First Five-Year Review Report
for the
Central Wood Preserving Company Superfund Site
East Feliciana Parish, Louisiana
April 2009
Performed by:
U.S. Environmental Protection Agency
Region 6
Dallas, Texas
Prepared by:
United States Army Corps of Engineers
Tulsa District
Tulsa, Oklahoma
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Determinations
It is determined that the remedy for the Central Wood Preserving Company Superfund Site is functioning as
designed as a result of the Remedial Actions that have taken place and continues to be protective of human
health and the environment because the wastes have been removed from the site, and those wastes
remaining, greater than three feet in depth, are addressed with the implementation of institutional controls.
One action item identified in the First Five-Year Review Report will require attention and be addressed as
described above in order for the remedy to be confirmed effective in the long term.
Samuel Coleman, P.E.
Director, Superfund Division
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CONCURRENCES
FIVE-YEAR REVIEW
Central Wood Preserving Company Superfund Site
EPA ID#LA008187940
Laura Stankosky :
Remedial Project Manager, tA/OK/NM Section
Date
Buddy Par
Chief, LA/OK/NM Section
Date
Edwin Quinones
Assistant Regieftal Counsel
Mark
Chief, Regional Counsel
H-il-O0!
Date
Donald Williams
Deputy Associate Director, Remedial Branch
larles Faultry
Associate Director, Remedial Branch
Date'' /
Date
Pamela Phillips /
Deputy Division Directo/, Superfund Division
Date
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Table of Contents
Section Page
List of Acronyms iii
Executive Summary iv
Five-Year Review Summary Form vii
1.0 INTRODUCTION 1
2.0 SITE CHRONOLOGY 2
3.0 BACKGROUND 2
3.1 PHYSICAL CHARACTERISTICS 2
3.2 OPERATIONAL HISTORY 3
3.3 REGULATORY HISTORY 3
3.4 ENVIRONMENTAL SETTING 4
3.5 LAND AND RESOURCE USE 6
3.6 HISTORY OF CONTAMINATION 7
3.7 INITIAL RESPONSE 9
3.8 SUMMARY OF BASIS FOR TAKING ACTION 11
4.0 REMEDIAL ACTIONS 12
4.1 REMEDY OBJECTIVES 13
4.2 REMEDY SELECTION 14
4.3 REMEDY IMPLEMENTATION 17
4.3.1 PREPARATORY ACTIVITIES 18
4.3.2 SOIL AND SEDIMENT EXCAVATION 18
4.3.3 THERMAL DESORPTION 20
4.3.4 WASTE MANAGEMENT AND DISPOSAL 20
4.3.5 SITE RESTORATION 21
4.3.6 MONITORING WELL INSTALLATION 22
4.4 OPERATIONS AND MAINTENANCE 23
5.0 FIVE-YEAR REVIEW PROCESS 24
5.1 COMMUNITY INVOLVEMENT 24
5.2 DOCUMENT REVIEW 24
5.3 DATA REVIEW 24
5.4 INSTITUTIONAL CONTROLS 28
5.5 INTERVIEWS 28
5.6 SITE INSPECTION 28
6.0 TECHNICAL ASSESSMENT 29
6.1 QUESTION A: Is THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION DOCUMENTS? 29
6.2 QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS, AND REMEDIAL
ACTION OBJECTIVES USED AT THE TIME OF THE REMEDY SELECTION STILL VALID? 30
6.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO QUESTION THE
PROTECTIVENESS OF THE REMEDY? 33
7.0 ISSUES 33
8.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS 34
9.0 PROTECTIVENESS STATEMENT 34
10.0 NEXT REVIEW 34
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List of Figures
Figure 1 Central Wood Preserving Superfund Site Location Map
Figure 2 Central Wood Preserving Post Remedial Investigation Site Plan
Figure 3 Central Wood Preserving Post Remedial Action Arsenic Concentrations in Unexcavated
Areas
Figure 4 Central Wood Preserving Post Remedial Action Benzo(a)anthracene Concentrations
Figure 5 Central Wood Preserving Topsoil Placement Site Plan
Figure 6 Central Wood Preserving Post Remedial Action Site Plan
List of Tables
Table 1 Chronology of Site Events
Table 2 Ground Water Analytical Results
Table 3 Monitoring Well Measurement Data
Attachments
Attachment 1 Documents Reviewed / References
Attachment 2 Interview Record Forms
Attachment 3 Site Inspection Checklist
Attachment 4 Site Inspection Photographs
Attachment 5 Notice to the Public Regarding the Five-Year Review
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List of Acronyms
|j,g/L Micrograms per liter
ACM Asbestos Containing Materials
ARARs Applicable or Relevant and Appropriate Requirements
bgs Below ground surface
BTU British thermal unit
CCA Copper chromated arsenate
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
COC Contaminants of concern
CRT Cone penetrometer
CWP Central Wood Preserving Company
CY Cubic yard
DNAPL Dense nonaqueous phase liquid
ELCR Excess lifetime cancer risk
EPA Environmental Protection Agency
ERB Emergency Response Branch
ESI Expanded site investigation
FS Feasibility Study
HI Hazard index
HRS Hazard Ranking System
LDEQ Louisiana Department of Environmental Quality
LDR Land disposal restrictions
LTTD Low Temperature Thermal Desorption
MCL Maximum contaminant level
MCLG Maximum contaminant level goals
mg/kg Milligrams per kilograms
MW Monitoring well
NAPL Nonaqueous phase liquid
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NPL National Priorities List
O&M Operation and maintenance
PAH Polynuclear aromatic hydrocarbons
PCP Pentachlorophenol
PRG Preliminary remediation goals
POP Proof of performance
ppm Parts Per million
RA Remedial Action
RAO Remedial Action Objectives
RCRA Resource Conservation and Recovery Act
RD Remedial Design
RECAP Risk Evaluation/Corrective Action Program
RG Remediation goal
Rl Remedial Investigation
ROD Record of Decision
ROST Rapid Optical Screening Tool
SA Site Assessment
SARA Superfund Amendments and Reauthorization Act
SH State Highway
SI Site Inspection
SVOC Semivolatile organic compound
TAT Technical Assistance Team
TCLP Toxicity Characteristic Leaching Procedure
USAGE U.S. Army Corps of Engineers
USGS United States Geological Survey
VOC Volatile organic compound
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Executive Summary
The First Five-Year Review of the Central Wood Preserving Company Superfund Site located in East
Feliciana Parish, Louisiana was completed in April 2009. The review was conducted from November 2008
through March 2009. The results of the First Five-Year Review indicate that the remedy is protective of
human health and the environment because wastes have been removed from the site, and wastes
remaining, greater than three feet in depth, are addressed with the implementation of institutional controls.
The facility operated from the 1950s to January 1, 1973, as Central Creosoting Company, Incorporated.
During that time creosote was used exclusively as the wood preservative. On January 3, 1973, the facility
was sold and began operating under the name Central Wood Preserving Company, Inc., and the use of
creosote was discontinued. Wood preserving from that time onward was accomplished with Wolmanac, a
solution of copper oxide, chromic acid, and arsenic acid (chromated copper arsenate, known as CCA).
Throughout the facility's history, treated wood was distributed throughout the property for drying. The source
of contamination is the result of spillage of creosote and Wolmanac on the site property over a period of 40
years. The site is currently owned by the East Feliciana Parish.
The Record of Decision (ROD), signed April 5, 2001, set forth the selected remedy for the site soils and
sediments as removal and Low Temperature Thermal Desorption (LTTD) on-site, with off-site stabilization
and disposal of removed soils, institutional controls and ground water monitoring.
The remedial Action (RA) began in November 2003 with excavation and LTTD completion in September
2004. Soil and sediment were excavated from arsenic-only and arsenic-PAH areas and stockpiled
separately. Arsenic-only soil/sediment was excavated, staged in 300 cubic yard stockpiles, sampled to verify
compliance with land-disposal regulations (LDRs), and transported off-site for disposal. Arsenic-Polynuclear
aromatic hydrocarbons (PAH) soil/sediment was excavated, stockpiled for drying and/or mixed with lime,
treated in LTTD unit, staged in approximately 300 CY stockpiles, sampled for PAHs and Toxicity
Characteristic Leaching Procedure (TCLP) arsenic and chromium to verify compliance with applicable LDRs,
and transported off-site for disposal. Arsenic concentrations from post excavation sampling ranged from 3.2
milligrams per kilogram (mg/kg) to 6.3 mg/kg, all well below the remediation goal (RG) of 20 mg/kg.
Benzo(a)anthracene was selected in the Remedial Investigation (Rl) to illustrate the extent of PAH
contamination as it was the organic constituent most frequently detected above the state screening criteria in
use that time. Benzo(a)anthracene sampling results ranged from 0.08 mg/kg to 210 mg/kg with an average
of 29.0 mg/kg. While the comparison showed exceedances for contaminants of potential concern (as
identified in the Rl) at eight of the 19 locations sampled, these exceedencces were found in a limited area
along a drainage pathway on the north property, north of State Highway 959.
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A subsequent investigation in response to Hurricanes Katrina and Rita was performed in October 2005, to
determine if the impact of the hurricanes affected the integrity of the remedy. This resulted in additional
excavation and removal of approximately 980 cubic yards of soils that was performed in May 2006. The
combined remedy was designed and implemented with the U.S. Environmental Protection Agency (EPA)
conducting the final site inspection for the site and issuing the Final Close-Out Report in
June 29, 2006.
As part of the selected remedy identified in the ROD, Institutional Controls were implemented in areas where
contaminants were left in place in the subsurface at concentrations above the Remediation Goals. A
Conveyance Notification was filed with the Clerk of Court on September 30, 2005, in accordance with
Comprehensive Environmental Response, Compensation, and Liability Act guidelines, which allows for
unrestricted access in the upper three feet of soils, but provides restrictions under State law on disturbing or
moving deeper soils (greater than five feet).
Another component of the selected remedy was the implementation of a ground water monitoring system to
monitor contaminant levels in the ground water. This component of the selected remedy has ceased.
Ground water was to be monitored to ensure that wastes left in place do not affect the ground water because
soils with organic contamination would be left in place in the subsurface (greater than 5 feet below ground
surface [bgs]). The ROD required that ground water samples would be collected on an annual basis, but the
sampling frequency may be modified if there are statistically significant changes in ground water sample
concentrations.
Nine ground water monitoring wells were installed during the Remedial Investigation (Rl). The only ground
water encountered during the Rl was that observed in shallow soil under the drainage pathway (-10 ft bgs),
and that observed in the -65 ft bgs aquifer. Three wells were installed at 10 ft bgs along the drainage
pathway to check for free-phase creosote migration; these wells accumulated some water (only two
accumulated enough for sampling). The only exceedances of chemicals of potential concern were found in
the monitoring wells installed in the shallow ground water 10 feet bgs beneath the drainage pathway where
most of the surficial creosote-related contamination remained. Non-aqueous phase liquids were not found in
the onsite wells during the Rl. However, approximately 0.2 feet of a dense nonaqueous phase liquid
(DNAPL) was detected in shallow site monitoring well, MW-S3E2, and a trace was detected in shallow
monitoring well, MW-S2E2, during remedial design (RD) data collection activities in November 2001.
Ground water evaluation performed during the remedial investigation (Rl) and RA indicated the shallow 10
feet bgs ground water zone is not laterally continuous beyond the drainage pathway, and does not
demonstrate significant volumes of water (one of three wells installed in this zone did not generate enough
water to sample). The ground water encountered at 55 to 65 feet bgs demonstrates capacities that are
borderline at best for meeting Louisiana Department of Environmental Quality's (LDEQ's) 2B classification for
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potentially potable ground water, and ground water is not used from within this or any other zone in the
vicinity of the site. Monitoring well abandonment began in late February 2004 and was completed in early
March 2004, concurrent with the RA Site Preparation stage of the work. The deepest site excavations for
LTTD treatment took place in the area where chemicals of potential concern were found in the monitoring
wells installed in the shallow ground water 10 feet bgs beneath the drainage pathway. Excavation likely
removed the small amounts of DNAPL found during RD data collection.
Existing monitoring well MW-S2E5 was left in place as originally planned, but the number of new monitoring
wells was reduced from eight to one based on the expectation that two monitoring wells would be sufficient
for evaluation of potential migration to ground water. A total of 8 (eight) monitoring wells were abandoned.
After several rounds of ground water monitoring, these two remaining monitoring wells were removed
(properly plugged and abandoned) at the request of LDEQ.
During this review, one issue was observed at the time of the site inspection. The site is being used by the
parish for staging woody debris from Hurricane Katrina damage. Most of the debris consists of tree and
brush debris. There are, however, several small piles of possible household waste/debris and a pile of large
treated wood timbers. The parish indicated that while the site gates have been opened during hurricane tree
and brush debris staging that illegal disposal has taken place on the site. This household waste and treated
wood timbers may have come from illegal disposal; however, this household waste and treated wood timbers
do not meet the conditions of the permit that the parish obtained from the LDEQ for staging of hurricane
woody debris and depending on the nature of the waste may potentially re-contaminate the site. Between
the time of inspection and when this review report was written a large portion has been removed from the
site and properly disposed of off of the site property.
At this time, based on the information available during this first Five-Year Review, the selected remedy
appears to be performing as intended. The selected remedy currently protects human health and the
environment based on the results from treated waste and soil sampling and shallow ground water sampling
and as wastes and contaminated soils have been removed from the site or treated through LTTD, and those
wastes remaining, greater than five feet in depth, are addressed with the implementation of institutional
controls. For the remedy to remain protective in the long-term the site should not be used for staging of
household waste/debris or treated wood timbers, the security fencing around the site should be maintained
to prevent illegal disposal, and the conveyance notice maintained.
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Five Year Review Summary Form
SITE IDENTIFICATION
Site name (from WasteLAN): Central Wood Preserving Company
EPA ID (from WasteLAN): LA008187940
Region: EPA Region 6 State:
Louisiana
SITE STATUS
City/County: East Feliciana Parish
NPL status: B Final D Deleted D Other (specify)
Remediation status (choose all that apply): D Under Construction B Operating B Complete
Multiple OUs?* D YES m NO | Construction completion date: 29 June 2006**
Has site been put into reuse? D YES S NO
REVIEW STATUS
Lead agency: S EPA D State D Tribe D Other Federal Agency
Author name: EPA Region 6, with support from USAGE Tulsa District
Review period:** November 2008 to March 2009
Date(s) of site inspection: 1 December 2008
Type of review:
H Statutory
D Policy
D Post-SARA D Pre-SARA
D Non-NPL Remedial Action Site
D Regional Discretion
D NPL-Removal only
D NPL State/Tribe-lead
Review number:
1 (first) 2 (second) D 3 (third) D Other (specify)
Triggering action:
H Actual RA On-site Construction D Actual RA Start
D Construction Completion DPrevious Five-Year Review Report
D Other (specify) ROD submittal that sets MNA as remedial alternative
Triggering action date (from WasteLAN): April, 2004
Due date (five years after triggering action date): April, 2009 (five years after RA initiation)
OU refers to operable unit
* based on the Final Close-Out Report date, (for additional remedial actions, triggered by post Hurricane Katrina sampling)
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Five-Year Review Summary Form, cont'd.
Issues:
During this review, one issue was observed at the time of the site inspection. The site is being used by
East Feliciana Parish for staging woody debris from Hurricane Katrina damage. Most of the debris consists
of tree and brush debris. There are, however, several small piles of possible household waste/debris and a
pile of large treated wood timbers. The parish indicated that while the site gates have been opened during
hurricane tree and brush debris staging that illegal disposal has taken place on the site. This household
waste and treated wood timbers may have come from illegal disposal; however, this household waste and
treated wood timbers do not meet the conditions of the permit that the parish obtained from the LDEQ for
staging of hurricane woody debris and depending on the nature of the waste may potentially re-
contaminate the site. Between the time of inspection and when this review report was written a large
portion has been removed from the site and properly disposed of off of the site property.
Recommendations and Follow-up Actions:
Work with East Feliciana Parish to ensure removal of the household waste/debris and treated wood
timbers and to ensure that illegal disposal is not allowed to continue.
Protectiveness Statement(s):
Based on the information available during this first Five-Year Review, the selected remedy is performing as
intended. The selected remedy is currently protective of human health and the environment in the short
term. This determination is based on the results from treated waste and soil sampling and shallow ground
water sampling. It is also based on the fact that wastes and contaminated soils have been removed from
the site or treated through LTTD, and those wastes remaining, greater than five feet in depth, are
addressed with the implementation of institutional controls. For the remedy to remain protective in the
long-term the site should not be used for staging of household waste/debris or treated wood timbers, the
security fencing around the site should be maintained to prevent illegal disposal, the conveyance notice
should be maintained, and contamination remaining below five feet must remain un-exposed.
Central Wood Preserving Company Superfund Site Vlll
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1.0 Introduction
The purpose of a Five-Year Review is to determine whether the remedy at the site is protective of human
health and the environment, and to identify any problems or concerns that are affecting or may in the
future affect the protectiveness of the remedy. This is the First Five-Year Review for the Central Wood
Preserving Company Superfund Site (CWP), located in East Feliciana Parish, Louisiana, and was
conducted during the period of November 2008 through April 2009 by the U.S. Army Corps of Engineers
(USAGE), Tulsa District, on behalf of the U.S. Environmental Protection Agency (EPA) Region 6. The
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP) call for Five-Year Reviews of certain
remedial actions. The statutory requirement to conduct a Five-Year Review was added to CERCLA as
part of the Superfund Amendments and reauthorization Act (SARA) of 1986. The EPA classifies each
Five-Year Review as either statutory or policy depending on whether it is being required by statute or is
being conducted as a matter of policy. The Five-Year Review for the CWP Site is required by statute.
As specified by CERCLA and the NCP, a statutory review for a First Five-Year Review is triggered by the
initiation of the first remedial action that leaves hazardous substances, pollutants, or contaminants on site
above levels that allow for unlimited use and unrestricted exposure. In cases where there are multiple
remedial actions, the earliest remedial action that leaves hazardous substances, pollutants, or
contaminants on site should trigger the initial review, even if it is an interim remedial action. The definition
of the actual Remedial Action (RA) start dates may vary as outlined in the Superfund/Oil Program
Implementation Manual. Statutory reviews are required for such sites if the ROD was signed on or after
the effective date of SARA. CERCLA §121 (c), as amended by SARA, states:
If the President selects a remedial action that results in any hazardous substances,
pollutants, or contaminants remaining at the site, the President shall review such
remedial action no less often than each five years after the initiation of such remedial
action to assure that human health and the environment are being protected by the
remedial action being implemented.
