FIFTH FIVE-YEAR REVIEW REPORT FOR
D.L. MUD, INC. SI PERU ND SITE
VERMILION PARISH, LOUISIANA

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FIFTH FIVE-YEAR REVIEW REPORT

D.L. MUD, INC. SUPERFUND SITE
VERMILION PARISH, LOUISIANA
EPA ID#: LAD981058019

This memorandum documents the U.S. Environmental Protection Agency's performance, determinations and
approval of the D.L. Mud, Inc. Superfund Site (Site) Fifth Five-year Review under Section 121(c) of the
Comprehensive Environmental Response. Compensation, and Liability Act, 42 U.S. Code Section 9621(c), as
provided in the attached five-year review report.

Summary of the Fifth Five-Year Review Report

The remedy included removal actions, excavation, and backfilling to grade with clean soil, enhancing site
security, and groundwater monitoring. The review of site monitoring data and the results of the site inspection
demonstrate that the soil remedial action continues to operate and function as designed. Cleanup goals and
performance standards for the soil remedy were achieved as documented in the April 1999 closeout report. The
Site achieved the construction completion milestone in June 1999. Operation and maintenance (O&M) activities
are ongoing; groundwater monitoring and site inspections are conducted annually. Institutional controls are in
place that restrict land use and prohibit drilling and well installation on the site property. The Site achieved the
site wide ready for anticipated use milestone in September 2007. The Site is not in reuse. Nearby land uses include
agricultural and residential areas.

The protectiveness of the remedy is anticipated to not be affected by extreme weather climate change. See Section
V, Question C for additional information.

The Environmental Justice (EJ) Screen analysis for the Site in 2023 (Appendix J) did not find any EJ concerns in
the surrounding community. Only one of the socioeconomic indicators is above the 80th percentile (less than a
high school education) at the national and state average level. Public input on the FYR was solicited through a
public notice in the Abbeville Meridional new spaper, on 12/21/2022. FYR interview s are included in Section IV.
Community Notification. Involvement & Site Interviews.

Actions Needed

The follow ing actions must be taken for the remedy to be protective in the long term:

•	Evaluate and confirm if arsenic, chromium, and manganese are Site-related or representative of
background and determine if ongoing groundwater monitoring is warranted for these inorganic
compounds. Update the Site O&M Plan as necessary.

•	Determine the status of two former domestic water wells and if they have been properly abandoned. If
not. abandon the wells and provide the documentation in the Louisiana Department of Natural Resources
database.

Determination

I have determined that the selected remedy for the D.L. Mud, Inc. Superfund Site is currently protective of human
health and the environment in the short term. This five-year review report specifies the actions that need to be
taken for the remedy to remain protective over the long term,
s s gk ypmnK ¦	Dicjits I!y sicjnGcl by LISA PRICE

LISA PRICE Dat& 2023 07.24 09:52:27

-05'00'

Lisa Price

Acting Director. Superfund and Emergency Management Division
U.S. Environmental Protection Agency. Region 6

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ISSUES/RECOMMENDATIONS

FIFTH FIVE-YEAR REVIEW REPORT

D.L. MUD, INC. SUPERFUND SITE
VERMILION PARISH, LOUISIANA
EPA ID#: LAD981058019

Issues and Recommendations Identified in the FYR:

OU(s): 1

Issue Category: Monitoring



Issue: Arsenic, chromium, and manganese consistently exceed MCLs and secondary
MCLs in groundwater. However, the PRPs attribute the presence of these inorganic
compounds to background conditions unrelated to the Site.



Recommendation: Evaluate and confirm if arsenic, chromium, and manganese are
site-related or representative of background and determine if ongoing groundwater
monitoring is warranted for these inorganic compounds. Update the O&M plan as
required.

Affect

Current
Protectiveness

Affect Future
Protectiveness

Party
Responsible

Oversight
Party/Support
Agency

Milestone Date

No

Yes

PRP

EPA/State

9/1/2025

OU(s): 1

Issue Category: Remedy Performance



Issue: The PRP Group noted in the 2015 Fourth Quarter Progress report and all
subsequent annual reports, that two domestic water wells with the same location
(5627Z and 8615Z) are on site, based on the LDNR groundwater database review. The
domestic water wells have not been observed during site visits and were reportedly
installed in April 1986 and November 1993, respectively, at the same locations,
including monitoring well (MW) 7085Z. MW 7085Z is reported as being plugged and
abandoned (no date provided). Based on this information, it is unclear if the two
domestic wells have also been plugged and abandoned but the status is not yet reflected
in the LDNR database.



Recommendation: Determine the status of the two former domestic water wells and if
they have been properly plugged and abandoned. If not. abandon the wells and provide
the necessary documentation in the LDNR database.

Affect
Current
Protectiveness

Affect Future
Protectiveness

Party
Responsible

Oversight
Party/Support
Agency

Milestone Date

No

Yes

PRP

EPA/State

9/1/2025

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Table of Contents

LIST OF ABBREVIATIONS AND ACRONYMS	6

I.	INTRODUCTION	7

Site Background	7

FIVE-YEAR REVIEW SUMMARY FORM	8

II.	RESPONSE ACTION SUMMARY	10

Basis for Taking Action	10

Response Actions	10

Status of Implementation	11

Institutional Control (IC) Review	 12

Systems Operations/Operation and Maintenance (O&M)	 14

III.	PROGRESS SINCE THE PREVIOUS REVIEW	15

IV.	FIVE-YEAR REVIEW PROCESS	15

Community Notification. Community Involvement and Site Interviews	15

Data Review	 16

Site Inspection	21

V.	TECHNICAL ASSESSMENT	21

QUESTION A: Is the remedy functioning as intended by the decision documents'.'	21

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the

remedy selection still valid'.'	22

QUESTION C: Has any other information come to light that could call into question the protectiveness of the
remedy'.'	22

VI.	ISSUES/RECOMMENDATIONS	20

OTHER FINDINGS	23

VII.	PROTECTIVENESS STATEMENT	24

VIII.	NEXT REVIEW	24

APPENDIX A - REFERENCE LIST	A-l

APPENDIX B - SITE CHRONOLOGY	B-l

APPENDIX C - PRESS NOTICE	C-l

APPENDIX D - SITE INSPECTION CHECKLIST	D-l

APPENDIX E - SITE INSPECTION PHOTOS	E-l

APPENDIX F - DETAILED DATA ANALYSIS	F-l

APPENDIX G - APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS REVIEW	G-l

APPENDIX H - SCREENING-LEVEL RISK REVIEW	H-l

APPENDIX I - INTERVIEW FORMS	1-1

APPENDIX J - EJ SCREEN REPORT	J-l

Tables

Table 1: 1994 ROD Soil and Subsurface Soil Cleanup Goals	 11

Table 2: Summary of Planned and/or Implemented Institutional Controls (ICs)	 12

Table 3: Annual O&M Costs	14

Table 4: Protectiveness Determinations/Statements from the 2018 FYR Report	15

Table 5: Status of Recommendations from the 2018 FYR Report	15

Table 6: Groundwater Monitoring Results for Barium. 2017 to 2022	 18

Table 7: Groundw ater Monitoring Results for Arsenic. 2017 to 2022	 19

Table 8: Groundw ater Monitoring Results for Chromium, 2017 to 2022	 19

Table 9: Groundw ater Monitoring Results for Manganese, 2017 to 2022	20

Table B-l: Site Chronology	B-l

Table F-l: Historical Groundwater Data. 2008 to 2021 	F-1

Table F-2: Summary of Mann-Kendall Trend Analysis	F-2

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Tabic F-3: Water Well Search Results. 2022	F-3

Table G-l: Groundwater ARARs Evaluation	G-l

Table H-l: Screening-Level Risk Evaluation of the Subsurface Soil Cleanup Goals	H-l

Figures

Figure 1: Site Vicinity Map	9

Figure 2: Institutional Control Map	13

Figure 3: Detailed Site Map	17

Figure F-l: Potentiometric Surface of the Upper Alluvium. 2016	F-4

Figure F-2: Potentiometric Surface of the Alluvium. 2018	F-5

Figure F-3: Water Well Survey, 2022	F-6

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LIST OF ABBREVIATIONS AND ACRONYMS

ARAR

Applicable or Relevant and Appropriate Requirement

CERCLA

Comprehensive Environmental Response. Compensation, and Liability Act

CIC

Community Involvement Coordinator

coc

Contaminant of Concern

Dow

The Dow Chemical Company

DSI

Dowell Schlumberger. Incorporated

EPA

United States Environmental Protection Agency

FS

Feasibility Study

FYR

Five-Year Review

GCVS

Gulf Coast Vacuum Services

HI

Hazard Index

HQ

Hazard Quotient

IC

Institutional Control

LDEQ

Louisiana Department of Environmental Quality

LDNR

Louisiana Department of Natural Resources

MCL

Maximum Contaminant Level

mg/kg

Milligrams per kilogram

mg/L

Milligrams per Liter

NCP

National Oil and Hazardous Substances Pollution Contingency Plan

NPL

National Priorities List

O&M

Operation and Maintenance

OU

Operable Unit

PRP

Potentially Responsible Party

RI

Remedial Investigation

RAO

Remedial Action Objective

ROD

Record of Decision

RSL

Regional Screening Level

STC

Schlumberger Technology Company

UU/UE

Unlimited Use and Unrestricted Exposure

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I. INTRODUCTION

The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy to
determine if the remedy is and will continue to be protective of human health and the environment. The methods,
findings and conclusions of reviews are documented in FYR reports such as this one. In addition. FYR reports
identify issues found during the review, if any, and document recommendations to address them.

The U.S. Environmental Protection Agency (EPA) is preparing this FYR pursuant to the Comprehensive
Environmental Response. Compensation, and Liability Act (CERCLA) Section 121. consistent with the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40 CFR Section 300.430(f)(4)(ii)) and
considering EPA policy.

This is the fifth FYR for the D.L. Mud, Inc. Superfund Site (the Site). The triggering action for this statutory
review is the completion date of the previous FYR. The FYR has been prepared because hazardous substances,
pollutants or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure

(UU/UE).

The Site consists of one operable unit (OU), which is addressed in this FYR. OU1 addresses the Site's final
source action.

EPA Remedial Project Manager (RPM) Michael Torres led the FYR. Participants included Destin Hooks for the
Louisiana Department of Environmental Quality, and Johnny Zimmerman-Ward and Claire Marcussen from EPA
FYR contractor Skeo. The potentially responsible parties (PRPs). the Dow Chemical Company (Dow) and
Schlumberger Technology. Corporation (STC) (formerly Dowel 1 Schlumberger Incorporated |DSI|). were
notified of the initiation of the FYR. The review process began on 10/11/2022.

Site Background

The 12.8-acre Site is about 2.5 miles southwest of Abbeville. Louisiana. The Site operated as a barium sul fate-
based drilling mud blending operation from 1969 until 1986 when the former site owner. D.L. Mud, went out of
business. During site operations, numerous large tanks and surface impoundments were used to mix and store raw
materials and waste. Site activities and waste disposal practices contaminated soil with hazardous chemicals.

The Gulf Coast Vacuum Services Superfund Site (GCVS) bounds the D.L. Mud, Inc. site on the north with
agricultural land (livestock grazing, crawfish farming, and crop production) to the east, south and west (Figure 1).
Residences are located near the Site on Parish Road P-7-31 (also know n as Junius Road) and Louisiana Highw ay
335, about half a mile east of the Site. A portion of the Pioneer Village subdivision also borders the southern tip
of the Site. The Site is currently owned by the Vermilion Parish Police Jurisdiction. The Site is covered by forest
and not currently in use.

The Site is generally flat and located in the low-lying flatland of the Atlantic Gulf Coastal Plain. Levees from a
former irrigation canal network bound the eastern and southern portions of the Site. An abandoned irrigation canal
transects the property from east to west. Surface runoff from the northern portion of the Site collects in the
unnamed drainage ditch that transects the GCVS site and proceeds to the northeast. The ditch merges with Coulee
Galleque and eventually forms a confluence with Coulee Kenny, which flows southeast to the Vermilion River
near the town of Perry. The southern portion of the Site drains to a highway ditch south of the Site and
ultimately flows through the Noel Canal to the Vermilion River near the town of Perry.

The Chicot Aquifer System is the principal source of groundwater supply within the Abbeville area. The shallow
portion, or Alluvial unit (betw een 30 feet and 70 feet below ground surface) is turbid from clays and silts and not
suitable for drinking or irrigation. The deeper portion or Upper Chicot unit (betw een 80 feet and 120 feet below
ground surface) is used for drinking water. Groundwater flow beneath the Site is generally to the southwest

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except where small variations in water levels show some localized flow between the Site and the GCVS site.
Appendix A includes site references used for this FYR. Appendix B contains the Site's order of events.

FIVE-YEAR REVIEW SUMMARY FORM



SITE IDEM II KM ION

Site Name: D.L. Mud, Inc.

EPA ID: LAD981058019

I Region: 6

State: Louisiana

City/County: Abbevil le/Vermi 1 ion Parish |

1

SITE S I A 1 l S

1 NPL Status: Deleted |

Multiple OUs?

No

Has the Site achieved construction completion?

Yes

Lead agency: EPA

Author name: RPM Michael Torres (w ith additional support provided by Skeo)

Author affiliation: EPA Region 6

Review period: 10/11/2022 - 8/1/2023

Date of site inspection: 2/28/2023

Type of rev iew: Statutory

Review number: 5

Triggering action date: 9/28/2018

Due date (fiveyears after triggering action date): 9/28/2023

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Disclaimer: This map and any boundary lines within the map are approximate
and subject to change. The map is not a survey. The map is for informational
purposes only regarding EPA's response actions at the Site. Map image is
the intellectual property of Esri and is used herein under license. Copyright ©
2020 Esri and its licensors. All rights reserved. Sources: Esri, Maxar.
Microsoft, the D L Mud. Inc. 2013 Operation and Maintenance Plan, the Gulf
Coast Vacuum Services 2003 FYR Report and the D.L Mud. Inc. 1994 ROD.

