HAZARD RANKING SYSTEM (HRS)
DOCUMENTATION RECORD - COVER SHEET

Name of Site:	Exide Baton Rouge

SEMS ID No.:	LAD008184137

Contact Persons

Site Investigation:	Michelle Delgado-Browa NPL Coordinator. EPA Reg.6

(214) 665-3154
(Telephone)

Documentation Record:	Michelle Delgado-Brown. NPL Coordinator. EPA Reg.6

(214) 665-3154
(Telephone)

Pathways. Components, or Threats Not Scored

1) Ground Water Pathway: Analytical results from groundwater samples collected by EPA in February 2023
from monitoring wells downgradient of site sources indicates the presence of several metals at concentrations
significantly above concentrations detected in the background monitoring well. The nearest known public supply
well is located approximately 0.62 mile from the facility and is approximately 300 feet deep [Ref. 4, p. 13; 7, pp.
68-72; 28, pp. 1,2], Evaluation of the ground water migration pathway would not significantly affect the listing
decision [Ref. 1, Sec. 2.2.3],

2)	Surface Water Pathway: Ground Water to Surface Water Migration Component: The overland/flood

migration component of the Surface Water Migration Pathway has been scored for the Human Food Chain and
Environmental Threats. The Ground Water to Surface Water Migration component has not been scored. Based
on information available at this time, evaluation of this component would not significantly affect the listing
decision [Ref. 1, Sec. 2.2.3],

3)	Soil Exposure and Subsurface Intrusion Pathway: Evaluation of the Soil Exposure and Subsurface Intrusion
pathway would not significantly affect the listing decision [Ref. 1, Sec. 2.2.3],

4)	Air Migration Pathway: Evaluation of the air migration pathway would not significantly affect the listing
decision [Ref. 1, Sec. 2.2.3],

These pathways and components are of concern to the U.S. Environmental Protection Agency (EPA) and may be considered
during a future evaluation.


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Name of Site:

EPA Site ID No.:

EPA Region:

Date Prepared:

Street Address of Site*:

City, County, State, and Zip:

HRS DOCUMENTATION RECORD

Exide Baton Rouge

LAD008184137

6

September 2023

2400 Brooklawn Drive

Baton Rouge, East Baton Rouge Parish,

Louisiana 70807 [Ref. 3, p. 2]

General Location within the State: Exide Baton Rouge is located in southeastern

Louisiana, near the east bank of the Mississippi River
(See HRS Documentation Record Figure 1).

Topographic Map(s):

Latitude/Longitude *:

The following U.S. Geological Survey (USGS) 7.5-minute series topographic
map was used in locating the site: Scotlandville Quadrangle, Louisiana (2020)
[Ref. 21 p. 1],

+30.586168, -91.245026

Latitude and Longitude coordinates correspond to contaminated soil sample locationEBR-S04-12-20230207-51;
identified in Figure 2 as EBR-S04 [Figure 2; Ref. 32, p. 2],

*The street address, coordinates, and contaminant locations presented in this HRS documentation record identify the
general area where the site is located. They represent one or more locations EPA considers to be part of the site
based on the screening information EPA used to evaluate the site for NPL listing. EPA lists national priorities among
the known "releases or threatened releases" of hazardous substances; thus, the focus is on the release, not precisely
delineated boundaries. A site is defined as where a hazardous substance has been "deposited, stored, disposed, or
placed, or has otherwise come to be located." Generally, HRS scoring and the subsequent listing of a release merely
represent the initial determination that a certain area may need to be addressed under CERCLA. Accordingly, EPA
contemplates that the preliminary description of facility boundaries at the time of scoring will be refined as more
information is developed as to where the contamination has come to be located.

Scores

Air Pathway	Not Scored

Ground Water Pathway1	Not Scored

Soil Exposure and Subsurface Intrusion Pathway	Not Scored

Surface Water Pathway	100.00

HRS SITE SCORE 50.00

^'Ground water" and "groundwater" are synonymous; the spelling is different due to "ground water" being codified
as part of the HRS, while "groundwater" is the modern spelling.

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WORKSHEET FOR COMPUTING HRS SITE SCORE

Ground Water Migration Pathway Score (Sgw) (from
Table 3-1, line 13)

&

NS NS

2a. Surface Water Overland/Flood Migration Component	100.00 10,000

(from Table 4-1, line 30)

2b. Ground Water to Surface Water Migration Component	NS	NS

(from Table 4-25, line 28)

2c. Surface Water Migration Pathway Score (Ssw)	NS NS

(Enter the larger of lines 2a and 2b as the pathway score)

3a. Soil Exposure Component Score (Sse)	NS NS

(from Table 5-1, line 22)

3b. Subsurface Intrusion Component Score (Sssi)	NS NS

(from Table 5-11, line 12)

3c. Soil Exposure and Subsurface Intrusion Pathway Score (Ssessi)	NS NS

Enter the sum of lines 3a and 3b as the pathway score.

4. Air Migration Pathway Score (Sa)	NS NS

(from Table 6-1, line 12)

Total of Sgw2 + Ssw2 + Ssessi2 + Sa2	10,000

6. HRS Site Score: Divide the value on line 5 by 4 and take the square	50.00

root.

Notes:

S	Score

S2	Score squared

NS	Not scored

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TABLE 4-1. SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET

DRINKING WATER THREAT - Not Scored (NS)

Factor Categories and Factors	Maximum Value	Value Assigned

Likelihood of Release

1.	Observed Release

2.	Potential to Release by Overland Flow:

2a. Containment
2b. Runoff

2c. Distance to Surface Water
2d. Potential to Release by Overland Flow
(lines 2a[2b + 2c])

3.	Potential to Release by Flood:

3 a. Containment (Flood)

3b. Flood Frequency
3c. Potential to Release Flood

(lines 3a x 3b)

4.	Potential to Release
(lines 2d + 3c, subject to a maximum of 500)

5.	Likelihood of Release (higher of lines 1 and 4)

Waste Characteristics

6.	Toxicity/Persistence	a	NS

7.	Hazardous Waste Quantity	a	NS

8.	Waste Characteristics
(Toxicity/Persistence x Hazardous Waste
Quantity, then assign a

value from Table 2-7)	100	NS

550

10
25
25

500

10
50

500

500
550

550

NS
NS
NS

NS

NS
NS

NS

NS
550

Targets

9.	Nearest Intake

10.	Population

10a. Level I Concentrations
10b. Level II Concentrations
10c. Potential Contamination
lOd. Population
(lines 10a + 10b + 10c)

11.	Resources

12.	Targets (lines 9 + lOd +11)
Drinking Water Threat Score

13. Drinking Water Threat Score
[(lines 5 x 8 x 12)/82,500
subject to a maximum of 100]

50

NS

b
b
b

NS
NS
NS

b
5
b

NS
NS
NS

100

NS

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TABLE 4-1. SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET

(CONTINUED)

HUMAN FOOD CHAIN THREAT

Factor Categories and Factors	Maximum Value	Value Assigned

Likelihood of Release

14.	Likelihoo d of Release

(Same value of line 5)	550	550

Waste Characteristics

15.	Toxicity/Persistence/Bioaccumulation	a	5x10-

16.	Hazardous Waste Quantity	a	10.000

17.	Waste Characteristics

(Toxicity/Persistence/Bioaccumulation x Hazardous Waste
Quantity, then assign a

value from Table 2-7)	1,000	1.000

Targets

18.	Food Chain Individual

19.	Population
19a. Level I Concentrations
19b. Level II Concentrations
19c. Potential Human Food Chain Contamination
19d. Population

(lines 19a + 19b + 19c)

20.	Targets (lines 18 + 19d)

Human Food Chain Threat Score

21.	Human Food Chain Threat Score
[(lines 14 x 17 x 20)/82,500
subject to a maximum of 100]	100	100.00

50	20

b	0

b	0

b	0.00000003

b	0.00000003

b	20.00000003

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TABLE 4-1. SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT

SCORESHEET (CONTINUED)

ENVIRONMENTAL
THREAT

Factor Categories and Factors	Maximum Value	Value Assigned

Likelihood of Release

22.	Likelihood of Release

(Same value of line 5)	550	550

Waste Characteristics

23.	Ecosystem Toxicity/PersistenceBioaccumulation	a	5xl08

24.	Hazardous Waste Quantity	a	10.000

25.	Waste Characteristics

(Ecosystem Tox./Persistence x Bioaccumulation x
Hazardous Waste Quantity, then assign a

value from Table 2-7)	1,000	1.000

Targets

26.	Sensitive Environments

26a. Level I Concentrations	b	0

26b. Level II Concentrations	b	25

26c. Potential Contamination

26c. Potential Contamination	b	NS

26d. Sensitive Environments

(lines 26a + 26b + 26c)	b	25

27.	Targets (value from line 26d)	b	25

Environmental Threat Score

28.	Environmental Threat Score
[(lines 22 x 25 x 27)/82,500

subject to a maximum of 60]	60	60.00

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORE FOR A WATERSHED

29.	Watershed Score0
[(Lines 13+21+28),

subject to a maximum of 100]	100	100.00

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORE

30.	Component Score0
(Highest score from Line 29
for all watersheds evaluated,

subject to a maximum of 100)	100	100.00

a Maximum value applies to waste characteristics category.
b Maximum value not applicable.

0 Do not round to nearest integer.

NS = Not Scored

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NOTE TO THE READER

1. Hazardous substances are often listed by the names used in the Superfund Chemical Data Matrix
(SCDM) [Ref. 2],

HRS Documentation Record	g	Exide Baton Rouge

LAD008184137


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FTGTTRFS

Figure 1	Site Location Map

Figure 2	Site and Source Location Map

Figure 3	Sediment Location Map (February/March 2023)

Figure 3 A	Zone of Contamination Map

Figure 4	15-Mile Surface Water Pathway Map

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FIGURE REFERENCE SHEET

Figure 1: Site Location Map

•	Basemap: Esri World Street Maps; used by EPA with Esri's permission.

•	Map annotated by EPA START to depict site location.

>	Ref. 4, p. 52

>	Ref. 5, p. 29

>	Ref. 32. p. 2

Figure 2: Site and Source Map

•	Basemap: Esri World Imagery; used by EPA with Esri's permission.

•	Hazardous Waste Pile areas calculated using ArcGIS Pro Calculate Geometry Tool.

•	Map annotated by EPA START to depict approximate reference point, site features and sources,
groundwater, and soil sampling locations, hazardous waste pile area calculations, facility boundaries, and
neighboring properties,

>	Ref. 4, p. 52

>	Ref. 22, p. 42

>	Ref. 28, p. 2

>	Ref. 32, p. 1-2

>	Ref. 35, p. 1-2

Figure 3: Sediment Sample Location Map (February/March 20231

•	Basemap: Esri World Imagery; used by EPA with Esri's permission.

•	U.S. Fish and Wildlife Service (USFWS) National Wetlands Inventory (NWI).

•	Map annotated by EPA START to depict [EPA Expanded Site Inspection Sampling Results].

>	Ref. 7, pp. 18-21, 48, 83, 89-90, 110-113, 140, 175, 181-182

>	Ref. 8, pp. 58, 76

>	Ref. 9, pp. 60-66, 74, 76

>	Ref. 10, pp. 3-5, 7, 20, 25

>	Ref. 11, pp. 3-10,20, 22

>	Ref. 12, pp. 8, 20

>	Ref. 22, p. 42

>	Ref. 28, pp. 3, 4

>	Ref. 32, pp. 1-2

>	Ref. 38, p. 1

Figure 3 A: Zone of Contamination Map

•	Basemap: Esri World Imagery; used by EPA with Esri's permission.

•	U.S. Fish and Wildlife Service (USFWS) National Wetlands Inventory (NWI).

•	Map annotated by EPA START to depict Level II Zone of Contamination and Level II Actual Contamination.

>	Ref. 22, p. 42

>	Ref. 32, p. 1

>	Ref. 38, p. 1

>	Section 4.1.4.3

Figure 4: 15-Mile Surface Water Migration Pathway Map

•	Basemap: Esri World Imagery; used by EPA with Esri's permission.

•	U.S. Fish and Wildlife Service (USFWS) National Wetlands Inventory (NWI).

•	Map annotated by EPA START to depict surface water pathway.

>	Ref. 22, p. 42

>	Ref. 38, pp. 1-4

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REFERENCES CITED

1.	U.S. Environmental Protection Agency (EPA). Hazard Ranking System, Title 40 Code of Federal Regulations (CFR)
Part 300, Appendix A (55 Federal Register [FR] 51583, Dec. 14, 1990, as amended at 82 FR 2779, Jan. 9, 2017; 83
FR 38037, Aug. 3, 2018), as published in the Code of Federal Regulations on July 1, 2019, with two attachments.
Attachment A: Federal Register Vol. 55, No. 241. December 14, 1990. Hazard Ranking System Preamble.
Attachment B: Federal Register Vol. 82, No. 5, January 9, 2017. Addition of a Subsurface Intrusion Component to
the Hazard Ranking System Preamble. [197 pages]

2.	EPA. Superfund Chemical Data Matrix (SCDM) Query: Factor Values and Benchmarks. Surface Water Pathway.
July 2022. Query accessed August 21, 2023. A complete copy of SCDM is available at
http://www.epa.gov/superfund/superfund-chemical-data-matrix-scdm. [43 pages]

3.	EPA. Superfund Enterprise Management System (SEMS). Site Information: Exide Baton Rouge. EPA ID:
LAD008184137.	Accessed	and	downloaded	from
https://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0600387 on August 14, 2023. [1 page]

4.	ENVIRON International Corporation (ENVIRON). RFI Implementation Risk Evaluation / Corrective Action
Program Investigation and Report. Exide Technologies - Baton Rouge Facility. October 2009. [458 pages]

5.	Stratman, Paul, Advanced Geoservices. Letter from Paul Stratman. Consultant. Letter to Keith Williams. Louisiana
Department of Environmental Quality (LDEO). Re: Class 1 Permit Modification. Revised Closure Plan. Exide
Technologies. LLC Baton Rouge Facility. AI#1396/LAD008184137/PER20170004: with attached Revised Closure
Plan. July 17, 2017. [661 pages]

6.	Stratman, Paul, Advanced Geoservices. Letter to Estuardo Silva. Administrator. LDEO. RE: Semi-Annual
Groundwater Report. Post Closure Hazardous Waste Piles. LAD008184137: AI #1396. Exide Environmental Trust
Site. East Baton Rouge Parish. March 7, 2022. [125 pages]

7.	EPA, Region 6 Laboratory. Final Analytical Report. Exide Baton Rouge. Project # 23 SF026. Work Orders 2302002.
2302003. 2302005. 2302006. 2302007. March 6, 2023. [366 pages]

8.	Pace Analytical. Analytical Report. Weston Solutions Inc. - Baton Rouge. LA. Sample Delivery Group L1597531.
Project No. 20600.016.001.1540.0. March 27, 2023. [199 pages]

9.	Pace Analytical. Analytical Report. Weston Solutions Inc. - Baton Rouge. LA. Sample Delivery Group L1597545.
Project No. 20600.016.001.1540.0. March 27, 2023. [227 pages]

10.	Weston Solutions, Inc. (WESTON®). Data Quality Assurance Review. Exide Baton Rouge ESI. SPG Number.
L1597531. April 17, 2023. [25 pages]

11.	WESTON. Data Quality Assurance Review. Exide Baton Rouge ESI. SPG Number L1597545. April 17, 2023.
[28 pages]

12.	EPA. Using Qualified Pata to Pocument and Observed Release and Observed Contamination (Pirective 9285.7-
89FS). November 2022. [20 pages]

13.	WESTON, Region 6 Superfund Technical Assessment and Response Team IV (START IV). Exide Baton Rouge
ESI Site Logbook. November 15, 2022 - March 22, 2023. [11 pages]

14.	PPM Consultants. Confirmation Soil Sampling Report. Exide Technologies. Inc.. Baton Rouge Recycling Center.
LPEO Agency Interest No. 1396. PPM Project No. 590801. March 2016. [38 pages]

HRS Documentation Record

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REFERENCES CITED (continued)

15.	O'Rourke, Kevin, and Stratman, Paul. Advanced Geoservices Corp. Letter to Lina Saale. LDEO. RE: Supplemental
Closure Plan Sampling Results - November 2015. Exide Technologies. Baton Rouge. February 1,2016. [64 pages]

16.	Studebaker, N. WESTON. Soil and Sediment Boring Logs. Project: Exide Baton Rouge ESI. Baton Rouge. LA.
February 6-9, 2023. [25 pages]

17.	Hadwin, E. WESTON. Sediment Boring Logs. Project: Exide Baton Rouge ESI. Baton Rouge. LA. March 21,
2023. [8 pages]

18.	FishAnywhere.com. Baton Rouge Fishing Charters and Guides. Accessed and downloaded from
https://fishanvwhere.com/charters-guides/south-louisiana-fishing-charters?date=05%2F13%2F2023 on May 10,
2023. [9 pages]

19.	U.S. Geological Survey (USGS). Stream Flow Data for Mississippi River at Baton Rouge. LA - 07374000.
Accessed	and	downloaded	from	https://waterdata.usgs.gov/monitoring-
location/07374000#parameterCode=00060&period=P365D on May 11, 2023. [4 pages]

20.	EPA. Petro Processors. Inc. Superfund Update. November 10, 1994. [6 pages]

21.	U.S. Department of the Interior, USGS. Scotlandville. Louisiana Quadrangle. 7.5-minute Series. 2018. [1 map]

22.	Edwards, Jody. Tetratech. Letter to Kirbv Biggs (EPA). Subject: Final Technical Memorandum. Focused Technical
Review of Exide Technologies LLC: Baton Rouge Recycling Center. Baton Rouge. Louisiana. EPA Contract No.
68-HE-051. EPA Task Order No. 68HE0523F0017. EPA Task Order Line Item No. 68HE0519D0005. Document
Tracking No. 1552a. April 25, 2023. [173 pages]

