEIIOL - U"
Z.4-0ICHLOROPHENOL - U"
4-CNLOIO-]-MET.YL'KENCK. - U.I
Z,4,5/6-TIIClLGIOPHENOL - U..
Z.4-DIIiITIOPIENOL - UJ
4-NITROPHENCK. - W
Z.3.4.6-TETIACHlOlOPHEIIOI. __00 u~1
4.6-DINrTIO-2-METNYlPKEIOL -
PENTACHLOROPHENOL -
fiELD SAMPLE HUMBERI 555-55'001 555'5S'002 555-55-003
EPA SAMPLE NUMBER I SF 2493 If 2494 Sf 2495
DEPTH (f t) -
METALS IOIIIICI 118/ICI - 1IIg/1C1 - r-O-
ALUMIIAII 4240.00 5560_00 6670.00
ANTlIIOIIY 8.50 U 7_90 U 9.10 U
AttSENIC 20.00 8 13.50 U 16.30 B
WIUM 2230.00 2320.00 2140.00
BERYLLIUM 0.69 8 0.65 8 0.74 8
CADMIUM 1.00 0.65 8 0.74 B
CALCIUM 13700.00 13000.00 16200.00
CHROMIUM 6.10 8.10 9.10
COBALT 3.00 8 3.20 8 3.50 8
COPPER 23.40 37.60 26.30
IROH 11900.00 11300_00 13200.00
LEAD 22.10 8 31.30 23.10 8
MAGNESIUM 331.00 8 435.00 8 488.00 8
MANGANESE 128.00 141 .00 134.00
NICKEL 3.30 8 6.50 5.00 8
POTASSIUM 186.00 8 309.00 8 278.00 8
5ELENIUM 16.00 U 18.10 8 22.00 8
5ILVER 0.52 U 0.48 u 0.56 U
SOOIUM 434.00 8 424.00 8 489.00 8
THALLIUM 160.00 217.00 253.00
VANADIUM 11.80 11.30 14.10
ZINC 11.00 76.00 116.00
MOlYBDENUM 8.70 U 8.10 U 9.30 U
PHOSPHORUS 131.00 139.00 128.00
STRONTIUM 95.20 96.80 98.30
EPA SAMPLE NUMBER: SF 2484 SF 2485 5F 2486
DIOICINS 1&8/KI - 118/K8 1&8/1C8 - f-a-
2378'TCOD U U U
2378-TCDF U U U
12378-PeCOF U U U
12378-'eCOO U U U
23478-PtCD' U U U
123478-HxCDF U U U
123678. HxCOF U U U
123478-HxCOO 1.0068 .1 0.8134 "
123678-HxCOD 3.4722 3.5459 3.3829
123789-HxCDD 2.1167 .. 2.5699 2.0360 J
234678-HxCDF U U U
123789-HxCD' U U U
1234678-HpCOF 23.1014 21.8857 22.3124 U
1234618-HpCDO 291.8809 289.9030 309.3229 U
1234789.HpCO' . 1.6633 .I 1.4480 .. U
OCOD 1420.6901 1470.1196 1383.7875 U
OCDF 164.1590 154.9121 159.7943 U
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APPENDIX C
AMERICAN CREOSOTE WORKS, INC.
SEDIMENT AND SURFACE WATER ANALYfICAL
-------
FIELD SAMPLE NUMBER: 503.50.001 S03'SO.002 s03-S0.003 S\l8.SO-001 s\I3.5\I.001 5113-S".002
EPA SAMPLE MUKBERI SF 2451 SF 2452 SF 2453 Sf 2499 SF 2454 SF 2455
DEPTH (It) - "
VDAa ~I/ICI - ~S/lCg ~I/ICI - ~I/L ~I/L " ,.I/L
~-
DILUTION FACTOR 1.00 1.00 1.00 1.00 1.00 1.00
BENZENE 0.20 U 0.20 U 0.20 U 0.13 U 0.13 U 0.13 U
CHLOR08ENZENE 0.20 U 0.20 U 0.20 U 0.16 U 0.16 U 0.16 U
1,2-DICHLOROBENZENE 0.40 U 0.30 U 0.40 U 0.26 U 0.26 U 0.26 U
1,3.DICHLOROBENZENE 0.30 U 0.30 U 0.30 U 0.21 U 0.21 U 0.21 U
1,4-DICHLOROBENZENE 0.30 U 0.20 U 0.30 U 0.19 U 0.19 U 0.19 U
ETHYL BENZENE 0.10 U 0.10 U I 1.10 0.08 U 0.08 U 0.08 U
TOLUENE 0.1D U 0.10 U 0.80 0.10 U 0.10 U 0.10 U
XYlENES 0.40 U 0.30 U 2.70 0.21 U 0.21 U 0.21 U
EPA SAMPLE NUMBER: SF 2451 Sf 2452 SF 2453 SF 2499 SF 2454 SF 2455
PHENOLS 1&9/K9 - ,.I/KI I&I/KII "IlL " ,.I/L "I/L ""
DILUTION fACTOR 0.167 0.167 0.167 0.001 0.001 0.001
PHENOLS 51.70 U 47.00 U 53.60 U 2.20 U 2.20 U 2.20 U
2-METHYL PHENOL 23.70 U 21.60 U 24.60 U 1.00 U 1.00 U 1.00 U
3-METHYL PHENOL 23.70 U 21.60 U 24.60 U 1.00 U 1.00 U 1.00 U
4-METHYL PHENOL 23.70 U 21.60 U 24.60 U 1.00 U 1.00 U 1.00 U
2,4.0IMETHYL PHENOL 15.40 U 14.00 U 15.90 U 0.63 U 0.63 U 0.63 U
2-CHLORO PHENOL 14.00 U 12.70 U 14.50 U 0.58 U 0.58 U 0.58 U "
Z,4.DICHLORO PHENOL 23.70 U 14.00 U 15.90 U 0.68 u 0.68 U 0.68 U
4-CHLORO-3-METHYL PHENOL 41.90 U 38.10 U 43.50 u 1.80 U 1.80 U 1.80 U
2,4.DINITROPHENOL 23.70 U 21.60 U 24.60 U 1.00 U 1.00 U 1.00 U
2'NITROPHENOL 18.20 U 16.50 U 18.80 U 0.77 u 0.77 U 0.77 U
2,4,6-TRICHLOROPHENOL 14.00 U 12.70 U 14.50 U 0.58 U 0.58 U 0.58 U
4,6-DINITRO.2-METHYL PHENOL 23.70 U 21.60 U 24.60 U 1.00 U 1.00 U 1.00 U
4.NITROPHENOL 16.80 U 15.20 u 17.40 U 0.70 U 0.70 U 0.70 U
PENTACHLOROPHENOL 14.00 U 12.70 U 14.50 U 0.59 U 0.59 U 0.59 U
EPA SAMPLE NUMBER: SF 2451DL SF 2452DL SF 2453DL SF 2499 Sf 2454 $' 2455
PAHS I'9/1C9 - IIS/ICI ~g/K9 "IlL - ,.I/L ,.8IL -
~
DILUTION FACTOR 20.00 20.00 20.00 1.00 1.00 1.00
ACENAPHTHENE 199.70 0 525.40 0 320.30 0 0.900 0.075 U 0.075 U
ACENAPHTHYLENE 419.00 DU 380.70 OU 434.80 OU 0.450 U 0.450 U 0.450 U : .
ANTHRACENE 68.20 0 60.70 0 76.80 0 0.060 0.030 U 0.030 U .
BENZO(A)ANTHRACENE 255.60 0 145.90 0 337.70 0 0.720 0.045 U 0.045 U
BENZO(A)PYAENE 173.20 0 11.20 0 184.10 0 0.075 U 0.075 U 0.075 U
BENZO(B)FLUORANTHENE 166.20 D 132.00 D 147.80 D 0.045 U 0.045 U 0.045 U .
BENZO(G,H,I)PERYLENE 69.40 0 38.10 OU 110.90 D 0.045 U 0.045 U 0.045 U
BENZO(K)FLUORANTHENE 137.80 0 126.90 OU 140.00 0 0.150 U 0.150 U 0.150 U
CHRYSENE 41.90 OU 165.00 0 43.50 DU 0.045 U 0.045 U 0.045 U' .
OIBENZO(A,H)ANTHRACENE 183.00 0 126.90 DU 82.20 0 0.150 U 0.150 U 0.150 U
FLUORANTHENE 821.20 0 538.10 D 566.70 0 1.910 0.150 U 0.150 U
fLUORENE 571.20 0 318.50 D 1031.90 D 0.578 0.075 U 0.075 U
INDEND(1,2,3-CD)PYRENE 111.70 D 38.10 DU 118.30 D 0.045 U 0.045 U 0.045 U
NAPHTHALENE 419.00 DU 380.70 DU 434.80 OU 1.200 0.450 U 0.450 U
PHENANTHRENE 68.20 D 60.70 D 76.80 D 0.060 0.030 U 0.030 U
PYRENE 340.80 D 218.30 D 194.20 0 0.150 U 0.150 U 0.150 U
Total PAKI 3166.20 - 2175.80 - 3387.70 - 5.43 - 0.00 f-- 0.00 -
-------
fiELD SAMPLE NUMBER: 5\18-50.001 5\13-5\1-001 S\I3-S\I-002 S03'SO-001 503,50-002 503-50-003
EPA SAMPLE NUMBER: Sf 2500 Sf 2471 Sf 2472 Sf 2459 SF 2460 Sf 2461
DEPTH (ft) - A .,/ICI - r-O-
METALS ~I/L I&I/L 11f1/L III/ICI WIg/1C1
AU.HIIUM 321.00 340.00 261~.00 1150.00 2030.00 1480.00
ANTIMONY 49.00 U 50.00 B 4 .00 U 10.00 U 9.40 U 11 .30 U
ARSENIC 84.00 U 84.00 U 84.00 U 24.00 B 20.50 B 19.40 U
BARIUM 90.00 B 82.00 B 94.00 B 224.00 4480.00 408.00
BERYLLIUM 2.00 B 2.00 B 2.00 8 0.61 B 0.58 B 0.69 8
CADH 111M 4.00 U 4.00 U 4.00 U 0.81 U 0.96 0.92 U
CALCIUM 70800.00 49200.00 51600.00 2760.00 41200.00 3010.00
CHROMIUM 6.00 B 8.00 B 11.00 4.30 7.10 4.40
COBALT 9.00 U 9.00 U 9.00 U 2.00 8 3.10 B 2.50 8
COPPER 3.00 B 8.00 B 4.00 8 3.10 B 3.10 8 2.80 B
IRON 1220.00 743.00 1440.00 2450.00 10600.00 2210.00
LEAD 50.00 U 50.00 U 50.00 U 18.90 8 27.10 8 11.50 U
MAGNESIUM 4360.00 B 2300.00 8 2390.00 8 103.00 B 337.00 B 185.00 .
MANGANESE 208.00 102.00 110.00 52.70 221.00 34.10
NICKEL 10.00 U 10.00 U 10.00 U 5.30 8 4.20 . 3.50 .
POTASSIUM 2220.00 B 1760.00 8 2580.00 B 69.20 B 97.70 8 61.50 .
SELENIUM 143.00 B 126.00 8 105.00 B 22.20 B 30.70 B 21.20 U
SILVER 3.00 U 3.00 U 3.00 U 0.61 u 0.58 U 0.69 U
SODIUM 20100.00 7050.00 7600.00 88.90 8 373.00 8 98.60 8
THALLIUM 181.00 B 152.00 8 239.00 8 98.80 125.00 117.00
VANADIUM 7.00 B 6.00 U 6.00 B 4.50 8 6.70 8 5.80 8
ZINC 49.00 42.00 44.00 26.00 37.40 20.10
MOLYBDENUM 50.00 U 50.00 u 50.00 U 10.20 U 9.60 U 11.50 U
PHOSPHORUS 141.00 8 83.00 8 150.00 83.00 136.00 63.60
STRONTIUM 485.00 276.00 306.00 13.20 241.00 24.40
EPA SAMPLE NUMBER: SF 2468 Sf 2469 SF 2470
DIOXINS ~g/Kg jig/KI ~I/IC, - ...0-
Z378-TCOD U U U
23T8-TCOF U U U
1Z378'P8CD' U U U
12378-P8CDD U U U
Z3478'PeCOF U U U
1Z3478-HxCDf U U 0.3470 J
123678-HxCD' U U U
123478-HxCDD U U U
1Z3678-HxCDD U U U
1Z3789-HxCOD U U U
234678-HxCO' U U U
123789-HxCOF U U U
1234678-HpCD' 0.1072 J U 0.3896 J
1234678-HpCDD 0.4359 J 0.3263 J 2.D8J7 J
1234789-HpCDF U U U
OCDD 5.3465 3.8824 J 22.4049
OCD' 0.4081 J 0.2827 J 1.9734 J
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fiELD SAMPLE ~ERI $0-01-$0-001 $O-OZ-$O-OOI $0-03-$0-001 $0'04-$0,001 $0-05-$0'001 $0-07-$0-001 $0.08'$0.001 $0'09-$0-001 $0,10'$0-001
EPA SAMPLE NUMBER: Of 0180 Gf0181 Of 0193 Of 0188 010189 010190 Of om Of 0227 010228
-
DEPTH
VOA ANAlTTES (40) 0 0 0 0 0 0 0 0 Q
I1-g/Kg - - - ".g/Kg - - - I1-g/Kg - - - I1-g/Kg - - - I1-g/lI:g - - ~ I1-g/Kg - - I1-g/lI:g - r-- - I1-g/Kg - f- ~ I1-g/Kg - -
VINYL CHLORIDE - UJ - UJ . UJ UJ - UJ UJ ' UJ . UJ . UJ
1,1-DICHlOROETHENE - U.. - UJ - UJ - UJ - U.. - UJ - UJ . UJ - UJ
TRANS-I.2-DICHLOROETHENE - UJ . UJ - UJ - UJ - UJ - UJ - UJ - UJ - UJ
1.1-0ICHlOROETHANE - UJ - UJ - UJ . UJ . UJ - UJ . UJ - UJ - UJ
CIS-I.2-0ICHlOROETHENE - U.. . UJ . UJ - UJ . UJ - UJ - UJ - UJ . UJ
CHLOROFORM - UJ - UJ - UJ . UJ - UJ . UJ - UJ - UJ - UJ
'. 1, I-TRICHLOROETHANE . UJ - UJ . UJ - UJ - UJ . UJ - UJ . UJ . UJ
CARBON TETRACHLORIDE - UJ - UJ - UJ . UJ . UJ - UJ . UJ - UJ - UJ
BENZENE - UJ . UJ . UJ . UJ . UJ - UJ . UJ . UJ . UJ
1,Z-DICHLOROETHANE - UJ . UJ - UJ - UJ . UJ . UJ - UJ - UJ - UJ
TRICHLORDETHENE - UJ - UJ - UJ - UJ . UJ . UJ . UJ - UJ - UJ
BROHODICHLOROKETHANE - UJ - UJ . UJ - UJ - UJ . UJ . UJ - UJ . UJ
TOLUENE . UJ - UJ - UJ . UJ - UJ - UJ . UJ - UJ . UJ
TETRACHlOROETHENE . UJ - UJ - UJ - UJ - UJ . UJ . UJ - UJ - UJ
CHLOROBENZENE - UJ - UJ . UJ - UJ - UJ . UJ . UJ . UJ . UJ
1.1.2.Z-TETRACHLOROETHANE . UJ - UJ . UJ . UJ . UJ . UJ - UJ - UJ - UJ
ETHYl8ENZENE - UJ - UJ . UJ . UJ - UJ . UJ . UJ - UJ - UJ
8ROMOfORM . UJ - UJ - UJ - UJ . UJ - UJ - UJ . UJ - UJ
M,P-XYLENE - UJ . UJ - UJ - UJ - UJ . UJ - UJ - UJ - UJ
O'XYLENE - UJ . UJ - UJ . UJ - UJ - UJ - UJ . UJ . UJ
PAH ANALYTES (330) OF018O 0 OF01" 0 QF019JRE 0 OF0188 0 OF0189 0 OF0190 0 oF0223 0 oF02JO Q OF0229 0
ltg/Kg - - - IIg/Kg - - - lig/Kg - - - ",g/Kg - - - ",g/Kg - - - jig/Kg - - - IIg/Kg - - ~ IIg/Kg - r-- - ltg/Kg - -
NAPHTHALENE UJ 26.00 J 210.00 J UJ UJ 77.00 J 38.00 J R R
ACENAPHTHYLENE - UJ . UJ 52.00 01 54.00 J - UJ 160.00 01 n.oo J - R - R
ACEHAPHTHENE . UJ 78.00 01 460.00 01 500.00 01 - UJ 1100.00 01 530.00 01 - R - R
FLUORENE . UJ 82.00 01 570.00 01 420.00 01 - UJ 1200.00 01 630.00 01 - R 48.00 R
PHENANTHRENE - UJ 282.00 01 1700.00 01 120.00 01 - UJ 2600.00 01 780.00 01 74.00 R 230.00 R
ANTHRACENE - UJ 27.00 01 270.00 J 74.00 01 - UJ 770.00 J 290.00 01 - R - R
fLUDlAMTHENE . UJ 247.00 01 1100.00 01 1900.00 J - UJ 4300.00 J 3000.00 01 160.00 R 490.00 R
PYRENE . UJ 239.00 01 1500.00 01 3000.00 01 - UJ 4000.00 01 2500.00 01 190.00 R 590.00 R
BENZ(A)ANTHRACENE . UJ 159.00 J 450.00 01 1300.00 01 - UJ 1800.00 01 1000.00 01 210.00 R 520.00 R
CHRYSENE . UJ 136.00 01 480.00 01 1300.00 01 - UJ 1800.00 01 710.00 01 280.00 R 560.00 R
8ENZO(B)/(IC)flUORAlTHENE - UJ 384.00 01 670.00 J 2100.00 J - UJ 3000.00 J 1600.00 01 590.00 R 990.00 R
BENZO(A)PYRENE . UJ 151.00 01 370.00 01 820.00 01 - UJ 1600.00 J 630.00 01 660.00 . 700.00 R
INDENO(I.2.3'CO)PYRENE . UJ 102.00 01 250.00 01 560.00 01 . UJ 1200.00 01 530~00 01 360.00 R 650.00 R
018ENZ(A,H)ANTHRACEHE - UJ - UJ 68.00 01 3Z0.OO 01 . UJ 4600.00 01 110.00 01 . R 130.00 R
BENZO(G,H,I)PERYlENE - UJ 13'.00 01 ao.oo 01 460.00 01 - UJ 1000.00 01 370.00 01 310.00 R 600.00 R
8(A)P Equlvatenc. C-. 0 - 217 - 580 - 1549 - 0 - 6818 - 1061 - 785 - 1052 -
Total PAHa 0 - 20106 - 9040 - 12928 - 0 i-- 29207 I-- 12850 - 2894 - 5508 -
