HRS DOCUMENTATION RECORD COVER SHEET

Name 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 significantly affect the

listing decision (Ref. 1, Sec. 2.2.3).

2) Surface Water Pathway: Ground Water to Surface Water Migration Component: The

overland/flood migration component of the Surface Water Migration Pathway has been scored

for the Human Food Chain Threat and Environmental Threat. The Ground Water to Surface

Water Migration component has not been scored. Based on information available at this time,

evaluation of this component would not significantly affect the listing decision (Ref. 1, Sec.

2.2.3).

3) Air Migration 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: Based on information available at this time, further evaluation 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

Name 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: 92o 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 general 

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 scoring 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 Sources with Site Inspection & Expanded Site Inspection Sampling Locations 

Figure 4 PPE Locations 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 references 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 

place 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

BGSBelow Ground Surface

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

CFSCubic feet per second

DRO Diesel Range Organics

COC Contaminants of Concern

ERT Environmental Response Team

ESIExpanded Site Inspection

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

PAHPolycyclic Aromatic Hydrocarbons

PCBPolychlorinated Biphenyl

PID Photoionization Detector

PPE Probable Point of Entry

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

yd3 Cubic Yards

4
Figure References

Figure 1: 

Base Map Source* 2013 National Geographic Society, i-cubed

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

Figure 2:

Base Map Source* Esri**, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, 

IGN, IGP, swisstopo, and the GIS User Community 

*Map 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.

Figure 3: 

Base Map Source* Esri**, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, 

IGN, IGP, swisstopo, and the GIS User Community 

*Map Annotated by EPA START-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.

Figure 4: 

Base Map Source* Esri**, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, 

IGN, IGP, swisstopo, and the GIS User Community 

*Map 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.

Figure 5

Base Map Source* Esri**, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, 

IGN, IGP, swisstopo, and the GIS User Community 

*Map 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.

Figure 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.

*Map annotated by EPA START-3 on 7/15/2015 for Surface Water Flow, Common Drainage,

Facility Boundary, Wetland delineation 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 source 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 1,250 2,500 5,000

Feet
Land 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

0 150 300 600Feet

^_

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-004 SBA-002

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 2016

.

1:5,000

0 125 250 500 750 1,000Feet

^_

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

Sources
Main 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 2016

.

1:5,000

0 125 250 500 750 1,000Feet

^_

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

0 125 250 500 750 1,000Feet

^_

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 0.5 0 1 Miles

.

1:75,000
WORKSHEET FOR COMPUTING HRS SITE SCORE

s 

1. Ground Water Migration Pathway Score (Sgw) 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 (Ssw) 100.00 

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

3. Soil Exposure Pathway Score (Ss) NS

4. Air Migration Pathway Score (Sa) NS

2 2 5. Total of Sgw +Ssw2

+Ss

2

+Sa

6. HRS 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 THREAT

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 THREAT (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 THREAT

Likelihood of Release

14. Likelihood of Release

(Same value as Line 5) 550 550

Waste Characteristics

15. Toxicity/Persistence/Bioaccumulation * 5x108

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 ** 0.03

19c. Potential Contamination ** 0.000006

19d. Population (Lines 10a+10b+10c) ** 0.030006

20. Targets ** 45.030006

(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 108

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) ** 25.065

27. Targets

(Value from Line 26d) ** 25.065

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)

100 100.00

Maximum value applies to waste characteristic category

Maximum value applicable

Do not round to the nearest integer

16 
REFERENCE SHEET

Ref.

No. Description of the Reference

1. U.S. EPA. Hazard Ranking System (HRS); Final Rule. Federal Register. Volume 55, Number

241.Washington, DC: U.S. Government Printing Office, December 14, 1990. Title Page only. A

complete version of this document is available online at:

https://semspub.epa.gov/work/HQ/174028.pdf

2. U.S. EPA Superfund Chemical Data Matrix. Appendix B. June 20, 2014. Excerpt Pages: 13. A

complete version of SCDM is available at:

https://www.epa.gov/superfund/superfund-chemical-data-matrix-scdm 

3. U.S. Geological Survey (USGS). 7.5’ Topographic Quadrangle. Mermentau Quadrangle

Louisiana. 2012. Total Pages: 1.

4. Dynamac Corp. Site 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. Michael Pisani and Associates Inc. Interim Measures/Removal Action Completion Report. SBA

Shipyards Site, Jennings, Louisiana. August 15, 2005. Total Pages: 629.

6. Woodward-Clyde Consultants. RCRA Facility Investigation Work Plan. SBA Shipyard Site,

Jennings, Louisiana. Prepared for SBA Shipyard, Inc. October 1996. Total Pages: 98.