D.L. Mud, Inc. Superfund Site

City of Abbeville, Vermilion County, Louisiana

Last Modified: 4/20/2023

Figure h Site Vicinity Map

Junius Road

D.L. Mud, Inc.
Approximate Site
Boundary

Gulf Coast Vacuum
Services Approximate
Site Boundary

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II. RESPONSE ACTION SUMMARY

Basis for Taking Action

After several site inspections by the Louisiana Department of Environmental Quality (LDEQ), and further site
investigations by EPA between 1983 and 1987, LDEQ and EPA determined that the Site posed a significant
environmental and human health risk. EPA proposed listing the Site on the Superfund program's National
Priorities List (NPL) in June 1988. EPA finalized the Site's listing in October 1989. The PRPs. Dow and DSI.
conducted the remedial investigation and feasibility study (RI/FS) between 1990 and 1994. The baseline risk
assessment conducted as part of the RI/FS evaluated a current trespasser exposed to site soil, surface water and
sediment. The baseline risk assessment also evaluated future residential and occupational exposures to soil,
surface water, sediment, and groundwater.

The findings of the risk assessment indicated only future residential exposure to surface soils results in
noncarcinogenic health effects due to incidental ingestion of barium in surface soils. The risks associated with
exposure to groundw ater were no different from background risks. The ecological risk assessment determined that
the Site did not provide habitat for ecological receptors due to the industrial nature of the Site. In addition,
exposure of aquatic and wildlife to surface water was determined to be minimal because site surface waters are
intermittent and would produce limited exposures.

Response Actions

In 1983, the Louisiana Department of Natural Resources (LDNR) inspected the Site and notified Dow that the
Site was out of compliance with Louisiana Waste Management Program requirements. In response. Dow removed
and manifested drums with waste; cleaned up. packed, and disposed of spill material; re-graded the Site; and
constructed a levee system around the tank farm. Between April and July 1987, Dow and DSI conducted a second
removal action under LDEQ oversight, as the presence of hazardous substances in the tanks and associated soil
posed an imminent danger to human health and the environment. The PRPs cleaned up and off site disposed of
1.3 million pounds of tank contents and associated soils and 14,800 gallons of tank liquid; decontaminated and
demolished tanks; removed and disposed of about 800 cubic yards of contaminated soils from eight on-site areas;
and placed clean, off-site fill material in the excavated areas.

EPA selected the long-term cleanup plan in the Site 1994 Record of Decision (ROD) to address the contaminated
soil and subsurface impoundment sludges. The remedial action objectives (RAO) defined in the ROD include:

•	Preserve human health and the environment by eliminating or reducing identified and/or potential risks by
preventing the ingestion of barium-contaminated soils.

•	Reduce the potential for migration of contaminants from both surface and subsurface soils to the
groundwater.

In addition. EPA established two specific RAOs:

•	Primary: Preserve the Site for non-residential uses and reduce the potential for migration to groundwater
of site-specific contaminants.

•	Secondary: Restore the Site for unrestricted uses.

EPA used future land use assumptions to formulate the primary and secondary remedial objectives. EPA
determined that because the site property was an abandoned light industrial facility located next to the GCVS site,
the Site's potential future use would likely continue to be industrial use. EPA also determined, that because there
were no land use restrictions on the property at the time of the ROD and residential areas were located nearby, it
was conceivable that residential uses could be considered for the Site in the future.

EPA selected the follow ing remedy components to achieve the RAOs:

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•	Implement engineering controls and institutional controls to address the low-level threats posed by the
residual barium contamination in the surface soils. Controls to be implemented include fencing and deed
notices/restrictions to ensure that future residential use of the property does not occur.1

•	Excavate and dispose of visually contaminated subsurface soil at an off-site disposal facility to eliminate
the potential for migration of the contaminants into the groundwater.

•	Bring excavated areas to grade with off-site (imported) soil and clean onsite. stockpiled backfill.

•	Monitor groundw ater to make certain that waste excavation actions are successful and potential
groundwater degradation from residual surface soil contaminants does not occur.

EPA established a health-based cleanup goal for barium in surface soil. EPA established cleanup levels for
subsurface soil, which are the criteria set in pit closure requirements contained in Louisiana Statew ide Order 29-
B. Section 129.B.7 (Table 1). Although EPA did not find that Site-related contamination had adverse impacts on
the groundwater, the RAOs require that remediation efforts eliminate the potential for migration of former
facility-related hazardous substances into the groundwater. Therefore, groundwater was not a contaminated
medium at the Site, and no remedial goals were necessary for groundwater. However, to ensure that contaminants
do not migrate into the groundwater, the ROD stipulated that groundwater monitoring activities make
comparisons with applicable maximum contaminant levels (MCLs) as part of the remedy.

Table 1: 1994 ROD Soil and Subsurface Soil Cleanup Goals

Contaminant of Concern
(COC)

Surface Soil'
	(mg/kg)

Subsurface Soilb
	(mg/kg)	

J2H_

6-9 standard units

Arsenic

10

Barium

5,400

40,000

Cadmium

10

Chromium

500

Lead

500

Mercury

10

Selenium

10

Silver

200

Zinc

500

Oil and Grease

<1% dry weight

Notes:

a.	A noncancer-based value equal to a noncancer hazard index of 1 based on residential
exposure.

b.	Applies to the pit closure requirements contained in Louisiana Statewide Order 29-B.
Section 129.B.7. governing the storage, treatment and disposal of nonhazardous oil
field wastes generated from the drilling and production of oil and gas wells. EPA
determined these regulations arc relevant and appropriate for the subsurface soils
associated with the former surface impoundment areas.

Not a COC for surface soil
mg/kg - milligrams per kilogram

Source: 1994 ROD (page 55 for surface soil and page 56 for subsurface soil).	

Status of Implementation

EPA and Dow/DSI entered a Consent Decree for the site remedial design and remedial action in federal district
court on April 15, 1998 (Civil Action No. CV98-0553). EPA approved the remedial design and remedial action
work plan in October 1998.

1 EPA included the fencing component of the remedy for site security reasons and not risk abatement reasons. The site fence

discourages site access to the former process area for trespassers and potential illegal dumping.

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Consistent with the remedy selected in the 1994 ROD. remedial activities were completed in 1999 and included
the following:

•	Reestablishing locations of former impoundments identified during the remedial investigation phase.

•	Excavating visually contaminated subsurface soil.

•	Backfilling excavated areas with off-site soils and clean, onsite stockpiled soil.

•	Collecting confirmation samples to verify that concentrations met the acceptable criteria (based on pit
closure requirements contained in Louisiana Statew ide Order 29-B, Section 129.B.7 and presented in
Table 1 of this FYR report).

•	Demolishing a shed on the northern portion of the Site.

•	Transporting and disposing of stained soil, drums, wastes and subsurface soil and debris to an off-site
disposal facility.

•	Grading the Site.

•	Enhancing site security with a chain-link fence topped with barb wire and a locked gate.

•	Installation of groundwater monitoring wells to support long-term monitoring of the remedy.

EPA conducted a final site inspection in February 1999. EPA concluded that the Site's selected remedy was
constructed and completed in accordance with the remedial design plans and specifications. EPA then issued the
Site's Final Close-Out Report in June 1999 and deleted the Site from the NPL in March 2000.

Institutional Control (IC) Review

The 1994 ROD for the Site required implementation of institutional controls to eliminate the potential for
ingestion of barium-contaminated surface soils by hypothetical future residents. During the 2008 FYR. a review
of deeds show ed that the PRPs filed a deed notice on the site property in 1998 with the Vermilion Parish Clerk.
However, it did not show that land use restrictions have been placed on the Site. The 2008 FYR report also noted
that there were exceedances of the barium MCL and the screening level for manganese in several site monitoring
wells and recommended that groundw ater use restrictions also be placed on the Site in the form of a deed notice.
Based on the findings of the 2008 FYR report. Dow/DSI worked with the current property owner of the Site
(Vermilion Parish Police Jury) to implement additional land use and groundwater restrictions at the Site in a deed
notice, which was filed in September 2011. The deed notice states that the site property may only be used for
industrial purposes and that all drilling and well installation activities are prohibited on the Site (Table 2 and
Figure 2). In addition, the 2013 Site O&M Plan required annual review of the LDNR groundwater database to
ensure that private groundwater wells are not installed in the vicinity of the Site that might jeopardize the
effectiveness of the remedy. The PRPs updated the O&M plan in 2020, which continues to include the
requirement to review the LDNR groundwater database annually.

Table 2: Summary of Planned and/or Implemented Institutional Controls (ICs)

Media,
Engineered
Controls, and
Areas That Do
Not Support
IJIJ/UE Based
on Cu rrent
Conditions

ICs

Needed

ICs Called for
in the Deeision
Doeuments

Impaeted

Pareel(s)

IC

Objective

Title of IC
Instrument
Implemented and
Date (or planned)

Soil

Yes

Yes

See Figure 2

Restrict properly from

residential use.

Deed Notice
#2011010122
September 29, 2011

Groundwater

Yes

No

See Figure 2

Restrict groundwater
use and well drilling.

Deed Notice
#2011010122

September 29, 2011

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Disclaimer: This map and any boundary lines within the map are
approximate and subject to change. The map is not a survey. The map
is for informational purposes only regarding EPA's response actions at
the Site. Map image is the intellectual property of Esri and is used
herein under license. Copyright © 2020 Esri and its licensors. All rights
reserved. Sources: Esri, Maxar, Microsoft, the Gulf Coast Vacuum
Services 2003 FYR Report and the D.L. Mud, Inc. 1994 ROD.

D.L. Mud, Inc. Superfund Site

City of Abbeville, Vermilion County, Louisiana

Last Modified: 4/20/2023

Figure 2: Institutional Control Map

Junius Road

D.L. Mud, Inc. Approximate Site Boundary
~ J"I Gulf Coast Vacuum Services Approximate Site Boundary
Area Covered by the 2011 Deed Notice

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Systems Operations/Operation and Maintenance (Q&M)

The long-term O&M phase of the remedy began in January 1999. The EPA approved 1998 Remedial Design and
Remedial Action Work pi an states that at each five-year interval the need for continuing O&M activities will be
re-evaluated based on the cumulative data generated to that date. The PRP Group revised the O&M Plan in 2013,
2016 and 2019. The most recent amendment occurred in April 2020 and was approved by the LDEQ and EPA in
June 2020. The PRP Group conducted O&M activities according to the April 2020 O&M plan, which includes:

•	Site inspections: annual inspections of the fence to ensure it remains secured and to ensure land use has
not changed.

•	Site maintenance: vegetation removal as needed to allow for site access and groundwater monitoring.

•	Groundwater sampling: annual measurements of water levels and sampling of well G-21 for total metals
including arsenic, barium, chromium, and manganese.

•	Review of LDNR Groundw ater Database: annual review of the database to ensure groundw ater wells are
not installed near the Site, which might jeopardize the effectiveness of the remedy.

•	Annual reporting.

The 1994 ROD did not identify groundwater as a contaminated medium at the Site and did not develop
remedial goals for groundwater. However, to ensure that soil contaminants do not migrate into the
groundwater, the ROD stipulated that groundwater monitoring activities make comparisons with
applicable MCLs as part of the remedy. EPA approved the original O&M Plan in 1998 and it included
analyzing groundwater samples for volatile organic compounds, semi-volatile organic compounds, and
metals. In 2001 and with EPA's approval. Dow/DSI reduced the analytes to arsenic, barium, total
chromium, iron. lead, manganese, nickel, and vanadium. Following the 2003 FYR. Dow/DSI then
condensed the sampling frequency from quarterly to annually and reduced the analyte list to arsenic,
barium, chromium, and manganese. These changes were documented in the 2013 O&M plan.

In 2016, Dow/DSI proposed eliminating site inspections and maintenance of the fence/signs and reducing
the monitoring network to one Alluvial well, G-21, for barium analysis only. After Agency review of the
proposed O&M revisions in 2019, Dow/DSI re-included the need for annual site inspections as well as
ensuring fencing is secure. Follow ing another Agency review of the 2019 O&M plan. Dow/DSI re-
included the need to analyze groundw ater samples from well G-21 for barium as well as arsenic,
chromium, and manganese in the 2020 O&M plan. The Data Review section of this FYR report discusses
the data further.

The ROD initially estimated site O&M costs at $14,000 per year for 30 years, resulting in a total O&M cost of
$169,000 over the life of the remedy. Table 3 provides estimates of O&M costs over the last five years incurred
for site maintenance and continued sampling costs.

Table 3: Annual O&M Costs

Year

Total Cost (rounded to the nearest

$1,000)

2018

$ 11,000

2019

$ 54,000

2020

$ 34,000

2021

$ 15,000

2022

$ 15,000

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III. PROGRESS SINCE THE PREVIOUS REVIEW

This section includes the protectiveness determinations and statements from the 2018 FYR report (Table 4) as
well as the recommendations from the 2018 FYR and the status of those recommendations (Table 5).

Table 4: Protectiveness Determinations/Statements from the 2018 FYR Report

OIJ #

Protectiveness
Determination

Protectiveness Statement

1

Short-term Protective

The remedy at OU1 is protective of human health and the
environment in the short-term. The remedy addressed short-
term. immediate exposure risk, and direct contact. The
remedy included quarterly site inspections and maintenance to
evaluate the integrity of site fencing and ensure that no
unauthorized land uses arc occurring, annual groundwater
monitoring for total inorganics, quarterly reporting, and
maintenance of ICs. For the remedy to be protective in the
long-term, continue ongoing groundwater monitoring and
analysis of the dataset in accordance with the site O&M plan.

Table 5: Status of Recommendations from the 2018 FYR Report

OU#

Issue

Recommendations

Current
Status

Current

Implementation
Status Description

Completion

Date (if
applicable)

1

Arsenic, chromium, and
manganese consistently exceed
their cleanup levels in
groundwater. Monitoring Well
G-21 also exceeded the barium
MCL during this FYR period.

Continue ongoing

groundwater
monitoring and
analysis of the dataset
in accordance with the
site O&M plan.

Ongoing

The PRP Group
continue to monitor
for arsenic, barium.

chromium, and
manganese in
groundwater.

Not
applicable

IV. FIVE-YEAR REVIEW PROCESS

Community Notification, Community Involvement and Site Interviews

A public notice was made available by a new spaper posting in the Abbeville Meridional new spaper on 12/21/2022
(Appendix C). It stated that the FYR was underway and invited the public to submit any comments to EPA. The
results of the review and the report will be made available at the Site's information repository. Vermilion Parish
Library, located at 405 East St. Victor Street in Abbeville. Copies of the document will also be placed in the site
file at EPA Region 6. 1201 Elm Street in Dallas. Texas.

During the FYR process, interviews were conducted to document any perceived problems or successes with the
remedy implemented to date. The interviews are summarized below and included in Appendix I.