PHENOl ANAlYTES (l700t OfOllORE G Of0181RE 0 Of 0193 0 Of 0188 Q Of 0189 0 Of 0190 0 010223 Q QF0227RE Q Of0228RE 0
IIg/lCg I1-1I/Kg - - - /Io1I/lCg - - - /Iog/lCg - - - I1-g/Kg - - '- /Iog/lCg - --- ~ I1-s/lCg - - - IIg/Kg - - - /Io8/Kg - -
PHENOl. - UJ - UJ . UJ 2.70 01 . UJ - UJ - UJ - UJ - UJ
Z'CHLOROPHEIIOL 170.00 J - UJ 60.00 J 37.00 01 . UJ . UJ 1200.00 J 60.00 01 130.00 J
O-CRESOL - U" - UJ . UJ 7.10 . . R . R - UJ . UJ - UJ
M/P'CRESOL . UJ - UJ . UJ 3.20 R . UJ . UJ 290.00 01 . UJ 97.00 J
2-IIITROPHENOL . UJ - UJ 65.00 R . UJ . UJ . UJ . UJ . UJ - UJ
Z.4-0IME'"YlPHENOl - U.. - UJ 24.00 . 40.00 R - UJ . UJ - UJ - UJ . UJ
2.4'DICHLOROPHEIIOL 690.00 J 490.00 J . UJ . UJ - UJ . UJ 430.00 01 810.00 J 450.00 01
4-CHLORO-3-METHYLPHENOL . UJ . UJ 12.00 R 14.00 . - UJ - UJ . UJ . UJ - UJ
2.4.5/6'TRICHLOROPHENOL . UJ . UJ 3.00 R 1.70 R - UJ . UJ '- UJ 460.00 R 570.00 01
Z.4-011lITROPHEIIOL . UJ . UJ 32.00 R . R . R . R . R - UJ . UJ
4-IIITROPHENOl . UJ - UJ . UJ . . . UJ . UJ . UJ 120.00 01 . UJ
2,3.4,6'TETRACHLOIOPHEIIOL 450.00 J 380.00 01 . UJ 48.00 01 '62.00 R . UJ . UJ 760.00 01 420.00. 01
4.6-D.NtTRO-Z'MET"YLPHENOL . U.I . UJ . UJ - UJ . R . R . R 87.00 R . R
-------
FIELD SAMPLE NUMBER. W-01-W-OO' SV-02-SV-001 SV-03-SW-00' W-eK-W-001 W.OS-W-001 W-06-SV-001 w-oa-W.OO1
EPA SAMPLE NUMBER: OF0184 OF0183 OF0197 OF0186 OF0187 OF0203 OF0224
DEPTH
~ ANALYTES (20) 0 0 sa 0 0 Q a
,.g/L "g/L ,.g/L jlg/L IIg/L ,.g/L "g/L - -
VINYL CHLORIDE - UJ - UJ - UJ - UJ - UJ - UJ - UJ
1,1-DICHLOROETHENE - UJ - UJ - UJ - UJ - UJ - UJ - UJ
TRANS-',2-DICHLOROETNENE UJ UJ UJ UJ I - UJ - UJ - UJ
- - - -
1,1-DICKlOROETHAME - UJ - UJ - UJ - UJ . UJ - UJ - UJ
CIS-1,2.DICHLOROETKEIE - UJ - UJ . UJ - UJ . UJ - UJ - UJ
CHLOROFORM - UJ - UJ - UJ - UJ - UJ - UJ - UJ
1,1,1-TRICHLOROETHANE - UJ - UJ - UJ . UJ . UJ - UJ - UJ
CARBON TETRACHLORIDE - UJ - UJ - UJ . UJ . UJ . UJ - UJ
BENZENE - UJ - UJ - UJ . UJ . UJ . UJ - UJ
1,Z-0ICHlOROETHANE - UJ - UJ - UJ - UJ . UJ - UJ . UJ
TRICHLOROETHENE - UJ - UJ - UJ - UJ . UJ - UJ - UJ
BRDMODICHlOROMETHAHE - UJ - UJ - UJ . UJ . UJ - UJ - UJ
TOLUENE - UJ - UJ - UJ - UJ . UJ - UJ . UJ
TETRACHLOROETHENE - UJ - UJ - UJ - UJ . UJ - UJ . UJ
CHLOR08ENZENE - UJ - UJ - UJ - UJ . UJ - UJ - UJ
',',Z,Z-TETRACHLOROETHANE . UJ . UJ - UJ - UJ . UJ - UJ - UJ
ETHYLBENlENE - UJ - UJ - UJ - UJ - UJ - UJ - UJ
BRlKlfOR" - UJ - UJ . UJ . UJ . UJ - UJ . UJ
",P-XYlENE . UJ - UJ . UJ . UJ . UJ - UJ - UJ
O-XYLENE . UJ - UJ - UJ . UJ . UJ 15.00 J - UJ
PAH ANALYTES (20) Gf0184 0 Of 0183 0 Of 0191 0 OF0186 Q OF0181 Q OfOZO]RE 0 GFOZZ' 0
jlg/l "all "g/L jla/L "g/L "g/L ".g/L - -
NAPHTHALENE - UJ - UJ - UJ . UJ - UJ - UJ - UJ
ACENAPHTMYLENE - UJ - UJ - UJ . UJ . UJ - UJ - UJ
ACENAPHTHENE - UJ - UJ - UJ . UJ . UJ - UJ - UJ
FLUORENE - UJ - UJ - UJ . UJ . UJ - UJ - UJ
PHENANTHRENE - UJ - UJ - UJ - UJ - UJ - UJ ' - UJ
ANTHRACENE - UJ - UJ - UJ . UJ . UJ - UJ . UJ
flUORANTHENE - UJ - UJ - UJ . UJ . UJ . UJ - UJ
PYRENE - UJ - UJ - UJ - UJ . UJ - UJ . UJ
BENZCA)ANTHRACENE - UJ - UJ - UJ . UJ . UJ . UJ - UJ
CHRYSEIIE - UJ - UJ - UJ - UJ . UJ . UJ - UJ
BENZO(B)/(K)FLUORANTHENE - UJ - UJ . UJ - UJ . UJ - UJ - UJ
BENZOCA)PYAEHE - UJ - UJ - UJ - UJ . UJ . UJ - UJ
, INOENOct,2,3-CO)PYRENE - UJ - UJ - UJ - UJ - UJ . UJ - UJ
DIBEN1CA,H)AIITHRACEIIE - UJ - UJ - UJ . UJ - UJ - UJ . UJ
BENZOCG,H,I)PERYLENE - UJ - UJ - UJ . UJ - UJ - UJ - UJ
SCA)P Equlvs'enc. c-. 0 - 0 - 0 - 0 - 0 - 0 - 0 -
Tots' PAH. 0 - 0 - 0 - 0 -. 0 - 0 - 0 -
PHENOl ANAlYTES (50) OF0184 Q OF0183 Q Of0197 0 OF0186 0 OF0187 Q OF0203 0 OFOZZ4 Q
,.g/L ,.g/L "g/L "./L ,.,/L "g/L "g/L - -
PHENOL - R - R - . - UJ - UJ - R - UJ
2-CHLOROPKENOL - R . R . UJ - UJ - UJ - UJ - UJ
O-CIIESOL - R - R . UJ . UJ - UJ - UJ - UJ
8I'P.CIIESOL . - R . R . UJ . UJ - UJ - UJ - UJ
2-NITROPHENOL . R - II - UJ - UJ - UJ - UJ - UJ
2,4-0IMETHYLPHEIOL . R - II . UJ - UJ . UJ - UJ - UJ
2,4-0ICHLOROPHEIIOL . R - R . UJ - UJ - UJ . UJ . UJ
4-CHLORO-'-METHYlPHENOL - R - R - UJ - UJ . UJ - UJ - UJ
2,4,5/6.TRICHLOROPHEIIOL . R - R . UJ - R . R . UJ . UJ
2,4-011lITIIOPHENOL - R - R - R - " . R . R . R
4-NnROPtIENOL - R - A - UJ - UJ . UJ . UJ . UJ
2,3,4,6-TETAACHLOROPIENOL - II . R - UJ 99.00 J 140.00 J . UJ . UJ
4,6.DIIIITRO-Z-METNYl'HENOL - II . R - UJ . UJ . UJ . UJ - UJ
PENTACHLOROPHENOL . R - R 68.00 J . UJ . UJ - UJ - UJ
FIELD SAMPLE NUMBER: 5011-50-001
EPA SAMPLE NUMBER: Sf Z901
DEPTH eft) I&a/I(g -r-O-
BHA
DILUTION FACTOR 10.00
bfsC2-CHLOROETHYLJETHER 120000.00 U
1,]-DICHLOROBENZENE 120000.00 U
"4-0 ICHLOROBENZENE 120000.00 U
1,2-0ICHLOROBENZENE 120000.00 U
2,2'-oxybls(1-CHlOROPROPANE) 120000.00 U
H-NITROSO.OI.N-PROPYLAMINE 120000.00.U
HEXACHOLORETHANE 120000.00 U
NITROBENZENE 120000.00 U
ISOPHORONE 120000.00 U
bll(2-CHLOROETHOXYJMETHANE 120000.00 U
1,2,4-TRICHLOR08ENZENE 120000.00 U
NAPHTHALEHE 77000.00 J
4-CHLOROANILINE 120000.00 U
HEXACHLOROBUTADIEHE 1Z0000.00 U
Z-METHYLHAP"T"ALENE 62000.00 J
HEXACHlOROCYClOPENTADIENE 120000.00 U
2-CHLORONAPHTHALENE '20000.00 U
2-HITROANILINE 300000.00 U
DIMETHYLPHTHAlATE 120000.00 U
ACENAPHTHYlENE 5300.00 J
3-NITROANILINE 300000.00 U
ACENAPHTHENE 76000.00 J
DIBENZOFURAN 77000.00 J
2,4-DINITROTOLUENE 120000.00 U
2,6-0INITROTOLUENE 120000.00 U
DIETHYLPHTHALATE 120000.00 U
4-CHLOROPHENYl PHENYlETHER 120000.00 U
FLUORENE 72000.00 J
4-NITROANILINE 300000.00 U
N-NITROSOOIPHENYLAMINE 120000.00 U
4-BROMOPKENYl-PHENYlETHER 120000.00 U
HEXACKLOR08ENZENE 120000.00 U
PHENANTHRENE 290000.00 J
ANTHRACENE 42000.00 J
CARBAZOLE 7300.00 J
DI-N-BUTYLPHTHALATE 120000.00 U
FlUORANTHENE 260000.00 J
PYRENE 210000.00 J
BUTYlBEHZYLPHTHALATE 120000.00 U
3,3'-DICHLOROBENZIDINE 120000.00 U
BEN10(AJANTHRACENE 48000.00 J
blsCZ-ETHYLHEXYL)PHTHALATE 120000.00 U
CHRYSENE 53000.00 J
DI-.-OCTYlPHTHALATE 120000.00 U
BEN10(B)FlUORAHTHENE 23000.00 J
BEN10CKJFLUORANTHENE 39000.00 J
BEN10(AJPYRENE Z2000.oo "
INDEHOC1,2,3-COJPYRENE 120000.00 U
DI8EHZO(A,H)ANTHRACENE .120000.00 U
BEN10CG,H,IJPERYLENE 120000.00 U
Toul PAHs 1217300.00 -
-------
APPENDIX D
AMERICAN CREOSOTE WORKS, INC.
SUBSURFACE SOIL ANALYTICAL SAMPLING
-------
fIELD SAMPLE NUMBEII: "'-OD-SS-001 "'-03A-SS-002 ""-04-$$-001 "".04-$$.002 ""-05-S5-OO1 "".05.$$-OOZ "".06.SS-001 ",,-06.SS.oo2 ",,-07.$$-001 MV-07.$$.OO2
EPA SAMPLE NUK8EII: Of 0198 OFO'" Of 0209 OFOZ'O Of 0211 OF02'2 OF0201 oF02oa OF0303 OF0305
OEPTH 0-10' 15' 5' 15' 0-10' 2-5' 1-10' 15' 0.'0' 19'
VOA ANAlYTE$ (40) 0 0 0 0 0 Q 0 0 0 0
,g/lCg - i-- ~ ,g/Kg - ~ - ,g/Kg - - - ,.g/K, - - ,.g/Kg - i-- ~ ,.,/Kg - I-- - ,.g/lCg - - - ,.gIKg - - 119IK9 - i-- ~ J9/Kg - -
VIIIYL CtIUIRIDE - UJ - UJ - UJ - UJ - UJ - UJ UJ UJ - UJ . UJ
1,1-DICHLOROETHENE - UJ - UJ . UJ . UJ - UJ . UJ . UJ . UJ - UJ - UJ
'AANS.',2.DICHLOROET.rN£ - UJ - UJ - UJ - UJ , - UJ . UJ . UJ . UJ . UJ - UJ
1,1-DICNLOIDE'HAN£ . UJ - UJ - UJ . UJ - UJ - UJ . UJ . UJ - UJ . UJ
CI$-1,2-0ICHLOROETHENE - UJ - UJ . UJ - UJ - UJ - UJ . UJ - UJ - UJ . UJ
CHLOROFORM - UJ - UJ - UJ - UJ - UJ . UJ . UJ - UJ - UJ - UJ
1,1,1-TRICHLOROETHANE - UJ . UJ - UJ - UJ - UJ - UJ . UJ . UJ - UJ . UJ
CARBON TETRACHLORIDE - UJ - UJ - UJ - UJ - UJ . UJ - UJ . UJ - UJ - - UJ
BENZENE . UJ . UJ 21.00 J 180.00 J 29.00 J 24.00 J 120.00 J 790.00 J - UJ - UJ
1,Z-DICKlOROETHAlE . UJ - UJ - UJ - UJ - UJ . UJ - UJ - UJ . UJ - UJ
TlICHLOROETHENE . UJ - UJ . UJ - UJ - UJ - UJ . UJ - UJ - UJ - UJ
BROMOD I CHLOROMETHANE . UJ - UJ - UJ - U" - UJ - U" . U" - U" - UJ . UJ
TOLUENE - UJ . UJ 76.00 J 630.00 J 25.00 .I 18.00 J 230.00 J 1200.00 .. . UJ . UJ
'£'RACHLORDE'HEN! - UJ . UJ . UJ - UJ - UJ - UJ - UJ - UJ . UJ - UJ
CHLOR08ENZENE . UJ . UJ - UJ . UJ - UJ . UJ . UJ - UJ . UJ - UJ
1,1,2,2-TETRACHLOROETHANE . UJ . U" . UJ - UJ - UJ - UJ - UJ - UJ . UJ . UJ
ETHYl8ENZENE . UJ . UJ 350.00 J 400.00 J 100.00 J 550.00 J 290.00 R 590.00 R . UJ - UJ
8ROHOFOR" . UJ . UJ - UJ - UJ - UJ - UJ . UJ - UJ . UJ - U"
",P-XYLENE . U" - U" 190.00 J 1100.00 J ".00 J . UJ 340.00 J 1200.00 J . UJ . UJ
O.XYLENE . UJ - UJ 50.00 .. 610.00 .. 1200.00 .. 55.00 .. 150.00 II 970.00 II . UJ . UJ
PAH MAU'E' (330) Of 019811£ 0 Of01911R£ Q OF0209 Q 0'OZ10 Q OF0211 0 OF0212 0 0'0207 Q OF0208 0 OF0304 0 OFOS06 0
,.g/K. - - - ,.g/Kg - - - ,.g/Kg - - - ,.g/lCg - - - 1II/1t, - - - "g/Kg - - ,.g/Kg - - - "g/Kg - - - ,.g/Kg - - flog/Kg - -
NAPHTHALENE 130.00 J UJ 30000.0 R 120000.0 J 101000.0 J UJ 260000.0 J - R . UJ . UJ
ACENAPHTHYlENE 9000.00 J . U" 8300.0 II 28000.0 .. 9200.0 .. . UJ 19000.0 J 82000.0 R . UJ - UJ
ACENAPH'HENE 110000.00 J . UJ 91000.0 R 61000.0 J 170000.0 J . UJ 240000.0 J . R - UJ 70.00 ..
fLUORENE 16000.00 J . UJ 300000.0 II - UJ 270000.0 R 120.00 J - UJ 75000.0 R . UJ 50.00 J
PHENANTHRENE 22000.00 J . UJ - It - U" 40000.0 .. 390.00 .. . UJ 380000.0 R 38.00 R 110.00 J
AN'HRACENE 28000.00 J . UJ . R - UJ - UJ 120.00 J 1080000.0 J - R . UJ . UJ
FlUORANTtlENE 7500.00 J . UJ . R - UJ . UJ 150.00 J . UJ 210000.0 R 180.00 J 80.00 ..
PYRENE 12000.00 .. . UJ 14000.0 R 23000.0 J 17000.0 J 110.00 J 22000.0 .. - R 220.00 J 16.00 J
BENZCA)AIITHRACENE - u" - UJ . R - UJ - UJ - UJ - UJ - II 11.0.00 J 52.00 J
CIIRTSENE 4000.00 .. - UJ 96000.0 R - UJ 84000.0 II - UJ - UJ 19000.0 II 180.00 J 44.00 J
8EIIZO(8)/CIt)flUORAlTHENE 1700.00 R - UJ . It 300.0 UJ . UJ - UJ . UJ 39000.0 II 190.00 J 50.00 J
8ENZOCA)PYRENE 10000.00 " - UJ 26000.0 I 34000.0 J 25000.0 R . UJ 30000.0 R . R 110.00 J . UJ
,IWENO( 1.Z,3-Q»)PfltEIIE 4500.00 J . UJ - I 3tooo.0 I - U.. - UJ - UJ 23000.0 R . UJ . UJ
DIIENZ(A.H)ANTHRACENE 8ZOO.GO J . UJ 26000.0 R - u,/ 23000.0 R . UJ 22000.0 " - R - UJ - UJ
IENZO(G,H,I)PEIIYLEME 2700.00 " 100.00 J - II 25000.0 J - UJ - UJ . UJ 11000.0 II - UJ . UJ
ICA)P Equlv.lence Cone. 18860 - 0 - 5Z960 - 37130 - 481140 - 0 - 52000 ~ 6390 '- 145 - 11 -
Tot.I PAH- 139730 - 100 - 591300 '- 322300 :'- 679200 - 890 - 1073000 - 8J90oo I-- 1058 - 532 -
PHEIIOt. ANAl"ES (1700) OF0198 0 OF0199 Q OF020911E 0 oF021ORe 0 OfOZURE 0 Of 0212 0 Of0201IE 0 OF0208RE 0 OF0303 0 OF0305 Q
IIII/lCg - - -",/K, - - IIS/K, - - - IltlKI - - - ""ltg - - - ,../Kg - - - "tlKg - - "g/lCg - - "O/lCg - - - ,.g/Kg - -
PII£NOL - UJ 390.00 . UJ UJ UJ UJ 17000.0 J - UJ 980.00 . 910.00 It
Z-CHLOICI'HENOL 44.00 J - UJ . 990.00 J 2000.00 J 1700.0 .. 1600.00 J 1300.0 J 97000.0 .. 260.00 .. 280.00 ..
O.ClESOL 5.00 . - UJ - UJ 2500.00 J 39_0. J 63.00 J 9300.0 J 35000.0 J - UJ - UJ
NlP-CiESOL 3.00 .. - UJ 620.00 .. 5200.00 J 700.0 J - UJ 26000.0 J . W 140.00 . t8O.oo .