7. Dynamac Corp. Expanded Site Inspection Report. SBA Shipyard Inc., Jennings, Jefferson 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 Davis Parish, Louisiana. Total Pages:

234.

9. Dynamac Corporation. Preliminary Assessment Report for SBA Shipyard, Jennings, Jefferson

Davis Parish, Louisiana. Prepared for U.S. EPA Region 6. June 3, 2013. Total Pages: 66.

10. U.S. Fish and Wildlife Service. National Wetlands Inventory. Wetland Mapper Digital Wetland

Map and Wetlands and Deepwater Habitats Classification Key. Accessed at

http://www.fws.gov/wetlands/Data/Mapper.html &

http://www.fws.gov/wetlands/Documents/Wetlands-and-Deepwater-Habitats-Classificationchart.pdf. February 26, 2015 and March 2, 2015. Total Pages: 5.

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

USGS 08012150 Mermentau River At Mermentau, LA. Accessed at 

September 2016 17 
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-MMDD&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-MMDD&rdb_compression=file&submitted_form=parameter_selection_list. Accessed

July 7, 2015. Total Pages: 2. 

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

Interest # 1478. July 30, 2008. Total pages: 1.

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

Accessed at http://www.wlf.louisiana.gov/sites/default/files/pdf/publication/31745-commercialfishing-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 Facility Investigation Work Plan. SBA

Shipyard Site, Jennings, Louisiana. Prepared for SBA Shipyard, Inc. September 1996. Total

Pages: 5.

17. FTN Associates, Ltd. Lake Arthur, Grand Lake, and Gulf Intercostal Waterway TMDLS For

Dissolved Oxygen, Nutrients, and Ammonia. Prepared for U.S. EPA Region 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: 11.

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, Jefferson 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. Envirofacts. 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 an

Observed Release and Observed Contamination. Publication 9285.7-14FS. November 1996. Total

Pages: 18.

32. Woodward-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 Pages: 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 Redrope#2 -

9535410. Dates: October 29, 1984 and June 3, 1981. Page Numbers: 115 and 197. Total Pages:

246.

46. SBA Shipyard. Work Orders, Invoices, 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, 1986; August 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 Mechling - 

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. Total 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. From 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 Environmental 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 sources 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 contaminations (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 (COCs) 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, pp. 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 scored; the third barge slip is 

applicable and will be considered in the site HRS scoring (Figure 2). The 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 held 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 review of the MSDSs 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 - methyl 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 operations area (Ref. 16, p. 2; Ref. 36, p. 38); The 

first step in cleaning and gas freeing barges was to remove the gross 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 pressure 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 were 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 of 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). Waste water was stored in two of the surface impoundments, the Oil Pit and Pit No. 2 

prior to closure of the surface impoundments (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.

Wastes 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, methylmethacrylate, methanol, caustic soda, styrene, coal tar, vinyl acetate, carbon tetra chloride, ethyl acrylate

and acrylates (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, pp .1, 4-12 & 19-41). Since approximately 1970, D018 

23 
(EPA Hazardous Waste Code – benzene), D043 (EPA Hazardous Waste Code – vinyl chloride) and 

D019 (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 waste 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 Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) 

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, methyl-methacrylate, 

methanol, caustic soda, styrene, coal tar, vinyl acetate, carbon tetra chloride, ethyl acrylate and acrylates

(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). Chemical 

hazards at this site included: arsenic, barium, mercury, lead, benzene, chloroform, 1,1,1-trichloroethane, 

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 the only explanation for the presence 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 management 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 and 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 early1991, the bio-remediation started on May 29, 1990 on 

one of the impoundments (Water Pit 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 Hazardous Waste Division 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) and 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, and clean-up the facility (Ref. 22, p. 4; Ref. 35, pp. 5-13). In December 2002 EPA 

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 analysis 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 

analytical 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 recreationally 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). 

26 
SO-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 Treatment 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 27 
SO-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 are 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 

scrapping 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 samples 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). 

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

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

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

anthracene, acenaphthylene, benzo(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, fluoranthene, fluorene, indeno(1,2,3-cd)pyrene, 2-methylnaphthalene, 

 28 
SO-Source Characterization

Source No.: 1

naphthalene, phenanthrene and pyrene at concentrations equal to or greater than their corresponding 

report limits (RLs) (Ref. 4, pp. 29 & 70; Table 4).

Semi-volatile organic compounds (VOCs) identified included: cyclohexane, benzene, 

methylcyclohexane, 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 their 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).