23.	Advanced Geoservices. Letter of Transmittal to LDEO RE: Exide Baton Rouge Conceptual Design, with attached
Conceptual Design Letter, July 21, 2016. [10 pages]

24.	Stratman. Paul. Letter to Marty Pacilloux. LDEO. Re: Exide Environmental Response Trust Site. Solid Waste
Landfill Closure Notification. Former Exide Battery Site - Baton Rouge. Louisiana. AI#: 1396. Standard Permit No.
P-0326. July 1, 2022. [47 pages]

25.	Foerter, Dennis. WESTON. Phone Conversation Record with Blake LeBlanc. Louisiana Department of Wildlife
and Fisheries. Subject: Fishery Information for Mississippi River (Profit Island to 1 Mile South of Rt. 10 Bridge.
July 18, 2023. [1 page]

26.	McAteer, Mike. EPA. Pollution/Situation Report. POLREP#!. Initial POLREP. Exide Baton Rouge. A6VR. Baton
Rouge. LA. March 23. 2023. [4 pages]

27.	Miller, Glenn. LDEQ. Letter to Glen Hasse. Vice President. Schuylkill Metals Corporation. Re: Slag Pile Closure.
March 28, 1985. [1 page]

28.	Foerter, Dennis. WESTON. Project Note to Exide Baton Rouge Site File. Subject: Expanded Site Inspection -
Sample Locations (February 2023 / March 20231. July 28, 2023. [4 pages]

29.	EPA. Fourth Five-Year Review Report for Petro-Processors of Louisiana Inc. (PPD Superfund Site. East Baton
Rouge County. Louisiana. May 2021. [82 pages]

30.	Gruntz, Connor. LDEQ. Solid Waste Full Compliance Evaluation Inspection Report. East Baton Rouge Parish
North Landfill. March 20, 2023. [14 pages]

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REFERENCES CITED (continued)

31.	Vega, Elliott. LDEQ. Letter to Sarah Boudreax. City of Baton Rouge/Parish of Baton Rouge. Subject: Louisiana
Pollutant Discharge Elimination System (LPDES) permit to discharge wastewaters associated with a Type I and
Type II sanitary landfill, thence to Bayou Baton Rouge, thence to Mississippi River (Outfalls 001. 002. 003. 004A
and 0091: and Profit Island Chute, thence into the Mississippi River (Outfall 0101. October 7, 2016. [68 pages]

32.	Gomez, Daniel, WESTON. E-mail correspondence to Dennis Foerter. WESTON. Subject: Exide Baton Rouge -
ESI Sample Coordinates: with attached table of sample coordinates. July 30, 2023. [2 pages]

33.	EPA. ECHO Detailed Summary Report. Oxbow Calcining LLC - Baton Rouge Calcined Coke Plant. Facility
Registry Service ID 110003360372. Accessed and downloaded from https://echo.epa.gov/detailed-facilitv-
report?fid=l 10003360372 on July 30, 2023. [11 pages]

34.	Vega, Elliott. LDEQ. Letter to Frank Newman. Oxbow Calcining. LLC. RE: Louisiana Pollutant Discharge
Elimination System (LPDES) permit discharge once through non-contact cooling water, stormwater runoff, dust
suppression runoff, pad washdown water, miscellaneous wastewaters including but not limited to firefighting water,
fire hydrant flushings, potable water sources, lawn watering, routine external building washdown. pavement
washdown. air conditioner condensate, vehicle washwater. and foundation or footing drains (no soaps or detergents
are used in washing! and previously monitored treated sanitary wastewater to local draining via a pipe, thence to
Bavou Baton Rouge from an existing petroleum coke calcining facility located at 2200 Brooklawn Drive in Baton
Rouge. East Baton Rouge Parish. January 31, 2019. [36 pages]

35.	Foerter, Dennis. WESTON. Phone Conversation Record with Robert Sherman. WESTON. Subject: Seep Samples
collected at Exide Baton Rouge on March 22. 2023. August 2, 2023. [2 pages]

36.	Pace Analytical. Analytical Report. Weston Solutions Inc. - Baton Rouge. LA. Sample Delivery Group L1597557.
Project No. 20600.016.001.1540.0. March 23. 2023. [116 pages]

37.	Pace Analytical. Analytical Report. Weston Solutions Inc. - Baton Rouge. LA. Sample Delivery Group L1597553.
Project No. 20600.016.001.1540.0. March 23, 2023. [116 pages]

38.	U.S. Fish and Wildlife Service. National Wetlands Inventory Exide Baton Rouge Maps. Accessed and downloaded
from https://fwsprimarv.wim.usgs.gov/wetlands/apps/wetlands-mapper. on August 14, 2023. [4 pages]

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SITE SUMMARY

The Site is comprised of sources at a former Exide Technologies (Exide) operated battery recycling facility located at 2400
Brooklawn Drive in Baton Rouge, East Baton Rouge Parish, Louisiana, and release of hazardous substances to Bayou Baton
Rouge (also referred to in some maps and references as Baton Rouge Bayou) [Ref. 3, p. 2; 5, p. 11], A Site Location Map is
presented in Figure 1. Sources evaluated at the Site include Source 1, which consists of two hazardous waste piles (i.e.,
Hazardous Waste Piles #1 and #2) and two areas of contaminated soil (Source 2 and Source 3) [see Section 2.2; Figure 2],
Sediment sampling and analysis by the U.S. Environmental Protection Agency (EPA) in February 2023 and March 2023
document the presence of inorganic analytes (i.e., antimony, cadmium, and lead) at concentrations that meet the criteria for
observed release [see Section 4.1.2.1.1; Figure 3], The contaminated sediment samples delineate a zone of contamination which
includes a total of 0.51 mile of wetland frontage subject to Level II actual contamination (see Section 4.1.4.3; Figure 3A).
Potential targets within the surface water target distance limit (TDL) downstream of the zone of contamination include wetlands
and a fishery (i.e., Mississippi River) [see Sections 4.1.3.3,4.1.4.3; Figure 4],

The Exide Technologies facility was a Resource Conservation and Recovery Act (RCRA) Hazardous Waste Transfer Storage
and Disposal (TSD) facility (Final Operating Permit No. LAD00818437-OP-1) [Ref. 5, p. 11], Land use directly surrounding
the Site is primarily industrial [Ref. 4, pp. 13, 17; 22, p. 16], The Site is bordered to the northeast by a non-hazardous industrial
waste disposal facility, to the east by a petroleum coke manufacturer, and the Baton Rouge Southern Railroad yard, and to the
south by National Priorities List (NPL) Site Petro-Processors of Louisiana, Inc. A Site and Source Location Map is presented
in Figure 2. The facility is directly bordered to the north and west by Bayou Baton Rouge. The bayou and its tributaries drain
the surrounding land and discharge to the Mississippi River. A Surface Water Migration Pathway Map is presented in Figure
4. The original owner of the Baton Rouge facility was Schuylkill Metals Corporation (SMC). SMC was owned by Arrow
Electronics, Inc. until 1987 when it was sold to Schuylkill Holdings, Inc. (SHI). Exide acquired the Baton Rouge facility from
SHI in 1995 [Ref. 6, p. 5],

The Exide facility operated as a secondary lead smelter and refinery which recycled inorganic lead-bearing materials from early
1969 to 2009. Lead-bearing materials were delivered to the facility in trucks or trailers. Lead acid batteries were stored on the
facility, and ultimately fed into a battery breaker. Other lead-bearing materials were received in drums which were either emptied
into a feed-stock pile in the containment building or temporarily stored in designated areas. The facility operated one blast
furnace and one reverberatory furnace that were used to smelt the lead-bearing raw materials, which generated slag waste
product as part of the recycling process [Ref. 5, p. 14],

While in operation, the facility generated solid waste materials which included slag and scrubber sludge [Ref. 6, p. 6]. Prior to
the mid-1980s (Pre-RCRA regulations) solid waste products were placed in two unlined waste piles. The hazardous waste piles
were closed in 1986 and are subject to long-term care and monitoring requirements pursuant to Louisiana Department of
Environmental Quality (LDEQ) Post-Closure Permit No. LAD 008 184 137, including semi-annual groundwater monitoring at
seven monitoring wells. This post-closure permit was issued on June 19, 1995 [Ref. 5, p. 15; 22, p. 16], From 1988 through
July 1999 waste products were stabilized (to pass toxicity levels established under RCRA) and placed into a solid waste landfill
located immediately north of the former plant production area [Ref. 6, p. 6], The solid waste landfill was semi-lined with clay
and operated under solid waste permit GD0332054P0160 [Ref. 5, p. 15; Ref. 22, p. 16], The solid waste landfill was closed due
to newer state requirements for landfill lining, resulting in the construction of a new solid waste landfill [Ref. 22, p. 16], After
July 1999, stabilized waste products were placed in an open solid waste landfill situated on the west side of Bayou Baton Rouge
[Ref. 6, p. 6], The open solid waste landfill is currently undergoing a RCRA closure [Ref. 22, p. 33], All units (i.e., closed
solid waste landfill, closed hazardous waste piles #1 and #2, and the open solid waste landfill) are connected to a leachate
collection system [Ref. 22, pp. 16, 21], Leachate is treated using an on-site water treatment system before being discharged to
Outfall 101 and then flows from Outfall 101 to Outfall 001 where it is discharged to Bayou Baton Rouge [Ref. 22, pp. 17, 22,
42],

In 2009, a RCRA Facility Investigation (RFI) was conducted at the site to evaluate and document subsurface conditions at the
Exide facility. During this investigation, four area of investigation solid waste management units (AOI-SWMUs) and one
additional area of investigation (AOI) were identified at the facility. These four AOI-SWMUs included the slag storage area
(AOI-SWMU #34), the truck wash down area (AOI-SWMU #40), the wastewater drainage and collection system (AOI-SWMU
#49), the railroad loading/unloading area (AOI-SWMU #60). In addition, the area of the facility outfalls into Bayou Baton
Rouge was identified as an AOI (i.e., AOI-BRBS). Analytical results from soil investigations and water samples collected from
boreholes identified arsenic, antimony, and lead as contaminants of concern [Ref. 4, pp. 13, 14, 16, 30], All of the SWMUs were
granted a finding of No Further Action (NFA) [Ref. 22, p. 16], The remaining area AOI (i.e., AOI-BRBS) receive corrective
action in the form of source removal. Source removal dredging occurred in 2015, and an NFA status was granted on May 26,
2016 [Ref. 22, p. 16],

HRS Documentation Record

12

Exide Baton Rouge
LAD008184137


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When the Site was idled in 2009, all remaining inventory and feed stock was either processed or shipped off site and remaining
waste materials were removed and sent for disposal or stabilized to render them non-hazardous and placed in the on-site landfill
[Ref. 5, p. 16],

Decontamination activities occurred at the facility between October 2013 and March 2015 in accordance with a November 2007
Closure Plan. Consequent rinse water samples showed that decontamination activities were unable to consistently attain the
established limits for cadmium, arsenic, and lead. Subsequent subsurface soil sample analytical results in 2015 and 2016
indicated that the majority of the former manufacturing areas are underlain by waste fill materials (such as slag) and
contaminated soils. It was determined that due to the extent of the subsurface impacts, the facility could not reasonably attain
"clean closure". Therefore, Exide, in consultation with LDEQ, concluded to execute an "in-place" closure scenario, including
capping over former manufacturing areas of the Site where soil sample results show subsurface contamination [Ref. 5, pp. 11,
16],

Exide declared Chapter 11 bankruptcy in May 2020. On October 23, 2020, the facility was abandoned by Exide and placed into
the Exide Environmental Response Trust (Trust). The Trust is managed by the Exide Environmental Corporation (Trustee) and
the beneficiary is LDEQ. The Site is currently inactive, except for continuing operations related to storm water collection, waste
pile and landfill leachate collection, wastewater treatment, and general site maintenance [Ref. 6, p. 5],

Due to allocated settlement funds from the 2020 Exide bankruptcy being exhausted, the Trust scheduled the wastewater
treatment plant (WWTP) for shutdown on March 31, 2023. On March 22, 2023, EPA Region 6's Removal Response Program
received a request from EPA RCRA to conduct an emergency response which would involve taking control/operation of the
WWTP to avoid shutdown of the operation. A WWTP shutdown would have resulted in releases to Bayou Baton Rouge [Ref.
26, p. 1], The Trust continued operating the WWTP until April 10, 2023, which is when EPA officially took over operation of
the WWTP [Ref. 26, p. 2],

HRS Documentation Record

13

Exide Baton Rouge
LAD008184137


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LOUISIANA STATE
POLICE TRAINING
FACILITY

Louisiana

LEGEND

A LEACHATESEEP SAMPLE
" LOCATION
© SOIL SAMPLE LOCATION
^ MONIIORING WELL LCCA1ION

(Background)

PROBABLE POINT OF ENTRY
(PPE)

FACILITY PROPERTY
BOUNDARY

G9 OUTFALL LOCATION

FORMER PROCESS AREA

IS? FORMER WASTE LOCATION

f — OFFICE BUILDING

WASTEWATER TREATMENT
1	1 PLANT

Q OPEN SOLID WASTE LANDFILL

J^MW:,12R ="	=¦ <=3

^ ^
HAZARDOUS	<

WASTE PILE #1

(1.86 ACRES)

¦=» tOUTFALI/vCra

| OPEN SOLID WASTE LANDFILL |

CLOSED SOLID
\ WASTE LANDFILL

MW-4R

SOURCE 3

Notes:

Acreage for Hazardous Waste Pile #1 and
Hazardous Waste Pile #2 were calculated
from the footprint deli neated in Ref. 22, p. 42

SOURCE 1

OUTFALL 001

SOURCE 2

FORMER PROCESS AREA

(Contaminated Soil)

WASTEWATER
TREATMENT PLANT

HAZARDOUS
WASTE PILE #2
(1.96 ACRES)

OFFICE

OXBOW
CALCINING

SCALE IN FEET

SOURCE: WORLD IMAGERY; ESRI

The source of this map is ESRI, used by EPA with ESRI's
permission.

US EPA REGION 6

FIGURE 2

SITE AND SOURCE LOCATION MAP

EXIDE BATON ROUGE
2400 BROOKLAWN DRIVE

BATON ROUGE, EAST BATON ROUGE PARISH, LOUISIANA

DATE

SEPTEMBER 2023

PROJECT NO

20600.012.001.1540

SCALE
AS SHOWN

FILE: G:\EPA\Region 6 START IV\Supeifund\Exide Baton Rouge\pro\Exide Baton Rouge\Exide Baton Rouge3.aprx 1:04 PM 8/16/2023 gomezd

Exide Baton Rouge
LAD008184137

HHS Documentation Record


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EBR SED12-12
20230206-51

EBR SED12 24
20230206-51

Sample ID

02/06/2023

02/06/2023

Depth (Inches)

Analyte

I Antimony

Cadmium

Sample ID

EBR-SED26-60-20230321-51

EBR-SED13-12-
20230206-51

EBR-SED13-24-
20230206-51

03/21/2023

Sample ID

Depth (Inches)

02/06/2023

02/06/2023

Units

Depth (Inches)

Analyte

Analyte

Cadmium

| Antimony

Cadmium

02/08/2023

02/08/2023

03/21/2023

03/21/2023

Units

Analyte

Cadmium

Cadmium

PF01A Wetjana

.

¦r

Sample ID

EBR-SED20-12-
20230321-51

EBR-SED20-24-
20230321-51

EBR-SED20-60-
20230321-51

| Date

3/21/2023

3/21/2023

3/21/2023

Depth (inches)

Oto 12

12 to 24

48 to 60

Units

mg/kg

mg/kg

mg/kg

Analyte







Cadmium

0.137 JQK

1.35 U

0.416 JQK

Lead

8.66 JQK (12.47)

11.8 JK (16.99)

32.5 JK (46.8)

I ) i

—

"—		_

Sample ID

EBR-SED07-24-20230207-51

Date

02/07/2023

Depth (Inches)

12 to 24

Units

mg/kg

Analyte



¦ Antimony

4.8

£ Cadmium



*|Lead

70.1



Sample ID EBR-SED25-60-20230321-51 (LAB ID 1597545-15) EBR-SED25-60-20230321-52 (Lab ID 1597545-16)
Date
Depth (Inches)

rag/kg

mg/kg

Sample ID

Depth
(Inches)
Units
Analyte

[Antimony

Sample ID

EBR-SED04-12-20230209-
51

Date

02/07/2023

Depth (Inches)

0 to 12

Units

mg/kg

Analyte



Lead

58.5

\





Sample ID

EBR-SED21-24-20230321-51



Date

03/21/2023



Depth (Inches)

12 to 24



Units

mg/kg



Analyte





Lead

79.8 JK (55.41)

'• $•>/' ty*r % I

wU W,

EBR-SED15-12-
20230209-51

mg/kg

EBR-SED15-24-
20230209-51

mg/kg

. *1

LEGEND

A SEDIMENT SAMPLE LOCATION-MARCH
" 2023

H OUTFALL LOCATION

A

SEDIMENT SAMPLE LOCATION -
FEBRUARY 2023

RIVER

~ FACILITY PROPERTY BOUNDARY
WETLANDS

FRESHWATER EMERGENT WETLAND

FRESHWATER FORESTED/SHRUB
WETLAND

FRESHWATER POND
LAKE

Notes:

1 .PF01A - Palustrine, forested, broad-leaved,
deciduous, temporarily flooded wetland

Analytical Notes

1.	mg/kg - milligrams per kilogram.