Destin Hooks: Mr. Hooks is the project manager with LDEQ. He believes the current phase of the remedy is
adequately monitoring groundwater and overall conditions of the Site. He is not aware of any complaints or
concerns from the local community. His office conducts site inspections to ensure that site periphery fencing, and
monitoring wells are maintained in good condition. In addition, his office conducts inspections, or updates site
management prior to and after hurricanes (e.g., Hurricane Laura in 2020 and Hurricane Ida in 2021) or extreme
weather events that may affect site conditions and no damage has been noted.

Mayor Roslvn White: Ms. White is the mayor of the City of Abbeville. She has learned of the site cleanup
activities by conducting her own research and subsequent discussions with the LDEQ. However, she does not
believe others are as informed as she is. She suggested that including information on site signage markers and

15


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annual reporting to local government officials may be helpful. She is not aware of any vandalism or
trespassing at the Site and is unaware of local regulation changes that would affect the protectiveness of the
Site's remedy. She is interested in possible site reuse since the FYR report states that EPA took the Site off
the NPL in July 2001.

Keith Rov: Mr. Roy is a Vermilion Parish administrator. He indicated that he is not familiar with the Site's
environmental issues or cleanup activities and would like to be informed via email.

A local resident and a deputy with the Vermilion Parish were interviewed and they did not have any concerns
regarding the Site's cleanup activities. Neither is aware of any vandalism or trespassing.

Dawn Townsen: Ms. Townsen is with the PRP's O&M contractor Jacobs Engineering Group. She believes the

remedy is effective and continues to be protective of human health and the environment in accordance with the
Site's RAOs. A deed notice filed in 2011 restricts land use to industrial activities and prohibits drilling and
installation of wells. Groundwater monitoring shows that barium (the only site contaminant of concern) has
remained less than the MCL for the past six years. Adequate fencing surrounds the Site, and neither vandalism
nor evidence of trespassing have been observed over the past 25 years. Site O&M activities are conducted
according to the amended 2020 O&M plan, which was optimized to reduce the monitoring frequency. Based on
the site conditions, discontinuing O&M activities is recommended and site closure should be considered.

Data Review

The 1994 ROD stipulated that groundwater monitoring activities make comparisons with applicable MCLs as part
of the remedy to ensure that soil contaminants do not migrate into the groundwater. The monitoring well network
for monitoring years 2017 through 2019 includes six wells (including one background well) that monitor the
Alluvium groundwater (above 23 feet below mean sea level) and five wells (including one background well) that
monitor the Upper Chicot groundwater (deeper than 23 feet below mean sea level) (Figure 3). Starting in 2020,
only one Alluvium well is currently monitored. G-21 (Table 6). The 2020 O&M plan requires that groundwater
samples be analyzed for total metals including the primary COC barium along with arsenic, chromium, and
manganese as required by EPA. This FYR studied the groundwater elevation data and analytical results from
2017 to 2022 to determine if the data show issues with the soil remedy at the Site. Long-term trends since 2008
were also reviewed (Table F-l) along with the Mann-Kendall trend analysis (Table F-2). In general, barium and
the other three inorganics (arsenic, chromium, and manganese) exhibit decreasing trends in the Alluvium wells
and decreasing, stable or no trend in the Upper Chicot wells. One exception was noted for manganese in well D-l.
which show s an increasing trend. Manganese has not been identified as a COC and has not been attributed to
former site activities.

Groundwater Elevations

Dow/DSI prepared the potentiometric surface map for the Alluvial groundwater in 2018, which was the last year
that all six Alluvial wells were sampled. Based on the groundwater elevations measured in December 2018, the
groundw ater flow pattern was determined to be southwest consistent with the previous reports. The potentiometric
surface map based on groundwater elevations in 2016 and 2018 are show n in Figures F-1 and F-2. respectively.
The figures depict groundw ater flow to the southw est from the Site and groundw ater flow from the adjacent
GCVS site onto the Site.

16


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boundary lines withi,
The map is not a survt
'ing EPA's response ac
oerty of Esri and is ui
its licensors. All rights re

Figure 3: Detailed Site Map

Junius Road

[BSR

^3 D.L. Mud, Inc. Approximate Site Boundary
™ ™ Gulf Coast Vacuum Services Approximate Site Boundary
V/\ Approximate Former Washout Pit
I XI Approximate Former West Pit
¦ Lower Chicot Well
^ Upper Alluvium Well

Pioneer Village Subdivision

17


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Barium Analytical Results and Trends

The groundwater results for the only site COC. total barium, show that all Alluvium and Upper Chicot
concentrations were below the MCL of 2 milligrams per liter (mg/L) for the past five years (Table 6). The Mann-
Kendall trend results (Table F-2) show that total barium exhibits decreasing trends in all the Alluvium wells and
stable or no trend in the Upper Chicot wells. Prior to 2017, groundwater monitoring well G-21 had been the only
well to consistently exceed the barium MCL but showed a steady decrease since 2008. By 2017, the
concentrations decreased below the MCL and have remained below the MCL for the past six consecutive
sampling events. The 2020 O&M plan stipulated that well G-21 would be monitored for 30 years, or until barium
concentrations remained less than the federal MCL for five consecutive events, whichever occurred sooner. The
2020 O&M plan also stated that once either of these conditions was met. a final assessment of groundwater
concentrations would be completed to demonstrate that future monitoring is not warranted. Barium concentrations
in groundw ater have remained below the MLC for six consecutive sampling events. Dow/DSI has proposed
terminating monitoring of barium in groundw ater. EPA is currently evaluating whether future groundw ater
monitoring at well G-21 is warranted.

Table 6: Groundwater Monitoring Results for Barium, 2017 to 2022

Well

Barium (m
-------
Table 7: Groundwater Monitoring Results for Arsenic, 2017 to 2022

Well

Arsenic (m«/L)

2017

2018

2019

2020

2021

2022

Alluvium

G-8 (Background)

0.00407

0.00462 J

0.00312 J

-

-

-

D-4

0.00104

<0.00109

<0.00109

-

-

-

G-20

0.000412 J

0.00161 J

<0.00109

-

-

-

G-21

0.000431 J

0.00270 J

<0.00109

<0.00109

0.000557 J

0.000506 J

G-22

0.000446 J

0.00117 J

<0.00109

-

-

-

G-23

0.000283 J

<0.00109

<0.00109

-

-

-

U

pper Chicot

D-8 (Background)

0.0228

0.0193

0.0139

-

-

-

D-l

0.00649

0.018

0.00962

-

-

-

D-2

0.00827

0.00581

0.00173 J

-

-

-

D-3

0.00329

0.00769

<0.00109

-

-

-

D-5

0.0061

0.0101

0.0058

-

-

-

Notes:













Bold value - background arsenic concentration exceeds EPA's MCL of 0.01 mg/L



Bold value - arsenic concentration exceeds EPA's MCL but is below background in well D-8

- monitoring well is no longer sampled
J - estimated concentration









Source: Table 3 of the Annual Report - 2022. D.L. Mud, Inc. Supcrfund Site. Agency Interest No.
5416. Abbeville. Louisiana. Schlumbcrger Technologv Corporation. January 2023.

• Chromium (Table 8)

o Alluvium: all Alluvium wells were below the MCL of 0.1 mg/L for chromium,
o Upper Chicot: one Upper Chicot well, D-3, showed chromium concentrations above the MCL in 2017
and 2018 but was below the MCL in 2019. In 2019, only well D-1 slightly exceeded the MCL. These
results suggest there is no source of chromium at the Site as all remaining wells were below the MCL
or below detection.

o The Mann-Kendall results (Table F-2) show that chromium exhibits decreasing trends in all the

Alluvium wells and stable, decreasing or no trend in the Upper Chicot wells,
o Prior studies in 2015, as cited in the amended 2020 O&M plan, indicate that chromium is in the less
toxic trivalent form and was not identified as a site-related contaminant.

Table 8: Groundwater Monitoring Results for Chromium, 2017 to 2022

Well

Chromium (mg/L)

2017

2018

2019

2020

2021

2022

Alluvium

G-8 (Background)

<0.000362

<0.0014

<0.0014

-

-



D-4R

0.00115 J

<0.0014

<0.0014

-

-



G-20

0.00114 J

0.00162 J

<0.0014

-

-



G-21

0.00047 J

<0.0014

<0.0014

<0.0014

<0.000525

<0.00056

G-22

<0.000362

<0.0014

<0.0014

-

-



G-23

0.00086 J

<0.0014

<0.0014

-

-



Upper Chicot

D-8 (Background)

0.0458

0.00169 J

<0.0014

-

-



D-l

0.0391

0.0718

0.142

-

-



D-2

0.00907

0.00247 J

0.00324 J

-

-



D-3

0.105

0.969

0.0033 J

-

-



D-5

0.0751

0.0797

0.0312

-

-



Notes:

Bold value - chromium concentration exceeds EPA's MCL of 0.1 mg/L

19


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- monitoring well is no longer sampled
J - estimated concentration

Source: Tabic 3 of the Annual Report - 2022. D.L. Mud, Inc. Supcrfund Site. Agency Interest No.
5416. Abbeville. Louisiana. Schlumberger Technology Corporation. January 2023.	

• Manganese (Tabic 9)

o Alluvium: alluvium groundwater exceeds EPA's tap water regional screening level (RSL) for

manganese of 0.430 mg/L in the background well and in monitoring wells G-21 and G-22.2
o Upper Chicot: Upper Chicot groundwater exceeds the RSL in the background well and all four
downgradient wells in 2017 and 2018. However, in 2019, the RSL was exceeded in the background
well and two downgradient wells, D-l, and D-5.
o The Mann-Kendall results (Table F-2) show that manganese exhibits decreasing or no trends in all the
Alluvium wells and decreasing trends in most wells in the Upper Chicot wells. The exception is well
D-l. which shows an increasing trend. Manganese has not been identified as a site COC and has not
been attributed to former site activities,
o The approved 2020 O&M plan states that the elevated manganese is naturally occurring at the Site
because of the chemically reducing and low dissolved oxygen conditions in the aquifer, which may be
further influenced by geochemical conditions associated with the GCVS site.

Table 9: Groundwater Monitoring Results for Manganese, 2017 to 2022

Well

Manganese (m«/'L)

2017

2018

2019

2020

2021

2022

Alluvium

G-8 (Background)

0.37 J

0.442

0.899

-

-

-

D-4R

0.0119

0.0231 J

0.0576

-

-

-

G-20

0.0671

0.0546

0.0362 J

-

-

-

G-21

5.42

3.94

2.49

1.46

1.51

1.77

G-22

0.908

1.13

0.782

-

-

-

G-23

0.206

0.0872

0.0761

-

-

-

Upper Chicot

D-8 (Background)

0.54

0.511

0.591

-

-

-

D-l

1.38

2.44

2.03

-

-

-

D-2

0.56

0.551

0.153

-

-

-

D-3

0.316

0.432

0.0257 J

-

-

-

D-5

0.848

3.01

0.699 J

-

-

-

Notes:













Bold value - manganese concentration exceeds EPA's tap water RSL of 0.430 mg/L
- monitoring well is no longer sampled
J - estimated concentration



Source: Table 3 of the Annual Report - 2022. D.L. Mud, Inc. Supcrfund Site. Agency Interest No. 5416.

Abbeville. Louisiana. Schlumberger Technology Corporation. January 2023





Annual Potable Well Survey

Dow/DSI reviews the LDNR Groundw ater Database on an annual basis to ensure groundw ater wells are not
installed near the Site, which might jeopardize the protectiveness of the remedy. The PRPs noted in the Site 2015
Fourth Quarter Progress Report and all subsequent annual reports, that two domestic water wells with the same
location (5627Z and 8615Z) are on site based on the LDNR groundwater database review. The domestic water
wells have not been observed during site visits. These wells were reportedly installed in April 1986 and
November 1993, respectively, at the same location as monitoring well 7085Z. Monitoring Well 7085Z is reported

2

Beginning in 2016 EPA updated the screening value to the current EPA RSL (0.43 mg/L), which replaced the EPA Region 6 human
health medium-specific screening level (1.7 mg/L) previously used to screen total manganese concentrations detected in groundwater.

20


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as being plugged and abandoned (no date provided). Based on this information, the two former domestic wells
may have also been plugged and abandoned, but the status is not yet reflected in the LDNR database (Table F-3
and Figure F-3).

Site Inspection

The site inspection took place on 2/28/2023. Participants included EPA site community involvement coordinator
(CIC) Thomas Ruiz. EPA CIC Adam Weece for the adjacent GCVS site. LDEQ project manager Destin Hooks.
PRP contractor representatives with Jacobs Engineering, and Johnny Z i m m e rm an - Ward and Claire Marcussen
from EPA support contractor Skeo. The inspection's purpose was to assess the protectiveness of the remedy. The
site inspection checklist and photographs are provided in Appendices D and E, respectively.

Site participants entered the Site through the north gate. The gate was secured with a chain and lock. There are
"no trespassing" signs posted at regular intervals on the perimeter chain-link fence topped with barb wire.
Participants observed the monitoring well network. Most wells were secured with locks except for well D-2; the
well is located within the secured fenced area. The well will be repaired as part of O&M activities. O&M
contractors and LDEQ are not aw are of any vandalism or trespassing issues at the Site. There was no damage to
fencing and signage. The Site was in good condition and looked properly maintained. The access roads appeared
mowed; and the perimeter fencing, and monitoring wells were easily accessible.

Follow ing the Site inspection, participants interview ed a resident and local government official. Skeo staff visited
the site repository at the Vermilion Parish Library, located at 405 East St. Victor Street in Abbeville. Site-related
documents were included through 2001. EPA will follow up by providing the library with a compact disk of the
most current information.

V. TECHNICAL ASSESSMENT

QUESTION A: Is the remedy functioning as intended by the decision documents'.'

Question A Summary:

The review of site groundwater monitoring data and the results of the site inspection demonstrate that the soil
remedial action continues to operate and function as designed. Cleanup goals and performance standards for the
soil remedy were achieved as documented in the 1999 final closeout report. EPA did not establish groundwater
cleanup goals because EPA did not find site-related contamination had adverse impacts on the groundwater.
However, to ensure that soil contaminants do not migrate into the groundwater, the 1994 ROD required that
groundwater be monitored and compared to drinking water standards.

The monitoring data show that barium is below the MCL in all wells. Arsenic, chromium, and manganese are
representative of background conditions. O&M activities continue as documented in the 2020 O&M plan. The site
inspection did not identify any issues or concerns with the site remedy.