 29 
SO-Source Characterization

Source No.: 1

Table 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: 

μg/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

 30 
SO-Source Characterization

Source No.: 1

Table 2- Source 1- Partially Buried Barge ESI Sample 

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 

 31 
SO-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 migrated 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- 

• Naphthalene

• Octachlorodibenzo-p-dioxin (OCDD)

• Pentachlorodibenzofuran, 2,3,4,7,8 – 

(PeCDF)

• Phenanthrene 

• Pyrene

• Tetrachloroethene 

• Toluene 

• Vinyl chloride

 32 
SO-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 Source 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 estimated 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 extrapolate a total or partial Hazardous Wastestream Quantity 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 interim measures/removal actions (IM/RA) at SBA specify that a total of 1.19 million 

gallons of pumpable oily material was pumped from the Partially Buried Barge and thermal destroyed 

(Ref. 5, p. 14). Pumpable oily material was removed from the partially buried barge till approximately 4

to 6 inches of heel remained between the structural members in the vessel, which could not be removed 

(Ref. 5, p. 14). 

After completion of the IM/RA on the Partially Buried Barge 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 Partially Buried Barge 

was later removed (Ref. 5, p. 8). The partially buried barge was ultimately emptied of all but 

 33 
SO-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 Partially Buried Barge 

were tack-welded shut (Ref. 5, p. 17). This 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 scrapping 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 Partially 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 

TOTAL 913, 897 gallons 

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

(yds3

) is 1 yd3 = 200 gallons (Ref. 1, Table 2-5, footnote b). The one time estimated capacity of the 

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

 913,897 gallons X 1 yd3

 / 200 gallons per 1 yd3 = 4,569.49 yd3

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 yd3 / 2.5 = 1,827.79 

 Volume of Source No. 1 (yd3): 4,569.49 

Reference(s): Ref. 1, Table 2-5, p. 51591 

Volume Assigned Value: 1,827.79 

 34 
SO-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 Source No. 1 in square feet (ft2

): 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 highest value assigned is Tier C. 

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

 35
SO-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: Former Water Pit 1

Number of source: 3 

Source Type: Surface Impoundment Buried/Backfilled 

Description and Location of Source: Former Water Pit 1 was a surface impoundment located on the 

southeast portion of the property, northwest of a designated 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 consisted 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 separator (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 total capacity of 9,500 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 functions 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). In 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 water and oil was pumped from 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 

formerly 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 southeast/east end of the impoundment, with accumulated rainwater 

periodically pumped to storage tanks (Ref. 6, p. 10; Ref. 24, p. 13). No information has been found 

mentioning or detailing the closure of Water Pit 1. 

The impoundment formerly known as Water Pit 1 had dimensions of approximately 160 feet x 100 feet 

x 15 feet 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 

estimated 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; Figure 3). The borings were 

advanced to a maximum depth of 16 feet below ground surface (bgs) using the procedures in the EPA 

 36 
SO-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 of 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 method CLP SOW SOM01.2 (method used - CLP OLM04.2 – GC/MS), TCL 

Pesticide/PCBs 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. 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 SBA-005 was sampled in the 

area of the former 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 gray and orange mottled coloring, and slightly plastic (Ref. 4, pp. 30, 57, 869 & 980);

• Sample SBA-002WT (10-12 feet bgs) – collected above water table; chemical odor; clay with 

silt seams, and visible product in seam (Ref. 4, pp. 30, 57& 981);

• Sample SBA-004-24 (2-4 feet bgs) – heavy chemical 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 moist stained, black (Ref. 4, p. 30, 57, 871& 985);

• Sample SBA-005PD (12-14 feet bgs) – collected at the highest PID reading; clay-ey/silt, tan 

stained dark grey coloring. (Ref. 4, pp. 31, 57, 872 & 986)

• Sample SBA-005WT (14-16 feet bgs) – collected above water table; clay-ey/silt, grey 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 intervals from the background soil sample (Table 3), 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. 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, chrysene, dibenz(a,h)anthracene, 

dibenzofuran, 2,4-dimethylphenol, fluoranthene, fluorene, indeno(1,2,3-cd)pyrene, 2-

methylnaphthalene, 2-methylphenol, 3 &/or 4-methylphenol, naphthalene, phenanthrene, and pyrene 

were detected greater than background levels. Constituents were detected at 2 to 4 feet bgs, 6 to 8 feet 

bgs, 10 to 12 feet bgs, 12 to 14 feet bgs and/or at between 14 to 16 feet bgs (Ref. 4, pp. 30-31, 482-491, 

546-563 & 582-607; Tables 3 & 5).

37
SO-Source Characterization

Source No.: 3

VOCs were detected above background concentrations (See Table 3) in the 2 to 4 feet bgs, 6 to 8 feet 

bgs, 10 to 12 feet bgs, 12 to 14 feet bgs and/or at depths between 14 to 16 feet 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 metal concentrations from the 2 to 4 feet bgs, 6 to 8 feet bgs, 10 to 12 feet bgs, 12 

to 14 feet bgs and/or between 14 to 16 feet bgs intervals were detected at concentrations above

background levels. Metals concentrations detected above background levels include: copper, 

manganese, mercury, nickel, zinc, barium, cadmium, cobalt, lead and arsenic (Ref. 4, p. 30-31, 482-491, 

546-563 & 582-607; Tables 3 & 5). Again, 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. 

