### HRS DOCUMENTATION RECORD COVER SHEET

N ame of Site: SBA Shipyard

CERCLIS No. : LAD008434185

Contact Persons

Site Investigation: Brenda Nixon Cook, EPA Region 6 (214) 665

- 7436 (Name) (Telephone)

Documentation Record: Brenda Nixon Cook, EPA Region 6 (214) 665

- 7436 (Name) (Telephone)

Pathways, Components, or Threats Not Scored

1) Ground Water Pathway: The ground water migration pathway has not been scored. Ground water monitoring wells located on SBA Shipyard have shown elevated levels of polycyclic aromatic hydrocarbons (PAHs) (Ref. 4, p.48). Based on information available at this time, further evaluation of the ground water migration pathway would not significan tly 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 Threat and Environmental Threat. The Ground Water to Surface Water Migratio n 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) A ir M igration Pathway: Based on information available at this time, evaluation of the air migration pathway would not significantly affect the listing decision (Ref. 1, Sec. 2.2.3).

4) Soil Exposure Pathway: B ased on information available at this time, further e valuation of the soil exposure 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.

### HRS DOCUMENTATION RECORD

N ame of Site: SBA Shipyard Date Prepared: September , 2015

Date Revised: September, 2016

CERCLIS Number: LAD008434185

Site Spill Identifier Number (SSID): A6FX

EPA Region: 6

Street Address of Site *: Section 19 of Range 2 West, Township 10 South and is located at the end of State Highway 3166 and adjacent to the west bank of the Mermentau River (Ref. 5, p. 9, Fig. 1 of this HRS documentation record)

City, County, State , Zip Code : Jennings, Jefferson Davis Parish, LA 70546

General Location in the State : SBA Shipyard is located southeast of the city of Jennings in the south

central portion of the state (Figure 1)

Topographic Map: Mermentau Quadrangle Louisiana (Ref. 3 , p. 1)

Latitude: 30 o 

### 9' 38.17 " North Longitude: 92 o 

### 36 ' 44.05 " West

Location coordinates were taken at location SBA-003 (Ref. 4, p. 175; Figure 3)

Air Pathway Not Scored Ground Water Pathway Not Scored Soil Exposure Pathway Not Scored Surface Water Pathway 100.00

HRS SITE SCORE 50.00

* The street address, coordinates, and contaminant locations presented in this HRS documentation record identify the genera l area 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 scor ing will be refined as more information is developed as to where the contamination has

come to be located.



### September 2016 

### 1

### FIGURES

Figure 1 Facility Location Map Figure 2 Aerial Site Sketch Figure 3 Source s with Site Inspection & Expanded Site Inspection Sampling Locations Figure 4 PPE Location s and Overland Flow Pathways Map Figure 5 Level II Contamination Segments Figure 6 Surface Water Migration Pathway

NOTES TO THE

READER

The following rules were used when citing refe rences in the HRS (Hazard Ranking System) package.

1. Hazardous substances are listed by how they appear in the Superfund Chemical Data Matrix (SCDM).

2. Significant figures: Calculations are reported to two significant figures to the right of the decimal plac e when the HRS does not specify rounding.

3. Abbreviations/Conventions used to identify references and citations: Figure Fig

Number No.

Reference Ref

Section Sec. Single Pages p. Multiple Pages pp. “.” Next Reference () Selected acronyms

2

### ABBREVIATIONS

BGS B elow G round S urface

CACO Consent Agreement and Consent Order

CDD Chlorinated Dibenzo

- p

- Dioxins

CDF Chlorinated Dibenzofurans

CERLA

CERCLIS Comprehensive Environmental Response, Compensation, and Liability Act Comprehensive Environmental Response, Compensation, and Liability Information System

CFS C ubic feet per second

DRO Diesel Range Organics

COC Contaminants of Concern

ERT Environmental Response Team

ESI E xpanded S ite I nspection

FIRM Flood Insurance Rate Map

ft 2 

### Square Feet

ft 3 

### Cubic Feet

HRS Hazard Ranking System

IM/RA Interim Measures/Removal Actions

LBS Pounds LDEQ Louisiana Department of Environmental Quality

LDWF Louisiana Department of Wildlife and

Fisheries

LTU Land Treatment Unit

MSDS Material Safety Data Sheet

NRC National Response Center

NWI National Wetlands Inventory

OCDD Octachlorodibenzo

- p

- dioxin

OPA Oil Pollution Act

ORO Oil Range Organics QASP Quality Assurance Sampling Plan

PAH P olycyclic A romatic H ydrocarbons

PCB P olychlorinated B iphenyl

PID Photoionization Detector

PPE Probable P oint of E ntry
RCRA Resource Conservation and Recovery Act

RFI RCRA Facility Investigation

RL Reporting Limit

SBA SBA Shipyard

SCDM Superfund Chemical Data Matrix

SFHA Special Flood Hazard Area

SI Site Inspection

SOP Standard Operating Procedure

3

### SSID Site Spill Identifier Number

START Superfund Technical Assessment and Response Team

SVOA Semi

- Volatile Organic Analysis

SWD Solid Waste Division

TAL Target Analyte List

TCL Target Compound List

TDL Target Distance Limit

TPH Total Petroleum Hydrocarbon

USGS United States Geological Survey

VOA Volatile Organic Analysis

VOC Volatile Organic Compounds yd 3 

### Cubic Yards

4

### F igure References

F igure 1: Base Map Source* 2013 National Geographic Society, i- cubed

*M ap annotated by EPA START-3 on 05/30/2013 (Ref. 4, p. 12; Ref. 5, pp. 9, 23 & 46; Ref. 24, p. 6)

F igure 2: Base Map Source* Esri ** , DigitalGlobe, GeoEye, i

- cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community

*M ap annotated by EPA START-3 on 6/25/2015 (Ref. 5, p. 24, Ref. 16, p. 2; Ref. 24, p. 10; Ref. 29, p.1) ** The source of this map image is Esri, used by EPA with Esri’s permission.

F igure 3: Base Map Source* Esri ** , DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid,
IGN, IGP, swisstopo, and the GIS User Community

*M ap Annotated by EPA STA RT -3 on 7/15/2015 to depict source locations and sample locations (Ref. 4, pp. 18-22, 26-35, 38-39, 41-47, 57, 109-120, 128-134, 138-142, 147-157, 175, 868-880 &971-1026; Ref. 5, p. 24; Ref. 7, pp. 18-21, 25-27, 30, 32- 33, 35 -37, 40, 50, 89-91, 93-94, 96-99, 101-103, 105-106, 110-111, 114-115, 118-119, 122-123, 126-127, 133-135, 137, 139-142, 173 & 967-982; Ref. 16, p.2 ** The source of this map image is Esri, used by EPA with Esri’s permission.

Fi gure 4: Base Map Source* Esri ** , DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid,
IGN, IGP, swisstopo, and the GIS User Community

*M ap annotated by EPA START-3 on 7/6/2015 for PPE, Drainage, Overland Flow, Sources and START-3 Observations/Logbooks (Ref. 4, pp. 147-157; Ref. 5, pp. 24 & 46; Ref. 7, p. 147-167; Ref. 9, pp. 44-49; Ref. 16, pp. 1-2; Ref. 20, pp. 4-5; Ref. 24, pp. 10, 12, 16 & 128) ** The source of this map image is Esri, used by EPA with Esri’s permission.

F igure 5 Base Map Source* Esri ** , DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid,
IGN, IGP, swisstopo, and the GIS User Community

*M ap Annotated by EPA START-3 on 7/15/2015 to depict background and release sample locations, PPEs, Fishery & Wetland Contamination and START-3 observations/logbooks (Ref. 4, pp. 26-27, 31, 33, 41, 43, 57, 109-113, 116-128, 147-157, 175, 868, 971-979,

September 2016 

### 5

### 1007-1008, 1011, 1013, 1015, 1017 & 1019; Ref. 5, p. 24; Ref. 7, pp. 20-21, 25, 33-36, 50, 89-91, 97-98, 101-103, 110-112, 114-116, 118-120, 126-127, 133 135, 140-141 &146-167; Ref. 9, pp. 44-49; Ref. 16, p. 2; Ref. 20, pp. 4-5; Ref. 24, pp. 12, 16 & 128) ** The source of this map image is Esri, used by EPA with Esri’s permission.

F igure 6: Base Map Source* Esri ** , DigitalGlobe, GeoEye, i- cubed, USDA, USGS, AEX , Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community; National Wetlands Inventory; and National Hydrography Dataset.

*M ap annotated by EPA START-3 on 7/15/2015 for Surface Water Flow, Common Drainage, Facility Boundary, Wetland delineat ion Maps, National Wetland Inventory and START-3 observations/logbooks (Ref. 3, p. 1; Ref. 4, pp. 12, 116, 119-127 & 147-157; Ref. 5, pp. 9, 23 & 46; Ref. 7, pp. 140-141 & 146-167; Ref. 9, pp. 44-49; Ref. 10, p. 1; Ref. 24, p. 6)

** The sour ce of this map image is Esri, used by EPA with Esri’s permission.

September 2016 

### 6

# ^ _

^ _ US EPA Region 6

START-3

Figure 1. Facility Location Map (SBA Shipyard) 9040 Castex Landing Road, Highway 3166, Jefferson Davis Parish, Jennings, LA 70546

CERCLIS: LAD008434185

TDD #: TO-0009-12-10-02 Map of Louisiana 

# .

1:24,000

May 2013 Legend



# ^ _ Facility Entrance

Facility Boundary

0 2,500 5,000 1,250

FeetLand Treatment

Unit

Water Pit 1

Oil Pit

Water

Pit 2 Water

Pit 3 Partially Buried Barge

Buried Barge and Associated Alkyne Storage Tank Pump House Horizontal
Saddle Tank

Barge Slip Dry Dock Barge Slip Barge

Slip



### Figure 2. Aerial Site Sketch (SBA Shipyard) 9040 Castex Landing Road, Highway 3166, Jefferson Davis Parish, Jennings, LA 70546

CERCLIS: LAD008434185

TDD #: 9/TO-0009-12-10-02 September 2013 

# .

1:4,000

0 300 600 150 Feet 

# ^ _

Map of Louisiana

Legend

Sources Main Office/Entrance



### US EPA Region 6

START-3

### ! (

! ( ! ( ! ( ! (

! ( ! ( !

(

! ( ! ( ! ( ! (

! ( ! (

! ( ! (

! (

! (

! ( ! ( ! (

! ( ! ( ! ( ! (

! (

! (

! (

! ( ! ( ! ( ! ( ! ( ! (

! (

! (

! (

! (

! (

! ( ! ( ! ( ! ( Main Office/

Entrance SBA-ESI-02 SBA-ESI-01

SBA-ESI-04

SBA-ESI-07 SBA-ESI-06 SBA-ESI-05

SBA-ESI-11 SBA-ESI-15

SBA-011 SBA-006 SBA-005

SBA-010 SBA-009

SBA-ESI-10 SBA-003 SBA-002 SBA-004

Source No. 1 Source No. 4 Source No. 3

SBA-ESI-09 SBA-ESI-08 Source No. 6 Source No. 5

SBA-040

SBA-039 SBA-033

SBA-032

SBA-031 SBA-030 SBA-029 SBA-028

SBA-027 SBA-026

SBA-025 SBA-024

SBA-008

SBA-007 SBA-001

CERCLIS: LAD008434185

TDD #: 9/TO-0009-12-10-02 September 201 6 

# .

1:5,000

0 250 500 750 1,000 125 Feet 

# ^ _

Map of Louisiana 

### US EPA Region 6

START-3

Figure 3. Sources with Site Inspection and Expanded Site Inspection Sampling Locations Map (SBA Shipyard) 9040 Castex Landing Road, Highway 3166, Jefferson Davis Parish, Jennings, LA 70546 Legend



### ! ( Sediment



### ! ( Soil



### ! ( Waste

SourcesMain Office/

Entrance

Source No. 1 Source No. 3

Source No. 6 Source No. 5

Source No. 4

PPE 3 PPE 2 PPE 1

PPE 4

CERCLIS: LAD008434185

TDD #: 9/TO-0009-12-10-02 September 201 6 

# .

1:5,000

0 250 500 750 1,000 125 Feet 

# ^ _

Map of Louisiana 

### US EPA Region 6

START-3

Figure 4. PPE Locations and Overland Flow Pathways Map (SBA Shipyard) 9040 Castex Landing Road, Highway 3166, Jefferson Davis Parish, Jennings, LA 70546 Legend

Overland Flow Direction

Sources

Drainage Ditch (Perennial)

Drainage Ditch (Intermittent) PPE Location

## ! H

! (

! ( 

## ! H

! (

! (



## ! H ! ( ! (

! ( 

## ! H ! H

! (

! (

! (

! ( ! (



## ! H

! H Main Office/

Entrance SBA-ESI-02 SBA-ESI-01

SBA-ESI-04

SBA-ESI-06 SBA-ESI-05

SBA-ESI-11 Wetland 1 Level II
Contamination

Wetland 2 Level II Contamination PPE 4 PPE 3

PPE 2 PPE 1

SBA-ESI-10

SBA-ESI-09 SBA-ESI-08 Wetland 3 Level II

Contamination Fishery Level II Contamination SBA-039 SBA-033

SBA-032

SBA-031 SBA-030 SBA-029 SBA-028

SBA-025 SBA-024 SBA-001

CERCLIS: LAD008434185

TDD #: 9/TO-0009-12-10-02 September 2013 

# .

1:5,000

0 250 500 750 1,000 125 Feet 

# ^ _

Map of Louisiana 

### US EPA Region 6

START-3

Figure 5. Level II Contamination Segments (SBA Shipyard) 9040 Castex Landing Road, Highway 3166, Jefferson Davis Parish, Jennings, LA 70546 Legend

SBA Shipyard, Inc.

Segment 2: Potential Contamination PPE 

## ! H Background Sample



### ! ( Release Sample

Potential Contamination

Fishery Level II Contamination

Wetland Level II Contamination! ( ! ( ! ( ! ( PPE 4 PPE 3

PPE 2 PPE 1

15-Mile TDL



### US EPA Region 6

START-3

Figure 6. Surface Water Migration Pathway (SBA Shipyard) 9040 Castex Landing Road, Highway 3166, Jefferson Davis Parish, Jennings, LA 70546

CERCLIS: LAD008434185

TDD #: TO-0009-12-10-02 January 2013 

# ^ _ Map of Louisiana Lake Arthur

Legend

Facility Boundary

Surface Water Flow

Freshwater Emergent Wetland

Freshwater Forested/Shrub Wetland

Freshwater Pond

Lake

Other

Riverine

1 0 1 0.5 Miles 

# .

1:75,000

### WORKSHEET FOR COMPUTING HRS SITE SCORE

s

1. Ground Water Migration Pathway Score (S gw 

### ) NS

2a. Surface Water Overland/Flood Migration Component 100.00 (from Section 4.3 of the HRS Documentation Record)

2b. Ground Water to Surface Water Migration Component NS

2c. Surface Water Migration Pathway Score (S

sw 

### ) 100.00 Enter the larger of the line 2a and 2b as the pathway score

3. Soil Exposure Pathway Score (S

s 

### ) NS

4. Air Migration Pathway Score (S

a 

### ) NS

2 2 

### 5. Total of S gw 

### +S

sw 2 

### +S

s 2 

### +S

a



### 6. H RS Site Score: Divide the value on line 5 by 4 and take the

square root.

NS = Not Scored 2 

### s

NS

10,000

NS

10,000

NS

NS

10,000

50.00

13

### Table 4 -1 Surface Water Overland/Flood Migration Component Score Sheet

Factor Categories and Factors Maximum Value Value Assigned

DRINKING WATER THREA T

Likelihood of Release

1. Observed Release 550 550

2. Potential to Release by Overland Flow:

2a. Containment 10

2b. Runoff

2c. Distance to Surface Water 25 2d. Potential to Release by Overland Flow (Lines 2a X [2b+2c]) 500 NS

3 Potential to Release by Flood 3a. Containment (Flood) 10 3b. Flood Frequency 50 3c. Potential to Release by Flood (Line 3a X 3b) 500 NS

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

5. Likelihood to Release (Higher of Lines 1 and 4) 550 550

NS

Waste Characteristics

6. Toxicity/Persistence *

7. Hazardous Waste Quantity *

8. Waste Characteristics 100 NS

Targets

9. Nearest Intake 50 NS

10. Population:

10a. Level I Concentrations ** NS

10b. Level II Concentrations ** NS

10c. Potential Contamination ** NS 10d. Population (Lines 10a+10b+10c) ** NS

14

### 11. Resources 5 NS

12. Targets (Lines 9+10d+11) ** NS

DRINKING WATER THREA T (Concluded) Drinking Water Threat Score

13. Drinking Water Threat Score ([Lines 5 x 8 x 12]/82,500, subject to a maximum of 100) 550 NS

HUMAN FOOD CHAIN THR EAT

Likelihood of Release

14. Likelihood of Release (Same value as Line 5) 550 550

Waste Characteristics

15. Toxicity/Persistence/Bioaccumulation * 5x10 8



### 16. Hazardous Waste Quantity * 10,000

17. Waste Characteristics 1,000 1,000 Targets

18. Food Chain Individual 50 45

19. Population:

19a. Level I Concentrations ** 0

19b. Level II Concentrations ** 0.0 3

19c. Potential Contamination ** 0.0 0 0 0 06 19d. Population (Lines 10a+10b+10c) ** 0.0 3 0 00 6

20. Targets ** 45 .0 3 0 0 0 6 (Value from Lines 18+19d)

Human Food Chain Threat Score

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

ENVIORNMENTAL THREAT

Likelihood of Release

22. Likelihood of Release (Same value as Line 5) 550 550

Waste Characteristics

23. Ecosystem Toxicity/Persistence/

Bioaccumulation * 5 X 10 8



### 24. Hazardous Waste Quantity * 10,000

25. Waste Characteristics 1,000 1,000

Targets

15

### 26. Sensitive Environments:

26a. Level I Concentrations ** 0

26b. Level II Concentrations ** 25

26c. Potential Contamination ** 0.065

26d. Sensitive Environments (Lines 26a+26b+26c) ** 25.0 65

27. Targets (Value from Line 26d) ** 25.0 65

ENVIORNMENTAL THREAT

28. Environmental Threat Score ([Lines 22 x 25 x 27]/82,500subject to a maximum of 60)

60 60.00

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORE FOR A

WATERSHED

29. WATERSHED SCORE (Lines 13 + 21 + 28, subject to a maximum of 100)

100 100.00

30. Component Score (S0,) (Highest score from Line 29 for all watersheds evaluated, subject to a maximum of 100)

100 1 0 0.00

Maximum value applies to waste characteristic category Maximum value applicable Do not round to the nearest integer



### 16

### REFERENCE S HEET

Ref.

No. Description of the Reference

1. U.S. EPA. H azard R ank ing S ystem (HRS); Fina l Rule. Federal Register. Volume 55, Number

241. Washington, DC: U.S. Government Printing Office, December 14, 1990. Title Page only. A complete v ersion o f

th is document is a vailable o nline a t: https://semspub.epa.gov/work/HQ/174028.pdf

2. U.S. E PA Superfund Chemical Data Matrix. Appendix B. June 20, 2014. Excerpt Pages: 13. A complete v ersion o f

S CDM is a vailable a t:
h ttps://www.epa.gov/superfund/superfund-chemical-data-matrix-scdm

3. U.S. Geological Survey (USGS). 7.5’ Topographic Quadrangle. M ermentau Q uadrangle

Louisiana. 2012. T o tal P ages: 1

.

4. Dy namac Corp. Sit e Inspection . SBA Shipyard Inc., Jennings, Jefferson Davis Parish, Louisiana. Prepared in cooperation with U.S. EPA Region 6. August 6, 2014. Total Pages:

1028.

5. Mi chael P isani an d A ssociates Inc. Interim Measures/Removal Action C omple tion Report. SBA Shipyards Site, Jennings, Louisiana. August 15, 2005. T otal P ages: 6 29.

6. Woodward-Clyde Consultants. R CRA F acili ty Investigation Work Plan. SBA Shipyard Site, Jennings, Louisiana. Prepared for SBA Shipyard, Inc. October 1996. T otal P ages: 9 8.

7. Dynamac Corp. Expanded Site Inspection Report. SBA Shipyard Inc., Jennings, J efferson Davis Parish, Louisiana. Prepared in cooperation with U.S. EPA Region 6. July 24, 2015. Total Pages:

1017.

8. U.S. Department of Agriculture. Soil Survey of Jefferson D avis P arish , Louisiana. T o tal P ages: 234.

9. Dynamac Corporation. P reliminary A ssessment Report f or SBA Shipyard, Jennings, J efferson

Davis Parish, Louisiana. Prepared for U.S. EPA Region 6. June 3, 2013. T otal P ages: 6 6.

10. U.S. Fish and W ildlife S ervice. National Wetlands Inventory . W etland M apper Digital Wetland Map an d W etlands an d D eepwater H abitats C lassification K ey. A ccessed at http://www.fws.gov/wetlands/Data/Mapper.htm l & http://www.fws.gov/wetlands/Documents/Wetlands-a n d -D eepwater -H abitats -C lassification

chart.pdf. February 26, 2015 and March 2, 2015. Total P ages: 5.

11. United S tates G eological S urvey ( USGS ). N ational W ater Information S ystem: W eb Interface,

USGS 08012150 Mermentau River At Mermentau, LA. Accessed at

17 September 2 016

### http://waterdata.usgs.gov/nwis/annual?referred_module=sw&site_no=08012150&por_ 08012150_18=198538,00060,18,1990,2015&partial_periods=on&year_type=W& format=html_table&date_format=YYYY

- MM

DD&rdb_compression=file&submitted_form=parameter_selection_list

. Accessed July 7, 2015. Total Pages: 2.

12. United States Geological Survey ( USGS ). National Water Information System: Web Interface,

USGS 08012470 Bayou Lacassine Near Lake Arthur , LA

. Accessed at http://waterdata.usgs.gov/la/nwis/annual?referred_module=sw&site_no=08012470&po r_08012470_13=198550,00060,13,1988,2005&partial_periods=on&year_type=W&am p;format=html_table&date_format=YYYY

- MM

DD &rdb_compression=file&submitted_form=parameter_selection_list

. A ccessed July 7, 2015. Total Pages: 2.

13. Louisiana Department of Environmental Quality Field Interview Form. SBA Shipyard. Agency

Interest # 1478. July 30, 2008. Total p ages: 1

.

14. Louisiana Department of Wildlife & Fisheries. Louisiana Commercial Fishing Regulations.

Accessed at http://w ww.wlf.louisiana.gov/sites/default/files/pdf/publication/31745- commercial

fishing-regulations/commercial_fishing_2011.pdf . 2011. Total Pages: 44.

15. Hook and Bullet. Lake Arthur , LA – Fishing, Guides, Charters, Bait Information. Accessed at: http://www.hookandbullet.com/c/fishing- lake -arthur- la/

. Accessed July 13 , 2104. Total Pages:

2.

16. Woodward-Clyde Consultants. Figures from the RCRA Facili ty Investigation Work Plan. SBA Shipyard Site, Jennings, Louisiana. Prepared for SBA Shipyard, Inc. September 1996. Total Pages: 5.

17. FTN Associates, Ltd. L ake Arthur , G rand Lake, and Gulf I ntercostal W aterway TMDLS For Dissolved Oxygen, Nutrients, and Ammonia. Prepared for U.S. EPA R egion 6. April 19, 2002. Total Pages: 61.

18. CSS -Dynamac Corp. Memorandum to File. Subject: Historical Google Earth Map Representation. July 13, 2015. Total Pages: 3.

19. Dynamac Corporation. U.S. EPA Preliminary Assessment Logbook and Photo log. SBA Shipyards Site, Jennings, Louisiana. December 11, 2012. Total Pages: 1 1.

20. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management Search (EDMS) . Reports. Reference Material

. Search AI# 1478. Document ID# 4111647.

Accessed at: http://edms.deq.louisiana.gov/app/doc/querydef.aspx . December 26, 1996. Total Pages: 6.

21. Louisiana Department of Environmental Quality. Correspondence National Response Center Report. October 23, 2012. Total Pages: 14

.

18

### 22. Fagan, Nancy L. RCRA Corrective Action Site Visit Report. SBA Shipyards, Inc. EPA ID Number LAD008434185, Hwy 3166, Jennings, LA 70546. Prepared for U.S. Environmental Protection Agency. February 12, 1998. Total pages: 8.

23. Woodward-Clyde Consultants. Groundwater Remediation and Monitoring Plan. SBA Shipyard Site, Jennings, Louisiana. Prepared for SBA Shipyard. October 1996. Total Pages: 31.

24. PRC Environmental Management Inc. Compliance Evaluation and Sampling Inspection At SBA Shipyards, Inc., Jennings, Louisiana, LAD008434185. Summary Report. Prepared for U.S. Environmental Protection Agency, Office of Solid Waste. October 26, 1994. Total Pages: 138.

25. Hutton, T. D., MSTC. Barge Scrapping at SBA Shipyard, Jennings, LA, 23 & 25 October 2012, Potential Discharge of an Unknown Amount of Waste Oil/Water. Total Pages: 15.

26. Federal Emergency Management Agency. Flood Insurance Rate Maps, Jef ferson Davis Parish,

Louisiana. Accessed at http://map1.msc.fema.gov/idms/IntraView.cgi?JX=1130&JY=503&ROT=0&KEY=92603394&I

FIT=1 . Accessed July 13, 2015. Total Pages: 2

.

27. Letter, Joseph V. Jr. Grand and White Lakes Flood Control Project. Numerical Model Investigation. Prepared for U.S. Army Engineer District, New Orleans. August 1993. Total Pages: 129.

28. U.S. Environmental Protection Agency. Enviro facts

. Accessed at: http://oaspub.epa.gov/enviro/multisys2_v2.get_list?facility_uin=110007299967 . Accessed July 8, 2015. Total Pages: 2.

29. Reference Number Reserved.

30. Environmental Solutions Inc. Solid Waste Closure Plan. SBA Shipyard, Inc. Surface Impoundments, Jennings, LA. December 28, 1990. Total Pages: 115.

31. U.S. EPA, Office of Emergency and Remedial Response. 

### Using Qualified Data to Document a n O bserved Release and Observed Contamination. Publication 9285.7-14FS. November 1996. Total Pages: 18.



### 32. W oodward- Clyde Consultants. Corrective Measures Implementation Plan

- Surface Impoundments, Tanks and Land Treatment Unit and Closure and Post- Closure Implementation Schedule and Cost Estimate. Closure Project, Jennings, Louisiana. Prepared for SBA Shipyard Inc. October 1996. Total Pages: 131.

33. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management Search (EDMS). Reports. Reference Material . Search AI#1478. Document ID#837689.

Accessed at: http://edms.deq.louisiana.gov/app/doc/querydef.aspx . October 5, 1992. Total Pages: 140.

19

### 34. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management Search (EDMS). Reports. Inspection. Search AI#1478. Document ID#837959. Accessed at: http://edms.deq.louisiana.gov/app/doc/querydef.aspx . May 11, 1993 . Total Pages: 235.

35. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management Search (EDMS). Reports. Inspection. Search AI#1478. Document ID#840744. Accessed at: http://edms.deq.louisiana.gov/app/doc/querydef.aspx

. July 2 , 1997. Total Pages: 21.

36. Woodward-Clyde Consultants. Water Permit Application. SBA Shipyard Inc., Jennings, Louisiana. Prepared for SBA Shipyard Inc. October 1997. Total Pages: 317.

37. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management Search (EDMS). Reports. Inspection. Search AI#1478. Document ID#8914440. Accessed at: http://edms.deq.louisiana.gov/app/doc/querydef.aspx . June 15, 1993. Total Pages: 41.

38. U.S. Environmental Protection Agency. Pollution/Situation Report. SBA Shipyards – Removal Polrep. Final Removal Polrep. June 23, 2015. Total Pages: 6.

39. GCAL Analytical Laboratories, LLC. Analytical Results. GCAL Report 215061151. June 19, 2015. Total Pages: 27.

40. Early, Brian Sean. Memorandum to File. Subject: HRS Wetland Status at SBA Shipyard. July 22, 2015. Total Pages: 2.

41. SBA Shipyards. Work Orders, Marine Chemist Certificates, Laboratory Data, Memorandums

and Miscellaneous Notes associated with Ashland - 9535410. Date : August 31, 1995. Page Number: 11. Total Pages: 268.

42. SBA Shipyards. Work Orders and Miscellaneous Notes associated with Conoco-9535412. Date : April 13, 1981. Page Number: 16. Total Pages: 77.

43. SBA Shipyards. Invoices, Work Orders, Miscellaneous Notes associated with Leevac -9535414. Date: May 6, 1993. Page Number: 33. Total Page s: 37.

44. SBA Shipyard . Work Orders, Invoices, Marine Chemist Certificates Associated with Redrope#1- 9535415. Dates: December 1, 1976; May 14, 1977; July 9, 1981; July 1, 1982; November 28, 1983; and February 14, 1980. Page Numbers: 162, 226, 232, 254, 274, and 379. Total Pages: 432.

45. SBA Shipyard. Work Orders, Invoices, and Miscellaneous Notes associated with Re drope#2 - 9535410. Dates: October 29, 1984 and June 3, 1981. Page Numbers: 115 and 197. Total Pages:

246.

46. SBA Shipyard. Work Orders, Inv oices, Marine Chemist Certificates and Miscellaneous Notes

associated with Redrope#4 - 9535418. Dates: October 3, 1979 and September 22, 1988. Page Numbers: 9 and 203. Total Pages: 214.

20

### 47. SBA Shipyard. Marine Chemist Certificates and Miscellaneous Notes associated with Redrope#5 - 9535419. Dates: July 9, 1994; June 8, 1988; September 22, 1988; April 12, 1990; April 10, 1978; May 15, 1978; May 29, 1978; May 21, 1979; April 17, 1984; May 22, 1984; and July 28, 1993. Page Numbers: 4, 15, 40, 50, 76, 78-79, 81, 125,-126 and 241. Total Pages:

317.

48. SBA Shipyard. Regulatory Documents, Letters, Work Orders, Invoices, Marine Chemist Certificates, Certified Mail, and Miscellaneous Notes associated with Customer Notice Files

- 9535425. Dates: April 24, 198 6; Au gust 1, 1986; and August 21, 1989. Page Numbers: 14, 16, and 388. Total Pages: 402.

49. SBA Shipyard. Work Orders, Invoices, Marine Chemist Certificates, Letters, Regulatory

Documents and Miscellaneous Notes associated with National Marine, Union/Dravo Mec hling

- 9535427. Dates: October 3, 1979; July 10, 1996; August 4, 1977; November 7, 1981; May 15, 1978; May 29, 1979; September 17, 1978; November 11, 1982; April 18, 1979; and March 16, 1990. Page Numbers: 3, 5- 13, 33-34, 38-40, 110, 236, and 266. Tot al Pages: 292.

50. SBA Shipyard. Marine Chemist Certificates, Letters, Certified Mailing, Technical Reports, Laboratory Reports, and Miscellaneous Notes associated with PRPS - 9535428. Dates: March 8, 1996; July 9, 1994; July 28, 1993; and February 20, 1992 . Page Numbers: 18-19, 25, 130, and 133. Total Pages: 432.

51. SBA Shipyards, Inc. Customer Information Relating to Historical Barge Cleaning Activities. Date: March 22, 1996. Page Numbers: 1 – 39. Total Pages: 39.