The PRP Group reviews the LDNR Groundwater Database annually to ensure groundwater wells are not installed
near the Site, which might jeopardize the remedy's protectiveness. The PRP Group's annual reviews show that
between 2018 through 2022 no private groundwater wells were installed near the Site. However, the PRP Group
noted in the 2015 Fourth Quarter Progress report and all subsequent annual reports, that two domestic water wells
with the same location (5627Z and 8615Z) are on site based on the LDNR groundwater database review. The
domestic water wells have not been observed during site visits and were reportedly installed in April 1986 and
November 1993, respectively, at the same locations as monitoring well (MW) 7085Z. MW 7085Z is reported as
plugged and abandoned (no date provided). Based on this information, it is unclear whether the two domestic
wells have also been plugged and abandoned, but the status is not yet reflected in the LDNR database.

An institutional control is in place in the form of a deed notice. It restricts land use and prohibits drilling and well
installation on the site property. There were no early indicators of potential remedy problems noted during this

FYR.

21


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QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the
remedy selection still valid'.'

Question 6 Summary:

The exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the remedy selection are
still valid. There have been no changes in standardized risk assessment methodologies that could affect the
protectiveness of the remedy. The only identified exposure concern at the time of the ROD was from ingestion of
barium-containinated surface soil under a future residential exposure scenario. The residential risk-based cleanup
goal for barium in surface soil presented in the ROD was 5,400 milligrams per kilogram (mg/kg). A screening-
level risk evaluation of this goal shows it remains valid. The remedy also included an institutional control in the
form of deed notices/restrictions to prevent hypothetical future residential exposure to barium in surface soil. This
FYR report includes a screening-level risk evaluation of the health-based soil cleanup goals (Appendix H). which
demonstrates that the cleanup goals remain valid based on a review of current toxicity values and default exposure
assumptions.

There have been no changes in the physical conditions, completed exposure pathway scenarios, or land use
changes at the Site that would affect the protectiveness of the remedy. A city representative expressed interest in
potential future reuse of the Site. However, currently there are no formal plans or any masterplan in place for Site
reuse.

The primary RAOs were to preserve human health and the environment by eliminating or reducing identified
and/or potential risks by preventing the ingestion of barium-contaminated soils and by reducing the potential for
migration of contaminants from both surface and subsurface soils to the groundwater. The primary RAOs were
met through a deed notice issued in 2011 restricting site use to industrial activities, which eliminates the risk
associated with future residential exposures to soil and groundwater. In addition, contaminant migration from soil
to groundwater was reduced by excavating and offsite disposing the contaminated subsurface soil. The deed
notice also eliminates exposure to groundwater as it prohibits drilling and installation of private water wells at the
Site. Further, the site remedy reduced the potential for migration of contaminants from soil to groundwater and
barium concentrations have been below the barium MCL for five consecutive years.

QUESTION C : Has any other information come to light that could call into question the protectiveness of the
remedy'.'

As part of this FYR. EPA conducted a forward-looking climate change analysis to estimate whether extreme
weather could affect the protectiveness of the remedy, and what actions would be needed to ensure its resilience
under future climate conditions that could affect short term and long-term protectiveness. The breakdown of
potential conditions at the site indicates very low vulnerability to extreme temperature; medium for annual and
seasonal precipitation; high susceptibility for heavy precipitation, inland flooding, sea level rise and hurricane
storm surge; low vulnerability for dry days, very low for landslides and high exposure for wildfires.

The contamination at the Site is subsurface, existing in the groundwater and surface soils. The remedy has been in
place since 1999 and has weathered several hurricanes in the past. During this FYR period. LDEQ completed the
requisite inspections prior to and after hurricanes (e.g., Hurricane Laura in 2020 and Hurricane Ida in 2021) and
no damage was reported. The soil cover remained in good condition. The Site is unlikely to be impacted by
conditions caused by potential climate change given its characteristics and the historical lack of impacts from past
major hurricanes (e.g., Hurricane Rita and Hurricane Katrina in 2005). Extreme/climate change weather exposure
will continue to be evaluated at subsequent five-year reviews to ensure remedy protectiveness.

No other information has come to light that could call into question the protectiveness of the remedy.

VI. ISSUES/RECOMMENDATIONS

22


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Issucs/Rccommcndations

OU(s) without Issues/Recommendations Identified in the FYR:
None

Issues and Recommendations Identified in the FYR:

OU(s): 1

Issue Category: Monitoring



Issue: Arsenic, chromium, and manganese consistently exceed MCLs and secondary
MCLs in groundwater. However, the PRPs attribute the presence of these inorganic
compounds to background conditions unrelated to the Site.



Recommendation: Evaluate and confirm if arsenic, chromium, and manganese are
indeed representative of background conditions and determine if ongoing monitoring is

warranted for these inorganic compounds. Update the amended O&M plan as
necessary.

Affect

Current
Protectiveness

Affect Future
Protectiveness

Party
Responsible

Oversight
Party/Support
Agency

Milestone Date

No

Yes

PRP

EPA/State

9/1/2025

OU(s): 1

Issue Category: Remedy Performance



Issue: The PRP Group noted in the 2015 Fourth Quarter Progress report and all
subsequent annual reports, that two domestic water wells with the same location
(5627Z and 8615Z) are on site based on the LDNR groundwater database review. The
domestic water wells have not been observed during site visits and were reportedly
installed in April 1986 and November 1993, respectively, at the same locations,
including monitoring well (MW) 7085Z. MW 7085Z is reported as being plugged and
abandoned (no date provided). Based on this information, it is unclear if the two
domestic wells have also been plugged and abandoned, but the status is not yet
reflected in the LDNR database.



Recommendation: Determine the status of the two former domestic water wells and
confirm they have been properly abandoned. If not. abandon the wells and provide the
documentation in the LDNR database.

Affect
Current
Protectiveness

Affect Future
Protectiveness

Party
Responsible

Oversight
Party/Support
Agency

Milestone Date

No

Yes

PRP

EPA/State

9/1/2025

OTHER FINDINGS

Two recommendations were identified during the FYR that do not affect current and/or future protectiveness.

•	Secure well D-2.

•	Assess if the institutional controls may be overly restrictive for the Site.

23


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VII. PROTECTIVENESS STATEMENT

Silcwiilc I'rolccliMMicss Stiitoment

Protectiveness Determination:

Short-term Protective

Protectiveness Statement: The remedy at OU I is protective of human health and the environment in
the short term. The remedy addressed short-term, immediate exposure risk and direct contact. The
remedy included annual site inspections and maintenance to evaluate the integrity of site fencing and
ensure that no unauthorized land uses are occurring, annual groundw ater monitoring for total
inorganics, quarterly reporting, and maintenance of institutional controls. How ever, for the remedy to
be protective in the long term, the follow ing actions need to be taken to ensure protectiveness:

•	Evaluate and confirm if arsenic, chromium, and manganese are Site-related or representative
of background and determine if ongoing groundw ater monitoring is warranted for these
inorganic compounds. Update the O&M plan as necessary.

•	Determine the status of the two former domestic water wells and if they have been properly
plugged and abandoned. If not. abandon the wells and provide the documentation in the LDNR
database.

VIII. NEXT REVIEW

The next FYR report for the D.L. Mud, Inc. Superfund Site is required five years from the completion date of this
review.

24


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APPENDIX A - REFERENCE LIST

Amended Operation and Maintenance Plan, D.L. Mud Site. Abbeville. Louisiana. CH2M Hill Engineers. Inc.
April 2020.

Annual Report - 2020. D.L. Mud, Inc. Superfund Site. Agency Interest No. 5416. Abbeville. Louisiana. CH2M
Hill Engineers. Inc. January 2021.

Annual Report - 2021. D.L. Mud, Inc. Superfund Site. Agency Interest No. 5416. Abbeville. Louisiana. CH2M
Hill Engineers. Inc. January 2022.

Annual Report - 2022. D.L. Mud, Inc. Superfund Site. Agency Interest No. 5416. Abbeville. Louisiana. CH2M
Hill Engineers. Inc. January 2023.

Civil Action No. CV98-0553, Consent Decree. United States of America v. The Dow Chemical Company et.
al. in the United States District Court for the Western District of Louisiana. Lafayette-Opelousas Division.

Filed April 1998.

Feasibility Study Report. D.L. Mud, Inc. Site. Abbeville. Louisiana. CH2M Hill Engineers. Inc. November 1993.

Final Close Out Report. D.L. Mud Superfund Site. Abbeville. Louisiana. Prepared by U.S. Environmental
Protection Agency Region VI. Superfund Division. June 1999.

Fourth Five-Year Review Report for the D.L. Mud, Inc. Superfund Site. Abbeville. Vermilion Parish. Louisiana.
U.S. Environmental Protection Agency. September 2018.

Operation and Maintenance Plan Addendum. D.L. Mud Superfund Site. Abbeville. Louisiana, Agency Interest
No. 5416. CH2M HILL Engineers. Inc. September 2016.

Progress Report - Fourth Quarter 2016. Mud Superfund Site. Abbeville. Louisiana, Agency Interest No. 5416.
CH2M HILL Engineers. Inc. January 2017.

Progress Report - First Quarter 2018. Mud Superfund Site. Abbeville. Louisiana, Agency Interest No. 5416.
CH2M HILL Engineers. Inc. April 2018.

Progress Report - Second Quarter 2018. Mud Superfund Site. Abbeville. Louisiana, Agency Interest No. 5416.
CH2M HILL Engineers. Inc. July 2018.

Progress Report - Third Quarter 2018. Mud Superfund Site. Abbeville. Louisiana, Agency Interest No. 5416.
CH2M Hill Engineers. Inc. October 2018.

Progress Report - Fourth Quarter 2018. Mud Superfund Site. Abbeville. Louisiana, Agency Interest No. 5416.
CH2M Hill Engineers. Inc. January 2019.

Progress Report - First Quarter 2019. Mud Superfund Site. Abbeville. Louisiana, Agency Interest No. 5416.
CH2M Hill Engineers. Inc. April 2019.

Progress Report - Third Quarter 2019. Mud Superfund Site. Abbeville. Louisiana, Agency Interest No. 5416.
CH2M Hill Engineers. Inc. October 2019.

Progress Report - Fourth Quarter 2019. Mud Superfund Site. Abbeville. Louisiana, Agency Interest No. 5416.
CH2M Hill Engineers. Inc. January 2020

A-l


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Progress Report - First Quarter 2020. Mud Superfund Site. Abbeville. Louisiana, Agency Interest No. 5416.
CH2M HILL Engineers. Inc. April 2020.

Record of Decision. D.L. Mud, Inc. Superfund Site. Vermilion Parish. Louisiana. U.S. Environmental Protection
Agency. September 1994.

Regional Screening Levels (RSLs) - Generic Tables. U.S. Environmental Protection Agency. May 2022.

Remedial Action Report. D.L. Mud, Inc. Superfund Site. Abbeville. Louisiana. Radian International. LLC. 1999.
June 10.

Remedial Design and Remedial Action Workplan. D.L. Mud, Inc. Superfund Site. Abbeville. Louisiana. Radian
International. LLC. 1998. September.

Remedial Investigation Report. D.L. Mud, Inc. Site. Abbeville. Louisiana. CH2M Hill Engineers. Inc.

December. 1992.

Second Five-Year Review Report for the D.L. Mud, Inc. Superfund Site. Abbeville. Vermilion Parish. Louisiana.
U.S. Environmental Protection Agency. September 2008.

Site Deletion from the National Priorities List. D.L. Mud, Inc. Superfund Site. U.S. Environmental Protection
Agency. July 1999.

Third Five-Year Review Report for the D.L. Mud, Inc. Superfund Site. Abbeville. Vermilion Parish. Louisiana.
U.S. Environmental Protection Agency. September 2013.

A-2


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APPENDIX B - SITE CHRONOLOGY

Table B-l: Site Chronology



Date

Lafayette Highway Equipment Sales and Service. Inc. sold the site
property to Gulf Coast Pre-Mix Trucking, Inc.

May 1. 1975

G.H. Drilling Fluid Services. Inc. (later G.H. Fluid Services. Inc.)

became the owner of the site property when Gulf Coast Pre-Mix Mud
Service. Inc. merged with Gulf Coast Pre-Mix Trucking. Inc.

January 11. 1979

EPA identified the Site following a citizen's complaint

June 27, 1980

EPA performed a preliminary sampling inspection

July- September 1980

G.H. Fluid Services. Inc. sent a notification of hazardous waste activity
to EPA

August 18, 1980

G.H. Fluid Services. Inc. sold 12.78 acres of the 25.56-acre site property
parcel to Dow

October 1, 1980

GCVS sold the 12.78-acre parcel to Dowel 1. a division of Dow

Fcbruarv 11. 1981

Dow filed a hazardous waste notification form with the LDNR

Fcbruarv 21, 1983

LDNR inspected the Site and issued a letter of warning for failure to
complv with state regulations

April 29, 1983

Dow completed the first removal action of site debris and contaminated
soil in response to a warning letter

May 18, 1983

Dow submitted a certification of inactivity at the Site to the LDNR

October 1983

Dow transferred site ownership to DSI

April 1984

DSI sold the site property to D.L. Mud, Inc.