2.	Only showing sediment results significantly above background.

3.	February 2023 background sediment locations are EBR-SED12, EBR-SED13, and EBR-SED15.

4.	March 2023 background sediment location is EBR-SED2G.

5.	J = The analyte was analyzed for, but the associated numerical value may not be consistent with the amount actually present in
the environmental sample or may not be consistent with the sample detection or quantitation limit. The value is an estimated quantity.
The data should be seriously considered for decision-making and are usable for many purposes [Ref. 10, p. 2:11, p. 2],

6.	U = The analyte was not detected at or above the reporting limit [Ref. 7, p. 357],

7.	K= Unknown bias [Ref. 10, p. 2:11, p. 2],

8.	Q = The reported concentration is less than the sample quantitation limit for the specific analyte in the sample [Ref, 10, p. 2; 11, p. 2],

9.	The J-qualified estimated results have been adjusted up to account for unknown bias per EPA Quick Reference Fact Sheet Using
Qualified Data to Document an Observed Release and Observed Contamination. The adjustment factors are provided in the fact sheet
and the adjusted results are shown in parentheses. Although J-qualified results are estimated, the presence of the analytes is not in
question and the result is usable [Ref. 12j.

10.	March 2023 observed release and background results with JQK qualifiers for cadmium and zinc are associated with no bias and
therefore are not adjusted with a correction factor. [Ref. 10, p. 5; 11, pp. 4-5; 12, p. 8],

11: Yellow highlighted concentration indicates an observed release.

SCALE IN FEET

SOURCE: WORLD IMAGERY; ESRi

NATIONAL WETLAND INVENTORY (NWI); U.S. FISH AND WILDLIFE
SERVICE

I The source of this map image is ESRI, used by EPA with
I ESRI's permission.

^ I US EPA REGION 6

FIGURE 3

SEDIMENT LOCATION MAP-
FEBRUARY/MARCH 2023
EXIDE BATON ROUGE
2400 BROOKLAWN DRIVE

I BATON ROUGE, EAST BATON ROUGE PARISH, LOUISIANA



HRS Documentation Record

I	 		I

Exide Baton Rouge
T.AD008184137'

I

DATE

SEPTEMBER 2023

PROJECT NO

20600.012.001.1540

SCALE
AS SHOWN

ebafon Rouge\pro\ExideBatonRouge\ExideBatonRouge3.aprx 1:13PM 8/16/2023gomezd


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r

.

¦/ -4 SB* ¦
V-7V""

*-¦»*' f „

LEGEND

A MOST DOWNSTREAM SAMPLE
SHOWING AN OBSERVED RELEASE

0 OUTFALL LOCATION

ZONE OF CONTAMINATION (2,062.41
FEET)

LEVEL II ACTUAL CONTAMINATION
WETLAND FRONTAGE (2,707.54 FEET)

RIVER

^3 FACIL. ITY PROPERTY BOU N DARY

WETLANDS

FRESHWATER FORESTED/SHRUB
WETLAND

FRESHWATER POND

Notes:

1.	PF01A- Paiustrine, forested, broad-leaved
deciduous, temporarily flooded wetland

2.	PPE - Probable Point of Entry to Surface
Water

I

II

I

285

570

SCALE IN FEET

SOURCES:

WORLD IMAGERY; ESRI

NATIONAL WETLAND INVENTORY (NWI); U.S. FISH AND WILDLIFE
SERVICE

The source of this map image is ESRI, used by EPA with
ESRI's permission.

^ I US EPA REGION 6

FIGURE 3A

ZONE OF CONTAMINATION MAP
EXIDE BATON ROUGE
2400 BROOKLAWN DRIVE

BATON ROUGE, EAST BATON ROUGE PARISH, LOUISIANA

DATE

SEPTEMBER 2023

PROJECT NO

20600.012.001.1540

SCALE
AS SHOWN

HRS Documentation Record

Exide Baton Rouge
LAD008184137 "

FILE: G:\EPA\Region 6 START IV\Supeifund\Exide Baton Rouge\pro\Exide Baton Rouge ESI.aprx 11:11 AM 8/16/2023 gomezd


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BRANCH 1

OUTFALL 003
OUTFALL 00,1

[M/^/ss/pp^/^

P Bat^Rouge^Bayou]

'Deyit's[Swamp]

\Baton]Houge]Harbori

BRANCH 2

Route

LEGEND

~ Facility Property Boundary
0 Outfall Location

Probable Point of Entry (PPE)
Surface Water Pathway
Wetland Frontage Subject to
Level II Contamination

US EPA REGION 6

TDL - Target Distance Limit

FIGURE 4

15-MILE SURFACE WATER PATHWAY MAP

EXIDE BATON ROUGE
2400 BROOKLAWN DRIVE

BATON ROUGE, EAST BATON ROUGE PARISH, LOUISIANA

Louisiana

SOURCE: WORLD IMAGERY; ESRI

NATIONAL WETLAND INVENTORY (NWI); U.S. FISH AND WILDLIFE SERVICE

DATE

SEPTEMBER 2023

PROJECT NO

20600 012.001 1540

SCALE
AS SHOWN

SCALE IN MILES

The source of this map image is ESRI, used by EPA with ESRI's permission.

HRS EX)	R d	1 O	FILE: G:\EPA\Region 6 START l\ASuperfund\Exide Baton Rouge\pro\Exide Baton Rouge\Exide	gomezd

cumen a ion ecor	LAD008184137


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2.2 SOURCE CHARACTERIZATION:

2.2.1 SOURCE IDENTIFICATION

Source Description: Source 1 - Hazardous Waste Piles #1 and #2
Source Type: Pile

Description and Location of Source:

Source 1 consists of two closed hazardous waste piles (i.e., Hazardous Waste Pile #1 and Hazardous Waste Pile #2). While in
operation, the Exide facility generated solid waste materials which included slag and scrubber sludge. Prior to the mid-1980s,
solid waste products during the battery recycling process were placed in the two unlined waste piles [Ref. 6, p. 6]. The piles are
subject to long-term care and monitoring requirements pursuant to Post-Closure Permit issued by LDEQ. Long-term monitoring
includes semi-annual monitoring for one upgradient and six downgradient wells [Ref. 5, p. 15], The waste piles are connected
to a leachate collection system. Leachate from the piles is treated using an on-site WWTP before being discharged to Bayou
Baton Rouge via Outfall 001 [Ref. 22, pp. 17, 22], Treatment is accomplished by a common metals treatment train consisting
of pH adjustment, coagulation/flocculation, settling in an inclined plate clarifier, and discharge to Outfall 101. The discharge
then flows from Outfall 101 to Outfall 001 where it is discharged to Bayou Baton Rouge [Ref. 22, pp. 21-22, 42],

Since the piles are classified as the same source type, affect similar target populations for the pathway, have similar containment
features; contain substances with similar waste characteristics; and are in the same watershed, as described in this and subsequent
sections of the HRS documentation record, Hazardous Waste Piles #1 and #2 are aggregated as one source.

Source Type

The source type is evaluated as "Pile" [Ref. 1, Table 2-5; Figure 2],

Source Location

Hazardous Waste Pile #1 is west of the former process area areas of the Site and is located approximately 100 feet from the
eastern bank of Bayou Baton Rouge and northwest of the wastewater treatment plant. Hazardous Waste Pile #2 is located south
of the wastewater treatment plant and the former process area of the Site; approximately 200 feet from the eastern bank of
Bayou Baton Rouge [Ref. 5, p. 15; Figure 2],

Source Containment
Release To Surface Water

The hazardous waste piles were capped as part of their closure in 1986. The caps consist of 24 inches of compacted clay and
6 inches of vegetated topsoil; however, certain areas of the piles were capped with 18 inches of compacted clay and 6 inches
of concrete [Ref. 27, p. 1], The hazardous waste piles consist of a maintained engineered cover and a functioning and
maintained run-on and runoff management system. Although there is a functioning leachate collection and removal system,
there is no liner beneath the piles to prevent further migration of the contamination [Ref. 6, p. 6], Areas of surface water
infiltration on the cap associated with Hazardous Waste Pile #2 were noted in 2021 [Ref. 22, p. 97], In addition, leachate
seeps were observed to be occurring in areas immediately downgradient of both piles [Ref. 35, p. 1], Analytical data from
these leachate seeps indicates the presence of several metals [see Section 2.2.2], Based on the presence of leachate seeps
immediately adjacent and downgradient of both hazardous waste piles and the pathway from both seeps to Bayou Baton
Rouge, it is apparent that leachate generated by the hazardous waste piles is not being adequately contained. There is
evidence of hazardous substance migration from both piles, as contaminants (i.e., metals) were detected in the leachate seep
samples. A surface water containment factor value for overland migration of 10 is assigned for this source [Ref. 1, Table 4-
2; 6, p. 6],

Containment Value: 10

HRS Documentation Record

19

Exide Baton Rouge
LAD008184137


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2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

During the ESI investigations conducted by EPA, three samples were collected which characterized the wastes associated with
Hazardous Waste Piles #1 and #2 as described below.

In February 2023, a leachate sample was collected from the WWTP prior to treatment. This sample (EBR-Pretreatment) was
analyzed by the EPA Region 6 Laboratory, Laboratory Services and Applied Science Division, for metals by EPA Method
6020B and6010D [Ref.7,pp. 103,195], The sample was validated in accordance with internal EPA data validation guidelines.
Analytical results from this sample indicated the presence of several metals including antimony (62.9 micrograms per liter
[ug/L]), arsenic (3,990 ug/L), cadmium (5.5 ug/L), lead (81.2, ug/L), manganese (87.7 ug/L), and zinc (36.7 ug/L) [Ref. 7, pp.
103, 195,363; 13, p. 8],

On March 22, 2023, EPA collected two leachate seep samples from two areas where leachate seeps were observed adjacent to
each of the hazardous waste piles. Leachate Sample SEEP1 was collected just west of Hazardous Waste Pile #1 and Sample
SEEP2 was collected west of Hazardous Waste Pile #2 [Ref. 13, p. 11; 35, pp. 1, 2], Groundwater flow beneath the Exide
facility is to the northwest; the locations of the leachate seeps were located downgradient of each hazardous waste pile [Ref.
22, pp. 18, 94], Leachate seep samples were analyzed by Pace Analytical for metals by EPA Method 6020 [Ref. 36, pp. 7,
116; Ref. 37, pp. 7, 116], Table 1 presents the analytical results for the leachate seep samples collected adjacent to Hazardous
Waste Piles #1 and #2.

TABLE 1 - SEEP SAMPLE RESULTS

Sample No.:

SEEP1

SEEP2

Location.:

West of Hazardous

West of Hazardous



Waste Pile #1

Waste Pile #2

Date:

3/22/23

3/22/23

Comments:

Leachate Seep

Leachate Seep

Metals (ug/L)

Result

RDL

Result

RDL

Antimony

299

4.0

11.1

4.0

Arsenic

14.6

2.0

4,680

2.0

Cadmium

2.27

1.0

5.87

1.0

Chromium

1.28 J

2.0

1.29 J

2.0

Copper

7.04

5.0

9.07

5.0

Lead

146

2.0

415

2.0

Manganese

454

5.0

1,630

5.0

Nickel

17.3

2.0

5.52

2.0

Zinc

69.7

25.0

14.3 J

25.0

References

Ref. 36, pp. 5,7, 113,

Ref. 37, pp. 5,7, 113,



116; 13, p. 11; 35, pp.

116; 13, p. 11; 35, pp. 1-



1-2



2



Notes:

ug/L - micrograms per liter

J = The identification of the analyte is acceptable; the reported value is an estimate [Ref. 37, p. 113],

RDL = reported detection limit. The RDL is the sample's level of quantitation adjusted for dilution and is equated to a sample
quantitation limit [Refs. 1, Section 1.1; 36, pp. 5, 113; 37, pp. 5, 113],

HRS Documentation Record

20

Exide Baton Rouge
LAD008184137


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2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

Containment

Gas release to air: The air migration pathway was not scored; therefore, gas release to air containment was not evaluated.

Particulate release to air: The air migration pathway was not scored; therefore, particulate containment was not evaluated.

Subsurface Intrusion release: The soil exposure and subsurface intrusion pathway was not scored; therefore, the subsurface

intrusion containment was not evaluated.

Release to groundwater: The ground water pathway was not scored; therefore, groundwater containment was not evaluated.

Release via overland migration: As discussed above, the hazardous waste piles are capped as part of their closure in 1986.
The caps consist of 24 inches of compacted clay and 6 inches of vegetated topsoil; however, certain areas of the piles were
capped with 18 inches of compacted clay and 6 inches of concrete [Ref. 27, p. 1], The hazardous waste piles consist of a
maintained engineered cover and a functioning and maintained run-on control and runoff management system. There is no
liner beneath the piles to prevent further migration of the contamination [Ref. 6, p. 6]. Areas of surface water infiltration on
the cap associated with hazardous waste pile #2 were noted in 2021 [Ref. 22, p. 97]. Based on the presence of leachate seeps
located adjacent and downgradient of both hazardous waste piles and the pathway from these seeps to Bayou Baton Rouge,
it is apparent that leachate generated by the hazardous waste piles is not being adequately contained [Ref. 35, pp. 1-2], There
is evidence of hazardous substance migration from both piles, as contaminants (i.e., metals) were detected in the leachate
seep samples. A surface water containment factor value for overland migration of 10 is assigned for this source [Ref. 1,
Table 4-2; 6, p. 6], Refer to Section 4.1.2.1 of this HRS documentation record for information supporting the significant
increase above background levels of inorganic analytes (i.e., antimony, cadmium, and lead) in Bayou Baton Rouge.

Containment Value: 10

HRS Documentation Record

21

Exide Baton Rouge
LAD008184137


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2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1 Source Hazardous Waste Quantity

2.4.2.1.1	Tier A: Hazardous Constituent Quantity - Not Calculated (NC)

The total Hazardous Constituent Quantity for Source 1 could not be adequately determined according to the HRS requirements;
that is, the total mass of all Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) hazardous
substances in the source and releases from the source is not known and cannot be estimated with reasonable confidence (Ref.
1, Section 2.4.2.1.1). There are insufficient historical and current data [manifests, potentially responsible party (PRP) records,
State records, permits, waste concentration data, etc.] available to adequately calculate the total or partial mass of all CERCLA
hazardous substances in the source and the associated releases from the source. Therefore, there is insufficient information to
calculate a total or partial Hazardous Constituent Quantity estimate for Source 1 with reasonable confidence. Scoring proceeds
to the evaluation of Tier B, Hazardous Wastestream Quantity (Ref. 1, Section 2.4.2.1.1).

Hazardous Constituent Quantity Value (S): NC
Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.2	Tier B: Hazardous Wastestream Quantity - Not Calculated (NO

The total Hazardous Wastestream Quantity for Source 1 could not be adequately determined according to the HRS requirements;
that is, the total mass of all hazardous waste streams and CERCLA pollutants and contaminants for the source and releases from
the source are not known and cannot be estimated with reasonable confidence (Ref. 1, Section 2.4.2.1.2). Insufficient historical
and current data (manifests, PRP records, State records, permits, waste concentration data, annual reports, etc.) are available
to adequately calculate the total or partial mass of all hazardous waste streams and CERCLA pollutants and contaminants for
the source and the associated releases from the source. Therefore, there is insufficient information to adequately calculate or
extrapolate a total or partial Hazardous Wastestream Quantity estimate for Source 1 with reasonable confidence. Scoring
proceeds to the evaluation of Tier C, Volume (Ref. 1, Section 2.4.2.1.2).

Hazardous Wastestream Quantity Value (W): NC
Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.3	Tier O Volume

Available data are insufficient to document a volume measure.

Dimension of source (yd3): NC
Volume (V) Assigned Value: 0

2.4.2.1.4 Tier D: Area

The area of hazardous waste pile #1 is 1.86 acres. The area of hazardous waste pile #2 is 1.96 acres [Ref. 22, p. 42; Figure
2], This equates to a total of 3.82 acres (i.e., 166,399.2 square feet). The source type is "Pile", so the area is divided by 13,
which results in an assigned value shown below [Ref. 1, Section 2.4.2.1.4],

Area of source (ft2): 166,399.2 / 13
Area Assigned Value = 12,799.93

2.4.2.1.5 Source Hazardous Waste Quantity Value

Per the HRS, the highest of the values assigned to the source for hazardous constituent quantity (Tier A), hazardous
wastestream quantity (Tier B), Volume (Tier C), and Area (Tier D) should be assigned as the source hazardous waste quantity
value [Ref. 1, Section 2.4.2.1.5],

HRS Documentation Record

22

Exide Baton Rouge
LAD008184137


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TABLE 2. SOURCE 1 - HAZARDOUS WASTE QUANTITY VALUE

Tier Evaluated

Source 1 Values

A

Not Calculated

B

Not Calculated

C

0

D

12,799.93

Source 1 Hazardous Waste Quantity Value: 12,799.93

HRS Documentation Record

23

Exide Baton Rouge
LAD008184137


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2.2 SOURCE CHARACTERIZATION:

2.2.1 SOURCE IDENTIFICATION

Source Description: Source 2 - Contaminated Soil (Former Process Area)

Source Type: Contaminated Soil
Description and Location of Source:

Source 2 consists of contaminated soil from within the boundaries of the former process area. From February 7 to 9, 2023, EPA
collected soil samples in four locations within the former process area [Figure 2; 28, pp. 1-2], Locations where soil samples
were collected included east of the rail tracks, from the former slag waste area, from the former lead storage building, and from
a location adjacent to the cap of Hazardous Waste Pile #1 [Figure 2; Ref. 4, p. 53; 23, pp. 3, 4, 8; 28, p. 2], Soil samples were
collected at depth intervals of 0 to 12 inches and 12 to 24 inches bgs [Ref. 16, pp. 2, 4, 5-6, 9; 28, p. 2], Analytical results of
soil samples collected from within the former process area indicated the presence of metals at concentrations significantly greater
than concentrations detected in the background sample location EBR-S09 [see Section 2.2.2],

Source Type

Based on analytical results from soil samples collected as part of the EPA ESI conducted in February 2023, the source type
for Source 2 is evaluated as "contaminated soil" [Ref. 1, Table 2-5; Section 2.2.2; 28, pp. 1-2],

Source Location

Based on analytical results of soil samples collected during the ESI conducted by EPA in February 2023, contaminated soil
associated with Source 2 is located within the boundary of the former process area of the facility [Figure 2; Section 2.2.2;
Ref. 28, pp. 1, 2],

Source Containment

Release to Surface Water via Overland Migration and/or Flood: Storm runoff from within the former process areas of the
Site (included contaminated soil associated with Source 2) is conveyed via surface flow, channels, and swales and discharges
it as "first flush" stormwater (defined as the first 1 inch of precipitation) to a 643,000-gallon capacity stormwater collection
tank located near the WWTP. The WWTP treats the combined influent from the process water tank (i.e., leachate and
groundwater) and stormwater collection tank (i.e., first-flush stormwater) and discharges it to Outfall 101. The water then
flows from Outfall 101 to Outfall 001 and discharges to Bayou Baton Rouge. Untreated "post-first-flush stormwater
discharges to Bayou Baton Rouge at Outfall 001 (where it is commingled with WWTP effluent at the outfall) [Ref. 22, p. 22;
23, p. 3],

Source 2 does not have a maintained engineered cover; however, runoff from areas of contaminated soil within the former
process area is directed to a functioning and maintained runoff management system. A surface water containment factor of
9 is assigned. [Ref. 1, Table 4-2; 16, pp. 2, 4, 5, 6; 23, p. 3],

Containment Value: 9

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2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

From February 7 to 9, 2023, EPA collected soil samples from four locations within the former process area [Figure 2; 28, pp.
1-2; 13, pp. 5-7], Soil samples were collected at depth intervals of 0 to 12 inches and 12 to 24 inches bgs [Ref. 16, pp. 2, 4-6, 9;
28, p. 2], Samples were analyzed by the EPA Region 6 Laboratory, Laboratory Services and Applied Science Division, for
metals by EPA Method 6020B and 6010D [Ref. 7, pp. 7, 8, 10-15], Samples were validated in accordance with internal EPA
data validation guidelines.