52. U.S. EPA. Email of Clarification. F rom Rick McMillin, EPA. To Brenda Cook, EPA. Subject: Region 6 Houston Lab's Definition of A Reporting Limit (RL) . August 4, 2015. Total Pages: 1.

53. Louisiana Department of Environmental Quality LDEQ) Electronic Document Management Search (EDMS). Reports. Inspection. Search AI#1478. Document ID# 4111644 . Accessed at: http://edms.deq.louisiana.gov/app/doc/querydef.aspx . February 27, 1986. Total Pages: 1.

54. Louisiana Department of Environ mental Quality LDEQ) Electronic Document Management Search (EDMS). Reports. Inspection. Search AI#1478. Document ID# 4111643 . Accessed at: http://edms.deq.louisiana.gov/app/doc/querydef.aspx . September 15, 1986. Total Pages: 3.

55. Louisiana Department of Environmental Quality LDEQ) Electronic Document Management Search (EDMS). Reports. Inspection. Search AI#1478. Document ID# 837675 . Accessed at: http://edms.deq.louisiana.gov/app/doc/querydef.aspx . August 15, 1980. Total Pages: 4.

21

### SITE DESCRIPTION AND HISTORY :

The site defines the release from SBA Shipyard (SBA) referring to sou rces of hazardous substances and

areas of contaminated water that are to be scored as a single unit . SBA Shipyard (SBA) is situated on approximately 98 acres of land located in a rural

- industrial area, at 9040 Castex Landing Road, Jennings, Jefferson Davis Parish, LA 70546, at the end of State Highway 3166 and adjacent to the west bank of the Mermentau River (Ref. 6, p. 7 & 17; Ref. 9, p. 7; Figure 1). SBA is located approximately 2.3 miles southwest (downstream) of Mermentau, Louisiana (Ref. 5, p. 9; Ref. 6, p. 7). SBA is bordered to the north by residents, south and west by wetlands, and to the east by the Mermentau River (Ref. 4, pp. 12-13; Figure 1). Property ownership of SBA is divided into two parcels, with the property north of the dry dock owned by LeeVac Shipyard, Inc. and the property south of the dry dock owned by Louis &

Suzanne Smailhall (Ref. 5, pp. 10, 23 & 46 ; Ref. 7, p. 167; Ref. 9, p. 46). Property division of SBA is between the dry dock and barge slip ( Ref. 5 , pp. 24 & 46; Ref. 20, p. 5). Currently SBA is inactive and

vacant (Ref. 9, p. 9).

The SBA Shipyard site as scored includes five sources: a partially buried barge container, one buried/backfilled surface impoundments, the former land treatment unit (LTU) and surface impoundments that have not been buried/backfilled , as well as a documented release to surface water. Contamination in the sources document numerous hazardous substances, including petroleum hydrocarbons, numerous polycyclic aromatic hydrocarbons (PAHs), dioxins/furans, metals and volatile organic compounds (VOCs) (Ref. 4, p.48; Ref. 7, pp. 40-42 ). Metal and PAH surface water contamination is documented based on wetland and channel sediment samples from one of the barge slips and the Mermentau River. Slightly greater than 2,800 feet of wetland frontage is located within the zone of Level II contamination, and an estimated 24.5 miles of wetland frontage is located along the 15

- mile target distance limit (TDL) outside of the zone of actual contam inations (Figure 5 & 6 ). Additionally, the HRS documentation record identifies a human food fishery in the Mermentau River

both within and outside the zone of actual contamination as well as in Lake Arthur at the terminus of the

15- mile TDL ( Figure 5 & 6; Ref. 7, pp. 42, 984- 992). The surface water overland migration pathway is the pathway of concern being evaluated for this HRS package. An observed release has been

documented to the Mermentau River and associated wetlands. Contaminates of Concern ( COC s) for the surface water pathway include: aroclor -1254, benzo(a)anthracene, benzo(a)pyrene, cadmium, copper, dibenz(a,h)anthracene, hexachlorodibenzo-p-dioxin 1,2,3,7,8,9-, hexachlorodibenzofuran 1,2,3,4,7,8-, hexachlorodibenzofuran 1,2,3,6,7,8 -, hexachlorodibenzofuran 2,3,4,6,7,8,-, mercury, octachlorodibenzop-dioxin (OCDD), pentachlorodibenzofuran 2,3,4,7,8-, phenol and pyrene.

SBA used the facility for construction, repair, retrofitting, sandblasting, and cleaning and painting of barges beginning in 1965 (Ref. 7, p. 13 ). Three barge slips and a dry dock are located off the

Mermentau River (Ref. 5, p p. 38-39; Ref. 6, p. 7 ; Figure 2 ). Two of the barge slips are located on the northern portion of the property and are not included in the site as score d; the third barge slip is applicable and will be considered in the site HRS scoring (Figure 2). T he slips were used to dock barges during cleaning or repair (Ref. 7, p. 13). The wastes from barges consisted of hydrocarbons and typically held diesel, coal, tar crude oil, gasoline and asphalt (Ref. 6, p. 10). Mr. Smailhall stated that the facility had in the past cleaned barges which previously contained coal tar (Ref. 33, p. 1). Some of the barges serviced at the facility h eld coal tar, creosote, miscellaneous chemicals or agricultural related materials such as tallow, corn oil or soybean (Ref. 32, p. 46). A deposition taken from the owner, Mr. Smailhall, indicated that he had used chlorinated solvents in his cleaning process in the past (Ref. 22, p.

September 2016 

### 22

### 3). Solvents used to clean painting equipment were saved and used to thin coatings applied to the barges

. Paint cans were then taken to a central location at the western end of the facility and turned upside down to drain on the ground (Ref. 33, p. 2). Material Data Safety Sheets (MSDS) provided by Mr. Smailhall in 1993 listed the paints and coatings used on the barges within the previous two years (Ref. 34, pp. 2 & 80-235). A r eview of the MSDS s revealed that the material was hazardous when discarded due to ignitability (EPA Hazardous Waste Code D0010) and the material exhibited the characteristic for MEK (EPA Hazardous Waste Code D035 - m ethyl ethyl ketone ) (Ref. 34, p. 2).

The barge cleaning services operation provided by SBA included the following steps: A barge was floated into the barge slip adjacent to the boilers and o perations area ( Ref. 16, p. 2; Ref. 36, p. 38); The first step in cleaning and gas freeing barges was to remove the gros s residuals from the entire barge or just those compartments scheduled for maintenance (Ref. 42 p. 51; Ref 43. P.5; Ref. 51, p. 5). The barge was then cleaned by a combination of methods including: spraying with high pr essure hot water, and/or removing solids and sludges by hand shoveling, and removing any remaining residual with a “butterworth” apparatus which consisted of a high pressure wash with diesel, water and a surfactant (Ref. 51, pp. 5-6 ). Originally, all residuals along with any wash water were pumped from the barge to the surface impoundments (Ref. 51, p. 5). The solids we re then carried to a double walled container and solidified/stabilized with the addition of lime, fly ash and fertilizer (Ref. 36, p. 38). The waste water generated as a result of washing comprises the predominant water flow (Ref. 36, p. 38). The waste

water was initially pumped into an oil water settling tank WT -8, with the separated oil flowing to T-1 or T-2 (Ref. 16, p. 2; Ref. 36, p. 38; Ref. 50, pp. 5-6 ). Since the wash water may have contained contaminates from the washing, it was pumped through WT -2 or WT-3 then through an oil water

separator OWS -1 (Ref. 16, p. 2; Ref. 36, p. 38; Ref. 51, pp. 5-6 ). The oil within T -1 and T- 2 was transported off- site for recovery o f thermal value within 90 days (Ref. 36, p. 38). The oil/water from

OSW -1was recycled back to WT-8 (Ref. 16, p. 2; Ref. 36, p.38). The water from OWS-1 flows to WT5 and was used as the primary source of water for barge cleaning (Ref. 16, p. 2; Ref. 36, p.38). Some of the water was recycled or converted to steam for the cleaning operations (Ref. 6, p. 10). Water, hydrocarbon and water/hydrocarbon emulsions generated by the sludge and residue removal process

were stored on

- site in a variety of tanks and converted barges (Ref. 51, p. 6). As part of the cleaning process the petroleum hydrocarbons were separated from the water into surface impoundments that were known as the Oil Pit, Water Pit 1, Water Pit 2 and Water Pit 3 (Ref. 6, p. 10). A large quantity of

water/ hydrocarbon emulsions was stored in one of the surface impoundments, the Oil Pit (Ref. 16, p. 2; Ref. 51, p. 6). W aste water was stored in two of the surface impoundments, the Oil Pit and Pit No. 2 prior to closure of the surface impound ments (Ref . 51, p. 6). Aboveground oil/water separators and storage tanks eventually replaced the functions of the pits (a.k.a. surface impoundments) (Ref. 6, p. 10). Figure 2 provides a layout of SBA features and former waste management areas.

W astes from the barge cleaning, for the most part, consisted of petroleum hydrocarbon residues (Ref. 6, p. 10). In addition to the hydrocarbons other wastes on site included asphalt, creosote, m ethyl

m ethacrylate , methanol , caustic soda, styrene, coal tar, vinyl acetate, c arbon t etra chloride , e thyl a crylate

and a crylates (Ref. 41, p. 11; Ref. 44, pp. 162, 226, 232, 254, 274 & 379; Ref. 45, pp. 115 & 197; Ref. 46, pp. 9 & 203; Ref. 47, pp. 4, 15, 40, 50, 76, 78, 79, 125, 126, 236 & 241; Ref. 48, pp. 14, 16 & 388;

Ref. 49, pp. 3, 33, 34, 38, 39, 110 & 236; Ref. 50, pp. 25, 130 & 133; Ref. 51, pp. 1-3 & 36-39 ). Waste samples taken from the water pits were found to contain benzene, vinyl chloride, 1,2-dichloroethane, tetrachloroethylene, trichloroethylene, methylene chloride, methyl ethyl ketone, carbon tetrachloride

, acetone and styrene (Ref. 35, pp. 6 -7; Ref. 37, p p .1 , 4-12 & 19-41 ). Since approximately 1970, D018

23

### (EPA Hazardous Waste Code – benzene), D043 (EPA Hazardous Waste Code – vinyl chloride) and

D01 9 (EPA Hazardous Waste Code - carbon tetrachloride) toxicity characteristic waste were placed in Water Pit 1 and 2 per a 1997 EPA Compliant, Compliance Order and Notice of Opportunity Hearing (Ref. 35, p.10). Beginning in 1991 and on several occasions since 1991, sludge from Water Pit 1 was mixed with fly ash and lime, removed and placed on the ground surface adjacent to the Water Pit 1 (Ref. 35, p. 12). Samples collected in October 1995 detected w aste in some of the tanks to be characteristically hazardous based on benzene, 1,2 -dichloroethane, tetrachloroethene, vinyl chloride or ignitability (Ref. 32, p. 46).

The presence of petroleum products at the site, as part of a site contamination, does not exclude the site

from C omprehensive Environmental Response, Compensation and Liability Act (CERCL A)

consideration. Sites are excluded from HRS scoring if they contain only CERCLA -excluded petroleum products. Any fractions of petroleum product that may fall under the Petroleum Exclusion in CERCLA have been comingled with other CERCLA hazardous substances onsite. The CERLCA hazardous

substances are subject to CERCLA response authority and responsibility. In 1980 SBA submitted a notification of hazardous waste activity to SBA as a generator of a Resource Conservation Recovery Act ( RCRA ) listed hazardous waste, D001 ( ignitable waste ) (Ref. 6, p. 44). Invoices and manifests from customers that had barges repaired, retrofitted or cleaned and painted during the operational period of SBA contained CERLCA eligible substances which included: asphalt, creosote, m ethyl -m ethacrylate

, methanol, caustic soda, styrene, coal tar, vinyl acetate, c arbon t etra chloride, e thyl a crylate and a crylates (Ref. 41, p. 11; p. 33; Ref. 44, pp. 162, 226, 232, 254, 274 & 379; Ref. 45, pp. 115 & 197; Ref. 46, pp. 9 & 203; Ref. 47, pp. 4, 15, 40, 50, 76, 78, 79, 125, 126, 236 & 241; Ref. 48, pp. 14, 16 & 388; Ref. 49, pp. 3, 33, 34, 38, 39, 110 & 236; Ref. 50, pp. 25, 130 & 133; Ref. 51, pp. 1-3 & 36-39). C hemical

hazards at this site included: arsenic, barium, mercury, lead, benzene, chloroform, 1,1,1-trichloroet hane, 1,2-dichloroethane, ethylbenzene, tetrachloroethene, trichloroethene, toluene, vinyl chloride, orthocresol, meta

- cresol, styrene and pyridine based on analysis of samples collected from the facilities four surface impoundments (Ref. 32, p. 49- 52 & 75- 94 ; Ref. 34, p. 1). Louisiana Department of Environmental Quality (LDEQ) concluded that t he only explanation for the prese nce of chlorinated hydrocarbons in the sludge and water samples collected and analyzed from the four impoundments on

site

, was that someone had negligently or intentionally mixed spent solvents with the barge contents, or that one of the barges contained these compounds as pure commodities (Ref. 33, p .15). Wastes from the barge cleaning operations were managed in a waste manage ment area that included four impoundments (Oil Pit, Water Pit 1, Water Pit 2, and Water Pit 3) , a land treatment unit (LTU) and storage tanks (Ref. 6, pp . 5 , 7-8 ). Waste from cleaning operations on site were comingled within the waste management units and not segregated during the operations or processing (Ref. 30, pp. 5, 21-26).

SBA has a regulatory history in regards to the storage and handling of hazardous wastes. In 1980, SBA

submitted a RCRA Part A Application to EPA indicating that SBA did not treat, store or dispose of hazardous waste (Ref .6, p. 44). In late 1989, SBA entered into an agreement with a contractor to handle the remediation and closure the former oil pit and former water pits 1, 2 a nd 3 that were in service since 1968 (Ref. 6, pp. 10 & 44). Visual indications of the possible presence of contamination were observed during subsurface investigations conducted from November 1989 to February 1990 by SBA contractors (Ref 6, pp. 25 & 44). In 1990, SBA submitted a notification to LDEQ as generator of hazardous waste (Ref. 6, p. 45). On February 15, 1990, the LDEQ Groundwater Protection Division (GWPD) issued a notification to SBA for the presence of subsurface contamination at the SBA site (Ref. 6, p. 45). In August 1990, the LDEQ, Solid Waste Division (SWD) issued an Order (OC-159) to SBA to close the

24

### waste management units (Ref. 6, p. 45). In early 1991, the bio-remediation started on May 29, 1990 on one of the impoundments (W ater P it 1) was deemed unsuccessful (Ref. 6, p. 10).

During 1994 LDEQ and EPA determined that closure activities for the site would be handled under the regulatory authority of either LDEQ H azardous W aste D ivision or EPA (Ref. 6, pp. 10-11 & 46 ). In 1994 the EPA Region 6 RCRA Enforcement Branch assumed the role for regulatory authority for the

site , and hired a contractor to conduct a Compliance Evaluation Inspection ( Ref. 6, p. 47; Ref. 22, p. 3 ).

SBA proposed to implement the RCRA Facility Investigation (RFI) an d submitted an RCRA RFI work plan in 1996, that proposed the compete closure of the impoundments and tanks (Ref. 6 , pp 5 & 11 ). EPA issued a RCRA 3008(a) Compliant, Compliance Order on July 1, 1997 (Ref. 22, p. 4). On September 9, 1997 SBA entered into a Consent Agreement and Consent Order (CACO) with EPA to resolve all issues presented in the complaint of storage, disposal and treatment of hazardous waste without a permit

, an d clean

- up the facility (Ref. 22, p. 4; Ref. 35, pp. 5-13). In December 2002 EP A issued an Order and Agreement for Interim Measures/Removal Action (IM/RA) of Hazardous/Principal Threat Wastes at SBA Shipyards, Inc., pursuant to RCRA Section 3008(h) (Ref. 5, pp. 29-37). Interim removal activities were conducted from March 2001 through January 2005 under the EPA 2002 Order and Agreement for IM/RA (Ref. 5, p. 6). Interim removal activities consisted of the removal of approximately 33.8 million pounds of oils, waxes and sludges, pumpable oily material and oily tank heels, 70 tons of contaminated debris, and 88 tons of recyclable scrap metal from the site (Ref. 5, p. 6).

Since regulatory site closure in 2002, tar- like material was observed in 2008 by LDEQ in soils down to a depth of 3 to 4 feet below ground surface (bgs) (Ref. 13, p. 1 ).

During the August 2013 EPA Site Inspection (SI) soil samples were collected down to 16 feet below ground surface (bgs) to identify the source material and contamination at SBA, ground water was collected to assess migration of contamination in the ground water pathway, and surface water samples and sediment samples were collected to assess the migration of contamination in the surface water pathway (Ref. 4, p.47). Analytical data from the soil and ground water samples indicated that the presence of numerous polycyclic aromatic hydrocarbons (PAHs) that exceeded background sample concentrations and met observed release criteria (Ref. 4, p. 48). As stated in the HRS , observed releases may be established based on either direct observation or chemical an alysis of samples (Ref. 1, p. 51589 ). Direct observation of the release of a hazardous substance into the media being evaluated establishes an observed release (Ref. 1, p. 51589) . An observed release by chemical analysis is established when

a nalytical evidence of a hazardous substance in the media being evaluated is significantly above the background level, and available information attributes some portion of the significant increase in the concentration of the hazardous substance to the site (Ref. 1, p. 51589 ).

During the September 2014 EPA Expanded Site Inspection (ESI) river sediment samples from the Mermentau River and wetland sediment samples were collected to identify and assess the migration of

contamination at SBA to the surface water pathway (Ref. 7, p. 40). Additional ground water was

collected on -site to assess the migration of contamination to the ground water pathway (Ref. 7, p.40). Waste samples were collected to identify the source material and contamination at SBA (Ref. 7, p. 40). Analytical data from the sediment samples indicated the presence of polycyclic aromatic hydrocarbons (PAHs) that met observed release criteria (Ref. 7, pp. 41-42).

Mermentau River is fished recreational ly as was observed and documented during the September 2014 ESI (Ref. 7, pp. 34 & 89-90). During the September 2014 ESI, a family of five was observed fishing in

25

### the Barge Slip adjacent to the Mermentau River and fishermen were observed during sediment sample collection along the Mermentau River (Ref. 7, pp. 89-91). Largemouth bass, crappie, bream, bluegill, catfish, gar, bullhead, carp, striped bass and sunfish are caught from Lake Arthur (Ref. 15, p. 1).

26SO

- Source Characterization



### 2.2 SOURCE CHARACTERIZATION

The sources evaluated at SBA Shipyard, for HRS purposes, are:

• Source No. 1: Partially Buried Barge ( Container)

• Source No. 3: Former Water Pit 1 (Surface Impoundment, Buried/Backfilled)

• Source No. 4: Former Land Treatmen t Unit (Land Treatment)

• Source No. 5: Dry Dock (Surface Impoundment, Not Buried/Backfilled)

• Source No. 6: Former Water Pit 3 (Surface Impoundment, Not Buried/Backfilled)

September 2016 

### 27SO

- Source Characterization

Source No.: 1



### 2.2.1 SOURCE IDENTIFICATION

– SOURCE 1

The following information corresponds to the first source identified for this documentation record.

Number of source : 1

Name of source : Partially Buried Barge

Source Type: Container

Description and Location of Source: A partially buried steel barge located on the southeast portion of the property, north of a designated wetland area (Figure 2) . The Partially Buried Barge is approximately

250 feet x 50 feet (Ref. 9, p.11). Waste oil and liquids from the barge a re being released into the wetlands (Ref. 9, pp. 53-55). An anonymous caller notified the National Response Center (NRC) in October 2012 that the barge was being scrapped and oil was being allowed to discharge to the ground (Ref. 21, p. 2). LDEQ conducted an investigation in October 2012 and reported evidence of the barge

scra pping activities and that oil was still visible inside the portion of the barge being salvaged, and along the perimeter and east end of the barge (Ref. 21, p. 14; Ref. 25 pp. 1-15 ).

Two (2 ) waste sample s were collected from within the Partially Buried Barge : one at location SBA-040 (Figure 3; Ref. 4, pp. 18, 22, 29, 141-142, 157, 895, 906-907 & 1026) and one at SBA

- ESI -15 (Figure 3;

Ref. 7, pp. 18, 21, 26, 93, 151, 921, 926-927 & 981 ).

• Location SBA-040, Sample SBA -040 – collected from the west corner of buried barge . Sample description is oily, asphaltic, black/saturated , and tarry material ( Figure 3; Ref. 4, pp. 29 & 1026).

• Location SBA- ESI -15, Sample SBA

- ESI -15 – collected at the northwestern edge of the partially buried barge. Sample description is hard, black and oily (Figure 3; Ref. 7, pp. 26 & 981).

Sample SBA -040 was shipped to the U.S. EPA Laboratory in Houston for analysis, data review and data

validation for Target Compound List (TCL) Volatile Organic Analysis (VOAs) by EPA method CLP

SOW SOM01.2 (method used -CLP OLM04.2 – GC/MS ) , TCL Semi

- Volatile Organic Analysis (SVOAs) by EPA method CLP SOW SOM01.2 (method used - CLP OLM04.2 – GC/MS ) , TCL

Pesticide/ Polychlorinated Biphenyls ( PCB ) by EPA method CLP SOW SOM01.2 (method used – CLP

OLM04.2 – GC/ECD ), Target Analyte List ( TAL ) Cyanides by EPA method CLP SOW ILM05.4 (method used 335.4 – Colorimetric ), and TAL Total Metals + Mercury by EPA method CLP SOW ILM05.4 (methods used - CLP ILM05.3

– ICP , CLP ILM05.3 – ICP/MS, CLP ILM05.3 – CVAAS ) (Ref . 4, pp. 22, 47 & 664 - 671 ).

S ample SBA

- ESI -15 was shipped to ALS Environmental in Houston for analysis for Dioxin/Furan by

EPA Method 8290 (Re f. 7, p. 283-285 ).

Sample SBA -040 contained polycyclic aromatic hydrocarbons ( PAHs ) that included : acenaphthene

, anthracene, acenaphthylene, b enzo(a)anthracene , benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, 1,1’-biphenyl, carbazole, chrysene, dibenzofuran, dibenz(a,h)anthracene, fluoranthen e, fluore ne, indeno(1,2,3- cd)pyrene, 2

- methylnaphthalene,

28SO

- Source Characterization

Source No.: 1



### naphthalene, phenanthrene and pyrene at concentrations equal to or greater than their cor responding report limits (RLs) (Ref. 4, pp. 29 & 70 ; Table 4 ).

Semi -volatile organic compounds (V OC s) identified included : cyclohexane, benzene,

m ethylcyclohexane , tetrachloroethene, toluene, ethylbenzene, xylene, isopropylbenzene, 1,2-

dichlorobenzene and vinyl chloride were also detected at concentrations equal to or greater than their corresponding RLs (Ref. 4, pp. 29 & 70 ; Table 4 ).

Metals constituents included: arsenic, chromium, cobalt, lead and mercury at concentrations equal to or greater than thei r corresponding RLs (Ref. 4, pp. 29 & 70 ; Table 4 ).

Sample SBA

- ESI

- 15 contained Chlorinated Dibenzo-p-Dioxins (CDDs) and Chlorinated Dibenzofurans (CDFs) . Those with some of the highest TEQs include: 2,3,4,7,8-Pentacholordibenzofuran (PeCDF), 2,3,4,6,7,8-Hexacholordibenzofuran (HxCDF), 1,2,3,6,7,8-Hexachlorodibenzofuran (HxCDF), 2,3,4,6,7,8-Hexachlorodibenzofuran (HxCDF), 1,2,3,7,8,9-Hexachlorodibenzo-p-dioxin (HxCDD) and Octachlorodibenzo-p- dioxin (Ref. 7, pp. 26-27, 57 & 1005-1008; Table 3 ).

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

The substances listed in Table 1 and 2 are associated with Source No. 1 based on analytical results from waste samples collected from the Partially Buried Barge during the 2013 SBA Shipyard SI and 2014

ESI. Sampling was conducted following the procedures set forth in the Quality Assurance Sampling Plan (QASP) (Ref. 4, pp. 882-969).

29SO

- Source Characterization

Source No.: 1



### T able 1 – Source 1 - Partially Buried Barge SI Sample

EPA/START Sample No. SBA

- 40

EPA Lab. Sample No. 1308020

- 30

Source No. 1 Barge

% Solids 79.29%

Units Result RL

μg/kg μg/kg

Analyte: SVOCs Acenaphthene 3.20E6 472000 Benzo (b) fluoranthene 1.02E6 118000

Benzo (g,h,i) perylene 389000 118000 Benzo (k) fluoranthene 914000 118000
1,1'

- Biphenyl 645000 118000 Acenaphthylene 385000 47200

Carbazole 1.66E7 J 1.18E6 Chrysene 3.04E6 1.18E6

Dibenzofuran 3.77E6 1.18E6

Dibenz (a,h) anthracene 145000 118000

Anthracene 4.61E7 4.72E6

Fluoranthene 6.79E6 472000

Fluorene 7.23E6 472000 Indeno (1,2,3

- cd) pyrene 450000 118000

2

- Methylnaphthalene 2.78E6 472000 Naphthalene 6.15E6 472000

Phenanthrene 1.69E7 472000 Pyrene 5.08E6 472000 Benzo (a) anthracene 1.98E6 118000 Benzo (a) pyrene 1.12E6 118000
Analyte: Total Metals mg/ kg mg/ kg
Mercury 1.46 0.074

Chromium 16.6 1.2

Cobalt 4.1 2.4

Lead 29.7 0.6

Arsenic 5.4 0.6
Analyte: VOCs μg/kg μg/kg Cyclohexane 10800 199

Benzene 17400 199 Methylcyclohexane 15300 199

Toluene 36500 199

Tetrachloroethene 267 199 Ethylbenzene 17900 199

meta

- /para

- Xylene 66400 398

ortho

- Xylene 29600 199 Isopropylbenzene 24700 199
1,2

- Dichlorobenzene 565 199 Vinyl chloride 313 199
Key:

μ g/kg = Concentrations in microgram per kilogram mg/kg = Concentrations in milligrams per kilogram

J

- The identification of the analyte is acceptable; The reported value is an estimate (Ref. 4, p. 865). The reported value for carbazole is biased unknown (Ref. 4, p. 181), but did not need to be adjusted as the presence of the hazardous substance is

not in question.

RL

- Reporting Limit

BOLD

- Concentration is greater than reporting limit

References Chain of Custody: Ref. 4, pp. 172

- 173 Laboratory Reports: Ref. 4, pp. 664

- 671

Data: Ref. 4, pp. 181, 666 & 865; Ref. 31, pp. 8 & 14; Ref. 52



### 30SO

- Source Characterization

Source No.: 1



### T able 2- Source 1- Partially Buried Barge ESI Sam ple

EPA/START Sample Number: SBA

- ESI

- 15
ELS Laboratory Sample Number: E1401160

- 002
Sampling Location: SBA

- ESI

- 15

Sample Description: Waste sample from NW corner of partially buried barge (Source 1)

% Solids: 80.30%

Units: ng/kg

Analyte: Dioxins and Furans Result Flag MRL TEQ

1,2,3,4,7,8

- Hexachlorodibenzofuran (HxCDF) 26.6 KJ 16 2.66

1,2,3,6,7,8

- Hexachlorodibenzofuran (HxCDF) 26.2 KJ 18.6 2.62

2,3,4,6,7,8

- Hexachlorodibenzofuran (HxCDF ) 32.2 J 22.8 3.22

2,3,4,7,8

- Pentachlorodibenzofuran (PeCDF) 46.8 KJ 38.9 14.0
1,2,3,7,8,9

- Hexachlorodibenzo

- p

- dioxin (HxCDD) 52.1 J 19.4 5.21

Octachlorodibenzo

- p

- dioxin (OCDD) 1370 J 6.1 0.411

Total TCDD TEQ

- 2005 WHO (ND = MRL) 30.2
Key:

MRL

- Method Reporting Limit ND

- Indicates concentration is reported

"Not Detected" ng/kg

- nanograms per kilogram MRL = Method Reporting Limit

TCDD

- Tetrachlorodibenzodioxins TEQ

- Toxicity Equivalency Quotient
U = Undetected at Reporting Limit WHO

- World Health Organization
J = an estimated value (Ref. 7, p. 262). The reported value for octachlorodibenzo

- p

- dioxin (OCDD) is biased unknown (Ref. 7, p. 998) but did not need to be adjusted as the presence of the hazardous substance is not in question.
K = estimated maximum possible concentration for the associated compound (Ref. 7, p. 262).

Bold = Concentration detected above the Reporting Limits

References
Chain of Custody: Ref. 7, p. 171
Laboratory Results: Ref. 7, pp. 1005

- 1008

Data: Ref. 7, pp. 262, 998 & 1005; Ref. 52

31SO

- Source Characterization

Source No.: 1



### 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.

Release to ground water: The ground water pathway was not scored; therefore, ground water

containment was not evaluated.

Release via overland migration: Documentation or evidence exists to indicate that Source No.

1 had either a dike or similar structure surrounding the container area, but hazardous substances

have migrat ed from the container area ( Ref. 4, p. 141-142; Ref. 19, pp. 7-8; Ref. 21, p. 2 ; Ref. 24, p. 8 ). The containment factor value of 10 is assigned to Source No.1 because of evidence of hazardous substance migration from the container area (Ref. 1, Table 4-2).

Because containment for this source is greater than zero, the following substances associated with the source can migrate via the Surface Water Migration Pathway (Ref. 1, Sec. 4.1.2.1.2.1.1):

• Acenaphthene

• Acenaphthylene

• Anthracene

• Arsenic

• Benzene

• Benzo(a)anthracene

• Benzo(a)pyrene

• Benzo(b)fluoranthene

• Benzo(g,h,i)perylene

• Benzo(k)fluoranthene

• Biphenyl, 1,1’

• Carbazole

• Chromium

• Chrysene

• Cobalt

• Cyclohexane

• Dibenz(a,h)anthracene

• Dibenzofuran

• Dichlorobenzene, 1,2-

• Ethylbenzene

• Fluoranthene

• Fluorene • Hexachlorodibenzo-p-dioxin, 1,2,3,7,8,9- (HxCDD)

• Hexachlorodibenzofuran, 1,2,3,4,7,8- (HxCDF)

• Hexachlorodibenzofuran, 1,2,3,6,7,8- (HxCDF)

• Hexachlorodibenzofuran

, 2,3,4,6,7,8- (HxCDF)

• Indeno(1,2,3- cd)pyrene

• Isopropylbenzene

• Lead

• Mercury

• Methylcyclohexane

• Methylnaphthalene, 2-

• Naphtha lene

• Octachlorodibenzo-p- dioxin (OCDD)

• Pentachlorodibenzofuran, 2,3,4,7,8 – (PeCDF)

• Phenanthrene

• Pyrene

• Tetrachloroeth ene

• Toluene

• Vinyl chloride

32SO

- Source Characterization

Source No.: 1



### • Xylene , -m, -p, -o

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1.1. Hazardous Constituent Quantity

– Tier A

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 CERCLA hazardous substances in the source and

releases from the source is not known and cannot be estimated with reasonable confidence (Ref. 1, pp. 51590-51591). Insufficient historical and current data (manifests, potentially responsible party [PRP] records, State records, permits, waste concentration data, etc.) are 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 Sour ce 1 with reasonable confidence.