March 1985

EPA prepared a potentially hazardous waste form for the Site noting that
there may have been some activities taking place at the Site after Dow

had declared the Site was inactive

June 6, 1985

EPA conducted a site inspection with sampling at the Site

July 10, 1985

EPA prepared a preliminary assessment

August 16, 1985

Dow and DSI conducted a second removal action to clean up and dispose
of tanks, tank contents and soils

April-July 1987

EPA completed an expanded site investigation documenting the Site
posed a significant environmental and human health risk

1987

EPA proposed the Site for inclusion on the NPL

June 24, 1988

EPA listed the Site on the NPL

October 4. 1989

EPA issued an Administrative Order on Consent to Dow/DSI
Dow/DSI began the RI/FS

June 20, 1990

Dow/DSI completed the RI/FS
EPA issued the ROD

September 22, 1994

EPA issued an Administrative Order on Consent to Dow/DSI
Dow/DSI began the remedial design

April 15, 1998

Dow/DSI completed the remedial design and began the remedial action

October 1, 1998

Dow/DSI began long-term O&M activities

January 22, 1999

Dow/DSI completed the remedial action

June 21, 1999

EPA issued the Site Final Closeout Report

June 30, 1999

EPA deleted the Site from the NPL

March 7, 2000

EPA signed the Site First FYR Report

September 16, 2003

EPA determined the Site achieved the Sitew ide Ready for Anticipated
Reuse performance measure

September 21, 2007

EPA signed the Site Second FYR Report

September 16, 2008

A deed notice was filed to restrict land use and groundw ater use

September 29, 2011

B-l


-------


Date

Dow/DSI submitted a formal O&M plan to EPA and LDEQ requiring
annual monitoring of arsenic, barium, chromium, and manganese in
groundwater in multiple wells

July 31, 2013

EPA signed the Site Third FYR Report

August 23,2018

EPA approved the My 2013 O&M plan

December 2015

Dow/DSI submitted an addendum to the 2013 O&M plan to remove the
need for site inspections and to conduct groundwater monitoring on one

well, G-21, only for barium

September 13, 2016

Dow/DSI submitted a rcvision to the September 2016 draft O&M plan
addendum to include the need for annual site inspections and to conduct

groundwater monitoring on one well, G-21, onlv for barium

October 4. 2019

EPA signed the Site Fourth FYR Report

September 28, 2018

Dow/DSI submitted a rcvision to the October 2019 draft O&M plan
addendum to include the need for annual site inspections and to conduct
groundwater monitoring on one well, G-21 for arsenic, barium.

chromium, and manganese

April 23, 2020

EPA and LDEQ approved the amended O&M plan

June 11,2020

Long-term groundwater monitoring achieved five consecutive years of
barium concentrations below the barium MCL in well G-21

June 1, 2021

B-2


-------
- PRESS NOTICE

Wednesday, December 21, 2022	ABBEVl I IE MERJDIQN

T



*L PRO"*'

V

PUBLIC NOTICE

D.L. Mud, Inc. Superfund Site
Public Notice
U.S. Environmental Protection Agency,
Region 6

December 2022

The U S Environmental Protection Agency Region 6 (EPA) will
be conducting the tilth live-year review of remedy ^ploinsn ation
and performance at the D.L. Mud, Inc. Superfund site (Site) in
Abbeville, Louisiana. From 1969 to 1986, the site owner operated
a drilling mud blending facility. Historical blending
waste disposal practices contaminated soil and groundwater with
hazardous chemicals.

EPA managed the site as one operable unit (OU1).The OU1 rem-
edy included removal actions, excavation and backfil ing to grad
with clean fill, enhancing site security, and groundwater monitor-
ing. Operation and maintenance activities are ongoing; grou
water monitoring and site inspections are conducted annually.
Nearby land uses include agricultural and residential areas.

The five-year review will determine if the remedies are still protec-
tive of human health and the environment. The ^e-year reviewms
scheduled for completion in June 2023. The report will to made
available to the public at the following local information repository.

Vermilion Parish Library- Abbeville Branch
405 East St. Victor Street
Abbeville, Louisiana 70510
(337) 893-2674

Site status updates are available on the Internet at

https://www.epa.gov/superftind/dl-mud

All media inquiries should be directed
to the EPA Press Office at (214) 665-2200

For more information about the Site, contact.

Michael Torres/Remedial Project Manager
(214) 665-2108
or by email at torres.michael@epa.gov

Jason McKinney/Community Involvement Coordinator
(214) 665-8132
or 1-800-887-6063 (toll-free)
or by email at McKinney.Jason@epa.gov

ir-r>. r>r:/~rMOFQ 91 OWA

For more information about the Site, contact:

Michael Torres/Remedial Project Manager
(214) 665-2108

or by email attorres.michael@epa.gov

Janetta Coats/Communily Involvement Coordinator
(214) 665-7308
or 1-800-887-6063 (toll-free)
or by email at coats.janetta@epa.gov

(PUBLISHED: DECEMBER 21,2022)

PUBLIC NOTICE

^IMUTPS OF SPECJALBQARD MEETING

A special meeting of the Board o1 Comm'ssionersofHosp'ta1

Service District No. 2, Abbeville General Hospltal F>ansh ol
Vermilion^ StateML^Wana ^called

following people present.

MEMBERS PRESENT: John Boudreaux, Chairman

John Budden, MD

Kelly Richard

Daleon Primeaux

Jody Landry

Oswald Broussard, Vice-Chairman

STAFF PRESENT: Michael J. Bertrand. II, Chief Executive Officer

Troy Hair, Chief Financial Officer

Heidi Broussard, Chief Nursing Officer
Abbey Palombo, Recording Secretary
Susan Landry, Recording Secretary

MEMBERS ABSENT: Anita Levy

SgSw. •«»¦>» ¦» "rgyssflSL.

unanimously carried. ^e,^'nu'^" |6 20922 were accepted
mlssloners meeting held November 16, 2022 were ac p

as written.

AccspVReject Bids

Diesel Fire Pump Replacement Proiect
One (1) bid was received as follows:

age (Bria

Mr. Briar

was ado

been up

Budget:

Upon m
Holiier <
adopte<
2023 Pi
to view

Old Bu:
Mr. Rai
would I
Board I
for non
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Meaux
Brian I
tionsti
the po
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$100,

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3.	R<

Thei
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C-l


-------
APPENDIX D - SITE INSPECTION CHECKLIST

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site Name: D.L. Mud Inc.

Date of Inspection: February 28. 2023

Location and Region: Abbeville. Vermilion Parish.
Louisiana. 6	

EPA ID: LAD0981058019

Agency, Office, or Company Leading the Five-Year
Review: EPA Region 6 	

Weather/Temperature: Partly sunnv/73°F

~	Monitored natural attenuation

~	Groundwater containment

~	Vertical barrier walls

Remedy Includes: (Check all that apply)

~	Landfill cover/containment
m Access controls
m Institutional controls

~	Groundwater pump and treatment

~	Surface water collection and treatment

m Other: Excavate soils and waste with off-site disposal, groundwater monitoring, engineering

	controls 	

Attachments: D Inspection team roster attached	Q Site map attached	

	II. INTERVIEWS (check all that apply)	

1. O&M Site Manager Dawn Townsen

Name

Interviewed ~ at site ~ at office ~ by phone
Problems, suggestions ~ Report attached:

Jacobs Engineering Project

Manager
Email: X

Date

2. O&M Staff

Zeb Anderson

Name

Interviewed ~ at site ~ at office ~ by phone
Problems/suggestions ~ Report attached:

Jacobs Engineering Staff
Title
Email: X

Date

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). Fill in all that apply.

Agency LDEQ
Contact Pest in Hooks

Name

Problems/suggestions ~ Report attached:.

Project

Manager
Title

3/9/2023
Date

Phone No.

Agency	

Contact 	

Name

Problems/suggestions ~ Report attached:.

Title

Date

Phone No.

Agency	

Contact 	

Name

Problems/suggestions ~ Report attached:.
Problems/suggestions ~ Report attached:.

Title

Date

Phone No.

4.	Other Interviews (optional) D Report attached:

Vermilion Parish administrator

Vermilion Parish deputy
Local resident

III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

1.

O&M Documents

D-l


-------


13 O&M manual [3 Readily available [3 Up to date

13 As-built drawings [3 Readily available [3 Up to date
13 Maintenance logs [3 Readily available [3 Up to date
Remarks:

~	N/A

~	N/A

~	N/A

2.

Site-Specific Health and Safety Plan

~ Contingency plan/emergency response plan

Remarks:

13 Readily available
~ Readily available

13 Up to date d N/A
~ Up to date 13 N/A

3.

O&M and OSHA Training Records
Remarks:

~ Readily available

~ Up to date [El N/A

4.

Permits and Service Agreements

~	Air discharge permit

~	Effluent discharge

~	Waste disposal, POTW
n Other permits:

Remarks:

~	Readily available

~	Readily available

~	Readily available

~	Readily available

~	Up to date |3 N/A

~	Up to date |3 N/A

~	Up to date |3 N/A

~	Up to date |3 N/A

5.

Gas Generation Records
Remarks:

~ Readily available

~ Up to date |3 N/A

6.

Settlement Monument Records
Remarks:

~ Readily available

~ Up to date |3 N/A

7.

Groundwater Monitoring Records
Remarks:

13 Readily available

13 Up to date d N/A

8.

Leachate Extraction Records
Remarks:

~ Readily available

~ Up to date |3 N/A

9.

Discharge Compliance Records

~	Air ~ Readily available ~ Up to date

~	Water (effluent) ~ Readily available ~ Up to date

Remarks:

13 N/A
13 N/A

10.

Daily Access/Security Logs
Remarks:

~ Readily available

~ Up to date |3 N/A

IV. O&M COSTS

1.

O&M Organization
Q State in-housc
~ PRP in-housc
Q Federal facility in-housc

n

~	Contractor for state
13 Contractor for PRP

~	Contractor for Federal facility

2.

O&M Cost Records

Q Readily available Q Up to date

Q Funding mechanism/agreement in place 13 Unavailable
Original O&M cost estimate: [~~l Breakdown attached

Total annual cost by year for review period if available
From: 12/2/2017 To: 11/30/2018 $11,000 |~1 Breakdown attached
Date Date Total cost



From: 12/3/2018 To: 11/29/2019
Date Date

$54,000 n Breakdown attached
Total cost



From: 11/30/2019 To: 11/27/2020
Date Date

$34,000 n Breakdown attached
Total cost



From: 11/28/2020 To: 11/26/2021
Date Date

$15,000 I-! Breakdown attached
Total cost



From: 11/27/2021 To: 11/25/2022
Date Date

$15,000 I-! Breakdown attached
Total cost

D-2


-------
3. Unanticipated or Unusually High O&M Costs during Review Period

	Describe costs and reasons: Not applicable 	

	V. ACCESS AND INSTITUTIONAL CONTROLS M Applicable ~ N/A

A. Fencing	

1. Fencing Damaged
Remarks:	

~ Location shown on site map m Gates secured ~ N/A

B. Other Access Restrictions

1. Signs and Other Security Measures
Remarks:	

~ Location shown on site map ~ N/A

C. Institutional Controls (ICs)

1. Implementation and Enforcement

Site conditions imply ICs not properly implemented

Site conditions imply ICs not being fully enforced

Type of monitoring (e.g., self-reporting, drive by): Site inspections

Frequency: Annual

Responsible party/agency: Dow/DSI

Contact 			

Name	Title

Reporting is up to date
Reports arc verified by the lead agency

Specific requirements in deed or decision documents have been met

Violations have been reported

Other problems or suggestions: Q Report attached

El Yes
~ Yes

m No ~ N/A
EI No ~ N/A

Date

EI Yes
[EI Yes
[EI Yes
~ Yes

Phone no.
~ No ON/A

~	No

~	No

[EI No

~	N/A

~	N/A

~	N/A

2.

Adequacy

Remarks:

ICs arc adequate

~ ICs arc inadequate

~ N/A

D. General

I. Vandalism/Trespassing ~ Location shown on site map m No vandalism evident
Remarks:

2. Land Use Changes On Site
Remarks:	

EI N/A

3. Land Use Changes Off Site

Remarks:

E N/A

VI. GENERAL SITE CONDITIONS

A. Roads

EI Applicable ~ N/A

I. Roads Damaged
Remarks:	

~ Location shown on site map EI Roads adequate

~ N/A

B. Other Site Conditions

Remarks:

VII. LANDFILL COVERS

~ Applicable EI N/A

A. Landfill Surface

I. Settlement (low spots)

Area extent:	

Remarks:	

~ Location shown on site map ~ Settlement not evident

Depth:	

Cracks

Lengths: _
Remarks:

~ Location shown on site map G] Cracking not evident
Widths:		Depths:	

Erosion

Area extent:.
Remarks:

CH Location shown on site map

~ Erosion not evident
Depth:	

Holes

Area extent:.
Remarks:

~ Location shown on site map

~ Holes not evident
Depth:	

Vegetative Cover
~ No signs of stress
Remarks:

~ Grass	~ Cover properly established

CH Trecs/shrubs (indicate si/c and locations on a diagram)

D-3


-------
6.

Alternative Cover (e.g., armored rock, concrete)

Remarks:

~ N/A

7.

Bulges ~ Location shown on site map

Area extent:

Remarks:

~ Bulges not evident

Height:

8.

Wet Areas/Water Damage Q Wet areas/water damage not evident



Q Wet areas Q Location shown on site map
Q Ponding ~ Location shown on site map
Q Seeps Q Location shown on site map
Q Soft subgrade Q Location shown on site map
Remarks:

Area extent:
Area extent:
Area extent:
Area extent:

9.

Slope Instability Q Slides
~ No evidence of slope instability

Area extent:

Remarks:

~ Location shown on site map

B.

Benches ~ Applicable ~ N/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in
order to slow down the velocity of surface runoff and intercept and com ev the runoff to a lined channel.)

1.

Flows Bypass Bench Q Location shown on site map
Remarks:

~ N/A or okay

2.

Bench Breached Q Location shown on site map
Remarks:

~ N/A or okay

3.

Bench Overtopped Q Location shown on site map
Remarks:

~ N/A or okay

C.

Letdown Channels ~ Applicable ~ N/A

(Channel lined with erosion control mats, riprap, grout bags or gabions that descend the steep side slope of
the cover and will allow the runoff water collected by the benches to move off from the landfill cover
without creating erosion gullies.)

1.

Settlement (Low spots) [_] Location shown on site map

Area extent:

Remarks:

~ No evidence of settlement
Depth:

2.

Material Degradation ~ Location shown on site map
Material tvpe:

Remarks:

~ No evidence of degradation
Area extent:

3.

Erosion ~ Location shown on site map

Area extent:

Remarks:

~ No evidence of erosion
Depth:

4.

Undercutting ~ Location shown on site map

Area extent:

Remarks:

~ No evidence of undercutting

Depth:

5.

Obstructions Tvpe:

n Location shown on site map Area extent:

Size:

Remarks:

~ No obstructions

6.

Excessive Vegetative Growth Tvpe:

~	No evidence of excessive growth

~	Vegetation in channels docs not obstruct flow

n Location shown on site map Area extent:
Remarks:



D.

Cover Penetrations ~ Applicable ~ N/A



1.

Gas Vents Q Active Q Passive
~ Properly secured/locked Q Functioning ~ Routinely sampled Q Good condition
Q Evidence of leakage at penetration Q Needs maintenance Q N/A
Remarks:

D-4


-------
2.

Gas Monitoring Probes

~ Properly secured/locked Q Functioning ~ Routinely sampled Q Good condition
Q Evidence of leakage at penetration Q Needs maintenance Q N/A

Remarks:

3.

Monitoring Wells (within surface area of landfill)

~ Properly secured/locked Q Functioning ~ Routinely sampled Q Good condition
Q Evidence of leakage at penetration Q Needs maintenance Q N/A

Remarks:

4.