The background and contaminated soil samples for each sampling event are considered comparable because all were: collected
from similar depositional environments (i.e., similar soil types that are predominantly silt, and clay, with similar percent solid
content); collected during the same time period (i.e., February 7-9, 2023) using EPA Standard Operating Procedures (SOPs);
collected from similar depth intervals; analyzed by the same laboratories using the same analytical methods; and validated
according to the same data validation guidelines [Ref. 7, pp. 31-32, 35-39, 41, 73-74; 16, pp. 2, 4-6, 9],

Soil Sample location S09 is used in this HRS Documentation Record to represent background condition, as it was collected in an
area that is not expected to have been impacted from on-site activities [Ref. 13, p. 7; 28, p. 2], Although not required by the HRS,
background concentrations are provided to show the relative increase of contaminant levels in the source over background.

Two soil samples were collected from background sample location EBR-S09; one sample was collected from the 0- to 12-inch
depth interval and another sample collected from the 12- to 24-inch depth interval [Ref. 7, pp. 73-74,165-166; 16, p. 9], Source
samples were compared to the higher of metals concentrations for each analyte to determine significance above background.
Table 3 below shows the highest background concentration used to show the presence of the following metals detected at
concentrations significantly above background. Table 4 presents the concentrations detected in both background and
contaminated soil samples.

TABLE 3. SIGNIFICANT BACKGROUND CONCENTRATIONS - SOURCE 2

Metal

Highest Background
Concentration
mg/kg

RL or 3 x
Background
mg/kg

Reference

Antimony

5.2

15.6

7, p. 166

Arsenic

11.9

35.7

7, p. 166

Cadmium

0.6 U

0.6

7, pp. 73, 74

Chromium

12.8

38.4

7, p. 74

Cobalt

9.6

28.8

7, p. 73

Copper

14.5

43.5

7, p. 74

Lead

45.5

136.5

7, p. 166

Nickel

16.1

48.3

7, p. 74

Silver

2.3 U

2.3

7, p. 73

Zinc

43.1

129.3

7, p. 74

Notes:

mg/kg = milligram per kilogram

U = The analyte was not detected at or above the reporting limit [Ref. 7, p. 357]

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TABLE 4: ESI SOIL SAMPLING RESULTS - CONCENTRATIONS SIGNIFICANTLY ABOVE BACKGROUND

Station ID:

EBR-S09

EBR-S09

EBR-S02

EBR-S02

EBR-S04

Sample No.:

EBR-S09-12-

EBR-S09-24-

EBR-S02-12-

EBR-S02-24-

EBR-S04-12-



20230209-51

20230209-51

20230207-51

20230207-51

20230207-51

Date:

2/9/23

2/9/23

2/7/23

2/7/23

2/7/23

Depth Interval (in.

Oto 12

12 to 24

Oto 12

12 to 24

Oto 12

bgs)
Comments:

Background

Background













Metals (mg/kg)

Result

RL

Result

RL

Result

RL

Result

RL

Result

RL

Antimony

1.7

0.6

5.2

0.5

U

20.2

U

5.4

4,630

453

Arsenic

7.9

0.1

11.9

0.1

15.8

4.0

10.3

1.1

3,660

90.6

Cadmium

U

0.6

U

0.5

1.6

0.5

U

0.5

17.1

0.5

Chromium

10.8

1.2

12.8

1.1

20.7

1.0

16.1

1.1

27.2

0.9

Cobalt

9.6

2.3

8.5

2.2

7.7

2.0

5.5

2.2

100

1.8

Copper

10.6

2.3

14.5

2.2

35.7

2.0

17.5

2.2

1,060

1.8

Lead

40.9

0.6

45.5

0.5

1,990

20.2

162

5.4

34,000

453

Nickel

12.9

2.3

16.1

2.2

18.9

2.0

17.7

2.2

868

1.8

Silver

U

2.3

U

2.2

U

1.0

U

1.1

9.3

0.9

Zinc

36.1

2.3

43.1

2.2

99.7

2.0

103

2.2

664

1.8

Reference(s)

Ref. 7, pp. 73, 165,

Ref. 7, pp. 74,

Ref. 7, pp. 31,

Ref. 7, pp. 32, 124,

Ref. 7, pp. 35,



363; 16, p. 9; 28,

166, 363;

16, p.

123,361;

16, p. 2;

361; 16, p. 2; 28,

127, 361;

16, p. 4;



pp. 1-2



9; 28, pp. 1-2

28, pp. 1-2

pp. 1-2



28, pp. 1-2























Station ID:

EBR-S04

EBR-S05

EBR-S05

EBR-S06

EBR-S06

Sample No.:

EBR-S04-24-

EBR-S05-12-

EBR-S05-24-

EBR-S06-12-

EBR-S06-24-



20230207-51

20230207-51

20230207-51

20230207-51

20230207-51

Date:

2/7/23

2/7/23

2/7/23

2/7/23

2/7/23

Depth Interval (in.

12 to 24

Oto 12

12 to 24

Oto 12

12 to 24

bgs)





















Comments:











INORGANICS

Result

RL

Result

RL

Result

RL

Result

RL

Result

RL

(mg/kg)





















Antimony

511

101

220

5.2

821

500

32.0 J

2.1

U

9.7

Arsenic

431

20.2

633

41.8

2,070

100

27.5

20.5

15.0

1.9

Cadmium

6.3

0.5

13.8

0.5

5.8

0.5

5.7

0.5

0.6

0.5

Chromium

37.4

1.0

52.1

1.0

38.3

1.0

18.1

1.0

15.0

1.0

Cobalt

22.3

2.0

22.4

2.1

20.4

2.0

3.6

2.1

9.6

1.9

Copper

157

2.0

357

2.1

1,600

2.0

37.9

2.1

18.2

1.9

Lead

7,820

101

17,300

209

39,800

500

7,570

103

296

9.7

Nickel

103

2.0

99.5

2.1

131

2.0

14.0

2.1

21.0

1.9

Silver

1.3

1.0

1.2

1.0

1.8

1.0

U

1.0

U

1.0

Zinc

307

2.0

752

2.1

1,240

2.0

55.5

2.1

57.3

1.9

References

Ref 7, p. 36, 128,

Ref. 7, pp. 37,

Ref. 7, pp. 38,

Ref. 7, pp. 39, 131,

Ref. 7, pp. 41,



361; 16, p. 4; 28,

129, 360;

16, p.

130, 360;

16, p. 5;

360; 16, p. 6; 28,

133, 360;

16, p. 6;



PP. 1-2



5; 28, pp. 1-2

28, pp. 1-2

PP. 1-2



28, pp. 1-2

Notes:

J = - Estimated concentration [Ref. 7, p. 357],
bgs - below ground surface

Results in bold indicate contaminant was detected significantly above the concentration detected in background soil sample
S09.

U = The analyte was not detected at or above the reporting limit [Ref. 7, p. 357]

RL = Reporting limit. The reporting limit is the laboratory reporting limit with any dilution factor, volume adjustment, or
percent solids for each sample taken into account and is equivalent to the SQL as defined in the HRS [Ref. 1, Section 1.1; 7, p.
5].

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2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

Containment

Gas release to air: The air migration pathway was not scored; therefore, gas release to air containment was not evaluated.

Particulate release to air: The air migration pathway was not scored; therefore, particulate containment was not evaluated.

Subsurface Intrusion release: The soil exposure and subsurface intrusion pathway was not scored; therefore, the subsurface
intrusion containment was not evaluated.

Release to groundwater: The ground water pathway was not scored; therefore, groundwater containment was not evaluated.

Release via overland migration: As discussed above, Source 2 does not have a maintained engineered cover; however, runoff
from areas of contaminated soil within the former process area is directed to a functioning and maintained runoff management
system. A surface water containment factor of 9 is assigned. [Ref. 1, Table 4-2; 16, pp. 2, 4, 5, 6; 23, p. 3], Refer to Section
4.1.2.1 of this HRS documentation record for information supporting the significant increase above background levels of
inorganic analytes (i.e., antimony, cadmium, and lead) in Bayou Baton Rouge.

Containment Value: 9

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2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1 Source Hazardous Waste Quantity

2.4.2.1.1	Tier A: Hazardous Constituent Quantity - Not Calculated (NC)

The total Hazardous Constituent Quantity for Source 2 could not be adequately determined according to the HRS requirements;
that is, the total mass of all Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) hazardous
substances in the source and releases from the source is not known and cannot be estimated with reasonable confidence (Ref.
1, Section 2.4.2.1.1). There are insufficient historical and current data [manifests, potentially responsible party (PRP) records,
State records, permits, waste concentration data, etc.] available to adequately calculate the total or partial mass of all CERCLA
hazardous substances in the source and the associated releases from the source. Therefore, there is insufficient information to
calculate a total or partial Hazardous Constituent Quantity estimate for Source 1 with reasonable confidence. Scoring proceeds
to the evaluation of Tier B, Hazardous Wastestream Quantity (Ref. 1, Section 2.4.2.1.1).

Hazardous Constituent Quantity Value (S): Not Calculated
Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.2	Tier B: Hazardous Wastestream Quantity - Not Calculated (NO

The total Hazardous Wastestream Quantity for Source 2 could not be adequately determined according to the HRS requirements;
that is, the total mass of all hazardous waste streams and CERCLA pollutants and contaminants for the source and releases from
the source are not known and cannot be estimated with reasonable confidence (Ref. 1, Section 2.4.2.1.2). Insufficient historical
and current data (manifests, PRP records, State records, permits, waste concentration data, annual reports, etc.) are available
to adequately calculate the total or partial mass of all hazardous waste streams and CERCLA pollutants and contaminants for
the source and the associated releases from the source. Therefore, there is insufficient information to adequately calculate or
extrapolate a total or partial Hazardous Wastestream Quantity estimate for Source 1 with reasonable confidence. Scoring
proceeds to the evaluation of Tier C, Volume (Ref. 1, Section 2.4.2.1.2).

Hazardous Wastestream Quantity Value (W): Not Calculated
Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.3	Tier O Volume

Based on the analytical results of soil samples collected during the February ESI, it is apparent that contamination is present at
depth; however, an exact volume is not known at this time [Ref. 7, pp. 31, 36, 38, 41, 123, 128, 130, 133; 28, pp. 1-2], A Tier
C volume value of >0 is assigned [Ref. 1, Section 2.4.2.1.3],

Dimension of source (yd3): >0 yd3
Volume (V) Assigned Value: >0/2,500 = >0

2.4.2.1.4 Tier D: Area

A Tier D area measure of 0 is assigned since the volume of the source could be estimated [Ref. 1, Section 2.4.2.1.4],

Area Assigned Value = 0

2.4.2.1.5 Source Hazardous Waste Quantity Value

Per the HRS, the highest of the values assigned to the source for hazardous constituent quantity (Tier A), hazardous
wastestream quantity (Tier B), Volume (Tier C), and Area (Tier D) should be assigned as the source hazardous waste quantity
value [Ref. 1, Section 2.4.2.1.5],

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TABLE 5. SOURCE 2 - HAZARDOUS WASTE QUANTITY VALUE

Tier Evaluated

Source 2 Values

A

Not Calculated

B

Not Calculated

C

>0

D

0

Source 2 Hazardous Waste Quantity Value: >0

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2.2 SOURCE CHARACTERIZATION:

2.2.1 SOURCE IDENTIFICATION

Source Description: Source 3 - Contaminated Soil (Outside Former Process Area)

Source Type: Contaminated Soil

Description and Location of Source:

Source 3 consists of contaminated soil located in the northeast corner of the Exide facility property and outside of the perimeter
of the former process area. EPA collected soil samples in two locations in the northeast corner of the facility where surface
runoff drains to Outfall 003, which discharges stormwater untreated to Bayou Baton Rouge [Ref. 22, p. 22; 28, pp. 1-2], Soil
samples were collected at depth intervals of 0 to 12 inches and 12 to 24 inches bgs [Ref. 16, pp. 3, 7, 9; 28, p. 2], Analytical
results of soil samples collected from this area indicated the presence of metals at concentrations significantly greater than
concentrations detected in the background samples collected at location EBR-S09. Metals detected at levels significantly above
background include antimony, arsenic, cadmium, chromium, copper, lead nickel, and zinc [see Section 2.2.2],

Source Type

Based on analytical results from soil samples collected by EPA in February 2023, the source type for Source 3 is evaluated as
"contaminated soil" [Ref. 1, Table 2-5; Section 2.2.3; Section 2.2.2; 16, pp. 3, 7; 28, pp. 1-2],

Source Location

Contaminated soil associated with Source 3 is in the northeast portion of the Exide facility property, in an area that drains
toward Outfall 003. Source 3 contaminated soil sample location EBR-S03 is located approximately 300 feet south of the PPE
(i.e., PPE1) to Bayou Baton Rouge [Figure 2; Section 2.2.2; 28, p. 2],

Source Containment

Release to Surface Water via Overland Migration and/or Flood: Stormwater runoff from the area along the eastern fence line
of the facility discharges without treatment via Outfall 003 to a wooded area which drains toward Bayou Baton Rouge, which
is approximately 200 feet north of Outfall 003 [Figure 2; Ref. 22, p. 22],

A surface water containment factor of 10 is assigned because runoff from contaminated soil samples locations EBR-S03 and
EBR-S07 discharges without treatment to Outfall 003, which drains to Bayou Baton Rouge. Contaminated soil in this area
is unlined and uncovered (i.e., the source has no maintained engineered cover, or functioning and maintained run-on control
system and runoff management system). [Ref. 1, Table 4-2; 16, pp. 3, 7; 22, pp. 22],

Containment Value: 10

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

In February 2023, EPA collected soil samples from two locations in the northeast corner of the facility where surface runoff
drains to Outfall 003, which discharges stormwater untreated to Bayou Baton Rouge [Ref. 22, p. 22; 28, pp. 1-2], Soil samples
were collected at depth intervals of 0 to 12 inches and 12 to 24 inches bgs [Ref. 16, pp. 3, 7,9; 28, p. 2], Samples were analyzed
by the EPA Region 6 Laboratory, Laboratory Services and Applied Science Division, for metals by EPA Method 6020B and
6010D [Ref. 7, pp. 7, 8,10-15], Samples were validated in accordance with internal EPA data validation guidelines. Analytical
results of soil samples collected from this area indicated the presence of metals at concentrations significantly greater than
concentrations detected in two soil samples collected from background sample location EBR-S09. Soil Sample location EBR-
S09 is used in this HRS Documentation Record to represent background conditions, as the two soil samples associated with this
location were collected in an area that is not expected to have been impacted from on-site activities [Figure 2], Although not

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required by the HRS, background concentrations are provided to show the relative increase of contaminant levels in the source
over background.

The background and contaminated soil samples are considered comparable because all were: collected during the same time
period (i.e., February 7-9, 2023) using EPA Standard Operating Procedures (SOPs); collected from similar depth intervals (0 to
24 inches); analyzed by the same laboratories using the same analytical methods; and validated according to the same internal
EPA data validation guidelines. The samples were also collected from similar depositional environments (i.e., similar soil types
that are predominantly silt, and clay, with similar percent solid content), except for contaminated soil sample EBR-S03-24-
20230207-51, which was predominantly sand [Ref. 7, pp. 33-34, 43 , 73-74, 125-126, 135, 165-166; 16, pp. 3, 7, 9],

Two soil samples were collected from background sample location EBR-S09; one sample was collected from the 0- to 12-inch
depth interval and another sample collected from the 12- to 24-inch depth interval [Ref. 16, p. 9]. Source samples were compared
to the higher of metals concentrations for each analyte to determine significance above background. Table 6 below shows the
highest background concentration used to show the presence of the following metals detected at concentrations significantly
above background. Table 7 presents the concentrations detected in both background and contaminated soil samples.