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, benzo(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, naphthalene, 

phenanthrene, and pyrene (Table 5). This is consistent with identification of buried impoundments used 

in the barge cleaning operations (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, methylcyclohexane, ethylbenzene, cis-1,2-

dichloroethane, tetrachloroethene, styrene, isopropylbenzene, 1,4-dichlorobenzene, 1,2-dichlorobenzene 

toluene, benzene, xylene and toluene were detected. Metal 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).

38
SO-Source Characterization

Source No.: 3

Table 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

Acenaphthene 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: 

μg/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, fluoranthene, 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. 865).

* - The detected concentration was adjusted 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 substance concentration, there is still a significant increase in contamination.

BOLD - Concentration 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

 39
SO-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'-Biphenyl 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)

Acenaphthylene 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)

Chrysene 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-Methylnaphthalene 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-Methylphenol 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) pyrene 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)

Copper 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)

Nickel 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)

Barium 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)

Cobalt 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)

Arsenic 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)

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

Ethylbenzene 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)

Toluene 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)

Styrene 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: 

μg/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, fluoranthene, 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. 865).

* - The detected concentration was adjusted 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 substance concentration, 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

40
SO-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: There 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 operation. 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): 

• Acenaphthene

• Acenaphthylene

• Anthracene 

• Arsenic

• Barium

• Benzene

• Benzo(a)anthracene

• Benzo(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 

• Pyrene

• Styrene

• Tetrachloroethene

• Toluene 

• Xylene, -m, -p, -o 

• Zinc

 41 
SO-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): 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 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 

reasonable 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 Quantity for Source 3 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

Initially, the Former Water Pit 1 was excavated 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 and had 

undergone partial closure (Ref. 24, p. 13). In 1996 dimensions were approximated at 160 feet x 100 feet 

x 15 feet 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, the information available is not sufficient to evaluate an score Tier C because details of 

closure activities 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 throughout 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

42
SO-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 (yd3): Not Scored

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 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 135 feet in length and approximately 85 feet in 

width; therefore, it occupied 11,475 square feet (ft2).

The hazardous waste quantity evaluation equation 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 ft2/13 = 882.69

Area of source (ft2

): 11,475.00

Area Assigned Value: 882.69

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 highest value assigned is Tier D.

Source No. 3 Hazardous Waste Quantity Value: 882.69

43
SO-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 Treatment Unit (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 dewatered and 

treated (Ref. 24, p. 5). The LTU was located approximately 200 feet northwest of Water 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). Surface water runoff from the LTU forms small puddles 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 discharges 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 Water Pit 

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 Water Pit 1 were solidified with fly ash and lime (Ref. 24, pp. 

15 & 107). Approximately one third of Water Pit 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 feet 

x 93 feet x 3 feet and was estimated to contain approximately 2,000 cubic yards of solidified sludge 

(Ref. 6, p. 8). As of October 26, 1994, no 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 Former Land Treatment Unit (Ref. 4, p. 32 & 908; 

Figure 3): 

• Sample SBA-007WT (8-10 feet bgs) – collected above water table; chemical odor

44 
SO-Source Characterization

Source No.: 4

• Sample SBA-008-24 (2-4 feet bgs) – no stains, no odor

• Sample SBA-008WT (10-12 feet bgs) – collected above 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, pp. 20, 47, 316-324, & 333-343). 

The soil sample results from this source area were compared to the concentrations in the corresponding 

foot intervals from the background soil sample (Tables 3 and 6). The hazardous substances associated 

with the former land treatment unit are polycyclic aromatic hydrocarbons (PAHs), volatile organic 

compounds (VOCs) and metals (Table 6).

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

Elevated levels of PAHs were found to include: acenaphthene, acenaphthylene, anthracene, 

benzo(a)anthracene, benzo(a)pyrene, benzo(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, naphthalene, phenanthrene, phenol and pyrene in concentrations greater than 

comparable background 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, methylcyclohexane, ethylbenzene, xylene, cis-1,2-

dichloroethene, benzene, toluene and vinyl chloride were detected. Metals concentrations of

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

45
SO-Source Characterization

Source No.: 4

Table 6 – Source 4 - Land 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: 

μg/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, methylcyclohexane, 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 actual 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

46
SO-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: There is was no functioning or maintained run-on or runoff 

management system (Ref. 24, p. 15). Surface 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 

into 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 Water Pathways (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

• Beryllium

• Biphenyl, 1,1'-

• Cadmium

• Chrysene

• Cyclohexane

• Dibenzofuran

• Dichloroethene, cis-1,2-

• Ethylbenzene

• Fluoranthene

• Fluorene

• Indeno(1,2,3-cd)pyrene

• Manganese

• Methylcyclohexane

• Methylnaphthalene, 2-

• Naphthalene

• Nickel

• Phenanthrene

• Phenol

• Pyrene

• 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. 