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

2.4.2.1.2. Hazardous Wastestream Quantity – Tier B

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 is not known and cannot be est imated with

reasonable confidence (Ref. 1, p. 51591). 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 extrapola te a total or partial Hazardous Wastestream Q uantity for

Source 1 with reasonable confidence.

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

2.4.2.1.3. Volume

– Tier C

The volume of Source 1 can be adequately determined based on a one time capacity volume, and not the

actual contents of the source (Ref 1, Sec. 2.4.2.1.3).

Completed i nterim measures/removal actions (IM/RA) at SBA specify that a total of 1.19 million gallons of pumpable oil y material was pumpe d from the Partially Buried B arge and thermal destroyed (Ref. 5, p. 14) . Pumpable oily material was removed from the partially bur i ed barge till approximately 4

to 6 inches of heel remained between the structural member s in the vessel, which could not be removed (Ref. 5, p. 14).

A ft er completion of the IM/RA on the P artially Buried B arge the emptied vessel was used as a collection tank for contaminated water generated by subsequent (IM/RA) cleanup activities (Ref. 5, p.14). The approximate 850,000 gallons of contaminated water collected in the P artially Buried B arge was later removed (Ref. 5, p. 8). The partially buried barge was ultimately emptied of all but

33SO

- Source Characterization

Source No.: 1



### approximately 2 to 6 inches of water and oily heel retained by structural members in the vessel (Ref. 5, p. 17) . To prevent water from refilling the vessel, all hatches and covers on the P artially Buried B arge were tack -welded shut (Ref. 5, p. 17). T his was ineffective

, because in October 2012 an anonymous caller notified the National Response Center (NRC) that the barge was being scrapped and oil was being allowed to discharge to the ground (Ref. 21, p. 2). LDEQ conducted an investigation and reported evidence of the barge scra p ping activities and that oil was still visible inside the portion of the barge being salvaged, and along the perimeter and east end of the barge (Ref. 21, p. 14).

Based on the IM/RA information available the one time volume capacity volume can be determined for

the P artially Buried Barge (Source No. 1). According to the pumpable oily material inventory the estimated maximum capacity was calculated for each compartment of the vessel ( Ref. 5, p. 47). The one time capacity volume will be based on the IM/RA which calculated the estimated maximum capacity for each compartment of the partially buried barge.

Bow Rake Tank 26,853 gallons

Deck Tank S Not Measured

Deck Tank P Not Measured Compartment 1S 75,054 gallons Compartment 1P 75,054 gallons Compartment 2S 71,808 gallons Compartment 2P 71,808 gallons Compartment 3S 100,279 gallons Compartment 3P 100,279 gallons Compartment 4S 100,279 gallons Compartment 4P 100,279 gallons Compartment 5S 86,908 gallons Compartment 5P 86,908 gallons

Aft Trim Tank 18,388 gallons

TOTA L 913, 897 gallons

The hazardous waste quantity evaluation equation applied for the conversion of gallons to cubic yards ( yds 3 

### ) is 1 yd 3 

### = 200 gallons (Ref. 1, Table 2-5, footnote b). The one time estimated capacity of the

P artially Buried Barge is 4,569.49 cubic yards (Ref. 1, Sec 2.4.2.1.3).

913,897 gallons X 1 yd 3 

### / 200 gallons per 1 yd 3 

### = 4, 569.49 yd 3



### The hazardous waste quantity evaluation equation for a container is V/2.5 (Ref. 1, Table 2- 5) . The

volume source will be assigned a volume hazardous waste quantity value of 1,827.79

4,569.49 yd 3 

### / 2.5 = 1,827.79

Volume of S ource No. 1 ( yd 3 

### ): 4,569.49 Reference(s): Ref. 1, Table 2 -5, p. 51591 Volume Assigned Value: 1,827.79

34SO

- Source Characterization

Source No.: 1



### 2.4.2.1.4. Area

– Tier D

Area was not calculated for Source 1 since volume was adequately determined and assigned a value

. Therefore, according to HRS, area is not calculated (Ref. 1, Sec. 2.4.2.1.3 and 2.4.2.1.4).



### Area of S ource No. 1 in square feet (ft 2 

### ): Not calculated Area Assigned Value: 0

References: Ref. 1, Sec. 2.4.2.1.4

2.4.2.1.5. Source Hazardous Waste Quantity Value

Source No. 1, Partially Buried Barge.

Measures Surface Water, Ground Water and Air Pathways

Tier A NC

Tier B NC

Tier C 

### 1,827.79

Tier D 

### NC Assigned Source Hazardous Waste Quantity Value (Ref. 1, Sec. 2.4.2.1.5) 

### 1,827.79

NC: Not Calculated



### The highest value assigned to either Tier A, Tier B, Tier C, or Tier D is assigned as the Source No. 1 Hazardous Waste Quantity Value (Ref. 1, Section 2.4.2.1.5). The h ighest value assigned is Tier C.

Source No. 1 Hazardous Waste Quantity Value: 1,827.79

35SO

- Source Characterization

Source No. : 3



### 2.2.1 SOURCE IDENTIFICATION

– SOURCE 3

The following information corresponds to the third source identified for this documentation record.

Name of source: F ormer Water Pit 1

Number of source : 3

Source Type: Surface Impoundment Buried/Backfilled

Description and Location of Source: F ormer Water Pit 1 was a surface impoundment located on the southeast portion of the property, northwest of a design ated wetland area (Figure 2 ; Ref. 16, p. 2 ; Ref. 18, p. 2 ). The Former Water Pit 1 was used to treat and store wastewater and sludges generated during the barge cleaning activities (Ref. 24, p. 8). The Former Water Pit 1 was excavated to an approximate depth of 18 feet bgs around 1968, and the soils below the unlined impoundment consist ed of clay to an approximately depth of 20 to 25 feet bgs (Ref. 24, pp. 8 & 107 ). During operation, Water Pit 1 received wastewater from the oil pit and the oil/water se parator (Ref. 24, pp. 12-13 ). Oil was returned to the oil pit, and water was pumped to Water Pit 2 (Ref. 24, p.13). Three barge tanks used for oil/water/sludge separation and storage were located south of Water Pit 1 (Ref. 24, p. 12). The oil/water tanks consisted of three converted barge tanks (Ref. 24, p. 14). The three tanks were fabricated by cutting a barge into three sections, sealing the ends, and placing the barges upside next to Water Pit 1 (Ref. 24, p.14). The

tanks had a tot al capacity of 9,5 00 barrels, were used to store and separate oil, water, and sludge (Ref. 24, p. 14). Subsequently, aboveground oil/water separators and storage tanks replaced the funct ions of Water Pit 1 prior to undergoing closure beginning in 1991 (Ref . 6, p. 10; Ref. 16, pp. 2-5).

By 1994, Water Pit 1 was inactive and had undergone partial closure (Ref. 24, p. 13). I n mid -1990 SBA began closure on Water Pit 1 by using an aerator to biologically treat the wastewater and sludges

, and by early 1991 the process was deemed unsuccessful (Ref. 6, p. 10; Ref. 24, p. 13). Prior to closure activities in 1991, an estimated 2,542 cubic yards of sludge was present in Water Pit 1 (Ref. 24, p. 13). In 1992, SBA implemented a new closure technique, the free wat er and oil was pumped fr om Water Pit 1 to the storage tanks or into the oil pit (Ref. 6, p. 10; Ref. 24, p. 13) . The remaining sludge in Water Pit 1 was then solidified by mixing with fly ash and lime (Ref. 6, p. 10). Approximately one third of the

solidified/stabilized sludges was removed from Water Pit 1 and placed on the ground at the area

former ly designated as the Land Treatment Unit (Ref. 6, p. 10; Ref. 24, p. 13). The remaining sludges in

Water Pit 1 were piled in the south east/east end of the imp oundment , with accumulated rainwater periodically pumped to storage tanks (Ref. 6, p. 10; Ref. 24, p. 13). No information has been found mentioning or detaili ng the closure of Water Pit 1.

The impoundment formerly known as Water Pit 1 had dimensions of approximate ly 160 f eet x 100 f eet
x 15 f eet and was estimated to contain an approximate 6,900 cubic yards of solidified sludge piled in the east end of the impoundment in 1996 (Ref. 4, p. 30; Ref. 6, p. 7 ). Prior to closure activities in 1991, an

estimat ed 2,542 cubic yards of sludge was present in the impoundment (Ref. 24, p. 13).

Soil borings were advanced using direct push technology at three (3) locations from the Former Water

Pit 1 area during the August 2013 EPA SI (Ref. 4, pp. 57, 906 & 908 ; Figur e 3). The borings were advanced to a maximum depth of 16 feet below ground surface (bgs) using the procedures in the EPA

36SO

- Source Characterization

Source No. : 3



### Environmental Response Team (ERT) Standard Operating Procedure (SOP) 2050, modified for the actual unit used by the driller (Ref. 4, pp. 20 & 934

- 946). Grab soil samples were collected from each boring, from intervals o f visual contamination or where PID readings for VOCs above background were detected (Ref. 4, pp. 20, 153, 893 & 934

- 946).

Soil samples were shipped to the U. S. EPA Laboratory in Houston for analysis

, data review and data

validation for Target Compound List (TCL) Volatile Organic Analysis (VOAs) by EPA method CLP

SOW SOM01.2 (method used

- CLP OLM04.2

– GC/MS ) , TCL Semi

- Volatile Organic Analysis (SVOAs) by EPA me thod CLP SOW SOM01.2 (method used

- CLP OLM04.2

– GC/MS ) , TCL

Pesticide/PCB s by EPA method CLP SOW SOM01.2 (method used

– CLP OLM04.2

– GC/ECD ) , TAL Cyanides by EPA method CLP SOW ILM05.4 (method used 335.4

– Colorimetric ) , and TAL Total Metals + Mercury b y EPA method CLP SOW ILM05.4 (methods used

- CLP ILM05.3

– ICP , CLP

ILM05.3

– ICP/MS, CLP ILM05.3

– CVAAS) (Ref. 4, pp. 20, 47 , 482

- 491, 546

- 563, 582

- 607 ).

Location SBA

- 002 was sampled north of the Former Water Pit 1 along the overland flow pathway for this source, Location SBA

- 004 was sampled along the approximate former east end of the Former Water

Pit 1 where remaining solidified/stabilized sludge was piled, and Location S BA

- 005 was sampled in the

area of the forme r oil/water separator associated with the former Water Pit 1 (Figure 3 ). The following samples were collected (Ref. 4, pp. 30

- 31, 57, 149, 869 & 871 ) :

• Sample SBA

- 002PD (6

- 8 feet bgs)

– collected at highest PID reading; chemical odor ; silty clay with g ray and orange mottled coloring, and s lightly plastic (Ref. 4, pp. 30, 57, 869 & 980 ) ;

• Sample SBA

- 002WT (10

- 12 feet bgs)

– collected above water table; chemical odor ; c lay w ith silt seams, and visible product in seam (Ref. 4, pp. 30, 57 & 981 ) ;

• Sample SBA

- 004

- 24 (2

- 4 feet bgs)

– heavy chemi cal odor, staining with a sheen ; clay

- ey/silt, and moist stained, black (Ref. 4, pp. 30, 57, 871 & 984 ) ;

• Sample SBA

- 004 004WT (12

- 14 feet bgs)

– collected above water table; chemical odor, sheen

present ; silty

- clay, and m oist stained, black (Ref. 4, p. 30, 57, 871 & 985 ) ;

• Sample SBA

- 005PD (12

- 14 f ee t bgs)

– colle cted at the highest PID reading ; c lay

- ey/ silt, t an stained dark grey coloring

. (Ref. 4, pp. 31, 57, 872 & 986 )

• Sample SBA

- 005WT (14

- 16 f ee t bgs)

– collected ab ove water table ; c lay

- ey/ silt, g rey color with black staining odor. (Ref. 4, pp. 31 , 57, 872 & 987 )

The soil sample results from these source areas were compared to the concentrations in the corresponding foot interval s from the background soil sample (Table 3) , while this increase in concentration is not required to assoc ia te the substances with the source, it does demonstrate the level in the soil samples are significantly above background. PAHs such as acenaphthene, acenaphthylene, anthracene, benzo (a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, bis(2

- ethylhexyl)phthalate, carbazole, c hrysene, dibenz(a,h)anthracene

, dibenzofuran, 2,4

- dimethylphenol, fluoranthene, fluorene, indeno(1,2,3

- cd)pyrene, 2

-

me thylnaphthalene

, 2

- m ethylphenol

, 3 &/or 4

- m ethylphenol

, naphthalene, phenanthrene, and pyrene

were detected greater than background levels

. Constituents were detected at 2 to 4 f ee t bgs

, 6 to 8 feet bgs, 10 to 12 feet bgs, 12 to 14 feet bgs and /or at betw een 1 4 to 16 f ee t bgs (Ref. 4, pp. 30

- 31, 482

- 491

, 546

- 563 & 582

- 607 ; Tables 3 & 5 ).

37SO

- Source Characterization

Source No. : 3



### VOCs were detected above background concentrations (See Table 3) in the 2 to 4 f ee t bgs, 6 to 8 feet bgs, 10 to 12 feet bgs, 12 to 14 feet bgs and /or at depths between 14 to 16 f ee t bgs for cyclohexane, methylcyclohexane, ethylbenzene, cis

- 1,2

- dichloroethane, tetrachloroethene, styrene, isopropylbenzene,
1,4

- dichlorobenzene, 1,2

- dichlorobenzene toluene, benzene

, xylene and toluene (Ref. 4, pp. 30

- 31, 482

- 491, 546

- 563 & 582

- 607; Tables 3 & 5). While this increase in concentration is not required to associate the substances with the source, it does demonstrate the level in the soil samples are significantly above background.

In addition, numerous m etal concentrations from the 2 to 4 f ee t bgs, 6 to 8 feet bgs, 10 to 12 feet bgs, 12 to 14 feet bgs and /or betw een 14 to 16 feet bgs intervals were detected at concentrations above background level s . Metals concentrations detected above background levels include: copper,

manganese, mercury, nickel, z inc, barium, cadmium, cobalt, lead and arsenic (Ref. 4, p. 30

- 31, 482

- 491,

546

- 563 & 582

- 607 ; Table s 3 & 5). Again, w hile this increase in concentration is not required to

associate the substances with the so urce, it does demonstrate the level in the soil samples are significantly above background.

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

Soil sample results from former source areas representing Source No. 3 included PAHs such as acenaphthene , acenaphthylene, anthracene, b enzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, 1,1’

- biphenyl, bis(2

- ethylhexyl)phthalate, carbazole, chrysene, dibenz(a,h)anthracene, dibenzofuran, 2,4

- dimenthylphenol, fluoranthene, fluorene, indeno(1,2,3

- cd)pyrene, 2

- methylnaphthalene, 2

- methylphenol, 3 &/or 4

- methylphenol, nap hthalene, phenanthrene, and pyrene (Table 5)

. This is consistent with identification of buried impoundments used in the barge cleaning operation s (Ref. 4, p. 31) . These constituents are also detected in other sources at
SBA including the Dry Dock and Partially Buried Barge (Sources 6 , and 1 respectively) (Ref. 4, p. 31; Ref. 7, p. 36)

.

In addition, numerous VOCs such as cyclohexane, methylcyclohe xane, ethylbenzene, cis

- 1,2

- dichloroethane, tetrachloroeth e ne, styrene, isopropylbenzene, 1,4

- dichlorobenzene, 1,2

- dichlorobenzene toluene, benzene

, xylene and toluene were detected. M etal concentrations were detected to include

mercury, copper, manganese , nickel, zinc, barium, cadmium, chromium, cobalt, lead and arsenic ( Ref. 4,

pp. 30

- 31, 482

- 491, 546

- 563 & 582

- 606 ; Tables 3 & 5).

38SO

- Source Characterization

Source No. : 3



### Ta ble 5 – Source 3 – Former Water Pit 1 Samples

EPA/START Sample No.: SBA

- 002

- PD SBA

- 002

- WT SBA

- 004

- 24
EPA Laboratory Sample No.: 1308020

- 16 1308020

- 17 1308020

- 20
Depth of Sample: 6 to 8 feet internal 10 to 12 feet internal 2 to 4 feet interval

% Solids: 73.22% 73.83% 80.81%

Unit: Result RL > 3x Bkgd or >

RL Result RL > 3x Bkgd or >

RL Result RL > 3x Bkgd or >

RL

Analyte: SVOCs μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg

Ace naphthene 70900 6710 246 (RL) 141000 23900 240 (RL) 1.12E6 47300 256 (RL)
Benzo (b) fluoranthene 24000 1680 615 (RL) 54900 5970 599 (RL) 481000 118000 639 (RL) Benzo (g,h,i) perylene 9830 1680 615 (RL) 25000 5970 599 (RL) 303000 118000 639 (RL)

Benzo (k) fluoranthene 16300 1680 615 (RL) 44000 5970 599 (RL) 486000 118000 639 (RL)

1,1'

- Biphenyl 22100 1680 615 (RL) 37300 5970 599 (RL) 257000 118000 639 (RL)
Bis(2

- ethylhexyl)phthalate U 1680 615 (RL) U 5970 599 (RL) 13100 N 11800 639 (RL) Acenaphthylene 4970 671 246 (RL) 6460 2390 240 (RL) 323000 47300 256 (RL)

Carbazole 45200 J (4520)* 16800 615 (RL) 51600 J (5160)* 5970 599 (RL) 5.94E6 J (5.94E5)* 1.18E6 639 (RL)

Chrysene 54700 16800 615 (RL) 93300 5970 599 (RL) 1.20E6 118000 639 (RL)

Dibenzofuran 74200 16800 615 (RL) 151000 59700 599 (RL) 1.55E6 118000 639 (RL)
Dibenz (a,h) anthracene 3540 1680 615 (RL) 8740 5970 599 (RL) 108000 106000 639 (RL)

2,4

- Dimethylphenol 111000 6710 615 (RL) 115000 2390 599 (RL) U 11800 639 (RL)

Anthracene 111000 6710 246 (RL) 115000 2390 240 (RL) 1.66E7 473000 256 (RL)

Fluoranthene 210000 6710 246 (RL) 495000 23900 240 (RL) 3.62E6 473000 256 (RL)

Fluorene 106000 6710 246 (RL) 208000 23900 240 (RL) 2.85E6 473000 256 (RL)
Indeno (1,2,3

- cd) pyrene 11900 1680 615 (RL) 27700 5970 599 (RL) 343000 118000 639 (RL)

2

- Methylnaphthalene 63300 6710 246 (RL) 86600 2390 240 (RL) 1.01E6 47300 256 (RL)

2

- Methylphenol U 1680 615 (RL) U 5970 599 (RL) U 11800 639 (RL)

3 &/or 4

- Methylphenol 428000 67100 615 (RL) 946000 23900 599 (RL) 13500 11800 639 (RL) Naphthalene 251000 6710 246 (RL) 191000 23900 240 (RL) 2.52E6 473000 256 (RL)

Phenanthrene 428000 67100 246 (RL) 946000 23900 240 (RL) 8.33E6 473000 256 (RL)
Pyrene 138000 6710 246 (RL) 333000 23900 240 (RL) 2.47E6 473000 256 (RL)
Benzo (a) anthracene 45500 16800 615 (RL) 98700 5970 599 (RL) 921000 118000 639 (RL)
Benzo (a) pyrene 23700 1680 615 (RL) 57600 5970 599 (RL) 610000 118000 639 (RL)

Analyte: Total Metals mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg

Mercury U 0.075 0.08 (RL) U 0.08 0.076 (RL) 0.709 0.075 0.082 (RL)
Copper 39.8 2.6 19.8 (3x) 29.0 2.5 22.8 (3x) 75.5 2.4 24.6 (3x)
Manganese 10900 0.6 68.7 (3x) 587 0.6 166.2 (3x) 156 0.6 435 (3x)

Nickel 70.9 2.6 14.4 (3x) 27.8 2.5 32.1 (3x) 17.5 2.4 14.1 (RL)

Zinc 66.7 2.6 33.6 (3x) 70.4 2.5 51.3 (3x) 150 2.4 89.7 (RL)

Barium 3730 1.3 591 (3x) 179 1.2 336 (3x) 246 1.2 285 (RL)

Cadmium 2.3 0.6 0.60 (RL) 1.5 0.6 0.60 (RL) 0.8 0.6 2.1 (3x)

Cobalt 200 2.6 9.6 (3x) 9.5 2.5 17.7 (3x) 10.2 2.4 2.5 (RL)

Lead 39.9 0.6 31.2 (3x) 20.7 0.6 44.7 (3x) 32.4 0.6 46.5 (3x)

Arsenic 18.2 0.6 9.9 (3x) 11.9 0.6 6.9 (3x) 3.5 0.6 13.2 (3x)

Analyte: VOCs μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg
Cyclohexane 229 99.9 4.1 (RL) 220 L 89.0 3.9 (RL) 735 100 4.1 (RL) Methylcyclohexane 680 99.9 4.1 (RL) 566 L 89.0 3.9 (RL) 1350 100 4.1 (RL) Ethylbenzene 498 99.9 4.1 (RL) 403 L 89.0 3.9 (RL) 2090 100 4.1 (RL)

meta

- /para

- Xylene 743 200 8.3 (RL) 908L 178 7.8 (RL) 12400 200 8.2 (RL)

ortho

- Xylene 418 99.9 4.1 (RL) 343 4.5 3.9 (RL) 4830 100 4.1 (RL)

cis

- 1,2

- Dichloroethene UJ 4.5 4.1 (RL) 30.3 4.5 3.9 (RL) 36.7 5.0 4.1 (RL)

Benzene 295 L 4.5 4.1 (RL) 273 4.5 3.9 (RL) 5570 100 4.1 (RL)

Toluene 191 L 4.5 4.1 (RL) 560 L 89.0 3.9 (RL) 6270 100 4.1 (RL)

Tetrachloroethene UJ 4.5 4.1 (RL) 9.7 4.5 3.9 (RL) 37.1 5.0 4.1 (RL)
Styrene UJ 4.5 4.1 (RL) 15.1 J (1.51)* 4.5 3.9 (RL) 2560 100 4.1 (RL) Isopropylbenzene 102 L 4.5 4.1 (RL) 73.2 4.5 3.9 (RL) 2250 100 4.1 (RL)

1,4

- Dichlorobenzene 32.3 L 4.5 4.1 (RL) 18.6 4.5 3.9 (RL) U 5.0 4.1 (RL)

1,2

- Dichlorobenzene 312 L 4.5 4.1 (RL) 178 4.5 3.9 (RL) 5.8 5.0 4.1 (RL)

Key:

μ g/kg = Concentrations in micrograms per kilograms RL

- Reporting Limit mg/kg = Concentrations in milligrams per kilogram PD

- Highest PID Reading

WT

- Above the Water Table U

- Undetected

J

- The identification of the analyte is acceptable; The reported value is an estimate (Ref. 4, p. 865). The reported values for carbazole in samples SBA

- 002

- PD, SBA

- 002

- WT, SBA

- 004

- 24, SBA

- 004

- WT,

SBA -005- PD, and SBA -005- WT are biased unknown (Ref. 4, p. 181). The reported values for anthracene, fl uo ranthene, phenanthrene, cyclohexane, and methylcyclohexane in sample SBA -005- PD are biased unknown (Ref. 31, pp. 181 & 186). The reported value for styrene in sample SBA -002- WT is biased unknown (Ref. 31, p. 185). The reported value for tetrachloroethene in sample SBA -005- WT is biased unknown (Ref. 31, p. 185). The presence of these substances is not in doubt.

L

- The identification of the analyte is acceptable; the reported value may be biased low. The actual value is expected to be greater than the reported value (Ref. 4, 865).

N

- There is a presumptive evidence that the analyte present; the analyte is reported as a tentative identification (Ref. 4, p. 8 65).

*

- The detected concentration was adjuste d by using the guidance document " Using Qualified Data to Document and Observed Release and Observed Contamination " (Ref. 31, pp. 8, 12, 14, & 15). After adjusting the value for the qualified data to reflect the possible effect of the bias on the substanc e concentration , there is still a significant increase in contamination.

BOLD

- C oncentration detected significantly above the background concentration or reporting limits.

References
Chain of Custody: Ref. 4, p. 170 Ref. 4, p. 170 Ref. 4, p. 171
Laboratory Results: Ref. 4, pp. 546

- 554 Ref. 4, pp. 555

- 563 Ref. 4, pp. 582

- 590

Data Ref. 4, p. 181, 474

- 481, 549 & 865; Ref. 31, pp. 8 and 14; Ref. 52 Ref. 4, p. 181, 185, 442

- 479, 556, 558 & 865; Ref. 31, pp. 8, 12, and 14; Ref. 52 Ref. 4, p. 181, 466

- 473, 585 & 865; Ref. 31, pp. 8 and 14; Ref. 52



### 39SO

- Source Characterization

Source No. : 3



### Table 5 (continued)

– Source 3

– Former Water Pit 1 Samples

EPA/START Sample No.: SBA

- 004

- WT SBA

- 005

- PD SBA

- 005

- WT EPA Laboratory Sample No.: 1308020

- 21 1308020

- 22 1308020

- 08
Depth of Sample: 12 to 14 feet interval 12 to 14 feet interval 14 to 16 feet interval

% Solids: 81.66% 83.19% 76.84%

Unit: Result RL 3x Bkgd or >

RL Result RL 3x Bkgd or > RL Result RL 3x Bkgd or >

RL

Analyte: SVOCs μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg
Acenaphthene 1.33E6 48300 259 (RL) 4590 475 259 (RL) 44000 1250 247 (RL)
Benzo (b) fluoranthene 552000 121000 649 (RL) 2610 1190 649 (RL) 18400 3120 618 (RL) Benzo (g,h, i) perylene 317000 121000 649 (RL) 2510 1190 649 (RL) 11400 3120 618 (RL)
Benzo (k) fluoranthene 584000 121000 649 (RL) 2010 1190 649 (RL) 14700 3120 618 (RL)

1,1'

- Biphen yl 455000 121000 649 (RL) 1480 1190 649 (RL) 15400 3120 618 (RL)
Bis(2

- ethylhexyl)phthalate U 12100 649 (RL) U 1190 649 (RL) U 3120 618 (RL) Acenaphthyl ene 409000 48300 259 (RL) 542 475 259 (RL) 4060 1250 247 (RL)

Carbazole 1.40E7 J (1.40E6)* 1.21E6 649 (RL) 6420 J (642.0)* 1190 649 (RL) 25800 J (2580)* 3120 618 (RL)

Ch

rysene 1.68E6 121000 649 (RL) 4510 1190 649 (RL) 31300 3120 618 (RL)

Dibenzofuran 2.38E6 1.21E6 649 (RL) 5220 1190 649 (RL) 52800 3120 618 (RL)
Dibenz (a,h ) anthracene 113000 112000 649 (RL) U 1190 649 (RL) 3210 3120 618 (RL)

2,4

- Dimethylphenol 22500 12100 649 (RL) U 1190 649 (RL) U 3120 618 (RL)

Anthracene 3.87E7 4.83E6 259 (RL) 16700 J (1670)* 475 259 (RL) 41100 1250 247 (RL)

Fluoranthene 4.23E6 483000 259 (RL) 16900 J (1690)* 475 259 (RL) 133000 12500 247 (RL)

Fluorene 4.81E6 483000 259 (RL) 5760 475 259 (RL) 65300 12500 247 (RL)
Indeno (1,2,3

- cd) pyrene 361000 121000 649 (RL) 1800 1190 649 (RL) 12000 3120 618 (RL)

2

- Methylnap hthalene 1.89E6 48300 259 (RL) 4080 475 259 (RL) 44500 1250 247 (RL)

2

- Methylphenol 16100 12100 649 (RL) U 1190 649 (RL) U 3120 618 (RL)

3 &/or 4

- Me thylphenol 36000 12100 259 (RL) U 1190 259 (RL) U 3120 618 (RL) Naphthalene 4.46E6 483000 259 (RL) 12100 475 259 (RL) 170000 12500 247 (RL)

Phenanthrene 1.19E7 483000 259 (RL) 32200 J (3220)* 4750 259 (RL) 273000 12500 247 (RL)

Pyrene 2 .58E6 483000 259 (RL) 12800 475 259 (RL) 98800 12500 247 (RL)
Benzo (a) anthracene 1.09E6 121000 649 (RL) 4090 1190 649 (RL) 29500 3120 618 (RL)
Benzo (a) p yrene 706000 121000 649 (RL) 2760 1190 649 (RL) 20200 3120 618 (RL)

Analyte: Total Metals mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg

Mercury 1.75 0.076 0.075 (RL) U 0.071 0.075 (RL) U 0.074 0.079 (RL)

C opper 104 2.3 54 (3x) 7.4 2.3 54 (3x) 13.6 2.5 12.3 (3x)
Manganese 161 0.6 498 (3x) 138 0.6 498 (3x) 891 0.6 110.1 (3x)

N ickel 16.8 2.3 54 (3x) 8.7 2.3 54 (3x) 26.5 2.5 24.6 (3x)

Zinc 205 2.3 158.7 (3x) 21.1 2.3 158.7 (3x) 45.3 2.5 42.6 (3x)

B arium 325 1.2 375 (3x) 87.4 1.1 375 (3x) 151 1.2 184.5 (3x)

Cadmium 0.8 0.6 2.1 (3x) U 0.6 2.1 (3x) 0.7 0.6 0.6 (RL)

C obalt 9.9 2.3 19.5 (3x) 3.0 2.3 19.5 (3x) 10.2 2.5 23.1 (3x)

Lead 48.0 0.6 44.4 (3x) 4.9 0.6 44.4 (3x) 14.0 0.6 23.4 (3x)

A

rsenic 5.1 0.6 12 (3x) 0.7 0.6 12 (3x) 8.3 0.6 2.1 (3x)

Analyte: VOCs μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg
Cyclohexane 1140 99.8 4.2 (RL) 62.6 J (6.26)* 4.1 4.2 (RL) 928 L 83.5 41.9 (RL)

M ethylcyclohexane 1970 99.8 4.2 (RL) 172 J (17.2)* 4.1 4.2 (RL) 4010 L 83.5 41.9 (RL)

E thylbenzene 3020 99.8 4.2 (RL) 23.3 4.1 4.2 (RL) 8330 L 83.5 41.9 (RL)

meta

- /para

- Xylene 17200 200 8.3 (RL) 76.9 8.1 8.3 (RL) 18900 L 167 41.9 (RL)

ortho

- Xylene 6820 99.8 4.2 (RL) 33.9 4.1 4.2 (RL) 6850 L 83.5 41.9 (RL)

cis

- 1,2

- Dichloroethene 64.1 4.9 4.2 (RL) U 4.1 4.2 (RL) 330 L 83.5 41.9 (RL)

Benzene 8320 99.8 4.2 (RL) 4.2 4.1 4.2 (RL) 2160 L 83.5 41.9 (RL)

Tolu ene 9220 99.8 4.2 (RL) 9.1 4.1 4.2 (RL) 8400 L 83.5 41.9 (RL)

Tetrachloroethene 252 99.8 4.2 (RL) 8.3 4.1 4.2 (RL) 60.3 J (6.03)* 4.1 41.9 (RL)

S tyrene 3900 99.8 4.2 (RL) 4.7 4.1 4.2 (RL) 1590 L 83.5 41.9 (RL) Isopropylbenzene 3240 99.8 4.2 (RL) 13.1 4.1 4.2 (RL) 1000 L 83.5 41.9 (RL)

1,4

- Dichlorobenzene U 4.9 4.2 (RL) U 4.1 4.2 (RL) 165 L 83.5 41.9 (RL)

1,2

- Dichlorobenzene 152 99.8 4.2 (RL) 12.4 4.1 4.2 (RL) 1640 L 83.5 41.9 (RL)

Key:

μ g/kg = Concentrations in micrograms per kilograms mg/kg = Concentrations in milligrams per kilogram

RL

- Reporting Limit U

- Undetected

WT

- Above the Water Table PD

- Highest PID Reading

J

- The identification of the analyte is acceptable; The reported value is an estimate (Ref. 4, p. 865). The reported values for carbazole in samples SBA

- 002

- PD, SBA

- 002

- WT, SBA

- 004

- 24, SBA

- 004

- WT,

SBA

- 005

- PD, and SBA

- 005

- WT are biased unknown (Ref. 4, p. 181). The reported values for anthracene, fl uo ranthene, phenanthrene, cyclohexane, and methylcyclohexane in sample SBA

- 005

- PD are biased unknown (Ref. 31, pp. 181 & 186). The reported value for styrene in sample SBA

- 002

- WT is biased unknown (Ref. 31, p. 185). The reported value for tetrachloroethene in sample SBA

- 005

- WT is biased unknown (Ref. 31, p. 185). The presence of the substance is not in doubt.