Under the NCP, the Code of Federal Regulations (CFR) states, in 40 CFR §300.430(f)(4)(ii):
If a remedial action is selected that results in hazardous substances, pollutants, or
contaminants remaining at the site above levels that allow for unlimited use and
unrestricted exposure, the lead agency shall review such action no less often than every
five years after the initiation of the selected remedial action.
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The triggering action for this review is the initiation of remedial actions conducted at the site. Remedial
construction activities began in November 2003 with the initial surveying of the site. Actual soil excavation
and treatment commenced in mid-April 2004. Significant construction completion was achieved in August
2004. As stated above, the definition of the actual RA start dates may vary as outlined in the
Superfund/Oil Program Implementation Manual. Because the CWP Site is a Superfund site, the EPA has
regulatory authority. As such, and through interpretation of the RA start date, EPA has determined the
First Five-Year Review as being due in April 2009. This is the First Five-Year Review for the CWP Site
and was conducted during the period of November 2008 through April 2009 by the USAGE, Tulsa District,
on behalf of EPA Region 6.
2.0 Site Chronology
A chronology of events and dates is included in Table 1, provided at the end of the report.
3.0 Background
This section describes the physical setting of the site, a description of the land and resource use, and the
environmental setting. This section also describes the history of contamination associated with the site,
the initial response actions taken, and the basis for each action.
3.1 Physical Characteristics
The CWP Site is located in an unincorporated area in the southern portion of East Feliciana Parish,
Louisiana, approximately 25 miles north of Baton Rouge. The site is situated north and south of State
Highway (SH) 959, about one mile east of Highway 67. Figure 1 shows the general location of the site.
The municipal address of the site is 10145 Highway 959, Slaughter, Louisiana, 70777. The geographical
coordinates of the site are 30°45'32.77" north latitude and 91°00'36.15" west longitude.
The site consists of two distinct properties. The property on the north side of SH 959 ("North Property")
was used as the main wood treatment process area, and the property on the south side of SH 959
("South Property") was operated as a raw lumber saw mill. The wood treatment process area on the
North Property originally included 10 above-ground storage tanks/pressure vessels, 12 on-site buildings,
and a concrete-lined containment basin, some of which were removed during the removal action. The
combined acreage of the North Property (10.03 acres) and South Property (7.05 acres) is approximately
17.08 acres. A creek (historically and herein referred to, as "Unnamed Creek") is located along the east-
southeast side of both properties. This creek is intermittent near the site; when it has water, it flows south-
southwest to intersect with Little Sandy Creek approximately 1.5 miles south of SH 959. (E&E, 1995a).
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Currently, as a result of remedial activities, all above-ground structures have been removed. A few grade
level concrete slabs are still present, with minimal CWP artifacts remaining. The site is currently being
used as a staging area to hold hurricane Katrina related debris (tree and limb debris only). There is a six
foot high chain link fence, with locked gates, along SH 959 for both the North and South Properties; this
restricts access to vehicular traffic. Foot access is readily available to both site portions as fence lines for
the remainder of the site (not adjacent to SH 959) are either non-existent or simple two- or three strand
barb wire.
3.2 Operational History
The facility operated from the 1950s to January 1, 1973, as Central Creosoting Company, Incorporated,
owned and operated by Mr. J. B. Herrod (now deceased). During that time, creosote was used
exclusively as the wood preservative. On January 3, 1973, the facility was sold to Mr. John Bamett, Jr.
(now deceased) and the facility began operating under the name Central Wood Preserving Company,
Incorporated. At that time, the use of creosote was discontinued, and wood preserving from that time
onward was accomplished with Wolmanac, (copper chromated arsenic or CCA). The North Property was
used as the main wood treatment process area, and the South Property was operated as a raw lumber
saw mill. During the facility's operation, treated wood was distributed throughout the property for drying.
The Central Wood Preserving Company filed for bankruptcy in 1991 and ceased operations the same
year. Subsequent to the conclusion of the wood treating activities, the property was reportedly leased to
Bobby Cotton of Legacy Wood Products for lumber storage purposes. There is no indication that
pentachlorophenol (PCP), another common wood-treating substance, was ever used at the CWP Site;
this was substantiated via personnel interviews conducted previously by the Louisiana Department of
Environmental Quality (LDEQ), and by the lack of PCP detected in site samples. A site visit performed by
LDEQ in March 1992 confirmed the wood preserving/processing portion of the site to be inactive (E&E,
1995a).
Currently the site is owned by the East Feliciana Parish Police Jury. Though the site is currently being
used to stage hurricane related debris, future re-use of the site for recreation is being evaluated by the
parish. The proposed re-development plan (presented in Appendix N of the RA report) consists of picnic
areas and trails and a baseball field located on the site.
3.3 Regulatory History
In November 1983, the CWP facility was confirmed as a Resource, Conservation, and Recovery Act
(RCRA) small quantity generator of hazardous waste consisting of CCA. Since that time, regulatory
activities have included involvement by LDEQ and EPA. In 1992, following a request by LDEQ, the EPA
Technical Assistance Team (TAT) conducted a Preliminary Site Assessment. This assessment and
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subsequent more detailed site assessments and inspections conducted through 1995 indicated elevated
levels of arsenic and chromium in soil and sediment, and asbestos fibers in insulation samples.
An EPA Action Memorandum was issued on April 3, 1995. This memorandum provided for a Time-Critical
Removal Action to address source control at the site. The EPA TAT initiated the Time-Critical Removal
Action on April 12, 1995. During the removal action, several site structures, tank contents, and an area of
contaminated surface soil near the main facility operations area (about 1,250 cubic yards [CY]) were
removed from the site. The containment basin contents were also removed and the basin sandblasted
and backfilled with soil. From July to December 1995, the EPA TAT conducted an Expanded Site
Inspection (ESI) to gather data for Hazard Ranking System (MRS) documentation.
In 1999, the site was proposed for inclusion on the National Priorities List (NPL) and a Remedial
Investigation/Feasibility Study (RI/FS) was initiated. The site was added to the NPL in May 1999. The Rl
and FS were completed in September and November 2000, respectively. EPA issued the ROD for the RA
on April 5, 2001.
A Remedial Design (RD) to define the implementation of the remedy for the CWP Site was completed in
May 2002. The RD described in detail the components of the selected remedy identified in the ROD.
Mobilization for the RA was initiated in December 2003 and significant construction completion was
documented in a pre-final site inspection conducted by EPA and LDEQ on August 25, 2004. A
Preliminary Closeout Report for the CWP Site was prepared and signed by EPA in September 2004.
(CH2M Hill, 2005).
In response to Hurricanes Katrina and Rita, EPA performed sampling at the site to determine if the impact
of the hurricanes affected the integrity of the remedy. The site was sampled on October 7-8, 2005, using
a grid-based approach to collect surface soils samples from the 0-3 inch interval. The results found that
several grids on the South Property of the site were above the remediation goal for arsenic. Additional
sampling was conducted in February 2006 to provide better definition of the contamination. The results of
the sampling were used to define additional excavation that was performed in May 2006. Approximately
980 cubic yards of soils were excavated from the area and sent off-site for disposal. A Final Close Out
Report for the site was signed June 29, 2006.
3.4 Environmental Setting
The CWP Site is located north of Baton Rouge in the southern portion of East Feliciana Parish, Louisiana,
in an area covered by the "Clinton" United States Geological Survey (USGS) 7.5 minute topographic
quadrangle, and the "Amite" USGS 15 minute topographic quadrangle, in Section 77, Township 3 South,
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Range 2 East. The "Fred" USGS 7.5 minute quadrangle, which adjoins the "Clinton" 7.5 minute
quadrangle on the south side, covers the downstream extent of the Unnamed Creek that originates on the
east side of the site. The site elevation is approximately 180 feet above mean sea level.
The Providence-Oliver soil association located on-site consists of gentle sloping upland soils comprised
of silty loam to a silty clay loam conducive for pasture and southern pine forest. This soil type is
characterized by a low permeability (E&E, 1995c). The topography in the area of the site is characterized
by a generally flat, gently sloping ground surface with multiple drainage ways, creeks and wetland areas
visible throughout the vicinity; these surface water features convey and accumulate runoff from the low
permeability soils. The Unnamed Creek borders the site to the east-southeast, and flows south-southwest
toward its confluence with Little Sandy Creek about 1.5 miles south-southwest of the site. The Unnamed
Creek originates near the north side of the site, and is fed by runoff drainage ways in the vicinity of the
site.
Two on-site drainage ways were documented during previous investigations on the eastern portion of the
North Property side of the site. The drainage ways converge on-site and continue toward the east for
approximately 200 feet from the former main wood treating process area to the Unnamed Creek. The
Unnamed Creek is originally shallow and not well-defined on the east side of the North Property. On the
South Property, the Unnamed Creek begins to demonstrate a more defined cut into the surficial soils,
eventually averaging several feet wide from top of bank to top of bank, and an average of 3 feet in vertical
extent from top of bank to base of the streambed. This profile continues downstream of the site
approximately one mile to a wetland area, where the Unnamed Creek spreads above a small naturally-
occurring dam and forms a swampy area. Downstream of the dam, the Unnamed Creek again assumes a
more distinct profile.
In the area north and inclusive of Baton Rouge, upland deposits overlying three subsurface hydraulic
zones (Zones 1, 2 and 3) are identified in available literature. The CWP Site is situated over an area
demonstrating undifferentiated Quaternary Upland deposits. These upland deposits form a hydraulic unit
which includes sediments that range from early Pleistocene to the most recent age (E&E, 1995c). The
upland deposits in the immediate vicinity of the site correlate with the shallow Pleistocene; the "400-foot"
sand, the "600-foot" sand, and possibly the "800-foot" sands of the Baton Rouge area. In the recharge
area, toward the north, surface streams are hydraulically connected with the aquifer.
A direct push/cone penetrometer (CPT) investigation conducted during the Rl provided detailed near-
subsurface data. This investigation revealed the presence of interbedded clay and silty clay, some moist,
mostly dry, from the surface to about 20 to 22 feet below ground surface (bgs), where the deposits
become sandy and mostly dry, with some moisture. The sandier deposits appear to extend to about 45
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feet bgs. Beyond that depth the deposits again become interbedded silty clay and clay, until about 60 feet
bgs, where the first saturated ground water zone was encountered. Ground water was encountered in a
shallow zone in soils under the drainage pathway at 10 feet bgs, and in an aquifer that occurs at
approximately 55 to 65 feet bgs. Subsurface materials between 10 and 55 feet bgs, including a sand zone
encountered from about 20 feet bgs to 45 feet bgs, were consistently dry throughout field investigations.
In addition, the shallow 10 feet bgs ground water zone is not laterally continuous beyond the drainage
pathway, and does not demonstrate significant volumes of water (one of three wells installed in this zone
did not generate enough water to sample). The ground water encountered at 55 to 65 feet bgs
demonstrates capacities that are borderline at best for meeting LDEQ's 2B classification for potentially
potable ground water, and ground water is not used from within this or any other zone in the vicinity of the
site. (CH2M HILL, 2000a).
During previous investigations, a review of registered wells within a 4-mile radius of the site was
performed, and no public water supply wells were identified in the Upland deposits or Zone
1 (approximately 340 feet bgs) within this 4-mile area. Water well information located within the 4-mile
radius can be found in Attachment H of the Site Assessment Report. One registered well was reported as
screened within the Zone 2 (approximately 1,180 feet bgs) deposits approximately 3.75 miles northwest
of the site, and four public supply wells were identified in Zone 3 (approximately 1690 feet bgs) within the
4- mile radius (E&E, 1995a). The public supply wells are installed to depths greater than 1,500 feet bgs,
and are generally protected from surface contamination within the area by the presence of the low
permeable clay located throughout the southern tier of East Feliciana Parish.
3.5 Land and Resource Use
At the time of the ROD, it was estimated that approximately 140 people lived within one mile of the site.
Although predominantly rural, residential land use in the area is increasing. New housing starts are up,
and a number of families from Baton Rouge have relocated to new homes in the area. Two older
residences, both occupied, are located within 350 feet of the west property boundary (north side of SH
959). These are the remaining two of nine original residences previously located on this small cul-de- sac;
these residences were originally built to house facility employees. Approximately 15 residences are
located on the east side of Mill Lane North, a street which runs along the east side of the property north of
SH 959; some of these residences may be duplexes, and some appear to be unoccupied.
A property appraisal for the CWP Site (North and South Properties) was performed in April 1999 toward
the end of the field investigation. The purpose of the appraisal was to provide documentation of the
expected future land use of the property for use in selection of Preliminary Remediation Goals (PRGs)
under the human health and ecological risk assessments being performed for the site. A copy of the
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appraisal report is provided as an appendix to the Human Health Risk Assessment Technical
Memorandum (CH2MHILL, 2000b).
The neighborhood description included in the report states that CWP is located in a primarily rural area
with some residential development; the immediate subject area is considered to be 25 percent built up.
The property is located within East Feliciana Parish, which does not participate in the National Flood
Insurance program, nor is it zoned. There are no known servitudes, easements, or encroachments that
affect the utility of the site. According to the appraisal, the most likely use of the property, if vacant, would
be as a future residential home site(s). Unincorporated areas of East Feliciana Parish have no zoning
ordinance and there are no known legal regulations or restrictions that would serve to limit the use of the
site. The site's size is considered to be typical for the area and there are no known physical
characteristics of the land that would impede or restrict possible uses of the site (exclusive of
environmental contamination) (Carlock and Associates, 1999). While site access need not be restricted
based on remaining contamination levels, the site is fenced and gates kept locked to prevent illegal or
unauthorized disposal of materials on site.
In April 2000, the East Feliciana Parish Police Jury applied for a reuse grant. In June 2000, the EPA
selected the CWP Superfund site as a Superfund Redevelopment Pilot. According to the Parish grant
application, "323 people currently live within 1 mile of the site. The growth rate for the East Feliciana area
has been 6.9% within the last 10 years. The growth rate appears to be increasing and the area being
developed because of the rapid growth in suburban Baton Rouge. Since suburban communities are
springing up around the site, community leaders are concerned about the lack of recreational space in
this growing area." In 2000, the Parish was reported to have hired a contractor to: 1) create a
comprehensive reuse plan, 2) create a reuse strategy, and 3) conduct community meetings. Public
meetings for the reuse plan were conducted in March 2001, (EPA, 2001a).
The site is currently being used by the East Feliciana Parish as a staging area to hold hurricane related
debris (tree and limb debris only). Future re-use of the site for recreation is being evaluated by the East
Feliciana Parish. The proposed re-development plan consists of picnic areas and trails and a baseball
field located on the site. A proposed site re-use plan is presented in Appendix N of the RA report.
3.6 History of Contamination
The CWP Site is an abandoned wood treating facility occupying approximately 17 acres that operated for
approximately 40 years. The facility treated various wood products via two wood preserving processes,
one that used creosote, and the other that used CCA. The wood preserving processes used pressure to
force a solution of creosote dissolved in diesel, or a solution of CCA, into the pore spaces of the wood.
The treated wood was then allowed to dry on a drip pad.
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Subsequent to LDEQ's identification of the CWP facility as abandoned in March 1992, EPA conducted a
series of phased investigations and a removal action. The initial investigation conducted by EPA's
Emergency Response Branch (ERB) was what became Phase I of the Site Assessment (SA). The SA,
with five phases, extended from 1992 through 1995. During Phase I, an extent-of-contamination survey
was conducted to define the degree to which a potential removal action would take place. Six soil
samples were collected for analysis of copper, chromium, arsenic; two soil samples for volatile organic
compounds (VOCs) and semi-volatile organic compounds (SVOCs); and two insulation samples for
asbestos. Samples indicated elevated levels of the metals, the presence of organic compounds
commonly found in creosote, and presence of asbestos.
During Phase II of the SA, conducted in July 1993, a grid system for composite sampling of on-site
surface soils and portions of the drainage that runs on the southeast side of the site was established and
sampled at various depths to 24 inches bgs. Thirty-eight on-site grid blocks and five creek grid blocks
were sampled. The grid was systematically expanded during the various phases of the SA for sampling of
surface soil and sediment both on- and off-site, based on analytical results of each previous phase. Also
sampled during the SA efforts were water samples from the containment basin and various on-site tanks,
samples from waste piles, and sediment samples from the containment basin (E&E, 1995a). Grab
samples from various locations were also collected from the drainage, and at various points along the
Unnamed Creek downstream of the site.
Analytical findings from the SA work indicated that elevated levels of arsenic and chromium were present
at both on-site and off-site locations and within on-site tanks, waste piles, and the containment basin.
Subsequent action levels of 50 milligrams per kilograms (mg/kg) for arsenic and 200 mg/kg for chromium
were established during this investigation with concurrence from the Agency for Toxic Substances and
Disease Registry. In addition, the presence of creosote was noted during sampling efforts.
Concurrent with performance of the SA, EPA initiated an evaluation of the site for potential inclusion on
the NPL. This effort began with the Preliminary Assessment (PA), completed by the TAT in 1994. Based
on the results of the PA, a Site Inspection (SI) was recommended for the site to further determine
potential candidacy for inclusion on the NPL. The SI activities were designed to supplement the SA
sampling activities, and to provide documentation for any remedial actions to be performed subsequent to
the EPA ERB removal action conducted in 1995(E&E, 1995c).
Samples for the first SI sampling effort were collected in December 1994; a total of thirty-seven
sediment/soil samples were collected. Analytical results from this effort exhibited the occurrence of metals
and Polynuclear Aromatic Hydrocarbons (PAHs) at concentrations greater than three times background.
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An ESI was conducted based on the results of the SI work, and included collection of thirty additional
samples to address areas not previously sampled and to confirm data collected during the previous
sampling activities.
3.7 Initial Response
Contamination at the site occurred as the result of approximately 40 years of wood preserving operations
with a lack of effective containment practices, and routine spills of creosote and CCA (E&E, 1995b).
Based on the findings of the EPA ERB SA sampling efforts, EPA determined that a Time-Critical Removal
Action was warranted to address a portion of the site. An Action Memorandum was issued on April 3,
1995, and the removal action initiated on April 12, 1995 (E&E, 1995c). The removal activities conducted
at the site included the removal of:
Buildings B-3, B-5, and B-6.
Building B-10 smokestack.
Portion of the concrete pad adjacent to the concrete containment basin.
All storage tanks (ST-1 through ST-10) and contents and associated piping system.