2-II.T"".- - J - UJ - U" - UJ - UJ - U" . UJ - UJ . UJ 66.00 J
2,4-DIME'KYLPIEIIOL 29.00 . - UJ - UJ 9200.00 .. . UJ . UJ 12000.0 J 42000.0 J 220.00 J 110.00 J
2,4-D.CHlOIOPIEIIOL - UJ - UJ - UJ - UJ 260.0 .. . U" . UJ - UJ 57.00 .. - W
4-CIILOIO-S.IIITIIYLPtIEa. 15.00 R - UJ 3700.00 .I 210.00 J 90.0 I - UJ ZOOOO.O .I 650.0 J -' U" - UJ
Z,4,"~T..CHlOlOPHEIIOt. 3.00 . 190.00 .. 100.00 .. 1100.00 .. 300.0 J - UJ 930.0 .I 2000.0 J 380.00 J 220.00 J
Z,4-DIII.TROPHEIDL 35.00 . - UJ 1600.00 . 4500.00 I 2800.0 II . II 8900.0 . 47000.0 . - UJ - UJ
4..nlOPllElIOL 8.00 . . W 1300.00 J 3700.00 .I 1800-0 ,/ . UJ 4900.0 J 15000.0 J . UJ - UJ
2,3,4,6-T~'IACNLOIOPI!NOL 63.00 . 1200.00 .. 2700.00 J 7000.00 . 6500.0 .. 54.00 .. 24000.0 .. 14000.0 J - UJ - UJ
4,6-011l.T.0-2-IIITHYLPHENOL 42.00 . - . 2200.00 . 5300.00 I Z700.0 II - UJ 13000.0 . 40000.0 . - UJ - UJ
-------
FIELD SAHPLE ~EI: "'-01-S5.001 ,.,-01.55.00Z ..,.01A.SS.001 "'.01A.SS-OOZ ..,.02.SI.001 '''.02-SI-002 MY.OlA.SS.001 "'-OlA-SS.ODZ "'-0]-SS-001 "'-0].".002
EPA SAHPLI NUMlEII Of029J ci,om a,om a'02f1 Qfom Qf0269 Qf0205 a'0206 Of 0265 0'0301
DEPT' ]6' 51' 0.10' 31.]5' 51' 0.10' 15' 32' 51'
VOA AMALYTES (40) a 0 0 Q 0 Q Q Q 0 0
IIlIIltl - - i- 1Ig/1t1 - - - 111'''1 - - - JII'" - ~ i- II,/r, - i-- ,.. J./I, - - - 1111"1 - - - J.,rl - - 11111"1 - - I- ,.IK. - :....-
VltlYL CHLORIDE Uol U.I Uol . Uol . Uol Uol . Uol . UJ . UJ . UJ
1,1-DICMLOROETHEME . Uol . U.I . U.I . Uol . Uol . Uol . Uol . UJ . UJ . UJ
TIAtIS.1.Z.DICKLOROETHEME . W . U.. . Uol . U.. . U.. . U.. . UJ . Uol . UJ . UJ
1.1.DICNLOIOETHANE . UJ . UJ . U.. . UJ . UJ . UoI ' . UJ . UJ . W . Uol
CIS.1.Z.DICMLaIOETKENE . UJ . UJ . W . U.. . UJ . Uol . Uol . UJ . Uol . UJ
CKLOIOfOUl - UJ . UJ . W . UJ . U.I . U.I . UJ . Uol . Uol . UJ
1.1.1.TRICHLOROETIAME - W . UJ . W . UJ - UJ . UJ . UJ . UJ - UJ . W
eMBOlI TETItACllLOIIDE . Uol . UJ . UJ . UJ . UJ . UJ . UJ - UJ . UJ . W
BEItZEItE W UJ UJ UJ I UJ . Uol 13.00 J . UJ - Uol . UJ
. . . - .
1,Z.OICKlOROETKAME . Uol . U.I . W . U.I - UJ . UJ . Uol . UJ . UJ . U.I
TlIlCHLOROEfHENE - UJ . UJ . UJ . UJ - U.I . UJ . U.I . W . U.I . U.I
BRONODICHLOROHETHAtlE . UJ . UJ . Uol . UJ . UJ . Uol . U.I . U.I . U.I . U.I
TOLUENE . UJ . U.I - W . U.I . UJ . UJ 89.00 .I . UJ - U.I - W
TETIIACHLOROETKEtIE . Uol . UJ . Uol . Uol . U.I . UJ . U.I . U.I . U.I . U.I
CHLOII08EtlZENE . W . UJ . Uol . U.I . UJ . Uol . UJ . UJ - UJ . UJ
1.1,2,Z-TETItACIILOIOETKANE . Uol . UJ . Uol . U.I . UJ . U.I . Uol . U.I . Uol . Uol
EfHYLBEtlZEME . U.I 320.00 01 . Uol . Uol - U.I - U.I 70.00 A - A . UJ - U.I
BROMO'ORM . Uol . UJ . U.I . U.I . U.I . Uol . U.I . UJ - UJ . U.I
",P-XYLENE . UJ . U.I . UJ . UJ . U.I . Uol 220.00 01 5.00 01 - UJ . UJ
O-XYLENE - UJ . UJ - W - U.I - UJ . Uol 110.00 R 100.00 R 110.00 .I - W
PAK ANALYTES e]30) 0,0294 0 0'0296 0 O,OZ99 0 0.0300 0 Of 0234 0.0270 Q 0.0205 0 OF0206 0 0.0266 0 0.0302 0
11.,1, - - i- lIg/r, - - - III/r, - - JI/". - ~ i- 1111/1(11 - i-- ,.. l1li11(1 - - -1I9/Kg - - 119/KII - - t- 1111/"11 - i-- I- II.IKI - -
IlAPHTMALEME . UJ . UJ - Uol U.I A UJ 80000.0 .I 25000.00 01 - Uol . Uol
ACEtlAPHTHYLEII£ - Uol . UJ . Uol . UJ . A - UJ 8200.0 01 1100.00 01 - UJ - UJ
ACEHAPHTKEME 380.00 .I 390.00 01 . UJ - UJ - I 200.00 .I 98000.0 01 22000.00 01 . UJ - UJ
.LUOREIIE 260.00 01 330.00 01 . Uol . UJ 910.00 R . I 120000.0 01 27000.00 01 78.00 01 . UJ
'MEMAII'HIEME . 360.00 . 280.00 R . UJ . UJ 6700.00 I . UJ - UJ 85000.00 01 160.00 01 . UJ
ANTMItACEIIE 110.00 01 . UJ . Uol - UJ 4600.00 R - UJ ]70000.0 01 9000.00 01 - UJ - UJ
fLUORAIITMEME 60.00 .I 41.00 01 - UJ . UJ 3000.00 R . UJ . UJ 41000.00 01 45.00 01 - w
PYIEIIE 45.00 .I . UJ . UJ . UJ 1600.00 R . UJ . UJ 28000.00 01 . UJ - UJ
BENZCA)ANTNRACEHE 54.00 01 . UJ . UJ . UJ 460.00 R - Uol 29000.0 R 7100.00 01 - UJ . UJ
CHRYSEIIE 50.00 . - UJ - UJ . UJ 480.00 I . UJ 27000.0 I 6100.00 01 . UJ - UJ
BEIIZOel)/CI)'LUOIANTKEIIE . Uol . UJ . UJ . UJ 120.00 R . UJ 25000.0 01 5200.00 01 . UJ . W
IEIIZOCA)PYlENE . W . UJ . UJ . UJ 81.00 R . UJ 12000.0 A 2600.00 01 230.00 01 . UJ
IMDElIOe1,Z,3-CO)PYRENE . Uol . UJ . UJ . UJ . I . UJ 5400.0 I 1500.00 01 490.00 01 . UJ
DIIEItZCA,H)AIITHRACENI - UJ . U.I . U.. . U.. - II . Uol 2500.0 R 800.00 01 . UJ . W
IEIIZO(G,N.I)PERYLEIIE - Uol . UJ . UJ . U.. . II . UJ 4600.0 II 1300.00 01 400.00 01 - UJ
leA)' EquIvalence CGnc, 6 - 0 - 0 - 0 i-- 144 i-- 0 - 20710 - 4841 - 279 i-- 0 -
Tota' PAIl. 131' - 1047 - 0 - 0 i-- 17951 :""- 200 - 781700 - 262700 - 1403 i-- 0 -
PKEIIOL ANALYTES (1700) QF0293 0 Qf0295 Q Of 0298 0 OF0297 0 OF02URE 0 OF0269 0 0'0205 0 0'0206 0 0'0265 0 OF0301 Q
IIl/rl - - i- ~g/rll - - 119/ICI - - I- JII/ICII - i-- i- 111/11 - i-- - ""'" - - - ,,/KI - - ,..IK. - - t- Jl/r. - f- I- ,.g/K, - -
PKEIIOL W 50.00 01 1000.00 II R 4].00 .I 760.00 01 UJ . UJ 110.00 J 850.00 .
Z-CHLORII'HEIIOL 570.00 .I 220.00 01 290.00 .I 1300.00 01 150.00 01 - UJ 280.00 01 940.00 01 1300.00 oI 210.00 ~
O-CRESOI. . UJ . UJ 22.00 01 31.00 01 . UJ . UJ - UJ . UJ . UJ . UJ
",,-caESOL . W Z40.oo ~ 31.00 R 190.00 I 73.00 .I - I . UJ 360.00 01 480.00 01 66.00 .
Z-"TIOPIlEIIOL . Uol . UJ - UJ 65.00 01 - W - . - U.. . U.. - UJ - UJ
2.'.DIMET'YLPHENOl - UJ . UJ '60.00 01 180.00 J . UJ - R - UJ . Vol . UJ 190.00 .
Z.'-DICllLOIOPIIEJIOL . W . UJ 51.00 01 45.00 ~ - U.. . UJ 110.00 oI . Uol . Uol 110.00 UJ
'.ClLORO.J.METIYLPHENOL . UJ . W . UJ - UJ . UJ - U.I "00.00 01 78.00 J . UJ - UJ
Z.',5/6-TIICHLOIIOPIEIOL - W 740.00 R 440,00 .. 190.00 J . UJ . UJ . UJ . UJ . UJ 170.00 01
Z.4.DIIiITIOPNEIOL - UJ . Uol . UJ - UJ - U.I - UJ 950.00 II - R . I . W
,-.nIOPHEIIOL . UJ . W . UJ . UJ 57.00 01 67.00 01 880.00 01 . UJ . U.. . UJ
2,3,4,6-'ETaACHLOIIOPNENOl . U.. no.OO J 33.00 01 . UJ 680.00 J . 150,00 01 500.00 01 510.00 J . UJ . UJ
4,6.0INITIO.Z-MET"YLPNEIOL . UJ . UJ . W . UJ . . . UJ 500.00 I 110.00 I - U.. . Uol
-------
flELO SAMPLE NUMBER: 1.-09.SS-002 11I-10'S$,001 I.' 11'SS.oo1 8H'12'$S.001 8,-1]'SS-001 811'1"-S5-oo1 1,-\4'SS,002 8.'''''SS.001 81"'5-55-001
EPA SAMPLE NUMBER I 0,OZS5 O,onz o'On7 0'02" o,02lo) 0'0259 0'0261 0'0263 0'0231
OEP1H 9.5' 5' 5' 5' 5' 0.10' 10'14.5' 18,21' 4-5'
VOA MAU'ES (40) 0 0 0 0 0 0 0 0 0
_g/I, - - - ,.gllg - - - .gll, - '- f- _Jl/Kg - i-- f- I&,,/K. - - N/lg - - I- I&gllg - - - I&g/Kg - - - I&,,/Ig - -
YIlIfI. CIILClIUO& - Uti . Vol . Uti . UJ . UJ Uti UJ UJ UJ
1,1-0ICHLOROE'N181 - U.I . U.I . . U.I - U.I - U.I - U.I - U.I - U.I - U.I
1RAMS.1.2.0ICHLOR0E11E1E . UJ . UJ . UJ . UJ I. UJ - UJ - UJ - UJ . UJ
1,1-0ICIILOROETKAIE . UI . UJ - UJ . UJ . UJ - U.. - UJ - UJ - UJ
CIS-I.2'DICHLCllOETIEIE - U.I - UJ - U.I - UI - U.I - U.I - U.I - U.I - U.I
tlllOllOfORlt - UJ . UJ . UJ . UJ - UJ - UJ - UJ - UJ . UJ
1,1,1-'RICHLCllClETNAN! - U.I - UJ . UJ . UJ . UJ . UJ . UJ . UJ - UJ
tAJlOM TETRACHLOIIOE - U.I . UJ . UJ . UJ - U.I - U.I . UJ - UJ - UJ
8£IIIEIiE . UJ 24.00 01 . UJ . UJ . UJ 150.00 01 65.00 01 24.00 01 . UJ
1,2-0ICHLOIIOETHANE - U.. . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ
TRICHLCllOETHENE - UJ - UJ - UJ . UJ . UJ . UJ . UJ . U.I . UJ
BRDMOOI CHLOR0HE1MANE - UJ . UJ . UJ . UJ . UJ . UJ - UJ . UJ - UJ
TOLUENE 9.40 01 270.00 J . UJ . UJ . UJ 410.00 01 81.00 01 32.00 01 - UJ
TETIACHLORDETHEIIE . W . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ
CHLOII08ENZENE - W . UJ . UJ . UJ . UJ . UJ . UJ . UJ . UJ
1,1.2,2-TE'RACHLOROETHANE - U.I - UJ - UJ - UJ - U.I - UJ - UJ - U.I - U.I
E1HYl8ENZENE 39.00 01 550.00 01 - UJ - UJ - UJ 290.00 01 36.00 01 - UJ . UJ
BII(ItO'OM . UJ . UJ - U.. . UJ . UJ - UJ . UJ . UJ . UJ
..,P-IIYlENE 100.00 .I "00.00 .I - U.I . U.I . UJ 550.00 .I 61.00 .I 470.00 J . UJ
O'XYlEIiE 52.00 01 640.00 01 740.00 01 . UJ . UJ 350.00 01 1800.00 01 180.00 01 . UJ
PAN MAL"ES (330) 0'0256 .0 O,OZS1 Q 0'0258 0 OF0246 Q OF0245 0 0'0260 0 0'0262 0 QF0264 a 0'0232 a
IIII/ICI - ~ I- III/KI - i-- I- jl9/KI - - - III/Kg - - - III/Kg - f-- - 1III/r:1 - - - I&,,/ICI - - - I&I/KI - - - I&"/KI - -
NAPHTHALENE 6000.00 J Z8OOO.oo .l UJ II R 58000.0 01 2600.00 .I 130.00 J R
AtEllAPHTNYlENE 770.00 01 850.00 J . UJ - II . R 6100.0 01 760.00 01 . UJ . R
ACEIlAPIITHEIIE 6000.00 J 16000.00 J . UJ - 1 - R 64000.0 01 1400.00. J 150.00 J - R
fLUCIIENE 6000.00 J 2ZOOO.oo 01 - UJ - It - R 57000.0 .I 2000.00 .I 180.00 .I - R
PHENAN1HRENE 21000.00 01 18ODO.00 01 80.00 01 . R . R 100000.0 01 5700.00 01 470.00 J - R
ANTHRACENE 3000.00 J 12000.00 01 . UJ . R - R . UJ 5600.00 01 92.00 J . R
'LUORAII'HEIIE 12000.00 J 25000.00 01 170.00 J . R - R 100000.0 01 2700.00 J 150.00 01 . R
"RENE 10000.00 J 19000.00 J 150.00 01 . R - R 54000.0 .I 2100.00 01 93.00 J - R
BENZ(A)ANTHRAtENE 3000.00 01 5700.00 J - UJ - R - R 97000.0 01 590.00 J . UJ . R
CHRYSENE Z9OO.00 J 4900.00 J . UJ . 1 - R 330.0 01 640.00 J - UJ . R
BENZO(I)/(I)FLUOIAITNEIE 3900.00 J 10000.00 J 70.00 J . 1 . R 65000.0 01 6900.00 01 . UJ . R
BEIIZO(A)PYREIIE 2100.00 tI 2500.00 1 260.00 J . R - R 36000.0 01 11000.00 J 1300.00 01 . R
IIIDENG(1,2.3'CO)PYlEIE 1200.00 01 '000.00 . . UJ . 1 - R 12000.0 01 3200.00 01 1100.00 01 - R
DIIEIIZCA.")ANTHRACE.E 240.00 01 300.00 1 . UJ . R - R . UJ 690.00 01 230.00 01 . R
BENZO(G.",I)PERYLENE 1000.00 J 880.00 1 . UJ . R . 1 12000.0 J 3000.00 J 780.00 01 . R
I(A)' Equivalence Cane. 3179 - 4519 - 267 - 0 '- 0 - 53403 - 12165 - 1640 - 0 -
Total PANs 79110 - 186130 - 730 - 0 -- 0 - 661430 - 48880 - 4675 - 0 -
'"EIIOL AllALnEI (1700) a,OZS5 Q OF0Z52 0 aF02S7 a aFOZ44RE Q o,02431E 0 aF02S9 0 aF0Z61 Q Qf0Z63 a aF02311E Q
1&8111 - i-- f- N/lCI - ~ I- I&g/II - i-- I- I&./ICI - - I&tlKI - I- - I&g/KI - - ,l/lCg - f-- I- 119/1C1 - f-- ... I&I/ICI - -
'HEIIOL Uti - 1 54,00 J .. UJ - UJ 1100.0 J . UJ 60.00 01 . UJ
2-CHLORCIPHEIICIL 1300.00 J 750.00 . . Uti 200.00 J 150.00 01 3200.0 01 1600.00 01 1800.00 01 120.00 tI
O-CiESOl - UI SOD.OO . . w . UJ - UJ . UJ 810.00 .J 690.00 J - U.I
",'-CI£ICIL . 270.00 01 440.00 R 240.00 01 110.00 J - UJ 6100.0 01 1700.00 J 1000.00 J - UJ
2'1 I 1IOPIIEIIOL . Vol . . . UJ . UI - UJ 510.0 01 . UJ . UJ . UJ
2,4'DIMl1I1YLPIEIOL . Vol 'WO.OO . . w . UJ - UJ 21000.0 01 2200.00 J 590.00 J . UJ
2.4'DICIL~ . Vol . . . UJ . UJ 350~00 01 . W . UJ - Vol 490.00 01
"ClL0R0-3-.TIIYLPEIJ&. 240.00 " 1400.00 . . w . UJ - W . UJ 5400.00 01 110.00 01 . UJ
Z.4,5/6-1RltHlCllOPllUOL . Vol 550.00 . . UJ . Uti 280.00 R 11000.0 1 900.00 1 - W 2'0.00 01
Z,4-DII11ROPHENOL 910.00 ' '800.00 . . 1 . UI - UJ ZZOOOO.O 1 1900.00 1 870.00 1 . UJ
4'.I1RCIPIlEIIOl 190.00 .. 1300.00 . . UJ . UJ - W 8ZOOOO.0 01 1300.00 J - UJ - UJ
Z.3,4,6'TETIACML0R0PIENOL 1200.00 I 7'0.00 . '900.00 01 500.00 tI 340.00 . 01 Z70000.0 01 1600.00 01 1400.00 01 360.00 ..