Extraction Wells Leachate

~ Properly secured/locked Q Functioning ~ Routinely sampled Q Good condition
Q Evidence of leakage at penetration Q Needs maintenance Q N/A

Remarks:

5.

Settlement Monuments Q Located Q Routinely surveyed ~ N/A
Remarks:

E.

Gas Collection and Treatment ~ Applicable ~ N/A

1.

Gas Treatment Facilities

~ Flaring ~ Thermal destruction ~ Collection for reuse
Q Good condition ~ Needs maintenance

Remarks:

2.

Gas Collection Wells, Manifolds and Piping
Q Good condition ~ Needs maintenance

Remarks:

3.

Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
Q Good condition ~ Needs maintenance Q N/A

Remarks:

F.

Cover Drainage Layer ~ Applicable ~ N/A

1.

Outlet Pipes Inspected Q Functioning ~ N/A
Remarks:

2.

Outlet Rock Inspected ~ Functioning ~ N/A

Remarks:

G.

Detention/Sedimentation Ponds ~ Applicable ~ N/A

1.

Siltation Area extent: Depth: [~~l N/A
Q Siltation not evident

Remarks:

2.

Erosion Area extent: Depth:
~ Erosion not evident

Remarks:

3.

Outlet Works Q Functioning ~ N/A

Remarks:

4.

Dam Q Functioning ~ N/A

Remarks:

EL Retaining Walls ~ Applicable ~ N/A

1.

Deformations Q Location shown on site map Q Deformation not evident
Hori/ontal displacement: Vertical displacement:

Rotational displacement:

Remarks:

2.

Degradation ~ Location shown on site map Q Degradation not evident

Remarks:

I. Perimeter Ditehes/Off-Site Discharge ~ Applicable ~ N/A

1.

Siltation Q Location shown on site map Q Siltation not evident

Area extent: Depth:

Remarks:

2.

Vegetative Growth Q Location shown on site map Q N/A
Q Vegetation docs not impede flow

Area extent: Tvpe:
Remarks:

3.

Erosion ~ Location shown on site map ~ Erosion not evident

D-5


-------
Area extent: Depth:
Remarks:

4.

Discharge Structure Q Functioning ~ N/A
Remarks:

VIII. VERTICAL BARRIER WALLS ~ Applicable [EI N/A

1.

Settlement Q Location shown on site map Q Settlement not evident

Area extent: Depth:

Remarks:

2.

Performance Monitoring Tvpe of monitoring:

~ Performance not monitored

Freaucncv: PI Evidence of breaching
Head differential:

Remarks:

rx.

GROUNDWATER/SURFACE WATER REMEDIES ^ Applicable ~ N/A

A.

Groundwater Extraction Wells, Pumps and Pipelines ~ Applicable N/A

1.

Pumps, W ellhead Plumbing and Electrical

~ Good condition ~ All required wells properly operating ~ Needs maintenance Q N/A
Remarks:

2.

Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances

~ Good condition ~ Needs maintenance

Remarks:

3.

Spare Parts and Equipment

Q Readily available Q Good condition ~ Requires upgrade Q Needs to be provided
Remarks:

B. Surface Water Collection Structures, Pumps and Pipelines ~ Applicable N/A

1.

Collection Structures, Pumps and Electrical

Q Good condition ~ Needs maintenance
Remarks:

2.

Surface W ater Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances

Q Good condition ~ Needs maintenance

Remarks:

3.

Spare Parts and Equipment

Q Readily available Q Good condition ~ Requires upgrade Q Needs to be provided
Remarks:

C.

Treatnient System ~ Applicable N/A

1.

Treatnient Train (check components that apply)

~	Metals removal Q Oil/water separation ~ Biorcmediation

~	Air stripping O Carbon adsorbers
n Filters:

n Additive (e.g.. chelation agent, flocculent):
n Others:

Q Good condition O Needs maintenance
Q Sampling ports properly marked and functional
Q Sampling/maintenance log displayed and up to date
Q Equipment properly identified
n Ouantitv of groundwater treated annuallv:
n Ouantitv of surface water treated annuallv:

Remarks:

2.

Electrical Enclosures and Panels (properly rated and functional)
Q N/A ~ Good condition ~ Needs maintenance
Remarks:

3.

Tanks, Vaults, Storage Vessels

Q N/A ~ Good condition ~ Proper secondary containment Q Needs maintenance
Remarks:

4.

Discharge Structure and Appurtenances

Q N/A ~ Good condition ~ Needs maintenance
Remarks:

D-6


-------
5.

Treatment Building)*)

Q N/A ~ Good condition (csp. roof and doorways) Q Needs repair

~ Chemicals and equipment properly stored

Remarks:

6.

Monitoring Wells (pump and treatment remedy)

~	Properly secured/locked Q Functioning ~ Routinely sampled ~ Good condition

~	All required wells located Q Needs maintenance Q N/A
Remarks:

D. Monitoring Data

1.

Monitoring Data

[3 Is routinely submitted on time [3 Is of acceptable quality

2.

Monitoring Data Suggests:

[3 Groundwater plume is effectively contained |3 Contaminant concentrations arc declining

E.

Monitored Natural Attenuation

1.

Monitoring Wells (natural attenuation remedy)

~	Properly secured/locked Q Functioning ~ Routinely sampled ~ Good condition

~	All required wells located Q Needs maintenance 13 N/A

Remarks:

X. OTHER REMEDIES

If there arc remedies applied at the site and not covered above, attach an inspection sheet describing the physical
nature and condition of anv facility associated with the rcmcdv. An example would be soil vapor extraction.

XI. 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 designed to accomplish (e.g., to contain contaminant
plume, minimize infiltration and gas emissions).

The site rcmcdv included soil and waste excavation with off-site disposal and backfill. The rcmcdv



continues to operate and function as designed bv preventing human exposure through excavation and off-
site disposal and limiting site uses to industrial/commercial purposes. Cleanup goals and performance
standards for the soil remedv are achieved. Ongoing groundwater monitoring shows residual



contamination does not impact site groundwater.

B.

Adequacy of O&M

Describe issues and observations related to the implementation and scope of O&M procedures. Discuss
their relationship to the current and long-term protcctivcncss of the remedy.

O&M is adequate.

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 protcctivcncss of the remedy may be compromised
in the future.



None.

D.

Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
Starting in 2020. monitoring of groundwater was optimized from 11 wells to one well.

Site Inspection Participants:

Thomas Ruiz. EPA site CIC
Adam Weece. EPA CIC (for the GCVS site)
Destin Hooks. LDEQ

Dawn Townsen. Jacobs Engineering Group
Zeb Anderson. Jacobs Engineering Group
Johnny Zimmerman-Ward, Skeo
Claire Marcussen. Skeo

D-7


-------
APPENDIX E - SITE INSPECTION PHOTOS

North locked gated entrance with a no trespassing sign, looking south

North entrance at the Vermillion Parish Police Jury maintenance facility, looking south

E-l


-------
Monitoring well G-21, looking north

Fencing inside the Site at the adjacent GCVS site, looking northwest

E-2


-------
Unsecured monitoring well D-2

Secured monitoring well G-23

E-3


-------
Road and fence near the southernmost wells

E-4


-------
Calvin LeBouef Road, which runs through the northeastern corner of the Site

Monitoring well G-20, immediately south of Calvin LeBouef Road

E-5


-------
APPENDIX F - DETAILED DATA ANALYSIS

Table F-l: Historical Groundwater Data, 2008 to 2021

Arsenic

Well ID

1Q08

4QQ9

2Q1Q

4Q11

2Q12

2Q13

4Q14

2Q15

4Q16

2Q17

4Q18

2Q19

4Q20

2Q21

Screening level"

001

0.01

0.01

0.01

0.02

0.01

O.OJ

0.0J

0.01

O.OJ

a oi

O.OJ

0.01

O.OJ

OS

0.014

0.021

0.027

0.044

0.019

0.82

0.02

0.0183

0.022S

0.022S

0.0193

0.0139

NA

m

01

<0.01

<0.01

0.019

0.01

<0,01

<0.01

< 0.0050

0.00356

0.00995

0.00649

0.018

0.00962

NA

m

02

<001

<0.01

0.015

o-oii

<0.01

<0.01

0.0077

0.00694

0.0098

0.00827

0.00581

0.001731

NA

NA

D3

<0.01

<0.01

<0.01

<0.01

<0.01

<0.01

< 0.0050

0.00261

0.00188J

0.00329

0.00769

< 0.00109

NA

NA

04

<0.01

<0.01

<0.01

<0.01

<0.01

<0.01

<0.0010

0.00117 J

0.0014 J

0.00104

< 0.00109

< 0.00109

NA

NA

05

<0.01

<0.01

0.014

0.016

<0.01

0.01

0.0052

0.00538

0.0076

0.0061

0.0101

0.0058

NA

NA

GS

NA

NA

MA

NA

m

0.096

0.016

0.00379

0.00141 j

0.00407

0.00462 J

0.00312 J

NA

NA

620

<0.01

<0.01

<0.01

<0.01

<0.01

<0.01

< 0.0050

<0.0010

< 0.002

0.000412 J

0.00161 j

< 0 00109

NA

NA

G21

<0.01

<0.01

<0.01

<0.01

<0.01

<0.01

< 0.0050

<0.00250

<0.002

0.000431J

0.00270 J

<0.00109

< 0.00109

0.000557i

622

<0.01

<0.01

<001

<0.01

<0.01

——

< 0.0050

0.000839 j

< 0.002

0.000446j

0.00117 J

<0.00109

NA

NA

623

<0.01

<0.01

<0.01

<0.01

<0.01

<0.01

< 0.0050

0.000586 J

0.00111 J

0.000283J

< 0.00109

< 0.00109

NA

NA

Barium

Well 10

1QG8

4Q03

2Q10

4Q11

2012

2013

4014

2015

4016

2Q17

4Q18

2019

4Q20

2Q21

Screening Level"

2.0

2.0

2.0

2,0

2.0

2.0

2.0

2.0

2.0

2,0

2-0

2.0

2.0

2.0

OS

0.24

0.24

0.28

0.27

0.21

0.21

0.21

0.205

0,25

0.212

0.231

0.228

NA

NA

01

0.31

0.28

0.40

0.32

0.32

0.31

0.29

0.316

0.377

0.339

0.627

0.575

NA

NA

D2

0.25

0.24

0.26

0.25

0.28

0.29

0.27

0.231

0.257

0.229

0.262

0.431

NA

NA

03

0.25

0.26

0.39

0.41

0.45

0.21

0.3

0.296

0.322

0.492

0.584

0.0956

NA

NA

04

0.27

0.31

0.25

0.18

0.13

0.13

0.1

0.115

0.105

0.0909

0.1

0.17/

NA

NA

D5

0.21

0.54

0.38

0.30

0.23

0.24

0.19

0.224

0.245

0.247

0.545

0.291 J

NA

NA

68



NA

NA

NA

NA

1.93

0.49

0.216

0.177

0.165

0.187

0.185

NA

NA



C' 15

0.14

0.11

0.10

0.081

0.065

0.064

0.043

0,103

0.0371

0.0397

0.0282

NA

NA

621

2.34

2.18

2.42

2.20

2.11

2.22

2.21

2.41

2.14

1.79

1.04

0.616

0.263

0.322 J

622

0.35

0.34

0.32

0.29

0.32

0.36

0.32

0.312

0.315

0.249 J

0.24

0.225

NA

NA

623

0.065

0.54

0.065

0.038

0.11

0.93

0,074

0.0258

0.0184

0.0176

0.0173

0.0168

NA

NA

Chromium

welt ID

i»

4Q0S

2Q10

4Q11

2Q12

2Q13

4Q14

2Q15

4Q16

2Q17

4Q18

2019

4Q20

2Q21

Screening Level"

O.JO

O.JO

0 to

0 10

0.10

0.10

0,10

0.10

0.10

0.10

0.10

0.10

0,10

0.10

m

0.019

0.1

0.18

0.026

<0.01

<0.01

0.007

0.00206

0.0224

0.0458

0.00169 J

< 0.0014

NA

m

01

0.023

<0.01

0.04

< 0.01

<0.01

<0.01

0.018

0.00114 J

0.0085S

0.0391

0.0718

a.j«

NA

NA

02

<0.01

<0.01

0.047

<0.01

<0.01

<0.01

<0.00050

0.00139J

0.00276

0.00907

0.00247 J

0.00324 J

NA

NA

D3













0.1$

t.07

0.0651

..... i-JOS; :.,

0.969

0.0033 J

NA

NA

04

0.027

0.046

0-011

<0.01

<0.01

<0.01

< 0 0010

0.00151J

0.00141 J

0.00115 J

< 0.00140

< 0.0014

NA

NA

D5

0.037



0.034

0.029

<0.01

< 0.01

0.0093

0.0233

0.0732

0.0751

0.0797

0.0312

NA

NA

G8

NA

NA

NA

NA

NA

' "M	

0.02

0.00497

0.00136 J

< 0.000362

< 000140

< 0.0014

NA

NA

620

< 0.01

<0.01

<0.01

<0.01

<0.01

<0.01

< 0.0050

<0.0010

< 0.0025

0.00114 J

0.00162 i

< 0.0014

NA

NA

621

<0.01

<0.01

<0.01

<0.01

<0-01

<0.01

< 0 0050

<0.00250

< 0.0025

0.00047 i

< 0.00140

< 0.0014

<0.00140

< O.OOOS25

622

<0.01

<0.01

<0.01

<0.01

<0,01

<0.01

<0.0050

0.00164J

< 0.0025

<0.000362

<0.00140

< 0.0014

NA

NA

623

<0.01

<0.01

<0.01

<0.01

<0.01

<0.01

<0.0050

0,0009591

0.00372 J

0.00086 J

< 0.00140

<0.0014

NA

NA



Weil ID

1Q08

4Q09

2Q10

4Q11

2Q12

2Q13

4Q14

2Q1S

4Q16

2Q17

4Q18

2Q19

4Q20

2Q21

Screening level*

1.7

1.7

1.7

1.7

17

1.7

1.7

1.7

0.43

0.43

0.43

0.43

0.43

0.43

OS

0.56

0.59

0.75

0.50

0.60

0.47

0.53

0.424

0.639

0.54



m%

NA

NA

01

1.28

1.29

1.36

1.44

1.57

1.49

1.54

1.3!'