Approximately 1,520 cy of solids including surface soil from the processing area defined by grid
blocks demonstrating arsenic greater than 50 mg/kg and chromium greater than 200 mg/kg, and
contaminated sediment from the containment basin.
Additionally, the following was completed:
The area along the creek one mile downstream from the site was determined to meet the
criteria for being defined as a wetland. A small drum in Building B-2 labeled as methoxychlor, a
derivative of DDT, was discovered on May 30, 1995 (no record of disposal is indicated).
Three on-site water supply wells were closed by over drilling, removal of the upper 20 to 40
feet of well casing, and filling with Portland cement.
The concrete containment basin was sandblasted.
The CWP Site was listed on the NPL in May, 1999. EPA authorized CH2M Hill to perform a RI/FS for the
site, which was completed in November 2000.
Results of the analyses conducted during the course of the various investigations, including the Rl,
indicated that the most significant contamination was from arsenic, chromium, copper, and PAHs in soil
and sediment. Analysis of the distribution and concentrations of chromium and copper indicated that the
occurrence of these compounds corresponded well with the occurrence of arsenic.
Soil samples were collected during the Rl and site assessment/site inspections from both the North and
the South Properties. On the North Property, arsenic concentrations ranged from a background
concentration of 20 mg/kg to 6,913 mg/kg. On the South Property, only limited areas of arsenic hot spots
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were identified to depths of 1.5 feet bgs, at a maximum concentration of 429 mg/kg. The majority of the
soil samples collected site-wide from below 1.5 feet bgs contained arsenic at concentrations at or near
the arsenic background level. Creosote contamination (quantified as total PAHs) was encountered in soil
at the North Property at depths ranging up to 23 feet bgs. Total PAH concentration ranged from 0.059 to
56,200 mg/kg, with the highest concentration observed in the vicinity of the former process area and
drainage way leading to the Unnamed Creek. On the South Property, creosote was limited to the
drainage along the eastern property border to a depth of 5 feet bgs. Total PAH concentration ranged from
0 to 33 mg/kg on the South Property.
In the Unnamed Creek, both sediment and surface water was sampled. Arsenic contamination was found
in sediment up to a depth of 1.5 feet in various discrete hot spots. Concentrations ranged from
background to 590 mg/kg. Some creosote-related constituents were also detected.
Arsenic and chromium were the most wide-spread constituents detected in site soils and sediment
samples in both on-site and Unnamed Creek samples. Arsenic and other constituents were also detected
in soil/sediment samples downstream in the Unnamed Creek as far as Little Sandy Creek. The ESI
indicates that, beginning at about 1,000 feet upstream from the confluence of the Unnamed Creek with
Little Sandy Creek, sediment samples showed detectable levels of constituents, but they were below
HRS observed released criteria of three times background (E&E, 1995c).
Three, 10-foot bgs ground water monitoring wells were installed to verify whether or not nonaqueous
phase liquid (NAPL) was present. The 10-foot wells were installed in a localized, 50-foot diameter area,
where direct push/CPT sampling previously indicated potential NAPL present. Three, 45-foot bgs ground
water monitoring wells were installed at three locations in the dry sand observed during the direct
push/CPT activities to confirm the lack of ground water in this sand, and to allow collection of ground
water samples if found at a later date. Three, 65-foot bgs ground water monitoring wells were installed in
the first occurrence of ground water to allow sampling for site-related constituents. See Figure 2 for
locations of monitoring well installed during the Rl.
Ground water samples were collected from two of the three wells in the shallow perched water zone, and
three wells in the deeper ground water aquifer at depths of 60 to 65 feet (the three intermediate wells
were set in a dry sand zone). NAPL was not found in any on-site wells during the Rl. Ground water
samples collected from both shallow wells, however, contained significant concentrations of arsenic and
creosote related compounds. Ground water samples collected during the Rl from the three deep wells did
not contain arsenic, copper, or PAHs at concentrations above detection limits.
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The asbestos survey performed during the Rl confirmed the presence of asbestos in the insulation of a
boiler tank previously identified in Building B-10 during the SA. The asbestos survey also evaluated the
presence or absence of asbestos in the remaining structures on the North and South Properties.
Insulation on the B-10 tank and the mastic coating on the insulation were found to contain asbestos
above the regulatory limit of 1 percent by weight. The 12- and 9-inch resilient floor covering in Building B-
1 and the associated tile mastic for the 12-inch tile also tested positive for asbestos content above 1
percent.
3.8 Summary of Basis for Taking Action
The purpose of the response actions conducted at the CWP Site was to protect public health and welfare
and the environment from releases or threatened releases of hazardous substances from the site.
Potential exposure to affected soil, ground water, surface water and sediment was determined to be
associated with human health risks higher than the acceptable range. The primary threats that the CWP
Site posed to public health and safety were direct contact with on-site waste material and/or the transport
of these materials and/or potential hazardous constituents and/or air emissions to nearby populated areas
by surface runoff, severe flooding, or disruption of waste areas. This threat was minimized with the Time-
Critical Removal Action which only addressed source control (i.e., removal of on-site tanks/vessels
containing hazardous substances and the removal of the soil surrounding these tanks). Contaminated soil
and sediment outside the main process area were not addressed during the removal action.
A baseline risk assessment, including an ecological assessment, was completed in September 2000,
which estimated the probability and magnitude of potential adverse human health and environmental
effects from exposure to contaminants associated with the site assuming no remedial action was taken. It
provided the basis for taking action and identified the contaminants and exposure pathways that need to
be addressed by the remedial action. The public health risk assessment followed a four step process: 1)
hazard identification, which identified those hazardous substances which, given the specifics of the site
were of significant concern; 2) exposure assessment, which identified actual or potential exposure
pathways, characterized the potentially exposed populations, and determined the extent of possible
exposure; 3) toxicity assessment, which considered the types and magnitude of adverse health effects
associated with exposure to hazardous substances, and 4) risk characterization and uncertainty analysis,
which integrated the three earlier steps to summarize the potential and actual risks posed by hazardous
substances at the site, including carcinogenic and non-carcinogenic risks and a discussion of the
uncertainty in the risk estimates.
As outlined in the ROD, Risk Characterization results were as follows:
For the North Property, Excess Lifetime Cancer Risk (ELCR) estimates for current receptors
(trespassers) and future receptors (adult residents) were above 1 x 10~4. ELCR estimates for future
construction workers were in the range of 1 x 10~5. In all cases, risks were due primarily to arsenic and to
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a lesser extent, to the presence of PAHs. Hazard Index (HI) estimates for trespassers, and residential
adults and children were also above the threshold of concern (HI = 1) at values of 1.1 up to 160 and were
a consequence of the high levels of arsenic. HI estimates for construction workers were below the
threshold of concern. For the Hot Spot within the North Property, the calculated risk estimates were
approximately one order of magnitude above the corresponding risk estimates for the entire North
Property.
For the South Property, ELCR estimates for future construction workers and future adult residents were
above 1 x 10~4, due primarily to arsenic. HI estimates for construction workers and residential adults and
children were also above the threshold of concern (HI = 1) at values of 2 up to 11 and were a
consequence of the high levels of arsenic. For the South Property current trespasser scenario, estimated
total ELCR and HI for potential exposures to surface soil were 4 x 10~5 and less than 1, respectively.
For sediment/soil in Segment 1 of the Unnamed Creek, the ELCR estimate for the Recreational Youth
was 3.4 x 10"3 which is above the range of concern of 1 x 10"4 to 1 x 10"6 and was due primarily to the
presence of arsenic, benzo(a)pyrene and benzo(b)fluoranthene. The associated HI estimate was above
the level of concern of 1 at 7 and was due to the presence of arsenic and dibenzofuran.
For Segments 2 and 3 of the Unnamed Creek, ELCR estimates for sediment/soil were in the range of
7x 10~6 down to 6 x 10~7 for the recreational youth scenario and 1x 10~5 down to 9 x 10~7 for the adult
hunter scenario. These risk levels are based on the reasonable maximum exposure; some actual
detected concentrations in these segments are above the 1 x 10~5 risk-based concentration. Noncancer
(HI) estimates for sediment/soil in Segment 2 and 3 were well below the level of concern of 1.0. ELCR
and HI estimates for potential exposures to surface water for both scenarios in all three segments of the
Unnamed Creek were also well below levels of concern.
Ecological Risk Assessment. Contaminants of Concern (COCs) were arsenic, copper, and chromium.
Although copper was not evaluated in the ecological risk assessment, it was one of the primary chemicals
used in this facility's operations and was detected in previous EPA site assessment investigations at
levels in excess of 1500 ppm. Copper is acutely toxic to plants and invertebrates. An evaluation of the
relationship between arsenic and copper in site soils/sediments revealed an almost 1 to 1 ratio. The
results of the baseline ecological risk assessment on the North and South properties and the Unnamed
Creek indicated that: 1) there was minimal risk to the terrestrial and riparian wildlife target receptors, and
2) there was risk to the benthic receptors. A 14-day Hyallela azteca bioassay, benthic surveys and
sediment chemistry, indicated that the observed mortality in the bioassays is not attributable to site-
related contamination, and the low diversity of benthic organisms in the Unnamed Creek may be a result
of limited physical habitat. Therefore, the final conclusion by the Agency is that by addressing the arsenic
levels as per the human health risk assessment, the copper will be also addressed, thereby addressing
the ecological risk.
Although the Creek contains a wetland (Segment 3) that has levels of arsenic above the human health
risk assessment remediation goal, this 100 cubic yard wetland area was not be remediated as
remediation would cause damage to the wetland and limited accessibility would prevent routine direct
human exposure to the contaminated sediments (EPA, 2001a).
4.0 Remedial Actions
This section provides a description of the Remedial Action Objectives (RAOs), remedy selection, and
implementation. It also addresses Operations and Maintenance (O&M), and the overall progress made at
the CWP Site. At this site, the EPA Time-Critical Removal Action completed in September 1995 had
addressed the principal threat posed by obvious wastes comprised of contaminated soil, sludge, and
waste at the former process areas. The contaminated materials that exceeded health based levels at the
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site were excavated and removed from the site. During 2000, the EPA contracted CH2M Hill, Inc. to
perform a RI/FS to fully characterize and define all residual contamination at the site to include surface
and subsurface soils, ground water, and surface water and sediment in the Unnamed Creek. The results
of the RI/FS warranted further remedial activities at the site.
4.1 Remedy Objectives
The ROD for the CWP Site established RAOs and described the remedy selected to achieve these
RAOs. The RAOs for the North and South Properties are to prevent human ingestion of, dermal contact
with, or inhalation of soil and sediments and human contact with structure/debris containing/contaminated
with COCs at concentrations which pose an ELCR greater than 1x10"6 or which have a HI of greater than
1 (based on a residential use scenario). The RAOs for the Unnamed Creek are to prevent human
ingestion of, dermal contact with, or inhalation of sediment contaminated with chemicals of concern at
concentration levels which pose an ELCR greater than 1 x 10"6, or which have a HI of 1 or greater (based
on a recreational use scenario). In addition, both the North and South properties and Unnamed Creek
have RAOs for ground water to prevent human ingestion of water which contains COCs exceeding non-
zero maximum contaminant level goals (MCLGs) or maximum contaminant levels (MCLs) where the
corresponding MCL is zero in ground water at the 60 foot aquifer (CH2M Hill, 2005a).
Based on these RAOs, the ROD established cleanup levels, or remediation goals (RGs), for each
medium. The risk assessment conducted for the site as part of the RI/FS had concluded that risk to
human health was primarily driven by the presence of arsenic; other contaminants that posed a risk were
found to be located within the footprint of arsenic contamination. Therefore, the ROD specifically
established RGs for arsenic in site soil and sediment.
As noted in the ROD, the RGs were calculated for surface soil/sediment on the North and South
Properties based on 1 x 10~6 carcinogenic risk using adult and child resident and construction worker
exposure scenarios. To be protective of both residents and construction workers, the lowest of the risk-
based concentrations was selected as the RG. The resulting arsenic RG for surface soil/sediment (0 to
3.0 feet bgs) was calculated as 0.03 parts per million (ppm). Since this concentration was lower than the
background concentration, and could not be met, the arsenic RG was set at the background
concentration of 20 ppm. This corresponds to a residential risk level of 1 x 10~4.
The RGs calculated for the 3-5 feet bgs interval for the North Property were based on 1 x 10~5
carcinogenic risk using a future utility worker scenario. The resulting arsenic RG for surface soil/sediment
was calculated as 300 ppm. As noted in the ROD, the 1 x 10~5 carcinogenic risk was chosen because: 1)
the area that requires action is a hot spot (hot spot is defined as a small area) and 2) the probability that
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utility lines will be located in this exact hot spot is unlikely since the hot spot is located near the Unnamed
Creek.
The RGs calculated for the Unnamed Creek were based on 1 x 10~5 carcinogenic risk using a recreational
youth and adult hunter scenario. As noted in the ROD, since the creek is located on several individual
residents' property, recreational youth and adult hunter access to the creek is limited. Therefore, 1 x 10~5
was used. The resulting arsenic RG was calculated as 160 ppm. The table below summarizes the RGs
established in the ROD (CH2M Hill, 2005a).
Chemicals of Cleanup Level Depth Basis for Risk Level
Concern ppm Feet bgs Cleanup Level at Cleanup
NORTH PROPERTY SOIL
arsenic 20 0-3 Risk Assessment and . 10-4
Background Concentration x
arsenic 300 3-5 Risk Assessment and
Background Concentration 1 x 10"4
SOUTH PROPERTY SOIL AND SEDIMENT
arsenic 20 0-1.5 Risk Assessment and
Background Concentration 1 x 10"4
UNNAMED CREEK SEDIMENT
arsenic 160 0-1.5 Risk Assessment 1x10"5
It is noted that Table 1 through Table 4 provided in the ROD summarize various data used in risk based
calculations, such as toxicity values, reference doses, etc. During document review for this First Five-
Year Review, it was discovered that several values provided in these tables were incorrectly transferred
from the actual Risk Assessment and its addendums, and/or these tables were simplified for incorporation
within the ROD. The review of the actual values and calculations performed in the Risk Assessment were
determined to be appropriate and correct.
4.2 Remedy Selection
Under its legal authorities, EPA's primary responsibility at Superfund sites is to undertake remedial
actions that are protective of human health and the environment. In addition, Section 121 of CERCLA
establishes several other statutory requirements and preferences, including: a requirement that EPA's
remedial action, when complete, must comply with all federal and more stringent state environmental and
facility standards, requirements, criteria or limitations, unless a waiver is invoked; a requirement that EPA
select a remedial action that is cost-effective and that utilizes permanent solutions and alternative
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treatment technologies or resource recovery technologies to the maximum extent practicable; and a
preference for remedies in which treatment permanently and significantly reduces the volume, toxicity or
mobility of the hazardous substances is a principal element over remedies not involving such treatment.
Response alternatives were developed to be consistent with these Congressional mandates. CERCLA
and the NCR set forth the process by which remedial actions are evaluated and selected. In accordance
with these requirements, remedial alternatives for the CWP Site were based on EPA's "Presumptive
Remedies Guidance for Soils, Sediments, and Sludges at Wood Treater Sites." The presumptive
remedies are preferred technologies for common categories of sites, based on EPA's experience and its
scientific and engineering evaluation of alternative technologies. EPA evaluated two of the applicable
presumptive remedies in addition to the no action alternative. The no action alternative has been retained
as a baseline for comparison, as required by the NCR. The remedial action alternatives for the CWP Site
for soils/sediments are as follows:
Alternative 1: No Action
Alternative 2: Removal and Thermal Desorption On-Site, Off-Site Stabilization and Disposal
Alternative 3: Removal and Incineration On-Site, Off-Site Stabilization and Disposal
Alternative 4: Excavation and On-Site Disposal
The process for the screening of alternatives and the analyses of the alternatives is explained in more
detail in Sections 2 and 3 of the Feasibility Study Report (CH2M Hill, 2000dj. The ROD identified
Alternative 2 as the selected remedy. Thermal desorption with off-site disposal is a comprehensive
remedy which utilizes source control and management of migration components to address the principal
site risks. EPA selected this alternative because it would achieve the removal of creosote- and arsenic-
contaminated soil/sediment that poses unacceptable risks. Thermal desorption would achieve reduction
in the volume, toxicity, and mobility of creosote-contaminated wastes. Off-site stabilization and disposal of
the arsenic contaminated wastes and residuals from the thermal desorption would permanently remove
the wastes that pose a risk based exposure. Although wastes below 5 feet would remain, these wastes
do not pose a risk to humans or the environment because there was no exposure to soils at this depth by
humans or the environment. In addition, wastes below 5 feet had not migrated to the ground water at the
55-60 feet bgs. Although Alternative 2 was more costly than Alternative 4 (RCRA vault), the selected
remedy would achieve permanent results and would restore the property for residential and recreational
reuse. (EPA, 2001a).
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Before initiation of the selected remedy, preparatory activities would first be necessary for the
implementation of that remedy. These preparatory activities include:
Grubbing - Portions of the on-site removal area would require grubbing prior to excavation.
Staging for contaminated soils/sediments - The Unnamed Creek portion of the excavation would
require clearing and staging areas down the length of the creek where excavation activities would occur.
Asbestos Abatement - The asbestos survey conducted at the site confirmed the presence of asbestos
above the regulatory limit of 1 percent by weight. A licensed asbestos removal contractor would remove
these materials from the site prior to initiation of other removal actions.
Building Demolition and Disposal of Materials -The North Property structures would require
demolition and removal to facilitate the surface soil excavation. Buildings demolished would be tested and
disposed of accordingly.
Removal and Disposal of Debris Piles - Previous testing on the debris piles shows elevated levels of
site-related metals in all debris piles on the North Property. These piles would be cleared from the
excavation area along with the building debris and disposed of accordingly.
The four major components of the selected remedy for soils/sediments included:
Excavation of Surface/Near-Surface Soil/Sediment that Exceed RGs - Soil/sediment that exceeds
RGs would be excavated and staged pending treatment/disposal. Excavated soil/sediment that exceeds
Land Disposal Restrictions (LDRs) would be staged separately from excavated soil/sediment that does
not exceed LDRs.
Thermal Desorption of Excavated Soil/Sediment that Exceeds LDRs - Excavated soil and sediment
exceeding LDRs based on site characterization data would be staged separately from excavated
soil/sediment that meets LDRs. The excavated soil/sediment exceeding LDRs would be prepared for
treatment and treated with an on-site thermal desorption unit. Toxicity Characteristics Leaching
Procedure (TCLP) sampling of the residuals would be required, and if the LDRs are exceeded, additional
stabilization may be required prior to off-site disposal. During the excavation and thermal desorption
processes, air monitoring and noise monitoring would be conducted to ensure compliance with Applicable
or Relevant and Appropriate Requirements (ARARs).