",6'DIIIIT'0'Z-ME'IIYLPKEIIOL 240.00 . 1600.00 . . UJ . . - 1 170000.0 1 1800.00 J - UJ . 1
PEl1At11LOROPHEIIOL 820.00 ' 1700.00 . 1900.00 tI . UJ - UJ ZOOOOO.O 1 6800.00 01 740.00 1 - W
-------
-
fiELD SAMPLE NUMBEII: '.-OI-U-ool 1.-01.51-002 111-03-15-001 III-04-SS-00' 1.-04-SS.OO2 IH-06-SS.00' IN-06.SS.OO2 IN-08-SS-001 811-08-SS-002 8H-W-SS-001
EPA SAMPLE MUNlEII: OfozaJ 0'0285 0.0291 Of 0287 0.0289 0.0271 0.0213 OF0250 OF0248 OfOlS3
OEPTH 1-'Z' 20' .5-" 0-12' 20' 0- 12' 20' 4' 10' 5'
VOA AlIA&. YTES (40) 0 0 0 0 0 0 0 0 0 0
JllIg - - ... 1I8IK8 - - '- ,8IK8 - - - ,8IK8 - - - ,.8IKg - f-- I- ..IKI - ~ ... .IIK, - ~ '- JeIK, - '-- f- JI/K. - I-- - JI/KI - -
VINYL tHLORIOE W U.I Uol . U.I Uol . UJ . UJ . UJ . UJ VJ
1.1'DICHLOROETNENE - W . V.I . U.I . U.I . U.I . U.. . UJ .. U.I - UJ . VJ
TIANS-I.Z-DICIILOIOEIHElE . UJ . UJ . U.I . UJ - U.. . U.. . UJ . W . U.. . UJ
'.1-DICNLOROETIANE . U.I . V.I . U.I . UJ - UJ - UJ . VJ . UJ - UJ . UJ
CIS-I.2-DICHLOIOETIEME . W . UJ . UJ . VJ . UJ . UJ - UJ . U.. . W - UJ
CHLOROfCIUI - V.I - V.I . VJ . V.. . U.I - UJ - UJ . UJ - UJ - UJ
1,1.I-TIIICHLOROETHANE - W . V.. . VJ . V.I . VJ - V.I . U.I - V.I - V.I - VJ
CAllION TETMCNLCIIIDE - UJ - VJ . UJ . UJ I . UJ . U.I . .,J . U.I - V.I - VJ
.ENZEIIE 240.00 J 130.00 J 63.00 J 220.00 J . UJ 4.00 J 7.90 J 53.00 J 100.00 J . UJ
1,2-DICHLOROEINAIIE - UJ . UJ . UJ - UJ - UJ - UJ . UJ . UJ . U.. - UJ
TRICHLOROETHENE - VJ . VJ - VJ . U.. . UJ - UJ . UJ . UJ - UJ - UJ
..0000ItIILOROMETIWIE - UJ . VJ - U.I - Vol . Vol - Vol - Vol . UJ - UJ - UJ
TOLUER 540.00 J no.oo J 520.00 J 140.00 J - VJ 20.00 J 6.10 J 160.00 .I 250.00 .I - VJ
TETMCHLOROETIlEIIE - VJ . UJ - VJ . VJ - UJ - UJ . VJ - Vol - VJ - VJ
C:HUIR08ENZENE - VJ . UJ . UJ . U" - UJ - VJ - UJ . VJ - UJ - V.I
1,1.2,2-1ETMClLOIDETHAIIE - U.I . UJ - UJ . U.. . UJ . UJ . UJ - UJ - UJ - U.I
ETHfLBE.ZEIIE 810.00 .I 1100.00 .I 870.00 .. 510.00 J 1400.00 oI 14.00 J - UJ 96.00 J 130.00 J - UJ
8ROMOfCIUI - UJ . UJ . U.. - U.. - v.. - UJ - UJ - V.I - V.I - V.I
M.P-XYLEIIE 760.00 .. 1100.00 .. 850.00 .. 240.00 oI . UJ 3Z.oo J 4.30 J 230.00 J 300.00 J . UJ
O.XfLE"E 370.00 .I 610.00 .I 390.00 .. . V.I - V.. 22.00 oI . UJ 280.00 J 150.00 oI - UJ
PAN AllALYTEI e33O) OF0284 . "0286 0 Of 0292 0 OF0288 . OF029O 0 OF02n . OF0274 0 0.0249 0 0.0247 0 0.0254 0
.alK, - I- '- .,/r., - '-- :.. II,/K, - - ... 110,11" - 10- I- "/K,, - '-- I- 118/KI - ~ '- IIoalK. - I-- '- ,../K, - I-- I- ,.,/K, - '-- :... .alK, - -
NAPHTHALENE 120000.0 J 48000.00 J UJ 47000_00 J UJ 30000.00 J 180.00 .. 36000.00 .. 38000.00 J U..
ACENAPNTHWLEIIE - V.I 1400.00 .. 4900.00 .. 4800.00 .. . v.. 2700.00 J . V.I 700.00 .. 2100.00 J . VJ
ACENAPIITHEIIE 37UOO.0 II 35000.00 II 2900.00 II 48000.00 II 320.00 II 35000.00 J 170.00 J 31000.00 J 33000.00 J - U.I
fLUORENE 51000.0 II J8OOO.OO II 10000.00 . 59000.00 . 270.00 II 34000.00 II IC,O.oo II 32000.00 J 35000.00 J - v..
PHENANTHRENE - II 93000.00 II - II 79000.00 II 420.00 II 44000.00 .. 550.00 .. 45000.00 .. 42000.00 J - UJ
AIITHRACEIIE - UJ . VJ . VJ . VJ 130.00 J - VJ 64.00 J - U" 330.00 II - U"
FLUORAIITHEIIE - II 46000_00 'J 740.00 R 77UOO.00 J 74.00 J 47UOO.00 J 35.00 J 42000.00 J 49000.00 .. 140.00 J
"RENE 4700.0 II 41000.00 .. - UJ 9000.00 J 60.00 .. 44000.00 J 30.00 .. 41000.00 J 47000.00 .. 170.00 J
8ENZeA)AIIIHRACENE 10000.0 J 12000.00 J 21000.00 J . U.. 110.00 J 13000.00 J 67.00 J 10000.00 J 15000.00 J 80.00 J
CUYSENE 110000.0 oI 11000.00 J 6700.00 II 18000.00 J 120.00 J 11000.00 J 58.00 J 10000.00 J '4000.00 J 100.00 J
8EIIZO(8)/(K)FLUORAMTHEIE 35000.0 J 3900.00 J 1300.00 II 28000.00' J - VJ 4000.00 J - UJ 15000.00 J 2ZOOO.00 J 330.00 J
IENZOeA)PYIIEIiE 51000.0 . 3500.00 J 3100.00 II 31000.00 J . UJ 3400.00 J . UJ 3200.00 II 4900.00 II 110.00 J
IIIOEIIOC1,2.3-CO)PYIIENE - UJ 1000.00 J . UJ . UJ . UJ 1500.00 J - UJ 1000.00 II 320.00 J 210.00 J
DIIENZCA,.)AIITKIIACEIII - UJ 480.00 " - UJ 15000.00 J . UJ 260.00 J . UJ Z10.OO R - UJ 0.00 J
IENZOCG.N,')P£lYLENE 12000.0 " 840.00 II 460.00 II . II . UJ 910.00 J . UJ .700.00 R - UJ 0.00 J
ICA)P Equlv.lenc. c-. 36600 - 5780 - 5397 - 48980 - 12 f-- 5620 f-- 7 I-- 6110 - 8m - 175 I--
Total 'Ab 410700 - 335t20 - 51100 - 415800 10- 1504 '-- 270770 f-- 1294 I-- 261810 - 302650 - 1140 I--
'HENOL ANALYTE' (1700) GF0283 0 OFOZ8S Q 0.0291 0 OF0287 . OF0289 0 OF0271 0 OF0273 0 Of 0250 0 Of 0248 0 OfOZS3 0
"8/K, - I-- I- II'/KI - - - JI/rl - - - ".11' - 10- I- ,../r, - I-- I- JI/K, - I-- I- ,.,111 - i-- I- ,.,/K, - - -- ,../IC, - - - "alK, - i--
PHENOL 13000.0 oI 8700.0 J 5500.00 J UJ UJ 1800.0 J 6600.00 " 5100.0 R II UJ
2-CHLOICIPHENOL 650.0 " 3100.0 " 870.00 " 2800.00 " 240.00 J - UJ 340.00 J 1700.0 . 9100.00 R 990.00 J
G-CIESOL 5500.0 " 1800.0 J 1700.00 J 160.00 J . U" 550.0 .. 1900.00 J 3200.0 II 3200.00 . . UJ
",P-CRESOL 16000.0 J 6000.0 J 5800.00 J 470.00 J 240.00 J 1800.0 . 6500.00 II 8900.0 II 10000.00 . 200.00 J
Z-lnllOPlIE- - UJ . U" - UJ . UJ . UJ - . . II . . . II . UJ
2,4.DIMETIIYLPHEIOL 9300.0 J 1300.0 J 5900.00 J 1500.00 .. . V" 820.0 II 1100.00 II 4500.0 II 3200.00 II . UJ
2,4-DICILOICIPHEIOL 17000.0 J 5100.0 J 7000.00 J . UJ . UJ - W . UJ . II - II . UJ
4-CIIUIRO"]-.TIIYLPIIDDL 320.0 J 1800.0 .. 760.00 .. 3400.00 J . UJ 2600.0 J . UJ 3900.0 II 3700.00 II . W
Z,4,5/6-TlltHLOIIOPIIEIIDL 800.0 J laoooo.O J 870.00 .. 430.00 .. . UJ 210.0 " . VJ 590.0 . . II . UJ
Z,4-D"'TIIOPHEIOL 6600.0 " 540.0 J 7100.00 .. 2300.00 J . UJ 2000.0 J . UJ 10000.0 II 960D.00 . . I
4.IIITIIOPHENOL 4900.0 J 560.0 .. 4900.00 J 1400.00 J . UJ 1600.0 UJ 190.00 J Z6OO.0 . 2300.00 I . UJ
2,J,4,'.TETIAClLOIIOPIEIOL 5800.0 J '500.0 J 13000.00 .. 4200.00 J 560.00 J' 13000.0 J 89.00 J 8200.0 II 4800.00 II . UJ
4,6-DIIITIIO-Z-METIIYLPIIIIDL 13000.0 J 500.0 ""000.00 J 2200.00 .. . UJ 2400.0 J 92.00 J 6800.0 I 3600.00 II . UJ
-------
fiELD SAMPLE NUMBER: "".08.SS.OO1 ",.08.S5.oo2
E'A SAMPLE NUKBER. Qf0200 QfOZ01
DEPTH 0-10' 15'
VOA ANAl"ES (40) 0 Q
II8IKt - ,-- I- IIt/Kt - -
VINYL CHLORIDE . UJ . UJ
1,1'DICHLOROETHEME - UJ - UJ
TRAMS-1,2-DICHLOROET"EME - u.I - UJ
1.1-DICHLOROETKANE - UJ - UJ
CIS-1,Z.DICHLOROETHEHE - VJ - UJ
tHLORDfORll - UJ - UJ
1.1,1.TRICHLOROETHANE - UJ - UJ
W80II TETRACHLORIDE - UJ - UJ
BENZENE - UJ - UJ
1.2-DICHLOROETKANE - UJ - UJ
TlIClllOROETHENE - UJ - UJ
'R~ICHLOROKET~E - UJ - UJ
TOlUENE - UJ - UJ
TETRACHLOROETHEIIE - UJ - UJ
CHLOROBENZENE - UJ - UJ
T.T.Z.Z-TETRACHLOROETHANE - UJ . UJ
ETHYLBENZENE - Vol . UJ
BROMOfORM - UJ - UJ
M.P-XYLENE - UJ - UJ
D-XYLENE - UJ - UJ
PAH ANAlYTES (330) Qf020DRE 0 Of0201RE a
NAPHTHALENE 118/1C8 - - - 118/Kt - ,--
- UJ - UJ
ACENAPHTHYLENE - UJ - uj
ACEIIA'HTHEIIE - UJ - UJ
fLUORENE - UJ . UJ
PHENANTHRENE 23.00 J - UJ
ANTHRACENE - VJ - UJ
fLUORANTHENE 62.00 01 - UJ
PYRENE 9T.00 01 - UJ
BENZ(A)AIITHRACEHE - UJ - UJ
CHRYSEIIE 65.00 01 . UJ
BENZOCB)/CK)FLUORAIITHEIIE - VJ - UJ
BEIIZO(A)PTREIIE - UJ - UJ
IMDENOC1.2.3'CD)PYRENE - VJ . UJ
DI8ENZ(A,H)ANTHRACENE - UJ - UJ
8EIIZD(G.H,I)PERYLENE 56.00 J - UJ
ICA)P Equlvattne:e Cone. I i- 0 f--
Tota' PAils Z97 ~ 0 -
PHENOL ANAL"ES (1700) QF0200 0 OF0201 0
PHENOL III/KI - - III/ICI - -
- UJ 780.00 J
2-CHLOROPHENOL - Vol - UJ
O'CRESOL - Vol . UJ
N/P-CRESOL 160.00 01 120.00 01
2.lInROPHENOL . UJ - UJ
2.4.DIMETHYLPHEIIOL . UJ. . UJ
2.4-DICHLOIIOPIlEIIDL 540.00 01 . UJ'
4-CHLOIIO-S-METHYL'HEIICIL - UJ . UJ
2,4,5/6-'IIICHLORDP"ENOL 240.00 01 Z3OO.oo 01
2,4-DIIIITIOPIEIIOL . I . I
4-11 "ROPHEIIDL . Vol . UJ
Z.',4.6.TE~OP"EIIOL ZOOO.OO 01 . UJ
4,6.DI.I'~2-HETHYLPHEIICIL . UJ - UJ
PEIITACHLOROPKEIOL no.oo 01 . UJ
FIELD SAMPLE NUMBER: ",,1A.S5.002 ",,7-55.001 BH3.S5-001
EPA SAMPLE NUMBER: SF 2539 5f 2527 Sf 252JDL
I DEPTH Cft) 20' 0 - 10' 0.5-6'
YOAI 119/Kg 118/1C9 - 119/Kg -
DILUTICH FACTOR 1.00 1.00 250.00
BENZENE 0.16 U 0.15 U 41.90 U
CHLOROSENZENE 0.20 U 0.19 U 51.60 U
1.Z-0ICHLORD8ENZENE 0.33 U 0.31 U 83.90 U
1,3-DICHLOR08ENZENE 0.27 U 0.25 U 67.70 U
1.4-0ICHLOROBENZENE 0.24 U 0.22 V 61.30 U
ETHYL BENZENE 0.10 U 0.09 U 2430.00 0
TOLUENE 0.13 U 0.12 U 410.00 0
XYLENE5 0.34 U 0.32 U 6210.00 0
EPA SAMPLE NUMBER: SF 2539 SF 2527 ... SF 2523
PHENOLS IL9/Kg IL9/Kg 119/Kg '"
- ~
DILUTION FACTOR 0.167 0.167 0.167
PHENOLS 47.00 U 44.00 U 48.00 U
2-METHYL PHENOL 21.00 U 20.00 U 22.00 U
3-METHYL PHENOL 21.00 U 20.00 V 22.00 U
4-METHYL PHENOL 21.00 U 20.00 U 22.00 U
2.4-0IMETHYL PHENOL 14.00 U 13.00 U 14.00 U
Z-CHLORO PHENOL 13.00 U 18.00 U 13.00 U
Z,4-DICHLORO PHENOL 14.00 U 13.00 U 14.00 U
4-CHLORO.]-METHYL PHENOL 38.00 U 35.00 U 39.00 U
2.4.DINITROPHENOL 21.00 U 20.00 U 22.00 U
2-N ITROPHENOL 16.00 . U 15.00 U 17.00 U
Z.4,6-TRICHLOROPHENOL 13.00 U 18.00 U 13.00 U
4.6-DINITRO-2-METHYL PHENOL 21.00 U 20.00 U 22.00 U
4-NITROPHENOL 15.00 U 14.00 U 16.00 U
PENTACHLOROPHENOL 13.00 U 18.00 U 13.00 U
EPA SAMPLE NUMBER: Sf 2539DL Sf 2527DL SF 25230L
PAHS jig/Kg ... "1/"1 ... ",/Kg ...