TABLE 6. SIGNIFICANT BACKGROUND CONCENTRATIONS - SOURCE 3

Metal

Highest Background
Concentration
mg/kg

RL or 3 x
Background
mg/kg

Reference

Antimony

5.2

15.6

7, p. 166

Arsenic

11.9

35.7

7, p. 166

Cadmium

0.6 U

0.6

7, pp. 73, 74

Chromium

12.8

38.4

7, p. 74

Copper

14.5

43.5

7, p. 74

Lead

45.5

136.5

7, p. 166

Nickel

16.1

48.3

7, p. 74

Silver

2.3 U

2.3

7, p. 73

Zinc

43.1

129.3

7, p. 74

Notes:

mg/kg = milligram per kilogram

U = The analyte was not detected at or above the reporting limit [Ref. 7, p. 357],

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TABLE 7: ESI SOIL SAMPLE

CONCENTRATIONS SIGNIFICANTLY ABOVE BACKGROUND

- SOURCE 3

Station ID:

EBR-S09

EBR-S09

EBR-S03

EBRS03

EBR-S07

Sample No.:

EBR-S09-12-
20230209-51

EBR-S09-24-
20230209-51

EBR-S03-12-
20230207-51

EBR-S03-24-
20230207-51

EBR-S07-12-
20230207-51

Date:

Depth Interval (in.

bgs)
Comments:

2/9/23
Oto 12

Background

2/9/23
12 to 24

Background

2/7/23
Oto 12

2/7/23
12 to 24

2/7/23
Oto 12

Metals (mg/kg)

Result

RL

Result

RL

Result

RL

Result

RL

Result

RL

Antimony

1.7

0.6

5.2

0.5

46.7

2.3

5,780

969

24.8

5.9

Arsenic

7.9

0.1

11.9

0.1

88.4

23.3

432

194

30.7

1.2

Cadmium

U

0.6

U

0.5

8.0

0.6

1.2

0.6

1.9

0.6

Chromium

10.8

1.2

12.8

1.1

23.5

1.2

150

1.2

54.4

1.2

Copper

10.6

2.3

14.5

2.2

126

2.3

385

2.4

356

2.4

Lead

40.9

0.6

45.5

0.5

7,010

116

76,400

969

1,870

23.6

Nickel

12.9

2.3

16.1

2.2

38.0

2.3

64.7

2.4

54.8

2.4

Silver

U

2.3

U

2.2

U

1.2

4.5

1.2

U

1.2

Zinc

36.1

2.3

43.1

2.2

1,790

2.3

5,540

2.4

2,720

2.4

Reference(s)

Ref. 7, pp. 73,
165, 363; 16, p.
9; 28, pp. 1-2

Ref. 7, pp. 74,
166,363; 16, p. 9;
28, pp. 1-2

Ref. 7, pp. 33, 125,
360; 16, p. 3; 28,
pp. 1-2

Ref. 7, pp. 34,
126, 360; 16, p. 3;
28, pp. 1-2

Ref. 7, pp. 43, 135.
360; 16, p. 7; 28, pp.
1-2

Notes:

J = - Estimated concentration [Ref. 7, p. 357]
bgs - below ground surface

Results in bold indicate contaminant was detected significantly above the concentration detected in background soil sample
S09.

U = The analyte was not detected at or above the reporting limit [Ref. 7, p. 357],

RL = Reporting limit. The reporting limit (RL) is the laboratory reporting limit with any dilution factor, volume adjustment,
or percent solids for each sample taken into account and is equivalent to the SQL as defined in the HRS [Ref. 1, Section 1.1;
7, p. 5],

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2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

Containment

Gas release to air: The air migration pathway was not scored; therefore, gas release to air containment was not evaluated.

Particulate release to air: The air migration pathway was not scored; therefore, particulate containment was not evaluated.

Subsurface Intrusion release: The soil exposure and subsurface intrusion pathway was not scored; therefore, the subsurface
intrusion containment was not evaluated.

Release to groundwater: The ground water pathway was not scored; therefore, groundwater containment was not evaluated.

Release via overland migration: Stormwater runoff from the area of Source 3 along the eastern fence line of the facility
discharges without treatment via Outfall 003 to a wooded area which drains toward Bayou Baton Rouge [Figure 2; Ref. 22, p.
22], As discussed above, there is no maintained engineered cover, liner, or a run-on control system and runoff management
system, and a surface water pathway (overland migration) containment factor value of 10 has been assigned [Ref. 1, Table 4-2;
16, pp. 3, 7, 9; 22, p. 22], Refer to Section 4.1.2.1 of this HRS documentation record for information supporting the significant
increase above background levels of inorganic analytes (i.e., antimony, cadmium, and lead) in Bayou Baton Rouge.

Containment Value: 10

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2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1 Source Hazardous Waste Quantity

2.4.2.1.1	Tier A: Hazardous Constituent Quantity - Not Calculated (NC)

The total Hazardous Constituent Quantity for Source 3 could not be adequately determined according to the HRS requirements;
that is, the total mass of all Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) hazardous
substances in the source and releases from the source is not known and cannot be estimated with reasonable confidence (Ref.
1, Section 2.4.2.1.1). There are insufficient historical and current data [manifests, potentially responsible party (PRP) records,
State records, permits, waste concentration data, etc.] available to adequately calculate the total or partial mass of all CERCLA
hazardous substances in the source and the associated releases from the source. Therefore, there is insufficient information to
calculate a total or partial Hazardous Constituent Quantity estimate for Source 1 with reasonable confidence. Scoring proceeds
to the evaluation of Tier B, Hazardous Wastestream Quantity (Ref. 1, Section 2.4.2.1.1).

Hazardous Constituent Quantity Value (S): Not Calculated
Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.2	Tier B: Hazardous Wastestream Quantity - Not Calculated (NO

The total Hazardous Wastestream Quantity for Source 3 could not be adequately determined according to the HRS requirements;
that is, the total mass of all hazardous waste streams and CERCLA pollutants and contaminants for the source and releases from
the source are not known and cannot be estimated with reasonable confidence (Ref. 1, Section 2.4.2.1.2). Insufficient historical
and current data (manifests, PRP records, State records, permits, waste concentration data, annual reports, etc.) are available
to adequately calculate the total or partial mass of all hazardous waste streams and CERCLA pollutants and contaminants for
the source and the associated releases from the source. Therefore, there is insufficient information to adequately calculate or
extrapolate a total or partial Hazardous Wastestream Quantity estimate for Source 1 with reasonable confidence. Scoring
proceeds to the evaluation of Tier C, Volume (Ref. 1, Section 2.4.2.1.2).

Hazardous Wastestream Quantity Value (W): Not Calculated
Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.3	Tier O Volume

Based on the analytical results of soil samples collected during the February ESI, it is apparent that contamination is present at
depth; however, an exact volume is not known at this time [Ref. 7, pp. 34, 73, 74, 126; 28, pp. 1-2], A Tier C volume value of
>0 is assigned [Ref. 1, Section 2.4.2.1.3],

Dimension of source (yd3): >0 yd3
Volume (V) Assigned Value: >0/2,500 = >0

2.4.2.1.4 Tier D: Area

A TierD area measure of 0 is assigned since the volume of the source could be estimated [Ref. 1, Section 2.4.2.1.4],

Area Assigned Value = 0

2.4.2.1.5 Source Hazardous Waste Quantity Value

Per the HRS, the highest of the values assigned to the source for hazardous constituent quantity (Tier A), hazardous wastestream
quantity (Tier B), Volume (Tier C), and Area (Tier D) should be assigned as the source hazardous waste quantity value [Ref. 1,
Section 2.4.2.1.5],

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TABLE 8. SOURCE 3 - HAZARDOUS WASTE QUANTITY VALUE

Tier Evaluated

Source 3 Values

A

Not Calculated

B

Not Calculated

C

>0

D

0

Source 3 Hazardous Waste Quantity Value: >0

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SITE SUMMARY OF SOURCE DESCRIPTION

TABLE 9. SITE SUMMARY AND SOURCE DESCRIPTION

Source
No.

Source Hazardous
Waste Quantity
Value

Source
Hazardous
Constituent
Quantity
Complete?
(Y/N)

Containment







Ground Water

Surface Water

Gas

Air Particulate

1

12,799.93

N

NE

10

NE

NE

2

>0

N

NE

9

NE

NE

3

>0

N

NE

10

NE

NE

TOTAL

12,799.93











Note:

NE = Not Evaluated

Other Possible Non-Scored Sources

Closed Solid Waste Landfill - From 1988 through July 1999 waste products were stabilized (to pass toxicity levels
established under RCRA) and placed into a solid waste landfill located immediately north of the former plant production area
[Ref. 6, p. 6], The solid waste landfill was semi-lined with clay and operated under solid waste permit GD0332054P0160 [Ref.
5, p. 15; 22, p. 16], The solid waste landfill was closed due to newer state requirements for landfill lining, resulting in the
construction of a new solid waste landfill [Ref. 22, p. 16], The closed solid waste landfill is connected to the facility's leachate
collection system [Ref. 22, pp. 16, 21], The closed solid waste landfill is regulated under a Louisiana Type 1 Solid Waste
Permit (Standard Permit No. P-0162) [Ref. 6, p. 6],

Open Solid Waste Landfill - After July 1999, stabilized waste products were placed in an open solid waste landfill situated on
the west side of Bayou Baton Rouge [Ref. 6, p. 6], The open solid waste landfill is currently undergoing RCRA closure [Ref.
22, p. 33], The open solid waste landfill is connected to the facility's leachate collection system [Ref. 22, pp. 16, 21], Leachate
is treated using an on-facility water treatment system before being discharged to Bayou Baton Rouge via Outfall 001 [Ref. 22,
pp. 17, 22], The open solid waste landfill is regulated under a Louisiana Type Permit (Standard Permit No. P-0326), which
regulates the construction, operation, and closure of the landfill [Ref. 6, p. 6; 24, p.7].

Waste Ponds - Background information indicates that stormwater and wastewater were treated in a series of ponds prior to
installation of the current stormwater collection system and WWTP were installed. The ponds are no longer present and were
reportedly capped by placing a 2-foot-thick layer of compacted clay. There is no record of whether the slag, sediments of piping
and pipe bedding material were removed or left in place prior to being and covered [Ref. 22, p. 19, 25, 45],

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4.0	SURFACE WATER MIGRATION PATHWAY

4.1	OVERLAND/FLOOD MIGRATION COMPONENT
4.1.1 GENERAL CONSIDERATIONS

4.1.1.1 Definition of Hazardous Substance Migration Path for Overland/Flood Component

The hazardous substance migration path includes the overland and in-water segments that hazardous substances would take as
they migrate away from sources in the watershed [Figure 2; Ref. 1, Section 4.1.1.1], The hazardous substance migration path
for overland and in-water segments are described below. The complete (overland and in-water segment) surface water pathway
is presented in Figure 4.

Drainage to Bavon Raton Ronpe

Leachate from the closed Hazardous Waste Piles #1 and #2, the closed solid waste landfill, and the open solid waste landfill is
collected by 11 leachate/groundwater collection wells. Leachate from each of the wells is pumped to a 101,000-gallon process
water tank and is then pumped to the WWTP. Treatment is accomplished by a common metals treatment train consisting of
pH adjustment, coagulation/flocculation, settling in an inclined plate clarifier, and discharge to Outfall 001 [Ref. 22, pp. 21-
22],

Stormwater for the former process areas of the Site is conveyed via surface flow, channels, and swales and discharges it as
"first flush" stormwater (defined as the first 1 inch of precipitation) to a 643,000-gallon capacity stormwater collection tank
located near the WWTP). The WWTP treats the combined influent from the process water tank (i.e., leachate and groundwater)
and stormwater collection tank (i.e., first-flush stormwater) and discharges it to Outfall 101. The water then flows from Outfall
101 to Outfall 001 and discharges to Bayou Baton Rouge. Untreated "post-first-flush stormwater discharges to Bayou Baton
Rouge at Outfall 001 (where it is commingled with wastewater treatment system (WWTS) effluent at the outfall) Stormwater
runoff from the area along the eastern fence line of the facility discharges without treatment via Outfall 003 to a wooded area
which drains toward Bayou Baton Rouge, which is approximately 200 feet north of Outfall 003. [Figure 2; Ref. 22, p. 22],

Source Distances to Surface Water Probable Points of Entry

As discussed below in the in-water segment section, there are two PPEs to surface water evaluated for the Exide Baton Rouge
facility. PPE 1 is located approximately 200 feet north of Outfall 003 and PPE2 is located at Outfall 001. Both PPEs are located
along Bayou Baton Rouge. Source 1 includes Hazardous Waste Pile #1, which is located approximately 100 feet from the
eastern bank of Bayou Baton Rouge; and Hazardous Waste Pile #2 which is located approximately 200 feet from the eastern
bank of Bayou Baton Rouge [Ref. 5, p. 15; Figure 2], Source 2 contaminated soil is located within the former process area and
its overland path to surface water PPE2 is approximately 850 feet, as runoff is directed to the WWTP and stormwater collection
system prior to being discharged to Bayou Baton Rouge via Outfall 001 [Figure 2; Ref. 22, p. 22]. The Source 2 contaminated
soil samples with the closest migration path to PPE2 are samples EBR-S04 and EBR-S05. Source 3 is delineated by two
contaminated soils samples; contaminated soil sample EBR-S07 is the closest sample to PPE1 and is located approximately
300 feet from PPE1 [Figure 2],

In-water Segment

The TDL begins within Bayou Baton Rouge approximately 200 feet north of Outfall 003. This location is evaluated
as PPE1. FromPPEl, the TDL extends west along the northern border of the Site, then south along the western border
of the site for approximately 0.4 mile to the location of Outfall 001, which is evaluated as PPE2. From PPE2, the TDL
continues along Bayou Baton Rouge for approximately 1.4 miles, where the surface water pathway splits. TDL 1 is the
continuation of Bayou Baton Rouge, which meanders south through Devil's Swamp for approximately 6 miles, where
it discharges to the Mississippi River. The remainder of TDL1 extends approximately 7.2 miles along the Mississippi
River where the TDL associated with upstream PPE1 ends; TDL1 continues for 0.4 mile along the Mississippi River
where the TDL associated with downstream PPE2 ends. From the point where the surface water migration pathway
splits, TDL2 meanders south, north and east through an unnamed stream for approximately 1.8 miles, where it
discharges to the Mississippi River. TDL2 continues along the Mississippi River for approximately 11.4 miles where
the TDL associated with upstream PPE1 ends; TDL2 continues for 0.4 mile along the Mississippi River where the TDL

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associated with downstream PPE2 ends at the point where Bayou Baton Rouge (i.e., TDL1) enters the Mississippi
River [see Figure 4],

Since there are two PPEs to surface water and a branched TDL, there are a total of four terminuses to the surface water
migration pathway as described above. Only the terminuses associated with the downstream PPE2 are included in
Figure 4. The two terminuses associate with upstream PPE1 would be located approximately 0.4 mile upstream of the
ends of TDL 1 and TDL2.

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4.1.2.1 Likelihood of Release
4.1.2.1.1 Observed Release
Observed Release hv Chemical Analyses

Sediment samples collected by EPA from the Bayou Baton Rouge in February 2023 and March 2023 document that
hazardous substances, (i.e., antimony, cadmium, and lead) are present in Bayou Baton Rouge sediments at levels that
meet the criteria for observed release by chemical analysis [Figure 3; Tables 10-14; Ref. 1, Section 4.1.2.1.1], A zone
of contamination extending from PPE2 at outfall 001 to downstream sample location EBR-SED04-12-20230209-51
is evaluated [Figure 3A and Section 4.1.4.3],

ESI Sediment Sampling (February 20231

EPA collected sediment samples from Bayou Baton Rouge from February 6 to 8, 2023. Sediment samples were
collected at locations upstream (i.e., background), at probable points of entry, and downstream of the Site [Ref. 28,
pp. 1, 3). Sediment samples were collected from depths of 0 to 12 inches and 12 to 24 inches below the sediment
surface (bss) [Ref. 16, pp. 10-25], Samples were analyzed by the EPA Region 6 Laboratory, Laboratory Services and
Applied Science Division, for metals by EPA Method 6020B and 6010D [Ref.7, pp. 7-15], Samples were validated
in accordance with internal EPA data validation guidelines. The contaminated sediment samples delineate a zone of
contamination extending from the Site's downstream PPE to surface water at Outfall 001 (i.e., PPE2) to downstream
sediment sample locationEBR-SED04-12-20230209-51 [see Figures 3,3A and Section 4.1.4.3],

ESI Sediment Sampling (March 2023)

EPA returned to the Site to collect sediment samples from Bayou Baton Rouge on March 21, 2023. Sediment samples
from points from Bayou Baton Rouge locations upstream (i.e., background) of Outfall 001, at probable points of entry
(PPE2), and downstream of the Site [Ref. 28, pp. 1, 4], Sediment samples were collected from one-foot intervals to a
depth of 5 feet bss [Ref. 17, pp. 1-8], Samples were analyzed by Pace Analytical for metals by EPA Method 6020
[Ref. 8, pp. 6-8; 9, pp. 6-9], Data was validated following USEPA National Functional Guidelines for Inorganic
Superfund Data Review (November 2020), Quality Assurance/Quality Control Guidance for Removal Activities
(April 1990), and/or Regional protocol for Holding Times, Blanks, and VOA Preservation (April 13, 1989) [Ref. 10,
p. 1; 11, p. 1]. The contaminated sediment samples delineate a zone of contamination extending from the Site's
downstream PPE to surface water at Outfall 001 (PPE2) to downstream sediment sample location EBR-SED21-12-
20230207-51 [see Figure 3 and Section 4.1.4.3],

Sample Similarity Discussion (Background and Release Samples) - February 2023

In February 2023, sediment samples were collected from three locations (i.e., EBR-SED12, EBR-SED13, and EBR-
SED15) in Bayou Baton Rouge to evaluate background conditions upstream of the Site [see Figure 3], Sediment
samples were collected from sample locations adjacent to PPEs of the site as well as locations downstream of the site.
The background and release sediment samples collected during the February 2023 sampling event are considered
comparable because all were: collected using EPA Standard Operating Procedures (SOPs); collected from similar
depth intervals; analyzed by the same laboratories using the same analytical methods; and validated according to the
same data validation guidelines [Ref. 7, pp. 18-21,48, 89-90, 110-113, 140, 175, 181-182], Samples were collected
from similar depositional environments (i.e., similar sediment types that are predominantly silt, and clay, with similar
percent solid content), except for background sediment sample EBR-SED13, which was predominantly sand [Ref. 16,
pp. 13, 16, 21-23], Background and release sediment sample physical characteristics are presented in Table 10.
Background and release sediment sample concentrations are presented in Tables 11 and 14, respectively.