Disposal of Excavated Soil/Sediment - The excavated soils would be tested and disposed of
accordingly.
Backfilling - The North and South Property removal areas would be backfilled with clean backfill and re-
vegetated following confirmation sampling. The excavated portions of the Unnamed Creek would be
backfilled with clean backfill and an erosion control layer would be installed following confirmation
sampling.
In addition to these components for soils remediation, the site would also require:
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Inspection - Prior to the completion of the remedial action and site deletion, EPA would also conduct a
review of the site.
Ground water Monitoring - To ensure that wastes left in place do not affect the ground water, ground
water monitoring would be implemented. Soils with organic contamination would be left in place in the
subsurface (greater than five feet bgs). To ensure protectiveness of ground water, a ground water
monitoring system would be necessary to monitor contaminant levels in the ground water. The dry sand
that exists from about 25 to 45 feet bgs would also be monitored to ensure no future migration pathway
develops. Ground water samples would be collected on an annual basis, but the sampling frequency may
be modified if there are statistically significant changes in ground water sample concentrations.
Institutional Controls/Deed Restrictions - Easements, covenants running with the land, and/or deed
notices as appropriate or as allowed by law would be implemented to prevent exposure to contaminants
remaining on-site on the North Property below five feet bgs (this area includes the drainage pathway
located outside the legal boundaries of the property that was originally owned by CWP [now East
Feliciana Parish]) (EPA, 2001a).
The expected outcome of the selected remedy was that the site would no longer present an unacceptable
risk to human health because the contaminated soil and sediment would be excavated, treated, and
disposed of off-site and the property would be suitable for residential and recreational land use. In
addition, institutional controls, such as the deed notice, would prevent future human exposure to soil
contamination below 5 feet. By addressing the unacceptable human health risks in the sediment
contamination in the Creek, EPA would address contamination that affects the wetlands and other habitat
in the Creek, thereby providing environmental and ecological benefits such as wetlands restoration.
Ground water monitoring would ensure that the remedy is protective. It was anticipated that the selected
remedy would also provide socio-economic and community revitalization impacts such as increased tax
revenues due to proposed redevelopment efforts and planning for the property by the local Parish
authority (EPA, 2001 a).
4.3 Remedy Implementation
A RD to define the implementation of the remedy for the CWP Site was completed in May 2002. The RD
described in detail the components of the selected remedy identified in the ROD. Remedial construction
activities began in November 2003 with the initial surveying of the site. Mobilization was initiated in
December 2003, with construction activities beginning in January 2004, and actual soil excavation and
treatment beginning in April. Significant construction completion was achieved in August 2004. Extensive
documentation of these events is found in the RA Report and its appendices. A brief summary of these
events follows.
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4.3.1 Preparatory Activities
The Site Preparation stage of the project began in December 2003 and was completed in March 2004.
Site Preparation was conducted to clear and grub the trees and vegetation in areas identified for soil and
sediment excavation. Tree stumps and root balls were washed to remove soil and burned on-site. Logs
were hauled off-site for recycling as pulpwood (approximately 130 tons). A portion of the wood debris was
shredded and left on-site for use as mulch during site restoration. Approximately 17 acres of land were
cleared, including 10 acres on the North Property and 7 acres on the South Property.
A total of eight ground water monitoring wells were abandoned; all of the monitoring wells installed during
the Rl, with the exception of one of the 65-foot deep wells, MW-S2E5, were abandoned. Two former
water supply wells on the south side of the South Property found during Site Preparation and Demolition
activities were also abandoned.
Building demolition and asbestos abatement began in January 2004 and were completed in mid-March
2004. Asbestos Containing Materials (ACM) found in two on-site buildings were removed and disposed
off-site, approximately 60 square feet of tile with ACM. All 14 on-site buildings were subsequently
demolished to allow for excavation of contaminated soil on the property and to provide for the safe
operation of excavation equipment in the vicinity. The building debris and pre-existing debris piles were
either recycled or disposed off-site. A total of approximately 108 tons of metal scrap from buildings and
other miscellaneous sources were recycled and about 1,200 CY of building debris were transported off-
site for disposal. Concrete slabs within areas to be excavated were removed, broken down,
decontaminated, and provided to East Feliciana Parish for use off-site as rip-rap. Approximately 1,300 CY
of concrete were recycled as rip-rap. Concrete slabs at or bgs in areas not requiring excavation were left
in place for future use. A total of 6,475 gallons of water was shipped to the Clean Harbors facility in White
Castle, Louisiana, for disposal (this included decontamination water for both the Site Preparation and
Asbestos Abatement/Demolition work). (CH2M Hill, 2005a).
4.3.2 Soil and Sediment Excavation
Excavation began on April 19, 2004. Soil and sediment were excavated from arsenic-only and arsenic-
PAH areas and stockpiled separately. Arsenic-only soil/sediment was excavated, staged in 300 CY
stockpiles, sampled for PAHs and TCLP arsenic and chromium to verify compliance with LDRs, and
transported off-site for disposal at Waste Management's Subtitle C landfill located in Carlyss, Louisiana.
The total volume of arsenic-only soil/sediment excavated at the CWP Site was 12,302 CY. Refer to
Figure 3 for approximate arsenic excavated areas on-site. Arsenic concentrations from post excavation
sampling ranged from 3.2 mg/kg to 6.3 mg/kg, all well below the RG of 20 mg/kg. The post excavation
sampling results were also well below the LDEQ Risk Evaluation/Corrective Action Program (RECAP)
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screening level soil concentration representing the soil concentration that does not result in the leaching
of an unacceptable constituent concentration from soil to groundwater.
Arsenic-PAH soil/sediment was excavated, stockpiled for drying and/or mixed with lime, treated in the
LTTD unit, staged in approximately 300 CY stockpiles, sampled for PAHs and TCLP arsenic and
chromium to verify compliance with applicable LDRs, and transported off-site for disposal at the same
Subtitle C landfill. The total volume of arsenic-PAH soil/sediment excavated at the CWP Site was 6,459
CY. Record samples were collected from the bottom of excavations in the arsenic-PAH area to provide
an accurate characterization of PAH concentrations remaining in-place at the site. A total of 19 record
samples were collected and analyzed for PAHs from the creosote containment area and drainage area.
Benzo(a)anthracene was selected in the Rl to illustrate the extent of PAH contamination as it was the
organic constituent most frequently detected above the RECAP screening criteria in use that time. The
record sample results were compared to the RECAP screening criteria. Benzo(a)anthracene sampling
results ranged from 0.08 mg/kg to 210 mg/kg with an average of 29.0 mg/kg. While the comparison
showed exceedances for contaminants of potential concern (as identified in the Rl) at eight of the 19
locations sampled, these exceedencces were found in a limited area along a drainage pathway on the
north property, north of State Highway 959 (Refer to Figure 4). No migration to ground water was
documented during pre-remediation ground water monitoring; post-remediation ground water monitoring
was specified by the ROD to ensure continued protectiveness of the ground water. Post-remediation
sampling also documented no migration to ground water and is discussed further in Sections 4.3.6 and
4.4.
The downstream portions of the Unnamed Creek that were remediated consisted of two sections, one
800 feet and one 100 feet in length, approximately 1100 feet downstream (south) of the South Property.
Remediation of this area was originally planned to consist of excavating the creek bed and creek banks
along these two sections to a depth of 1.5-feet bgs. Implementation of the "area average" cleanup
strategy (See Section 4.0 and Appendix F of the Rl Report) at the CWP Site indicated that the arsenic
RGs for the remote portions of Unnamed Creek south of the site were already achieved and no further
excavation was technically required. However, in keeping with the intent of the ROD (that other site
contaminants were to be addressed as part of the footprint of the arsenic contamination), the remedial
activity was still performed but reduced to include excavation of only 6-inches of sediment from the creek
bed and 1.5 feet of soil from two areas of the creek bank (instead of 1.5 feet in all locations), and
confirmation sampling was performed to confirm that the arsenic RGs were also met at the bottom of the
excavations.
A total of 218 CY of arsenic contaminated soils were excavated from the downstream portions of
Unnamed Creek located south of the South Property. The confirmation sampling was performed following
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excavation and prior to backfilling; samples were collected from the creek bed and banks. As noted
above, these samples were collected to confirm that the arsenic RG was met at the bottom/sides of the
excavations. Additional excavation would have been performed if the concentrations remaining in place
exceeded the RG. A total of 13 confirmation samples were collected and sent to an EPA Contract
Laboratory Program laboratory for arsenic analysis. All analyses showed that arsenic levels were below
the targeted RG of 160 mg/kg, and that no additional excavation would be required (CH2M Hill, 2005a).
4.3.3 Thermal Desorption
LTTD soil treatment technology was utilized at the CWP Site to reduce the PAH concentrations in the soil
to levels below LDRs. The LTTD operations area was divided into three subareas: the Feed Storage and
Preparation area, the Unit Operations area, and the Treated Materials Handling area. Prior to placing soil
in the LTTD unit, a soil feedstock amenable to LTTD operations had to be generated. Stockpiles of
excavated soils were first processed through a 2-inch screen to remove any debris and deleterious
material then through a 1-inch screen prior to treatment. In some instances, lime had to be added to the
feed soil prior to screening to reduce soil moisture. Approximately 191 tons of lime was mixed with the
feed soil prior to screening. After screen ing, composite soil samples were collected to verify the British
Thermal Unit (BTU) and moisture contents of the material. Although soil blending was anticipated to be
required to achieve lower soil BTU contents more amenable to treatment in the LTTD system, the BTU
samples indicated that overall BTU content was sufficiently low as not to require blending.
During the startup stage, completed on May 24, 2004, approximately 552 tons of materials were treated.
Following the startup period, the unit was down for eight days until June 2, 2004, for repairs due to hot
embers forming in the unit and burning the exhaust filter bags in the baghouse. During the shakedown
stage that followed the startup stage and continued through June 8, 2004, approximately 1,188 tons of
material were successfully treated. The Proof of Performance (POP) test phase followed and continued
for 10 days through June 18, 2004. The POP test was conducted to verify that the soil treated and stack
gasses emitted did not contain contaminants above regulatory levels. The POP test exceeded all
performance standards on the effluent soil, but failed stack gas emission standards for mercury and
arsenic. (Appendix G of the Rl Report contains a full POP report; Appendix Q contains a Tier II and Tier
III analysis regarding these exceedances). LTTD operations were completed on August 6, 2004, with the
completion of treatment of 9,142 tons of material (not including the 190 tons of lime added to reduce
moisture, and 20 tons of re-burned material) (CH2M Hill, 2005a).
4.3.4 Waste Management and Disposal
Each 300 CY pile of soil was sampled forTCLP Arsenic, TCLP Chromium, and PAHs prior to being
approved for shipment and disposal off-site. A total of 19,764 tons of arsenic-only material and 7,983 tons
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of arsenic-PAH LTTD treated material (total of 27,746 tons) was shipped off-site to Waste Management's
Subtitle C landfill located in Carlyss, Louisiana. In addition, a pile of sawdust originally located on the east
side of the South Property (associated with the raw lumber mill), which was originally planned for use as
mulch during the site restoration, was sampled during the RA to confirm its suitability for use. The results
of this sampling indicated elevated levels of lead. A total of 321 tons of sawdust was shipped off-site as
nonhazardous waste to Waste Management's Woodside Landfill in Walker, Louisiana. Decontamination
water from the cleaning of equipment and other activities was containerized and sampled for site-related
contaminants for characterization. Based on the analytical results, a total of 34,985 gallons of water was
shipped to the Clean Harbors facility in Deer Park, TX for final disposal) (CH2M Hill, 2005a).
4.3.5 Site Restoration
A clean, contaminant-free backfill meeting the specified geotechnical requirements was identified and
sampled to confirm the fill material was suitable fill for site excavations. Each excavation was backfilled
with clean clay to a depth of six inches bgs to allow for placement of topsoil. The backfill was placed in
lifts and compacted to meet the required compaction specifications. In-place density tests were
performed. The volume of backfill placed on-site totaled 15,846 CY.
Site restoration included the placement of a 9-inch layer of organic-rich topsoil uniformly distributed in the
excavation areas that had not been backfilled to grade (refer to Figure 5). A three-inch layer of topsoil
was placed and uniformly distributed on areas that were either not excavated, or were backfilled to grade.
Topsoil was not placed within the excavated bed of the Unnamed Creek. A total of 4,425 CY of topsoil
was imported for use at the site. Prior to being imported to the site, the topsoil was tested for
contamination and geotechnical parameters. Following topsoil placement, approximately 14 acres were
seeded to establish a vegetative cover. Rye grass was planted at the site in late October 2004, and
Bermuda was seeded and planted in late March of 2005. In early March 2005, approximately 250
Superior Loblolly pine seedlings were planted at approximately 125 locations throughout the North and
South Properties. Along the Unnamed Creek on the North and South Properties, where the soil tends to
contain more moisture, approximately 50 Cherrybark Oak trees were planted at 25 locations. Seedlings
were planted over an area of about 12 acres, in a somewhat random pattern approximately 50 to 80 feet
apart.
One area in the southeast corner of the South Property was left free of trees for a baseball field proposed
in future reuse plans. Temporary erosion control measures were installed and maintained during site
restoration construction activities (CH2M Hill, 2005a).
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4.3.6 Monitoring Well Installation
Nine ground water monitoring wells were installed during the Rl in 1999: three 10-foot bgs wells at three
locations to verify whether or not nonaqueous phase liquid noted in core samples in this area were
present; three, 45-foot bgs wells in the dry sand observed during the direct push/CRT activities to confirm
the lack of ground water in this sand and to allow collection of ground water samples if found at a later
date; and three, 65- foot bgs wells in the first occurrence of ground water to allow sampling for site-related
constituents. The only ground water encountered during the Rl was that observed in shallow soil under
the drainage pathway (-10 ft bgs), and that observed in the -65 ft bgs aquifer. Three wells were installed
at 10 ft bgs along the drainage pathway to check for free-phase creosote migration; these wells
accumulated some water (only two accumulated enough for sampling). The only exceedances of
chemicals of potential concern were found in the monitoring wells installed in the shallow ground water 10
feet bgs beneath the drainage pathway where most of the surficial creosote-related contamination
remained. Non-aqueous phase liquids were not found in the onsite wells during the Rl. However,
approximately 0.2 feet of a dense nonaqueous phase liquid (DNAPL) was detected in shallow site
monitoring well, MW-S3E2, and a trace was detected in shallow monitoring well, MW-S2E2, during
remedial design (RD) data collection activities in November 2001.
Five of the nine ground water monitoring wells were sampled after their installation in 1999 (four were
dry). The three 65 foot deep wells were sampled in November 2001 to gather additional data to support
the RD. In January, June, and October of 2005, the existing two wells (one each from the Rl and RA)
were sampled. Ground water evaluation performed during the remedial investigation (Rl) and RA
indicated the shallow 10 feet bgs ground water zone is not laterally continuous beyond the drainage
pathway, and does not demonstrate significant volumes of water (one of three wells installed in this zone
did not generate enough water to sample). The ground water encountered at 55 to 65 feet bgs
demonstrates capacities that are borderline at best for meeting Louisiana Department of Environmental
Quality's (LDEQ's) 2B classification for potentially potable ground water, and ground water is not used
from within this or any other zone in the vicinity of the site. Monitoring well abandonment began in late
February 2004 and was completed in early March 2004, concurrent with the RA Site Preparation stage of
the work. Eight of these nine ground water monitoring wells were abandoned during the RA in 2004
because they were located in areas targeted for soil excavation/remediation. The deepest site
excavations for LTTD treatment took place in the area where chemicals of potential concern were found
in the monitoring wells installed in the shallow ground water 10 feet bgs beneath the drainage pathway.
Excavation likely removed the small amounts of DNAPL found during RD data collection.
Monitoring well, MW-1 was installed on January 21, 2005 by a licensed Louisiana drilling contractor. The
location of the 2005 monitoring well is shown in Figure 6. The well was constructed of 2-inch Schedule
40 PVC to a depth of 65 feet bgs. A 10-foot section of 0.01-inch slotted screen was installed from 55 to 65
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feet bgs. The annulus around the well screen was filled with silica sand to a height of approximately two
feet above the top of the well screen. A bentonite seal was installed and the borehole annulus was
grouted to the surface. The well construction was completed with the installation of a 4-inch steel
protective casing, a 4- by 4-foot concrete pad, and four concrete-filled steel bollards.
4.4 Operations and Maintenance
The ROD stated that:
Soils with organic contamination would be left in place in the subsurface (greater than 5
feet bgs). To ensure protectiveness of ground water, a ground water monitoring system
would be necessary to monitor contaminant levels in the ground water. The dry sand that
exists from about 25 to 45 feet bgs would also be monitored to ensure no future migration
pathway develops. Ground water samples would be collected on an annual basis, but the
sampling frequency may be modified if there are statistically significant changes in
ground water sample concentrations.
Ground water was to be monitored to ensure that wastes left in place do not affect the ground water
because soils with organic contamination would be left in place in the subsurface (greater than 5 feet
below ground surface [bgs]). The ROD required that ground water samples would be collected on an
annual basis, but the sampling frequency may be modified if there are statistically significant changes in
ground water sample concentrations.
Nine wells were originally proposed to be installed during the RA. Existing monitoring well MW-S2E5 was
left in place as originally planned, but the number of new monitoring wells was reduced from eight to one
based on the expectation that two monitoring wells would be sufficient for evaluation of potential migration
to ground water from the limited site area with residual PAH contamination. A total of 8 (eight) monitoring
wells were abandoned. After several rounds of ground water monitoring, these two remaining monitoring
wells were removed (properly plugged and abandoned) at the request of LDEQ. Use of creosote
compounds ceased in 1973, with no evidence of migration occurring from the containment basin area.
No migration of contamination to ground water was found to have occurred during post-RA sampling.
Because ground water monitoring wells are no longer present on-site, O&M of a ground water monitoring
network is no longer required. The O&M operations now required are maintaining the site such that soils
greater than three feet bgs are not exposed.
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5.0 Five-Year Review Process
This Five-Year Review has been conducted in accordance with the EPA's Comprehensive Five-Year
Review Guidance, dated June 2001 (EPA, 2001 b). The Five-Year Review for this site was initiated by
the EPA which tasked the USAGE to perform the technical components of the multidisciplinary review.