L

- The identification of the analyte is acceptable; the reported value may be biased low. The actual value is expected to be greater than the reported value (Ref. 4, 865).

N

- There is a presumptive evidence that the analyte present; the analyte is reported as a tentative identification (Ref. 4, p. 8 65).

*

- The detected concentration was adjusted by us ing the guidance document " Using Qualified Data to Document and Observed Release and Observed Contamination " (Ref. 31, pp. 8, 12, 14, & 15). After adjusting the value for the qualified data to reflect the possible effect of the bias on the substance conce ntration , there is still a significant increase in contamination.

BOLD

- Concentration detected significantly above the background concentration or the reporting limits.

References
Chain of Custody: Ref. 4, p. 171 Ref. 4, p. 171 Ref. 4, p. 168
Laboratory Results: Ref. 4, pp. 591

- 599 Ref. 4, pp. 600

- 607 Ref. 4, pp. 482

- 491

Data: Ref. 4, p. 181, 450

- 457, 594 & 865; Ref. 31, pp. 8 and 14; Ref. 52 Ref. 4, p. 181, 186, 450

- 457, 600, 602

- 604 & 865; Ref. 31, pp. 8, 14 & 15; Ref. 52 Ref. 4, p. 181, 185, 458

- 465, 485

- 486 & 865; Ref. 31, pp. 8, 12 and 14; Ref. 52



### 40SO

- Source Characterization

Source No. : 3



### 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.

Release to ground water: The ground water pathway was not scored; therefore, ground water

containment was not evaluated.

Release via overland migration: T here is no evidence to indicate the former source was lined

since the Former Water Pit 1 consisted of a clay bottom (Ref. 24, p. 107 ). There is no evidence

that the Former Water Pit had any containment features when in op eration . The containment factor value for Source No. 3 is 10 (Ref. 1, Table 4-2).

Because containment for this source is greater than zero, the following substances associated with the source can migrate via the Surface Water Pathways (Ref. 1, Sec. 4.1.2 .1.2.1.1):

• A cenaphthene

• A cenaphthylene

• Anthracene

• Arsenic

• Barium

• Benzene

• B enzo(a)anthracene

• B enzo(a)pyrene

• Benzo(b)fluoranthene

• Benzo(g,h,i)perylene

• Benzo(k)fluoranthene

• Biphenyl, 1,1’-

• Bis (2

- ethylhexyl)phthalate

• Cadmium

• Carbazole

• Cobalt

• Copper

• Chrysene

• Cyclohexane

• Dibenz(a,h)anthracene

• Dibenzofuran

• Dichlorobenzene, 1,2- & 1,4

- • Dichloroethene, cis -1,2-

• Dimethylphenol, 2,4-

• Ethylbenzene

• Fluoranthene

• Fluorene

• Indeno(1,2,3- cd)pyrene

• Isopropylbenzene

• Lead

• Manganese

• Mercury

• Methylcyclohexane

• Methylnaphthalene, 2-

• Methylphenol, 2- & 3&/or4

-

• Naphthalene

• Nickel

• Phenanthrene

• P yrene

• Styrene

• Tetrachloroethene

• Toluene

• Xylene , -m, -p, -o

• Zi nc

41SO

- Source Characterization

Source No. : 3



### 2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1.1. Hazardous Constituent Quantity

– Tier A

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 CERCLA hazardous substances in the source and releases from the source is not known and cannot be estimated with reasonable confidence (Ref. 1, pp.

51590

- 51591, Section 2.4.2.1.1). Insufficient historical and current data (manifests, PRP] records, State records, permits, waste concentration data, etc.) are 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 3 with reasonable confidence.

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

2.4.2.1.2. Hazardous Wastestream Quantity

– Tier B

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 wastestreams and CERCLA pollutants

and contaminants for the source and releases from the source is not known and cannot be estimated with

reason able confidence (Ref. 1, p. 51591, 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 wastestreams 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 Q uantity for Source 3 with reasonable confidence.

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

2.4.2.1.3. Volume

– Tier C

Initially, the Former Water Pit 1 was excav ated for active use to an approximate depth of 18 feet bgs around 1968 (Ref. 24, pp. 8 & 107). Prior to closure activities in 1991, an estimated 2,542 cubic yards of sludge was present in Water Pit 1 (Ref. 24, p. 13). By 1994, Water Pit 1 was inactive a nd had undergone partial closure (Ref. 24, p. 13). In 1996 d imensions were approximate d at 160 f eet x 100 f eet
x 15 f eet and was estimated to contain an approximate 6,900 cubic yards of solidified sludge piled in the east end of the impoundment (Ref. 4, p. 30; Ref. 6 , p. 7 ).

However

, t he information available is not sufficient to evaluate an score Tier C because details of

closure activiti es on Water Pit 1 are incomplete, the dimensions of Water Pit 1 are approximate, there exists an inconsistency and conflict in the depth of the pit according to site evidence from 1968 and

1996

, the depth of excavation is unknown and may not have been uniform and unvarying througho ut the

source , and closure details mention solidified/stabilized sludge being piled and remaining in the southeast/east end of the impoundment (Ref. 6, p. 10; Ref. 24, p. 13) ; therefore, it is not possible to

42SO

- Source Characterization

Source No. : 3



### adequately determine a source volume (Tier C ) (Ref. 1, Sec. 2.4.2.1.3, p. 51591). As a result, the evaluation of source volume proceeds to the evaluation of Tier D, source area (Ref. 1, Sec. 2.4.2.1.4, p. 51591).

Volume of source ( yd 3 

### ): Not Scored

Refer ence(s): Ref. 1, Table 2

- 5, p. 51591 Volume Assigned Value: 0

2.4.2.1.4. Area

– Tier D

Historical maps and historical aerial photographs were used to estimate the size of the former Water Pit 1 ( Ref. 16, p. 2; Ref. 18, p. 2 ). Based on Figure 2, the scale of the figures in reference 16, page 2 and 18, page 2 , the former Water Pit 1 dimensions were 1 3 5 feet in length and approximate ly 85 feet in

width ; therefore, it occupied 11,475 square feet (ft 2 

### )

.

The hazardous waste quantity evaluation equatio n for a buried/backfilled surface impoundment is A/13 (Ref. 1, Table 2

- 5). The area source will be assigned an area hazardous waste quantity value of 882.69.

11,475 ft 2 

### /13 = 882.69

Area of source (ft 2 

### ): 1 1

, 475 .00 Area Assigned Value: 8 82

. 69

References : Fig. 2 ; Ref. 1, Sec. 2.4.2.1.4

2.4.2.1.5. Source Hazardous Waste Quantity Value

Source No. 3, Former Water Pit 1

.

Measures Surface Water, Ground Water and Air Pathways

Tier A NC

Tier B NC

Tier C NS

Tier D 882.69 Assigned Source Hazardous

Waste Quantity Value (Ref. 1, Sec. 2.4.2.1.5) 882.69

NS: Not Scored

NC: Not Calculated



### The highest value assigned to either Tier A, Tier B, Tier C, or Tier D is assigned as the Source No. 3 Hazardous Waste Quantity Value (Ref. 1, Section 2.4.2.1.5). The highe st value assigned is Tier D

.

Source No. 3 Hazardous Waste Quantity Value: 8 82

. 69

43SO

- Source Characterization

Source No. : 4



### 2.2.1 SOURCE IDENTIFICATION

– SOURCE 4

The following information corresponds to the fourth source identified for this documentation record.

Name of source : Former Land Treatment Unit (LTU)

Number of source : 4

Source Type: Land Treatment

Description and Location of Source : The Former Land T reatment U nit (LTU) was present west of the

surface impoundments located on the southeast portion of the property (Figure 2 ). The land farm was a solid waste management unit on which sludge from the surface impoundments were dewate red and treated (Ref. 24, p. 5). The LTU w as located approximately 200 feet northwest of W ater Pit 1 and had approximate dimensions of 100 feet wide and 200 feet long (Ref. 24, pp. 15 & 107 ). The LTU is currently covered with soil (Ref. 4, p. 32). S urface water runoff from the LTU forms small pu ddles in the grass that is north of the unit (Ref. 24, pp. 15 & 107 ). The ground surface slopes to the northeast,

and there is no surface water run -on or runoff control (Ref. 24, pp. 15 & 107 ). Runoff from the LTU area enters the drainage canal which dis charges into the Mermentau River and adjacent wetlands (Ref. 24, pp. 5 & 107 ).

In early 1992, SBA began using a LTU to treat solidified sludges that had been removed from W ater P it 1 during closure of the impoundment (Ref. 24, pp. 15 & 107 ). The LTU was used to bio treat stabilized sludge that was removed from Water Pit 1 during bioremediation activities from 1990-1991 (Ref. 6, p. 10; Ref 24, pp. 13 & 107). The sludges in W ater Pit 1 were solidified with fly ash and lime (Ref. 24, pp.

15 & 10 7 ). Approximately one third of W ater P it 1 sludges were placed directly on the ground surface of the LTU (Ref. 24, p. 15). The solidified material on the LTU was periodically disked to enhance bio

treatment until approximately 1993 (Ref. 6, p.45). The LTU had dimensions of approximately 190 f ee t
x 93 f ee t x 3 f ee t and was estimated to contain approximately 2,000 cubic yards of solidified sludge (Ref. 6, p. 8). As of October 26, 1994, n o closure or post closure care measures have been enacted for

the LTU (Ref. 24, p. 15). Documentation has not been obtained to indicate that closure or post- closure care measures have been enacted at the LTU from October 26, 1994 to the present.

Soil borings were advanced using direct push technology at two (2 ) locations in the former LTU area (Ref. 4, pp. 57, 906 & 908; Figure 3). The borings were advanced to a maximum depth of 16 feet bgs using the procedures in the EPA Environmental Response Team (ERT) Standard Operating Procedure (SOP) 2050, modified for the actual unit used by the driller (Ref. 4, pp. 20 & 934-946). Grab soil samples were collected from each boring, from intervals of visual contamination or where PID readings

for VOCs above background were detected (Ref. 4, pp. 20, 874-875, 893, 934-946 ).

Location SBA-007 was sampled at the southwest corner of the former LTU, and Location SBA-008 was sampled in the approximate center of the former LTU (Figure 3 ). Three (3 ) soil samples were collected

from the two (2) boring locations in the area of the F ormer Land Treatment U nit (Ref. 4, p. 32 & 908; Figure 3 ):

• Sample SBA -007WT (8-10 f ee t bgs)

– collected above water table; chemical odor

44SO

- Source Characterization

Source No. : 4



### • Sample SBA

- 008

- 24 (2

- 4 f ee t bgs)

– no stains, no odor

• Sample SBA

- 008WT (10

- 12 f ee t bgs)

– collected a bove water table; chemical odor

Soil samples was shipped to the U.S. EPA Laboratory in Houston for analysis

, data review and data

validation for Target Compound List (TCL) Volatile Organic Analysis (VOAs) by EPA method CLP

SOW SOM01.2 (method used

- CLP OLM04.2

– GC/MS ) , TCL Semi

- Volatile Organic Analysis (SVOAs) by EPA method CLP SOW SOM01.2 (method used

- CLP OLM04.2

– GC/MS ) , TCL Pesticide/PCB by EPA method CLP SOW SOM01.2 (method used

– CLP OLM04.2

– GC/ECD ) , TAL Cyanides by EPA method CLP SOW ILM05.4 (method used 335.4

– Colorimetric ) , and TAL Total Metals + Mercury by EPA method CLP SOW ILM05.4 (methods used

- CLP ILM05.3

– ICP , CLP

ILM05.3

– ICP/MS, CLP ILM05.3

– CVAAS) (Ref. 4, p p. 20

, 47, 316

- 324, & 333

- 343 ).

Th e soil sample results from this source area were comp ared to the concentrations in the corresponding

foot interval s from the background soil sample (Table s 3 and 6). The hazardous substances associated

with the former land treatment unit are poly cyclic aromatic hydrocarbons (PAHs) , volatile organic compounds (VOCs) and metals (Table 6 )

.

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

E levated levels of PAHs were found to includ e : acenaphthene, acenaphthylene, anthracene, benzo(a)anthracene, benzo(a)pyrene, b enzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene,
1,1’

- biphenyl, chrysene

, dibenzofuran, fluoranthene, fluorene, indeno(1,2,3

- cd)pyrene, 2

- methylnaphthalene, na phthalene, phenanthrene, phenol and pyrene in concentrations greater than

compara ble backgrou nd soils at these depths ( Ref. 4, p. 32; Table 6 )

. While this increase in concentration is not required to associate the substances with the source, it does demonstrate the level in the samples are significantly above background.

In addition, numerous VOCs such as cyclohexane, m ethylcyclohexane , e thylbenzene , x ylene , cis

- 1,2

- d ichloroethene , benzene, toluene and vinyl chloride were detected. Metals concentrations of

manganese , nickel, beryllium, cadmium, and arsenic were also detec ted (Table 6).

45SO

- Source Characterization

Source No. : 4



### Table 6

– Source 4

- L and Treatment Unit (LTU) Samples

EPA/START Sample No.: SBA

- 007

- WT SBA

- 008

- WT EPA Laboratory Sample No.: 1308018

- 06 1308018

- 08 Depth of Sample: 8 to 10 ft interval 10 to 12 ft interval

% Solids: 76.78% 76.57%

Units: Result RL 3x Bkgd. or > Bkgd.

RL Result RL 3x Bkgd. or > Bkgd. RL

Analyte: SVOCs μg/kg μg/kg μg/g μg/kg μg/kg μg/g Acenaphthene 26300 643 236 (RL) 15300 1100 240 (RL) Benzo (b) fluoranthene 7740 1610 590 (RL) 7240 2760 599 (RL) Benzo (g,h,i) perylene 2890 1610 590 (RL) 5210 2760 599 (RL) Benzo (k) fluoranthene 6130 1610 590 (RL) 7640 2760 599 (RL)
1,1'

- Biphenyl 6760 1610 590 (RL) 5640 2760 599 (RL) Acenaphthylene 2410 643 236 (RL) U 1100 240 (RL)

Carbazole 12600 J (1260)* 1610 590 (RL) 15000 J (1500)* 2760 599 (RL) Chrysene 13700 1610 590 (RL) 14400 2760 599 (RL)

Dibenzofuran 28300 1610 590 (RL) 21400 2760 599 (RL)

Anthracene 21700 643 795 (3x) 17800 1100 240 (RL)

Fluoranthene 48700 12900 236 (RL) 51600 1100 240 (RL)

Fluorene 35700 12900 236 (RL) 24500 1100 240 (RL) Indeno (1,2,3

- cd) pyrene 3560 1610 590 (RL) 5230 2760 599 (RL)

2

- Methylnaphthalene 22400 643 236 (RL) 14100 1100 240 (RL) Naphthalene 85800 12900 236 (RL) 54300 1100 240 (RL)

Phenanthrene 131000 12900 236 (RL) 113000 11000 240 (RL)

Phenol 2640 1610 590 (RL) U 2760 599 (RL) Pyrene 48100 12900 236 (RL) 42500 1100 240 (RL) Benzo (a) anthracene 13900 1610 590 (RL) 13000 2760 599 (RL) Benzo (a) pyrene 8110 1610 590 (RL) 9540 2760 599 (RL)

Analyte: Total Metals mg/kg mg/kg mg/g mg/kg mg/kg mg/g
Manganese 680 0.6 117 (3x) 501 0.6 166.2 (3x)

Nickel 25.2 2.3 19.8 (3x) 20.8 2.3 32.1 (3x) Beryllium 1.0 0.6 0.6 (RL) 0.9 0.6 1.8 (3x)

Cadmium 0.8 0.6 0.6 (RL) 0.9 0.6 0.6 (RL)

Arsenic 10.1 0.6 0.6 (RL) 10.3 0.6 6.9 (3x)

Analyte: VOCs μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg Cyclohexane 138 L 89.7 3.9 (RL) 75.7 J (7.57)* 4.3 3.9 (RL) Methylcyclohexane 168 L 89.7 3.9 (RL) 247 J (24.7) 4.3 3.9 (RL) Ethylbenzene 159 L 89.7 3.9 (RL) 152 99.9 3.9 (RL)

meta

- /para

- Xylene 1070 L 179 7.8 (RL) 474 200 7.8 (RL)

ortho

- Xylene 393 L 89.7 3.9 (RL) 321 J (3.21)* 4.3 3.9 (RL)

cis

- 1,2

- Dichloroethene 252 L 89.7 3.9 (RL) 52.0 J (5.20)* 4.8 3.9 (RL)

Benzene 218 L 89.7 3.9 (RL) 61.1 4.3 3.9 (RL)

Toluene 367 L 89.7 3.9 (RL) 222 J (22.2)* 4.3 3.9 (RL) Vinyl chloride UJ 89.7 3.9 (RL) 6.4 J (0.64)* 4.8 3.9 (RL)
Key:

μ g/kg = Concentrations in micrograms per kilograms Bkgd.

- Background mg/kg = Concentrations in milligrams per kilograms RL

- Reporting Limit

U

- Undetected WT

- Above the Water Table

BOLD

- Concentration detected significantly above background concentration or above background reporting limit

J

- The identification of the analyte is acceptable; the reported value is an estimate (Ref. 4, p. 865). The reported values for carbazole in samples SBA

- 007

- WT and SBA

- 008

- WT are biased unknown (Ref. 31, p. 181). The reported values for cyclohexane, met hylcyclohex a ne, o

- xylene, cis

- 1,2

- Dichloroethene, and toluene are biased unknown (Ref. 4, pp. 185 and 187). The presence of the substances is not in doubt.

L

- The identification of the analyte is acceptable; the reported value may be biased low. The actu al value is expected to be greater than the reported value (Ref. 4, p. 865).

*

- The detected concentration was adjusted by using the guidance document " Using Qualified Data to Document an Observed Release and Observed

Contamination" (Ref. 31, pp. 5

- 14). After adjusting the reported value for the qualified data to reflect the possible effect of the bias on the substance

concentration

, there is still a significant increase in contamination.

References Chain of Custody: Ref. 4, p. 162 Ref. 4, p. 162 Laboratory Results: Ref. 4, pp. 316

- 324 Ref. 4, pp. 333

- 343

Data: Ref. 4, pp. 181, 316

- 324 & 865; Ref. 31, pp. 5

- 14; Ref.

52 Ref. 4, pp. 185 & 187, 333

- 343 & 865; Ref. 31, pp. 5

- 14; Ref.52



### 46SO

- Source Characterization

Source No. : 4



### 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.

Release to ground water: The ground water pathway was not scored, therefore, ground water

containment was not evaluated.

Release via overland migration : T here is was no functioning or maintained run

- on or runoff management system (Ref. 24, p. 15). S urface water runoff from the LTU forms small puddles in the grass north of the unit (Ref. 24, p. 15). Runoff water flows into a drainage ditch that empties

int o the Mermentau River (Ref. 24, p. 107). The containment factor value for Source No. 4 is 10 (Ref. 1, Table 4

- 2).

Because containment for this source is greater than zero, the following substances associated with the source can migrate via the Surface Wa ter Pathways (Ref. 1, Sec. 4.1.2.1.2.1.1):

• A cenaphthene

• A cenaphthylene

• A nthracene

• Arsenic

• Benzene

• B enzo(a)anthracene

• B enzo(a)pyrene

• B enzo(b)fluoranthene

• B enzo(g,h,i)perylene

• B enzo(k)fluoranthene

• Beryllium

• Biphenyl

, 1,1'

-

• Cadmium

• C hrysene

• Cyclohexane

• D ibenzofuran • Di chloroethene, cis

- 1,2

-

• Ethylbenzene

• F luoranthene

• F luorene

• I ndeno(1,2,3

- cd)pyrene

• Manganese

• Methylcyclohexane

• Methylnaphthalene

, 2

-

• N aphthalene

• Nickel

• P henanthrene

• P henol

• P yrene

• Toluene

• Vinyl Chloride

• Xylene

, - m,

- p,

- o

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1.1. Hazardous Constituent Quantity

– Tier A

The total Hazardous Constituent Quantity for Source 4 could not be adequately determined according to the HRS requirements; that is, the total mass of all CERCLA hazardous substances in the source and releases from the source is not known and cannot be estimated with reasonable confidence (Ref. 1, pp.

47SO

- Source Characterization

Source No. : 4



### 51590

- 51591, Section 2.4.2.1.1). Insufficient historical and current data (manifests, PRP records, State records, permits, waste concentration data, etc.) are available to adequately calculate the total or partial

mass of all CERCLA hazardous substances in the s ource and the associated releases from the source. Therefore, there is insufficient information to calculate a total or partial Hazardous Constituent Quantity

estimate for Source 4 with reasonable confidence.

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

2.4.2.1.2. Hazardous Wastestream Quantity

– Tier B

The total Hazardous Wastestream Quantity for Source 4 could not be adequately determined according to the HRS requir ements; that is, the total mass of all hazardous wastestreams and CERCLA pollutants

and contaminants in the source and releases from the source is not known and cannot be estimated with reasonable confidence (Ref. 1, pp . 51590

- 51591, Section 2.4.2.1.2 ). In sufficient historical and current data (manifests, PRP records, State records, permits, waste concentration data, etc.) are available to adequately calculate the total or partial mass of all CERCLA hazardous substances in the source and the

associated rele ases from the source. Therefore, there is insufficient information to calculate a total or partial Hazardous Constituent Quantity estimate for Source 4 with reasonable confidence.

Hazardous Wastestream Quantity Value (S): Not Calculated

Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.3. Volume

– Tier C

Volume was not calculated by reason of Source No. 4 bei ng a land treatment source type and the depth

of contamination in the soil is unknown ; therefore, it is not possible to adequately determine a source volume (Tier C) in cubic yards (yd 3 

### ) (Ref. 1, Sec. 2.4.2.1.3, p. 51591). As a result, the evaluat ion of

source volume proceeds to the evaluation of Tier D, source area (Ref. 1, Sec. 2.4.2.1.4 , p. 51591).

Volume of S ource (yd 3 

### ): Not C alculated Volume Assigned Value: 0

2.4.2.1.4. Area

– Tier D

The LTU was located approximately 200 feet northwest of water pit 1, and had approximate dimensions of 100 feet wide and 200 feet long when put into u se (Ref. 24, pp. 15 & 107). In 1996 it was noted that the LTU had approximate surface dimensions of 190 f ee t x 93 f ee t (Ref. 6, p. 8). The LTU is currently

covered with soil and n o closure or post closure care measures have been enacted for the LTU ( Ref. 4, p.
32; Ref. 24, p. 15).

Using the most conservative estimate for the source area of the former LTU of 190 feet x 93, it occupied approximately 1 7,670 square feet (ft 2 

### ) (Ref. 6, p. 8)

. The hazardous waste quantity evaluation equation

for a land tr eatment unit is A/270 (Ref. 1, Table 2

- 5). The area source will be assigned an area hazardous waste quantity value of 65.44.

1 7 ,670 ft 2 

### /270 = 65.44

48SO

- Source Characterization

Source No. : 4



### Area of s ource (ft 2 

### ): 17, 670 .00 Area Assigned Value: 65.44 References: Fig. 2; Ref. 1, Sec. 2.4.2.1.4

2.4.2.1.5. Source Hazardous Waste Quantity Value

Source No. 4

, Former Land Treatment Unit (LTU)

.

Measures Surface Water, Ground Water and Air Pathways

Tier A NC

Tier B NC

Tier C NC

Tier D 65.44 Assigned Source Hazardous Waste Quantity Value (Ref. 1, Sec. 2.4.2.1.5) 65.44

NC: Not Calculated



### The highest value assigned to either Tier A, Tier B, Tier C, or Tier D is assigned as the Source No. 4 Hazardous Waste Quantity Value (Ref. 1, Section 2.4.2.1.5). The highest value assigned is Tier D.

Source No. 4 Hazardous Waste Quantity Value: 65.44

49SO

- Source Characterization

Source No.: 5



### 2.2.1 SOURCE IDENTIFICATION

– SOURCE 5

The following information corresponds to the fifth source identified for this documentation record.

Name of source : Dry Dock

Number of source: 5

Source Type: Surface Impoundment (Not Buried/Backfilled)

Description and Location of Source : The Dry Dock is located on the eastern edge of the SBA property adjacent to the Mermen tau River (Ref. 54, p. 3; Figure 2 ). The D ry D ock was commonly referred to as the graving dock (Ref. 54, p. 3). The graving dock was used for the building of new offshore and inland tank barges, and the repair and or conversion of tank barges and tug boats (Ref. 55, p. 1). The graving dock was a basin that was flooded by two 26 inch lines with river water , once a barge was in the dry dock the water was pumped out with two 26 inch pumps back to the river (Ref. 53, p. 1). Thus

, each time water from the dry dock was discharged back to the river any w aste that had settled and was not removed from the basin migrated from the source (Ref. 53, p. 1). The D ry D ock has dimensions of approximately 500 f ee t x 250 f ee t (Ref. 4, pp. 17 & 33 ). Currently, t he D ry D ock contain s water (Ref. 4, pp.33 & 114-115 ).

Sediment samples were collected by the Superfund Technical Assessment and Response Team ( START )

contractor , during a SI conducted in August 2013, using stainless steel spoons or a benthic dredge and

transferred dir ectly to the sample containers (Ref. 4, pp. 20-21 ).

During the SI, the background sediment sample, SBA -028SD, was collected off a private dock on the Mermentau River north of the facility, which is approximately 275 feet northeast of the SBA facility entrance (Ref. 4, pp. 27, 109 & 1011; Figure 3). The SI off- site background sediment sample was collected from similar medium as the characterization samples (i.e., sediment) (Ref. 4, pp. 20- 21 & 1009-1011). The SI off- site background sediment sample collected, Location SBA -028D, was grayish in color, a silty-clay, with no odor, and collected at 0 to 3 inches below water surface using a benthic dredge (Ref. 4, p. 1011). The Soil Survey for Jefferson Davis Parish, Louisiana was reviewed along

with observations made during the ESI

, to determine the similarity of sediment types within the area of concern (Ref. 8, pp. 25- 26 ; Ref. 40, pp. 1-2).

Two (2 ) sediment samples were collected at two separate locations within the D ry D ock (Ref. 4, p p. 34

, 110, 114-115, 906 & 1009-1010 ). Location SBA-026 sediment sample was collected from the

northwest corner of the D ry Dock slip, and Location SBA- 027 sediment sample was collected from the south side of the loading dock (Figure 3; Ref. 4, p. 34). The following samples were collected:

• Sample SBA -026SD – brownish grey clayey silt ; collected at 0 to 3 inches below water surface using a spoon and mixing bowl (Ref. 4, pp. 114 & 1009).

• Sample SBA -027SD – dark grey, silty sediment, with hydrocarbon sheen/odor ; collected at 0 to

3 in ches below water surface (10 to 15 feet in depth to bottom) using a benthic dredge (Ref. 4, pp. 115 & 1010).

50SO

- Source Characterization

Source No.: 5



### Sediment samples SBA

- 02 6SD, SBA

- 02 7 SD and SBA

- 028SD were sent to the U.S. EPA Laboratory in Houston for analysis

, data review and data validation for Target Compound List (TCL) Volatile Organic Analysis (VOAs) by EPA method CLP SOW SOM01.2 (method used

- CLP OLM04.2

– GC/MS ) , TCL

Semi

- Volatile Organic Analysis (SVOAs) by EPA method CLP SOW SOM01.2 (method used

- CLP

OLM04.2

– GC/MS ) , TCL Pesticide/PCB by EPA method CLP SOW SOM01.2 (method used

– CLP

OLM04.2

– GC/ECD ) , TAL Cyanides by EPA method CLP SOW ILM05.4 (method used 335.4

– Colorimetric ) , and TAL Total Metals + Mercury by EPA method CLP SOW ILM05.4 (methods used

- CLP ILM05.3

– ICP , CLP ILM05.3

– ICP/MS, CLP ILM05.3

– CVAAS) (Ref. 4, pp. 21

- 23, 47, 180,

244

- 251 & 389

- 404 ).

The sediment sample results from the source area were compared to the concentrations in the in the background sediment sample (Table s 7 and 8 ). Analysis of the s ediments from the D ry D ock detected

numerous PAHs, select metals and the chlorinated PCB s
, Aroclor

- 1254 (Ref. 4, pp. 34 & 389

- 404;

Table 7

- 8).

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

Analysis of the sediments from within the Dry Dock detected various PAHs such as: acenaphthylene, anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene

, b enzo (k) fluoranthene

. b enzo(g,h,i)perylene

, c arbazole

, chrysene

, dibenzofuran, fluoranthene, fluorene, i ndeno(1,2,3

- cd)p yrene
, 2

- methylnaphthalene, n aphthalene , phenanthrene and pyrene above concentration s in background sediment levels (Table s 7

- 8 ). While the increase in concentration is not required to associate the substances with the source, it does demonstrate the level in the sediment samples are significantly above background. The constituents detected in the dry dock sediment samples are the same or similar

to those detected in the waste sample collected from the Partially Buried Barge ( Source 1 ) used in the barge cleaning p rocess ( Ref. 4, p. 34 & 389

- 404 ; Table 1)

.

Metals detected included mercury, z inc, and arsenic while no volatile organic compounds ( VOCs ) were detected in the samples (Ref. 4, p. 70 & 389

- 404 ; Table 8 ) . The chlorinated polychlorinated biphenyl (PCB), Aroclor

- 1254 was detected in sediment sample SBA

- 026SD ( Ref. 4, p p. 70 & 396; Table 4 ).