Sample Similarity Discussion (Background and Release Samples) - March 2023

In March 2023, sediment samples were collected from one location (i.e., EBR-SED20) in Bayou Baton Rouge to
evaluate background conditions [see Figure 3], This sample was collected upstream of PPE2 but downstream of
PPE1. This location was deemed an adequate background sediment location for the March 2023 sediment sampling

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event, as sediment samples collected from locations within Bayou Baton Rouge between the PPEs during the February
2023 sediment sampling event did not exhibit concentrations of metals at levels significantly above levels detected in
background sediment samples. Specifically, analytical results from sediment samples collected from locations EBR-
SED09, EBR-SED10, and EBR-SED011 did not have any concentrations significantly above those detected in
background sediment samples collected from background locations EBR-SED12, EBR-SED13, and EBR-SED15
[Figure 3; Ref. 7, pp. 16-21, 51-54, 89-90, 108-113, 143-146, 181-182, 236-241, 264-267, 284-285; 28, p. 3],

The background and release sediment samples collected during the March 2023 sampling event are considered
comparable because all were: collected using EPA Standard Operating Procedures (SOPs); collected from similar
depth intervals; analyzed by the same laboratories using the same analytical methods; and validated according to the
same data validation guidelines [Ref. 8, pp. 58, 76; 9, pp. 60-61, 64, 74, 76; 10, pp. 3-5, 7, 20, 25; 11, pp. 3-10, 20,
22], Background and release sediment samples were also collected from similar depositional environments (i.e.,
similar sediment types that are predominantly silt and clay, with similar percent solid content); except for release
sample EBR-SED21, which was predominantly sand at the 1-2 feet depth below top of sediment [Ref. 17, pp. 1-2, 6-
7], Background and release sediment sample physical characteristics are presented in Table 10. Background and
release sediment sample concentrations are presented in Tables 11 and 14, respectively.

Bavou Baton Rouge Sediment Removal

It should be noted that analytical results from a sediment sample collected adjacent to Outfall 001 in February 2023
(EBR-SED08) did not show metals concentration which would qualify for an observed release to surface water [Ref.
7, pp. 49-50, 141-142, 361; 28, p. 3], In October 2013, a consultant for Exide conducted sediment sampling from 10
locations in the Bayou Baton Rouge to determine the extent of metals distribution in the bayou and to prepare a Risk
Evaluation/Corrective Action Plan (RECAP) Management Option 3 (MO-3) report. Analytical results indicated that
all sediment samples were below RECAP-M03 risk standards, except for arsenic in one sample at the 1 to 3 and 3 to
5-foot intervals. Delineation sampling conducted in October 2013 identified a contaminated area with arsenic
concentrations up to 91 milligrams per kilogram (mg/kg). From January to April 2015, approximately 350 cubic yards
of impacted sediments and soil were removed from the bayou adjacent to Exide Outfall 001. The excavation advanced
to a depth of approximately 5 to 7 feet below surface in the bayou adjacent to Outfall 001. Confirmation samples
were required by the Louisiana Department of Environmental Quality (LDEQ). Samples were below site remediation
standards for arsenic. LDEQ requested additional sampling near Outfall 001 to further evaluate lead concentrations in
the sediment. In February 2016, three additional confirmation soil samples were collected; results from these samples
indicated concentrations of lead below RECAP standards [Ref. 14, pp. 6-8, 13-14, 16],

This sediment removal may be the reason for low metals concentrations detected in the sediment sample adjacent to
Outfall 001 during EPA sampling event conducted in February 2023.

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TABLE 10. SEDIMENT SAMPLE PHYSICAL CHARACTERISTICS

Field Sample ID

Lab Sample ID

Sample Date
(Military Time)

Depth below top
of sediment
(inches)

Solids
(%)

Sediment Description

Sample Location/Rationale

References

Background Samples - February 2023

EBR-SED12-12-
20230206-51

2302002-03

2/6/2023
(10:20)

0-12

63.74

Clayey silt, some organics, trace sand,
gray, low plasticity, fine to very fine
grained, no odor

Bayou Baton Rouge - upstream
of site

Figure 3; 7, pp. 18, 110,
359; 13, p. 5; 16, p. 21; 28,
p. 3

EBR-SED 12-24-
20230206-51

2302002-04

2/6/2023
(10.20)

12-24

65.49

Clayey silt, some organics, trace sand,
gray, moderate plasticity, no odor

Bayou Baton Rouge - upstream
of site

Figure 3; 7, pp. 19, 111,
359; 13, p. 5; 16, p. 21; 28,
p. 3

EBR-SED13-12-
20230206-51

2302002-05

2/6/2023
(10:45)

0-12

86.94

Sand, gray and black, medium grained,
subangular, well sorted, no odor

Bayou Baton Rouge - upstream
of site

Figure 3; 7, pp. 20, 112,
359; 13, p. 5; 16, p. 22; 28,
p. 3

EBR-SED 13-24-
20230206-51

2302002-06

2/6/2023
(10:45)

12-24

83.39

Sand, gray and black, medium grained,
subangular, well sorted, no odor

Bayou Baton Rouge - upstream
of site

Figure 3; 7, pp. 21, 113,
359; 13, p. 5; 16, p. 22; 28,
p. 3

EBR-SED15-12-
20230209-51

2302006-17

2/8/2023
(13:00)

0-12

80.93

Sand and clay, some gravel, gray, very
poorly sorted, subangular, medium
grained, no odor.

Bayou Baton Rouge - upstream
of site

Figure 3; 7, pp. 89, 181,
364; 13, p. 7; 16, p. 23; 28,
p. 3

EBR-SED15-24-
20230209-51

2302006-18

2/8/2023
(13:00)

12-24

63.81

Clay, some organics, trace sand, gray,
no plasticity, no odor; note - interval
contained a leather-like debris

Bayou Baton Rouge - upstream
of site

Figure 3; 7, pp. 90, 182,
364; 13, p. 7; 16, p. 23; 28,
p. 3

Background Samples - March 2023

EBR-SED20-12-
20230321-51

L1597545-01

3/21/2023
(12:01)

0-12

73.0

Silt, some organics, tan to grey, no
odor, moist

Bayou Baton Rouge - upstream
of Outfall 001/Background

Figure 3; 9, pp. 60, 226; 13,
pp. 9, 10; 17, p. 1; 28, p. 4

EBR-SED20-24-
20230321-51

L1597545-02

3/21/2023
(12:02)

12-24

74.0

Silt, some organics, tan to grey, no
odor, moist

Bayou Baton Rouge - upstream
of Outfall 001/Background

Figure 3; 9, pp. 61, 226; 13,
pp. 9, 10; 17, p. 1; 28, p. 4

EBR-SED20-36-
20230321-51

L1597545-03

3/21/2023
(12:03)

24-36

76.5

Sandy silt, gray, fine grained, no odor,
moist

Bayou Baton Rouge - upstream
of Outfall 001/Background

Figure 3; 9, pp. 62, 226; 13,
pp. 9, 10; 17, p. 1; 28, p. 4

EBR-SED20-48-
20230321-51

L1597545-04

3/21/2023
(12:05)

36-48

75.1

Clay, some organics, tan, high
plasticity, slightly moist

Bayou Baton Rouge - upstream
of Outfall 001/Background

Figure 3; 9, pp. 63, 226; 13,
pp. 9, 10; 17, p. 1; 28, p. 4

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TABLE 10. SEDIMENT SAMPLE PHYSICAL CHARACTERISTICS

Field Sample ID

Lab Sample ID

Sample Date
(Military Time)

Depth below top
of sediment
(inches)

Solids
(%)

Sediment Description

Sample Location/Rationale

References

EBR-SED20-60-
20230321-51

L1597545-05

3/21/2023
(12:06)

48-60

77.9

Clay, some organics, tan, high
plasticity, slightly moist

Bayou Baton Rouge - upstream
of Outfall 001/Background

Figure 3; 9, pp. 64, 226; 13,
pp. 9, 10; 17, p. 1; 28, p. 4

















Release Samples - February 2023

EBR-SED07-
24-20230207-
51

2302003-20

2/7/2023
(10:25)

12-24

70.96

Clayey silt, trace organics, gray, low
plasticity, no odor

Bayou Baton Rouge -
downstream of outfall 001
and within Palustrine wetland

Figure 3; 7, pp. 48, 140,
361; 13, p. 5; 16, p. 16;
28, p. 3

EBR-SED04-
12-20230209-
51

2302006-11

2/7/2023
(13:48)

0-12

73.99

Sandy clay, gray, well sorted, very
fine grained, no odor

Bayou Baton Rouge -
downstream of outfall 001
and within Palustrine wetland

Figure 3; 7, pp. 83, 175,
364; 13, p. 6; 16, p. 13;
28, p. 3

Release Samples - March 2023

EBR-SED21-
24-20230321-
51

L1597531-02

3/21/2023
(16:07)

12-24

72.5

Sand, brown, well sorted, no odor

Bayou Baton Rouge -
downstream of Outfall 001
and within palustrine wetland

Figure 3; 8, pp. 58, 198;
13, pp. 9, 10; 17, p. 2; 28,
P. 4

EBR-SED25-
60-20230321-
51 (Lab ID
L1597545-15)

L1597545-15

3/21/2023
(10:36)

48-60

74.7

Silty sand, gray, moderately sorted,
no odor, moist

Bayou Baton Rouge -
downstream of Outfall 001
and upstream of palustrine
wetland

Figure 3; 9, pp. 74, 226;
13, pp. 9, 10; 17, p. 6; 28,
p. 4

EBR-SED25-
60-20230321-
52(Lab ID
L1597545-16)

L1597545-16

3/21/2023
(10:37)

48-60

74.9

Silty sand, gray, moderately sorted,
no odor, moist

Bayou Baton Rouge -
downstream of Outfall 001
and upstream of palustrine
wetland

Figure 3; 9, pp. 76, 226;
13, pp. 9, 10; 17, p. 6; 28,
p. 4

EBR-SED26-
60-20230321-
51

L1597531-20

3/21/2023
(14:53)

48-60

78.4

Silt, brown, well sorted, no odor,
moist

Bayou Baton Rouge -
downstream of Outfall 001
and upstream of palustrine
wetland

Figure 3; 8, pp. 76, 199;
13, pp. 9, 10; 17, p. 7; 28,
p. 4

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TABLE 11. BACKGROUND SEDIMENT SAMPLE CONCENTRATIONS

Station Location

Hazardous
Substance

Concentration

ACRQL

Units

Reference

Background Samples - February 2023

EBR-SED12-12-
20230206-51

Antimony

0.5 U

0.5

mg/kg

Figure 3; 7, pp. 110, 359; 13, p. 5; 16,
p. 21; 28, p. 3

Cadmium

0.5 U

0.5

mg/kg

Figure 3; 7, pp. 18, 359; 13, p. 5; 16, p.
21; 28, p. 3

Lead

11.2

0.5

mg/kg

Figure 3; 7, pp. 110, 359; 13, p. 5; 16,
p. 21; 28, p. 3

EBR-SED 12-24-
20230206-51

Antimony

0.7 U

0.7

mg/kg

Figure 3; 7, pp. 111, 359; 13, p. 5; 16,
p. 21; 28, p. 3

Cadmium

0.7 U

0.7

mg/kg

Figure 3; 7, pp. 19, 359; 13, p. 5; 16, p.
21; 28, p. 3

Lead

12.4

0.7

mg/kg

Figure 3; 7, pp. Ill, 359; 13, p. 5; 16,
p. 21; 28, p. 3

EBR-SED13-12-
20230206-51

Antimony

0.5 U

0.5

mg/kg

Figure 3; 7, pp. 112, 359; 13, p. 5, 16,
p. 22; 28, p. 3

Cadmium

0.5 U

0.5

mg/kg

Figure 3; 7, pp. 20, 359; 13, p. 5, 16, p.
22; 28, p. 3

Lead

5.0

0.5

mg/kg

Figure 3; 7, pp. 112, 359; 13, p. 5, 16,
p. 22; 28, p. 3

EBR-SED 13-24-
20230206-51

Antimony

0.6 U

0.6

mg/kg

Figure 3; 7, pp. 113, 359; 13, p. 5, 16,
p. 22; 28, p. 3

Cadmium

0.6 U

0.6

mg/kg

Figure 3; 7, pp. 21, 359; 13, p. 5, 16, p.

22; 28, p. 3

Lead

7.7

0.6

mg/kg

Figure 3; 7, pp. 113, 359; 13, p. 5, 16,
p. 22; 28, p. 3

EBR-SED15-12-
20230209-51

Antimony

1 U

1.0

mg/kg

Figure 3; 7, pp. 181, 364; 13, p. 7; 16,
p. 23; 28, p. 3

Cadmium

0.5 U

0.5

mg/kg

Figure 3; 7, pp. 89, 364; 13, p. 7; 16, p.
23; 28, p. 3

Lead

7.9

1.0

mg/kg

Figure 3; 7, pp. 181, 364; 13, p. 7; 16,
p. 23; 28, p. 3

EBR-SED 15-24-
20230209-51

Antimony

1.4 U

1.4

mg/kg

Figure 3; 7, pp. 182, 364; 13, p. 7; 16,
p. 23; 28, p. 3

Cadmium

0.7 U

0.7

mg/kg

Figure 3; 7, pp. 90, 364; 13, p. 7; 16, p.
23; 28, p. 3

Lead

10.8

1.4

mg/kg

Figure 3; 7, pp. 182, 364; 13, p. 7; 16,
p. 23; 28, p. 3

Background Samples - March 2023

EBR-SED20-12-
20230321-51

Lead

8.66 JK (12.47)

2.74

mg/kg

Figure 3; 9, pp. 60, 226; 11, pp. 3-6;
13, pp. 9, 10; 17, p. 1; 28, p. 4

Cadmium

0.137 JQK

1.37

mg/kg

Figure 3; 9, pp. 60, 226; 11, pp. 3-6;
13, pp. 9, 10; 17, p. 1; 28, p. 4

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TABLE 11. BACKGROUND SEDIMENT SAMPLE CONCENTRATIONS

Station Location

Hazardous
Substance

Concentration

ACRQL

Units

Reference

EBR-SED20-24-
20230321-51

Lead

11.8 JK (16.99)

2.70

mg/kg

Figure 3; 9, pp. 61, 226; 11, pp. 3-5, 7;
13, pp. 9, 10; 17, p. 1; 28, p. 4

Cadmium

1.35 U

1.35

mg/kg

Figure 3; 9, pp. 61, 226; 11, pp. 3-5, 7;
13, pp. 9, 10; 17, p. 1; 28, p. 4

EBR-SED20-36-
20230209-51

Lead

20.2 JK (29.08)

2.62

mg/kg

Figure 3; 9, pp. 62, 226; 11, pp. 3-5, 8;
13, pp. 9, 10; 17, p. 1; 28, p. 4

Cadmium

0.145 JQK

1.31

mg/kg

Figure 3; 9, pp. 62, 226; 11, pp. 3-5, 8;
13, pp. 9, 10; 17, p. 1; 28, p. 4

EBR-SED20-48-
20230209-51

Lead

26.7 JK (38.44)

2.66

mg/kg

Figure 3; 9, pp. 63, 226; 11, pp. 3-5, 9;
13, pp. 9, 10; 17, p. 1; 28, p. 4

Cadmium

0.123 JQK

1.33

mg/kg

Figure 3; 9, pp. 63, 226; 11, pp. 3-5, 9;
13, pp. 9, 10; 17, p. 1; 28, p. 4

EBR-SED20-60-
20230209-51

Lead

32.5 JK (46.8)

2.57

mg/kg

Figure 3; 9, pp. 64, 226; 11, pp. 3-5,
10; 13, pp. 9, 10; 17, p. l;28,p. 4

Cadmium

0.416 JQK

1.28

mg/kg

Figure 3; 9, pp. 64, 226; 11, pp. 3-5,
10; 13, pp. 9, 10; 17, p. l;28,p. 4

Notes:

•	mg/kg - milligrams per kilogram used for metal analytes.

•	J = The analyte was analyzed for, but the associated numerical value may not be consistent with the amount actually
present in the environmental sample or may not be consistent with the sample detection or quantitation limit. The value
is an estimated quantity. The data should be seriously considered for decision-making and are usable for many
purposes [Ref. 11, p. 2],

•	U = The analyte was not detected at or above the reporting limit [Ref. 7, p. 357],

•	K = Unknown bias [Ref. 11, p. 2],

•	Q = The reported concentration is less than the sample quantitation limit for the specific analyte in the sample [Ref. 10,
p. 2; 11, p. 2],

•	The J-qualified estimated results have been adjusted up to account for unknown bias per EPA Quick Reference Fact
Sheet Using Qualified Data to Document an Observed Release and Observed Contamination. The adjustment factors
are provided in the EPA fact sheet and the adjusted results are shown in parentheses in the tables above. Although J-
qualified results are estimated, the presence of the analytes is not in question and the result is usable [Ref. 12, pp. 5-9,
20],

•	March 2023 background results with JQK qualifiers for cadmium are associated with no bias and, therefore are not
adjusted with a correction factor [Ref. 11, pp. 4-5],

•	The adjusted contract required quantitation limit (ACRQL) is the contract required quantitation limit with any dilution
factor, volume adjustment, or percent solids for each sample taken into account, and because the samples were analyzed
through the CLP, it is equivalent to the CRQL as defined in the HRS [Ref. 1, Section 1.1],

Background Sample Determinations

During the February 2023 ESI sampling event, all sediment samples were collected from the 0- to 12-inch and 12- to 24-inch
intervals. Contaminants in release samples qualifying for an observed release in February 2023 were compared to the highest
of the background samples concentrations for each observed release contaminant (i.e., antimony, cadmium, and lead).