The ROD, signed on April 5, 2001, set forth the selected remedy for soils/sediments for the site, which
includes Removal and Thermal Desorption On-Site, Off-Site Stabilization and Disposal. Initiation of this
First Five-Year Review was based on initiation of remedial actions at the site, thus this First Five-Year
Review is dated April, 2009. Members of the review team include Mr. David Jones, Ms. Jeanne Carroll,
and Mr. John Lambert, all of the Tulsa District USAGE.
Interviews were conducted with relevant parties; a site inspection was conducted; and applicable data
and documentation covering the period of the review were evaluated. The findings of the review are
described in the following sections.
5.1 Community Involvement
A public notice announcing commencement of the Five-Year Review was published in the Baton Rouge
Advocate on February 12, 2009. Upon signature, the Five-Year Review will be placed in the information
repositories for the site, including the Audubon Library in Clinton, Louisiana and the EPA Region 6 office
in Dallas, Texas. A second notice will be published in the Baton Rouge Advocate to summarize the
findings of the review and announce the availability of the report at the information repositories. A copy of
the first public notice is provided as Attachment 7 to this report.
5.2 Document Review
This Five-Year Review included a review of relevant site documents, including the ROD, RA Report, Rl
Report, FS Report, construction and implementation reports, ground water sampling reports, and related
monitoring data. Documents that were reviewed are listed in Attachment 1.
5.3 Data Review
One purpose of a Five-Year Review is to review data collected since the triggering action of that Five-
Year Review. The trigger action is usually a previous Five-Year Review, or in this case, the initiation of
the RA. Because the site soils/sediment were remediated during the RA, review of soils data is not
compulsory for this Five-Year Review, but review of the site's ground water data is mandatory by
definition. A general overview of the site's soil/sediment remediation follows.
Prior to the Time-Critical Removal Action, numerous site assessments were performed at the CWP Site in
order to characterize the nature and extent of any COCs present. The Time-Critical Removal Action then
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focused on particular on-site structures and soils, removing several site structures and approximately
1,520 CY of solids. The RD for the selected remedy set forth in the ROD was completed in May 2002.
The RD provided the basis of design and included specifications for implementation of the remedy.
During the RA, additional remaining on-site structures were removed and over 20,000 CY of solids were
removed from the site and the Unnamed Creek. EPA closely monitored this project to ensure that all
construction activities met the RD specifications in accordance with the Construction Quality Assurance
Plan, Field Sampling Plan, and Quality Assurance Project Plan. EPA analytical methods were utilized for
all confirmation and record samples collected by CH2M HILL during the RA; sampling was conducted in
accordance with approved sampling plans and analyses were conducted by certified laboratories. EPA
and LDEQ representatives visited the site monthly to review construction progress and evaluate and
review the results of QA/QC activities. Based on CH2M MILL'S design and oversight of the RA, EPA
concluded that the construction activities and results were consistent with the ROD and the RD plans and
specifications.
In response to Hurricanes Katrina and Rita, EPA performed sampling at the site to determine if the impact
of the hurricanes affected the integrity of the remedy. The site was sampled on October 7-8, 2005, using
a grid-based approach to collect surface soils samples from the 0-3 inch interval. The results found that
several grids on the south-side of the site were above the remediation goal for arsenic. Additional
sampling was conducted in February 2006 to provide better definition of the contamination. The results of
the sampling were used to define additional excavation that was performed in May 2006. Approximately
980 cubic yards of soils were excavated from the area and sent off-site for disposal. A Final Close Out
Report for the site was signed June 29, 2006.
In regard to site soils, the site meets all the site completion requirements as specified in Close-Out
Procedures for NPL Sites, OSWER Directive 9320.2 - 09A-P. Specifically, the completion of construction
of all the elements of the ROD and the implementation of the institutional controls has addressed the
threats to human health and the environment. A Conveyance Notification was filed with the Clerk of Court
that allows for unrestricted access in the upper three feet of soils, but provides restrictions under State
law on disturbing or moving deeper soils.
O&M for the site, was based on monitoring site ground water: As discussed in Section 4.4, the
CWP Site ground water monitoring wells have been sampled from 1999 through 2006. Table 2
lists all detected analytes for these sampling rounds.
Nine ground water monitoring wells were installed during the Rl in 1999: three 10-foot bgs wells at three
locations to verify whether or not nonaqueous phase liquid noted in core samples in this area were
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present; three, 45-foot bgs wells in the dry sand observed during the direct push/CRT activities to confirm
the lack of ground water in this sand and to allow collection of ground water samples if found at a later
date; and three, 65- foot bgs wells in the first occurrence of ground water to allow sampling for site-related
constituents. The only ground water encountered during the Rl was that observed in shallow soil under
the drainage pathway (-10 ft bgs), and that observed in the -65 ft bgs aquifer. Three wells were installed
at 10 ft bgs along the drainage pathway to check for free-phase creosote migration; these wells
accumulated some water (only two accumulated enough for sampling). The only exceedances of
chemicals of potential concern were found in the monitoring wells installed in the shallow ground water 10
feet bgs beneath the drainage pathway where most of the surficial creosote-related contamination
remained. Non-aqueous phase liquids were not found in the onsite wells during the Rl. However,
approximately 0.2 feet of a dense nonaqueous phase liquid (DNAPL) was detected in shallow site
monitoring well, MW-S3E2, and a trace was detected in shallow monitoring well, MW-S2E2, during
remedial design (RD) data collection activities in November 2001.
Five of the nine ground water monitoring wells were sampled after their installation in 1999 (four were
dry). The three 65 foot deep wells were sampled in November 2001 to gather additional data to support
the RD. In January, June, and October of 2005, the existing two wells (one each from the Rl and RA)
were sampled. Ground water evaluation performed during the remedial investigation (Rl) and RA
indicated the shallow 10 feet bgs ground water zone is not laterally continuous beyond the drainage
pathway, and does not demonstrate significant volumes of water (one of three wells installed in this zone
did not generate enough water to sample). The ground water encountered at 55 to 65 feet bgs
demonstrates capacities that are borderline at best for meeting Louisiana Department of Environmental
Quality's (LDEQ's) 2B classification for potentially potable ground water, and ground water is not used
from within this or any other zone in the vicinity of the site. Monitoring well abandonment began in late
February 2004 and was completed in early March 2004, concurrent with the RA Site Preparation stage of
the work. Eight of these nine ground water monitoring wells were abandoned during the RA in 2004
because they were located in areas targeted for soil excavation/remediation. The deepest site
excavations for LTTD treatment took place in the area where chemicals of potential concern were found
in the monitoring wells installed in the shallow ground water 10 feet bgs beneath the drainage pathway.
Excavation likely removed the small amounts of DNAPL found during RD data collection.
The three monitoring wells set in the first water producing aquifer at approximately 65 feet bgs were
sampled during the November 2001 sampling event. All detected analytes were below available MCL
and/or RECAP values. Two of these three wells were removed during RA activities; MWS2E5, which is
located on the extreme southeastern portion of the North Property was left in place. An additional well,
MW-1 was installed, to an approximate depth of 65' (See Figure 6).
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The two existing site wells, MWS2E5 and MW-1, were sampled in January, June, and October of 2005.
For the January 2005 event, MW-S2E5 showed no detections above the reporting limit for all constituents
analyzed. The detection of several SVOCs in ground water at a depth of approximately 65-feet, in MW-1,
was a first-time occurrence at the site. The detected constituents did not exceed the RECAP screening
standards for ground water. Samples collected during the two previous sampling events from three wells
screened in this interval showed no detections of these constituents, however, these SVOC constituents
are similar to those detected in ground water samples collected at a depth of approximate 10 feet bgs
during the Rl. During the installation of monitoring well MW-1, hydrocarbon staining was observed to a
depth of 23 feet bgs. It is possible that the detection of SVOCs was a result of cross-contamination due to
a drag-down of contaminants during well installation, through the shallow zone, and not the detection of a
contaminant occurrence in this ground water zone. (CH2M Hill, 2005b),
Prior to the next sampling event in June 2005, MW-1 was re-developed in an effort to remove what is
believed to be residual SVOC contamination resulting from well installation activities detected during the
first semiannual sampling event conducted in January 2005. Re-development of monitor well MW-1
commenced on June 29, 2005 after water levels were collected. No SVOCs , or arsenic, were detected in
samples from either monitor well during this sampling event. It is speculated that the SVOCs detected
during the first sampling event at MW-1 were a result of cross-contamination during well installation, and
not the detection of a contaminant in this ground water zone.
In response to Hurricanes Katrina and Rita, EPA performed sampling at the site to determine if the impact
of the hurricanes affected the integrity of the remedy. The two monitoring wells were sampled in October
of 2005. No COCs, with the exception of one SVOC, were detected in samples from either monitoring
well during this sampling event. The one detection, bis(2-ethylhexyl)phthalate, was above the RECAP
value, but is considered a common lab contaminant.
Correspondence from LDEQ to EPA (LDEQ, 2006), citing previous ground water data, requested
concurrence to abandon the two remaining wells. Because no ground water monitoring wells are now
present on-site, O&M of a ground water monitoring network is no longer required. The O&M operations
now required are maintaining the site such that soils greater than three feet bgs are not exposed. The
institutional controls described in Section 5.4 outline that unrestricted exposure is permitted in theO-3 foot
interval, but that disturbing soil at depths greater than 5 feet may pose a threat to human health and the
environment. The parish regulates use of the site by maintaining engineering controls such as the fence
with locked gates. Through the parish's regulation of the site contaminated soil exposure is restricted.
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5.4 Institutional Controls
As part of the site remedy identified in the ROD, Institutional controls were to be implemented in areas
where contaminants were left in place in the subsurface at concentrations above the RGs. Institutional
controls in the form of deed notices were to be put in place to inform the public of site conditions.
Specifically, EPA would request LDEQ, in accordance with La. Rev. Stat. Ann. § 30:2039 (2000) and La.
Admin. Code title. 33 § 3525 (1999), to require affected property owners to record a notice in the
mortgage and conveyance records of East Feliciana Parish. The East Feliciana Parish Police Jury
submitted a Conveyance Notification which was filed for registry and recorded in the Clerk of Courts on
September 30, 2005 (EFPPJ, 2005). This notice provided the following information:
That the property has been the subject of CERCLA response;
That hazardous substances remain in surface soils outside the excavation areas on the property
but are below levels that allow for unrestricted exposure in the 0-3 foot interval. (Shown in
Attachment 2 of the conveyance);
That hazardous substances remain in subsurface soils (> 5 feet) on the property (Shown in
Attachment 3 of the conveyance) and may exceed risk-based levels. Disturbing or moving soil
in these subsurface locations may pose a threat to human health or the environment, and may
subject the property owner and the party causing the disturbance to liability under CERCLA or
other laws;
That structures including monitoring wells, and any other feature necessary for protectiveness of
the remedy or for its successful operation and maintenance, remain on the property at specified
locations;
That disturbing or moving these features of the remedy may pose a threat to human health or the
environment, and may subject the property owner and the party causing the disturbance to
liability under CERCLA or other laws; and,
That the property may be subject to restrictions under LAC 33.V. Chapter 35.
5.5 Interviews
A partial interview was conducted with the LDEQ Project Manager, Ms. Wanda Ballou during the site visit
conducted on December 1, 2008. A follow-up interview was conducted via email on January 30, 2009.
An in-person interview was conducted with Mr. Greg Beauchamp, Director of Public Works, on
December 1, 2008. The completed interview record forms are presented in Attachment 2.
5.6 Site Inspection
An inspection was conducted at the site on December 1, 2008. The completed site inspection checklist is
provided in Attachment 3. Site inspection tasks included a visual inspection of site features including
existing concrete slabs, fences and gates, in addition to inspecting the numerous woody debris piles
staged on-site. No site logs, documents, or records were available on-site. Photographs taken during the
CWP Site inspection are provided in Attachment 4. The site inspection indicated that the chosen
remedy appeared appropriate, relating to being protective of human health and the environment, but
because the site is currently being used to stage Hurricane Katrina woody debris, the original end use for
Central Wood Preserving Company Superfund Site 28
First Five-Year Review
-------
the site is not being attained. There was no indication that any disturbance of site soils, such as
excavation or grading, had taken place in the recent past. The inspection team consisted of Mr. David
Jones and Ms. Jeanne Carroll of the USAGE. They were accompanied by Ms. Laura Stankosky of EPA
Region 6 and Ms Wanda Ballou, of LDEQ.
6.0 Technical Assessment
The Five-Year Review must determine whether the remedy at a site is protective of human health and the
environment. The EPA guidance describes three questions used to provide a framework for organizing
and evaluating data and information, and to ensure all relevant issues are considered when determining
the protectiveness of a remedy.
6.1 Question A: Is the Remedy Functioning as Intended by the Decision
Documents?
The document that details the remedial decisions for the site is the April 2001 ROD. The ROD set forth
the selected remedy for the site as Removal and Thermal Desorption On-Site, with Off-Site Stabilization
and Disposal. The selected remedy is a comprehensive approach for this site that addresses all current
and potential future risks caused by wastes left in place at depth and implements institutional controls to
ensure future site use is consistent with the acceptable risk levels in the on-site soils. The selected
remedy, pertaining to on- and off- site soils/sediments as described in the ROD, has been fully
implemented; as a result, the remedy is functioning as intended in the ROD. The major components of
this remedy are:
Excavation of Surface/Near-Surface Soil/Sediment that Exceeds RGs - Soil/sediment that exceeded
RGs were excavated and staged pending treatment/disposal. Excavated soil/sediment that exceeded
Land LDRs were be staged separately from excavated soil/sediment that did not exceed LDRs.
Thermal Desorption of Excavated Soil/Sediment that Exceeds LDRs - Excavated soil and sediment
exceeding LDRs were prepared for treatment and treated with an on-site thermal desorption unit. TCLP
sampling of the residuals was performed prior to off-site disposal.
Disposal of Excavated Soil/Sediment - The excavated soils were tested and disposed of accordingly.
Backfilling - The North and South Property removal areas were backfilled with clean backfill and re-
vegetated following confirmation sampling. The excavated portions of the Unnamed Creek were backfilled
with clean backfill and an erosion control layer was installed to aid in revegetation.
In addition to these components for soils remediation, the site would also require, as specified in the
ROD:
Central Wood Preserving Company Superfund Site 29
First Five-Year Review
-------
Ground water Monitoring - To ensure that wastes left in place do not affect the ground water, ground
water monitoring would be implemented. Soils with organic contamination would be left in place in the
subsurface (greater than 5 feet bgs). To ensure protectiveness of ground water, a ground water
monitoring system would be necessary to monitor contaminant levels in the ground water. The dry sand
that exists from about 25 to 45 feet bgs would also be monitored to ensure no future migration pathway
develops. Ground water samples would be collected on an annual basis, but the sampling frequency may
be modified if there are statistically significant changes in ground water sample concentrations.
Institutional Controls/Deed Restrictions - Institutional controls were implemented in areas where
contaminants were left in place in the subsurface at concentrations above the RGs. Specifically, in
accordance with La. Rev. Stat. Ann. § 30:2039 (2000) and La. Admin. Cod tit. 33 § 3525 (1999), the East
Feliciana Parish Jury submitted conveyance records as appropriate or as allowed by law to prevent
exposure to contaminants remaining on-site on the North Property below three feet bgs .
Inspection - Prior to the completion of the remedial action, EPA conducted a review of the site.
The expected outcome of the selected remedy is that the site would no longer present an unacceptable
risk to human health because the contaminated soil and sediment was excavated, treated, and disposed
of off-site and the property would be suitable for residential and recreational land use. In addition,
institutional controls, such as the deed notice, would prevent future human exposure to soil contamination
below three feet. By addressing the unacceptable human health risks in the sediment contamination in
the Creek, EPA addressed contamination that affects the wetlands and other habitat in the Creek, thereby
providing environmental and ecological benefits such as wetlands restoration.
Ground water monitoring was initially implemented to ensure that the remedy is protective. There is no
evidence that historic site activities affected the first true water-bearing zone. Correspondence from
LDEQ to EPA (LDEQ, 2006), citing previous ground water data, requested concurrence to abandon the
two remaining post-RA wells.
6.2 Question B: Are the Exposure Assumptions, Toxicity Data, Cleanup
Levels, and Remedial Action Objectives Used at the Time of the Remedy
Selection Still Valid?
The purpose of this question is to evaluate the effects of any significant changes in standards or
assumptions used at the time of remedy selection. Changes in promulgated standards or "to be
considered" and assumptions used in the original definition of the remedial action may indicate that an
adjustment in the remedy is necessary to ensure the protectiveness of the remedy.
Central Wood Preserving Company Superfund Site 30
First Five-Year Review
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Changes in ARARs
ARARs for this site were identified in the ROD dated April 2001. The five-year review for this site included
identification of and evaluation of changes in the ROD-specified ARARs to determine whether such
changes may affect the protectiveness of the selected remedy. The ARARs identified by the ROD for the
CWP Site include chemical, action and location specific ARARs, and are described below.
Chemical-Specific Requirements
Chemical specific ARARs are usually health or risk based numerical values or methodologies that, when
applied to site-specific conditions, result in the establishment of numerical values. These values establish
the acceptable amount or concentration of a chemical that may be found in, or discharged to, the
environment. Potential exposure pathways for contamination include air and soil. The State of Louisiana
has not identified MCL values for PAHs. Also, no Federal or State of Louisiana regulatory cleanup
standards had been promulgated for soil; therefore, risk based criteria were identified for this media.
The human health risk based RGs for contaminants of concern were calculated for the North and South
Properties based on 1 x 10~6 carcinogenic risk using adult and child resident and construction worker
exposure scenarios. The resulting arsenic RG for surface soil/sediment was calculated as 0.03 ppm.
Since this concentration was lower than the background concentration, and could not be met, the arsenic
RG was set at the background concentration of 20 ppm. This corresponds to a residential risk of 1 x 10~4.
The human health risk based RGs for contaminants of concern were calculated for the 3-5 foot interval for
the North property based on 1 x 10~5 carcinogenic risk using a future utility worker scenario. The resulting
arsenic RG for surface soil/sediment was calculated as 300 ppm.
The human health risk based RG was calculated for the Unnamed Creek based on 1 x 10~5 carcinogenic
risk using a recreational youth and adult hunter scenario. The resulting arsenic RG calculated was 160
ppm.