51SO

- Source Characterization

Source No.: 5



### T able 7 - Background Sediment Samples

EPA/START Sample No.: SBA

- 28SD EPA Laboratory Sample No.: 1308016

- 03

Matrix: Sediment Background

Unit: RL Result

% Solids 69.74 Analyte: SVOCs μg/Kg μg/Kg Acenaphthene 286 U Benzo (b) fluoranthene 715 U Benzo (g,h,i) perylene 715 U Benzo (k) fluoranthene 715 U Acenaphthylene 286 U

Carbazole 715 U Chrysene 715 U

Dibenzofuran 715 U Dibenz (a,h) anthracene 715 U

Anthracene 286 U

Fluoranthene 286 U

Fluorene 286 U Indeno (1,2,3

- cd) pyrene 715 U

2

- Methylnaphthalene 286 U Naphthalene 286 U

Phenanthrene 286 U Pyrene 286 U Benzo (a) anthracene 715 U Benzo (a) pyrene 715 U

Analyte: Total Metals mg/kg mg/kg

Barium 1.3 214

Chromium 1.3 8.1

Cobalt 2.5 6 Copper 2.5 6.1 Manganese 0.6 292 Mercury 0.07 U

Nickel 2.5 7.4

Vanadium 2.5 16.7

Zinc 2.5 21.2

Lead 0.6 11.7

Arsenic 0.6 U

Analyte: PCBs μg/Kg μg/Kg

Aroclor

- 1254 23.4 U
Key: μg/Kg

- Concentrations in micrograms per kilogram U

- Undetected mg/Kg

- Concentration in milligrams per kilogram SD

- Sediment

PCBs

- Polychlorinated biphenyls

RL

- Reporting Limit

References Chain of Custody: Ref. 4, p. 160 Laboratory Results: Ref. 4, pp. 244

- 251



### 52SO

- Source Characterization

Source No.: 5



### Table 8

– Source 5

- Dry Dock Samples

EPA/START Sample No.: SBA

- 26SD SBA

- 27SD EPA Laboratory Sample No.: 1308018

- 14 1308018

- 15 Location (Source 5): Dry Dock W Dry Dock S

% Solids: 45.52% 43.06%

Result RL 3x Bkgd. or > Bkgd. RL Result RL 3x Bkgd. or > Bkgd.

RL

Unit: μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg
Analyte: SVOCs
Benzo (b) fluoranthene 12800 J (1280)* 1090 715 (RL) 8030 J (803)* 1140 715 (RL) Benzo (g,h,i) perylene 8210 J (821)* 1090 715 (RL) 6660 J (666)* 1140 715 (RL) Benzo (k) fluoranthene 10100 J (1010)* 1090 715 (RL) 6290 J (629)* 1140 715 (RL) Acenaphthylene 1690 438 286 (RL) 1160 458 286 (RL)

Carbazole 3460 J (346.0)* 1090 715 (RL) 50400 J (5040.0)* 11400 715 (RL)

Chrysene 10100 1090 715 (RL) 9090 1140 715 (RL)

Dibenzofuran U 1090 715 (RL) 4270 1140 715 (RL) Dibenz (a,h) anthracene 1830 J (183)* 1090 715 (RL) 1320 J (132)* 1140 715 (RL)

Anthracene 11000 438 286 (RL) 137000 4580 286 (RL)

Fluoranthene 11600 438 286 (RL) 7280 4580 286 (RL)

Fluorene 937 438 286 (RL) 12000 458 286 (RL) Indeno (1,2,3

- cd) pyrene 7610 J (716)* 1090 715 (RL) 5630 J (563)* 1140 715 (RL)

2

- Methylnaphthalene U 438 286 (RL) 2710 458 286 (RL) Naphthalene 1270 438 286 (RL) 3180 458 286 (RL)

Phenanthrene 6260 438 286 (RL) 24200 4580 286 (RL) Pyrene 19000 438 286 (RL) 8210 458 286 (RL) Benzo (a) anthracene 8650 1090 715 (RL) 4030 1140 715 (RL) Benzo (a) pyrene 11000 J (1100)* 1090 715 (RL) 7480 J (748)* 1140 715 (RL)

Analyte: Total Metals mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg
Mercury 0.109 0.095 0.07 (RL) 0.203 0.084 0.07 (RL)

Zinc 73.8 3.7 63.6 (3x) 243 3.7 63.6 (3x)

Arsenic 5.2 0.9 0.6 (RL) 3.8 0.9 0.6 (RL)

Analyte: PCBs μg/kg μg/kg μg/Kg μg/kg μg/kg μg/kg

Aroclor

- 1254 39.6 J 39.3 23.4 (RL) U 154 23.4 (RL)
Key: μg/kg

- Concentrations in microgram per kilogram U

- Undetected mg/kg

- Concentrations in milligrams per kilogram SD

- Sediment

S

- South W

- West Bkgd.

- Background sample RL

- Reporting Limit

J

- The identification of the analyte is acceptable; The reported value is an estimate (Ref. 4, 865). The reported values for ben zo (b) fluoranthene, benzo (g,h,i) perylene, benzo (k) fluoranthene, carbazole, dibenz (a,h) anthracene, in deno (1,2,3

- cd) pyrene, and benzo (a) pyrene in samples SBA

- 026SD and SBA

- 027SD are biased unknown (Ref. 4, p. 181). The reported value for Arochlor

1254 in sample SBA

- 026SD is biased unknown (Ref. 4, p. 182). The presence of the substances is not in doub t. ( )*

- The detected concentration was adjusted by using the guidance document " Using Qualified Data to Document an Observed

Release and Observed Contamination " (Ref. 31, pp. 8, 14

- 16). After adjusting the reported value for the qualified dat a to reflect the possible effect of the bias on the substance concentration , there is still a significant increase in contamination.

Bold

- Concentration detected is significantly above the background concentration or greater than the background reporting limit.

References Chain of Custody: Ref. 4, p. 163 Ref. 4, p. 163 Laboratory Results: Ref. 4, pp. 389

- 396 Ref. 4, pp. 397

- 404

Data: Ref. 4, pp. 181

- 182, 244

- 251, 391

- 392, 396, & 865; Ref. 31, pp. 8, 14

- 16; Ref.52 Ref. 4, pp. 181

- 182, 244

- 251, 399

- 400, & 865; Ref. 31, pp. 8, 14

- 15; Ref. 52



### 53SO

- Source Characterization

Source No.: 5



### 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.

Release to ground water: The ground water pathway was not scored, therefore, ground water

containment was not evaluated.

Release via overland migration: T here is no eviden ce that the D ry D ock had a liner . T he D ry
D ock appears to be an earthen berm enclosure reinforced with metal sheeting and bound with a

76 f oo t gate along the Mermentau River ( Ref. 4, p .114; Ref. 7, p. 110 ; Ref. 54, p. 3 ).

C ontaminants we re detected down gradient of the D ry D ock in the Mermentau River, due to seepage around or underneath the 76 ft gate in place or when the gate was opened

. Also, Source

No. 5 is designated by the Flood Insurance Rate Map (FIRM) as flood zones AE, and considered a Special Flood Hazard Area (SFHA). The SFHA is an area that would be inundated by flooding having a one (1) percent chance of being equaled or exceeded base flood level in any given year (Ref. 26 , pp. 1

- 2 ). The containment factor value of 10 i s assigned to Source No. 5 (Ref. 1, Table

4

- 2 & Table 4

- 9).

Because containment for this source is greater than zero, the following substances associated with the source can migrate via the Surface Water Pathways (Ref. 1, Sec. 4.1.2.1.2.1.1):

• Acenaphthylene

• Anthracene

• Ar oc lor

- 1254

• Arsenic

• Benzo(a)anthracene

• Benzo(b)fluoranthene

• B enzo (k) fluoranthene

• Benzo(g,h,i)perylene

• Benzo(a)pyrene

• C arbazole

• Chrysene

• Copper • Dibenzofuran

• Fluoranthene

• Fluorene

• I ndeno (1,2,3

- cd) pyrene

• Manganese

• Mercury

• Methylnaphthalene, 2

-

• Naphthalene

• Phenanthrene

• Pyrene

• Zinc

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1.1. Hazardous Constituent Quantity

– Tier A

The total Hazardous Constituent Quantity for Source 5 could not be adequately determined according to the HRS requirements; that is, the total mass of all CERCLA hazardous substances in the source and

54SO

- Source Characterization

Source No.: 5



### releases from the source is not known and cannot be estimated with reasonable confidence (Ref. 1, pp.

51590

- 51591, Section 2.4.2.1.1). Insufficient historical and current data (manifests, PRP records, State records, permits, waste concentration data, etc.) are available to adequately calculate the total or partial

mass of all CERCLA hazardous substances in the s ource and the associated releases from the source. Therefore, there is insufficient information to calculate a total or partial Hazardous Constituent Quantity

estimate for Source 5 with reasonable confidence.

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

2.4.2.1.2. Hazardous Wastestream Quantity

– Tier B

The total Hazardous Wastestream Quantity for Source 5 could not be adequately determined according to the HRS requirements; that is, the total mass of all hazardous wastestreams and CERCLA pollutants

and contaminants for the source and releases from the source is not known and cannot be estimated with

reason able confidence (Ref. 1, p. 51591, 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 wastestreams 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

Wastestre am Quantity for Source 5 with reasonable confidence.

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

2.4.2.1.3. Volume

– Tier C

The information available is not suff icient to evaluate Tier C of the dry dock because the depth of contamination is not known throughout the source; therefore, it is not possible to adequately determine a source volume (Tier C) in cubic yards (yd 3 

### ) (Ref. 1, Sec. 2.4.2.1.3, p. 51591). For a more conservative

volume estimate, the volume source will be assigned an area hazardous waste quantity value of >0. The

value >0 reflects that the volume value is known to be greater than 0, but the exact area is unknown.

Volume of source ( yd 3 

### ): Not calculated Reference(s): Ref. 1, Table 2

- 5, p. 51591 Volume Assigned Value: 0

2.4.2.1.4. Area

– Tier D

Historical maps and historical aerial photographs were used to estimate the size of the dry dock (Ref. 4,

pp . 17 & 33 ). Based on aeri al photographs th e dry dock has approximate dimensions of 500 feet i n length and 250 feet in width; therefore, it occupied approximately 125,000 square feet (ft 2 

### ) (Ref. 4

, p p. 17 & 33; R ef. 18, p.3 )

.

The hazardous waste quantity evaluation equation for a surface impoundment is A/13 (Ref. 1, Table 2

- 5). The area source will be assigned an area hazardous waste quantity value of 9,615.38. 125,000 ft 2 

### / 13 = 9,615.38

55SO

- Source Characterization

Source No.: 5



### Area of source (ft 2 

### ): 125,000.00 References: Fig. 2; Ref. 1, Sec. 2.4.2.1.4 Area Assigned Value: 9 ,615.38

2.4.2.1.5. Source Hazardous Waste Quantity Value

Source No. 5, Dry Dock.

Measures Surface Water, Ground Water and Air Pathways

Tier A NC

Tier B NC

Tier C NC

Tier D 9, 615.38 Assigned Source Hazardous Waste Quantity Value (Ref. 1,

Sec. 2.4.2.1.5) 9, 615.38

NC: Not Calculated



### The highest value assigned to either Tier A, Tier B, Tier C, or Tier D is assigned as the Source No. 5 Hazardous Waste Quantity Value (Ref. 1, Section 2.4.2.1.5). The highest value assigned is Tier D.

Source No. 5 Hazardous Waste Quantity Value: 9,615.38

56SO

- Source Characterization

Source No.: 6



### 2.2.1 SOURCE IDENTIFICATION

– SOURCE 6

The following information corresponds to the sixth source identified for this documentation record.

Name of source : Former Water Pit 3

Number of source : 6

Source Type: Surface Impoundment ( Not Buried/Backfilled )

Description and Location of Source: Surface impoundment located in the southeast portion of the property, adjoining a designated wetland area (Figure 2). Former Water Pit 3 was originally excavated to an approximate depth of 6 feet bgs around 1968, and the soils below the unlined Water Pit 3 consisted of clay to an approximately depth of 20 to 25 feet bgs (Ref. 24, p. 14 ). Water pit 3 was a pproximately 150 feet long, 50 feet wide and 6 feet deep in 1996 (Ref. 24, p. 14). Water Pit 3 was used to treat and store wastewater and sludges generated during the barge cleaning activities, with Water Pit 3 receiving

wastewater from W ater Pit 2 (Ref. 24, pp. 8 & 12-14). Subsequently, abo veground oil/water separators and storage tanks replaced the functions of the surface impoundments (Ref. 4, p. 13 ).

In 1997, the inactive surface impoundment had approximately 600 cubic yards of sediment/sludge excavated and stacked alongside the surfac e impoundment (Ref. 6, p. 8). During storm events rainwater accumulates in the impoundment (Ref. 6, pp. 10). The impoundment formerly known as W ater Pit 3 is located on the southeast portion of the property, bordering a designated wetland area (Figure 2). The

dimensions were approximately 283 f ee t x 55 f ee t x 6 f ee t and contained water (Ref. 4, p. 30; Ref. 6, p.

8 ).

According to the December 2002 IM/RA agreed order 750,000 gallons of water was pumped from

F ormer W ater P it 3 (former water pit) to the drainage ditch that drains to the Mermentau River (Ref. 5, pp. 8, 20-21 & 24 ) . The emptied W ater P it 3 (former water pit) was then used to receive treated storm

water from the P artially Buried B arge (Ref. 5, pp. 8, 20 & 24 ). Approximately 100,000 gallons of

treated storm water was left in W ater P it 3 (former water pit) (Ref. 5, pp. 8 & 21 ). W ater P it 3 (former water pit) was later closed by using a hydraulic excavator to break a wide gap in the earthen berm separating it from the Mermentau River bottomland directly east of the water pit (Ref. 5, pp. 8, 21). Upon removal of the segment of the earthen berm, water from the Mermentau River flowed into the

F ormer W ater P it 3 (former water pit) , raising the level of the water in the pit to approximatel y four (4) feet deep (Ref. 5, pp. 8, 21 ). Thus, linking F ormer Water Pit 3 with the designated wetland area to the immediate west (Figure 2).

Two (2) wetland sediment grab sample s were collected from the F ormer W ater P it 3 area , which is now part of t he wetlands to the east (Figure 3). During the SI of August 2013 one (1 ) sediment sample , SBA

032D, was collected using a benthic dredge, and during the ESI of September 2014 one (1) wetland sediment sample , SBA

- ESA -10 was collected using a metal retrieval pole with a beaker attachment to a depth of 1-6 inches bgs (Ref. 4, pp. 117-118 & 1018; Ref. 7, p. 35-36 & 135-136). All grab samples were transferred directly into sample containers (Ref. 4, pp. 20-21; Ref. 7, pp. 36 ).

G rab wetland sediment sample s were collected from location s of visual contamination (Ref. 4, pp. 31 & 117-118; Ref. 7, pp. 36, 135-136 & 164).

57SO

- Source Characterization

Source No.: 6



### Wetland s ediment sample SBA -32 SD was collected from the southwest corner of Former W ater P it 3 that is presently part of the wetland area , and sediment sample SBA

- ESI

- 10 SD was collected from approximately the southwest corner of Former Wa ter P it 3 that is currently part of the wetland area (Ref. 4, pp. 57, 117-118 & 1018; Ref. 7, pp. 50 & 135-136 ). The following samples were collected :

• Sample SBA -032SD – oily matrix ; glades of oil; light gray; clayey; collected at 2 to 3 in ches below ground surface (Ref. 4, pp. 117-118 & 1018).

• Sample SBA

‐ ESI

‐ 10SD – noticeable hydrocarbon odor; contained a sizeable amount of organic

debris ; collected in the wetland near source 6 (Ref. 7, pp. 135-136, 164 & 976).

The wetland sediment sample results from Location SBA-032 were compared to the background

sediment levels established from a wetland sediment sample collected south of the former f acility operations, Location SBA-031 ( Figure 3). Location SBA-031, Sample SBA-031SD was collected southwest of the source areas and is considered the background sample for the wetlands ( Figure 3; Ref. 4, pp. 116 & 121-127).

The wetland sediment sample results from Location SBA- ESI -10 was compared to the higher of the four background sediment levels established from two wetland sediment samples collected north of the former facility operations ( Location SBA

- ESI -01 and SBA- ESI -02), and two wetland sediment samples collected downstream of the former facility operations (Location SBA- ESI -08 and SBA- ESI -09) (Figure 3; Ref. 7, pp. 97-98, 101-102, 126-127, 133 & 967-968 ).

Wetland s ediment sample s SBA -031SD and SBA -032 SD was sent to the U.S. EPA Lab ora tory in Houston for analysis, data review and data validation for Target Compound List (TCL) Volatile Organic Analysis (VOAs) by EPA method CLP SOW SOM01.2 (method used -CLP OLM04.2 – GC/MS ) , TCL

Semi

- Volatile Organic Analysis (SVOAs) by EPA method CLP SOW SOM01.2 (method used - CLP

OLM04.2 – GC/MS ), TCL Pesticide/PCB by EPA method CLP SOW SOM01.2 (method used – CLP

OLM04.2 – GC/ECD ), TAL Cyanides by EPA method CLP SOW ILM05.4 (method used 335.4 –

Colorimetric ) , and TAL Total Metals + Mercury by EPA method C LP SOW ILM05.4 (methods used -

CLP ILM05.3

– ICP , CLP ILM05.3 – ICP/MS, CLP ILM05.3 – CVAAS) (Ref. 4, pp. 21-23, 47, 632-

647 ).

Wetland sediment sample s SBA

- ESI -01, SBA- ESI -02 , SBA

- ESI -08, SBA- ESI -09 and SBA

- ESI

- 10SD

were shipped to the U.S. EPA Laboratory in Houston for analysis, data review and data validation for TCL SVOAs by EPA method CLP OLM04.2 – GC/MS (Ref. 7, pp. 22 & 632-647 ).

Analysis of the background wetland sediment sample, SBA -031SD did not detect any organic or volatile organic constituents. Metals such as mercury, copper, manganese, nickel, vanadium, zinc, barium, chromium, lead and arsenic were detected above the reporting limits (Ref. 4, pp. 43 & 632-639; Table 9).

I n wetland sediment sample SBA -032SD PAHs such as acenaphthene, acenaphthylene, anthracene

, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, chrysene, dibenzofuran, fluoranthene, fluorene, indeno(1,2,3- cd)pyrene, 2 -methylnaphthalene,

58SO

- Source Characterization

Source No.: 6



### naphthalene, p henanthrene, and pyrene were detected at greater than background levels (Ref. 4, pp. 70,

642

- 6 44 ; Table 9 ). In addition, metal concentrations were detected at greater than background level s for beryllium and cobalt ( Ref. 4, p p. 6 4 6

- 647; Table 9 ). W hile this increase in concentration is not required to associate the substances with the source, it does demonstrate the level in the source sample is significantly above background.

Analysis of the background wetland s ediment samples, SBA

- ESI

- 01, SBA

- ESI

- 02, SBA

- ESI

- 08 and

SBA

- ESI

- 09 did not detect any semi

- volatile organic constituents (Ref. 7, pp. 25 , 34, 192

- 197 & 201

- 206; Table 10).

PAHs were detected in wetland sediment sample SBA

- ESI

- 10SD. PAHs such as acenaphth ene, acenaphthylene, anthracene

, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, chrysene, dibenz(a,h)anthracene, dibenzofuran, fluoranthene, fluorene, indeno(1,2,3

- cd)pyrene, 2

- methylnaphthalene, napht halene, p henanthrene and

pyrene were detected at greater than background sediment levels ( Ref. 7, pp. 213

- 215; Table 10 ). While this increase in concentration is not required to associate the substances with the source, it does

demonstrate the level in the waste sample is significantly above background.

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

A nalysis of the sediments from Former Water Pit 3 detected numerous PAHs such as: acenaphthene, acenaphthylene, anthracene

, benzo(a)anthracene, benzo (a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, chrysene, dibenz(a,h)anthracene, dibenzofuran, fluoranthene, fluorene, indeno(1,2,3

- cd)pyrene, 2

- methylnaphthalene, naphthalene, p henanthrene, and

pyrene (Ref. 4, p p. 640

- 647 ; Ref. 7, p p. 213

- 215; Table s 9 and 10 )

. Metals such as beryllium and cobalt

were also detected (Ref. 4, pp. 646

- 647). These constituents are also detected in other sources on site including the Dry Dock and Partially Buried Barge (Sources 5 and 1 respec tively).

59SO

- Source Characterization

Source No.: 6



### Table 9

- Background and Source 6 ( Former Water Pit 3 ) Wetland Sample s From SI

EPA/START Sample No.: SBA

- 31SD SBA

- 32SD EPA Laboratory Sample No.: 1308020

- 26 1308020

- 27

Matrix: Background Sediment Wetland Sediment

% Solids: 53.54% 62.29%

Units: Result RL Result RL 3x Bkgd or > Bkgd RL
μg/kg μg/kg μg/kg μg/kg μg/kg
Analyte: SVOC Acenaphthene U 367 7520 311 367 (RL) Benzo (b) fluoranthene U 918 12700 3890 918 (RL) Benzo (g,h,i) perylene U 918 7620 3890 918 (RL) Benzo (k) fluoranthene U 918 6900 3890 918 (RL) Acenaphthylene U 367 1150 311 367 (RL) Butyl benzyl phthalate U 918 U 778 918

Carbazole U 918 2540 J (254.0)* 778 918 (RL) Chrysene U 918 12800 3890 918 (RL)

Dibenzofuran U 918 3340 778 918 (RL)

Dibenz (a,h) anthracene U 918 2070 J (207.0)* 778 918 (RL)

Anthracene U 367 21400 1560 367 (RL)

Fluoranthene U 367 20300 1560 367 (RL)

Fluorene U 367 10500 311 367 (RL) Indeno (1,2,3

- cd) pyrene U 918 8830 3890 918 (RL)

2

- Methylnaphthalene U 367 1880 311 367 (RL) Naphthalene U 367 786 311 367 (RL)

Phenanthrene U 367 26600 1560 367 (RL) Pyrene U 367 21800 1560 367 (RL) Benzo (a) anthracene U 918 8910 3890 918 (RL) Benzo (a) pyrene U 918 13800 3890 918 (RL)

Analyte: Total Metals mg/kg mg/kg mg/kg mg/kg mg/kg Beryllium U 0.7 0.7 0.7 0.7 (RL)

Cobalt U 2.8 6.0 2.8 2.8 (RL)
Key:

μ g/kg = Concentrations in micrograms per kilogram RL

- Reporting Limit mg/kg = Concentrations in milligrams per kilograms SD

- Sediment Bkgd

- Background U

- Undetected

J

- The identification of the analyte is acceptable; The reported value is an estimate (Ref. 4, p. 865). The reported values for carbazole and dibenz (a,h) anthracene in sample SBA

- 32SD are biased unknown (Ref. 4, pp. 181, 642

- 643).

*

- The detected concentration was adjusted by using the guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 31, pp. 8 and 14). After Adjusting the value for the qualified

data to reflect the possible effect of the bias on the substance concentration , t here is still a significant increase in

contamination.

BOLD

- concentration detected significantly above the background concentration or above the reporting limits.

References Chain of Custody: Ref. 4, p. 172 Ref. 4. p. 172 Laboratory Results: Ref. 4, pp. 632

- 639 Ref. 4. pp. 640

- 647

Data: Ref. 4, p. 181; 632

- 639 & 865; Ref. 31, pp. 8 & 14; Ref. 52 Ref. 4, p. 181; 642

- 643 & 865; Ref. 31, pp. 8 & 14; Ref. 52



### 60SO

- Source Characterization

Source No.: 6


### Table 10

- Background and Source 6 ( Former Water Pit 3 ) Sample s From ESI

EPA/START Sample No.: SBA

- ESI

- 01SD SBA

- ESI

- 02SD SBA

- ESI

- 08SD SBA

- ESI

- 09SD SBA

- ESI

- 10SD

EPA Laboratory Sample No.: 1409034

- 01SD 1409034

- 02SD 1409028

- 04SD 1409028

- 05SD 1409034

- 05SD Sampling Location: SBA

- ESI

- 01 SBA

- ESI

- 02 SBA

- ESI

- 08 SBA

- ESI

- 09 SBA

- ESI

- 10

Sample Description: Background Wetland Sediment along the main shipping channel Background Wetland Sediment along the original river channel Background Sediment along wetland boundary on right descending bank of river Background Sediment along wetland boundary on left descending bank

of river Wetland Sediment SE of Former

Water Pit 3

% Solids: 67.42% 41.91% 35.36% 60.85% 26.10%

Units: Result RL Result RL Result RL Result RL Result RL 3x Bkgd

or > Bkgd

RL

μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg

Analyte: SVOCs

2

- Methylnaphthalene 277 U 277 476 U 476 543 U 543 307 U 307 35,900 5,490 543 U Acenaphthene 277 U 277 476 U 476 543 U 543 307 U 307 250,000 5,490 543 U Acenaphthylene 277 U 277 476 U 476 543 U 543 307 U 307 46,400 5,490 543 U

Anthracene 277 U 277 476 U 476 543 U 543 307 U 307 1,040,000 54,900 543 U Benzo (a) anthracene 693 U 693 693 U 693 1360 U 1360 768 U 768 664,000 137,000 1360 U Benzo (a) pyrene 693 U 693 693 U 693 1360 U 1360 768 U 768 507,000 137,000 1360 U Benzo (b) fluoranthene 693 U 693 1190 U 1190 1360 U 1360 768 U 768 484,000 137,000 1360 U Benzo (g,h,i) perylene 693 U 693 1190 U 1190 1360 U 1360 768 U 768 150,000 137,000 1360 U Benzo (k) fluoranthene 693 U 693 1190 U 1190 1360 U 1360 768 U 768 495,000 137,000 1360 U

Carbazole 693 U 693 1190 U 1190 1360 U 1360 768 U 768 16100 J (1610)* 13,700 1360 U

Chrysene 693 U 693 1190 U 1190 1360 U 1360 768 U 768 822,000 137,000 1360 U Dibenz (a,h) anthracene 693 U 693 1190 U 1190 1360 U 1360 768 U 768 61,900 54,900 1360 U

Dibenzofuran 693 U 693 1190 U 1190 1360 U 1360 768 U 768 157,000 13,700 1360 U

Fluoranthene 277 U 277 476 U 476 543 U 543 307 U 307 1,540,000 54,900 543 U

Fluorene 277 U 277 476 U 476 543 U 543 307 U 307 510,000 54,900 543 U Indeno (1,2,3

- cd) pyrene 693 U 693 1190 U 1190 1360 U 1360 768 U 768 167,000 137,000 1360 U Naphthalene 277 U 277 476 U 476 543 U 543 307 U 307 9,140 5,490 543 U

Phenanthrene 277 U 277 476 U 476 543 U 543 307 U 307 1,590,000 54,900 543 U Pyrene 277 U 277 476 U 476 543 U 543 307 U 307 1,380,000 54,900 543 U
Key: μg/kg

- Concentrations in micrograms per kilogram RL

- Reporting Limit Bkgd

- Background U

- Undetected at Reporting Limit

J

- The identification of the analyte is acceptable; the reported value is an estimate (Ref. 7, p. 251). The reported value for c arbazole in sample SBA

- ESI

- 10SD is biased unknown (Ref. 7, p. 179).

*

- The detected concentration was adjusted by using the guidance " Using Qualified Data to Document an Observed Release and Observed Contamination " (Ref. 31, pp. 8 & 14). After adjusting the value for the qualified data to reflect possible bias , there is still a significant increase in contamination.

BOLD

- Concentration detected is significantly above the background concentration or the Reporting Limits.

References: Chain of Custody: Ref. 7, p. 170 Ref. 7, p. 170 Ref 7, p . 169 Ref. 7, p. 1 69 Ref. 7, p. 170 Laboratory Results: Ref. 7, pp. 201

- 203 Ref. 7, pp. 204

- 206 Ref. 7, pp. 192

- 194 Ref. 7, pp. 195

- 197 Ref. 7, pp. 213

- 215

Data: Ref. 7, pp. 201

- 203; Ref. 52 Ref. 7, pp. 204

- 206; Ref.

52 Ref. 7, pp. 192

- 194; Ref. 52 Ref. 7, pp. 195

- 197; Ref.

52 Ref. 7, pp. 179, 213, & 251; Ref. 31, pp. 8 & 14; Ref. 52



### 61SO

- Source Characterization

Source No.: 6



### 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.

Release to ground water: The ground water pathway was not scored, therefore, ground water

containment was not evaluated.

Release via overland migration : Up on removal of the segment of the earthen berm, water from

the Mermentau River flowed into the F ormer W ater P it 3, raising the level of the pit to approximately four (4) feet deep (Ref. 5, pp. 8, 20

- 21 & 24). Thus, making the former surface impoundment co mbined with the designated wetland area to the immediate west (Figure 2). In addition, there is no evidence to indicate the former source had an artificial line r since Water Pit

3 consisted of a local (native) clay bottom (Ref. 24, pp. 8 & 107). Also, So urce No. 6 is designated by the Flood Insurance Rate Map (FIRM) as flood zones AE, and considered a Special Flood Hazard Area (SFHA). The SFHA is an area that would be inundated by flooding having a one (1) percent chance of being equaled or exceeded base flood level in any given year (Ref. 26 , pp. 1

- 2 ). The containment factor value of 10 is assigned to Source No. 6 (Ref. 1, Table

4

- 2)

.

Because containment for this source is greater than zero, the following substances associated with the

source can migrate via the Surface Water Pathways (Ref. 1, Sec. 4.1.2.1.2.1.1):

• A cenaphthene

• A cenaphthylene

• Anthracene

• B enzo(a)anthracene

• B enzo(a)pyrene

• B enzo(b)fluoranthene

• B enzo(g,h,i)perylene

• B enzo(k)fluoranthene

• Beryllium

• C hrysene • Cobalt

• D ibenz(a,h )anthracene

• D ibenzofuran

• F luoranthene

• F luorene

• I ndeno(1,2,3

- cd)pyrene

• Methylnaphthalene

, 2

-

• Naphthalene

• P henanthrene

• P yrene

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1.1. Hazardous Constituent Quantity

– Tier A

The total Hazardous Constituent Quantity for Source 6 could not be adequately determined according to the HRS requirements; that is, the total mass of all CERCLA hazardous substances in the source and

releases from the source is not known and cannot be est imated with reasonable confidence (Ref. 1, pp.

62SO

- Source Characterization

Source No.: 6



### 51590

- 51591, Section 2.4.2.1.1). Insufficient historical and current data (manifests, PRP records, State records, permits, waste concentration data, etc.) are available to adequately calculate the total or par tial

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 6 with reasonable confid ence.

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

2.4.2.1.2. Hazardous Wastestream Quantity

– Tier B

The total Hazardous Wastestream Quantity for Source 6 could not be adequately determined according to the HRS requirements; that is, the total mass of all hazardous wastestreams and CERCLA pollutants

and contaminants for the source and releases from the source is not known and cannot be estimated with

reasonable confid ence (Ref. 1, p. 51591, 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 haz ardous wastestreams 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 for Source 6 with reasonable confidence.

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

2.4.2.1.3. Volume

– Tier C

The volume of Source 6 can be adequately determined based on a one time capacity volume, and not the actual contents of the source (Ref 1, Sec. 2.4.2.1.3).

According to the December 2002 IM/RA agreed order the F ormer W ater P it 3 was closed by using a hydraulic excavator to b reak a wide gap in the earthen berm separating it from the Mermentau River bottomland directly east of the water pit (Ref. 5, p. 21 ) . Upon removal of the segment of the earthen berm, water from the Mermentau River flowed into W ater P it 3 , raising the leve l of the water in the pit

to ap proximately four (4) feet deep (Ref. 5, pp. 8, 21). Thus, linking the F ormer Water Pit 3 with the designated wetland area to the immediate west (Figure 2). In addition, there is no evidence to indicate

Former Water Pit 3 (former water pit) was lined with an artificial liner, since the impoundment consisted

of a local (native) clay bottom (Ref. 24, pp. 8 & 107).