~ ~
DILUTION FACTOR 1.00 UD 10.00 2000.00
ACENAPHTHENE 31.60 \ID 217.00 D 728000.00 D
ACENAPHTHYLENE 190.00 uo 177.00 \D 311700.00 \D
ANTHRACENE 12.60 UD 92.30 D 666000.00 D
BENZOCA)ANTHRACENE 19.00 UD 532.00 0 75800.00 0
BENZOCA)PJRENE 31.60 uo 507.00 D 37300.00 0
BENZO(B)FLUORANTHENE 19.00 uo 421.00 D 40900.00 D
BENZOCG.H.I)PERYLENE ".00 UD 99.00 D 3870.00 UD
BENZOCK)FLUORANTHENE 63.20 UD 378.00 0 25500.00 D
CHRYSENE 19.00 UD 537.00 D 70800.00 0
DIBENZOCA,H)ANTHRACENE 63.20 UD 246.00 D 12900.00 UD
FLUORANTHENE 63.20 UD 934.00 D 232000.00 0
fLUORENE 31.60 UD 966.00 D 1800000.00 D
INOENOC1,2,3-CO)PYREN& 19.00 UD 276.00 0 3870.00 uo
NAPHTHALENE 190.00 \ID 177.00 0 4660000.00 D
PHENANTHRENE 12.60 UD 92.30 UD 666000.00 D
PYRENE 63.20 UD 642.00 0 181000.00 0
Total PAHI 0.00 ~ 6024.30 ~ -9183300.00 i---
-------
fiELD SAMPLE NUMBER I 8H16.$$.001 8H16.$$-002 8H16-$$-003 8H16.$$-004 8H16-IS-006 IH17-SS.001 1818-55.001 8H19.5S.001 8H20-5S-001
EPA SAMPLE NUMBER' SF 2581 SF 2582 Sf 2583 SF 2584 SF 2585 " 2904 SF 2905DL Sf 2906 Sf 2908
DEPTH Ut) 28' 38! 47' 58' 74' 8' 10' 10' 9'
INA 1I1I11C1l - _1I/1C1l - 1&1I11C1l - JIIIICII - JIIIICII - JIIIICII - IIIIIICII - IIIIIICII ,.II/ICII ....,...0-
~
DILUTION FACTOR 1.00 200.00 1.00 20.00 1_00 1.00 2.00 100.00 10.00
btl(2.CHLOROETHYL)ETHEI 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000_00 U 4200.00 U
1,3-DICHLOROBENZENE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
1,4-DICHLOROBENZENE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
1,2.0ICHLOROBENZENE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
2,2'.oxybll(1-CHLOROPROPANE) 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
N-NITAOSO.OI-N.PROPYLAMINI 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
HEXACHOLORETHANE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
HITROBENZENE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
I $OPHOROHE 12000.00 U 67000.00 U 2200.00 32000.00 770.00 6000.00 E 5700.00 0 310000.00 11000.00
bil(2.CHLOROETHOKY)METHANE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
1,2,4.TRICHLOROBENZENE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
NAPHTHALENE 66000.00 250000.00 410.00 U 8500.00 U 420.00 U 410.00 U 800.00 " 42000.00 U 6200.00 8
4-CHLOROANILINE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
HEXACHLOROBUTADIENE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
2-METHYLNAPHTNALEN! 34000.00 120000.00 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4600.00
HEXACHLOROCYCLOPENTADIENE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
2-CHLORONAPHTHALENE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1100.00 U 42000.00 U 4200.00 U
Z-NITROANILINE 29000.00 U 170000.00 U 1000.00 U 21000.00 U 1100.00 U 990.00 U 1700.00 U 110000.00 U 10000.00 U
OIMETHYLPHTHALAT! 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
ACENAPHTHYLENE 110.00 J 2400.00 J 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
3.NITROANILINE 29000.00 U 170000.00 U 1000.00 U 21000.00 U 1100.00 U 990.00 U 1700.00 U 110000.00 U 10000.00 U
ACENAPHTHENE 21000.00 12000.00 410.00 U 8500.00 U 420.00 U 410.00 U 1100.00 U 42000.00 U 3300.00 J
OIBENZOFURAN 26000.00 89000.00 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 3000.00 "
2,4-0INITROTOLUENE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
2,6.DINITROTOLUENE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
DIETHYLPHTHALATE 12000.00 U 61000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
4-CHLOROPHENYL PHENYLETHER 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
flUORENE 22000.00 68000.00 410.00 U 8500.00 U 420.00 U 410.00 U 1100.00 U 42000.00 U 3800.00 "
4-NI TROANI LINE 29000.00 U 170000.00 U 1000.00 U 21000.00 U 1100.00 U 990.00 U 1700.00 U 110000.00 U 10000.00 U
N-NITROSODIPHENYLAMINE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1100.00 U 42000.00 U 4200.00 U
4-IROMOPHENYL.PHENYLETHER 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
HEXACHLOR08ENZENE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1100.00 U 42000.00 U 4200.00 U
PHENANTHRENE 56000.00 260000.00 56.00 J 8500.00 U 420.00 U 410.00 U 1100.00 U 42000.00 U 14000.00
ANTHRACENE 8200.00 " 20000.00 " 410.00 U 8500.00 U 20.00 " 410.00 U 1700.00 U 42000.00 U 1300.00 "
CARIAZOLE 2500.00 " 7200.00 " 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 1,20.00 J
DI-N.8UTYLPHTHALATE 12000.00 U 61000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
FLUORANTHENE 28000.00 96000.00 33.00" 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 990.00 J
PYRENE 19000.00 70000.00 10.00 " 8500.00 U 420.00 U 410.00 U 1100.00 U 42000.00 U 410000.00
BUTYLBENZYLPHTHALATE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
3,3'.DICHLOR08ENZIDINE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1100.00 U 42000.00 U 4200.00 U
BENZO(A)ANTHRACENE 4300.00 " 15000.00 " 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
bil(2.ETHYLHEXYL)PHTNALATE 12000.00 U 61000.00 U 31.00 " 8500.00 U 120.00 " 410.00 U 1700.00 U 42000.00 U 4200.00 U
CHRYSENE 4400.00 J 15000.00 " 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 2900.00 "
OI.N.OCTYLPHTHALATE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
BENZO(B)FLUORANTHENE 2000.00 J 61000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 2100.00 "
BENZO(K)FLUORANTHENE 2000.00 " 61000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1100.00 U 42000.00 U 2100.00 "
BENZO(A)PYRENE 2300.00 " 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 930.00 "
INDENO(1,2,3.CO)PYRENE 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 480.00 "
DIBENZO(A,H)ANTHRACENB 12000.00 U 67000.00 U 410.00 U 8500.00 U 420.00 U 410.00 U 1700.00 U 42000.00 U 4200.00 U
BENZO(G,H,I)PERYLENE 12000.00 U 67000.00 U 410.00 U 8500.00 U .420.00 U 410.00 U 1100.00 U 42000.00 U 4200.00 U
Totat PAHs 235970.00 - 868400.00 - 99.00 ,..- 0.00 I-- 20.00 f- 0.00 i-- 800.00 f- 0.00 - 448100.00 I--
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flELO SAMPLE NUMBER: SS5-SS-001 555'55-002 555-55-003 BH3-SS-001 BH9-SS-001 MW1A-SS-001 BH3'$S-001 8H9-SS-001 MW1A-SS'001
EPA SAMPLE NUMBER: SF 2493 SF 2494 SF 2495 SF 2549 SF 2515 SF 2547 SF 2549 SF 2515 SF 2547
DEPTH eft) 0.5' - 6' 5' 0 - 10' 0.5' - 6' 5' 0 - 10'
METALS mg/Kg mg/K9 - mg/K9 mg/K9 - mg/Kg - mg/Kg - mg/lCg - mg/lCg mg/Kg - -0-
--- ~
ALUMINUM 4240.00 5560.00 6670.00 17700.00 13200.00 5310.00 17700.00 13200.00 5310.00
ANTIMONY 8.50 U 1.90 U 9.10 U . 11.50 U 7.90 U 8.50 U 11.50 U 7.90 U 8.50 U
ARSENIC 20.00 13.50 16.30 B 25.60 8 I 13.50 U 14.50 U 25.60 8 13.50 U 14.50 U
8 U
8ARIUM 2230.00 2320.00 2140.00 962.00 253.00 139.00 962.00 253.00 139.00
BERYlLIUM 0.69 B 0.65 B 0.74 B 0.71 B 0.64 B 0.52 B 0.11 B 0.64 B 0.52 B
CADMIUM 1.00 0.65 8 0.74 B 1.40 0.64 U 0.69 U 1.40 0.64 U 0.69 U
CALCIUM 13100.00 13000.00 16200.00 29600.00 803.00 8 3020.00 29600.00 803.00 8 3020.00
CHROMIUM 6.10 8.10 9.10 16.90 11.80 8.80 16.90 11.80 8.80
COBALT 3.00 8 3.20 8 3.50 B 7.10 . 10.00 3.60 8 7.10 8 10.00 3.60 8
COPPER 23.40 37.60 26.30 26.80 5.60 15.20 26.80 5.60 15.20
IRON 11900.00 11300.00 13200.00 15500.00 8530.00 4000.00 15500.00 8530.00 4000.00
LEAD 22.70 B 31.30 23.10 8 15.50 B 8.90 B 8.60 . 15.50 8 8.90 8 8.60 .
MAGNESIUM 331.00 8 435.00 8 488.00 B 4230.00 816.00 2480.00 4230.00 816.00 2480.00
MANGANESE 128.00 141.00 134.00 144.00 n2.00 45.60 144.00 n2.00 45.60
NICKEL 3.30 8 6.50 5.00 B 9.60 4.30 6.20 9.60 4.30 6.20
POTASSIUM 186.00 8 309.00 8 278.00 B 930.00 . 508.00 ' 1010.00 930.00 . 508.00 8 1010.00
SELENIUM 16.00 U 18.10 8 22.00 8 21.60 U 14.80 U 15.90 U 21.60 U 14.80 U 15.90 U
SILVER 0.52 U 0.48 U 0.56 U 0.71 U 0.48 U 0.52 U 0.11 U 0.48 U 0.52 U
SOOIUM 434.00 8 424.00 8 489.00 8 2000.00 1450.00 538.00 8 2000.00 1450.00 538.00 8
THALLIUM 160.00 217.00 253.00 31.00 B 15.30 8 27.80 8 31.00 B 15.30 8 21.80 8
VANADIUM 11.80 11.30 14.10 48.90 18.20 7.30 8 48.90 18.20 1.30 8
ZINC 11.00 76.00 116.00 48.20 14.80 41.60 48.20 14.80 41.60
MOLYBDENUM 8.70 U 8.10 U 9.30 U 11.80 U 8.10 U 8.60 U 11.80 U 8.10 U 8.60 U
PHOSPHORUS 131.00 139.00 128.00 613.00 28.30 324.00 613.00 28.30 324.00
STRONTIUM 95.20 96.80 98.30' 376.00 32.90 65.80 376.00 32.90 65.80
EPA SAMPLE NUMBER: SF 2484 SF 2485 SF 2486 SF 2556 SF 2512 SF 2552 SF 2556 SF 2512 SF 2552
DIOXINS ltg/Kg - Jg/Kg - 1&9/Kg .. "'II/KII .. I&O/KI .. Jg/Kg - "'9/Kg - Jig/Kg JI/KI - f-4-
~ .....
2318-TCOD U U U U U U U U U
2318'TCOF U U U U U U U U U
12378-PeCDF U U U U U U U U U
12378-PeCDD U U U U U U U U U
23478-.PeCDF U U U U U U U U U
123478'HxCDF U U U 0.25 J 2.5699 U 0.25 J 2.5699 U
123678' HxCDF U U U 1.27 J U U 1.27 J U U
123478-HxCDO 1 .0068 " 0.8134 " 0.41 .. 0.0170 .. u 0.47 " 0.0170 " U
123678' HxCDD 3.4n2 3.5459 3.3829 2.12 J 0.6304 .. U 2.12 J 0.6304 J U
123789'HxCDD 2.1167 J 2.5699 2.0360 .. 1.42 " 0.2169 J U 1.42 " 0.2169 J U
23467S'HxCDF U U U 6.11 U U 6.11 U U
123189.HxCDF U U U 0.20 J U U 0.20 J U U
1Z34678'HpCOf 23.7014 21.8857 22.31Z4 U 10.34 2.9892 U 10.34 2.9892 U
1234678-HpCDD 291.8809 289.9030 309.3229 U 99.74 18.1289 0.15 " 99.74 18.1289 0.15 "
1234789'HpCDF 1 .6633 J 1.4480 J U 0.80 J U U 0.80 J U U
OCDD 14Z0.6901 1470.1196 1383.7875 U 862.10 E 117.1610 0.64 J 862.10 E 117.1610 0.64 J
OCOF 164.1590 154.9121 159.7943 U 10.40 15.0575 U 10.40 15.0575 U
TCOD Equivalence 5.3200 5.4700 5.4800 3.2260 0.6900 0.0020 3.2260 0.6900 0.0020
.)
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APPENDIX E
AMERICAN CREOSOTE WORKS, INC. .
GROUND WATER ANALYfICAL SAMPLING
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FIelD SAMPLE NUMBER: MIIS-G\I-002 M\l6.G\I.001 MIl6-GY-002 M\I1-G\l.001 MW8.G\I-001 M-W.001
EPA SAMPLE NUMBER: SF 25170L SF 25940L SF 259501. SF 2592 SF 2586 SF 2593
DEPTH (It) . - .. - - -
WAS 119/1. 119/1. 119/1. !LII/L jtll/I. IIII/L
DILUTION FACTOR 5.00 50.00 10.00 1.00 1.00 1.00
BENZENE 4.70 D 146.00 0 84.00 0 0.13 U 0.13 U 0.13 U
CHLOROBENZENE 0.80 U 1.60 U I 1.60 U 0.16 U 0.16 U 0.16 U
1,2'0ICHLOROBENZENE 1.30 U 2.60 U 2.60 U 0.26 U 0.26 U 0.26 U
1,3-DICHLOROBENZENE 1.10 U 2.10 U 2.10 U 0.21 U 0.21 U 0.21 U
1 ,'-DICHLOROBENZENE 1.00 U 1.90 U 1.90 U 0.19 U 0.19 U 0.19 U
ETHYL BENZENE 16.80 0 19.00 0 20.00 0 0.08 U 0.08 U 0.011 U '
TOLUENE 5.90 0 62.00 0 163.00 0 0.10 U 0.10 U 0.10 U
XYLENES 23.10 0 97.00 0 102.00 0 0.27 U 0.27 U 0.27 U
EPA SAMPLE NUMBER: SF 2577 SF 2594 SF 2595 SF 2592 .. SF 2586 SF 2593 "
PHENOlS ILg/1. - jig/L - 1L9/L .. jig/I. /lg/I. " IIg/1.
DILUTION FACTOR 0.0010 0.0010 0.0010 0.0010 0.001 0.001
PHENOLS 2.20 U 2.20 U 2.20 U 2.20 U 2.20 U 2.20 U
2-METHYL PHENOL 1.00 U 1.00 U 1.00 U 1.00 U 1.00 U 1.00 U
3-METHYL PHENOl 1.00 U 1.00 U 1.00 U 1.00 U 1.00 U 1.00 U
4-METHYL PHENOL 1.00 U 1.00 U 1.00 U 1.00 U 1.00 U 1.00 U
2,4-DIMETHYL PHENOL 0.63 U 0.63 U 0.63 U 0.63 U 0.63 U 0.63 U
2-CHLORO PHENOl. 0.58 U 0.58 U 0.58 U 0.58 U 0.58 U 0.58 U
2,4-DICHLORO PHENOL 0.68 U 0.68 U 0.68 U 0.68 U 0.68 U 0.68 U
4-CHlORO'3'MET"Yl PHENOL 1.80 U 1.80 U 1.80 U 1.80 U 1.80 U 1.80 U
2,"0INITROPHENOL 1.00 U 1.00 U 1.00 U 1.::0 U 1.00 U 1.00 U
2'NITROPHENOl 0.77 U 0.77 U 0.77 U 0.", U 0.77 U 0.77 U
2,4,6'TRICHlOROPH!NOL 0.58 U 0.58 U 0.58 U 0.58 U 0.58 U 0.58 U
4,6'DINITRO-2'METHYI. PHENOL 1.00 U 1.00 U 1.00 U 1.00 U 1.00 U 1.00 U
4-NITROPHENOL 0.70 U 0.70 U 0.70 U 0.70 U 0.70 U 0.70 U
PENTACHLOROPHENOL 0.59 U 0.59 U 0.59 U 0.59 U 0.59 U 0.59 U
EPA SAMPLE NUMBER: SF 25770L SF 2594 SF 2595 SF 2592 Sf 2586 Sf 2595
PAHS 1111/1. .. 119/1. .. 119/1. - 119/1. .. 1111/1. .. 1111/1. ..
-
DII.UTlON FACTOR 100.00 1.00 1.00 1.00 1.00 1.00
ACENAPHTHENE 68.00 0 2250.00 3310.00 0.390 0.480 3.2900
ACENAPHTHYl.ENE 45.00 DU 450.00 U 450.00 U 0.450 U 0.450 U 0.4500 U
ANTHRACENE 13.00 OP 526.90 810.00 0.060 0.210 P 0.0300 U
BENZO(A)ANTHRACENE 4.50 OU 857.00 818.00 0.045 U 0.080 0.0450 U
BENZO(AJPYRENE 7.50 DU 203.40 317.00 0.075 U 0.075 U 0.0750 U
BENZO(B)fI.UORANTHENE 4.50 DU 175.00 266.00 0.045 U 0.045 U 0.0450 U
8ENZO(G,H,I)PERYI.ENE 4.50 OU 45.00 U 45.00 U 0.045 U 0.045 U 0.0450 U
BENZO(K)fLUORANTHENE 15.00 DU 91.80 234.00 0.150 U 0.150 U 0.1500 U .
CHRYSENE 4.50 DU 4340.00 547.00 0.045 U 0.050 0.0045 U
DIBENZO(A,H)ANTHRACENE 15.00 OU 150.00 U 150.00 U 0.150 U 0.150 U 0.1500 U
FI.UORANTHENE 23.00 DU 8311.00 9880.00 0.150 U 0.890 P 0.1500 U
fLUORENE 122.00 DP 8980.00 12200.00 0.390 1.270 0.1100
INDENO(1,2,3-CD)PYRENE 4.50 DU 45.00 U 45.00 U 0.045 U 0.045 U 0.0450 U
NAPHTHALENE 748.00 0 Z0900.00 18500.00 0.450 U 2.290 0.4500 U
PHENANTHRENE 13.00 OP 526.00 810.00 0.060 0.210 P 0.0300 U
PYRENE 15.00 OU 637.00 666.00 0.150 U 0.300 0.1500 U
TOt8t PAHI 964.00 f-- 40325.10 i-- 48358.00 ~ 0.90 - 5.78 ~ 3.40 -
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FIELD SAMPLE NUMBER: M\l1-G\/-001 M\I2A-aw-001 M\I3-aw-001 M\I3-G\/-002 M\l3A-GW-001 MWS-aw-001
EPA SAMPLE NUMBER: SF 2912 SF 2573 SF 2910 SF 2911 SF 2575 SF 2580
DEPTH (ft)
METALS "SIlL - I1S1/L - !,II/L "SIlL - "SIlL - "II/L
ALUMINUM 93.00 B 604.00 84.00 U 84.00 U 2920.00 27700.00
ANTIMONY 49.00 U 49.00 U 49.00 U 49.00 U 49.00 U 49.00 U
ARSENIC 84.00 U 84.00 U 84.00 U 84.00 U 87.00 I 84.00 U
BARIUM 111.00 B 124.00 B 237.00 231.00 95.00 B 485.00
BERYLLIUM 3.00 B 3.00 B 3.00 B 3.00 B 3.00 B 3.00 .
CADMIUM 4.00 U 4.00 U 4.00 U 4.00 U 11.00 4.00 U
CALCIUM 4340.00 B 21400.00 10900.00 10600.00 21200.00 30700.00
CHROMIUM 10.00 6.00 U 6.00 U 6.00 U 6.00 U 31.00
COBALT 9.00 U 9.00 U 9.00 U 9.00 U 83.00 14.00 .
COPPER 5.00 B 9.00 B 5.00 B 6.00 B 7.00 B 30.00
IRON 2500.00 14200.00 3550.00 3420.00 118000.00 31100.00
LEAD 50.00 U 50.00 U 50.00 u 50.00 U 50.00 U 74.00 .
MAGNESIUM 1860.00 8 8280.00 4200.00 B 3990.00 B 8100.00 8180.00
MANGANESE 59.00 622.00 95.00 92.00 18500.00 408.00
NICXEL 15.00 10.00 u 10.00 u 10.00 U 18.00 12.00
POTASSIUM 3150.00 B 3250.00 8 3280.00 B 3360.00 B 1890.00 8 6000.00
SELEHIUM 92.00 U 92.00 U 92.00 u 92.00 U 92.00 U 92.00 U
SILVER 3.00 U 3.00 u 3.00 u 3.00 U 3.00 U 3.00 U
SOD IUM 29600.00 51900.00 24300.00 23500.00 487000.00 82200.00
THALLIUM 92.00 8 107.00 8 60.00 U 79.00 B 60.00 U 75.00 .
VANADIUM 6.00 U 6.00 U 6.00 U 6.00 U 40.00 8 49.00 .