Action-Specific Requirements
Action-specific ARARs are typically technology or activity-based requirements applicable to actions
involving special categories of wastes. Action-specific requirements are usually triggered by certain
remedial activities that may be a component of the overall cleanup alternative. The following action-
specific requirements were applicable during remedial actions, but are not still applicable unless further
remediation is performed:
Asbestos Abatement:
o Toxic Substances Control Act, 40 CFR §763.121
o Clean Air Act § 112, 42 U.S.C. § 7412.40 CFR Part 61
o Asbestos Standards for Demolition and Renovation, 40 CFR Part 61.145
Central Wood Preserving Company Superfund Site 31
First Five-Year Review
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Soil Treatment:
o Prevention of Significant Deterioration of Air Quality, 42 USC § 7475, 40 CFR § 52.21
o Hazardous Waste Burned in Boilers and Industrial Furnaces, 40 CPR 266 Subpart H
o Control Facilities to be Installed when Feasible, 33 LAC:III.905
o Control of Fugitive Emissions, 33 LAC:III.1305
Waste Disposal:
o Land Ban, 40 CFR Part 268, Subpart C - Prohibitions on Land Disposal, Subpart D - Treatment
Standards
o Manifest Requirements, 33 LAC:V.903 (Note: Moved to 33 LAC:V.1516 - Manifests forTSD
Facilities)
o Manifest Document Flow, 33 LAC:V.913 (Note: Moved to 33 LAC:V.1516 - Manifests forTSD
Facilities)
oThe Manifest System, 33 LAC:V.1107
o Manifest System Emergency Response Information, 33 LAC:V.1108
o Pre-Transport Requirements, 33 LAC:V.1109
o Preparedness and Prevention, 33 LAC:V.1511
Permits and Enforcement, CERCLA § 121(e), 42 U.S.C. § 9612(e)
Monitoring Well Abandonment and Sealing of Bore Holes, 33 LAC:V.3323
Location-Specific Requirements
Location-specific ARARs are restrictions placed on remedial activities solely on the basis of the location
of the remedial activity. Some examples of locations that might prompt a location-specific ARAR include
wetlands, sensitive ecosystems or habitats, floodplains, areas of historical significance. The following
location-specific ARARs are applicable:
Floodplain Management, Executive Order No. 11988
Fish and Wildlife Coordination Act, 16 USC § 661 etseq., 16 USC § 742a, 16 USC § 2901
The LDEQ and the Federal regulations have not been revised to the extent that the effectiveness of the
remedy at the site would be called into question. The Louisiana RECAP standards were updated in 2003;
however, no significant changes have been made that would question the site remedy effectiveness. The
2003 RECAP values were used during ground water sampling evaluation and comparisons performed in
2005 for the site. Changes were made to 33 LAC:V where Chapter 9 was repealed on May 20, 2006, but
the two ARARs related to that chapter were moved to Chapter 15 (see notes above).
Central Wood Preserving Company Superfund Site 32
First Five-Year Review
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Changes in Exposure Pathways, Toxicity, and Other Contaminant Characteristics.
There have been no changes in exposure pathways, toxicity characteristics, or other contaminant
characteristics for the CWP Site. There has been no change to the standardized risk assessment
methodology that would affect the protectiveness determination of the remedy.
6.3 Question C: Has Any Other Information Come to Light That Could Call
into Question the Protectiveness of the Remedy?
No other information, such as a potential future land use change in the vicinity of the site, change in site
conditions, or exposure pathways, etc., that might call into question the protectiveness of the selected
remedy has been identified with this five-year review that would impact the protectiveness of the remedy.
7.0 Issues
During this review, issues were observed at the time of the site inspection, as described in the following
table.
No.
1
Issues
The site is being used by East Feliciana Parish for staging
woody debris from Hurricane Katrina damage. Most of the
debris consists of tree and brush debris. There are,
however, several small piles of possible household
waste/debris and a pile of large treated wood timbers. The
parish indicated that while the site gates have been opened
during hurricane tree and brush debris staging that illegal
disposal has taken place on the site. This household waste
and treated wood timbers may have come from illegal
disposal; however, this household waste and treated wood
timbers do not meet the conditions of the permit that the
parish obtained from the LDEQ for staging of hurricane
woody debris and depending on the nature of the waste
may potentially re-contaminate the site. Between the time
of inspection and when this review report was written a
large portion has been removed from the site and properly
disposed of off of the site property.
Affects
Protectiveness
(Y/N)
Current
N
Future
Potential
Impact
Central Wood Preserving Company Superfund Site
First Five-Year Review
33
-------
8.0 Recommendations and Follow-Up Actions
Recommended further actions are listed in the table below.
No.
1a
1b
Recommendations/Follow-up
Actions
Work with East Feliciana Parish to
ensure removal of the household
waste/debris and treated wood
timbers.
Work with East Feliciana Parish to
ensure that illegal disposal is not
allowed to continue.
Party
Responsible
LDEQ
LDEQ
Oversight
Agency
EPA
EPA
Milestone
Date
October
2009
October
2009
Follow-up
Actions: Affects
Protectiveness
(Y/N)
Current
N
N
Future
Y
Y
9.0 Protectiveness Statement
Based on the information available during this first Five-Year Review, the selected remedy is performing
as intended. The selected remedy is currently protective of human health and the environment in the
short term. This determination is based on the results from treated waste and soil sampling and shallow
ground water sampling. It is also based on the fact that wastes and contaminated soils have been
removed from the site or treated through LTTD, and those wastes remaining, greater than five feet in
depth, are addressed with the implementation of institutional controls. For the remedy to remain
protective in the long-term the site should not be used for staging of household waste/debris or treated
wood timbers, the security fencing around the site should be maintained to prevent illegal disposal, the
conveyance notice should be maintained, and contamination remaining below five feet must remain un-
exposed.
10.0 Next Review
The next Five-Year Review, the second for this site, should be completed by April, 2014. The review
should focus primarily on an update to the status of the site and that implemented institutional controls
are being maintained.
Central Wood Preserving Company Superfund Site
First Five-Year Review
34
-------
Figures and Tables
-------
NORTH
PROPERTY
APPROXIMATE LOCATION
- OF ADJACENT RESIDENCES
\
PA FENCE LINE
ORIGINAL \
FACILITY ' \
FENCE LINE ,
REMNANT OF
ORIGINAL
CONTAINMENT
BASIN WALL
ORIGINAL PROPERTY
BOUNDARY
iaton i r
Q"' Rouge *'<
-CENTRAL WOOD
PRESERVING SITE
UNNAMED CREEK
SOUTH
PROPERTY
REVISED PROPERTY BOUNDARY
IN ACCORDANCE WITH BOUNDARY
AGREEMENT BETWEEN EAST FELICIANA
PARISH AND SUCCESSION OF BOB R. JONES,
DATED JULY 12, 2002 (REPLACES PORTION
OF ORIGINAL PROPERTY BOUNDARY
BETWEEN ARROWS.)
LOUISIANA
LEGEND
EXISTING STRUCTURES
APPROXIMATE LOCATION OF
REMOVED STRUCTURES
APPROXIMATE 1995 REMOVAL AREA
CWP PROPERTY BOUNDARY
-------
EPA FENCE LINE
LEGEND
N
180
NORTH
PROPERTY '
APPROXIMATE LOCATION /
OF ADJACENT RESIDENCES /
(EXISTING AND REMOVED) -. /
\
/
/
/
/
^
^
/
/
/ /
/ "--./
/
' BLDG 19
/ (SLAB ONLY)
/
/
SOUTH /
PROPERTY / BLDG18
/
/
/
/
/
/
^
^
^
^ V. BLDG 13
^ ^ BLDG 14
^
A A ^
W W WATER ^ .
SUPPLY ^\
WELLS ^ ^
"-... -. /
BLDG 8 \ ^"~~~ - .
\ ' \
\ - - -^ '. A MONITORING WELL
BLDG 9 M I ;
'\ /^ ORIGINAL . / ^ WATER SUPPLY WELL
1 \ ^-^ FACILITY ; ' V (ABANDONED DURING REME
\ ^ jS^ FENCE LINE ,
, \ I ^ UNCOVERED BOREHOLE
\ \ \ / (ABANDONED DURING REMEI
/\ ^ "~^ /
BLDG 4 . \ ~^~~ 1
A ^ ^
\ MW-N2EO ^ ^ v /
BLDG 5 i ^X /V
(SLAB ONLY) \ / ^^^
\ V\ ' ^^^ UNNAMED CREEK
\ >
/\
BLDG * AMW-SOE1 \
\\ / \
^ -^..\>-.-,x"
MW-S2E1^ \MW-S2E2 /' /'
BLDG \A / '
1 \ A MW-S2E3 x''^-^
^r-f-. BLDG 2 MWS3E2A1 ' ^ ^ ^^~~^ REVISED PROPERTY BOUNDARY
^/G,., \ / / IN ACCORDANCE WITH BOUNDARY
°%|,, \ / , AGREEMENT BETWEEN EAST FELICIANA
9Sg \ ' ,' PARISH AND SUCCESSION OF BOB R. JONES,
MW-S4E2 > ' / DATED JULY 12, 2002 (REPLACES PORTION
A i ,' xx OF ORIGINAL PROPERTY BOUNDARY
BLDG 7 A y MW-S2E5^X BETWEEN ARROWS.)
A MW-S5E2 \ >- '
/ \ /
BLDG r*
\
. ^ ORIGINAL PROPERTY
/ /* ^ * ^^ BOUNDARY
BLDG .'' ^ \. \
16 / " \ \
/ ^\ \
/' ' ^ '
' /' ^^ '
/
/ /
/ /
BLDG .. /
17 ^x
/
//
/
//'
//
-------
LEGEND
AJR-07
7.70
NORTH
PROPERTY-
»AJR-OB
6.20
AJR-05
6.60
AJR-04
7.30
60 120
J
Scale In Feet
180
AJR-09
6.60
AJR-03
10.40
S1W10-00
6.60
AJR-10
8.40
S2W1WO
3.10
S3W10-00
6.40
S4W10-00
9.60
N6W5-00
24.50 mg/Kg
RI0140
6.10
RI0141
8.10
S3W9-00
9.20
AJC-11
6.00
IRI0125
7.80
RI0126
5.10
RI0066
10.20
RI0071
16.10
S4W9-00
115°S3W8-OO.IR|01
26-90 ]
-510190
9.30
(S4W8-00
20.20
RI0070
9.50
RI0069
13.40
RI0073
6.60
DPG19-00
) 38.00
DPC12-00
17.70
S3E5-OOAVG
5.35
S4E5-OOAVGS3E5-02
5.70 3.30
S4E5-02
3.30
S5E5-OOAVG
3.30
S5E5-02
3.30
EAST FELICIANA PARISH
PROPERTY BOUNDARY LIMITS
EXCAVATED AND BACKFILLED WITH
NATIVE SOIL (0 TO 1.5 FT BGS)
EXCAVATED AND BACKFILLED WITH
NATIVE SOIL (0 TO 3 FT BGS)
EXCAVATED AND BACKFILLED WITH
NATIVE SOIL (0 TO 5 FT BGS)
SOIL SAMPLE LOCATION (0 TO 1.5 FT BGS)
WITH CORRESPONDING ARSENIC CONCENTRATION
SHARED SOIL SAMPLE LOCATIONS AND
CORRESPONDING ARSENIC CONCENTRATION
(TOP NUMBER IS 0 TO 1.5 FT BGS
AND BOTTOM NUMBER IS 1.5 TO 3 FT BGS)
NOTES:
1. ARSENIC CONCENTRATIONS IN THE BACKFILL SOIL AVERAGED 4.85 mg/Kg.
SEE ALSO RECORD DRAWING M-3.
2. ALL CONCENTRATIONS ARE IN mg/Kg.
BGS-39
CWPSS-08
11.60
RI0116
7.60
RIOT 17
6.10
RI0095
2.30
. RI0096
14.30
| RIOT 19
6.10
RI0120
9.70
DPG10-00
428.00
- S6E3-OOAVG
156.50
S6E3-02
18.90
-------
LEGEND
60 120 180
^^^
Scale In Feet
I I
N2E1
1.0
S1E3
1.0
S3E2
1 0
PROPERTY BOUNDARY LIMITS,
AREA EXCAVATED
AREA EXCAVATED AND THERMALLY
TREATED TO BELOW PAH LDR'S
AREA NOT EXCAVATED
RECORD SAMPLE FROM 1 .5 FT BGS
AND CORRESPONDING
CONCENTRATION IN mg/Kg
RECORD SAMPLE FROM 3.0 FT BGS
AND CORRESPONDING
CONCENTRATION IN mg/Kg
RECORD SAMPLE FROM 5.0 FT BGS
AND CORRESPONDING
CONCENTRATION IN mg/Kg
NOTES:
1. BENZO (a) ANTHRACENE WAS SELECTED AND MAPPED AS AN
INDICATION OF THE EXTENT OF PAH CONTAMINATION IN SOIL AND
SEDIMENT BECAUSE IT WAS THE MOST FREQUENTLY DETECTED
ABOVE THE RECAP SCREENING CRITERIA DURING THE REMEDIAL
INVESTIGATION.
2. SEE APPENDIX H FOR DEFINITION OF DATA QUALIFIERS.
-------
180
ORIGINAL PROPERTY
BOUNDARY
V
LEGEND
PROPERTY BOUNDARY LIMITS
TOPSOIL AREAS
(6 - INCHES)
RACR_FIG3-3.dgn
-------
ROBERT L . ANDERSON
(NOW OR FORMERL Yl
60 120
J L
Scale In Feet
180
THE J.B. HERROD TRUST
FINAL PROPERTY BOUNDARY AS ACCORDING TO THE
BOUNDARY SURVEY PERFORMED BY 5JB GROUP,
INC.
\ SUCCESSION OF
\ BOB R. JONES, et a I
SOUTH
PROPERTY
APPROXIMATE LOCATIONS OF
CLEARED VEGETATION BURN PIT
(BACKFILLED WITH NATIVE SOIL)
CONCRETE
SLAB
{COVERED KITH
TOPSOIL AND SEEDED
GRAVEL
PARKING LOT
(SOUTH)
^ .^HISTORIC SAWMILL
f\ .7 EQUIPMENT STAGING
^~"
CLEARED VEGETATION
MULCH PILE
LOT C-2
ALINE M. HERROD ESTATE
LEGEND
DEEP MONITORING WELL
(~ 65 FEET)
PROPERTY BOUNDARY LIMITS
ALINE M. HERROD ESTATE
-------
Table 1
Chronology of Site Events
Central Wood Preserving Company
East Feliciana parish, Louisiana
Date
1950s
January 3,1973
November 1983
January 1, 1991
March 4, 1992
March 17, 1992
Aprils, 1992
June 1992
July- October
1992
January 1993
June 1, 1993
July 1993
September 1993
November 9,
1993
November 1993
August 1994
Januarys, 1994
April - June
1994
October 31,
1994
November -
December 1994
March 27, 1995
March 30, 1995
Aprils, 1995
Aprils, 1995
April 12, 1995
April- July 1995
June 15, 1995
June- July 1995
November 6,
1995
December 27,
1995
August 4, 1998
January 19,1999
April 29, 1999
April 1999
Event
Wood preserving facility begins operations under the name of Central Creosoting
Company, Incorporated. Creosote was used exclusively as the wood preservative.
Facility was sold and began operating under the name of Central Wood Preserving
Company, Inc. During this year the use of creosote was discontinued, and the
facility began using Wolmanac
The CWP facility was confirmed as a RCRA small quantity generator of hazardous
waste composed of copper oxide, chromic acid, and arsenic acid (CCA, or
Wolmanac).
CWP, Inc., declared bankruptcy and ceased operations.
LDEQ confirmed the wood preserving/processing portion of the site to be inactive.
LDEQ conducts a site visit to document location of structures, spilss, and drainage pathways.
LDEQ informs EPA that the facility is a potential hazardous waste site and formally requests EPA
assistance.
Technical Assistance Team (TAT) is directed by ERB to conduct an (initial) Site Assessment (SA)
TAT conducts initial SA: Phase I SA conducted during this activity
Initial SA Report submitted
Following review of initial SA Report, ERB directs TAT to conduct additional SA
Phase II SA sampling performed; a grid system is established and surface soil samples collected
Phase III SA sampling performed; grid system is expanded and surface, subsurface, and creek
bed samples collected
ATSDR approves established action levels for arsenic and chromium (50 mg/kg and 200 mg/kg
respectively)
Phase IV SA sampling performed; surface, subsurface, storage tank, and creek bed samples
collected. Findings indicate contamination is present beyond CWP boundaries. A deed and title
search for adjacent properties commences.
TAT is directed by EPA to conduct a Preliminary Assessment (PA) based on a concern for
surface water pathway and soil exposure
TAT, OSC, and LDEQ meet on-site to discuss disposal options for contaminated soils. LDEQ
provides OSC with requested water well information. Trans-River CO, on-site dismantling the
sawmill, is informed of the OSHA regulations governing an uncontrolled hazardous waste site.
Phase V SA sampling performed on adjacent site properties south of site and along creek bed.
TAT collects data for PA of the site for MRS ranking.
PA report submitted in order to determine CERCLA eligibility and whether further investigations
warranted. The SA had been completed at the time of submittal of the PA. Based on the PA, a
Site Inspection (SI) is recommended to determine candidacy to NPL and to address data gaps.
SI initiated. Samples collected including 37 sediment/soil samples and background samples.
Results of SI prompt an Expanded SI
SA Report submitted
SI Rep[ort Submitted
Action Memorandum was issued for the time-critical removal action completed by EPA to
provide source control.
TAT is tasked to provide technical assistance during removal activities
Time-critical removal action initiated.
Removal activities occur
ESI work plan is submitted
ESI activities occur including collection of 30 soil/sediment samples targeting adjacent properties
Removal Funded Report submitted
ESI Report submitted
EPA issued CH2M HILL a work assignment to perform a Remedial Investigation/
Feasibility Study for the site.
EPA proposed the site for inclusion on the NPL.
Summary Appraisal Report for site submitted
Community Involvement Plan submitted
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Table 1
Chronology of Site Events
Central Wood Preserving Company
East Feliciana parish, Louisiana
May 10,1999
September 2000
September 2000
September 2000
November 2000
April 5, 2001
September 4,
2001
November 2001
May 2002
November 13,
2003
Decembers,
2003
August 25, 2004
September 2004
October 2004
January 2005
March 2005
June 23 2005
June 2005
September 30,
2005
October 2005
October 7-8,
2005
February 2006
May 2006
June 72006
June 26, 2006
September 15,
2006
December 1,
2008
February 18
2009
April 2009
The CWP Superfund Site was listed on the NPL.