Based on the IM/RA information available the one time volume capacity volume can be determined for

F ormer W a ter P it 3 (s urface impoundment ). The dimensions for F ormer W ater P it 3 are approximately

283 fee t x 55 feet x 6 feet; therefore, it occupied approximately 93,390 cubic feet ( ft 3 

### ) ( Ref. 4, pp. 16 &

30 ; Ref. 6, p. 8 ; Figure 2 ).

The most common value used for c ubic yards to cubic feet volume conversion is 1 yd 3 

### = 27 ft 3



### . The

estimated source volume of F ormer W ater P it 3 is 3,458.89 yd 3



### .

93,390 ft 3 

### / 27 ft 3 

### per 1 yd 3 

### = 3,458.89 yd 3



### 63SO

- Source Characterization

Source No.: 6



### The hazardous waste quantity evaluation equation for a surface impoundm ent is V/2.5 (Ref. 1, Table 2- 5). The volume source will be assigned a volume hazardous waste quantity value of 1,383.56.

3,458.89 yd 3 

### / 2.5 = 1,383.56

Volume of Source (yd 3 

### ): 3,458.89 Reference(s): Ref. 1, Table 2 -5, p. 51591 Volume Assigned Value: 1,383.56

2.4.2.1.4. Area – Tier D

Area was not calculated by reason of Source 6 yielding a volume that can be assigned a value. Therefore, area is assigned a value of 0 and scoring will be based on the evaluation of volume according to the HRS (Ref. 1, Sec. 2.4.2.1.3).



### Area of source (ft 2 

### ): Not calculated Area Assigned Value: 0

2.4.2.1.5. Source Hazardous Waste Quantity Value

Source No. 6, Water Pit 3.

Measures Surface Water, Ground Water and Air Pathways

Tier A NC

Tier B NC

Tier C 1,383.56

Tier D NC Assigned Source Hazardous Waste Quantity Value (Ref. 1, Sec. 2.4.2.1.5) 1,383.56

NC: Not Calculated 

### The highest value assigned to either Tier A, Tier B, Tier C, or Tier D is assigned as the Source No. 6 Hazardous Waste Quantity Value (Ref. 1, Section 2.4.2.1.5). The highest value assigned is Tier C.

Source No. 6 Hazardous Waste Quantity Value: 1,383.56 2.4.2.2.5 Calculation of Hazardous Waste Quantity Factor Value

64SO

- Summary

Other Possible Sources



### SITE SUMMARY OF SOURCE DESCRIPTIONS

Containment

Source

No. Source Hazardous Waste Quantity

Value

Ground

Water Surface

Water Air

Surface Water Migration Pathway Soil Exposure Pathway Gas Air

Particulate

1 1,8 27

. 79 NS NS 10 NS NS

3 8 82

. 69 NS NS 10 NS NS

4 65

. 44 NS NS 10 NS NS

5 9,615

. 38 NS NS 10 NS NS

6 1,383.56 NS NS 10 NS NS

Total 13,744.86

NS: Not Scored

September 2016 

### Other Possible Sources

Other possible sources at SBA include a buried barge/ associated alkyne storage tank pump house , a former oil pit, and stained soils (Figure 2). The buried barge and associated alkyne storage tank pump

house are located on the eastern portion of the property, south of the barge slip and west of the partially buried barge (Figure 2). The tank and equipment were used in the barge cleaning process, but not part of the RCRA facility investigation study performed in 1996. Contents of the alkyne storage pump house have been observed leaking into the wetlands loca ted to the southwest and are evident by the stained

soils west of the buried barge (Ref. 4, pp. 34- 35 & 135-140; Ref. 7, pp. 27, 40-41 & 94-95).

During the 2013 SI one sludge sample Location SBA-038, was collected from southwest corner of the

tank area (Ref .4, pp. 34, 57, 135-139 & 1024 ). Again in 2014, during the ESI another sample was collected from the stained soil observed near the alkyne storage tank building, Location SBA- ESI -14 (Ref. 7, pp. 27, 50, 94-95 & 980 ). H azardous substances related to the buried barge and associated alkyne storage tank pump house are numerous PAHs and the chlorinated PCB, Aroclor-1254 (Ref. 4, p. 35, 70-71 & 218-225). Hazardous substances related to the stained soils originating from the buried barge and alkyne storage tank pump house are Chlorinated Dibenzo-p-Dioxins (CDDs) and Chlorinated Dibenzofurans (CDFs) (Ref. 7, pp. 27, 40-41, 57 & 279-282). In October 2014, two samples were collected to assess the contents of the buried barge, the threat posed to the nearby wetland and the Mermentau River, and the necessary steps to mitigate that threat (Ref. 38, p. 2). Samples collected from the barge indicated results of elev ated concentrations of Polycyclic Aromatic Hydrocarbons (PAH) and Total Petroleum Hydrocarbons (TPH) in the form of diesel (DRO) and motor oil range organics (ORO). Sample results confirmed that the removal should be funded as an Oil Pollution Act ( OPA )

r emoval action (Ref. 38, p. 2).

In May and June of 2015 an OP A removal was performed on the buried barged and associated alkyne storage tank pump house to remove the oily water waste that had been observed leaking (Ref. 38, p. 2 ).

65SO

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Other Possible Sources



### In June 2015, a composite sample of sludge was taken from three hatch openings on the north side of the buried barge, and a grab sample was taken from the diesel tank inside the barge for laboratory analysis

an d characterization of contents. Removal and offsite disposal of slu dge contents that remained in the buried barge was postponed until sample characterization was complete (Ref. 38, p. 3). CERCLA wastes were identified in the analytical results of the sludge taken from the barge and diesel tank inside the barge (Ref. 38, pp. 3 & 5; Ref. 39, pp. 6-17 ). Thus, additional CERCLA wastes identified at the site will be addressed using CERCLA funding and authority (Ref. 38, p. 5).

The former oil pit is a former surface impoundment located in the southeast portion of the property, northwest of a designated wetland area (Figure 2; Ref. 16, p. 2). The former oil pit was originally excavated to approximately 18 feet deep circa 1968, and the soils below the unlined impoundment consisted of clay to a depth of 20 – 25 feet below ground surface (bgs) (Ref. 24, p. 8). Waste from the barge cleaning services at SBA that were stored in the former oil pit mainly consisted of hydrocarbons

resid ues (Ref. 6, p. 10). A partially buried barge tank used for sludge storage (Source 1) was adjoining and positioned on the lower west side of the Oil Pit (Ref. 16, p. 2; Ref. 24, p. 12). The sludge storage tank was a converted barge that was sealed, overt urned, and tested for leaks before entering service (Ref. 24, p. 14). The tank was used to store sludge from the other tanks and impoundments, and had observed leaks on the west side of the barge (Ref. 24, p. 14). Subsequently, aboveground oil/water separators and storage tanks replaced the functions of the surface impoundments (Ref. 6, p. 10). The f ormer o il p it contained oils, waxes and sludges (Ref. 5, p. 10). There is no evidence to indicate the former oil pit was lined since it consisted of a clay bottom (Ref. 24, p.107). The former oil pit also had minimal containment when in operation in the form of a 5 foot berm above the surrounding ground surface on the north perimeter of the former oil pit (Ref. 24, p. 8).

The former oil pit underwent an IM/RA under RCRA in accordance with the December 2002 IM/RA agreed order (Ref. 5, p. 6). During the IM/RA, a stabilizing agent was mixed into oily material in the Former Oil Pit, allowed to cure for a minimum of three days, and later excavated from the oil pit until underlying clayey soils showed no staining (Ref. 5, pp. 15 & 57- 59). Excavated material from the oil pit was temporarily stockpiled on-site in a bermed area lined with plastic sheeting (Ref. 5, pp. 15 & 60-63). The oil pit was excavated of an es timated 11,954 tons of oily material, and portions of the former oil pit were backfilled with clean clay soil and fill material acquired onsite from unaffected areas southwest of the former oil pit (Ref. 5, pp. 7, 16, 64 & 86-87). In addition, 4,119 tons of clean fill soil and 15 tons of roadbed gravel were imported from off -site (Ref. 5, p. 7). Storm water control berms around the temporary stockpiles diverted and collected water that came into contact with uncovered oily materials

into the open excavati on of the Former Oil Pit (Ref. 5, p.15). Storm water that collected in the excavated former oil pit was pumped to the partially buried barge, but there is no indication further excavation was completed after the removal of storm water (Ref. 5, p. 19).

A 1994 report recorded that t he impoundment formerly known as the o il p it had estimated dimensions of 100 feet long, 75 feet wide and 18 feet deep (Ref. 24, p. 8). In a work plan dated 1996, the oil pit’ s dimensions were given as approximately 160 f ee t x 100 f ee t x 6 f eet , and the pit was estimated to contain approximately 3,600 cubic yards of oily sludge (Ref. 4, p. 30; Ref. 6, p.7 ).

During the August 2013 EPA SI soil borings were advanced using direct push technology at two (2)

locations near the former oil pit area (Ref. 4, pp. 57; Figure 3). The borings were advanced to a maximum depth of 16 feet bgs using the procedures in the EPA Environmental Response Team (ERT)

September 2016 

### 66SO

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Other Possible Sources



### Standard Operating Procedure (SOP) 2050, modified for the actual unit used by the driller (Ref. 4, pp. 20, 149 & 934-946). Grab soil samples were collected from each boring from intervals of visual

contamination , or where photoionization detector (PID) readings for VOCs above background were detected (Ref. 4, pp. 20, 893 & 934-946 ). Sample location SBA-003 was near the northern edge of the Former Oil Pit, and sample location SBA -009 was in the area of concern for the former sludge storage tank located on the west side of the former oil pit (Figure 3). The following samples were collected (Ref. 4, pp. 30-31, 57):

• Sample Location SBA-003 Sample SBA-003-68 (6- 8 feet bgs) – chemical odor

• Sample SBA -003WT (10- 12 feet bgs)

– collected above water table; chemical odor

• Sample SBA -009-02 (0- 2 feet bgs)

– asphalt like material, slight odor

• Sample SBA -009WT (12- 14 feet bgs)

– collected above water table; chemical odor

PAHs such as acenaphthene, acenaphthylene, anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, 1,1’-biphenyl, chrysene, carbazole, dibenz(a,h)anthracene, dibenzofuran, fluoranthene, fluorene, indeno(1,2,3-cd)pyrene, 2- methylnaphthalene, naphthalene, phenanthrene, phenol, and pyrene were detected. These constituents were also detected in other sources at SBA including the Dry Dock and Partially Buried Barge (Sources 6 and 1, respectively). In addition, numerous volatile organic compounds (VOCs) such as benzene, cyclohexane, methylcyclohexane, 1,2-dichlorobenzene, ethylbenzene, tetrachloroethene, st yrene, isopropylbenzene, tetrachloroethene, xylene, cis-1,2-dichloroethane, and toluene were detected. Metal concentrations included manganese and cadmium (Ref. 4, pp. 31, 564-581 & 608-623).

During historical sampling events prior to IM/RA removal activi ties additional samples were collected from the oil pit. These included:

• Sludge from the oil pit sampled November 22, 1989.

• Sludge from the oil pit sampled August 24-25, 1994.

• Sludge from the oil pit sampled October 25, 1995 (Ref. 6, pp. 18-19).

Volatile organic compounds detected included benzene, ethylbenzene, toluene, xylenes, chloroform, carbon tetrachloride, 1,2-dichloroethane, 1,1,1-trichloroethane, trichloroethene, tetrachloroethene. Semivolatile organic compounds detected included acenaphthene, ac enaphthylene, anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(ghi)perylene, benzo(k)fluoranthene, chrysene, fluoranthene, fluorine, indeno(1,2,3- cd)pyrene, naphthalene, phenanthrene, and pyrene. Metals including cadmium were also detected (Ref. 6, pp . 19-21, 49, 52-54, 57).

Another potential source at SBA include contaminated soil located in an area south of Source No. 3 (water pit 1) and west of the former oil pit (Figure 2). The contaminated soil , as delineated by samples

SBA -005, SBA-006, SBA -010, and SBA-011, is located south of where wastes from the barge cleaning operations were mana ged in a waste management area that included the former o il p it. Water Pit 2, a land treatment unit (LTU) and storage tanks (Figure 3). Six soil samples were collected from three

locations in this locale during the 2014 SI , Location SBA -006, SBA-010 and SBA-011(Figure 3; Ref. 4, pp. 31, 57, 988-989 & 995 -998 ). The following samples were collected:

September 2016 

### 67SO

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Other Possible Sources



### • Location SBA-006, Sample SBA -006-24: Colle cted approximately 2

- 4 feet bgs; clay; g rey -ish tan with dark streaks; PID: 0.4 ppm; Visible hydrocarbon, oil material (Ref. 4, p. 988)

• Location SBA-006, Sample SBA-006- WT: Collected approximately 14 -16 f eet bgs and above

the water table ; clay with some silt , tan, orange mottled; PID: 7.8 ppm ; n o visible hydrocarbon,

oil material (Ref. 4, p. 989).

• Location SBA-010, Sample SBA-010- PD: Collected approximately 6

- 8 feet bgs at the highest

PID reading, 2.9 parts per million (ppm); silty clay; reddish brown; no visible hydrocarbon, oil

material (Ref. 4, p.995).

• Location SBA-010, Sample SBA-010- WT: Collected approximately 8

- 10 f eet bgs above the water table; sand

- silt and clay; r eddish- brown ; n o visible hydrocarbon, oil material (Ref. 4, p.996).

• Location SBA-01 1,Sample SBA -011- PD: Collected approximately 8 -10 f eet bgs at the highest PID reading; silt; t an; loose soft dry; no visible hydrocarbon, oil material (Ref. 4, p, 997)

• Location SBA-011, Sample SBA-011- WT: Collected approximately 8

- 10 feet bgs above the

wa ter table; clay; orange/tan mottled; dense plastic; no visible hydrocarbon, oil material (Ref. 4, p. 998).

Hazardous substances associated with the soil samples collected south of the former o il p it, Water Pit 2,

a land treatment unit (LTU) and storage tanks are PAHs, VOCs and various metals at depths ranging from 2 to 4 feet, 6 to 8 feet, 8 to 10 feet and 14 to 16 feet bgs (Ref . 4, pp. 74 -79, 344-359 & 492-526 ). Although there is no evidence to indicate that this area was used in the management of waste during barge cleaning operations at SBA, t hese constituents are also detected in surrounding units that were used as waste management areas at SBA during operations including the former o il p it

, Water Pit 1 (Source No. 3), and the Land Treatment Unit (LTU) (Source No. 4).

September 2016 

### 68SWOF

- Surface Water Overland Flow/Flood Migration Component

Observed Release



### SURFACE WATER MIGRATION PATHWAY

4.1 OVERLAND/FLOOD MIGRATION COMPONENT

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

General Considerations:

Four probable points of entr ies ( PPEs ) have been identified:

• PPE 1 is a zone located on the eastern portion of the SBA property along the man

- made structure between the dry dock and Mermentau River (Figure 4 ).

• PPE 2, located directly north of the partially buried barge is a zone where the overland flow meets the barge slip, is also located on the eastern portion of the property and a probable entry point from Source No. 1. (Figure 4 ).

• PPE 3 is a segment along where the partially buried barge and former water pit 3 (Source s No.1

& 6), have been reported to have discharged into the adjacent wetlands along a perennial drainage ditch which runs on the property from the northwest, through the wetlands and drains to

the Mermentau River (Ref. 6, p. 13; Ref. 20, pp. 4 & 5; Ref. 24, pp. 5, 10 & 128 ; Figure 4).

Surface run

- off from Source s No. 3 & 4 eventually flow into a segment of PPE -3 , the depressed

area of the drainage ditch that flows through the wetland th at drains to the Mermentau River (Ref. 24, p. 5,107 & 128 ; Ref. 20, pp. 4-5; Figure 5 ).

• PPE 4 is a zone located along the eastern edge of for me r water pit 3 (Source No. 6) (Figure 4). The former water pit 3 was closed by using a hydraulic excavator to break a wide gap in the earthen berm separating it from the Mermentau River bottomland directly east of the water pit (Ref. 5, pp. 8 & 21). Upon removal of the segment of the earthen berm, water from the Mermentau River flowed into the former water pit 3, raising the level of the water in the pit to approximately four (4) feet deep (Ref. 5, pp. 8, 21 & 24). Thus, linking the former surface impoundment with the designated wetland area to the immediate west (Figure 2).

Contamination could hav e entered the Mermentau River anywhere along the boundary of the perennial drainage ditch, wetlands, barge slip or dry dock and PPE 1 releases directly to the Mermentau River from the dry dock (Source No. 5). The migration route of all sources and PPEs eventually flow toward

and into the Mermentau River (Figure 5). From this point, PPE 1, the Mermentau River flows for approximately 10.2 miles until it enters Lake Arthur. The remainder of the 15- mile Target Distance Limit (TDL) for the surface water mig ration pathway is located in Lake Arthur (Figure 6).

Surface Water Pathway Description for Each Source

Source

No Pathway Description PPE

1 A Partially B uried B arge located on the southeast portion of the property, north of a designated wetland area

. Distance to the PPE -2 is approximately 25 feet and

distance to PPE -3 is approximately 35 feet ( Ref. 5 , p . 24 ; Figure 2 & 4 ) PPE 2 Zone adjacent to the Barge Slip that is part of

the Mermentau River

. PPE 3 : A segment of the d rainage ditch that flows through the Palustrine Forested Wetlands contiguous

with Mermentau River

. 3 Former Water Pit 1 located on the southeast portion of the property, northwest of a designated wetland area. Distance to the PPE is approximately 12 2 feet ( Ref. 24, p. PPE 3: A segment of the d rainage ditch that flows through the Palustrine Forested Wetlands contiguous

with Mermentau River

.



### September 2016 

### 69SWOF

- Surface Water Overland Flow/Flood Migration Component

Observed Release

Surface Water Pathway Description for Each Source
12; Figure 2 & 4)

4 A former LTU located west of Source No. 3 on the southeast portion of the property, northwest of a designated wetland. Distance to the PPE is approximately 261 feet (Ref. 24, p. 12; Figure 2 & 4) PPE 3: A segment of the d rainage ditch that flows through t he Palustrine Forested Wetlands contiguous

with Mermentau River

.

5 A D ry (Graving) D ock is located on the eastern edge of the property adjacent to the Mermentau River (Ref. 5 , p. 24 ; Figure 2 & 4) PPE 1 : A zone of w ater flow around/under the man

made structure along the east side of the dry dock

.

6 Former Water Pit 3 located on the southeast portion of the property, bordering a designated wetland area to the east

. Distance to the PPE

- 3 is approximately 71 feet

. (Ref. 24, p. 12; Figure 2 & 4) PPE 3: A segment of the d rainage ditch that flows through the Palustrine Forested Wetlands contiguous

with Mermentau River

. PPE 4 A zone along the Palustrine Forested Wetlands contiguous with Mermentau River

.



### Definition of In- Water Segments

The in

- water segment of the 15 mile TDL consists of the most upstream point of PPE 1 and the most downstream point of PPE 4, from which the 15 mile TDL starts. The Mermentau River flows for approximately 10.2 miles of the 15 mile TDL until it enters Lake Arthur (Figure 6).

Segment 1

Mermentau River, consisting of the branch segments which include PPE 1, the barge slip and the

wetland s to sample location SBA-030, flows for approximately a quarter mile of the 15 TDL (Figure 5 ). PPEs 2, 3 and 4 flow into this segment. A Unit ed States Geological Survey (USGS) gauging station 08012150, located in Jefferson Davis Parish in Mermentau, Louisiana has an average annual flow rate of the Mermentau River as measured for water year s 1990 through 2015 of 1,976 cubic feet per second ( cfs ) (Ref. 11, pp. 1-2 ). USGS gauging station, 08012150, is located approximately 3.0 miles upstream
of site on the Mermentau River at latitude 30 o 

### 11'24.00 " North and longitude 92 o 

### 35 ' 26.00 " West (Ref. 11, p. 1). A large stream to river with an average stream flow greater than 1,000 cfs to 10,000 cfs receives a dilution value of 0.001 (Ref. 1, Table 4-13 ).

The Mermentau consists of an upper and lower portion. The Mermentau at the upper end of Lake Arthur is considered the upper Mermentau River and the lower Mermentau River is located at the lower end of Grand Lake (Ref. 17, pp. 3 & 8). D uring low flows the hydraulic system of the lower Mermentau River is affected by water levels in the Gulf of Mexico and by operation of several Corp of Enginee r control structures in the lower Mermentau Basin (Ref. 17, p. 10 ). The lower Mermentau River is tidal downstream of the Catfish Point Control Structure, at the outlet of Grand Lake into the lower Mermentau River (Ref. 27, p. 11). During low river flows the system upstream of the closed control

structure s can be viewed as a large storag e basin with no tidal influence, and at higher river flows when the structures are opened tidal effects are temporarily reduced in a local portion of the system (Ref. 27, p. 11). When Gulf water levels are abnormally high tidal influences and salinity intrude through the myriad of small bayous and canals, this intrusion has a minor influence on the primary lakes and i nland waterways (Ref. 27, p.11). The upper Mermentau Riv er lies north of the designated Louisiana saltwater line definition provided by Louisiana Department of Wildlife and Fisheries (LDWF) (Ref. 14, p. 16).

70SWOF

- Surface Water Overland Flow/Flood Migration Component

Observed Release



### Segment 2

The remainder of the 15- mile TDL surface water migration pathway starts at and continues into Lake

Arthur. No published average flow data is available for Lake Arthur. The flow rate at the target

location was assigned a dilution weight based on the sum of the average annual flows for t he headwaters

of Bayou Lacassine near Lake Arthur and the Mermentau River (Ref. 11, pp. 1-2; Ref. 12, pp. 1-2). According to gauging station 08012470 located at Bayou Lacassine near Lake Arthur, Louisiana the average annual flow rate of Bayou Lacassine as measured for water year 1988 through 2005 is 594 cfs.

Lake Arthur will be assigned the average flow rate of 2,570 cfs , based on Bayou Lacassine average annual flow rate and the Mermentau R iver average flow rate . Thus, this segment will be considered to

be a large stream to river and will be assigned a dilution value of 0.001 (Ref. 1, Table 4-13 ).

4.1.2.1 Likelihood of Release

4.1.2.1.1 Observed Release

Direct Observation:

Two (2) sediment samples were collected, one during the August 2013 SI and the other during the September 2014 ESI, to identify and assess the migration and observed release by direct observation of

contamination in the surface water pathway from Former Water Pit 3 (Source No. 6) and associated with PPE 4 (Figures 3 & 4). Former Water Pit 3 was closed according to the December 2002 IM/RA by using a hydraulic excavator to break a wide gap in the earthen berm separating it from the Mermentau River bottomland directly east of the water pit (Ref. 5, pp. 8 & 21). Upon removal of the segment of the earthen berm, water from t he Mermentau River flowed into Former Water Pit 3 (former water pit), raising the level of water in the pit to approximately four (4) feet deep (Ref. 5, pp. 8, 21 & 24). Thus, making Former Water Pit 3 combined with the designated wetland area to the imm ediate west and being designated not only as a source but an observed release by direct observation to the wetlands based on prior documentation of contamination in Water Pit 3 (Ref. 4, pp. 642- 644). The following samples were

collected:

• Sample SBA -032SD – oily matrix ; glades of oil; light gray; clayey; collected at 2 to 3 in ches below ground surface (Ref. 4, pp. 117-118 & 1018). See Table 11 for observed release sample

concentrations.

• Sample SBA

‐ ESI

‐ 10SD – noticeable hydrocarbon odor; contained a sizeable amount of organic debris (Ref. 7, pp. 135-136, 164 & 976). See Table 12 for observed release sample

concentrations.

The release sediment samples along PPE 4 contained concentrations of PAHs that met observed release by direct observation criter ia (Ref. 1, Table 2- 3) were: acenaphthene, acenaphthylene, anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, chrysene, dibenz(a,h)anthracene, dibenzofuran, fluoranthene, fluorene, indeno(1,2,3- cd)pyrene, 2

- methylnaphthalene, naphthalene, phenanthrene and pyrene (Tables 11 & 12).

71SWOF

- Surface Water Overland Flow/Flood Migration Component

Observed Release



### Chemical Analyses:

Sediment samples (SBA -24SD, SBA-25SD, SBA-029SD and SBA-30 SD) and wetland samples (SBA

32SD, SBA-33SD and SBA-39SD) collected during the August 2013 SI, were compared to the representative background samples ( sediment sample SBA -28SD and wetland sediment sample SBA

31SD ) also collected during that specif ic sampling event ( Table 11 ). Background sediment sample

SBA

- 28SD was collected off

- site, from the bank of the Mermentau River located approximately 275 feet northeast of the facility entrance (Ref. 4, p. 27; Figure 5). S BA

- 28SD was designated as a background sediment sample since no organic or volatile organic compounds were detected (Ref. 4, p. 28 & 246-250). SBA

- 31SD was collected southwest of the source areas and is considered the background sample for the wetlands as analysis of the sample did not detect any organic or volatile organic constituents (Ref. 4, pp. 43 & 634-639 ; Figure 5 ). See T able 11 for background sediment and wetland samples, and observed release sample concentrations.

Respectively, sediment samples (SBA

- ESI -04, SBA- ESI -05 and SBA- ESI -06) and wetland samples (SBA

- ESI -10 and SBA- ESI

- 11) collected during the September 2014 ESI were compared to the representative background samples ( sediment samples SBA

- ESI -01 and SBA- ESI -02 and wetland sediment samples SBA

- ESI -08 and SBA- ESI -09) also collected during that speci fic sampling event (Table 12). Background sediment samples SBA- ESI -01 and SBA- ESI

- 02 were collected off

- site along

the Mermentau River approximately 500 to 600 feet upstream from the shoreline of the site (Ref. 7, p. 25; Figures 5). Sample location SBA- ESI

- 01 is located northeast of the site approximately 600 feet upstream and along the main/shipping channel of the Mermentau River (Ref. 7, p. 25; Figure 5). SBA

ESI -02 is located northwest and approximately 500 feet upstream and along the original river channel (Ref. 7, p. 25; Figure 5). N o semi

- volatile organics analytes were detected in either background sediment sample

, SBA

- ESI -01SD or SBA- ESI -02SD (Ref. 7, pp. 26 & 201-206). Background sediment samples, SBA

- ESI -08 and SBA- ESI -09, were collected along the downstream wetland bounda ry of the site (Ref. 7, p. 34; Figure 5). Sediment sample SBA- ESI

- 08 was collected along the west bank of the Mermentau River along the wetland boundary in an area subject to sediment build up, and sediment sample SBA

- ESI

- 09 was collected off- site long th e east bank of the Mermentau River along the wetland boundary (Ref. 7, p. 34; Figure 5). Given no semi

- volatiles constituents were detected in either

sediment sample collected along the wetland boundary of the Mermentau River, SBA- ESI -08 and SBAESI

- 09 we re defined as background sediment samples (Ref . 7 p. 34 & 192-197; Figure 5). See Table 12 for background sediment and wetland samples, and observed release sample concentrations.

Two (2) sediment samples were collected , one during the August 2013 SI and the other during the September 2014 ESI, to identify and assess the migration of contamination in the surface water pathway

from the D ry D ock (Source 5 ) and associate d with PPE 1 (Figures 3 & 4). The following samples were

co llected:

• Sample SBA -029SD – sediment sample from north of Dry Dock Slip (Ref .4, p. 41)

• Sample SBA

- ESI -04SD – collected down gradient of the Dry Dock (Ref. 7, p. 33)

The release sediment sample s associated with the Dry Dock and PPE 1 contained concentrations of

PAHs that met observed release criteria (Ref. 1, Table 2- 3) were : chrysene, fluoranthene , fluore ne, phenanthrene and pyrene (Table 12 ).

72SWOF

- Surface Water Overland Flow/Flood Migration Component

Observed Release



### Three (3) sediment samples collected during the August 2013 SI and two (2) sediment sampl es collected during the September 2014 ESI were collected from within the barge slip from five separate locations upstream and downstream of PPE 2 to assess the migration of contamination in the surface water pathway from former SBA (Ref. 19, p. 9). The following samples were collected :



### • Sample SBA -024SD – collected at the NW corner of the Barge Slip (Ref. 4, pp. 33 & 112)

• Sample SBA -025SD – hydrocarbon sh een (Ref. 4, pp. 33 & 113)

• Sample SBA -030SD – near the Bar ge Slip on the Mermentau River (Ref. 4, p. 111)

• Sample SBA

- ESI -05SD – collected in the western section of the barge slip (Ref. 7, pp. 33 & 114-117)

• Sample SBA

- ESI -06SD – collected in the eastern section of the barge slip (Ref. 7 , pp. 33 & 118- 121)

T he release sediment sediments from the barge slip , PPE 2, detected numerous PAHs that met observed

release criteria (Ref. 1, Table 2-3) were: acenaphthene, acenaphthylene, anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, chrysene, dibenz(a,h)anthracene, dibenzofuran, fluoranthene, fluorene, indeno(1,2,3-cd)pyrene, 2- methylnaphthalene, naphthalene, phenanthrene and pyrene above three times the concentration in background sediment levels ( Tables 1 1 & 1 2 ).

Three (3 ) sediment samples were collected , two during the August 2013 SI (SBA -033 and SBA-039) and one during the September 2014 ESI (SBA

- ESI -11SD) from the wetlands located south and northeast

of S BA former operations to identify and assess the migration of contamination in the surface water pathway from the P artially Buried B arge (Source 1) and former surface impoundments (Sources No. 3, 4

and 6 ), and associated with PPE 3 (Ref. 4, p. 57; Ref. 7, p. 50; Figures 3 & 5 ). The following samples

were collected:

• Sample SBA -033 – collected east of the impoundment areas and south of the P artially Buried

B arge (Ref. 4, p. 119)

• Sample SBA -039 – collected east of the P artially Buried B arge (Ref. 4, pp. 120)

• Sample SBA

- ESI -11SD – collected northeast of former Water Pit 3 in wetland; noticeable hydrocarbon odor; hydrocarbon sheen observed on surface of water (Ref. 7, pp. 137-138 & 164).

The release sediment samples along PPE 3 contained concentrations of PAHs that met observed release

criteria (Ref. 1, Table 2- 3) were : acenaphthene

, acenaphthylene, anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, carbazole, chrysene, dibenzofuran, fluoranthene, fluorene, indeno(1,2,3- cd)pyrene, 2 -methylnaphthalene, naphthal ene, phenanth rene and pyrene (Table s 11 & 12 ).

During a 1994 compliance evaluation and sampling inspection tasked by the EPA, two samples were collected from the Former Water Pit 3 and analyzed for volatiles, semi- volatiles, total metals, TCLP

volatiles , semi -volatiles and metals, and ignitability (Ref. 24, pp. 18 & 114). VOCs such as benzene, ethylbenzene, methylene chloride, toluene, 1,1,2 –trichloroethane and xylene were detected (Ref. 24, p. 135). In, addition PAHs such as acenaphthene, anthracene, benzo(a)anthracene, benzo(b)fluoranthene, chrysene, fluoranthene, fluore ne, naphthalene, phenanthrene and pyrene were detected in Water Pit 3(Ref. 24, p. 136). Total metals detected in the sludge/sediment samples collected from Water Pit 3

September 2016 

### 73SWOF

- Surface Water Overland Flow/Flood Migration Component

Observed Release



### included silver, arsenic, cadmium, chromium, copper, mercury, nickel, lead, antimony, selenium, thallium and zinc (Ref. 24, p. 137).