ZINC 16.00 8 27.00 18.00 B 19.00 B 43.00 300.00
MOLYBDENUM 50.00 U 50.00 u 50.00 u 50.00 U 50.00 U 50.00 U
PHOSPHORUS 298.00 290.00 172.00 224.00 1190.00 323.00
STRONTIUM 213.00 686.00 489.00 476.00 650.00 575.00
EPA SAMPLE NUMBER:
DIOXINS
2378- TCOO
2378- TCDF
12378-PecDF
12378-PeCDO
23478-PeCDF
123478.HxCDF
123678. NxCD F .
123478-HxCDO
1Z3678-HxCDO
123789-HxCOO -
234678-HxCDF
123789-HxCDF
1234678-HpCDF
1234678-HpCDD
1234789-HpCDF
OCDD
OCDF
TCDD Equ}va\ence
FIELD SAMPLE NUMBER: MWS-GW-002 MII6-GII-001 MW8-GII.001
EPA SAMPLE NUMBER: SF 2578 SF 2914 SF 2909
DEPTH eft) - - "SIlL - r-CI-
METALS "\IlL /&II/L
ALUMINUM 13800.00 257.00 2700.00
ANTIMONY 49.00 U 49.00 U 49.00 U
ARSENIC 104.00 B 84.00 u 84.00 U
BARIUM 548.00 79.00 B 300.00
BERYLU UM 3.00 8 3.00 8 3.00 8
CADMIUM 4.00 B 21.00 4.00 U
CALCUM 31200.00 113000.00 22800.00
CHROMIUM 19.00 6.00 U 6.00 U
COBALT 16.00 B 133.00 9.00 U
COPPEI 31.00 7.00 B 8.00 B
IRON 28200.00 . 26000.00 19400.00
LEAD 66.00 B 79.00 B 50.00 U
MAGNESIUM 7700.00 80900.00 6950.00
MAllCiANES! 419.00 3280.00 636.00
NICKEL 20.00 10.00 U 10.00 U
POTASSIUM 4900.00 8 6000.00 3920.00 B
SELENIUM 92.00 U 92.00 U 92.00 U
SILVER 3.00 U 3.00 U 3.00 U
SODIUM 83800.00 281000.00 39700.00
THALLIUM 88.00 B 60.00 U 60.00 U
VANADIUM 39.00 B 91.00 8.00 B
ZINC 340.00 126.00 22.00
IIOUBOENUM 50.00 U 50.00 U .50.00 U
PHOSPHORUS 346.00 270.00 115.00 B
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FIELD SAMPLE NUMBERS: M\I3-G\I-001 JIII3-GW-002 MW6-G\l-001 M\I7.GW-001 MW1-GW-001 M'II9-GW-001
SAMPLE NUMBER 1 2 3 4 5 - 6
REO RILL WELL
8N 8/L 8/L g/L 8/L a 8IL 8/L- rOo-
ACENAPHTHENE 2.00 U 2.00 U 5620.00 2.00 U 2.00 U 2.00 U
ACENAPHTHYLENE 2.00 U 2.00 U 400.00 U 2.00 U 2.00 U 2.00 U
ANTHRACENE 2.00 U 2.00 U 2350.00 2.00 U 2.00 U 2.00 U
BENZIDINE 20.00 U 20.00 U 4000.00 U 20.00 U 20.00 U 20.00 U
BENZOIC ACID 10.00 U 10.00 U 2000.00 U 10.00 U 10.00 U 10.00 U
BENZOCA)ANTHRACENE 8.00 U 8.00 U 1600.00 U 1.00 U 8.00 U 1.00 U
BENZOCA)PYRENE 8.00 U 8.00 U 1600.00 U 8.00 U 1.00 U 8.00 U
BENZOCB)FLUORANTHENE 8.00 U 8.00 U 1600.00 U 1.00 U 8.00 U 8.00 U
BENZOCG,H,I)PERYLENE 8.00 U 8.00 U 1600.00 U 8.00 U 8.00 U 8.00 U
BENZOCK)FLUORANTKENE 8.00 U 8.00 U 1600.00 U 1.00 U 8.00 U 8.00 U
BENZYL ALCOHOL 4.00 U 4.00 U 800.00 U 4.00 U 4.00 U 4.00 U
BISC2-CHLOROETHOXY)METHANE 2.00 U 2.00 U 400.00 U 2.00 U 2.00 U 2.00 U
BISC2-CHLOROETHYL)ETHER 2.00 U 2.00 U 400.00 U 2.00 U 2.00 U 2.00 U
BISC2.CHLOROISOPROPYL)ETHER 2.00 U 2.00 U 400.00 U 2.00 U 2.00 U 2.00 U
BIS-C2-ETHYLKEXYL)PHTHALATE 4.00 U 4.00 U 800.00 U 4.00 U 4.00 U 4.00 U
4-BROMOPHENYLPHENYL ETKER 8.00 U 8.00 U 1600.00 U 8.00 U 8.00 U 8.00 U
BUTYLBENZYLPHTHALATE 4.00 U 4.00 U 800.00 U 4.00 U 4.00 U 4.00 U
CARBAZOLE 10.00 U 10.00 U 2000.00 U 10_00 U 10.00 U 10.00 U
4-CHLORCWnLINE 4.00 U 4.00 U 800.00 U 4.00 U 4.00 U 4.00 U
2-CHLORONAPHTHALENE 2.00 U 2.00 U 400.00 U 2.00 U 2.00 U 2.00 U
2-CHLOROPHENOL 4.00 U 4.00 U 800.00 U 4.00 U 4.00 U 4.00 U
4.CHLOROPHENYLPHENYL ETHER 8.00 U 8.00 U 1600.00 U 8.00 U 8.00 U. 8.00 U
4-CKLORO-3-METHYLPHENOL 8.00 U 8.00 U 1600.00 U 8.00 U 1.00 U 8.00 U
CHRYSENE 8.00 U 8.00 U 1600.00 U 8.00 U 8.00 U 8.00 U
OIBENZOFURAII 2.00 U 400.00 U 3530.00 2.00 U 2.00 U 2.00 U
OIBENZOCA,H)ANTHRACENE 8.00 U 8.00 U 1600.00 U 8.00 U 8.00 U 8.00 U
1, 2-D I CHLOROBENZENE 3.00 U 3.00 U 600.00 U 3.00 U 3.00 U 3.00 U
1,3-DICHLOROBENZENE 3.00 U 3.00 U 600.00 U 3.00 U 3.00 U 3.00 U
1,4-0ICHLORORBENZENE 3.00 U 3.00 U 600.00 U 3.00 U 3.00 U 3.00 U
3,3'-OICHLOROBENZIDINE 10.00 U 10.00 U 2000.00 U 10.00 U 10.00 U 10.00 U
2,4-DICHLOROPHENOL 6.00 U 6.00 U 1200.00 U 6.00 U 6.00 U 6.00 U
DIETHYLPHTHALATE 2.00 U 2.00 U 400.00 U 2.00 U 2.00 U 2.00 U
2,4-DIMETHTLPHENOL 6.00 U 6.00 U 11600.00 6.00 U 6.00 U 6_00 U
DIMETHYLPHTHALATE 2.00 U 2.00 U 400.00 U 2.00 U 2.00 U 2.00 U
2,4-DINITROPHENOL 30.00 U 30.00 U 6000.00 U 30.00 U 30.00 U 30.00 U
2,4-DINITROTOLUENE 6.00 U 6.00 U 1200.00 U 6.00 U 6.00 U 6.00 U
2,6'0INITROTC>LUENE 6.00 U 20.00 U 4000.00 U 6.00 U 6.00 U 6.00 U
2,6-DINITRO-2-METHYLPHENOL 6.00 U 6.00 U 1200.00 U 6.00 U 6.00 U 6.00 U
DI-N-BUTYLPHTKALATE 20.00 U 20.00 U 400.00 U 20.00 U 20.00 U 20.00 U
DI-N-OCTYL PHTHALATE 2.00 U 2.00 U 800.00 U 2.00 U 2.00 U 2.00 U
FLUORANTHENE 4.00 U 4.00 U 6140.00 4.00 U 4.00 U 4.00 U
FLUORENE 2.00 U 2.00 U 4410.00 2.00 U 2.00 U 2.00 U
HEXACHLOROBENZENE 2.00 U 2.00 U 400.00 U 2.00 U 2.00 U 2.00 U
HEXACHLOROBUTAD I ENE 2.00 U 2.00 U 1000.00 U 2.00 U 2.00 U 2.00 U
HEXACHLOROCYCLOPENTADIENE 5.00 U 5.00 U 2000.00 U 5.00 U 5.00 U 5.00 U
HEXACHLOROETHANE 10.00 U 10.00 U 600.00 U 10.00 U 10.00 U 10.00 U
INDENOC1,2,3-CO)PYRENE 3.00 U 3.00 U 1600.00 U 3.00 U 3.00 U 3.00 U
ISOPHORONE 8.00 U 8.00 U 800.00 U 8.00 U 8.00 U 8.00 U
2-METHYLNAPHTHALENE 4.00 U 4.00 U 2220.00 4.00 U 4.00 U 4.00 U
2-NETHYLPHENDL 2.00 U 2.00 U 23600.00 2.00 U 2.00 U 2.00 U
4-NETHYLPHENOL 6.00 U 6.00 U 66300.00 6.00 U 6.00 U 6.00 U
NAPHTHALENE 6.00 U 6.00 U 26900.00 6.00 U 6.00 U 6.00 U
2-NITRCWlILlNE 2.00 U 2.00 U 1600.00 U 2.00 U 2.00 U 2.00 U
3-NITROANILINE 8.00 U 8.00 U 1600.00 U 8.00 U 8.00 U 8.00 U
4.NITROANILINE 8.00 U 8.00 U 1600.00 U 8.00 U 8.00 U 1.00 U
NITROBENZENE 2.00 U 2.00 U 400.00 U 2.00 U 2.00 U 2.00 U
2-NITROPHENOL 10.00 U 10.00 U 2000.00 U 10.00 U 10.00 U 10.00 U
4-NITROPKENOL 13.00 U 13.00 U 2600.00 U 13.00 U 13.00 U 13.00 U
N-NITROSCOIPHENYLAMINE 4.00 U 4.00 U 800.00 U 4.00 U 4.00 U 4.00 U
N-NITROSO-DI-N-PROPYLAMINE 6.00 U 6.00 U 1200.00 U 6.00 U 6.00 U 6.00 U
PENTRACHLOROPHENOL 15.00 U 15.00 U 3000.00 U 15.00 U 15.00 U 15.00 U
PHENANTHRENE 2.00 U 2.00 U 14000.00 2.00 U 2.00 U 2.00 U
PHENOL 4.00 U 4.00 U 52900.00 4.00 U 4.00 U 4.00 U
PYRENE 2.00 U 2.00 U 4540.00 2.00 U 2.00 U 2.00 U
1,2,4-TRICHLOROBENZENE 3.00 U 3.00 U 600.00 U 3.00 U 3.00 U 3.00 U
2,4,S-TRICHLOROPHENOL 6.00 U 6.00 U 1200.00 U 6_00 U 6.00 U 6.00 U.
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APPENDIX F
AMERICAN CREOSOTE WORKS, INC.
RECORD OF DECISION RESPONSIVENESS
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THE RESPONSIVENESS SUMMARY
The Responsiveness summary has been prepared to provide written
responses to comments submitted regarding the Proposed Plan of
Action at the American Creosote works, Inc., site.
1. Summary of Mafor Comments Received
Public notices announcing the public comment period and opportunity
for a public meeting were printed in the Winnfield Entercrise-News
American. Shreveport Times. and Monroe News Star. The first.
Proposed Plan was distributed to those on the site mailing list on
July 29, 1992, and the Final Proposed Plan was issued on March 1,
1993, which included new individuals added to the mailing list.
Public meetings were conducted on August 3, 1992, and september 15,
1992, to inform the public about the Feasibility study Report and
the Proposed Plan of Action. The first comment period began on
July 29, 1992, and ended on September 28, 1992. A second comment
period was conducted from March 1, 1993, to Marc~ 30, 1993, which
provided the public a total of 90 days to comment on alternatives
to remediate the site. At the meetings, EPA officials discussed
the hazardous substance contamination problems at the site,
presented the various remedial alternatives that were considered,
and presented the preferred alternatives for the remediation of the
American Creosote Works, Inc., site.
Approximately four people attended the first meeting, while over
sixty people were in attendance at the second meeting. At both
meetings, the public was given the opportunity to make comments or
ask questions. A full account of the public meetings can be found
in the public meeting transcripts that have been placed in the
American Creosote Works, Inc., administrative record. Nine letters
with comments were received during the comment periods and have
also been placed in the administrative record. The Administrative
Record is available for public review at the Winn Parish Public
Library, winnfield, LA, the Louisiana Department of Environmental
Quality, Baton Rouge, LA, and the Environmental Protection Agency,
Dallas, TX.
1
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a) Verbal Comments
1.
Comment:
Is the water table severely contaminated?
Response.:
Yes. Because the ground water is in contact with contaminated
soils and Non Aqueous Phase Liquids (NAPLs) whose principal
hazardous substance constituents are creosote and pentachlorophenol
(PCP), the shallow ground water has become highly contaminated.
2.
Comment:
What is meant by an environmental threat?
Response:
An environmental threat is a threat to animals or vegetation posed
by compounds, such as hazardous substances, that come into contact
with those animals or vegetation through their immediate
environment. In the context of the American Creosote site, this
means health threats exist to fish in the Creosote Branch and to
native wildlife, such as deer, mice, and fox that come into contact
with contaminants related to the American Creosote Works, Inc.
site. In addition, the term also includes the threat posed by
contact with site-related contaminants to the wetlands and forested
lands located within and surrounding the American Creosote plant.
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. .
3.
Comment:
Are the current owners responsible for the site?
previous owners, are they also responsible?
What about
Response:
Yes, under section 107 of the superfund law, known as the
comprehensive Environmental Response, compensation and Liability
Act (CERCLA), 42 V.S.C. S 9607, current and past owners and
operators of a facility from which there are or have been releases
of hazardous substances are responsible parties for liability
purposes. EPA is currently negotiating with a past owner of the
site to recover past response costs incurred at the site. Xn
addition, EPA's attempts to contact the current site owner,
Reinhardt Investments, have been unsuccessful due to its failure to
respond to EPA inquiries. Reinhardt Investments appears to be a
shell corporation whose only known address is a post office box in
the Netherlands Antilles.
4.
Comment:
Who will own the property when the remediation is complete?
Response:
The answer to this question is not clear at this time, although the
act of remediating a site generally does not affect the title to a
property. EPA, however, will not take over ownership of the
property either during or after this site is remediated.
currently, the contaminated area is owned by two companies,
Reinhardt Investments that owns the property on which the wood
treating operations were conducted, and Louisiana Pacific
Corporation that owns part of the tar mat area. (Louisiana Pacific
is not considered a liable party at this time). Xf the site is
sold in the future, EPA will attempt to recover response costs from
the proceeds. Those that are responsible for the waste, however,
will not be allowed to take advantage of the Superfund cleanup to
increase the value of their land without due compensation.
3
.
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. f.'.: ~
~
5.
Comment:
":If you're looking -for a comment, we'd like the site cleaned up to
the fullest extent. Because if you don't, it will eventually be
more than what you're paying now; and you'd get rid of the problem
for the people that live in this area."
Response:
EPA believes the selected remedy (incineration
bioremediation) will meet the goals of this comment.
and
in-situ
6.
Comment:
:If the state is responsible for a 10 percent match for construction
activities, who will guarantee that the state will provide the
funds?
Response:
EPA will enter into a Superfund State Contract with the state of
Louisiana that is a formal contract between the state and EPA in
which the state guarantees to provide its 10 percent matched
funding and commit to long term operations and maintenance as
defined in the ROD. EPA cannot start construction activities until
the state of Louisiana signs this Superfund state Contract.
7.
Comment:
What danger does the site pose for the people living close to the
site and is there danger in this contamination getting into the
city of Winnfield's water system.
Response:
As presented in the risk assessment portion of the ROD, there are
potential direct contract threats from surface tar mat materials to
any trespassers on the site. However, these risks are chronic
rather than acute, which means the potential for risk increases
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with an increased exposure to the contaminants rather than just
coming into contact with the material once or twice. A greater
risk to the public is associated with someone consuming
contaminated ground water. CUrrently, the City of winnfield's
water system is not impacted by any of the site-related ground
water contamination because it is drawn from an aquifer not
affected by the site. However, the potential remains that future
generations of residents within the site area may drill shallow
ground water wells that intercept this contaminated ground water
plume, should contaminants remain.
8.
Comment:
"0
What precautions are EPA taking to prevent trespassers from getting
on-site.
Response:
. .. .".
EPA has constructed a fence and posted signs against trespassing at
the site. EPA will try and maintain the fence until the selected
remedy is implemented. During actual site remediation, site
security will be the responsibility of the Remedial Action
Contractor. Once the cleanup is completed, the state of Louisiana
will maintain the site.
9.
Comment:
The people of Winnfield would like to see some of the money
associated with cleanup of the site spent in the local area.
Response:
The likelihood is that the remedial action will have a positive
economic impact on the city of Winnfield and winn Parish. The
remedial action will be awarded to a qualified bidder that is
selected by procedures established in the Federal Acquisition
Regulations. Based on experience at other superfund proj ects, the
selected remedial action contractors generally spend proceeds from
the contract on buying materials from local businesses and hiring
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local labor. In addition, these contractors often buy homes and
rent facilities in the communities surrounding the superfund sites
which should bring benefits to the affected communities. However,
the Federal Acquisition Regulations do not guarantee that the
contractor will hire local labor forces or purchase materials in
the affected community.
10.
Comment:
Has the abandoned creosote site contributed to Winn Parish having
the highest cancer rate in Louisiana?
Response:
This. is a very difficult issue to ascertain. The Louisiana
Department of Health is preparing analyses of cancer rates within
the various Parishes of Louisiana. It is not certain that Winn
Parish has the highest cancer rate in Louisiana. It is also not
possible at this time to attribute a specific cancer-related death
or illness to the abandoned American Creosote plant. The
contaminants from the abandoned plant have carcinogenic compounds
which can lead to cancer. However, in order to prove the materials
at the plant caused any cancer one must establish exposure by a
cancer-afflicted person to these specific carcinogenic compounds
from the specific site. This linkage is further complicated by an
average person I s exposure to other carcinogenic compound from other
sources (~., smoking, car exhaust, natural carcinogens in foods,
etc.).
11.
Comment:
The subsurface beneath Winn Parish contains numerous faults which
could have caused the migration of contaminants to much lower
geologic formations.
Response:
Based on the extensive investigations at the site, the ground water
contamination has not migrated to lower aquifers. This has been
shown by analyzing ground water and subsurface soil samples in the
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area of the shallow and deeper aquifers. Furthermore, there is an
upward gradient from the lower aquifer toward the shallow aquifer
that acts to prevent the downward migration of contaminants.
12.
Comment:
How long will it take to complete incineration of all the material
at the site.
Response:
The incineration aspect of the selected remedy is anticipated to
take approximately 4 years from the date of remedial action
solicitation. Assuming the project is advertized in the fall of
1993, the incineration could be completed as early as the end of
1997.
13.
Comment:
If EPA builds an incinerator, will it be purely
cleaning up the contaminants associated with the
accept-other wastes.
dedicated to
site and not
Response:
If an incinerator is constructed for the American creosote site, it
will be used only to burn contaminants related to this site. It
will be fully dismantled when the contaminants at the American
Creosote site have been incinerated.
14.