Remedial Investigation completed and report submitted
Human Health Risk Assessment completed
Ecological Risk Assessment completed
Feasibility Study completed.
EPA signed the Record of Decision for the site.
US Department of Health and Human Services submits Public Health Assessment for site
Ground water sampling of three of the nine on-site wells
Remedial Design completed.
Remedial Action Work Plan approved by EPA.
RA Site Preparation Activities commenced.
RA Construction Activities and Pre-Final Inspection completed.
Preliminary Closeout Report (PCOR) signed by EPA.
Site Restoration activities commenced.
Ground water sampling of two on-site wells
Remedial Action Report submitted
First Quarterly Ground water Report submitted (for January 2005 sampling)
Ground water sampling of two on-site wells
East Feliciana Police Jury submits Conveyance Notification to Clerk of Court
Ground water sampling of two on-site wells
Surface soil sampling from 0-3 inches to determine any impact from hurricane
Katrina
Additional surface soil sampling conducted to better delineate post-Katrina sampling grids
980 cubic yards soils sent off-site for disposal based on post-Katrina sampling
June 5 2005 Ground water Report submitted
Final Closeout Report signed by EPA
LDEQ submits request to EPA to plug and abandon two on-site ground water
monitoring wells
Site Inspection of the CWP site conducted by EPA, LDEQ, and USAGE
Public notice announcing commencement of the First Five-Year Review place
Advocate
in Baton Rouge
First Five-Year Review submitted
-------
Table 2 Groundwater Analytical Results
Sample ID
MCL
RECAP
EF105
137'
N2EO-GW
65'
S2E5-GW
65'
S5E2-GW
65'
S2E2-GW
10'
S3E2-GW
10'
June 1999
VOCs (ug/L)
1 ,2-Dichloroeth
2-Hexanone
Acetone
Benzene
Carbon Tetracf
Chloroform
Ethylbenzene
5
NA
5
5
100
700
Methyl Ethyl Ketone (2-Butanoi
Styrene
Toluene
Xylenes, total
100
1000
10000
5
100
5
5
100
700
190
100
1000
10000
<1
<2
<32
<1
0.5 J
1 J
NT
13J
NA
2J
NT
2
<2
<2
<1
<1
3
<1
<2
<1
<1
<1
<0.5
<2
<2
<1
<1
2
<1
<2
<1
<1
<1
2
<2
<2
<1
<1
1
<1
<2
<1
<1
<1
<1
11
1.800J
<1
<1
<1
8
<2
1
34
28
<10
<20
84 J
3J
<10
<10
<10
<20
<10
<10
3 J
Metals (ug/L)
Arsenic
Barium
Boron
Calcium
Chromium, Tot
Copper
Lead
Iron
Magnesium
Manganese
Potassium
Selenium
Silicon
Sodium
Strontium
Zinc
10
2000
100
1,300
15
50
10
2000
100
1,300
15
50
1100
35.4
NT
NT
NT
10.8
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
<1.7
35.1 J
NT
NT
32.4
<0.5
<1.5
NT
<1.5
79.5 J
NT
<6.3
NT
NT
NT
96.8 J
<1.8
38.7 J
NT
NT
0.73
0.5
<1.5
NT
<1.5
50.5 J
NT
<4.6
NT
NT
NT
19.2 J
<1.7
46.8 J
NT
NT
<0.5
<0.5
<1.5
NT
<1.5
100 J
NT
<4
NT
NT
NT
86.6 J
68.7
162 J
NT
NT
1.8 J
8.5
<1.5
NT
<1.5
3,270 J
NT
<4.8
NT
NT
NT
99.9 J
7,530
1,160 J
NT
NT
6.8 J
10.5
<1.5
NT
<1.5
1 8,000 J
NT
<3.1
NT
NT
NT
137 J
SVOCs (ug/L)
2,4-Dimethylphenol
2-Methylnapthalene
2-Methylphenol (o-Cresol)
4-Methylphenol (p-Cresol)
Acenapthene
Anthracene
bis(2-ethylhexy
Carbazole
Dibenzofuran
Flouranthene
Flourene
Napthalene
Phenanthrene
Phenol
Pyrene
37
43
6
2.4
150
24
10
18
73
0.62
37
43
6
10
150
24
10
180
180
18
NT
<10
NT
NT
<10
<10
NT
NT
NT
NT
<10
<10
<10
NT
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<26
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
350
280
220
810
440
22 J
<200
310
270
<20
250
1,500
190 J
100 J
<20
420
54 J
640
550
230
<10
110J
66 J
130 J
<20
110J
<200
40 J
220
<20
N2EO-GW
65'
S2E5-GW
65'
S5E2-GW
65'
November 2001
<5
NT
<20
<5
<5
<5
<5
<20
<5
<5
<5
<5
NT
<20
<5
<5
<5
<5
<20
<5
<5
<5
<5
NT
<20
<5
<5
<5
<5
<20
<5
<5
<5
0.54
39.9
<10
4.58
2.1
4.6
<.5
<10
1.45
NT
2.76
NT
4.84
44.3
80
58.6
1.37
29.1
17
4.46
2.41
4.66
0.7
16
1.57
NT
<2
NT
5.16
35.5
12
15.4
0.64
42
<10
7.11
2.46
3.43
1.56
1090
2.48
NT
<2
NT
8.15
41.5
25
30.8
<10
NT
NT
NT
<10
<10
<10
NT
NT
<10
<10
<10
<10
<10
<10
<10
NT
NT
NT
<10
<10
<10
NT
NT
<10
<10
<10
<10
<10
<10
<10
NT
NT
NT
<10
<10
<10
NT
NT
<10
<10
<10
<10
<10
<10
S2E5-GW
65'
MW-1
65'
MW-1 FD
65'
January 2005
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
<1
NT
NT
NT
<1
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
<1
NT
NT
NT
<1
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
<1
NT
NT
NT
<1
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
<2
<0.5
<2
<2
<0.5
<0.5
<2
<2
<2
<0.5
<0.5
<0.5
0.5
<2
0.5
<2
0.6
<2
<2
5.2
0.8
<2
<2
2.3
4.7
3.6
O.5
4.1
<2
2.9
<2.2
O.5
<2.2
<2.2
4.9
O.5
<2.2
<2.2
<2.2
2.1
1.2
O.5
0.5
<2.2
1.2
S2E5-GW
65'
MW-1
65'
MW-1 FD
65'
June 2005
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
<2
NT
NT
NT
7.8
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
<2
NT
NT
NT
6
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
<2
NT
NT
NT
5.4
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
<2
O.5
<2
<2
0.5
O.5
<2
<2
<2
O.5
0.5
O.5
0.5
<2
0.5
<2
O.5
<2
<2
0.5
O.5
<2
<2
<2
O.5
0.5
O.5
0.5
<2
0.5
<2
O.5
<2
<2
0.5
O.5
<2
<2
<2
O.5
0.5
O.5
0.5
<2
0.5
S2E5-GW
65'
S2E5-GW-FD
65'
MW-1
65'
October 2005
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
<40
NT
NT
NT
<1.7
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
<40
NT
NT
NT
<2
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
<40
NT
NT
NT
<1.3
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
12.9
<10
<10
<10
<10
<10
<10
<10
<10
1.) NT = Not Tested for
2.) Blank data blocks = no MCL or RECAP values listed
3.) Bolded numbers indicate a concentration above detection limits
4.) Shaded blocks represent values greater than one or more screening levels
5.) Well EF10 is an old supply well found on-site abandoned during the Rl
-------
TABLE 3 SUMMARY OF GROUND WATER WELL WATER LEVEL
MEASUREMENTS - NOVEMBER 2001
Well ID
Top of
Casing
Elevation
Ground
Water
Elevation
Depth to
Free Product
Depth to
Water
Depth to
Well Bottom
Deep Wells
MWN2EO
MWS2E5
MWS5E2
179.66
176.58
177.26
127.75
127.53
127.65
ND
ND
ND
51.91
49.05
49.61
67.3
68.85
67.89
Intermediate Wells
MWSOE1
MWS2E1
MWS4E2
178.24
178.65
179.94
132.25
132.48
138.26
ND
ND
ND
45.99
46.17
41.68
46.05
47.52
41.7
Shallow Wells
MWS2E2
MWS2E3
MWS3E2
178.97
179.66
179.98
172.03
171.81
172.63
@12.95
ND
13.01
6.94
7.85
7.35
13.02
13.02
13.33
-------
Attachment 1
Documents Reviewed
and
References
-------
Carlock & Associates, 1999. Summary Appraisal Report 15+/1 Acres, Vacant Land Known as "Central
Wood Preserving Property". April 29, 1999.
CH2M HILL, 1999. Community Involvement Plan Central Wood Preserving Company, East
Feliciana Parish, Louisiana.. August 1999
CH2M HILL, 2000a. Remedial Investigation Report. Central Wood Preserving Company, East
Feliciana Parish, Louisiana. September 2000.
CH2M HILL, 2000b. Human Health Risk Assessment Technical Memorandum Central Wood Preserving
Company, East Feliciana Parish, Louisiana. September 2000.
CH2M HILL, 2000c. Ecological Risk Assessment Technical Memorandum Central Wood Preserving
Company, East Feliciana Parish, Louisiana. September 2000.
CH2M HILL, 2000d. Feasibility Study Report. Central Wood Preserving Company, East Feliciana
Parish, Louisiana. November 2000.
CH2M HILL, 2002. Remedial Design. Central Wood Preserving Company, East Feliciana Parish,
Louisiana. May 2002.
CH2M HILL, 2003. Remedial Action Work Plan. Central Wood Preserving Company, East Feliciana
Parish, Louisiana. September 2003.
CH2M HILL, 2004a. Quality Assurance Project Plan, Central Wood Preserving Company, East
Feliciana Parish, Louisiana. March 2004.
CH2M HILL, 2004b. Remedial Action Field Sampling Plan, Central Wood Preserving Company,
East Feliciana Parish, Louisiana. April 2004.
CH2M HILL, 2004c.Construction Quality Assurance Plan, Central Wood Preserving Company, East
Feliciana Parish, Louisiana. May 2004.
CH2M HILL, 2004d. Health and Safety Plan. Central Wood Preserving Company, East Feliciana
Parish, Louisiana. March 2005.
CH2M HILL, 2005a. Remedial Action Report. Central Wood Preserving Company, East Feliciana
Parish, Louisiana. March 2005.
CH2M HILL, 2005b. First Quarter Groundwater Monitoring Results Technical Memorandum Central Wood
Preserving Company, East Feliciana Parish, Louisiana. June 23, 2005.
CH2M HILL, 2006. June 2005 Ground Water Monitoring Event Technical Memorandum Central Wood
Preserving Company, East Feliciana Parish, Louisiana. June 7, 2006.
East Feliciana Parrish Police Jury (EFPPJ), Clerk of Court 2005. Conveyance Notification. 30 September,
2005.
Ecology and Environment, Inc. (E&E), 1995a. Site Assessment Report, March 27, 1995.
Ecology and Environment, Inc. (E&E), 1995b. Removal Funded Report. November 6, 1995.
Ecology and Environment, Inc. (E&E), 1995c. Expanded Site Inspection Report. December 27, 1995.
Louisiana Department of Environmental Quality (LDEQ), 2006. Request to Plug and Abandon Monitoring
Wells, Central Wood Preserving Company: A1 Number 1416. 15 September, 2006.
-------
U. S. Environmental Protection Agency (EPA), 2000. Proposed Plan for Central Wood Preserving
Company. October 2000.
U. S. Environmental Protection Agency (EPA), 2001 a. Record of Decision Summary. Central Wood
Preserving Superfund Site, East Feliciana Parish, Louisiana. LAD008187940. April 2001.
U.S. Environmental Protection Agency (EPA), 2001 b. Comprehensive Five-Year Review Guidance.
OSWER No. 9355.7-03B-P. June 2001.
U. S. Environmental Protection Agency (EPA), 2003. Close Out Procedures for National Priorities
List Sites. January 2003.
U.S. Environmental Protection Agency (EPA), 2003. Draft Guidance on Surface Soil Cleanup at
Hazardous Waste Sites: Implementing Cleanup Levels, Office of Emergency and Remedial
Response, 2003.
U. S. Environmental Protection Agency (EPA), 2006. Proposed Plan for Central Wood Preserving
Company. October 2000.
U. S. Department of Health and Human Services 2001. Final Close Out Report Central Wood Preserving
Company, East Feliciana Parish, Louisiana. June 26, 2006.
-------
Attachment 2
Interview Record Forms
-------
Site Name: Central Wood Superfund Site
Subject: Five- Year Review - 1st
Type: n Telephone n Visit X Other
Location of Visit: electronic mail
EPA ID No.: LAD008187940
Time: 3:45 pm
Date: 1-30-09
n Incoming n Outgoing
Contact Made By:
Name: Laura Stankosky
Title: RPM
Organization: U.S. EPA
Individual Contacted:
Name: Wanda Ballon Title: LDEQ Project Manager
Telephone No: 225-219-3223
Fax No: 225-219-3239
E-Mail Address: wanda.ballou@la.gov
Organization: LDEQ
Street Address: 602 N. Fifth Street
City, State, Zip: Baton Rouge, LA 70884
Summary Of Conversation
1. What is your overall impression of the project? (general sentiment)
The site is currently being used as a staging area for hurricane debris as well as a wood waste debris storage site.
As I understand it, the site has been granted approval to operate as a temporary storm debris management unit.
2. What effects have post-construction site activities in the last five years had on the surrounding community?
The site was remediated to standards for residential reuse.
3. Are you aware of any community concerns regarding the site or its operation and administration? If so, please
give details.
About 3 years ago, we received several complaints from the citizens of loud noises due to trucks dumping wood
waste debris and open burning. Our investigation of the site revealed several piles of wood waste along with a
couple of piles of creosote treated lumber as well as painted lumber from construction demolition of wood-type
structures. We also found a few small piles of trash. There were no signs of open burning.
However, an inspection dated January 27, 2009, revealed that about a third of wood waste debris had been
removed.
4. Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or emergency
responses from local authorities? If so, please give details.
No.
Page 1 of 3
-------
5. Do you feel well informed about the site's activities and progress?
Yes.
6. Have there been routine communications or activities (site visits, inspections, reporting activities, etc.) conducted by
your office regarding the site? If so, please give purpose and results.
Yes. The site has been inspected on a semi-annual basis for the purpose meeting our internal requirement of inspecting the
site semi-annually.
7. Have there been any complaints, violations, or other incidents related to the site requiring a response by your office? If
so, please give details of the events and results of the responses.
See numbers.
8. Is the remedy functioning as expected? How well is the remedy performing?
The remedy appears to be functioning as expected. The cover remains intact. There is no evidence of erosion.
9. What does the monitoring data show? Are there any trends that show contaminant levels are decreasing?
N/A
10. Is there a continuous on-site O&M presence? If so, please describe staff and activities. If there is not a continuous on-
site presence, describe staff and frequency of site inspections and activities.
No.
11. Have there been any significant changes in the O&M requirements, maintenance schedules, or sampling routines since
start-up or in the last five years? If so, do they affect the protectiveness or effectiveness of the remedy? Please describe
changes and impacts.
The remediation activity for this has been completed.
12. Have there been unexpected O&M difficulties or costs at the site since start-up or in the last five years? If so, please
give details.
N/A
Page 2 of3
-------
13. Have there been opportunities to optimize O&M, or sampling efforts? Please describe changes and resultant or desired
cost savings or improved efficiency.
N/A
14. Do you have any comments, suggestions, or recommendations regarding the site's management or operation?
No, not at this time.
Page 3 of3
-------
Site Name: Central Wood
Subject: Five- Year Review
Type: n Telephone
Location of Visit:
Superfund Site
-1st
X Visit n Other
EPA ID No.: LAD008187940
Time: 1:15 pm Date: 12-1-08
n Incoming n Outgoing
INTERVIEW RECORD
Contact Made By:
Name: Laura Stankosky
Title: RPM
Organization: U.S. EPA
Individual Contacted:
Name: Greg Beauchamp
Title: Director of Public Works
Telephone No: (225) 683-3104
Fax No:
E-Mail Address:
Organization: East Feliciana
Parish
Street Address: 11046 Parish Banks Rd
City, State, Zip: Clinton, LA 70722
Summary Of Conversation
1. What is your overall impression of the project? (general sentiment)
Site is currently owned and used by East Feliciana Parish.
2. What effects have site operations had on the surrounding community?
Site was cleaned up and is currently used to hold tree debris from Hurricane Katrina damage.
3. Are you aware of any community concerns regarding the site or its operation and administration? If so, please
give details.
No concerns. The community wants to use the Site as a park.
4. Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or emergency
responses from local authorities? If so, please give details.
There have been minor instances of illegal dumping when the gate was left open during brush and tree removal
after the hurricane.
Page 1 of 2
-------
5. Do you feel well informed about the site's activities and progress?
As one of the parish managers I do feel well informed of site activity.
6. Do you have any comments, suggestions, or recommendations regarding the site's management or operation?
The parish manages the Site. We are currently trying to determine what to do with the tree debris to get it off of
the Site. The Site is mowed twice during the Spring.
Page 2 of 2
-------
Attachment 3
Site Inspection Checklist
-------
Five-Year Review Site Inspection Checklist
I. SITE INFORMATION
Site name: Central Wood Preserving Superfund Site
Location and Region: East Feliciana Parish
Agency, office, or company leading the Five- Year
Review: USAGE
Date of inspection: December 1, 2008
EPA ID: LAD008187940
Weather/temperature: clear, mostly sunny, 65 ° F
Remedy Includes: (Check all that apply)
Landfill cover/containment Monitored natural attenuation
Access controls Ground water containment (Cap)
S Institutional controls Vertical barrier walls
Ground water pump and treatment
Surface water collection
Other:
Attachments: Inspection team roster attached Site map attached
Inspection Team: David Jones and Jeanne Carroll of USAGE; Laura Stankosky of EPA; Wanda Ballon ofLDEQ
II. INTERVIEWS (Check all that apply)
1. O&M site manager
Name: Wanda Ballon Title: LDEQ Project Manager Manager Date: 1/30/09
Interviewed at site at office S by email
Problems, suggestions: see interview form
2. DIRECTOR OF PUBLIC WORKS
Name: Gary Beauchamp Title: Director of Public Works Date: 12/1/08
Interviewed S at site at office by phone
Problems, suggestions: see interview form
-------
3. Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response
office, police department, office of public health or environmental health, zoning office, recorder of
deeds, or other city and county offices, etc.) Fill in all that apply.