During the March 2023 sampling event, sediment samples at each location were collected at one-foot intervals to a depth of 60
inches. The highest background concentrations of each observed release contaminant from the 0 to 24 inch and 24-to-60-inch
depth ranges are compared to release samples. The table below identifies the highest concentration of each observed release
contaminant (i.e., cadmium and lead) within the 0 to 24 and 24-to-60-inch depth intervals.

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TABLE 12. SIGNIFICANT BACKGROUND SEDIMENT CONCENTRATIONS

FEBRUARY 2023

Depth
Range

Sample ID

Lab ID

Hazardous
Substance

Concentration

ACRQL

References

0-24"

EBR-SED15-24-
20230209-51

2302006-18

Antimony

1.4 U mg/kg

1.4 mg/kg

Figure 3; 7, pp.

182, 364; 13, p.
7; 16, p. 23; 28,
p. 3



EBR-SED12-24-
20230206-51

EBR-SED15-24-
20230209-51

2302002-04
2302006-18

Cadmium

0.7 U mg/kg

0.7 mg/kg

Figure 3; 7, pp.

19, 90, 359, 364;
13, p. 5; 7, 16, p.
21, 23; 28, p. 3



EBR-SED 12-24-
20230206-51

2302002-03

Lead

12.4 mg/kg

0.7 mg/kg

Figure 3; 7, pp.

Ill, 359; 13, p.
5; 16, p. 21; 28,
p. 3

MARCH 2023

Depth
Range

Sample ID

Lab ID

Lead

(mg/kg)

ACRQL

Cadmium

(mg/kg)

ACRQL

Reference

0-24"

EBR-SED20-
12-20230321-
51

L1597545-
01

8.66 JK
(12.47)

2.74

0.137
JQK

1.37

Figure 3; 9, pp. 60, 226;
11, pp. 3-6; 13, pp. 9, 10;
17, p. 1; 28, p. 49, p. 60

EBR-SED20-
24-20230321-
51

L1597545-
02

11.8 JK

(16.99)

2.70

1.35 U

1.35

Figure 3; 9, pp. 61, 226;
11, pp. 3-5,7; 13, pp. 9,
10; 17, p. 1; 28, p. 4

24-60"

EBR-SED20-
36-20230321-
51

L1597545-

03

20.2 JK
(29.08)

2.62

0.145 J

1.31

Figure 3; 9, pp. 62, 226;
11, pp. 3-5, 8; 13, pp. 9,
10; 17, p. 1; 28, p. 4

EBR-SED20-
48-20230321-
51

L1597545-
04

26.7 JK
(38.44)

2.66

0.123
JQK

1.33

Figure 3; 9, pp. 63, 226;
11, pp. 3-5, 9; 13, pp. 9,
10; 17, p. 1; 28, p. 4

EBR-SED20-
60-20230321-
51

L1597545-
05

32.5 JK
(46.8)

2.57

0.416
JQK

1.28

Figure 3; 9, pp. 64, 226;
11, pp. 3-5, 10; 13, pp. 9,
10; 17, p. 1; 28, p. 4

Note:

Bolded concentrations identify the highest background of that depth range.

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SW Pathway - Likelihood of Release

Based on an evaluation of the above, the Release samples will be compared to the designated background level as shown
below:

TABLE 13. SIGNIFICANT BACKGROUND SEDIMENT CONCENTRATIONS - FEBRUARY AND MARCH 2023

Hazardous
Substance

Maximum
Background
Concentration

(mg/kg)

ACRQL or 3 x
Background

(mg/kg)

Maximum Background Concentration Sample No.

February 2023 Samples (0-24 inches)

Antimony

1.4 U

1.4

EBR-SED15-20230209-51

Cadmium

0.7 U

0.7

EBR SED15-24-20230209-51/EBR-SED12-24-20230206-51

Lead

12.4

37.2

EBR-SED 12-24-20230206-51

March 2023 Samples (0-24 inches)

Lead

11.8 JK (16.99)*

50.97

EBR-SED20-24-20230321-51

Cadmium

1.35 U

1.35

EBR-SED20-24-20230321-51

March 2023 Samples (24 to 60 inches)

Cadmium

0.416 JQK

1.248

EBR-SED20-60-0321 -51

Lead

32.5 JK (46.8)*

140.4

EBR-SED20-60-0321 -51

Notes:

•	mg/kg - milligrams per kilogram (mg/kg) used for metal analytes.

•	U = The analyte was not detected at or above the reporting limit [Ref. 7, p. 357],

•	J = The analyte was analyzed for, but the associated numerical value may not be consistent with the amount actually
present in the environmental sample or may not be consistent with the sample detection or quantitation limit. The
value is an estimated quantity. The data should be seriously considered for decision-making and are usable for many
purposes [Ref. 11, p. 2],

•	K = Unknown bias [Ref. 11, p. 2],

•	Q = The reported concentration is less than the sample quantitation limit for the specific analyte in the sample [Ref.
11, p. 2],

•	* - adjusted concentration

•	The J-qualified estimated results have been adjusted up to account for unknown bias per EPA Quick Reference Fact
Sheet Using Qualified Data to Document an Observed Release and Observed Contamination. The adjustment factors
are provided in the fact sheet and the adjusted results are shown in parentheses. Although J-qualified results are
estimated, the presence of the analytes is not in question and the result is usable [Ref. 12, pp. 5-9, 20],

•	March 2023 observed release background results with JQK qualifiers for cadmium are associated with no bias and,
therefore are not adjusted with a correction factor [Ref. 11, pp. 4-5],

•	ACRQL - Adjusted Contract Required Quantitation Limit.

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Observed Release

TABLE 14. RELEASE SEDIMENT SAMPLE CONCENTRATIONS

Station Location

Hazardous
Substance

Concentration

ACRQL

Background-
ACRQL or 3x
Result

Units

Reference

February 2023 (0-24 inches)

EBR-SED04-12-
20230209-51

Lead

58.5

1.2

37.2

mg/kg

Figure 3; 7, pp. 175, 364; 13, p.
6; 16, p. 13; 28, p. 3

EBR-SED07-24-
20230207-51

Antimony

4.8

1.1

1.4 U

mg/kg

Figure 3; 7, pp. 140, 361; 13, p.
5; 16, p. 16; 28, p. 3

Cadmium

4.0

0.5

0.7 U

mg/kg

Figure 3; 7, pp. 48, 361; 13, p.
5; 16, p. 16; 28, p. 3

Lead

70.1

1.1

37.2

mg/kg

Figure 3, 7, pp. 140, 361; 13, p.
5; 16, p. 16; 28, p. 3

March 2023 (0-24 inches)

EBR-SED21-24-
20230321-51

Lead

79.8 JK (55.41)

2.76

50.97

mg/kg

Figure 3; 8, pp. 58, 198: 10, pp.
3-5, 7; 12, pp. 8, 20; 13, pp. 9,
10; 17, p. 2; 28, p. 4

March 2023 (24-60 inches)

EBR-SED25-60-
20230321-51 (Lab
ID L1597545-15)

Cadmium

2.64

1.34

1.248

mg/kg

Figure 3; 9, pp. 74, 226; 11, pp.
3-5, 20; 13, pp. 9, 10; 17, p. 6;
28, p. 4

EBR-SED25-60-
20230321-52 (Lab ID
L1597545-16)

Cadmium

1.72

1.33

1.248

mg/kg

Figure 3; 9, pp. 76, 226; 11, pp.
3-5, 22; 13, pp. 9, 10; 17, p. 6;
28, p. 4

EBR-SED26-60-
20230321-51

Cadmium

6.62

1.28

1.248

mg/kg

Figure 3; 8, pp. 76, 199; 10, pp.
3-5, 25; 13, pp. 9, 10; 17, p. 7;
28, p. 4

Notes:

•	mg/kg - milligrams per kilogram.

•	J = The analyte was analyzed for, but the associated numerical value may not be consistent with the amount actually
present in the environmental sample or may not be consistent with the sample detection or quantitation limit. The
value is an estimated quantity. This data should be seriously considered for decision-making and are usable for many
purposes [Ref. 10, p. 2],

•	K = Unknown bias [Ref. 10, p. 2; 11, p. 2],

•	U = The analyte was not detected at or above the reporting limit [Ref. 7, p. 357],

•	The J-qualified estimated results have been adjusted per EPA Quick Reference Fact Sheet Using Qualified Data to
Document an Observed Release and Observed Contamination. Unknown bias and bias high observed release
concentrations are adjusted down. Bias low observed release concentrations are not adjusted. The adjustment factors
are provided in the fact sheet and the adjusted results are shown in parentheses. Although J-qualified results are
estimated, the presence of the analytes is not in question and the result is usable [Ref. 12, pp. 5-9, 20],

•	The adjusted contract required quantitation limit (ACRQL) is the contract required quantitation limit with any
dilution factor, volume adjustment, or percent solids for each sample taken into account, and because the samples
were analyzed through the CLP, it is equivalent to the CRQL as defined in the HRS [Ref. 1, Section 1.1; 8, p. 9; 10,
p. 2],

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Attribution

ESI Sediment samples collected by EPA from Bayou Baton Rouge downstream of the Exide facility in February and March
2023 contained concentrations of lead, antimony, and cadmium at concentrations significantly above concentrations detected in
background sediment samples collected upstream of the Exide facility [see Section 4.1.2.1.1], Lead, antimony, and cadmium
were also detected in pre-treatment leachate samples collected from the WWTP, and in leachate seep samples collected from
seep areas located downgradient and adjacent to Hazardous Waste Piles #1 and #2 (i.e., Source 1). Lead, antimony and cadmium
were also detected in soil samples at levels significantly above background in contaminated soil Sources 2 and 3. Each of these
sources are not fully contained (see Section 2.2 of this HRS Documentation Record for each of these sources). Runoff from
Sources 1 and 2 is directed to a WWTP for treatment prior to being discharged to Bayou Baton Rouge via Outfall 001. However,
leachate seeps downgradient of both Hazardous Waste Piles #1 and #2 have a direct route to Bayou Baton Rouge. Source 3 has
a direct overland route to Bayou Baton Rouge, as stormwater runoff from Source 3 is directed to Bayou Baton Rouge untreated.
Metals included in the observed release are attributable to the site as evidenced by the Site's previous history as a lead-battery
recycler that operated a lead smelter and refinery which recycled lead bearing materials between 1969 and 2009 [Ref. 5, p. 14];
and the presence of the same substances in soil samples collected from site sources during the ESI sampling event conducted
by EPA in February and March 2023.

With respect to upstream sources to the contaminants scored in an observed release to surface water, it does not appear that
sediment quality within Bayou Baton Rouge is being impacted from upstream sources. ESI sediment sample EBR-SED11,
collected from just downstream of Exide PPE1 did not exhibit concentrations of metals at concentration significantly above the
concentrations detected in background ESI sediment samples collected from sample locations EBR-SED12, EBR-SED13, and
EBR-SED15 [Ref. 7, pp. 18-21, 53-54, 89-90, 110-113, 145-146, 181-182; 28, p. 3],

Other Possible Sites

The Exide Baton Rouge Site is located in an industrial area. The following is a summary of other possible sites that have
potential sources of hazardous substances in the area.

Petro Processors of Louisiana, Inc.

Petro Processors Inc. (EPA ID No. LAD057482713) is a National Priorities List (NPL) site located immediately south of the
Exide Baton Rouge facility [Figure 2; Ref. 29, p. 2], The site consists of two disposal areas, known as Scenic Highway and
Brooklawn [Ref. 20, p. 1]. The Brooklawn disposal area is located immediately south of the Exide Baton Rouge facility [Figure
2; Ref. 29, p. 13], Petrochemical wastes were disposed in two lagoons along the Bayou Baton Rouge floodplain and in pits in
the northern portion of the site. Site disposal practices resulted in the contamination of sediment, surface water, soil, and air
with organic contaminants [Ref. 29, p. 2], Chemicals of concern associated with the Petro site include 1,2-dichloroethane
(DCA), cis-l,2-dichloroethylene (cis-DCE), trans-1,2-dichloroethylene (trans-DCE), hexachlorobenzene (HCB),
hexachlorobutadiene (HCBD), tetrachloroethene (PCE), 1,1,2,2-tetrachloroethane (TeCA), 1,1,2-trichloroethane (TCA),
trichloroethylene (TCE), and vinyl chloride [Ref.29, p. 14]. The metals contamination found in sediment in Bayou Baton Rouge
do not appear to be attributable to processes at the Petro Processors facility.

Oxbow Calcining. LLC

Oxbow Calcining, LLC operates a coke calcining plant on Brooklawn Drive and borders the Exide facility to the east [see
Figure 2], This facility has a National Pollutant Discharge and Elimination System (NPDES) permit that allows discharge to
Bayou Baton Rouge. Materials permitted for discharge include once through non-contact cooling water, stormwater runoff,
dust suppression runoff, pad washdown water, miscellaneous wastewaters including but not limited to firefighting water, fire
hydrant flushings, potable water sources, lawn watering, routine external building washdown, pavement washdown, air
conditioner condensate, vehicle washwater, and foundation or footing drains (no soaps or detergents are used in washing), and
previously monitored treated sanitary wastewater [Ref. 34, pp. 8-9], Between 2020 and 2022, three violations to this permit
occurred; parameters violated were associated with oil and grease (1 violation) and total suspended solids (2 violations) [Ref.
33, p. 6-7],

The Oxbow facility does not appear to be contributing to the metals contamination detected downstream of the Exide facility,
as ESI sediment sample EBR-SED11, collected from just downstream of Exide PPE1 did not exhibit concentrations of metals
at concentration significantly above the concentrations detected in background ESI sediment samples EBR-SED12, EBR-
SED13, and EBR-SED15 [Ref. 7, pp. 18-21, 53-54, 89-90, 110-113, 145-146, 181-182; 28, p. 3],

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East Baton Rouge Parish North Landfill

The East Baton Rouge Parish North Landfill is located on Samuels Road, approximately 1 mile northeast of the Exide facility
[Ref. 30, p. 1], The facility is owned by East Baton Rouge Parish and is operated under contract by Waste Management, Inc.
The landfill began receiving waste in 1993. The current size of the disposal area is 127.4 acres [Ref. 30, p. 2], Pursuant to the
Clean Water Act, the East Baton Rouge Parish North Landfill operates under LPDES Permit No. LA0086169, effective
December 1, 2016 [Ref. 31, pp. 1, 10], The facility is permitted to receive Type I, II, and III, solid waste with one sludge
handling facility (mixing pit/solidification basin) for solidification of liquid wastes. Surface impoundments exist on the facility
for the on-facility generated solid waste processing (i.e., contact stormwater and leachate). The landfill, mixing basin, and
surface impoundments are all permitted. [Ref. 30, p. 3], The site has monitoring wells located around the perimeter of the
landfill which are sampled semi-annually in accordance with its solid waste permit. The groundwater monitoring wells are
sampled for antimony, cadmium, and lead in addition to other analytes [Ref. 30, p. 8], Leachate is pumped to an on-site
wastewater treatment system and routed Bayou Baton Rouge via a permitted NPDES outfall [i.e., Outfall 001] [Ref. 30, p. 10],
The landfill does not appear to be contributing to the metals contamination detected downstream of the Exide facility, as ESI
sediment sample EBR-SED11, collected from just downstream of Exide PPE1 did not exhibit concentrations of metals at
concentration significantly above the concentrations detected in ESI background sediment samples EBR-SED12, EBR-SED13,
and EBR-SED15 [Ref. 7, pp. 18-21, 53-54, 89-90, 110-113, 145-146, 181-182; 28, p. 3],

Hazardous Substances Released

Antimony
Cadmium
Lead

Likelihood of Release Factor:

Based on the analytical data and attribution components listed above, antimony, cadmium, and lead have been documented as
hazardous substances in the observed release to the Bayou Baton Rouge. Therefore, the observed release factor value
of 550 was assigned to the surface water migration pathway [Ref. 1, Section 4.1.2.1.1].

Likelihood of Release Factor Value: 550

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4.1.2.1.2 POTENTIAL TO RELEASE
4.1.2.1.2.1 Potential to Release bv Overland Flow

Potential to release was not evaluated because an observed release to surface water was established by chemical analysis
(see Section 4.1.2.1.1 of this HRS documentation record).