Sample s SBA -24 SD

, SBA -025 SD

, SBA -029 SD

, SBA -030SD, SBA -033 and SBA-039 were sent to the

U.S. EPA Lab oratory in Houston for analysis, data review and data validation for Target Compound List (TCL) Volatile Organic Analysis (VOAs) by EPA method CLP SOW SOM01.2(method used - CLP

OLM04.2 – GC/MS ) , TCL Semi

- Volatile Organic Analysis (SVOAs) by EPA method CLP SOW SOM01.2 (method used - CLP OLM 04.2 – GC/MS ) , TCL Pesticide/PCB s by EPA method CLP SOW SOM01.2 (method used – CLP OLM04.2 – GC/ECD ), TAL Cyanides by EPA method CLP SOW ILM05.4 (method used 335.4 – Colorimetric ) , and TAL Total Metals + Mercury by EPA method CLP

SOW ILM05.4 (methods used - CLP ILM05.3

– ICP , CLP ILM05.3 – ICP/MS, CLP ILM05.3 – CVAAS) (Ref. 4, pp. 22-23, 47, 230-243, 262-275, 640-647, 648-655, 658-660, ).

Samples SBA

- ESI -04SD, SBA- ESI -05SD, SBA- ESI -06SD, and SBA

- ESI -11 SD were shipped to the U.S. EPA Laboratory in Houston for analysis, data review and data validation for TCL SVOAs by EPA

method CLP OLM04.2 – GC/MS (Ref. 7, pp. 22, 183-189, 210-218, ).

An observed release by chemical an alysis of the sediment samples collected at and down gradient of PPE 1, within the barge slip for PPE 2, along the drainage ditch of PPE 3 that flows through the wetland and finally into the Mermentau River is analytical evidence of a hazardous substance in the media significantly above background and attribution of at least part of the increase to the site.

74SWOF

- Surface Water Overland Flow/Flood Migration Component

Observed Release


### Table 11 – Site Inspection Background and Release Samples

EPA/START Sample No.: SBA

- 28SD SBA

- 0 29SD SBA

- 24SD SBA

- 25SD SBA

- 30SD SBA

- 31SD SBA

- 33SD SBA

- 39SD SBA

- 32SD
EPA Laboratory Sample No.: 1308016

- 03 1308016

- 05 1308016

- 01 1308016

- 02 1308016

- 06 1308020

- 26 1308020

- 28 1308020

- 29 1308020

- 27

Sample Location: Sediment Background (PPE 1) Sediment (PPE 2) Barge Slip

NW Sediment (PPE 2) Barge Slip

N Sediment (PPE 2) Sediment Wetland Background (PPE 3) Wetland (PPE 3) Wetland (PPE 4) Wetland

% Solids: 69.74% 70.49% 71.26% 56.39% 69.98% 53.54% 73.91% 17.25% 62.29%

Units: Result RL 3x Bkgd.

or > RL Result RL Result RL Result RL Result RL RL Result 3x Bkgd.

or > RL Result RL Result RL Result RL

Analyte: SVOCs μg/kg μg/kg μg/k g μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/Kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg μg/kg

Ac enaphthene U 286 286 (RL) U 283 1270 279 U 346 U 278 367 U 367 (RL) U 2410 U 1130 7520 311

Benzo (b) fluoranthene U 715 715 (RL) 1510 J (151)* 707 4100 697 22500 8660 4450 695 918 U 918 (RL) 53,200 30100 U 2820 12700 3890

Benzo (g,h,i) perylene U 715 715 (RL) 1750 J (175)* 707 2860 697 11000 866 2990 695 918 U 918 (RL) 32,900 30100 U 2820 7620 3890

Benzo (k) fluoranthene U 715 715 (RL) 976 J (97.6)* 707 2950 697 16300 8660 2640 695 918 U 918 (RL) 38,600 30100 U 2820 6900 3890

Acenaphthylene U 286 286 (RL) U 283 621 279 3000 346 376 278 367 U 367 (RL) 3,980 2410 U 1130 6900 3890

Carbazole U 715 715 (RL) U 707 U 697 2880 J (288)* 866 U 695 918 U 918 (RL) 119000 J (11900)* 6010 U 2820 2540 J (254)* 778

Chrysene U 715 715 (RL) 1040 J (104)* 707 5240 697 19200 8660 9130 695 918 U 918 (RL) 44400 6010 U 2820 12800 3890

Dibenzofuran U 715 715 (RL) U 707 U 697 1860 866 U 695 918 U 918 (RL) 9960 6010 U 2820 3340 778

Dibenz (a,h) anthracene U 715 715 (RL) U 707 712 697 3780 866 852 695 918 U 918 (RL) 6720 J (672)* 6010 U 2820 2070 J (207)* 778

Anthracene U 286 286 (RL) 873 J (87.3)* 283 1030 279 4750 3460 278 J (27.8)* 278 367 U 367 (RL) 353000 12000 U 1130 21400 1560

Fluoranthene U 286 286 (RL) 418 J (41.8)* 283 8440 279 33600 3460 2110 J (211)* 278 367 U 367 (RL) 52200 2410 U 1130 20300 1560

Fluorene U 286 286 (RL) U 283 395 279 2330 346 U 278 367 U 367 (RL) 32000 2410 U 1130 10500 311

Indeno (1,2,3

- cd) pyrene U 715 715 (RL) 1630 J (163)* 707 3090 697 12900 866 3490 695 918 U 918 (RL) 38300 30100 U 2820 8830 3890

2

- Methylnaphthalene U 286 286 (RL) U 707 U 279 700 346 U 278 367 U 367 (RL) 5970 2410 U 1130 1880 311

Naphthalene U 286 286 (RL) U 283 U 279 4170 346 U 278 367 U 367 (RL) 10600 2410 U 1130 786 311

Phenanthrene U 286 286 (RL) U 283 404 279 21400 3460 285 J (28.5)* 278 367 U 367 (RL) 61000 2410 U 1130 26600 1560

Pyrene U 286 286 (RL) 903 J (90.3)* 283 12600 279 33700 3460 4780 278 367 U 367 (RL) 62000 2410 U 1130 21800 1560

Benzo (a) anthracene U 715 715 (RL) U 707 3470 697 16000 866 3680 695 918 U 918 (RL) 27500 6010 U 2820 8910 3890

Benzo (a) pyrene U 715 715 (RL) 1630 J (163)* 707 5500 697 21000 8660 5120 695 918 U 918 (RL) 50800 30100 U 2820 13800 3890

Key:

μ g/kg = Concentrations in microgram per kilogram RL

- Reporting Limit
Bkgd

- Background SD

- Sediment

N

- North U

- Undetected

NW

- Northwest

PPE

- Probable Point of Entry ntification of the analyte is acceptable; The reported value is an estimate (Ref. 4, p. 865). The reported values for the SVOCs detected in sample SBA

- 0 29SD are biased unknown (Ref. 4, pp. 181, 262

- 265). The reported values for carbazole in samples SBA

- 35SD, SBA

- 32SD, and SBA

- 33SD are

ased unknown (Ref. 4, pp. 181, 238, 642 & 650). The reported value for Dibenz (a,h) anthracene in samples SBA

- 32D and SBA

- 33SD are biased unknown (Ref.4, pp. 181, 251 & 643).

ected concentration was adjusted by using the guidance document " Using Qualified Data to Document an Observed Release and Observed Contamination " (Ref. 31, pp. 8, 14

- 15). After adjusting the value for the qualified data to reflect he possible bias , the concentration of the analyte still meets the

quirement for an observed release by chemical analysis.

References

Chain of Custody: Ref. 4, p. 160 Ref. 4, p. 160 Ref. 4, p. 160 Ref. 4, p. 160 Ref. 4, p. 160

- 161 Ref. 4, p. 172 Ref. 4, p. 172 Ref. 4, p. 172 Ref. 4. p. 172

Laboratory Results: Ref. 4, pp. 246 -251 Ref. 4, pp. 262 -267 Ref. 4, pp. 230 -235 Ref. 4, pp. 238 -243 Ref. 4, pp. 270 -275 Ref. 4, pp. 634 -639 Ref. 4, pp. 650 -655 Ref. 4, pp. 658

- 663 Ref. 4. pp. 642

- 647

Data: Ref. 4, pp. 246

- 250; Ref. 52 Ref. 4, p. 181, 262

- 264, & 865; Ref. 31, pp. 8, 14 -15;

Ref. 52 Ref. 4, pp. 230 -235;

Ref. 52 Ref. 4, pp. 181, 238 & 865; Ref. 31, pp. 8 & 14; Ref. 52 Ref. 4, pp. 270

- 275; Ref.

52 Ref. 4, pp. 634

- 639; Ref. 52 Ref. 4, pp. 181, 650

- 651 & 865; Ref. 31, pp. 8 & 14; Ref. 52 Ref. 4, pp. 658

- 660 & 662 ; Ref.

52 Ref. 4, pp. 181,

642- 643, 865; Ref. 31, pp. 8 &

14: Ref. 52



### 75SWOF

- Surface Water Overland Flow/Flood Migration Component

Observed Release


### Table 12 – Expanded Site Inspection Background and Release Samples

EPA/START Sample Number: SBA

- ESI

- 01SD SBA

- ESI

- 02SD SBA

- ESI

- 04SD SBA

- ESI

- 05SD SBA

- ESI

- 06SD

EPA Laboratory Sample No.: 1409034

- 01 1409034

- 02 1409034

- 04 1409028

- 01 1409028

- 02 Sampling Location: SBA

- ESI

- 01 SBA

- ESI

- 02 SBA

- ESI

- 04 SBA

- ESI

- 05 SBA

- ESI

- 06

Sample Description: Sediment Background along the main shipping channel Sediment Background along the original river channel (PPE 1) Sediment downstream from Dry dock (PPE 2) Sediment in Barge Slip (PPE 2) Sediment in Barge Slip

% Solids: 67.42% 41.91% 64.21% 40.04% 45.14%

Units: μg/kg μg/kg μg/kg μg/kg μg/kg

Analyte: SVOCs Result Flag RL Result Flag RL Result Flag RL Result Flag RL Result Flag RL

2

- Methylnaphthalene 277 U 277 476 U 476 293 U 293 486 U 486 430 U 430 Acenaphthene 277 U 277 476 U 476 293 U 293 1110 U 486 430 U 430 Acenaphthylene 277 U 277 476 U 476 293 U 293 486 U 486 430 U 430

Anthracene 277 U 277 476 U 476 293 U 293 486 U 486 430 U 430 Benzo (a) anthracene 693 U 693 1190 U 1190 732 U 732 2120 1210 1390 1080 Benzo (a) pyrene 693 U 693 1190 U 1190 732 U 732 1830 1210 1460 1080 Benzo (b) fluoranthene 693 U 693 1190 U 1190 732 U 732 1940 1210 1740 1080 Benzo (g,h,i) perylene 693 U 693 1190 U 1190 732 U 732 1210 U 1210 1080 U 1080 Benzo (k) fluoranthene 693 U 693 1190 U 1190 732 U 732 1560 1210 1350 1080

Carbazole 693 U 693 1190 U 1190 732 U 732 1210 U 1210 1080 U 1080 Chrysene 693 U 693 1190 U 1190 760 732 3840 1210 2260 1080 Dibenz (a,h) anthracene 693 U 693 1190 U 1190 732 U 732 1210 U 1210 1080 U 1080

Dibenzofuran 693 U 693 1190 U 1190 732 U 732 1210 U 1210 1080 U 1080

Fluoranthene 277 U 277 476 U 476 1040 293 4630 486 2890 430

Fluorene 277 U 277 476 U 476 381 293 1480 486 430 U 430 Indeno (1,2,3

- cd) pyrene 693 U 693 1190 U 1190 732 U 732 1210 U 1210 1080 U 1080 Naphthalene 277 U 277 476 U 476 293 U 293 486 U 486 430 U 430

Phenanthrene 277 U 277 476 U 476 1200 293 4850 486 1530 430 Pyrene 277 U 277 476 U 476 808 293 3990 486 2430 430
Key:

BOLD

- Concentration detected is significantly above the background concentration or the Reporting Limits

PPE

- Probable Point of Entry into Surface Water

U

- Undetected at Reporting Limit

RL

- Reporting Limit

References Chain of Custody: Ref. 7, p. 170 Ref. 7, p. 170 Ref. 7, p. 170 Ref. 7, p. 169 Ref. 7, p. 169 Laboratory Results: Ref. 7, pp. 201

- 203 Ref. 7, pp. 204

- 206 Ref. 7, pp. 210

- 212 Ref. 7, pp. 183

- 185 Ref. 7, pp. 186

- 189

Data: Ref. 7, pp. 201

- 203; Ref. 52 Ref. 7, pp. 204

- 206; Ref. 52 Ref. 7, pp. 210

- 212; Ref. 52 Ref. 7, pp. 183

- 185; Ref.

52 Ref. 7, pp. 186

- 189; Ref.

52



### 76SWOF

- Surface Water Overland Flow/Flood Migration Component

Observed Release


### Table 12 (continued) – Expanded Site Inspection Background and Release Samples

EPA/START Sample Number: SBA

- ESI

- 08SD SBA

- ESI

- 09SD SBA

- ESI

- 11SD SBA

- ESI

- 10SD

EPA Laboratory Sample No.: 1409028

- 04 1409028

- 05 1409034

- 06 1409034

- 05 Sampling Location: SBA

- ESI

- 08 SBA

- ESI

- 09 SBA

- ESI

- 11 SBA

- ESI

- 10

Sample Description: Sediment Background along wetland boundary on right descending bank of river Sediment Background along wetland boundary on left descending bank of river (PPE 3) Wetland Sediment NE of

Former Water Pit 3 (PPE 4) Wetland Sediment SE of

Former Water Pit 3

% Solids: 35.36% 60.85% 57.57% 26.10%

Units: μg/kg μg/kg μg/kg μg/kg

Analyte: SVOCs Result Flag RL Result Flag RL Result Flag RL Result Flag RL

2

- Methylnaphthalene 543 U 543 307 U 307 32,400 1,520 35,900 5,490 Acenaphthene 543 U 543 307 U 307 51,100 1,520 250,000 5,490 Acenaphthylene 543 U 543 307 U 307 8,820 1,520 46,400 5,490

Anthracene 543 U 543 307 U 307 1,190,000 152,000 1,040,000 54,900 Benzo (a) anthracene 1360 U 1360 768 U 768 114,000 38,000 664,000 137,000 Benzo (a) pyrene 1360 U 1360 768 U 768 92,100 38,000 507,000 137,000 Benzo (b) fluoranthene 1360 U 1360 768 U 768 107,000 38,000 484,000 137,000 Benzo (g,h,i) perylene 1360 U 1360 768 U 768 35,600 34,200 150,000 137,000 Benzo (k) fluoranthene 1360 U 1360 768 U 768 98,200 38,000 495,000 137,000

Carbazole 1360 U 1360 768 U 768 308000 (30,800)* J 38,000 16100 (1619)* J 13,700

Chrysene 1360 U 1360 768 U 768 177,000 38,000 822,000 137,000 Dibenz (a,h) anthracene 1360 U 1360 768 U 768 10100 (1,010)* J 3,800 61,900 54,900

Dibenzofuran 1360 U 1360 768 U 768 57,600 3,800 157,000 13,700

Fluoranthene 543 U 543 307 U 307 413,000 15,200 1,540,000 54,900

Fluorene 543 U 543 307 U 307 173,000 15,200 510,000 54,900 Indeno (1,2,3

- cd) pyrene 1360 U 1360 768 U 768 44,300 38,000 167,000 137,000 Naphthalene 543 U 543 307 U 307 15,000 1,520 9,140 5,490

Phenanthrene 543 U 543 307 U 307 477,000 15,200 1,590,000 54,900 Pyrene 543 U 543 307 U 307 297,000 15,200 1,380,000 54,900
Key:

BOLD

- Concentration detected is significantly above the background concentration or the Reporting

Limits μg/kg = micrograms per kilogram PPE

- Probable Point of Entry into Surface Water

RL

- Reporting Limit U

- Undetected at Reporting Limit

J

- The identification of the analyte is acceptable; The reported value is an estimate (Ref. 7, p. 251). The reported values for carbazole in samples SBA

- ESI

- 10SD and ESI

- 11SD are biased unknown (Ref. 7, pp. 179, 213 and 216). The reported value for Diben z (a,h) anthracene in sample SBA

- ESI

- 11SD is biased unknown (Ref. 7, pp. 179 and 217).

*

- The detected concentration was adjusted by using the guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 31, pp. 8 and 14). After adjusting the value for the qualified data to reflect the possible bias , the concentration of the analyte still meets the requirement for an observed release by chemical analysis.

References Chain of Custody: Ref 7, p .169 Ref. 7, p. 169 Ref. 7, p. 170 Ref. 7, p. 170 Laboratory Results: Ref. 7, pp. 192

- 194 Ref. 7, pp. 195

- 197 Ref. 7, pp. 216

- 218 Ref. 7, pp. 213

- 215

Data: Ref. 7, pp. 192

- 194; Ref. 52 Ref. 7, pp. 195

- 197; Ref. 52 Ref. 7, pp. 179, 216

- 217 & 251; Ref. 31, pp. 8 and 14; Ref. 52 Ref. 7, pp. 179, 213 and 251; Ref. 31, pp. 8 and 14; Ref. 52



### 77SWOF

- Surface Water Overland Flow/Flood Migration Component

Observed Release



### At tribution:

SBA Shipyard previously used the property for construction, repair, retrofitting and cleaning of barges

since the mid -1960’s (Ref. 6, p.7). Three barge slips and a dry dock are located off the Mermentau River (Figure 2; Ref. 5, pp. 38-39; Ref. 6, p. 7). The slips were used to dock bar ges during cleaning or repair (Ref. 7, p. 13). Barges serviced by SBA typically held diesel, coal tar, crude oil, gasoline and asphalt (Ref. 6, p. 10). Mr. Smailhall stated that the facility had in the past cleaned barges which previously contained coal tar, and acknowledged in another statement that chlorinated solvents were used in the cleaning process in the past (Ref. 22, p. 3: Ref. 33, pp. 1-2). Also, Mr. Smailhall provided MSDS’s for paints used on the barges for the previous two years (Ref. 34, pp. 2 & 80-235). Review of the MSDS revealed that the material was hazardous when discarded due to ignitability, and also the material

exhibited the characteristic for m ethyl ethyl ketone (Ref. 34, p. 2). During the painting of barges, solvents used for cleaning painting equipment were saved and used to thin coating s applied to barges (Ref. 33, p. 2). Some barges held coal tar, creosote, miscellaneous chemicals or agricultural related materials such as tallow, corn oil or soybean (Ref. 32, p. 46 ). SBA was an industrial location for waste and fuel storage associated with past barge cleaning operations (Ref. 6, p. 17). W astes from the barge cleaning, for the most part, consisted of hydrocarbons (Ref. 6, p. 10). In addition to the hydrocarbons other waste streams on site included asphalt, creosote, m ethyl

m ethacrylate , methanol , caustic soda, styrene, coal tar, vinyl acetate, c arbon t etra chloride , e thyl a crylate

and a crylates (Ref. 41, p. 11; Ref. 44, pp. 162, 226, 232, 254, 274 & 379; Ref. 45, pp. 115 & 197; Ref. 46, pp. 9 & 203; Ref. 47, pp. 4, 15, 40, 50, 76, 78, 79, 125, 126, 236 & 241; Ref. 48, pp. 14, 16 & 388;

Ref. 49, pp. 3, 33, 34, 38, 39, 110 & 236; Ref. 50, pp. 25, 130 & 133: Ref. 51, pp. 1-3 & 36-39 ). Waste samples taken from W ater P its 1, 2, and 3 were found to contain vinyl chloride, 1,2-dichloroethane, tetrachloroethylene, trichloroethylene, methylene c hloride, methyl ethyl ketone, carbon tetrachloride, acetone and styrene (Ref. 35, pp. 6 -7; Ref. 37, pp .1, 4-12 & 19-41). Since approximately 1970, benzene, vinyl chloride, and carbon tetrachloride toxicity characteristic waste s were placed in Wate r Pit 1 and 2 (Ref. 35, p.10). Waste in some of the tanks were found to be characteristically hazardous based on benzene, 1,2-dichloroethane, tetrachloroethane, vinyl chloride or ignitability (Ref. 32, p. 46).

COCs at the site that are being scored are not normally found in petroleum products, or can be associated with non-petroleum excluded products histor ically associated with the site

. CERLCA hazardous substances are subject to CERCLA response authority and r esponsibility . Invoices and manifests from customers that had barges repaired, retrofitted or cleaned and painted during the operational period of SBA contained CERLCA eligible waste to include: asphalt, creosote, m ethyl

m ethacrylate , methanol , caustic soda, styrene, coal tar, vinyl acetate, c arbon t etra chloride , e thyl a crylate

and a crylates (Ref. 41, p. 11; Ref. 44, pp. 162, 226, 232, 254, 274 & 379; Ref. 45, pp. 115 & 197; Ref. 46, pp. 9 & 203; Ref. 47, pp. 4, 15, 40, 50, 76, 78, 79, 125, 126, 236 & 241; Ref. 48, pp. 14, 16 & 388; Ref. 49, pp. 3, 33, 34, 38, 39, 110 & 236; Ref. 50, pp. 25, 130 & 133: Ref. 51, pp. 1-3 & 36-39). Potential chemical hazards at this site included: chloroform, 1,2-dichloroethane, tetrachloroethene, trichloroethene, vinyl chloride, ortho- cresol, meta -cresol and pyridine (Ref. 32, p. 49; Ref. 34, p. 1). Additional, possible constituents of concern at the site identified include 1,1,1-trichloroethane, vinyl chloride, 1,2-dichloroethene, benzene, tetrachloroethylene, toluene, eth ylbenzene, xylene, styrene, chloroform, creosol, pyridine, arsenic, barium, mercury and lead (Ref. 32, pp. 49-52 & 75-94; Ref. 34, p. 1). Wastes from the barge cleaning operations were managed in a waste management area that included impoundments (Oil Pit , Water Pit 1, Water Pit 2, and Water Pit 3) , a land treatment unit (LTU) and storage tanks (Ref. 6, p. 5). All wastes managed on site consisted of non-petroleum and petroleum

78SWOF

- Surface Water Overland Flow/Flood Migration Component

Observed Release



### products that were comingled within the waste management units and not segregated during the operations or processing (Ref. 24, pp. 5 & 7; Ref. 30, pp. 5, 21-26 ).

Two sediment samples were collected from two separate locations in the vicinity of the Dry Dock (PPE 1) (Figure 5 ). Location SBA -029 , Sample SBA -029SD from the north of the dry dock , and Location

SBA

- ESI -04, S ample SBA

- ESI -04SD down gradient of the dry dock (Ref. 4, p. 41: Ref. 7, p. 33).

In the release sediment sample s from the Dry Dock , chrysene, fluoranthene, fluo rene, phenanth rene, and

p yrene were detected and met observed release criteria (Ref. 4, pp. 260-267; Ref. 7, pp. 210-212; Table s 11 & 12 ).

Five (5 ) sediment samples (SBA -024SD, SBA -025SD , SBA -030SD, SBA

- ESI -05SD, SBA

- ESI -06 SD ) were collected from within the barge slip from four separate locations upstream and at PPE 2 to

determine the migration of contamination in the surface water pathway from former SBA operations (Figure 5)

. The samples had the same constituents as the other sediment samples collected from the

P artially B urie d B arge scored as Source 1, and which receives drainage from Source 1 (Ref. 4, pp. 228- 243 & 268-275; Ref. 7, pp. 183-188 ; Tables 1 1 & 1 2).

Three (3) sediment samples (Sample SBA -33, Sample SBA-39 and SB A- ESI -11SD) were collected from the wetland located south and northeast of SBA former operations to identify and assess the migration of contamination in the surface water pathway from the partially buried barge (Source 1) and former surface impou ndments (the former oil pit and Sources No. 3, 4 and 6 ) and associated with PPE 3 (Figure 5 ). The wetland sediment samples had the same constituents as the other samples collected from

the P artially Buried Barge (Source 1), the two former s urface impoundments (the former oil pit and

Source 3 ), LTU (Source 4) and surface impoundment that is now part of the wetland (Source 6) (Tables

11 & 12 ). The wetland located south and northeast of former SBA operation receives drainage from all site sources (Figure s 4 & 5).

Two (2) wetland sediment samp les (SBA -032 and SBA- ESI

- 10) were collected from the location of Former Water Pit 3 that is currently a part of the wetland and document an observed release by direct observation associated with PPE 4 (Figure 5). The wetland sediment samples had the same constituents as the other samples collected from the Partially Buried Barge (Source No. 1), the two former surface impoundments (the former oil pit and Source No. 3) and the LTU (Source 4) ( Tables 11 & 1 2 ). Former Water Pit 3, that is presently part of th e wetlands and PPE 4, is along the surface water migration pathway and receives drainage from the f ormer o il pit, Former Water Pit 1 (Source No. 3) and the former LTU (Source No. 4)

Alternative sites that could potentially be contributing releases of hazardous substances to those found at

the SBA facility were identified. A f ormer terminal is located north of the site, which consists of two storage tanks (Ref. 6, p. 17; Ref. 28, p. 1 ). Little information is known about th e dates of operation at

this facility

. Available information indicate s that the property north of the SBA facility was occupied by Citgo (Ref. 2 8). There are no other industries located within a 2-mile radius of the property that might be responsible fo r the contamination in the PPE or the wetlands . Background sediment samples collected upstream from the site indicate the form er terminal is unlikely to be impacting sediments at, or downstream of, SBA shipyard. Residential areas are located north of the property, wetlands to the south and west, and the Mermentau River to the east (Ref. 4, pp. 12-13). The area west of the property

Septem ber 20 16 

### 79SWOF

- Surface Water Overland Flow/Flood Migration Component

Observed Release



### includes agricultural use such as pastures ( Ref. 6, p. 17). The frontage along highway 3166 includes a number of residential structures, some residences may be used as recreational properties , others may be year round residences (Ref. 6, p. 17).

Background sediment samples collected did not detect any contam inants of concern that have been

associated with the site (Tables 11 & 12). The background sediment samples SBA-28SD, SBA- ESI -01

and SBA- ESI -02 were collected upstream of the site while SBA -31SD, SBA- ESI -08 and SBA- ESI -09

were collected downstream from th e site. The background sediment sample results indicate that the significant increase in the concentration of the hazardous substances in the observed release is not due to other sites. The sources contained the same constituents in the observed release and in the drainage pathway to the wetlands and Mermentau River ( Tables 1, 4, 5, 6, 7, 8, 9 & 10 ).

Observed Release Factor Value: 550

80SWOF/

Human Food Chain

- Toxicity/Persistence/Bioaccumulation



### 4.1.3.2 HUMAN FOOD CHAIN THREAT - WASTE CHARACTERISTICS

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation

The human food chain waste characteristics section provides the toxicity, persistence and bioaccumulation factor values for hazardous substances that are available to migrate from sources at the

site to surface water in the watershed via the overland/flood hazardous substances migration path for the watershed (Ref. 1, Section 4.1.3.2.1), the hazardous waste quantity value for the watershed (Ref. 1, Section 4.1.3.2.2), and the calculation of the human food chain threat- waste characteristics factor

category v alue (Ref. 1, Section 4.1.3.2.3). The highest combined toxicity, persistence and

bioaccumulation factor is used to determine the waste characteristics factor value for the human food chain threat of the surface water migration pathway (Ref. 1, Section 4.1.3.2.1.4).

Hazardous substances that meet the criteria for an observed release to surface water and all hazardous substances associated with the sources that have a surface water containment factor value greater than 0 for the watershed are presented in Table 13 below. Each hazardous substance eligible to be evaluated is assigned a toxicity/persistence/bioaccumulation factor value. The hazardous substance with the highest toxicity/persistence/bioaccumulation

81SWOF/

Human Food Chain

- Toxicity/Persistence/Bioaccumulation



### Table 13 – Human Food Chain Threat - Toxicity/Persistence/Bioaccumulation Summary

Hazardous Substance Source No. Toxicity

Factor

Value Persistence

Factor

Value* Toxicity/

Persistence

Factor Value (Table 4

- 12) Bioaccumulation

Factor Value ** Toxicity/Persistence /

Bioaccumulation F actor

Value (Table 4 -16) Reference

Acenaphthene 1 , 3, 4, 6 , OR 10 0.4 4 500 2,000

Ref. 1, Table 4

- 12, 4

- 16; Ref. 2, Appendix B, pp.

1-10 Acenaphthylene 1 , 3

- 6, OR 1 0.4 0.4 500 200

Anthracene 1 , 3

- 6, OR 10 0.4 4 50,000 200,000

Aroclor

- 1254 1 5 10,000 1 10,000 50,000 500,000,000

Arsenic 1, 3

- 5 10,000 1 10,000 5 50,000

Barium 3 10,000 1 10,000 500 5,000,000

Benzene 1, 3, 4 1,000 0.4 400 5,000 2,000,000

Benzo(a)anthracene 1 , 3

- 6, OR 1,000 1 1,000 50,000 50,000,000

Benzo(a)pyrene 1 , 3

- 6, OR 10,000 1 10,000 50,000 500,000,000

Benzo(g,h,i)perylene 1 , 3

- 6, OR 0 1 0 50,000 0

Benzo(b)fluoranthene 1 , 3

- 6, OR

Benzo(k)fluoranthene 1 , 3

- 6, OR 100 1 100 50,000 5,000,000

Beryllium 4, 6 10,000 1 10,000 50 500,000

Biphenyl, 1,1'

- 1, 3, 4

Bis (2

- ethylhexyl) phthalate 3 100 1 100 50,000 5,000,000

Cadmium 3, 4 10,000 1 10,000 50,000 500,000,000

Carbazole 1 , 3

- 6, OR 10 1 10 500 5,000

Chromium 1 10,000 1 10,000 5 50,000

Chrysene 1 , 3

- 6, OR 10 1 10 5 50

Cobalt 1

, 3, 5, 6 10,000 1 10,000 50 500,000

Copper 3

- 5 100 1 100 50,000 5,000,000

Cyclohexane 1 ,3, 4

Dibenz(a,h)anthracene 1

, 3, 5, 6, OR 10,000 1 10,000 50,000 500,000,000

Dibenzofuran 1 , 3

- 6,OR 1,000 0.4 400 500 200,000

Dichlorobenzene, 1,2

- 1

, 3

Dichlorobenzene, 1,4

- 3 10 0.4 4 5,000 20,000

Dichloroethene, 1,2

- cis

2 3, 4 1,000 0.4 400 50 20,000

Dimethyl phenol, 2,4

- 3 100 1 100 500 50,000

Ethylbenzene 1, 3, 4 10 0.4 4 50 200

Fluoranthene 3 1 , 3

- 6,OR 100 1 100 5,000 500,000

Fluorene 1 , 3

- 6,OR 100 0.4 40 500 20,000

Hexachlorodibenzo

- p

- dioxin 1,2,3,7,8,9

- 1 10,000 1 10,000 50,000 500,000,000

Hexachlorodibenzofuran 1,2,3,4,7,8

- 1 10,000 1 10,000 50,000 500,000,000

Hexachlorodibenzofuran 1,2,3,6,7,8

- 1 10,000 1 10,000 50,000 500,000,000

Hexachlorodibenzofuran 2,3,4,6,7,8

- 1 10,000 1 10,000 50,000 500,000,000

Indeno (1,2,3

- cd) pyrene 1 , 3

- 6,OR 1,000 1 1,000 50,000 50,000,000

Isopropylbenzene 4 1

, 3 10 0.4 4 500 2,000

Lead 1, 3 10,000 1 10,000 5,000 50,000,000

Manganese 3

- 5 10,000 1 10,000 500 5,000,000

Mercury 1, 3, 5 10,000 1 10,000 50,000 500,000,000

Methylphenol, 2

- 3

Methyl phenol, 4

- 3 10 0.0007 0.007 50 0.35

Methylcyclohexane 1 , 3, 4

2

- Methylnaphthalene 1 , 3

- 6, OR 1,000 0.4 400 50,000 20,000,000

Naphthalene 1 , 3

- 6, OR 1,000 0.4 400 50,000 20,000,000

Nickel 3, 4, 6 10,000 1 10,000 5 50,000

Oct a chlorodibenzo

- p

- dioxin (OCDD) 1 10,000 1 10,000 5,000 50,000,000

Pentachlorodibenzofuran 2,3,4,7,8

- 1 10,000 1 10,000 50,000 500,000,000

Phenanthrene 1 , 3

- 6,OR 1 0.4 0.4 5,000 2,000

Phenol 4 10 1 10 50 500

Pyrene 1 , 3

- 6,OR 100 1 100 50,000 5,000,000

Styrene 3 10 0.4 4 50 200

Tetrachloroethene 5 1

, 3 100 0.4 40 50 2,000

Toluene 1 , 3, 4 10 0.4 4 50 200

Vanadium 4 10,000 1 10,000 500 5,000,000

Vinyl Chloride 1, 4 10,000 0.0007 7 5 35

Xylene, m

- & p

- 1 , 3, 4 100 0.4 40 50 2,000

Xylene, o

- 1 , 3, 4 100 0.4 40 50 2,000

Zinc 3, 5 10 1 10 500 5,000



### September 2016 

### 82SWOF/

Human Food Chain

- Toxicity/Persistence/Bioaccumulation

* Persistence values assigned are based on Mermentau River, which is a perennially flowing water classified as a River.