Agency Louisiana Department of Environmental Quality
Contact
Name: Wanda Ballou Title: LDEQ Project Manager DatePhone no.: 225-219-3223
Problems; suggestions:
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; Report attached
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; Report attached
Agency
Contact
Name Title Date Phone no.
Problems; suggestions; Report attached
4. Other interviews (optional) Report attached.
Interview record forms are provided in Attachment 2 to the Five-Year Review.
-------
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
III. ON-SITE DOCUMENTS &
RECORDS VERIFIED (Check all that apply)
O&M Documents
O&M manual Readily available Up to date S N/A
As-built drawings Readily available Up to date S N/A
O&M logs Readily available »Up to date S N/A
Post-RA data reviewed. Ground water monitoring has been discontinued at the request ofLDEQ and
because no site constituents found in ground water for several rounds of monitoring.
Site-Specific Health and Safety Plan
Contingency plan/emergency response
Remarks
O&M and OSHA Training Records
Remarks
Permits and Service Agreements
Air discharge permit
Effluent discharge
Waste disposal, POTW
Other permits
Remarks
Readily available
plan Readily available
Readily available
Readily available
Readily available
Readily available
Readily available
Up to date
Up to date
Up to date
Up to date
Up to date
Up to date
Up to date
^N/A
^N/A
^N/A
^N/A
^N/A
^N/A
^N/A
Gas Generation Records Readily available Up to date S N/A
Remarks
Settlement Monument Records
Remarks
Ground water Monitoring Records
Remarks: Records/reports available.
Leachate Extraction Records
Remarks
Discharge Compliance Records
Air
Water (effluent)
Remarks
Readily available
S Readily available ^
'Readily available
Readily available
Readily available
Up to date
Up to date
Up to date
Up to date
Up to date
^N/A
N/A
^N/A
^N/A
^N/A
Daily Access/Security Logs Readily available Up to date ^ N/A
Remarks: There is a six foot high chain link fence, with locked gates, along highway 959 for both the
North and South properties; this restricts access to vehicular traffic. Foot access is readily available to
both site portions as fence lines for the remainder of the site (not adjacent to highway 959) is either non-
existent or simple two- or three strand barb wire.
IV. O&M COSTS
-------
1.
2.
3.
O&M Organization
S State in-house Contractor for State
PRP in-house Contractor for PRP
Federal Facility in-house Contractor for Federal Facility
Remarks: Ground water monitoring wells have been plugged and abandoned. Mowing and grubbing
not occurring as wood debris piles cover a large portion of the site.
O&M Cost Records
Readily available Up to date
Funding mechanism/agreement in place (entirely funded by PRP)
/ NA
Unanticipated or Unusually High O&M Costs During Review Period
Describe costs and reasons: N/A
V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A
A.
1.
B.
1.
Fencing
Fencing damaged Location shown on site map S Gates secured N/A
Remarks. There is a six foot high chain link fence, with locked gates, along SH 959 for both the North
and South properties; this restricts access to vehicular traffic. Foot access is readily available to both
site portions as fence lines for the remainder of the site (not adjacent to highway 959) is either non-
existent or simple two- or three strand barb wire.
Other Access Restrictions
Signs and other security measures Location shown on site map N/A
Remarks: There are no signs of any type either identifying the site as a Super fund site or restriction
access.
-------
C. Institutional Controls (ICs)
1. Implementation and enforcement
Site conditions imply ICs not properly implemented Yes S No N/A
Site conditions imply ICs not being fully enforced Yes S No N/A
Type of monitoring: Conveyance Notice
Frequency:
Responsible party/agency: East Feliciana Parish owns site property
Contact:
Name: East Feliciana Parish Police Jury Title: N/A Date 9/30/2005 Phone no. (225) 683-5145
Reporting is up-to-date S Yes No N/A
Reports are verified by the lead agency Yes No N/A
Specific requirements in deed or decision documents have been met ^ Yes No N/A
Violations have been reported Yes No N/A
Remarks: The ROD proposed that easements, covenants running with the land, and/or deed notices as
appropriate or as allowed by law will be implemented to prevent exposure to contaminants remaining on-site on
the North Property below 5 feet bgs (this area includes the drainage pathway located outside the legal
boundaries of the property that was originally owned by CWP [now East Feliciana Parish]). ICs are in place.
1. Adequacy S ICs are adequate ICs are inadequate N/A
Remarks
D. General
1. Vandalism/trespassing Location shown on site map ^ No vandalism evident
2. Land use changes on site N/A
Remarks: The site was originally intended to be used as a park, but is currently being used to stage
woody debris from Hurricane Katrina forest damage.
3. Land use changes off site ^N/A
Remarks
VI. GENERAL SITE CONDITIONS
A. Roads S Applicable N/A
1. Roads damaged Location shown on site map ^ Roads adequate N/A
Remarks
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B. Other Site Conditions
Remarks
VII. ENGINEERED COVERS Applicable S N/A
A. Surface
1. Settlement (Low spots) Location shown on site map Settlement not evident
Area! extent Depth
Remarks
2. Cracks Location shown on site map Cracking not evident
Lengths Widths Depths
Remarks
3. Erosion Location shown on site map Erosion not evident
Area! extent Depth
Remarks
4. Holes Location shown on site map Holes not evident
Area! extent Depth
Remarks
5. Vegetative Cover Grass Cover properly established No signs of stress
Trees/Shrubs (indicate size and locations on a diagram)
Remarks
6. Alternative Cover (armored rock, concrete, etc.) N/A
Remarks
7. Bulges Location shown on site map S Bulges not evident
Area! extent Height
Remarks
8. Wet Areas/Water Damage Wet areas/water damage not evident
Wet areas Location shown on site map Area! extent
Ponding Location shown on site map Area! extent
Seeps Location shown on site map Area! extent
Soft subgrade Location shown on site map Area! extent
Remarks
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9. Slope Instability 'Slides Location shown on site map No evidence of slope instability
Area! extent
Remarks
B. Benches Applicable S N/A
Remarks
1. Flows Bypass Bench Location shown on site map okay
Remarks
2. Bench Breached Location shown on site map okay
Remarks
3. Bench Overtopped Location shown on site map okay
Remarks
C. Letdown Channels Applicable S N/A
Remarks
1. Settlement Location shown on site map No evidence of settlement
Area! extent Depth
Remarks
2. Material Degradation Location shown on site map No evidence of degradation
Material type Area! extent
Remarks
3. Erosion Evidence of Erosion No evidence of erosion
Area! extent Depth
Remarks
4. Undercutting Evidence of undercutting No evidence of undercutting
Remarks
5. Obstructions Type No obstructions
Location shown on site map Area! extent
Size
Remarks
6. Excessive Vegetative Growth Type
No evidence of excessive growth
Vegetation in channels does not obstruct flow
Location shown on site map Area! extent
Remarks
D. Cover Penetrations Applicable S N/A
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1.
2.
3.
4.
5.
Gas Vents Active Passive
Properly secured/locked Functioning Routinely sampled Good
Evidence of leakage at penetration Needs Maintenance
N/A
Remarks
condition
Gas Monitoring Probes
Properly secured/locked* Functioning Routinely sampled Good condition
Evidence of leakage at penetration Needs Maintenance N/A
Remarks
Monitoring Wells (within surface area of landfill)
Properly secured/locked Functioning Routinely sampled Good
Evidence of leakage at penetration Needs Maintenance N/A
Remarks
Leachate Extraction Wells (dual purpose: same as gas vent wells)
Properly secured/locked Functioning Routinely sampled
Evidence of leakage at penetration Needs Maintenance N/A
Remarks
Settlement Monuments Located Routinely surveyed
Remarks
condition
Good condition
N/A
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E. Gas Collection and Treatment
Applicable S N/A
1. Gas Treatment Facilities
Flaring Thermal destruction Collection for reuse
Good condition Needs Maintenance
Remarks
2. Gas Collection Wells, Manifolds and Piping
Good condition Needs Maintenance
Remarks
3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
Good condition Needs Maintenance N/A
Remarks
F. Cover Drainage Layer
Applicable S N/A
1. Outlet Pipes Inspected
Remarks
Functioning N/A
2. Outlet Rock Inspected
Remarks
Functioning
N/A
G. Detention/Sedimentation Ponds
Applicable S N/A
1. Siltation Area! extent_
Siltation not evident
Remarks
Depth_
N/A
2. Erosion Area! extent_
Erosion not evident
Remarks
Depth
Outlet Works
Remarks
Functioning N/A
Dam
Remarks
Functioning N/A
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H. Retaining Walls Applicable S N/A
1. Deformations Location shown on site map Deformation not evident
Horizontal displacement Vertical displacement
Rotational displacement
Remarks
2. Degradation Location shown on site map Degradation not evident
Remarks _
I. Perimeter Ditches/Off-Site Discharge Applicable S N/A
1. Siltation Location shown on site map Siltation not evident
Area! extent _ Depth _
Remarks
2. Vegetative Growth Location shown on site map N/A
S Vegetation does not impede flow
Area! extent Type
Remarks:
3. Erosion Location shown on site map S Erosion not evident
Area! extent Depth
Remarks
4. Discharge Structure Functioning N/A
Remarks
VIII. VERTICAL BARRIER WALLS 'Applicable S N/A
1. Settlement Location shown on site map Settlement not evident
Area! extent Depth
Remarks
2. Performance Monitoring Type of monitoring DNAPL compliance
Performance not monitored
Frequency Annual Evidence of breaching
Head differential
Remarks
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A.
1.
2.
3.
B.
1.
2.
3.
IX. GROUND WATER/SURFACE WATER REMEDIES Applicable
Ground water Extraction Wells, Pumps, and Pipelines Applicable S
^N/A
N/A
Pumps, Wellhead Plumbing, and Electrical
Good condition All required wells properly operating Needs Maintenance N/A
Remarks
Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances
Good condition Needs Maintenance
Remarks
Spare Parts and Equipment
Readily available Good condition Requires upgrade Needs to
Remarks
Surface Water Collection Structures, Pumps, and Pipelines Applicable S
Collection Structures, Pumps, and Electrical
Good condition Needs Maintenance
Remarks
be provided
N/A
Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances
Good condition Needs Maintenance
Remarks
Spare Parts and Equipment
Readily available Good condition Requires upgrade Needs to
Remarks:
be provided
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C. Treatment System Applicable S N/A
1. Treatment Train (Check components that apply)
Metals removal Oil/water separation Bioremediation
Air stripping Carbon adsorbers
Filters
Additive (e.g., chelation agent, flocculent)
Others
Good condition Needs Maintenance
Sampling ports properly marked and functional
Sampling/maintenance log displayed and up to date
Equipment properly identified
Remarks:
2. Electrical Enclosures and Panels (properly rated and functional)
N/A Good condition Needs Maintenance
Remarks
3. Tanks, Vaults, Storage Vessels
N/A Good condition Proper secondary containment Needs Maintenance
Remarks
4. Discharge Structure and Appurtenances
N/A Good condition Needs Maintenance
Remarks
5. Treatment Building(s)
N/A Good condition (esp. roof and doorways) Needs repair
Chemicals and equipment properly stored
Remarks
6. Monitoring Wells (pump and treatment remedy)
Properly secured/locked Functioning Routinely sampled Good condition
All required wells located Needs Maintenance N/A
Remarks
D. Monitoring Data Applicable S N/A - ground water monitoring wells plugged and abandoned
1. Monitoring Data
Is routinely submitted on time Is of acceptable quality
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F. Monitored Natural Attenuation
1. Monitoring Wells (natural attenuation remedy)
Properly secured/locked Functioning Routinely sampled Good condition
All required wells located Needs Maintenance N/A
Remarks
X. OTHER REMEDIES
If there are remedies applied at the site which are not covered above, attach an inspection sheet describing
the physical nature and condition of any facility associated with the remedy. An example would be soil
vapor extraction.
XL OVERALL OBSERVATIONS
A. Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume,
minimize infiltration and gas emission, etc.).
The initial part of the remedy, for site soils/sediments, has been completed and involved excavation,
treatment, and disposal of the soils off-site. Site excavations that were backfilled and revegetated are in
good shape. No "dead zones " were evident in those areas that could be inspected, however, a significant
portion of the site is covered with hurricane Katrina debris and could not be confirmed as adequate
regarding vegetative cover. Per the ROD, the ongoing remedy was to perform ground water monitoring
and to maintain ICs, however, ground water monitoring was ceased with the abandonment of the on-site
wells as requested by LDEQ. ICs (easements and//or land use agreements within the deed) appear to be
current.
B. Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protectiveness of the remedy.
Much of the site was covered with woody debris at the time of the Five-Year Review Site Inspection.
C. Early Indicators of Potential Remedy Problems
Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised
in the future.
None
3.1.1. D. Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
None
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Attachment 4
Site Inspection Photographs
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ROBERT L. ANDERSON
I NOW OR FORMERL Y)
180
THE J.B. HERROD TRUST
FINAL PROPERTY BOUNDARY AS ACCORDING TO THE
BOUNDARY SURVEY PERFORMED BY SJB GROUP,
INC.
\ SUCCESSION OF
\ BOB R. JONES, ef ol
SOUTH
PROPERTY
APPROXIMATE LOCATIONS OF
CLEARED VEGETATION BURN PIT
BACKFILLED WITH NATIVE SOIL!
Photograph
Location
Site Plan
ALINE M. HERROD ESTATE
-------
Central Wood Preserving Company Superfund Site
Photo 1: South Property - gate entrance access off of SH 959
Photo 2: South Property - gate/entrance access off of SH 959
-------
Central Wood Preserving Company Superfund Site
Photo 3: South Property - chain link fence along SH959
Photo 4: South Property - looking west from gravel lot
-------
Central Wood Preserving Company Superfund Site
Photo 5: South Property - looking west from gravel lot
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Photo 6: South Property - silt fencing left southeast portion
-------
Central Wood Preserving Company Superfund Site
Photo 1: South Property - woody debris on northern portion
Photo 8: South Property - sawmill machinery on small cement pad
-------
Central Wood Preserving Company Superfund Site
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Photo 9: South Property - sawmill machinery on southernmost cement pad
Photo 10: South Property - sawmill machinery on southernmost cement pad
-------
Central Wood Preserving Company Superfund Site
Photo 11: South Property - sawmill machinery on southernmost cement pad
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Photo 12: South Property - southeast area
-------
Central Wood Preserving Company Superfund Site
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-------
Central Wood Preserving Company Superfund Site
Photo 15: North Property - gate/entrance access off of SH 959
Photo 16: North Property - chain link fence along SH 959
-------
Central Wood Preserving Company Superfund Site
Photo 17: North Property - looking north at woody debris piles from gravel lot
Photo 18: North Property - debris pile of treated wood (not originating from site)
-------
Central Wood Preserving Company Superfund Site
Photo 19: North Property - woody debris pile on northwest portion.
Evidence of debris burning was seen in area of this photo
Photo 20: North Property - building debris on northwest portion.
Possible asbestos containing material (floor tiles) in this debris pile.
-------
Central Wood Preserving Company Superfund Site
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Photo 21: North Property - fence line along north property line
Photo 22: North Property - woody debris in central portion of property
Showing some household debris mixed in
-------
Central Wood Preserving Company Superfund Site
Photo 23: North Property - open field and fence line of northeast property edge
Photo 24: North Property - open field and site planted trees of northeast portion
-------
Central Wood Preserving Company Superfund Site
Photo 25: North Property - opening in chain link fence
Adjacent to drainage ditch by SH959
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Attachment 5
Notice to the Public Regarding the
Five-Year Review
-------
Central Wood Preserving Company, Superfund Site
PUBLIC NOTICE
U.S. EPA Region 6 Begins First Five-Year Review of Site Remedy
February 2009
The U.S. Environmental Protection Agency Region 6 (EPA) has begun the First
Five-Year Review of the remedy for the Central Wood Preserving Company,
Superfund Site located in East Feliciana Parish, Louisiana. The site was a wood
treating facility whose operations resulted in contamination of soil by creosote and
other wood preserving compounds. The remedy, which EPA selected in 2004, consisted of four
major components: thermal desorption, off-site destabilization and disposal, demolition of
buildings/debris on-site, and institutional controls/ground water monitoring. The Review will
determine whether the remedy at the site remains protective of public health and the environment
Once completed, the results of the Five-Year Review will be made available to the public at the
following Information Repository:
Audubon Library
P.O. Box 8389
Clinton, Louisiana 70722
Information about the Central Wood Preserving Company, Superfund Site is also available on
the Internet at http://www.epa.gov/region6/6sf/6sf.htm
For more information about the Site, contact:
Ms. Laura Stankosky Ms. Wanda Ballou
Remedial Project Manager (Mail Code 6SF-RL) Louisiana Department of Environmental Quality
U.S. Environmental Protection Agency, Region 6 Remediation Services Division
1445 Ross Avenue, Suite 1200 P.O. Box 4314
DaUas, Texas 75202 Baton Rouge, LA 70821
Phone: (214) 665-752 or toU free (800) 533-3508 Phone: (225) 219-3223
E-mail Stankosky.Laura@epamail.epa.gov E-mail: wanda.ballou@la.gov
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CAPITAL CITY PRESS
Publisher of
THE ADVOCATE
PROOF OF PUBLICATION
The hereto attached notice was
published in THE ADVOCATE,
daily newspaper of general circulation
published in Baton Rouge, Louisiana,
and the official Journal
of the State of Louisiana,
the City of Baton Rouge,
and the Parish of East Baton Rouge,
in the following issues:
02/12/09
Susan A.Bush, Public Notices Clerk
»
Sworn and subscribed before me by the ,~
person whose signature appears above:
February 12. 2009
Pegeen (jjJgley, Notary «uhlib, #$6565
--- My Commission Expires: Indefinite
Baton Rouge, Louisiana
r.Ui
US ARMY COE - TULSA 4039937
DAVID JONES SWT
1645 S101ST EAST AVE
TULSA OK 74128
-------
Central Wood Preserving Company, Superfund Stte
PUBLIC NOTICE
U.S. EPA Region Ct Begins First Fhre-Year
Review of Sn% Remedy
January 200O :;
The U& Environmental Protection Agency Region 6 (EPA) has begun the First Ffve-Yoar FteylBWr of ft? rem-
edy for the Central Wood Preserving Company. Superfund Site located In East Feilcmna Parish, tolilslonn.
The site was a wood treating facility whose operations resulted In contamination of soil by creosote and other
wood preserving compounds. The remedy. whtoh; EPA selected in 2004, consisted of four major romppnerfeK
mem«].dBSp
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