47
SO-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 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 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 requirements; 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). 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 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 being 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 (yd3

) (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 (yd3

): Not Calculated

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 use (Ref. 24, pp. 15 & 107). In 1996 it was noted that 

the LTU had approximate surface dimensions of 190 feet x 93 feet (Ref. 6, p. 8). The LTU is currently 

covered with soil and no 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 17,670 square feet (ft2

) (Ref. 6, p. 8). The hazardous waste quantity evaluation equation 

for a land treatment unit is A/270 (Ref. 1, Table 2-5). The area source will be assigned an area 

hazardous waste quantity value of 65.44. 

17,670 ft2/270 = 65.44

 48
SO-Source Characterization

Source No.: 4

Area of source (ft2): 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

 49
SO-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 Mermentau River (Ref. 54, p. 3; Figure 2). The Dry Dock 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 waste that had settled and was 

not removed from the basin migrated from the source (Ref. 53, p. 1). The Dry Dock has dimensions of 

approximately 500 feet x 250 feet (Ref. 4, pp. 17 & 33). Currently, the Dry Dock contains 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 directly 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 Dry Dock (Ref. 4, pp. 34, 

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

northwest corner of the Dry 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 inches below water surface (10 to 15 feet in depth to bottom) using a benthic dredge (Ref. 4, 

pp. 115 & 1010). 

 50 
SO-Source Characterization

Source No.: 5

Sediment samples SBA-026SD, SBA-027SD 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 (Tables 7 and 8). Analysis of the sediments from the Dry Dock detected 

numerous PAHs, select metals and the chlorinated PCBs, 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, benzo (k) fluoranthene. 

benzo(g,h,i)perylene, carbazole, chrysene, dibenzofuran, fluoranthene, fluorene, indeno(1,2,3-

cd)pyrene, 2-methylnaphthalene, naphthalene, phenanthrene and pyrene above concentrations in 

background sediment levels (Tables 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 process (Ref. 4, p. 34 & 389-404; Table 1).

Metals detected included mercury, zinc, 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, pp. 70 & 396; Table 4).

 51
SO-Source Characterization

Source No.: 5

Table 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

 52 
SO-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 benzo (b) 

fluoranthene, benzo (g,h,i) perylene, benzo (k) fluoranthene, carbazole, dibenz (a,h) anthracene, indeno (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 Arochlor1254 in sample SBA-026SD is biased unknown (Ref. 4, p. 182). The presence of the substances is not in doubt.

( )* - 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 data 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

 53
SO-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: There is no evidence that the Dry Dock had a liner. The Dry 

Dock appears to be an earthen berm enclosure reinforced with metal sheeting and bound with a 

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

Contaminants were detected down gradient of the Dry Dock 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 is 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

• Aroclor-1254

• Arsenic

• Benzo(a)anthracene

• Benzo(b)fluoranthene

• Benzo (k) fluoranthene

• Benzo(g,h,i)perylene

• Benzo(a)pyrene

• Carbazole

• Chrysene

• Copper

• Dibenzofuran

• Fluoranthene

• Fluorene

• Indeno (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 

 54
SO-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 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 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 

reasonable 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 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 sufficient 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 (yd3

) (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 (yd3

): 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 aerial photographs the dry dock has approximate dimensions of 500 feet in 

length and 250 feet in width; therefore, it occupied approximately 125,000 square feet (ft2

) (Ref. 4, pp. 

17 & 33; Ref. 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 ft2 / 13 = 9,615.38

 55
SO-Source Characterization

Source No.: 5

Area of source (ft2): 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 

 56 
SO-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 approximately 

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 Water Pit 2 (Ref. 24, pp. 8 & 12-14). Subsequently, aboveground 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 surface impoundment (Ref. 6, p. 8). During storm events rainwater 

accumulates in the impoundment (Ref. 6, pp. 10). The impoundment formerly known as Water Pit 3 is 

located on the southeast portion of the property, bordering a designated wetland area (Figure 2). The 

dimensions were approximately 283 feet x 55 feet x 6 feet 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 

Former Water Pit 3 (former water pit) to the drainage ditch that drains to the Mermentau River (Ref. 5, 

pp. 8, 20-21 & 24). The emptied Water Pit 3 (former water pit) was then used to receive treated storm 

water from the Partially Buried Barge (Ref. 5, pp. 8, 20 & 24). Approximately 100,000 gallons of 

treated storm water was left in Water Pit 3 (former water pit) (Ref. 5, pp. 8 & 21). Water Pit 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 

Former Water Pit 3 (former water pit), raising the level of the water in the pit to approximately four (4) 

feet deep (Ref. 5, pp. 8, 21). Thus, linking Former Water Pit 3 with the designated wetland area to the 

immediate west (Figure 2).