1.67

1.38

¦life '

zm ¦

NA

NA

D2

—

i

0.63

0.62

0.68

0.66

0.63

0.589

0.652

056

QJSS

0.153

NA

NA

03

0.12

0.15

0.53

0.13

0.52

<0.02

0.078

0.147

0 143

0.316



0.0257 J

NA

NA

04

0.064

0.20

0.088

0.027

<0.02

0.033

0.035

0.0372

0.CJ121 i

0.0VJ3

0.0231 J

0.0576

NA

NA

05

0.47

' -



1.3

0.86

0,62

0.32

0.53

0.642

0.848

-.. Sfti' . -



NA

NA

68

NA

NA

NA

NA

NA

-4M

:' 2M-:

0.795

r 0 (>03 J

0-17 j





NA

NA

620

0.08

<0 02

0.079

0.05

0.14

0.078

0.130

0.0247

0.127

1

0.0671

0.0546

0.0362 i

NA

NA

621





¦1&M-

	 W

' '

¦ B,m,

• MM'

8.71'



' ' 5.42 ' '

IK

2,49



1.S1

622

0.55

0.9



1.29

131

1.58

1.31

1.2*»

1.14

0.908

1.13

0*82

NA

NA

623





is®

" • 'iif	



' 11.3



1.12

0 1??

0.206

0.08/2

0.076.1

NA

NA

Notes:

* USF.PA Maximum Contaminant Level

b USEPA Region 6 Human Health Medium-Specific Screening Level
The results are shown In miliigram(s) per liter (mg/l).

Bold - Detected

< = Analyte was not; detected above the method detection limit

j = The analyte was positively identified; the associated numerical value is the approximate concentration of the snalyte in the sample.
NA » Not Analysed
NO = Not Detected

USEPA = U.S. Environmental Protection Agency







Total Parameters





Analyte

Arsenic

Barium

Chromium

Manganese



Screening Level

O.GiO*

2s

0.1"

i; -ir

Monitoring Well Location

Sample Date









6-21

11/10/2022

0.000506 J

0.216

< 0.0005

. 1.77

Motes:

* USEPA Maximum Contaminant Level

"USEPA Regional Screening Level

The results are shown in miiigramfs) per liter frng/Lj-

Bold = Detected

< = Analyte was not detected above the method detection limrt

j = The analyte was positivefy identified; the associated numerical value is The approximate concentration of the analyte in the
sample.

U5EPA = U.S. Environmental Protection Agency

Sources: Tabic 3 of the 2021 Annual Report and Table 2 of the 2022 Annual Report.

F-l


-------
Table F-2: Summary of Mann-Kendall Trend Analysis

Moftftomf W#lt Location £oo«teltfli of Variation

M«nn*Ktndall Statistics (s)

Confidence Factor (%)

M* Tr»nd



{Jpfffff Adwfiitfit

G S (Background)

I B7

9

88,1

No Tt«wJ

C, .'0

0.69

-33

m ?



a

0/4

m

99.6

OecwiiiBf

Lower Upper ChUot

U-l

0 68

-5

6'H

4uW#

OS

0 4%

-4

Sg.O

SI»W*

0-i

0 4*

2 3



0 B

T

70 0

Stable

0-S {84CfcgroufKi|

0 u

14

81 0

St»W»





b 8 ;BdCk^?Oiinrti

2,20

46

9^0





0M

59

W ?

D*cr»-»«ns

'\-2\

0

68

1hl)9 9

0«Cf«»sing

ti })

0 6-8

46

;oo

Oeereuioj

$ j „> \

0 6

¦4b

KK>

Oecfeisinj

r> 4

1.59

hQ

-99 9

O*o#»slng

tower Uppei Chrcot

h t

0*7

I

SO 0

SUM*

o i

1 66

j«

a?s

Mo T»f nd

D J

i ¦'.<>

• ;-i

91 5

CiotaW* D(ti«an|

0 S

1 2b

¦3

^ S

No Trend

• h ft.M ^ 3u« r

1 Sfc

;9

<>'/ 4

D«tr«»iini





 9

No Tr»d

G'JO

0 ss

lb



Oecrmtnj

f> i

0^

3 *

. 9



c, i;

0 i! ?

;*>



Smtmtunt

Cj ?

I V



9,1 9

Ottmmint

IM

0 60

I

»,) 1

No Trp.rv;

lower Upper Chicot

0 I

o an

n

% 4

lnaemm$

ov

;j m



i&.f

Stable

fj 1

;/



I.,? r

Swbie



0 M

I?

as 4

Stiiile

t! Ji tBttkgiouml?

0 IS

a

oi 1













yvnd^i Vv.r,

o"nj\j u-;ttg ¦'»i.i M.5!' o

;ki»





J> ^efp- (Sussed h;nl \.1 *r<<-

;s':«'*rbo£ d-Mea.-on U<,v>3

• J' ddt* i-M \h$

c

c
ce

1
%



•' Wn» kit Jf'MjtV,, 1', gl

vn**t iKim 40 t

< 'i'? •rvei-? ,v»> w

\*
-------
Table F-3: Water Well Search Results, 2022

Source: 2022 Annual Report.

F-3


-------
Figure F-l: Potentiometric Surface of the Upper Alluvium, 2016

DI Mirf mmm bwh cflltecicij on SWWIOtS

CCVS MKf K-wh cakcM an V2STI6 iMtCWJfi. 20161

Aeronymy

CCVS • Gulf Cony Vacuum SanKn	t

Sbk> (« DvuCtoe imilfr. LMteW Ctsjnftes. CWS.W. OS. UMM,
USPS, K t GMUfpni	CK KR ml^t. x* tm Gl$ iha Cmnva)

(Figure 4

2016 Alluvium Paterrtiometnc Surface Map
20 IS Fourth Quartet Progress Report
m a,,	DX Mud. Inc Super fund Sue. At #54J 6

Form* DomiSdtkmtomgm Fx&ty Abbnnte Loumuna

	 w-

Source: Figure 4 of the 2018 Fourth Quarter Progress Report. D.L. Mud, Inc. Superfund Site. Abbeville, Louisiana. Prepared
by Schlumberger. January 2019.

F-4


-------
Figure F-2: Potentiometric Surface of the Alluvium, 2018

14, »l

Rgwrc 3.

2011 Upper Alluvium Potentiometnc Suffice Map

20 f S Fourth Quarter Progress Report
01 Uud Inc Supertund Site A/MU16
former Doe/en Schkjmberger FeoUy Abbeville Lomtisnt



Source: Figure 3 of the 2018 Fourth Quarter Progress Report. D L Mud, Inc. Superfund Site. Abbeville, Louisiana. Prepared
by Schlumberger. January 2019.

LEGEM)

DL Mud Muvium Wei Location
S<1« Boundary

Site Features

2018 Groundwater Elevator Contax
fleet a&ove mean sea level)
2018 Groundwater Flow Direction

mmm



F-5


-------
Figure F-3: Water Well Survey, 2022

V

o
-------
APPENDIX G - APPLICABLE OR RELEVANT AND APPROPRIATE

REQUIREMENTS REVIEW

Groundwater

Although adverse impacts on the Site's groundwater due to site-related contamination were not identified in the
1994 ROD. the primary R AO requires that the potential for migration of hazardous substances into the
groundwater should be eliminated. Therefore. EPA did not establish remedial goals for groundwater. However, to
ensure that contaminants do not migrate into the groundwater, the 1994 ROD stipulated that groundwater
monitoring activities make comparisons with applicable MCLs as part of the remedy.

The MCL listed in the ROD for arsenic is more stringent. However, the PRP Group uses the most current MCLs
when evaluating the long-term groundwater monitoring data (Table G-l).

Table G-l: Groundwater ARARs Evaluation



1994 ROD MCLs"
(m«/L)

Cu rrent



coc

Standard/Screening
Level (m«j/L)b-c

Change

Arsenic

0.05

0.01

More stringent

Barium

2.0

2.0

None

Chromium

0.1

0.1

None

Manganese

-

0.430°

Not Applicable

Notes:







a.	Table 8 and 9 of the 1994 ROD. The monitoring performance goals used during the 2018 to 2022
monitoring period.

b.	Current federal Safe Drinking Water Act standards can be found at: https://www.era.gov/ground-

water-and-drinking-water/table-regulated-drinking-water-contaminants (accessed 10/10/2022).

c. Current monitoring reports rely on EPA's tap water RSL for manganese, which was verified at EPA's
RSL table located at http://www2.era.gov/risk/risk-based-screening-table-generic-tables (accessed

3/15/2023).

MCL not established.

The 1994 ROD selected pit closure requirements as the cleanup goals for subsurface soils. The criteria were
applied to the pit closure requirements contained in Louisiana Statew ide Order 29-B, Section 129.B.7 that govern
the storage, treatment and disposal of nonhazardous oil field wastes generated from the drilling and production of
oil and gas wells. EPA determined these regulations are relevant and appropriate for the subsurface soils
associated with the former surface impoundments areas. The current criteria are in LAC 43:XIX.313 and the
values have not changed since the 1994 ROD was signed.3

3 The current pit closure criteria for land treatment units were accessed 4/14/2023 at:
https://www.dnr.louisiana.gov/assets/OC/eng div/Rules/Onsite Disposal Criteria.txlt"

G-l


-------
APPENDIX H - SCREENING-LEVEL RISK REVIEW

To determine if soil cleanup goals established by Louisiana's Pit Closure requirements4 remain valid for the
current and future industrial use of the Site, the cleanup goals were compared to the EPA's 2022 RSLs. since the
RSLs incorporate current toxicity values and standard default exposure factors. The evaluation of soil cleanup
levels (Table H-l) demonstrates that the cleanup goals fall below or within EPA's risk management range of 1 x
10"6 to 1 x 10"4 The cleanup goals also are equivalent to a noncancer hazard quotient (HQ) less than EPA's target
HQ of 1. These results demonstrate that the subsurface cleanup goals remain valid. EPA established a surface soil
cleanup goal for barium of 5,400 mg/kg based on a residential exposure. The current residential soil RSL is
15,000 mg/kg. which is less stringent than the ROD cleanup goal indicating that the cleanup goal remains
protective for residential exposures.

Louisiana Pit Closure requirements established cleanup criteria for pH with an acceptable pH range of 6 to 9
standard units and criteria for oil and grease not to exceed less than 1% dry weight. These values do not have an
established RSL for comparison; therefore, a screening-risk review was not conducted for the two criteria.

Table H-l: Screening-Level Risk Evaluation of the Subsurface Soil Cleanup Goals

coc

1994 ROD
Subsurface
Soil Cleanup
Levels
(mg/kg)

Commercial RSL"
(mg/kg)

Cancer Riskh

Noncancer HQ1'

1 x SO"6Risk

HQ= 1.0

Arsenic

10



480

3.3.\ I Or"

0.02

Barium

40,000

NA

220,000

-

0.2

Cadmium

10

9300

100

1.1 x 10"9

0.1

Chromium (trivalent)'1

500

NA

1.8 x 106

-

0.0003

Lead

500

800e

<800

Mercury

10

NA

46

-

0.2

Selenium

10

NA

5,800

-

0.002

Silver

200

NA

5,800

-

0.03

Zinc

500

NA

350,000

-

0.001

Notes:











a. Current EPA RSLs. dated November 2022, are available at https://www.era.gov/risk/regional-screeniiig-

levels-rsls-generic-tables (accessed 12/26/2022).
b. The cancer risks were calculated using the following equation, because RSLs arc derived based on 1 x

10"6 risk: cancer risk = (cleanup level

cancer based RSL) x 10~6.





c. The noncancer HQ was calculated using the following equation: HQ
RSL.

= cleanup level

noncanccr-bascd

d. Prior studies in 2015 as cited in the approved 2020 O&M Plan, indicate that chromium is in the less toxic

trivalent form and was not identified as a site-related

contaminant.





c. RSL based on the EPA's blood lead model.







NA = toxicity value not applicable as this chemical is not a carcinogen per EPA
- Cancer risk could not be calculated due to absence of a toxicity value.



4 Established in Louisiana Statewide Order 29-B, Section 129.B.7 governing the storage, treatment and disposal of
nonhazardous oil field wastes generated from the drilling and production of oil and gas wells.

H-l


-------
APPENDIX I - INTERVIEW FORMS

D.L. MUD, INC. SUPERFIJND SITE
FIVE-YEAR REVIEW INTERVIEW FORM

Site Name: D.L. Mud. Inc.

EPA ID: LAD981058019

Interviewer name:

Interviewer affiliation:

Subject name: Destin Hooks

Subject affiliation: LDEQ

Subject contact information: destin.hooks@ia.gov 7 337-262-5572

Interview date: 3/9/2023	Interview time

Interview' format (circle one): In Person	Phone	Mail	Email X Other:

Interview category: State Agency	

1.	What is your overall impression of the project, including cleanup, maintenance and reuse activities (as
appropriate)?

My impression of the project is that the Site is being monitored, while natural attenuation takes place, in order
to ensure that contaminants are contained in order to protect human health and the environment.

2.	What is your assessment of the current performance of the remedy in place at the Site?

The current annual sampling of groundwater is adequate to ensure site conditions do not deteriorate.

3.	Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial activities
from residents in the past five years?

No.

4.	Has your office conducted any site-related activities or communications in the past five years? If so, please
describe the purpose and results of these activities.

Yes. Inspections of the Site occur to observe site conditions, specifically to ensure that site fencing and
monitoring wells are maintained in good condition. Annual inspection and monitoring reports, submitted by the
PRP Group, are reviewed and commented on if necessary. Finally, inspections and/or contact with site
management is conducted prior and after hurricane or extreme weather events that may affect site conditions.

5.	Are you aware of any changes to state laws that might affect the protectiveness of the Site's remedy?

No.

6.	Are you comfortable with the status of the institutional controls at the Site? If not, what are the associated
outstanding issues?

Yes.

7.	Are you aware of any changes in projected land use(s) at the Site?

No.

8.	Do you have any comments, suggestions or recommendations regarding the management or operation of the
Site's remedy?

No. Annual monitoring of groundwater at the Site is sufficient currently.

1-1


-------
9. Do you consent to have your name included along with your responses to this questionnaire in the FY R report?
Yes.

1-2


-------
D.L. MUD, INC. SUPERFIJND SITE

	FIVE-YEAR REVIEW INTERVIEW FORM	

Site Name: D.L. Mud. Inc.	