Comment:
What are the potential
incineration.
effects. on the community related to
Response:
There should not be any adverse effects on human health or the
environment. The operation of an incinerator at the American
Creosote site will be overseen by representatives of EPA to ensure
protection of human health and the environment. There are possible
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;.-
air emissions resulting from the excavation of the contaminated
sludges prior to the incineration of these materials. However, the
contract to conduct the remedial action places engineering controls
on these operations to reduce the chances of such emissions.
Furthermore, the attainment of all substantive permitting standards
applicable to the operation of hazardous waste incinerators will
ensure the protection of the community. .
In addition, the Agency for Toxic Substances and Disease Registry
in February, 1992, issued a document. entitled "Public Health
OVerview of Incineration as a Means to Destroy Hazardous Wastes,"
which states "ATSDR believes that a properly designed and operated
incinerator can effectively destroy .certain kinds of hazardous
wastes in a manner that is protective of public health." The
contaminants at the site have been proven to be effectively
destroyed by incineration treatability studies and therefore, there
are not expected to be any harmful impacts on the community.
15.
Comment:
Will anyone-have to be relocated during construction. -
Response:
Based on available information, it does not appear necessary to
relocated anyone during the implementation of the remedial action.
16.
Comment:
Will the City of Winnfield be assessed any charge?
Response:
No. EPA has determined that the City is not a liable party
pursuant to Section 107 of CERCLA, 42 U.S.C. S 9607. Therefore, it
has no liability for response costs incurred at the site.
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17.
Comment:
Can the material from the American Creosote site be moved to Texas,
Oklahoma, etc.
Response:
PA has determined the most cost effective and protective measure to
address human health and the environment is to treat the
contaminated materials on-site.
18.
Comment:
What happens if incineration doesn't work?
Response:
Treatability studies and experience at other sites have shown that
incineration should effectively destroy the contaminants to below
health-based limits. However, if incineration and in-situ
bioremediation prove unable to attain those goals, then EPA would
re-evaluate other remedial technoloqies and would meet with the
community and representatives of the state to propose alternate
remedial solutions for the site.
19.
Comment:
A city councilman from the district that includes the American
Creosote site stated a preference for Alternative 5, On-site
Incineration.
Response:
This comment was considered in the formulation of the final remedy.
community support was an important factor in the Region's decision
to incinerate the highly contaminated siudges.
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20.
Comment:
Will there be any odors during the remediation?
Response:
During the remediation air emissions will be controlled to ensure
protection of human health and the environment. There may be an
occasional odor associated with the excavation operation. The
incinerator, however, should not emit siqnificant odors.
21.
Comment:
One individual stated "I recommend if it's going to be cleaned up,
you know, clean it all up. There is no use in cleaning a portion
of it."
Response:
EPA aqrees1 the selected alternative is protective and provides a
permanent remedy to the hazards associated with the site.
b) written Comments
1.
Comment:
On Auqust 26, 1992, EPA received a letter from the Mayor of
Winnfield requesting another public meeting with an extension of
time for the public comment period. It also stated "We feel that
the waste at the American Creosote site should be actively treated,
contained, capped and monitored. This includes both liquid and
solid, surface and subsurface. This appears to be in agreement
with your stated preferred altemative."
Response:
EPA, Reqion 6, did extend the oriqinal public comment period by 30
days and held a second meeting on september 15, 1992. Based on
preliminary discussions between EPA and the state of Louisiana, EPA
had issued a recommendation in the July 29, 1992, Proposed Plan for
capping surface wastes and pumping and treatment contaminated
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ground water and subsurface oils. Subsequent evaluations within
EPA, and discussions with the state and the community (based on the
August 3, 1992, public meeting), have shown that incineration of
the- wastes may. be more acceptable in meeting goals to remediate the
site. In response to this, EPA issued a notice and the local news
media published articles about the possible use of on-site
incineration in early september, 1992.
During the public meeting of september 15, 1992, the city council,
the Mayor, and over 50 individuals from the local area responded to
EPA's proposed alternatives to remediate the site. The number of
people at this meeting was significantly greater than attended the
previous one that was attended only by 4 individuals. Based on the
comments from both meetings it appears that the local community
favors on-site incineration as presented in the Administrative
Record transcripts from the public meetings. No opposition to on-
site incineration was voiced by any individual at either public
meeting.
EPA and LDEQ evaluated written and verbal comments recorded during
the aforementioned comment period and considered the cost for full-
scale incineration at approximately $185 million.- In March 1993,
LDEQ and EPA released a new proposed remedy for the American
Creosote si te which combined elements of remedies previously
proposed and added in-situ biological treatment for the bulk of the
buried contaminated soils. The suggested remedy consisted of the
following components:
(1) PumD. seDarate and treat liauid contaminants. Light
nonaqueous phased liquids (LNAPLs) and dense nonaqueous phased
liquids (DNAPLs) would be pumped from the zones of pooled
product beneath the site, separated from the water, and
destroyed by on- or off- site incineration. (Proposed in July,
1992. )
(2) On site incineration of 25.000 cubic vards of hiahlv
contaminated tars and sludaes. 25,000 cubic yards of tars and
sludges located in the "sludge overflow area" of the site,
which is the most highly contaminated material, would be
excavated and thermally treated on-site. The incinerator ash
would be landfilled on-site. (proposed in August, 1992.)
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(3) In-situ bio1oaica1 treatment of 250.000 cubic vards of
contaminated soils. The remainder of the site's contaminated
soils/sludges from process areas and buried pits would be
addressed in-situ by injecting, via wells, nutrients, microbes
and oxygen as is necessary to attain stated treatment goals.
The ground water extraction system used for NAPL recovery
would also be used to hydraulically control any off-site
migration of ground water contamination and allow for
recirculation of the bacteria for efficient treatment.
Because of the expected pace of remediation, the EPA
would categorize this site remediation as a Long Term
Remedial Action. What this means is that implementation
of this alternative is expected to take several years.
The EPA will be responsible for 90% funding beyond the
customary 1 year time period of the completed remedy.
90' funding will continue until such time as the
established remediation goals are met. The state of
Louisiana will be responsible for 10% of the costs. This
compone!1t is innovative and is expected to provide
permanent treatment. (Based on comments/ information
received during the public comment period).
(4) CaDtdna of surface contaminated soils. decontamination and on-
site 1andfi11ina of Drocess eauiDment and scraD. Grading and
capping would be done to complement the above remedial
actions. (proposed in July, 1992).
The net cost of this set of remedies was estimated between $40-$50
million, which is significantly less than the total cost of the
incineration remedial option (approximately $185 million) and more
environmentally protective than the oriqinal pumping/capping
proposal. Biological treatment of creosote-contaminated soils is
being attempted at numerous wood treater sites nationwide.
Although biological treatment for the site was initially screened
from consideration early in the Feasibility study, in light of the
comments received and considering the extreme cost of complete on-
site incineration, the EPA and LDEQ believe this innovative
technology warrants implementation.
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2.
Comment:
On AUCJUst 26, 1992, EPA received a letter from the Louisiana
Pacific Corporation, which owns the property on which the tar mat
area is located. The letter recommended removal of the tar mat
materials and materials along the natural drainage from the tar mat
area. The letter also recommended additional surface soil sampling
in the area between the tar mat and Creosote Branch and full scale
remediation of the ground water in the same area "to the same
degree and in the same time frame as the ground water on the
American creosote site." Furthermore, the letter suggests that EPA
consider purchasing the Louisiana Pacific corporation property
on which the contamination is located.
Response:
EPA's selected remedy would remove and treat contaminated materials
from the tar mat area and its related drainage area. The soils in
the area between the tar mat and Creosote Branch have been
sufficiently sampled and are not being removed as part of this
remedy-- These soils are not considered a significant threat to
ground water and involve an area defined as a- wetlands. The
wetlands would be destroyed if these soils were excavated and, as
discussed in the Summary of site Risks section of this ROD, the
soils are within the EPA's acceptable risk range. Removal of the
source of contamination from the impoundment, process, and tar mat
areas wili allow the restoration of ground water by natural
attenuation. In addition, EPA does not acquire property for the
convenience of the landowner, but takes actions to protect the
human health or the environment. CERCLA S 104(e) (3) (D), 42 U.S.C.
i 9604 (e) (3) (D), permits EPA to gain access to the property on
which contamination is found to effectuate a response action.
Therefore, EPA' s selected remedy calls for a response action
pursuant to CERCLA Section 106, 42 U.S.C. i 9606, and it is not the
intent of the EPA to purchase property but to address this threat
to human health or the environment.
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. .
3.
Comment:
EPA received a letter from a resident of Winnfield, Louisiana
stating "My personal opinion is that EPA clean up the entire area
as soon as possible. :I don't know enough about the options to say
which :I prefer. Your choice would be the best I'm sure."
Response:
EPA appreciates the faith of the public and will make every effort
to address the site as soon as possible. It is believed that the
selected remedy will meet the goals of this comment.
4.
Comment
EPA received a letter dated September 21, 1992, from a commercial
remediation contractor recommending bioremediation for the
creosote-contaminated soils. Their information indicated that the
contractor could process approximately 240 tons of contaminated
material in-three-day cycles and that the cost would be-between $50
to $75 per ton (not including excavation costs). using these
values and considering that the site contains approximately 275,000
cubic yards of contaminated material, which equals about 385,000
tons, it would take almost 13 years to remediate the site at a cost
of about $25 million (not including excavation and dewatering).
Response:
Even considering this information, it is believed that in-situ
bioremediation will be the most cost effective remedy for reducing
concentrations of subsurface contamination. It is expected that a
savings of over $50 million as compared to ex-situ bioremediation
will be realized. :In addition, as stated in the ROD, it is
necessary to incinerate the highly contaminated sludges which are
not conducive to bioremediation.
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s.
Comment
EPA received. a letter from a resident of Winnfield, Louisiana on
September 29, 1992, stating "It is my belief and desire that you
use Alternative 5C (On-site Incineration) and remove all
contamination once and for all so that our children and
grandchildren would have a safe place to live."
Response:
EPA and LDEQ believe that the selected remedy will achieve the same
goals as indicated at a substantial savings using a combination of
incineration and in-situ bioremediation, rather than full-scale
incineration.
6.
Comment:
EPA received a letter on september 29, 1992, from one of the
businesses located in Winnfield, Louisiana, that stated "Of the
options presented at the meeting, in my opinion, Option 5C
(incineration) would be the most feasible and. safest for the
citizens of this community. n .
Response:
See response to Comment s.
7.
Comment:
EPA received a letter dated March 25, 1993, from a commercial
incineration company regarding a closed loop incineration system
that reportedly could conduct the work at a substantially reduced
cost than presented in the Feasibility Study.
Response:
The selected remedy includes partial excavation and incineration of
the sludges, and the cost estimates are presented as estimates only
and are accurate for comparative purposes at the ROD stage. The
-------
cost estimate will be refined during the Remedial Design, and if
the commentor takes the opportunity to submit a proposal and bid
according to the planned solicitation, then its proposal will be
evaluated under the terms of the Federal Acquisition Regulations
(FARS) .
8.
Comment:
The Louisiana-Pacific corporation submitted two additional comments
in a letter dated Karch 26, 1993. The first comment dealt with the
word "site" and requested that a drawing be prepared showing
property lines and identifying that contamination has been
identified and will be remediated on Louisiana-Pacific
corporation's property. The second comment dealt with deed notices
or deed restrictions placed on Louisiana-Pacific Corporation's
property that is currently contaminated.
Response:
When applying the term "site" to a Superfund site, EPA uses the
definition as consisting of the areal extent of contamination and
all suitable areas in very close proximity to the contamination
necessary for implementation of the response action. EPA
recognizes that contamination from the wood treating facility is
located on Louisiana-Pacific corporation's property and is
addressing the contamination as specified in the ROD. At this
stage it is unnecessary to show property boundaries. EPA will
coordinate with the Louisiana-Pacific corporation to gain access to
conduct the remedial action.
At this time it appears that all contaminated sludges above heal th-
based standards on the Louisiana-Pacific property will be
incinerated. As such it appears that it may be unnecessary at the
time of completion of incineration operations to place deed notices
or deed restrictions on this property. .
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9.
Comment:
EPA received a letter from the City of Winnfield's Director of
Public Works which indicated a preference for full-scale
incineration. However, the letter also recognized that if that
alternative was not implemented that support would be given to the
proposed remedy as outlined in the March 1, 1993, Final Proposed
Plan.
Response:
No response necessary.
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APPENDIX G
AMERICAN CREOSOTE WORKS, INC.
RECORD OF DECISION ADMINISTRATIVE
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ADMINISTRATIVE RECORD INDEX
INTERIM
SITE NAME:
American Creosote Site
SITE NUMBER:
LAD 000239814
INDEX DATE:
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DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
INTERIM
~':c;;.-
American Creosote Site
LAD 000239814
000001 - 000026
Undated
26
Office of Waste Programs Enforcement
U.S. EPA
File
Users Manual
Compendium of CERCLA Response Selection Guidance Documents
000027 - 000029
06/11/85
3
Larry Fitzgerald
Louisiana Department of Environmental Quality
Thomas H. Patterson, Enforcement Program Manager,
Dept. of Environmental Quality
General Inspection Report
Re: Previous infraction/Follow-up inspection
Louisiana
000030 - 000030
03/16/87
1
Buddy Parr
U.S. EPA Region 6
Files
Record of Communication (ROC)
Re: Follow-up action needed to determine exact site
boundaries to identify the area owned by Stallworth Timber
000031 - 000031
03/16/87
1
Pat Hammack
U.S. EPA Region 6
File
Site Identification Form
Potential Hazardous Waste Site Identification
possible removal. action at site
concerning
1
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
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NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
INTERIM
American Creosote Site
LAD 000239814
000032 - 000075
05/14/87
44
Linda E. \Tilson, Technical Assistant Team (TAT)
Ecology and Environment, Inc.
Pat Hammack, On Scene Coordinator (OSC) , U.S. EPA Region 6
Site Report
Site Assessment on American Creosote Co. SitefWood Treatment
Facility updating 04/27/87 interim site assessment report
000076 - 000085
07/27/87
10
Keith Bradley, Field Investigation Team (FIT), Regional
Project Officer (RPO)
U.S. EPA Region 6
Martha McKee, Chief, Compliance Section, U.S. EPA Region
Preliminary Assessment Report
The report identifies hazardous material, contaminants, and
structures within the area
000086 - 000102
08/03/87
17
Joe Phillips
ICF Technology
U.s. EPA Region 6
Report with attachment A and B
Potential Hazardous \Taste Site
- Site Inspection Report
000103 - 000213
08/12/87
111
Linda E. \Tilson, U.S. EPA Region 6, TAT
Ecology and Environment, Inc.
Jim Staves, OSC, U.S. EPA Region 6,
Site Sampling Plan
The plan identifies potentially hazardous materials and
characteristics of appropriate methods of removing the
creosote
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SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
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DOCUMENT TYPE:
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ADMINISTRATIVE RECORD INDEX
INTERIM
American Creosote Site
LAD 000239814
000214 - 000214
08/13/87
1
James C. Staves, OSC
u.S. EPA Region 6
Hilton Frey, Chief, Superfund Compliance
Region 6
Memorandum
Re: Removal Action at
Louisiana; recommends
party (PRP) search to
Section, U.S. EPA
the American Creosote Site, Yinnfie1d,
the initiation of potential responsible
find PRPs to assist in removal
000215 - 000255
08/21/87
41
Dave Wineman, FIT RPO
U.S EPA Region 6
Martha McKee, Chief, Compliance, u.S. EPA Region 6
Report and Attachments
Site Inspection Report describing ground and migration'
contaminants
000256 - 000257
09/02/87
2
Oscar Cabra, Jr., P.E., Yater Supply Branch
U.S. EPA Region 6
Martha McKee, Chief, Superfund Compliance Section,
Region 6
Comments on Site Inspection Report
Re: Recommmendation that groundwater sampling be
the sampling survey
u.S. EPA
included in
000258 - 000315
10/13/87
58
Peter Frasca, Ph.D.
Electron-Microsc~py Service Laboratories Inc.
Ecology & Environment, Inc.
Lab report
Asbestos fiber analysis - North Tank & South Pipe
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."
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SITE NAME:
SITE NUMBER:
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AUTHOR:
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DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
INTERIM
American Creosote Site
LAD 000239814
000316 - 000505
10/22/87
190
Ann Looney, TAT
Ecology & Environment, Inc.
Jim Staves, OSC, U.S. EPA Region 6,
Report and Attachments
Immediate Removal Potential Report;
Sampling Mission
000506 - 000572
10/23/87
67
Ann Looney, TAT
Ecology & Environment, Inc.
Jim Stavens, OSC, U.S. EPA Region 6
Report and Attachments
Immediate Removal Potential Report -
analysis
Sampling for asbestos
000573 - 000573
11/25/87
1
James C. Staves, ose
U.S. EPA Region 6
Brent Truskowski, Superfund Compliance Section, U.S. EPA
Region 6
Memorandum
Re: Precautions that have been proposed for the site
000574 - 000576
11/30/87
3
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
William Shuler Jr., Yinnfield, LA
104(e) letter
A discovery letter notifying any person who generates, stores,
treats, transports or otherwise handles or has handled'
hazardous waste, shall upon request furnish information
relating to such wastes
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SITE NUMBER:
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. DOCUMENT NUMBER:
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AUTHOR:
COMP~"!/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
INTERIM
American Creosote Site
LAD 000239814
000577 - 000579
11/30/87
3
Allyn M. Davis, Director, Hazardous Yaste Management Division
U.S. EPA Region 6
Yilliam Shuler, Jr.
104(e).Letter
Re: Request to provide answers to questions about disposal
practices at the American Creosote site in Winnfield,
Lousis iana
000580 - 000582
12/07/87
3
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Dennis Stallworth, President, Stallworth Timber Co. Inc.
104(e) Letter
Re: Request to provide answers to questions about disposal
practices at the American Creosote Site in Winnfield,
Louisiana
000583 - 000586
12/07/87
4
Allyn M. Davis, Director, Hazardous Waste Management Division
U.S. EPA Region 6
Dennis Stallworth, President, Stallworth Timber Co. Inc.
104(e) Request Letter
Any person who generates, stores, treats, transports or
otherwise handles or has handled hazardous wastes, shall upon
request furnish information of such wastes
000587 - 000590
01/05/88
4
George Pettigrew
Agency fot Toxic
James C. Staves,
Memorandum
Re: Health Consultation -
and Mark Mclanahan, Ph.D.
Substances and Disease Registry
OSC, U.S. EPA Region 6
American Creosote Company
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SITE NUMBER:
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DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
INTERIM
American Creosote Site
lAD 000239814 .
000591 - 000594
01/07/88
4
James W. Thames, General Manager
Stallworth Timber Company, Inc.
Brent Truskowski, U.S. EPA Region 6
104(e) Response Letter
A response answering questions from a
12/7/87
104(e) letter dated
000595 - 000653
01/22/88
59
Ann L. Looney, TAT
Ecology &.Environment, Inc.
James Staves, OSC, U.~. EPA Region 6
Information Management Report
Removal Technology Alternatives
000654 - 000670
01/27/88
17
Frances Verhalen, FIT Environmental Scientist
Ecology and Environment, Inc.