Two (2) wetland sediment grab samples were collected from the Former Water Pit 3 area, which is now 

part of the wetlands to the east (Figure 3). During the SI of August 2013 one (1) sediment sample, SBA032D, 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).

Grab wetland sediment samples were collected from locations of visual contamination (Ref. 4, pp. 31 & 

117-118; Ref. 7, pp. 36, 135-136 & 164). 

 57 
SO-Source Characterization

Source No.: 6

Wetland sediment sample SBA-32SD was collected from the southwest corner of Former Water Pit 3

that is presently part of the wetland area, and sediment sample SBA-ESI-10SD was collected from 

approximately the southwest corner of Former Water Pit 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 inches

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 facility 

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 sediment samples SBA-031SD and SBA-032SD was 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, 632-

647).

Wetland sediment samples 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). 

In 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, 

 58 
SO-Source Characterization

Source No.: 6

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

642-644; Table 9). In addition, metal concentrations were detected at greater than background levels for

beryllium and cobalt (Ref. 4, pp. 646-647; Table 9). While 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 sediment 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 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 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

Analysis 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, phenanthrene, and 

pyrene (Ref. 4, pp. 640-647; Ref. 7, pp. 213-215; Tables 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 respectively).

 59
SO-Source Characterization

Source No.: 6

Table 9 - Background and Source 6 (Former Water Pit 3) Wetland Samples 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: 

μg/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, there 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

 60
SO-Source Characterization

Source No.: 6

Table 10 - Background and Source 6 (Former Water Pit 3) Samples 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 carbazole 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. 169 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

 61
SO-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: 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 pit to 

approximately four (4) feet deep (Ref. 5, pp. 8, 20-21 & 24). Thus, making the former surface 

impoundment combined 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 liner since Water Pit 

3 consisted of a local (native) clay bottom (Ref. 24, pp. 8 & 107). Also, Source 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):

• Acenaphthene

• Acenaphthylene

• Anthracene 

• Benzo(a)anthracene

• Benzo(a)pyrene

• Benzo(b)fluoranthene

• Benzo(g,h,i)perylene

• Benzo(k)fluoranthene

• Beryllium

• Chrysene

• Cobalt

• Dibenz(a,h)anthracene

• Dibenzofuran

• Fluoranthene

• Fluorene

• Indeno(1,2,3-cd)pyrene

• Methylnaphthalene, 2-

• Naphthalene

• Phenanthrene

• Pyrene

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 estimated with reasonable confidence (Ref. 1, pp. 

 62
SO-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 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 6 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 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 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 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 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, p. 21). Upon removal of the segment of the earthen 

berm, water from the Mermentau River flowed into Water Pit 3, raising the level of the water in the pit 

to approximately four (4) feet deep (Ref. 5, pp. 8, 21). Thus, linking the Former 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 

Former Water Pit 3 (surface impoundment). The dimensions for Former Water Pit 3 are approximately 

283 feet x 55 feet x 6 feet; therefore, it occupied approximately 93,390 cubic feet (ft3

) (Ref. 4, pp. 16 & 

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

The most common value used for cubic yards to cubic feet volume conversion is 1 yd3 = 27 ft3. The 

estimated source volume of Former Water Pit 3 is 3,458.89 yd3.

93,390 ft3 / 27 ft3 per 1 yd3 = 3,458.89 yd3

 63
SO-Source Characterization

Source No.: 6 

The hazardous waste quantity evaluation equation for a surface impoundment 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 yd3 / 2.5 = 1,383.56 

 Volume of Source (yd3): 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 (ft2): 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 

 64 
SO-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 1,827.79 NS NS 10 NS NS

3 882.69 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 located 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). Hazardous 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 elevated 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) 

removal action (Ref. 38, p. 2). 

In May and June of 2015 an OPA 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). 

 65 
SO-Summary

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 

and characterization of contents. Removal and offsite disposal of sludge 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 

residues (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, overturned, 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 former oil pit 

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 estimated 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 excavation 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 the impoundment formerly known as the oil pit 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 feet x 100 feet x 6 feet, 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 66 
SO-Summary

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, styrene, 

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 activities 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, acenaphthylene, 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 managed in a waste management area that included the former oil pit. 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 67 
SO-Summary

Other Possible Sources

• Location SBA-006, Sample SBA-006-24: Collected approximately 2-4 feet bgs; clay; grey-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 feet bgs and above 

the water table; clay with some silt, tan, orange mottled; PID: 7.8 ppm; no 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 feet bgs above the 

water table; sand-silt and clay; reddish-brown; no visible hydrocarbon, oil material (Ref. 4, 

p.996). 