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SW Pathway - Human Food Chain Threat

4.1.3.2 HUMAN FOOD CHAIN THREAT - WASTE CHARACTERISTICS

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation

TABLE 15. HFC THREAT - TOXICITY/PERSISTENCE/BIOACCUMULATION SUMMARY

Hazardous
Substance

Source
Number

Toxicity
Factor Value

Persistence
Factor Value

Bioaccumulation *
Value

Toxicity/
Persistence/
Bioaccumulation
Factor Value

Reference

Antimony

1, 2, 3, OR

10,000

1

5

5.0 x 104

2, p. 2

Arsenic

1,2,3

10,000

1

5

5.0 x 104

2, p. 5

Cadmium

1, 2, 3, OR

10,000

1

50,000

5.0 x 108

K>

V

00

Chromium

1,2,3

10,000

1

5

5.0 x 104

2, p. 11

Cobalt

2

10,000

1

50

5.0 x 105

2, p. 14

Copper

1,2,3

100

1

50,000

5.0 x 106

2, p. 17

Lead

1, 2, 3, OR

10,000

1

5,000

5.0 x 107

2, p. 20

Manganese

1

10,000

1

500

5 xlO6

2, p. 37

Nickel

1,2,3

10,000

1

5

5.0 x 104

2, p. 23

Silver

2, 3

100

1

50

5.0 x 103

2, p. 26

Zinc

1, 2,3

10

1

500

5.0 x 103

2, p. 29

Notes:

OR = Observed Release

1 Bioaccumulation factor values are assigned from the SCDM (Ref. 2), for the type of water body "Fresh Water", in which the fishery is

located [Ref. 1, Sect. 4.1.3.2.1.3],

The hazardous substance with the highest Toxicity/Persistence/Bioaccumulation Factor Value is cadmium [Ref. 1, Table 4-16],

Toxicity/Persistence/Bioaccumulation Factor Value: 5 x 108

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4.1.3.2.2 Hazardous Waste Quantity

Table 16. Hazardous Waste Quantity Summary

Source
No.

Source Hazardous Waste
Quantity
Value

Containment





Ground Water

Surface Water

Gas

Air Particulate

1

12,799.93

NE

10

NE

NE

2

>0

NE

10

NE

NE

3

>0

NE

10

NE

NE

TOTAL

12,799.93









Note:

NE= not evaluated

The sum of the hazardous waste quantity values is assigned as the Hazardous Waste Quantity Factor Value [Ref. 1, Sec.
2.4.2.2 and Table 2-6], The sum of the source hazardous waste quantity values for Surface Water pathway is 12,799.93.
Therefore, a value of 10,000 is assigned for the surface water pathway hazardous waste quantity factor.

Sum of Values: 12,799.93

Hazardous Waste Quantity Factor Value (Ref. 1, Sec. 4.2.2.2, Table 2-6): 10,000

4.1.3.2.3 Waste Characteristics Factor Category Value

Toxicity/Persistence Factor Value: 10,000
Hazardous Waste Quantity Factor Value: 10,000
Bioaccumulation Potential Factor Value: 50,000

8	8

(Toxicity/Persistence Factor Value) x (Hazardous Waste Quantity Factor Value) = 1 x 10 (maximum of 1 x 10
according to HRS Section 4.1.3.2.3)

(Toxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value) x

12	12

(BioaccumulationPotential Factor Value) = 5 x 10 (maximum of 1 x 10 accordingto HRS Section 4.1.3.2.3)

A hazardous waste quantity factor of 10,000 is assigned according to HRS Section 2.4.2.2 Table 2-6. From Reference 2 and
Table 4-12 of the HRS, cadmium have a toxicity/persistence value of 10,000 and a bioaccumulation potential factor of 50,000.

12

The waste characteristics factor category value from Reference 1, Table 2-7 for waste characteristics product of 1 x 10
(subject to a maximum of 1 x 1012) is 1,000.

Waste Characteristics Factor Category Value: 1,000

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4.1.3.3 HUMAN FOOD CHAIN THREAT - TARGETS

The Bayou Baton Rouge is not considered a fishery. The nearest fishery is the Mississippi River, which is approximately 3.25
miles downstream of the Site's downstream PPE (i.e., PPE2) to surface water. The portion of the Mississippi River within the
TDL is fished for consumption [Ref. 18, p. 5; 25, p. 1; Figure 4],

4.1.3.3.1 Food Chain Individual

A food chain individual factor of 20 is assigned based on an observed release (from chemical analysis) of hazardous
substances with a BioaccumulationFactor Value of 500 or greater (i.e., cadmium and lead) in sediments in the watershed,
and also based on a fishery (ie., Mississippi River) being present within the TDL of the in-water segment [Table 14; Ref. 1, Sec.
4.1.3.3.1; 2, pp. 8, 20; 18, p. 5; 25, p. 1],

	Food Chain Individual Factor Value: 20

4.1.3.3.2 Population
4.1.3.3.2.1 Level I Concentrations

The Level I concentrations factor value is 0 because there are no fisheries subject to Level I concentrations [Ref. 1, Section
4.1.3.3.2.1],

Level I Concentrations Factor Value: 0

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SW Pathway - Human Food Chain Threat

4.1.3.3.2.2 Level TT Concentrations

The Level II concentrations factor value is 0 because there are no fisheries subject to Level II concentrations [Ref. I, Section
4.1.3.3.2.2],

Sum of Level II Human Food Chain Population Values: 0

Level II Concentrations Factor Value: 0

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SW Pathway - Human Food Chain Threat

4.1.3.3.2.3 Potential Human Food Chain Contamination
Potential Population Targets

The human food chain production for the fishery (i.e., Mississippi River) is unknown and is therefore evaluated as greater than
0 to 100 pounds per year and a value of 0.03 is assigned from HRS Table 4-18 [Ref. 1, Section 4.1.3.3.2.3, Table 4-18],

TABLE 17. POTENTIAL POPULATION TARGETS

Identity of
Fishery

Annual
Production
(pounds)

Type of
Surface
Water
Body

Average
Annual
Flow (cfs)

Reference

Population
Value (Pi)

(Ref. 1,
Table 4-18)

Dilution
Weight

(DO
(Ref. 1,
Table 4-
13)

Pi x Di

Mississippi
River

>0

Very Large
River

>100,000

Ref. 19, p. 2

0.03

0.00001

0.0000003

Sum of Pi x 0.0000003
(Sum ofPiX DO/10: 0.00000003

Potential Human Food Chain Contamination Factor Value: 0.00000003

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4.1.3.3.2.4 Calculation of Population Factor Value

The population factor value is equal to:

Level I Concentrations (0) + Level II Concentrations (0) + Potential Human Food Chain
Contamination (0.00000003) = 0.00000003

A value of 0.00000003 is assigned as the Population Factor Value.

Population Factor Value: 0.00000003
4.1.3.3.3 Calculation of Human Food Chain Threat - Target Factor Category Value

The Human Food Chain Threat - Targets Threat Category value is calculated by summing the food chain individual and
population factor values for the watershed:

Food Chain Individual Factor Value (20) + Population Factor Value (0.00000003) = 20.00000003

Target Factor Category Value: 20.00000003

4.1.3.4 Calculation of Human Food Chain Threat Score for a Watershed

The Human Food Chain Threat Score is calculated by multiplying the human food chain threat factor category values for
the likelihood of release, waste characteristics, and targets for the watershed (Ref. 1, Sec. 4.1.3.4).

Likelihood of Release (550) x Waste Characteristics (1,000) x Targets (20.00000003) = 11,000,000 (rounded to the nearest
integer)

This product is then divided by 82,500:

11,000,000/82,500= 133.33
The resulting value, subject to a maximum of 100, is assigned as the Human Food Chain Threat Score.

Human Food Chain Threat Score: 100.00

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SWOF/Environment-Hazardous Waste Characteristics

4.1.4.2 Environmental Threat - Waste Characteristics

4.1.4.2.1 Ecosystem Toxicitv/Persistence/Bioaccumulation

TABLE 18. ECOTOXICITY/PERSISTENCE/BIOACCUMULATION





Fresh



Fresh Water
Ecosystem
Bioaccumulation
Factor Value





Hazardous
Substance

Source
Number

Water
Ecotoxicity
Factor

Persistence
Factor

Ecotoxicity/Persistence/
Bioaccumulation
Factor Value (HRS

Ref.
2





Value

Value

Table 4-21)

Page

Antimony

1,2, 3, OR

1

1

5

5

2

Arsenic

1,2,3

10

1

50,000

5 x 105

5

Cadmium

1, 2, 3, OR

10,000

1

50,000

5 x 108

8

Chromium

1, 2,3

10,000

1

500

5 x 106

11

Cobalt

2

0

1

50

0

14

Copper

1,2,3

1,000

1

50,000

5 x 107

17

Lead

1,2, 3, OR

1,000

1

50,000

5 x 107

20

Manganese

1

100

1

50,000

5 x 106

37

Nickel

1,2,3

100

1

50,000

5 x 106

23

Silver

2,3

10,000

1

50

5 x 105

26

Zinc

1,2,3

10

1

50,000

5 x 105

29

Notes:

OR = Contaminant has a documented Observed Release to the surface water migration pathway.

The hazardous substance with the highest Ecosystem Toxicity/Persistence/Bioaccumulation Factor Value is cadmium [Ref. 1, Table
4-16],

4.1.4.2.2 Hazardous Waste Quantity

TABLE 19. HAZARDOUS WASTE QUANTITY

Source Number

Source Hazardous Waste Quantity
(HWQ) Value (HRS Section 2.4.2.1.5)

Is source hazardous constituent
quantity data complete? (yes/no)

1

12,799.93

No

2

>0

No

3

>0

No

Sum of Values:

12,799.93

The sum corresponds to a hazardous waste quantity factor value of 10,000 in HRS Table 2-6 [Ref. 1, Section 2.4.2.2],
4.1.4.2.3 Waste Characteristics Factor Category Value

Cadmium is associated with Sources 1, 2, and 3, which all have surface water pathway containment factor values greater than
0 for the watershed, correspond to an eco toxicity/persistence factor value of 10,000 and bioaccumulation potential factor value
of 50,000, as shown above [Ref. 1, Section 4.1.4.2.1.4; 2, p. 8],

(Ecotoxicity/persistence factor value) x (hazardous waste quantity factor value) = 10,000 x 10,000 = 1 x 108 (Subject to a
maximum of 1 x 108) [Ref. 1, Section 4.1.4.2.3]

(Ecotoxicity/persistence factor value x hazardous waste quantity factor value) x (bioaccumulation potential factor value) = (1
x 108) x (50,000) = 5 x 1012 (Subject to a maximum of 1 x 1012) [Ref. 1, Section 4.1.4.2.3]

The value of 1 x 1012 corresponds to a waste characteristics factor category value of 1,000 in Table 2-7 of the HRS [Ref. 1,
Section 2.4.3.1],

Ecosystem Toxicity/Persistence/Bioaccumulation Factor Value: 5 x 108
Hazardous Waste Quantity Factor Value: 10,000
Waste Characteristics Factor Category Value: 1,000

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SWOF/Environment-Targets

4.1.4.3 Environmental Threat - Targets

The zone of contamination (i.e., the area of Bayou Baton Rouge where observed release by chemical analysis is documented)
along the surface water migration pathway downstream of the sources identified at Exide begins at PPE2 and extends
downstream along Bayou Baton Rouge to sediment sample location EBR-SED04, which is the most downstream observed
release sample from the February 2023 and March 2023 sampling events [see Figure 3], The zone of contamination has a total
length of 0.39 mile (i.e., 2,062 feet) [see Figure 3A], Within the zone of contamination is approximately 0.51 mile (i.e., 2,707.54
feet) of wetland frontage subject to Level II concentrations. The wetland frontage is measured in Bayou Baton Rouge from the
point where it enters a palustrine forested broad-leaved deciduous temporarily flooded (PFOIA) wetland (i.e., approximately
650 feet downstream of PPE2) to sample location EBR-SED04. This portion of Bayou Baton Rouge has wetlands on both sides;
therefore, wetland frontage was measured along each side of Bayou Baton Rouge. There are no media-specific benchmarks for
sediment, so the target sensitive environment is subject to Level II concentrations [Ref. 1, Sections 2.5 and 4.1.4.3],

It should be noted that the portion of the TDL within Bayou Baton Rouge between upstream PPE1 and downstream PPE2 was
not included in the zone of contamination. Sediment samples collected from locations within Bayou Baton Rouge between the
PPEs did not exhibit concentrations of metals at levels significantly above levels detected in background sediment samples.
Specifically, analytical results from sediment samples collected from locations EBR-SED09, EBR-SED10, and EBR-SED011
did not have concentrations significantly above those detected in background sediment samples collected from background
locations EBR-SED12, EBR-SED13, and EBR-SED15 [Figure 3; Ref. 7, pp. 16-21,51-54, 89-90, 108-113, 143-146, 181-182,
236-241, 264-267, 284-285; 28, p. 3], Therefore, a conservative approach was taken and this 0.4-mile portion of the TDL was
not included in the zone of contamination [see Figure 3A],

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Samples for Observed Release/Level II Concentrations

The sediment concentration meets the criteria for Level II concentrations because they meet the criteria for observed release,
and there are no media-specific benchmarks for sediment [Ref. 1, Sections 2.5, 4.1.4.3.1, and 4.1.4.3.1.2]:

TABLE 20. SEDIMENT SAMPLES FOR OBSERVED RELEASE/LEVEL II CONCENTRATIONS

Sample ID

Depth
(inches)

Hazardous
Substance

Concentration
(mg/kg)

Reference(s)

February 2023 Sampling

EBR-SED04-12-
20230209-51

0-12

Lead

58.5

Figure 3; 7, pp. 175, 364; 13, p. 6; 16, p.
13; 28, p. 3

EBR-SED07-24-
20230207-51

12-24

Antimony

4.8

Figure 3; 7, pp. 140, 361; 13, p. 5; 16, p.
16; 28, p. 3

EBR-SED07-24-
20230207-51

12-24

Cadmium

4.0

Figure 3; 7, pp. 48, 361; 13, p. 5; 16, p.
16; 28, p. 3

EBR-SED07-24-
20230207-51

12-24

Lead

70.1

Figure 3, 7, pp. 140, 361; 13, p. 5; 16, p.
16; 28, p. 3

March 2023 Sampling

EBR-SED21 -24-
20230321-51

12-24

Lead

79.8 JK (55.41)

Figure 3; 8, pp. 58, 198: 10, pp. 3-5, 7;
12, pp. 8, 20; 13, pp. 9, 10; 17, p. 2; 28,
P. 4

EBR-SED25-60-
0321-51 (Lab ID
L1597545-15)

48-60

Cadmium

2.64

Figure 3; 9, pp. 74, 226; 11, pp. 3-5, 20;
13, pp. 9, 10; 17, p. 6; 28, p. 4

EBR-SED25-60-
0321-52 (Lab ID
L1597545-16)

48-60

Cadmium

1.72

Figure 3; 9, pp. 76, 226; 11, pp. 3-5, 20;
13, pp. 9, 10; 17, p. 6; 28, p. 4

EBR-SED26-60-
20230321-51

48-60

Cadmium

6.62

Figure 3; 8, pp. 76, 199; 10, pp. 3-5, 25;
13, pp. 9, 10; 17, p. 7; 28, p. 4

Notes:

mg/kg - milligrams per kilogram.

J = The analyte was analyzed for, but the associated numerical value may not be consistent with the amount actually present in the
environmental sample or may not be consistent with the sample detection or quantitation limit. The value is an estimated quantity.
This data should be seriously considered for decision-making and are usable for many purposes [Ref. 10, p. 2],

K = Unknown bias [Ref. 10, p. 2; 11, p. 2],

U = The analyte was not detected at or above the reporting limit [Ref. 7, p. 357],

The J-qualified estimated results have been adjusted per EPA Quick Reference Fact Sheet Using Qualified Data to Document an
Observed Release and Observed Contamination. Unknown bias and bias high observed release concentrations are adjusted down. Bias
low observed release concentrations are not adjusted. The adjustment factors are provided in the fact sheet and the adjusted results are
shown in parentheses. Although J-qualified results are estimated, the presence of the analytes is not in question and the result is usable
[Ref. 12, pp. 5-9,20],

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SWOF/Environment-Level I/Level II Concentrations

4.1.4.3.1 Sensitive Environments

4.1.4.3.1.1 Level I Concentrations

The Level I concentrations factor value is 0 assigned because there are no sensitive environments subject to Level I
concentrations [Ref. 1, Section 4.1.4.3.1.1].

Level I Concentrations Factor Value: 0

4.1.4.3.1.2 Level II Concentrations

There are no media-specific benchmarks for sediment; therefore, the target sensitive environment located within the zone of
actual contamination is subject to Level II concentrations [Ref. 1, Sections 2.5 and 4.1.4.3.1.2],

Sensitive Environments

The Level II concentration factor value of 0 is assigned because there are no sensitive environments listed in HRS Table 4-23
that are subject to Level II concentrations.

Wetlands

A total of 0.51 mile of HRS-eligible wetland frontage exists along the zone of actual contamination in the Bayou Baton Rouge.
The wetland frontage is measured in Bayou Baton Rouge from the point where it enters a palustrine, forested, broad-leaved
deciduous, temporarily flooded (PFOIA) wetland (i.e., approximately 650 feet downstream of PPE2) to sample location EBR-
SED04 [Figure 3A; Ref. 22, p. 37; 38, p. 1], This portion of Bayou Baton Rouge has wetlands on both sides; therefore, wetland
frontage was measured along each side of Bayou Baton Rouge.

TABLE 21. LEVEL II CONCENTRATIONS - WETLANDS

Sensitive Environment

Wetland Frontage subject
to Level II Contamination

Sensitive Environment
Value (HRS Table 4-24)

Reference

Palustrine Wetlands (PFOIA)

0.51 mile

25

Figure 3A; 22, pp.

37, 47; 38, p. 1

PFOIA - Palustrine Forested Broad-leaved Deciduous Temporarily Flooded Wetland [Ref. 22, p. 37]

Sensitive Environments Value: 0
Wetland Value: 25

Sum of Sensitive Environments Value + Wetland Value: 25

Level II Concentrations Factor Value: 25

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SWOF/Environment-Potential Contamination

4.1.4.3.1.3 Potential Contamination

The potential contamination factor value is not scored because the site already receives a listing-eligible site score based on
other factors.

Sensitive Environments

The sensitive environment value (Sj) is not scored.

Wetlands

The wetland frontage value (Wj) is not scored.

Potential Contamination Factor Value: NS

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