Dave Wineman, Regional Project Officer (RPO)
Memorandum with attachment
Re: Sampling location descriptions for American
Works site, attached site location maps
Creosote
000671 - 000683
02/02/88
13
Bill Barham
Ecology and Environment, Inc.
Greg McAnarney, Ecology and Environment
Plan
Hazardous and Toxic Materials Team Site Safety Plan
massive on~site and off-site surface contamination
concerning
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SITE NUMBER:
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DOCUMENT TYPE:
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AUTHOR:
COMPANY/AGENCY:
aECIPIENT:
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ADMINISTRATIVE RECORD INDEX
INTERIM
American Creosote Site
LAD 000239814
000684 - 000693
02/29/88
10
James C. Staves, OSC
U.S. EPA Region 6
Robert E. Layton Jr., Regional Administrator
Action Memorandum
Request for Removal Action at the American Creosote site
000694 - 000710
03/07/88
17
Christopher L. Quina, U.S. EPA Region 6, TAT
Ecology & Environment, Inc.
Jim Staves, OSC, U.S. EPA Region 6
Report and Attachments
Site Assessment - EPA Environmental Response Team Extent of
Contamination Project Oversite
000711 - 000719
03/24/88
9
Ann L. Looney, TAT
Ecology & Enviroment, Inc.
Greg Fife, OSC, U.S. EPA Region 6
Correspondence and Attachments
Letter indentifying surrounding property
may be enclosed by the fence surrounding
owners whose proper=y
the site
000720 - 000727
04/01/88
8
Tom Nystrom, Gene Keepper .
Ecology and Environment, Inc.
File
Trip Report
Wetland Delineation Trip Report concerning
two sites that were found to have wetlands
investigation of
present
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ADMINISTRATIVE RECORD INDEX
INTERIM
American Creosote Site
LAD 000239814
000728 - 000728
04/05/88
1
Brent J. Truskowski
U.S. EPA Region 6
J ames Thames ," Stallworth Timber Company
Correspondence .
Re: Access to the American Creosote site
purposes
for sampling
-000729 - 000729
04/05/88
1
Brent J. Truskowki
U.S. EPA Region 6
William Pharr, Louisiana Pacific Lumber Company
Correspondence
Re: Access to Louisiana Pacific Lumber Company's property for
purposes of a removal action to be performed by EPA
000730 - 000730
04/05/88
1
Brent J. Truskowski
U.S. EPA Region 6
William Shuler, Jr.
Correspondence
Re: Access to property for purpose of fencing the American
Creosote site
000731 - 000905
04/05/88
175
Kenneth Tyson and Kwasi Boateng
U.S. EPA Region 6
Harry Compton and George Prince
Report and Attachments
Final Draft Report - Environmental
American Creosote Chemical site
investigation of the
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ADMINISTRATIVE RECORD INDEX
INTERIM
American Creosote Site
LAD 000239814
000906 - 000906
04/19/88
1
Keith Newsom
Louisiana-Pacific Corporation
Brent Truskowski, U.S. EPA Region 6
Letter
Louisiana-Pacific (LP) grants EPA permission to access the
property with a stipulation that LP is allowed to harvest
timber
000907 - 000907
04/21/88
1
Allyn M. Davis, Hazardous Yaste Management Division
U.S. EPA Region 6
Yilliam B. DeVille, Administrator, Louisiana Department of
Environmental Quality
Transmittal Letter without Attachment
Re: Administrative Order issued by the EPA to the Stallworth
Timber Company; no attachments
000908 - 000926
04/21/88
19
J. Hilton. Frey, Chief, Superfund Compliance Section
U.S. EPA Region 6
James Thames, Stallworth Timber Company
Letter and Administrative Order
Explaining procedures that the Stallworth Timber Company would
have to perform in pursuant to Section 106(a) of the
Comprehensive Enviromental Response, Compensation and
Liability Act of 1980
000927 - 000945
04/21/88
19
Donald L. Perry. Ph.D.
Enviromed Laboratories, Inc.
Peterson Reidel
Lab Report
Organic analyses report of toxies taken from water tanks on
04/05/88
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.
SITE NAME:
SITE NUMBER:
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ADMINISTRATIVE RECORD INDEX
INTERIM
American Creosote Site
LAD 000239814
000946 - 000949
04/26/88
4
Harry R. Compton,
U.S. EPA Region 6
Jim Staves, OSC
Memorandum
Executive Summary
Site
Enviro11D1ental Response Branch (EBB)
and final report for the American Creosote
000950 - 000951
05/01/88
2
Barbara Biggers, Emergency Response Branch
U.S. EPA Region 6
Public
Information Bulletin
Re: Construction of fencing/warning signs around the American
Creosote facility
000952 - 000952
05/04/88
1
Billy Thames, General Manager
Stallworth Timber Company, Inc.
Brent Truskowski, Superfund Compliance Section, U.S. EPA
Region 6
Letter
Re: Administrative Order - Billy Thames is designated as
facility coordinator as requested by the order
000953 - 000957
05/16/88
5
James C. Staves, OSC
U.S. EPA, Region 6
Stallworth Timber Company, Inc.
Record of Communication
Conference call with Stallworth Timber
to ensure Work Plan would be available
Company Representative
on OS/23/88
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ADMINISTRATIVE RECORD INDEX
. INTERIM
American Creosote Site
LAD 000239814
000958 - 000992
05/18/88
35
Kei th S. Kline
ATEC Associates, Inc.
Dennis Heuring, TMS Analytical Services, Inc.
Lab Report .
Report of test results taken on site on 05/10/88
000993 - 001137
OS/25/88
145
Dave Wineman, FIT RPO, Hazardous Waste Section
U.S. EPA Region 6
Martha McKee, Chief, Compliance Section, U.S. EPA Region 6
Memo with attachment
Sampling Inspection Report with attached sample location maps,
organic analysis summary and chain of custody-records
001138 - 001139
OS/27/88
2
James C. Staves, OSC
U.S. EPA, Region 6
Robert E. Layton Jr., P.E., U.S. EPA, Region 6
Memorandum
Re: Request for Redirection of Approved Funds for American
Creosote Site
001140 - 001141
OS/27/88
2
B. Truskowski
U.S. EPA, Region 6
Billy Thames, Stallworth Timber Company
ROC
Re: Stallworth's refusal to perform removal action, permits
access to site by EPA
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SITE NUMBER:
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ADMINISTRATIVE RECORD INDEX
INTERIM
American Creosote Sit~
LAD 000239814
001142 - 001142
06/09/88
1
Unspecified
Unspecified
U.S. EPA Region 6 Site Files
Attendees List
06/09/88 meeting concerning American Creosote site
001143 - 001144
07/21/88
2
Oscar Cabra, Jr., P.E., Chief, Water Supply Branch
U.S. EPA Region 6
Presley Hatcher, Acting Chief, Superfund Compliance Section,
U.S. EPA Region 6
Memorandum
Comments on CERCLA Investigation Reports Re: No contaminants
were detected, no further action regarding drinking water
necessary at this time
001145 - 001325
09/13/88
181
Technical Assistance Team
Ecology and Environment, Inc.
J. Chris Petersen, U.S. EPA, Region 6
Report
Site Assessment Report on American Creosote, Winnfie1d,
Louisiana
001326 - 001326
09/13/88
1
Jo Ann Woods, Emergency Response Branch
U.s. EPA Region 6
Hilton Frey, Chief, Enforcement Compliance, u.S. EPA Region 6
Memorandum
Re: Notification of a Proposed Time-Critical Removal Action
at the American Creosote site
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ADMINISTRATIVE RECORD INDEX
INTERIM
American Creosoce Site
LAD 000239814
001327 - 001331
09/13/88
5
Unspecified
U.S. EPA, Region 6
Pub lic
Notice of Public Availability
Removal Administrative Record File,
Winnfield, Louisiana
American Creosote Site,
001332 - 001349
02/10/89
18
James C. Staves, OSC
U.S. EPA, Region 6
Robert E. Layton Jr., U.S. EPA, Region 6
Action Memorandum
Re: Request for Removal Action at American Creosote Site,
Winnfie1d, Louisiana
001350 - 001367
02/13/89
18
Unspecified
U.S. EPA, Region 6
Stallworth Timber Company, Inc.
Administrative Order
Re: Orders company to appoint a facility coordinator,
develop work plan in 14 days, and reimburse EPA for costs
within 60 days upon receipt of invoice
001368 - 001389
02/16/89
22
Unspecified
Unspecified
U.S. EPA Region 6 Site Files
Index
Removal Administrative Record Inde. for American Creosore site
\
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ADMINISTRATIVE RECORD INDEX
INTERIM
American Creosote Site
lAD 000239814
001390 - 001390
02/28/89
1
James Y. Thames, General Manager
Stallworth Timber Company
Buddy Parr, U.S. EPA Region 6
ROC
Re: Request for extension on the requirement in the .
Administrative Order (AO) that the company submit a plan for
cleaning up the site within 14 days of effective date of the
AO
001391 - 001391
03/16/89
1
Buddy Parr
U.S. EPA Region 6
Files
ROC
Re: Meeting held between EPA and Stallworth Timber Company in
response to AO issued 2/13/89 directing Stallworth to perform
certain removal actions at site
001392 - 001580
03/30/89
189
Technical Assistance Team (TAT)
Ecology and Environment, Inc.
J. Chris Petersen, Deputy Project Officer, U.S. EPA Region 6
Report
Technical Assistance Report - Project Support for Proposed
Removal Actions at American Creosote site.
001581 - 001583
04/06/89
3
Robert A. Matthews
McKenna, Conner & Cuneo Law Firm
Buddy Parr, U.S. EPA Region 6
Correspondence
Re: In the Matter of Stallworth Timber Co., Inc., Respondent,
Regarding American Creosote Site; financial inability to fully
cooperate with Administraive Order Docket Number
CERCLA-VI-04-89
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COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE: -
DOCUMENT TITLE:
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AUTHOR:
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, DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
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DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
INTERIM
American Creosote Site
LAD 000239814
001584 - 001586
04/06/89
3
Robert A. Mattews
McKenna. Conner & Cuneo
Buddy Parr. Cost Recovery Section. U.S. EPA Region 6
Letter
Re: Stallworth Timber Co. - Administrative Order; Stallworth
Timber Co. is willing to cooperate with EPA, however,
Stallworth Timber Co. is financially incapable of funding the
cleanup
001587 - 001587
04/11/89
1
H.J. Parr, Chief, Cost Recovery Section
U.S. EPA Region 6
Billy Thames, General Manager, Stallworth Timber Company
Correspondence
Re: Refusal by Stallworth Timber Company to comply with
Adminstrative Order issued to conduct removal actions at site
001588 - 001601
06/23/89
14
. TAT
Ecology and Environment, Inc.
J. Chris Petersen, Deputy Project Officer, u.S. EPA, Region 6
Report .
Special Projects Report - "Notice of Public Availability" of
the Administrative Record on American Creosote Site,
Winnfield, Louisiana
001602 - 001609
07/26/89 .
5
Gregory E. Fife. ose
U.S. EPA Region 6
Robert E. Layton. Jr., P.E., Regional Administrator, U.S. EPA
Region 6
Action Memorandum
Re: Request for ceiling increase of $467,700 to continue
removal action at American Creosote site
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ADMINISTRATIVE RECORD INDEX
INTERIM
American Creosote Site
lAD 000239814
001607 - 001628
09/13/89
22
Ann L. Looney Jarboe, Region 6, Technical Assistance Team
(TAT)
Ecology and Environment, Inc.
Greg Fife, ose, U.S. EPA Region 6
Technical Report
Removal Report - American Creosote Site
001629 - 001637
02/26/90
9
Charles A. Gazda, Chief, Emergency Response Branch
U.S. EPA Region 6
Sam Becker, Chief, Superfur.a Enforcement Branch, U;S. EPA
Region 6
Memorandum
Re: Enclosure of After Action Memorandum - American Creosote,
Site ID :fIG3
001638 - 001658
06/12/90
21
Troy M. Naquin, Region 6, TAT
Ecology and Environment, Inc.
Greg Fife, OSC, U.S. EPA Region 6
Technical Report
Site Assessment Report - American Creosote Site,
include location maps and photodocumentation
attachment:s
001659 - 001667
06/25/91
9
Allyn M. Davi!.
Hazardous Waste Management Division, U.S.EPA Region 6
Mr. William Jacob Shuler, Jr.
104(e) Letter
Letter requesting information regarding the American
Creosoting Site
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ADMINISTRATIVE RECORD INDEX
INTERIM
American Creosote Site
LAD 000239814
001668 - 001675
06/25/91
8
Allyn M. Davis
Hazardous Waste Management Division, U.S. EPA Region 6
John Ball
104(e) Letter
Letter requesting information relating to the American
Creosoting Site
001676 - 001677
12/12/91
2
Robert A. Matthews
McKenna & Cuneo
John Dugdale, Esq., Office of Regional Counsel, U.S. EPA
Region 6
Letter
Letter confirms Stallworth's financial inabilfty to
participate in removal activities. Due to Stallworth's
financial position, Stallworth waives its rights to receive an
EPA Special Notice.
001678 - 002029
01/31/92
352
William A. Koski, P.E., Deputy Project Manager
CDM Federal Programs Corporation
Burt Griswold, Remedial Project Manager, U.S. EPA Region
Cover Letter and Plan
Field Sampling Plan for Remedial Investigations/Feasibility
Study
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
AMERICAN CREOSOTE SITE
SITE NUMBER: LAD 000239814
INDEX DATE:
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IN'I'RODUCI10N
Section 113{J1(1) of the CompreheDsive Envinmmental Respcmse, Co~matiou. ami
Liability Act (CERCLA) pnwides that judicial review of any issues CODCemiDg the adequacy
of any respoDSe action shan be limited to the admimstrative record wbich has been
c:ompiled for the site at issue.
Section 113(k)(1) of CERCIA, requires that the UDited States Euviromnema1 Protection
Agency (AgeDC)') establish admimstrative records for the selection of CERCIA respcmse
amom. '!be admiDistrative record is the body of ~''''en1S upon which the Agency based
its se1ecdOl1 of a respouse action must be d""'.~ed thoroughly in the admiDistrative
record. '!be Agency must eIisure that the record is a compiJation of d""Uments le8m,,! up
to and refleMi"g the AgenCy's respoDse cfetoilion.
In accordance with U.s. EPA Headquarters OSWER Directive 9833.3, Section 113(k) of
the Comprehemive Enviromnental Response, CompeDSation and Liability Act (CERCLA),
as An1ended in 1986 by the Superfund AmeDdm~nts and Reauthorization Act (SARA) the
U.S. EP A is required to compile and make available to the public .A.dminictrative Records
CODtaini"g documents used to suppon respouse actions authorized under CERCLA and
SARA.. The .A.dminictrative Records are to be mamtained at the relevant U.S. EP A
. RegioDal Offices as weD as "at or near the facility at issue." .
This ~tive Record File Index consists of information upon which the Agency based
its decision on selection of respouse actions. It is a subset of information included in the
site files. The records in this Administrative Record File Index have been arranged in
chronological order (from the earliest date to the most recent date), based on the date of
the corresponding document. Each document contained in the Administrative Record File
has been stamped with sequential document numbers, to assist in the location of the
document within the Record File.
This Adminictrative Record File Index has been compiled in accordance with OSWER
DireCtive Number 9833.1a Interim Guidance on Adminictrative Records for DecisioDS on
SeleCtion of CERCLA Response Actions. 'Ibis guidance reflects, to the extent practicable
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. ..AAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAA.AAAAA
AAAA.AAAAAAAAAA.AAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAA
* I. CHRONOLOGICAL LISTING *
***AAAAAAAAAAAAAAAAAAA**AAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAA
*********.AA..AAAA.AAAAA***AAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAA
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SITE NAME:
SITE NUMBER.:
DOCUMENT NUMBER.:
DOCUMENT DATE:
NUMBER. OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
DOCUMENT NUMBER.:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE: -
DOCUMENT TITLE:
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DOCUMENT DATE:
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AUTHOR:
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RECIPIENT:
DOCUMENT TYPE:
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DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
AMERICAN CREOSOTE SITE
LAD 000239814
002030 - 002171
06/08/92
142
A. Siag and J .W. Lee
Acurex Environmental Corporation Incineration Research
Facility
U.S. EPA Region 6 Site Files
Report
"'Evaluating the Thermal Treatability of Contaminated Soils
. from the Popile and American Creosote Superfund Sites'"
(Superfund Technical Assistance Response Team Screening Tests)
002172 - 002360
06/26/92
189
Staff Consultants
CDM Federal Programs Corporation
U.S. EPA Region 6 Site Files
Remedial Investigation/Feasibility
Remedial Investigation/Feasibility
(Sections 1-8)
Study
Study Report - Volume 1
002361 - 002496
06/26/92
136
Staff Consultants
CDM Federal Programs Corporation
U.S. EPA Region 6 Site Files
Remedial Investigation/Feasibility Study
Remedial Investigation/Feasibility Study Report
(Sections 9-11)
- Volume 2
002497 - 003210
06/26/92
714
Staff Consultants
CDM Federal Programs Corporation
U.S. EPA Region 6 Site Files
Remedial Investigation/Feasibility Study
Remedial Investigation/Feasibility Study Report
(Appendixes A-E)
- Volume 3
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SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
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AUTHOR:
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RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
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ADMINISTRATIVE RECORD INDEX
ADDENDUM:
AMERICAN CREOSOTE SITE
LAD 000239814
003211 - 003888
06/26/92
678
Staff Consultants
CDM Federal Programs Corporation
U.S. EPA Region 6 Site Files
Remedial Investigation/Feasibility Study
Remedial InvestigationjFeasibility Study Report
(Appendix E)
- Volume 4
003889 - 004339
06/26/92
451
Staff Consultants
CDM Federal Programs Corporation
U.S. EPA Region 6 Site Files
Remedial Investigation/Feasibility Study
Remedial Investigation/Feasibility Study Report
(Appendixes F-G)
- Volume 5
004340 - 004341
07/13/92
002
Paul A. Karas, Task Manager
CDM Federal Programs Corporation
Robert Griswold, RPM, Superfund Branch, U.S. EPA Region 6
Correspondence
Re: Revised Feasibility Study (Volume 2 of 5) and minor
changes and additions to other sections and appendices
004342 - 004369
07/13/92
028
David Y. Charters, Ph.D. Environmental Response Team
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Report
HYetland Delineation Report for the American Creosote SiteN
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
AMERICAN CREOSOTE SITE
LAD 000239814
004370 - 004448
07/13/92
079
EPA Staff
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Raw Data
~w Data from Stabilization Treatability Study for American
Creosote Yorks, IncN
004449 - 004663
07/13/92
215
Staff Consultants
CDM Federal Programs Corporation
U.S. EPA Region 6 Site Files
Risk Assessment
NRisk Assessment for the American Creosote
Site"
004664 - 004721
07/20/92
058
EPA Staff
U.S. EPA Region 6
U.S. EPA Region 6 Site Files
Report
"Ecological Risk Assessment
Yinnfield, lAN
for the American Creosote Site,
004722 - 004743
07/22/92
022
EPA Staff
u.s. EPA Region 6
U.S. EPA Region 6 Site Files
Announcement for Proposed Plan
"EPA Announces Proposed Plan"
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