EPA ID: LAD981058019		

Interviewer name:	Interviewer affiliation:	

Subject name: Dawn Townsen	 Subject affiliation: Jacobs Engineering Group

Subject contact information: Da.wn.Townsen@Ja.cobs.com	

Interview' date: 3/6/2023	Interview' time: 10:00 a.m. CT	

Interview' format (circle one): In Person	Phone	Mail	Email X Other:	

Interview category: O&M Contractor	

1.	What is your overall impression of the project, including cleanup, maintenance and reuse activities (as
appropriate)?

The remedy is effective and continues to be protective of human health and the environment in accordance
with the RAOs for the Site. A deed notice previously filed on September 29, 2011, restricts land use to
industrial activities and prohibits drilling and installation of wells. O&M activities consist of an annual site
inspection, limited vegetation clearing, and annual collection and analysis of groundwater samples. Barium
(the only site-specific COC) in groundwater has remained less than the MCL for the past 6 years. Fencing
surrounds the Site, and neither vandalism nor evidence of trespassing have been observed over the past 25
years.

2.	What is your assessment of the current performance of the remedy in place at the Site?

The remedy has performed as intended.

3.	What are the findings from the monitoring data'.' What are the key trends in contaminant levels that are being
documented over time at the Site?

Refer to the 2022 Annual Report, D.L. Mud, Inc. Superfund Site, Abbeville, Louisiana submitted to the
[USEPA] for review on January 30, 2023. The only site-related COC in groundwater (barium) has remained
below the MCL in samples collected from the approved monitoring network over the past 6 years.

4.	Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and activities.
Alternatively, please describe staff responsibilities and the frequency of site inspections and activities if there
is not a continuous on-site O&M presence.

There is not a continuous onsite O&M presence. Site inspections, maintenance as needed (mowing to access
well G-21 and fencing), and groundwater sampling are currently completed annually in accordance with the
2020 Amended O&M Plan approved by the [LDEQ] and USEPA on June 5, 2020.

5.	Have there been any significant changes in site 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 Amended O&M Plan approved by LDEQ and USEPA on June 5, 2020, optimized the monitoring
network by reducing the number of wells sampled from 11 to one. Approval of the Amended O&M Plan by
LDEQ and USEPA also reduced the frequency of vegetation clearance and inspections from quarterly to
annually. Optimized O&M activities have continued to ensure site conditions remain protective of human
health and the environment, and the existing remedy remains effective.

6.	Have there been unexpected O&M difficulties or costs at the Site since start-up or in the last five years? If so,
please provide details.

1-3


-------
There have been no unexpected difficulties or costs at the Site. In addition to routine O&M activities, site
inspections were conducted after major storm events at EPA's request. Post-storm inspections did not indicate
any potential concerns or need for additional O&M.

7.	Have there been opportunities to optimize O&M activities or sampling efforts? Please describe changes and
any resulting or desired cost savings or improved efficiencies.

Refer to response to question No. 5 for optimization of O&M activities. The optimizations resulted in cost
savings.

8.	Do you have any comments, suggestions or recommendations regarding O&M activities and schedules at the
Site?

The Site has remained protective of human health and the environment, and barium in groundwater has
remained below the MCL over the past 6 years. It is recommended to cease O&M activities and consider the
site for closure as stated in the 2021 Annual Report, D.L. Mud, Inc. Superfund Site, Abbeville, Louisiana
submitted to USEPA on January 25, 2022.

9.	Do you consent to have your name included along with your responses to this questionnaire in the FY R
report?

Yes.

1-4


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D.L. M1JD, INC. SIJPERFUND SITE
FIVE-YEAR REVIEW INTERVIEW FORM

Site Name: D.L. Mud. Inc.

EPA ID: LAD981058019

Interviewer name:

Interviewer affiliation:

Subject name: Mayor Roslvn White

Subject affiliation: Mayor, City of Abbeville

Subject contact information:mavor@citvofabbeville.net

Interview' date: 3/14/2023	 Interview time: 3:54 p.m.

Interview location: City Hall

Interview' format (circle one): In Person	Phone	Mail	Email X Other:

Interview category: Local Government	

1.	Are you aware of the former environmental issues at the Sites and the cleanup activities that have taken
place to date'.'

Yes, somewhat through self-research and subsequent discussions with LDEQ.

2.	Do you feel well-informed regarding the Sites' activities and remedial progress? If not, how might EPA
convey site-related information in the future'.'

I have taken the time to research these sites and speak with DEQ/EPA, I do not think others are as

informed. Perhaps site signage markers with information as well as annual reporting to local government
if it is not already happening.

3.	Have there been any problems with unusual or unexpected activities at the Sites, such as emergency

response, vandalism or trespassing?

Not that I am aware of.

4.	Are you aware of any changes to state laws or local regulations that might affect the protectiveness of

the Sites' remedy?

Not that I am aware of.

5.	Are you aware of any changes in projected land use(s) at the Sites?

Not that I am aware of.

6.	Has EPA kept involved parties and surrounding neighbors informed of activities at the Sites?

I am not sure because I am new to the office of Mayor.

How can EPA best provide site-related information in the future'.'

Annual meeting with local officials and/or surrounding property holders.

7.	Do you have any comments, suggestions or recommendations regarding the project'.'

Report states: Following construction of the site's remedy, EPA took the Site off the NPL in July 2001.

Does this mean the sites can be put back into use?

1-5


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8. Do you consent to have your name included along with your responses to this questionnaire in the FYR
report'.'

Yes.

1-6


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D.L. MUD, INC SUPERFUND SITE
FIVE-YEAR REVIEW INTERVIEW FORM

Site Name: D.L. Mud, Inc.

EPA ID: LAD981058019

Interviewer name:

Interviewer affiliation:

Sub ject name: Mr. Keith Roy

Subject affiliation: Vermilion Parish Administrator

Subject contact information:

Interview date: 2/16/2023

Interview time:

Interview' format (circle one): In Person

Phone

Mail

Email X Other:

Interview category: Local Government

1.	Are you aware of the former environmental issues at the Site and the cleanup activities that have taken place
to date'.'

No.

2.	Do you feel well-informed regarding the Site's activities and remedial progress'.' If not. how might EPA
convey site-related information in the future'.'

No. Send information to the email used to send this survey.

3.	Have there been any problems with unusual or unexpected activities at the Site, such as emergency response.

vandalism, or trespassing'.'

Unknown.

4.	Are you aware of any changes to state laws or local regulations that might affect the protectiveness of the
Site's remedy'.'

No.

5.	Are you aw are of any changes in projected land use(s) at the Site'.'

No.

6.	Has EPA kept involved parties and surrounding neighbors informed of activities at the Site'.' How can EPA
best provide site-related information in the future'.'

Unknown.

7.	Do you have any comments, suggestions, or recommendations regarding the project'.'

No.

8.	Do you consent to have your name included along w ith your responses to this questionnaire in the FYR
report'.'

Yes.

1-7


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D.L. MUD, INC SUPERFUND SITE
FIVE-YEAR REVIEW INTERVIEW FORM

Site Name: D.L. Mud, Inc.

EPA ID: LAD981058019

Interviewer name: CIC Tom Ruiz

Interviewer affiliation: EPA

Sub ject name: Deputy

Subject affiliation: Vermilion Parish Sheriffs Office

Subject contact information:

Interview date: February 28, 2023	 Interview time: 12:00 p.m.

Interview location: Sheriff"s Offices

Interview' format (circle one): In Person X Phone	Mail	Email	Other:

Interview category: Local Government	

1.	Are you aware of the former environmental issues at the Sites and the cleanup activities that have taken place
to date'.'

Yes. grew up in the area and knew about it a long time ago before cleanup.

2.	Do you feel well-informed regarding the Sites" activities and remedial progress'.' If not. how might EPA
convey site-related information in the future'.'

Not applicable.

3.	Have there been any problems with unusual or unexpected activities at the Sites, such as emergency response.

vandalism or trespassing'.'

None.

4.	Are you aware of any changes to state laws or local regulations that might affect the protectiveness of the
Sites" remedy'.'

Not applicable.

5.	Are you aw are of any changes in projected land use(s) at the Sites'.'

Not applicable.

6.	Has EPA kept involved parties and surrounding neighbors informed of activities at the Sites'.' How can EPA
best provide site-related information in the future'.'

Not applicable.

7.	Do you have any comments, suggestions or recommendations regarding the project'.'

There have been no issues noted from the Sheriff"s office over the last five years.

1-8


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APPENDIX J - EJ SCREEN REPORT

A EPA

United States
Environmental Protection
Agency

EJScreen Report (Version 2.11)

1 mile Ring Centered at 29.958497,-92.185694, LOUISIANA, EPA Region 6
Approximate Population: 326
Input Area (sq. miles): 3.14
D.L. Mud

Selected Variables

State
Percentile

USA
Percentile

Environmental Justice Indexes

Particulate Matter 2.5 EJ index

17

38

Ozone EJ index

4

7

Diesel Particulate Matter EJ index*

10

14

Air Toxics Cancer Risk EJ index*

11

34

Air Toxics Respiratory HI EJ index*

16

36

Traffic Proximity EJ index

2

2

Lead Paint EJ index

18

15

Superfund Proximity EJ index

19

15

RMP Facility Proximity EJ index

21

25

Hazardous Waste Proximity EJ index

20

22

Underground Storage Tanks EJ index

24

31

Wastewater Discharge EJ index

19

29

EJ Indexes - The ~ indexes help users screen for potential EJ concerns. To do this, the EJ index combines data on low income and people of color populations
with a single environmental indicator.





EJ Index for the Selected Area Compared to All People's Blockgroups in the State/US



J

I

¦ I 11 d

V.









\W



•V,

"V

%>

EJ Indexes

v, X
, X. \ \t



'x ,%>V
% x

state Fe'centiie tl USA Percent le

*Diesel particular matter, air toxics cancer risk, and air toxics respiratory hazard index are from the EPA's Air Toxics Data Update, which is the Agency's ongoing,
comprehensive evaluation of air toxics in the United States. This effort aims to prioritize air toxics, emission sources, and locations of interest for further study. It
is important to remember that the air toxics data presented here provide broad estimates of health risks over geographic areas of the country, not definitive risks
to specific individuals or locations. Cancer risks and hazard indices from the Air Toxics Data Update are reported to one significant figure and any additional
significant figures here are due to rounding. More information on the Air Toxics Data Update can be found at: https://www.epa.gov/haps/air-toxics-data-update.

May 04, 2023

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«Q.gpy^emgj»SS&Protects	EJScreen Report (Version 2.11)

1 mile Ring Centered at 29.958497,-92.185694, LOUISIANA, EPA Region 6

Approximate Population: 326
Input Area (sq. miles): 3.14
D.L. Mud

Sites reporting to EPA

Superfund NPL

0

Hazardous Waste Treatment, Storage, and Disposal Facilities (TSDF)

0

May 04. 2023	2/4

J-2


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c^FPA	Protectren	EJScreen Report (Version 2.11)

1 mile Ring Centered at 29.958497.-92.185694, LOUISIANA, EPA Region 6
Approximate Population: 326
Input Area (sq. miles): 3.14
D.L. Mud

Selected Variables

Value

State

%ile in

USA

%ile in





Avg.

State

Avg.

USA

Pollution and Sources

Particulate Matter 2.5 (ng/m3)

8.82

9.2

28

8.67

57

Ozone (ppb)

34.5

37

4

42.5

9

Diesel Particulate Matter* (ng/m3)

0.106

0.297

13

0.294

<50th

Air Toxics Cancer Risk* (lifetime risk per million)

30

40

52

28

80-90th

Air Toxics Respiratory HI*

0.4

0.45

62

0.36

80-90th

Traffic Proximity (daily traffic count/distance to road)

0.74

640

2

760

2

Lead Paint (%Pre-1960 Housing)

0.037

0.2

26

0.27

23

Superfund Proximity (site count/km distance)

0.022

0.076

33

0.13

20

RMP Facility Proximity (facility count/km distance)

0.16

0.96

30

0.77

30

Hazardous Waste Proximity (facility count/km distance)

0.15

1.4

28

2.2

26

Underground Storage Tanks (count/km2)

0,26

2.2

33

3.9

34

Wastewater Discharge (toxicity-weighted concentration/m distance)

0.00076

0.37

39

12

46

Socioeconomic Indicators

Demographic Index

14%

41%

13

35%

19

Supplemental Demographic Index

12%

17%

28

15%

45

People of Color

18%

42%

32

40%

36

Low Income

10%

38%

10

30%

17

Unemployment Rate

2%

7%

38

5%

34

Limited English Speaking Households

0%

2%

0

5%

0

Less Than High School Education

23%

14%

76

12%

84

Under Age 5

8%

7%

71

6%

77

Over Age 64

7%

15%

19

16%

15

Low Life Expectancy

22%

22%

48

20%

74

~Screen is a screening tool for pre-decisional use only. It can help identify areas that may warrant additional consideration, analysis, or outreach. It does not
provide a basis for decision-making, but it may help identify potential areas of EJ concern. Users should keep in mind that screening tools are subject to substantial
uncertainty in their demographic and environmental data, particularly when looking at small geographic areas. Important caveats and uncertainties apply to this
screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see
~Screen documentation for discussion of these issues before using reports. This screening tool does not provide data on every environmental impact and
demographic factor that may be relevant to a particular location. EJScreen outputs should be supplemented with additional information and local knowledge
before taking any action to address potential ~ concerns.

May 04, 2023	3/4

J-3


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xv EPA Environmental Protection	EJScreen Report (Version 2.11)

1 mile Ring Centered at 29.958497,-92.185694, LOUISIANA, EPA Region 6
Approximate Population: 326
Input Area (sq. miles): 3.14
D.L. Mud

Selected Variables

State
Percentile

USA
Percentile

Supplemental Indexes

Particulate Matter 2.5 Supplemental Index

25

58

Ozone Supplemental Index

3

10

Diesel Particulate Matter Supplemental Index*

11

18

Air Toxics Cancer Risk Supplemental Index*

18

58

Air Toxics Respiratory HI Supplemental Index*

26

61

Traffic Proximity Supplemental Index

2

2

Lead Paint Supplemental Index

18

16

Superfund Proximity Supplemental Index

28

21

RMP Facility Proximity Supplemental Index

28

36

Hazardous Waste Proximity Supplemental Index

26

31

Underground Storage Tanks Supplemental Index

31

39

Wastewater Discharge Supplemental Index

29

45

Supplemental Indexes - The supplemental indexes offer a different perspective on community-level vulnerability. They combine data on low-income, limited
English speaking, less than high school education, unemployed, and low life expectancy populations with a single environmental indicator.



Supplemental Index for the Selected Area Compared to All People's Blockgroups in the State/US

I

I

I ill

*r-



"X,.

'%

'
-------