** Bioaccumulation values are food chain values assigned based on the surface water category of fresh water (Ref. 27, p.1).

1 Aroclor

- 1254 is listed as polychlorinated biphenyls (PCBs) in the Superfund Chemical Data Matrix (SCDM) and given a general value (Ref. 2, p. 8).

2 Dichloroethene, 1, 2

- cis

- is listed as d ichloroethylene, 1,2

- cis

- in the SCDM (Ref. 2, p. 4 ).

3 Fluoranthene is listed as b enzo( j,k )f luoranthene in the SCDM (Ref. 2, p. 2).

4 Isopropylbenzene is listed as cumene in the SCDM (Ref. 2, p. 3 ).

5 Tetrachloroethene is listed as t etrachloroethylene in the SCDM (Ref. 2, p. 9 ).

OR

– Substance documented in the observed release



### The hazardous substances with the highest Toxicity/Persist ence/Bioaccumulation Factor Value s are

aro clor -1254, benzo(a)pyrene, cadmium, dibenz(a,h)anthracene, hexachlorodibenzo-p-dioxin 1,2,3,7,8,9-, hexachlorodibenzofuran 1,2,3,4,7,8- , hexachlorodibenzofuran 1,2,3,6,7,8 -, h exachlorodibenzofuran 2,3,4,6,7,8

- , mercury, and p entachlorodibenzofuran 2,3,4,7,8-.

Toxicity/Persistence/Bioaccumulation Factor Value: 500,000,000

83SWOF/Human Food Chain

- Hazardous Waste Quantity



### 4.1.3.2.2 Hazardous Waste Quantity

Source Number Source Hazardous Waste Quantity Value (Section 2.4.2.1.5) Is Source Hazardous Constituent Quantity Data Complete? (yes/no)

1 1,827.79 No

3 882.69 No

4 65.44 No

5 9,615.38 No

6 1,383.56 No

TOTAL 13,744.86

The sum of the source 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, rounded to the nearest inte ger, is 13,745.

Sum of Values: 13,745 Hazardous Waste Quantity Assigned: 10,000 (Ref. 1 Table 2-6)

September 2016 

### 84SWOF/Human Food Chain

- Hazardous Waste Quantity



### 4.1.3.2.3 Waste Characteristics Factor Category Value

The waste characteristics factor category value is assigned based on the Waste Characteristics Product. The Waste Characteristics Product is the product of the Toxicity/Persistence Factor Value and the Hazardous Waste Quantity Factor Value subject to a max imum of 1 x 10 8 

### . This product is multiplied by the Bioaccumulation Potential Factor Value subject to a maximum value of 1 x 10 12 

### . The hazardous

substances with the highest Toxicity/Persistence/Bioaccumulation factor value s for the watershed Aroclor-1254, benzo(a)pyrene, cadmium, dibenz(a,h)anthracene, hexachlorodibenzo-p-dioxin 1,2,3,7,8,9-, hexachlorodibenzofuran 1,2,3,4,7,8- , hexachlorodibenzofuran 1,2,3,6,7,8 -, h exachlorodibenzofuran 2,3,4,6,7,8

- , mercury, and p entachlorodibenzofuran 2,3,4,7,8- (Ref. 1, Section

4.1.3.2.1.4 ).

Toxicity/Persistence Factor Value: 10,000 x Hazardous Waste Quantity Factor Value: 10,000

(Toxicity/Persistence x Hazardous Waste Quantity):
10,000 X 10,000 = 1 X 10 8


### (Subject to a maximum product of 1.0 x 10 8



### Bioaccumulation Potential Factor Value: 50,000 (Toxicity/Persistence x Hazardous Waste Quantity) x

Bioaccumulation Potential Factor Value:

(1 X 10 8 

### ) X (50,000) = 5.0 X 10 12


### (Subject to a maximum product of 1.0 x 10 12 

### )

A Waste Characteristics Product value of 1.0 X 10 12 

### receives a waste characteristics factor

value of 1,000 (Ref. 1, Table 2-7 ).

Hazardous Waste Quantity Assigned Value: 10,000 Waste Characteristics Factor Category Value: 1,000

85SWOF/Human Food Chain

- Targets



### 4.1.3.3 HUMAN FOOD CHAIN THREAT

- TARGETS

Largemouth b ass , crappie, b ream, b luegill , c atfish , g ar , b ullhead , c arp , s triped b ass and sunfish are caught from Lake Arthur (Ref. 15, p. 1). Mermentau River is also fished recreational as was observed and documented during the September 2014 ESI (Ref. 7, pp. 34 & 89-90 ). During the September 2014 ESI, a family of five was observed fishing in the Barge Slip (PPE 2) adjacent to the Mermentau River (near sample location SBA

‐ ESI

‐ 05 and PPE 2). The family stated that they do not fish in the barge slip often, but when they do, they only catch catfish for consumption (Ref. 7, pp. 34 & 984-992). The Mermentau River is fished recreationally, as is evident by the fishermen observed during the ESI during sediment sample collection al ong the Mermentau River (Ref. 7, pp. 89- 91).

4.1.3.3.1 Food Chain Individual

A food chain individual factor value of 45 is assigned based on an observed release by chemical analyses of a cenaphthene , anthracene, barium, benzo(a)anthracene, benzo(a)pyren e, benzo(k)fluoranthene, cadmium, c arbazole , copper, dibenz(a,h)anthracene , d ibenzofuran, fluoranthene (benzo(j,k) fluoranthene), fluorene, i ndeno (1,2,3

- cd) pyrene, lead, manganese, mercury, 2- methylnaphthalene, n aphthalene , nickel, p henanthrene

, pyrene, vanadium and zinc sediments within

the fishery present in the barge slip, a branch of the Mermentau River (Sec. 4.1.3.2.3 )( Ref.1, Sec. 4.1.3.3.1; Ref. 2, pp. 1-5, 7-8 & 10; Ref. 7, pp. 984-992; Figure 6; Table s 11 & 12 ).

Food Chain Individual Fa ctor Value: 45 (Ref. 1, Section 4.1.3.3.1)

86SWOF/Human Food Chain

- Targets



### 4.1.3.3.2 Population

The Population Factor for the watershed is based on three factors: Level I concentrations, Level II concentrations, and potential human food chain contamination.

4.1.3.3.2.1 Level I Concentrations

There are no Level I concentrations established because there were no tissue samples collected ( Ref. 1,

Sec. 4.1.3.3.2.1 ).

4.1.3.3.2.2 Level II Concentrations

Level II concentrations have been established for approximately 1,300 feet of the Mermentau River (Figure 5 ). During the September 2014 ESI, a family of five was observed fishing in the Barge Slip (PPE 2) adjacent to the Mermentau River (near sample locat ion SBA

‐ ESI

‐ 05). The family stated that they do not fish in the barge slip often, but when they do, they only catch catfish for consumption (Ref. 7, pp. 984 & 987 ). Recreation fishing is common , and conducted within the Mermentau River ( Ref. 7, pp. 34 & 988-991). The Louisiana Department of Wildlife and Fisheries (LDWF) does not keep records on pounds of fish caught and consumed annually per water body; however, fishing for consumption is known to occur within the zone of Level II contamination as discussed above. Therefore, a human food chain population value of 0.03 is assigned for production greater than zero (>0) and less than 100 (<100) pounds per year of annual human consumption (Ref. 1, Table 4-18 ; Ref. 7, pp. 34, 89-91, 149 & 984-

992 ).

Level II Human Food Chain Contamination Factor Value: 0.03 (Ref 1, Table 4 -18)

4.1.3.3.2.3 Pot ential Human Food Chain Contamination

Recreation fishing is common in the Mermentau River and Lake Arthur

. Recreational fishing is conducted within Mermentau River ( Re f. 7, pp. 34, 984 & 988-981). The Louisiana Department of Wildlife and Fisheries (LDWF) does not keep records on pounds (lbs) of fish caught and consumed annually per water body; therefore the most conservative estimate of fish caught and consumed annually (0 lbs < 100 lbs) from the Mermentau River and Lake Arthur will be used (Ref. 7, pp. 34, 89-91, 149 & 984-992).

According to gauging station 08012150, located in Jefferson Davis Parish in Mermentau, Louisiana, approximately 3.0 miles upstream of site, the average annual flow rate of the Mermentau River as measured for water year 1990 through 2015 is 1,975.82 cfs (Ref. 11, pp. 1-2 ). The flow rate for the Mermentau river falls into the large stream to river category which has an assigned dilution value of 0.001 (Ref. 1, Table 4- 13).

No gauging stations are located in Lake Arthur. The flow rate at that target location was extrapolated using the flow data for Mermentau River and for the headwaters of Bayou Lacassine near Lake Arthur (Ref. 11, pp. 1-2; Ref. 12, pp. 1-2). According to gauging station 08012470 located at Bayou Lacassine near Lake Arthur, Louisiana the average annual flow rate of Bayou Lacassine as measured for water year 1988 through 2005 is 594.18 cfs. Lake Arthur will set to the average flow rate of 2,570 cfs based

87SWOF/Human Food Chain

- Targets



### on Bayou Lacassine and Mermentau River average annual flow rate. Therefore, Lake Arthur will be

considered to be a large stream to river and will be assigned a dilution value of 0.001 (Ref. 1, Table 4- 13).

Table 1 4 – Fishery Identification Study

Identity of Fishery Annual

Production

(pounds) Type of

Surface

Water Body Average

Annual

Flow Population Value (P i 

### ) Dilution Weight

(D i 

### ) P i 

### xD i 

### Reference

Mermentau

River 

### >0

- 100 Large

stream

to R iver 1,975.82

cfs 0.03 0.001 0.00003 Ref.1,

Tables 4

- 13; Ref. 11, pp. 1-2

Lake

Arthur >0

- 100 Large

stream

to R iver 2,570 cfs 0.03 0.0 0 1 0.0 0 003 Ref.1,

Tables 4

- 13; Ref. 12,

p. 1

- 2

Sum: 0.00006 (Sum of P1 x 01)/10: 0.000006

Potential Human Food Chain Contamination

Factor Value: 6.0 x 10 -6



### 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 ( 0.03) + Potential Human Food Chain Contamination (0.000006) = 0.030006.

A value of 3.0006 x 10 -2 

### is assigned as the Population Factor Value.

Population Factor Value: 3.0006 x 10 -2



### 88SWOF/Human Food Chain

- Targets



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

Food Chain Individual + Population Factor = 45 + 0.030006 = 45.030006

Target Factor Category Value: 45.030006

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 likelihood of release, waste characteristics, and targets for the watershed ( Ref. 1,

Section 4.1.3.4 ).

Likelihood of Release (550) x Waste Characteristics ( 1,000 ) x Targets (45.030006) = 24,766,503 (rounded to the nearest integer).

This product is then divided by 82,500:

24,766,503 ÷ 82,500 = 300.20

The resulting value, subject to a maximum of 100, is assigned as the Human Food Chain Threat Score.

Human Food Chain Threat Score= 100

89SWOF/Environment al

- Toxicity/Persistence/Bioaccumulation



### 4.1.4.2 ENVIRONMENTAL THREAT - WASTE CHARACTERISTICS

4.1.4.2.1 Ecosystem Toxicity/Persistence/Bioaccumulation

The environmental threat waste characteristics section provides the ecosystem toxicity, persistence and bioaccumulation factor values for hazardous substances that are available to migrate from sources at the site to surface water in the watershed via the overland/flood hazardous substances migration path for the watershed (Ref. 1, Section 4.1.4.2.1), the hazardous waste quantity value for the watershed (Ref. 1, Section 4.1.4.2.2), and the calculation of the environmental threat- waste characteristics factor category value. The highest combined ecosystem toxicity, persistence and eco bioaccumulation factor is used to

determine the waste characteristics factor value for the environmental threat of the surface water migration pathw ay (Ref. 1, Section 4.1.4.2.3)

Hazardous substances that meet the criteria for an observed release to surface water and all hazardous substances associated with the sources that have a surface water containment factor value greater than 0 for the watershed are presented in Table 1 5 below. Each hazardous substance eligible to be evaluated is assigned an ecosystem toxicity/persistence/bioaccumulation factor value. The hazardous substance with the highest ecosystem toxicity/persistence/ eco bioaccumulation factor value for the watershed is used to assign the value to this factor (Ref. 1, Section 4.1.4.2.1.4).

90SWOF/Environment al

- Toxicity/Persistence/Bioaccumulation



### Table 1 5- Ecosystem Toxicity/Persistence/EcoBioaccumulation Factor Summary

Hazardous Substance Source No. Eco Toxicity

Factor

Value Persistence

Factor

Value* Eco Toxicity/

Persistence

Factor Value (Table 4

- 12) Bioaccumulation

Factor Value ** Eco Toxicity/Persistence/

Bioaccumulation Factor

Value (Table 4 -16) Reference

Acenaphthene 1 , 3, 4, 6 , OR 500 0.4 200 500 10,000

Ref. 1, Table

4- 12, 4 -16; Ref. 2, pp. 1

- 10 Acenaphthylene 1 , 3

- 6, OR 0 0.4 0 500 0

Anthracene 1 , 3

- 6, OR 10 ,000 0.4 4,000 50,000 200,000 ,000

Aroclor

- 1254 1 5 10,000 1 10,000 50,000 500,000,000

Arsenic 1, 3

- 5 10 1 10 5 0,000 5 0 0,000

Barium 3 1 1 1 500 500

Benzene 1, 3, 4 1,000 0.4 400 5,000 2,000,000
Benzo(a)anthracene 1 , 3

- 6, OR 1 0 ,000 1 1 0 ,000 50,000 5 0 0,000,000 Benzo(a)pyrene 1 , 3

- 6, OR 10,000 1 10,000 50,000 500,000,000 Benzo(g,h,i)perylene 1 , 3

- 6, OR 0 1 0 50,000 0
Benzo(b)fluoranthene 1 , 3

- 6, OR Benzo(k)fluoranthene 1 , 3

- 6, OR 0 1 0 50,000 0 Beryllium 4, 6 1,000 1 1,000 50 50,000 Biphenyl, 1,1'

- 1, 3, 4 Bis (2

- ethylhexyl) phthalate 3 1 ,0 00 1 1 ,0 00 50,000 5 0 ,000,000

Cadmium 3, 4 10,000 1 10,000 50,000 500,000,000

Carbazole 1 , 3

- 6, OR 1 ,00 0 1 1 ,00 0 500 5 00 ,000

Chromium 1 10,000 1 10,000 500 5,000,000 Chrysene 1 , 3

- 6, OR 1 ,00 0 1 1 ,00 0 5 ,000 5

, 0 00,000

Cobalt 1

, 3, 5, 6 0 1 0 50 0 Copper 3

- 5 1 ,0 00 1 1 ,0 00 50,000 5 0 ,000,000 Cyclohexane 1 , 3, 4 Dibenz(a,h)anthracene 1

, 3, 5, 6, OR 0 1 0 50,000 0

Dibenzofuran 1 , 3

- 6,OR 1,000 0.4 400 500 200,000
Dichlorobenzene, 1,2

- 1

, 3
Dichlorobenzene, 1,4

- 3 1 ,00 0 0.4 400 5,000 2 0 0,000
Dichloroethene, 1,2

- cis

2 3, 4 0 1 0 50 0 Dimethyl phenol, 2,4

- 3 100 1 100 500 50,000 Ethylbenzene 1, 3, 4 1 0 0 0.4 40 50 2 ,0 00

Fluoranthene 3 1 , 3

- 6,OR 1 0,0 00 1 1 0,0 00 5,000 5 0,0 00,000

Fluorene 1 , 3

- 6,OR 1 ,0 00 0.4 4 0 0 5 ,0 00 2 ,00 0,000

Hexachlorodibenzo

- p

- dioxin 1,2,3,7,8,9

- 1 0 1 0 50,000 0
Hexachlorodibenzofuran 1,2,3,4,7,8

- 1 0 1 0 50,000 0
Hexachlorodibenzofuran 1,2,3,6,7,8

- 1 0 1 0 50,000 0
Hexachlorodibenzofuran 2,3,4,6,7,8

- 1 0 1 0 50,000 0
Indeno (1,2,3

- cd) pyrene 1 , 3

- 6,OR 0 1 0 50 0 Isopropylbenzene 4 1

, 3 10 0 0.4 4 500 2 0 ,000

Lead 1, 3 1,000 1 1,000 5 0 ,000 50,000,000 Manganese 3

- 5 100 1 100 5 0,0 00 5,000,000
Mercury 1, 3, 5 10,000 1 10,000 50,000 500,000,000 Methyl phenol, 2

- 3 Methyl phenol, 4

- 3 10 0 0.0007 0.07 50 3.5 Methylcyclohexane 1 , 3, 4

2

- Methylnaphthalene 1 , 3

- 6, OR 1 0 00 0.4 4 0 0 50,000 2,000,000 Naphthalene 1 , 3

- 6, OR 1,000 0.4 400 50,000 20,000,000

Nickel 3, 4, 6 100 1 100 5 0 5,000

Octachlorodibenzo

- p

- dioxin (OCDD) 1 0 1 0 50,000 0
Pentachlorodibenzofuran 2,3,4,7,8

- 1 0 1 0 50,000 0

Phenanthrene 1 , 3

- 6,OR 1 0,000 0.4 4,000 5 0 ,000 2 00,000 ,000

Phenol 4 10 ,000 1 10 ,000 50 ,000 500 Pyrene 1 , 3

- 6,OR 100 1 100 50,000 5 00 ,000,000 Styrene 3 10 0 0.4 4 0 50 2 ,0 00

Tetrachloroethene 5 1

, 3 100 0.4 40 50 2,000

Toluene 1 , 3, 4 10 0 0.4 4 0 5 ,00 0 200 ,000

Vanadium 4 100 1 100 50,000 5,000,000 Vinyl Chloride 1, 4 0 0.0007 0 5 0 Xylene, m

- & p

- 1 , 3, 4 Xylene, o

- 1 , 3, 4 100 0.4 40 50 2,000

Zinc 3, 5 10 1 10 5 0,0 00 5 00 ,000

* Persistence values assigned are based on Mermentau River, which is a perennially flowing water classified as a River.

** Bioaccumulation values are assigned based on the surface water category of fresh water (Ref. 27, p.1).

1 Ar o clor

- 1254 is listed as p olychlorinated biphenyls (PCBs) in the Superfund Chemical Data Matrix (SCDM) and given a general value (Ref. 2, p. 8).

2 Dichloroethene, 1, 2

- cis

- is listed as d ichloroethylene, 1,2

- cis

- in the SCDM (Ref. 2, p. 4 ).



### September 2016 

### 91SWOF/Environment al

- Toxicity/Persistence/Bioaccumulation

3 Fluoranthene is listed as benzo(j,k) fluoranthene in the SCDM (Ref. 2, p. 2).

4 Isopropylbenzene is listed as cumene in the SCDM (Ref. 2, p. 3 ).

5 Tetrachloroethene is listed as t etrachloroethylene in the SCDM (Ref. 2, p. 9 ).

OR

– Substance documented in the observed release



### The contaminant with the highest Ecosystem Toxicity/Persistence/Bioaccumulation Factor Value are Aroclor-1254, benzo(a)anthracene, benzo(a)pyrene, cadmium, mercury and pyrene (Ref. 1, Table 4-21; Ref. 2, pp. 2, 6-8 & 10 ).

Ecosystem Toxicity/Persistence/Bioaccumulation Factor Value: 500,000,000

92SWOF/Environment al

- Hazardous Waste Quantity



### 4.1.4.2.2 Hazardous Waste Quantity

Sum of Values: 13,745

September 2016 

### Source Number Source Hazardous Waste Quantity Value (Section 2.4.2.1.5) Is Source Hazar dous Constituent Quantity Data Complete? (yes/no)

1 1,827.79 No

3 882.69 No

4 65.44 No

5 9,615.38 No

6 1,383.56 No

TOTAL 13,744.86

The sum of the source 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, rounded to the nearest integer, is 13,745. For a Hazardous Waste Quantity range of greater than 10,000 to 1,000,000, a value of 10,000 is assigned from Ref. 1, Table 2-6 for the migration pathway (Ref. 1, Sec. 2.4.2.2, Table 2-6).

Hazardous Waste Quantity Factor Value: 10,000 (Ref. 1 Table 2

- 6)

93SWOF/Environment al

- Hazardous Waste Quantity



### 4.1.4.2.3 Waste Characteristics Factor Category Value

A Waste Characteristics Factor Category Value is assigned based on the Waste Characteristic Product. The hazardous substances with the highest ecosystem toxicity/persistence/bioaccumulation factor valu e for the watershed are aroclor -1254, b enzo(a)pyrene , cadmium, dibenz(a,h)anthracene, hexachlorodibenzo-p-dioxin 1,2,3,7,8,9-, hexachlorodibenzofuran 1,2,3,4,7,8-, hexachlorodibenzofuran 1,2,3,6,7,8-, hexachlorodibenzofuran 2,3,4,6,7,8-, mercury, pentachlorodibenzofuran 2,3,4,7,8- , and vanadium (Ref. 1, Section 4.1.4.2.3). These values are used to determine th e water characteristic product. The Waste Characteristic Product is the product of the Ecosystem Toxicity/Persistence/ Factor

Value and the H azardous Waste Quantity Factor Value subject to a maximum product of 1 x 10 8



### . This product is multiplied by the Ecosystem Bioaccumulation Potential Factor Value Subject to a maximum product of 1 x 10 12



### .

Using HRS Table 4 -20 and Table 15 of this HRS docu mentation record, the Ecosystem Toxicity/Persistence value for Aroclor-1254, benzo(a)anthracene, b enzo(a)pyrene , cadmium, mercury, and pyrene is 10,000.

A Hazardous Waste Quantity Factor Value of 10,000 is assigned from the sum of Source Hazardous Waste Q uantity Value and the documented observed release (Ref. 1, Section 2.4.2.2, Table 2- 6).

Ecosystem Toxicity/Persistence Factor Value= 10,000 Hazardous Waste Quantity Factor Value = 10,000 10,000 X 100 =1.0 X 10 8


### (Subject to a maximum product of 1.0 x 10 8



### The Ecosystem Bioaccumulation Value for Aroclor -1254, benzo(a)anthracene, b enzo(a)pyrene

, cadmium, mercury and pyrene is 50,000 (Ref. 2, pp. 2, 6-8 & 10 ).

Ecosystem Bioaccumulation Value = 50,000

(Ecosystem Toxicity/Persistence x Hazardous Waste Quantity) x Bioaccumulation Factor Value:

(1 X 10 8 

### ) X (50,000) = 5 x 10 12



### (Subject to a maximum product of 1 x 10 12 

### )

A Waste Characteristics Product Value of 1 x 10 12 

### receives a Waste Characteristic Factor Value of 1,000 (Ref. 1, Table 2-7 ).

( Ecosystem Toxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value ) x Bioaccumulation Factor Value: 1 x 10 12



### Waste Characteristics Factor Value: 1,000

94S WOF/Environmental

- Targets



### 4.1.4.3 ENVIRONMENTAL THREAT - TARGETS

4.1.4.3.1 Sensitive Environments

4.1.4.3.1.1 Level I Concentrations

No water, benthic, or tissue samples have been collected within the Surface Water Pathway; therefore, Level l concentrations are not being scored (Ref. 1, Sec. 4.1.4.3.1.1).

Level I Concentrations Factor Value: 0

95SWOF/Environment al

- Level II Concentrations



### 4.1.4.3.1.2 Level II Concentrations

Wetlands, as identified on National Wetland Inventory (NWI) as a PFO2/1F designation, palustrine forested needle-leaved deciduous/broad leaved deciduous wetland, meets the 40 CFR 230.3 definition of a wetland, are located on the southeast side of SBA and along the east 

### bank of the Merment au River, a cross from PPE 1 and PPE 2, and are conti guous with the Mermentau River (Ref. 4, pp. 116-127; Ref. 7, pp. 135 &

139-142 ; Ref. 10, pp. 1-4; Ref. 40, pp. 1-2 ).

Level II concentrations have been establish ed in the wetlands by chemical analysis of wetland samples

that met observed release criteria ( Tables 11 & 12). The total frontage of wetlands subject to Level II contamination is approximately 2,823 feet ( Figure 5). The frontage of Wetland 1 is determined by the distance, approximately 1,380 feet, measured from PPE 1 (Sample SBA -029SD) to PPE 3 (SBA -030SD) along the left descending bank of the Mermentau River and the continuous wetland (Figure 5) . The frontage for Wetland 2 is determined by the distance, approximately 1,160 feet, measured from the

northwest corner of the wetlands (SBA -033SD) to the Mermentau R iver ( Figure 5 ). The frontage of Wetland 3 is determined to by the length of the Former Water Pit 3, approximately 283 feet (Ref. 6, p. 8). A value of 25 is assigned from Table 4-24 of the HRS for the approximate 2,823 feet of wetland subj ect to Level II contamination (Ref. 1, sec. 4.1.4.3.1.2 ).

Threatened and endangered species have been reported within the general area; however, it is not known if their habitats overlap the z one of Level II contamination therefore , t hese other sensitive environments will not be evaluated. The Level II concentration factor value is the sum of the wetlands value (25) and sensitive environments value (0):

25 + 0 = 25

Level II Concentrations Factor Value: 25 (Ref. 1, Sec. 4.1.4.3.1.2 and Tab le 4 -24)

96SWOF/Environment al

- Potential Contamination



### 4.1.4.3.1.3 Potential Contamination

W etlands

Palustrine forested needle-leaved deciduous/broad leaved deciduous wetlands, as identified on NWI that

are semi

- permanently flooded are located on the frontage along the Mermentau River and Lake Arthur (Ref. 4, pp. 116 & 119-127; Ref. 7, pp. 140-141; Ref. 10, pp. 1-4; Ref. 40, pp. 1-2 ). These wetlands meet the criteria as defined in 40 CFR 230.3, clas sified in the palustrine system and subcategory of a

forested wetland (Ref. 10, pp. 1 - 4). The wetland frontage along the Mermentau River was measured

from National Wetland Invento ry (NWI) maps (Ref. 10, p. 5).

Type of Surface

Water Body Wetland Frontage ( miles ) Reference Wetland Value (Ref. 1, Table 4

- 24)

Mermentau River 20.4 Ref. 10 , p. 2 ; Figure 6 500

Lake Arthur 4.05 Ref. 10 , p. 2 ; Figure 6 150

To obtain the Potential Contamination Factor Value, the sum of the sensitive environments value is added to the wetland value, which is then multiplied by the assigned dilution for each in- water segment. This value is then divided by 10 to obtain the Potential Contamination Factor Value (Ref. 1, Section 4.1.4.3.1.3).

Type of Surface

Water Body Sum of Sensitive

Environment

Values (Sj) Wetland Frontage Value ( W j) Adjusted

Dilution Weight ( D j) ( W j + Sj) Dj

Mermentau River 0 500 .001 0. 5

Lake Arthur 0 150 .001 0.15

Potential Contamination Factor Value

0.65/10 = 0.065

Sum of Sensitive Environments Value+ Wetland Value: 0

Potential Contamination Factor Value: 0.065

97SWOF/Environment al

- Factor Category Value



### 4.1.4.3.1.4 Environmental Threat- Targets Factor Category Value

The environmental threat target facto r category value for the watershed is the sum of the values for the Level l (0), Level II (25), and Potential Contamination factors (0.065 ) (Ref. 1, Section 4.1.4.3.1.4 ).

0 + 25 + 0. 065 = 25.065

4.1.4.4 Calculation of Environmental Threat Score

The enviro nmental threat score is calculated by multiplying the environmental threat factor category values for likelihood of release (550), waste characteristics (1,000 ), and targets ( 25.07 ) for the watershed; rounding the product to the nearest integer; and dividing by 82,500. The resulting value (167.13), subject to a maximum of 60, is assigned as the environmental threat score for the watershed (Ref. 1, Sections 4.1.4.4 and 4.1.4.3.1.4 ).

Calculations: 550 X 1,000 X 25.065 = 13,785,750/82,500 = 167.1 (subject to a maximum of 60)

4.1.5 Calculation of Overland/Flood Migration Component Score for a Watershed

The overland/flood migration component score for the watershed is calculated by summing the scores for the drinking water threat (0), human food chain threa t ( 100), and environmental threat (60 ) assigned as the surface water overland/flood migration component score for a watershed (Ref. 1, Section 4.1.5 ).

Calculations:

0 + 100 + 60 = 160 (subject to a maximum value of 100)

4.1.6 C alculation of Overland/Flood Migration Component Score

The highest surface water overland/flood migration component score from the watersheds evaluated (in this case, only one watershed was evaluated) is selected and assigned as the surface water overland/flood migration component score for the site, subject to a maximum of 100. The overland/flood migration component score is assigned a value of 100 (Ref. 1, Section 4.1.6 ).

98S WOF

– Pathway Score



### 4.2 GROUND WATER TO SURFACE WATER MIGRATION COMPONENT

This component was not scored because an observed release was documented for the overland flow/flood component.

4.3 CALCULATION OF SURFACE WATER MIGRATION PATHWAY SCORE

The overland/flood migration component was scored and this value (100) is assigned to the surface water migration pathway score.

Ground Water to Surface Water Factor Value: NS Surface Water Migration Pathway Score: 100

99