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. ------- 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. HRS Documentation Record 1 Exide Baton Rouge LAD008184137 ------- 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 HRS Documentation Record 2 Exide Baton Rouge LAD008184137 ------- 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 HRS Documentation Record 3 Exide Baton Rouge LAD008184137 ------- 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 HRS Documentation Record 4 Exide Baton Rouge LAD008184137 ------- 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 HRS Documentation Record 5 Exide Baton Rouge LAD008184137 ------- 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 ------- 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 HRS Documentation Record 7 Exide Baton Rouge LAD008184137 ------- 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 HRS Documentation Record 8 Exide Baton Rouge LAD008184137 ------- 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 9 Exide Baton Rouge LAD008184137 ------- 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] HRS Documentation Record 10 Exide Baton Rouge LAD008184137 ------- 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] HRS Documentation Record 11 Exide Baton Rouge LAD008184137 ------- 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 ------- 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 ------- ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 HRS Documentation Record 24 Exide Baton Rouge LAD008184137 ------- 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] HRS Documentation Record 25 Exide Baton Rouge LAD008184137 ------- 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]. HRS Documentation Record 26 Exide Baton Rouge LAD008184137 ------- 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 HRS Documentation Record 27 Exide Baton Rouge LAD008184137 ------- 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], HRS Documentation Record 28 Exide Baton Rouge LAD008184137 ------- 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 HRS Documentation Record 29 Exide Baton Rouge LAD008184137 ------- 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 HRS Documentation Record 30 Exide Baton Rouge LAD008184137 ------- 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], HRS Documentation Record 31 Exide Baton Rouge LAD008184137 ------- 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], HRS Documentation Record 32 Exide Baton Rouge LAD008184137 ------- 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 HRS Documentation Record 33 Exide Baton Rouge LAD008184137 ------- 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], HRS Documentation Record 34 Exide Baton Rouge LAD008184137 ------- 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 HRS Documentation Record 35 Exide Baton Rouge LAD008184137 ------- 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], HRS Documentation Record 36 Exide Baton Rouge LAD008184137 ------- SW Pathway - Likelihood of Release 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 HRS Documentation Record 37 Exide Baton Rouge LAD008184137 ------- SW Pathway - Likelihood of Release 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. HRS Documentation Record 38 Exide Baton Rouge LAD008184137 ------- SW Pathway - Likelihood of Release 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 HRS Documentation Record 39 Exide Baton Rouge LAD008184137 ------- SW Pathway - Likelihood of Release 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. HRS Documentation Record 40 Exide Baton Rouge LAD008184137 ------- SW Pathway - Likelihood of Release 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 HRS Documentation Record 41 Exide Baton Rouge LAD008184137 ------- SW Pathway - Likelihood of Release 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 HRS Documentation Record 42 Exide Baton Rouge LAD008184137 ------- SW Pathway - Likelihood of Release 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 HRS Documentation Record 43 Exide Baton Rouge LAD008184137 ------- SW Pathway - Likelihood of Release 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. HRS Documentation Record 44 Exide Baton Rouge LAD008184137 ------- SW Pathway - Likelihood of Release 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. HRS Documentation Record 45 Exide Baton Rouge LAD008184137 ------- 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. HRS Documentation Record 46 Exide Baton Rouge LAD008184137 ------- SW Pathway - Likelihood of Release 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], HRS Documentation Record 47 Exide Baton Rouge LAD008184137 ------- SW Pathway - Likelihood of Release 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], HRS Documentation Record 48 Exide Baton Rouge LAD008184137 ------- SW Pathway - Likelihood of Release 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 HRS Documentation Record 49 Exide Baton Rouge LAD008184137 ------- SW Pathway - Likelihood of Release 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). HRS Documentation Record 50 Exide Baton Rouge LAD008184137 ------- 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 HRS Documentation Record 51 Exide Baton Rouge LAD008184137 ------- SW Pathway - Human Food Chain Threat 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 HRS Documentation Record 52 Exide Baton Rouge LAD008184137 ------- SW Pathway - Human Food Chain Threat 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 HRS Documentation Record 53 Exide Baton Rouge LAD008184137 ------- 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 HRS Documentation Record 54 Exide Baton Rouge LAD008184137 ------- 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 HRS Documentation Record 55 Exide Baton Rouge LAD008184137 ------- 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 HRS Documentation Record 56 Exide Baton Rouge LAD008184137 ------- 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 HRS Documentation Record 57 Exide Baton Rouge LAD008184137 ------- 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], HRS Documentation Record 58 Exide Baton Rouge LAD008184137 ------- 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], HRS Documentation Record 59 Exide Baton Rouge LAD008184137 ------- 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 HRS Documentation Record 60 Exide Baton Rouge LAD008184137 ------- 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 HRS Documentation Record 61 Exide Baton Rouge LAD008184137 ------- |