• Location SBA-011,Sample SBA-011-PD: Collected approximately 8-10 feet bgs at the highest 

PID reading; silt; tan; 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 

water 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 oil pit, 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, these constituents are also detected in surrounding units that were 

used as waste management areas at SBA during operations including the former oil pit, Water Pit 1

(Source No. 3), and the Land Treatment Unit (LTU) (Source No. 4). 

September 2016 68 
SWOF-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 entries (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 (Sources 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 Sources No. 3 & 4 eventually flow into a segment of PPE-3 , the depressed 

area of the drainage ditch that flows through the wetland that 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 former 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 have 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 migration pathway is located in Lake Arthur (Figure 6). 

Surface Water Pathway Description for Each Source

Source 

No 

Pathway Description PPE

1 A Partially Buried Barge 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 drainage 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 122 feet (Ref. 24, p. 

PPE 3: A segment of the drainage ditch that flows 

through the Palustrine Forested Wetlands contiguous 

with Mermentau River.

September 2016 69 
SWOF-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 drainage ditch that flows 

through the Palustrine Forested Wetlands contiguous 

with Mermentau River. 

5 A Dry (Graving) Dock 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 water flow around/under the manmade 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 drainage 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 

wetlands 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 United 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 years 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 30o 11'24.00" North and longitude 92o 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). During 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 Engineer 

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 

structures can be viewed as a large storage 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 inland 

waterways (Ref. 27, p.11). The upper Mermentau River lies north of the designated Louisiana saltwater 

line definition provided by Louisiana Department of Wildlife and Fisheries (LDWF) (Ref. 14, p. 16). 

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SWOF-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 the 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 River 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 the 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 immediate 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 inches

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 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 (Tables 11 & 12). 

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SWOF-Surface Water Overland Flow/Flood Migration Component

Observed Release

Chemical Analyses: 

Sediment samples (SBA-24SD, SBA-25SD, SBA-029SD and SBA-30SD) and wetland samples (SBA32SD, 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 SBA31SD) also collected during that specific 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). SBA-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 Table 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 specific 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). SBAESI-02 is located northwest and approximately 500 feet upstream and along the original river channel 

(Ref. 7, p. 25; Figure 5). No 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 boundary 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 the 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 were 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 Dry Dock (Source 5) and associated with PPE 1 (Figures 3 & 4). The following samples were 

collected: 

• 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 samples 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, fluorene, 

phenanthrene and pyrene (Table 12). 

 72 
SWOF-Surface Water Overland Flow/Flood Migration Component

Observed Release

Three (3) sediment samples collected during the August 2013 SI and two (2) sediment samples 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 sheen (Ref. 4, pp. 33 & 113) 

• Sample SBA-030SD – near the Barge 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) 

The 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 11 & 12). 

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 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 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 Partially Buried 

Barge (Ref. 4, p. 119) 

• Sample SBA-039 – collected east of the Partially Buried Barge (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, naphthalene, 

phenanthrene and pyrene (Tables 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, fluorene, 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 73 
SWOF-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). 

Samples SBA-24SD, SBA-025SD, SBA-029SD, SBA-030SD, SBA-033 and SBA-039 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/PCBs 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-11SD 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 analysis 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. 

 74 
SWOF-Surface Water Overland Flow/Flood Migration Component

Observed Release

Table 11 – Site Inspection Background and Release Samples 

EPA/START Sample No.: SBA-28SD SBA-029SD 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/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 μg/kg

Acenaphthene 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: 

μg/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-029SD 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

 75 
SWOF-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

 76 
SWOF-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 Dibenz (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

 77 
SWOF-Surface Water Overland Flow/Flood Migration Component

Observed Release

Attribution: 

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 barges 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 methyl ethyl ketone (Ref. 34, p. 2). During the painting of barges, 

solvents used for cleaning painting equipment were saved and used to thin coatings 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). Wastes 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, methylmethacrylate, methanol, caustic soda, styrene, coal tar, vinyl acetate, carbon tetra chloride, ethyl acrylate

and acrylates (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 Water Pits 1, 2, and 3 were found to contain vinyl chloride, 1,2-dichloroethane, 

tetrachloroethylene, trichloroethylene, methylene chloride, 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 wastes were placed in Water 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 historically associated with the site. CERLCA 

hazardous substances are subject to CERCLA response authority and responsibility. 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, methylmethacrylate, methanol, caustic soda, styrene, coal tar, vinyl acetate, carbon tetra chloride, ethyl acrylate

and acrylates (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, ethylbenzene, 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 

 78 
SWOF-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, Sample SBA-ESI-04SD down gradient of the dry dock (Ref. 4, p. 41: Ref. 7, p. 33). 

In the release sediment samples from the Dry Dock, chrysene, fluoranthene, fluorene, phenanthrene, and 

pyrene were detected and met observed release criteria (Ref. 4, pp. 260-267; Ref. 7, pp. 210-212; Tables 

11 & 12). 

Five (5) sediment samples (SBA-024SD, SBA-025SD, SBA-030SD, SBA-ESI-05SD, SBA-ESI-06SD) 

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 

Partially Buried Barge scored as Source 1, and which receives drainage from Source 1(Ref. 4, pp. 228-

243 & 268-275; Ref. 7, pp. 183-188; Tables 11 & 12). 

Three (3) sediment samples (Sample SBA-33, Sample SBA-39 and SBA-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 impoundments (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 Partially Buried Barge (Source 1), the two former surface 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 (Figures 4 & 5).

Two (2) wetland sediment samples (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 & 12). Former 

Water Pit 3, that is presently part of the wetlands and PPE 4, is along the surface water migration 

pathway and receives drainage from the former oil 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 former 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 the dates of operation at 

this facility. Available information indicates that the property north of the SBA facility was occupied by 

Citgo (Ref. 28). There are no other industries located within a 2-mile radius of the property that might 

be responsible for the contamination in the PPE or the wetlands. Background sediment samples 

collected upstream from the site indicate the former 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 

September 2016 79 
SWOF-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 contaminants 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 the 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 

 80 
SWOF/

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 value (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

 81 
SWOF/

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 Factor 

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-12541 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-cis2 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

Fluoranthene3 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

Isopropylbenzene4 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

Octachlorodibenzo-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

Tetrachloroethene5 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 82 
SWOF/

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 dichloroethylene, 1,2-cis- in the SCDM (Ref. 2, p. 4). 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 tetrachloroethylene in the SCDM (Ref. 2, p. 9).

OR – Substance documented in the observed release 

The hazardous substances with the highest Toxicity/Persistence/Bioaccumulation Factor Values are

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-, 

hexachlorodibenzofuran 2,3,4,6,7,8-, mercury, and pentachlorodibenzofuran 2,3,4,7,8-. 

Toxicity/Persistence/Bioaccumulation Factor Value: 500,000,000 

 83 
SWOF/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 integer, is 13,745. 

 Sum of Values: 13,745 

Hazardous Waste Quantity Assigned: 10,000 (Ref. 1 Table 2-6) 

September 2016 84 
SWOF/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 maximum of 1 x 108. This product is multiplied by 

the Bioaccumulation Potential Factor Value subject to a maximum value of 1 x 1012. The hazardous 

substances with the highest Toxicity/Persistence/Bioaccumulation factor values 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-, 

hexachlorodibenzofuran 2,3,4,6,7,8-, mercury, and pentachlorodibenzofuran 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 108

(Subject to a maximum product of 1.0 x 108

Bioaccumulation Potential Factor Value: 50,000 

(Toxicity/Persistence x Hazardous Waste Quantity) x 

Bioaccumulation Potential Factor Value:

 

(1 X 108) X (50,000) = 5.0 X 1012

(Subject to a maximum product of 1.0 x 1012) 

A Waste Characteristics Product value of 1.0 X 1012 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 

 85 
SWOF/Human Food Chain-Targets

4.1.3.3 HUMAN FOOD CHAIN THREAT-TARGETS

Largemouth bass, crappie, bream, bluegill, catfish, gar, bullhead, carp, striped bass 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 along 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 acenaphthene , anthracene, barium, benzo(a)anthracene, benzo(a)pyrene, 

benzo(k)fluoranthene, cadmium, carbazole, copper, dibenz(a,h)anthracene, dibenzofuran, fluoranthene 

(benzo(j,k) fluoranthene), fluorene, indeno (1,2,3-cd) pyrene, lead, manganese, mercury, 2-

methylnaphthalene, naphthalene, nickel, phenanthrene, 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; Tables 11 & 12). 

Food Chain Individual Factor Value: 45 (Ref. 1, Section 4.1.3.3.1) 

 86 
SWOF/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 location 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 Potential Human Food Chain Contamination 

Recreation fishing is common in the Mermentau River and Lake Arthur. Recreational fishing is 

conducted within Mermentau River (Ref. 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 

 87 
SWOF/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 14 – Fishery Identification Study 

Identity 

of Fishery

Annual 

Production 

(pounds)

Type of 

Surface 

Water 

Body

Average 

Annual 

Flow

Population 

Value (Pi)

Dilution 

Weight 

(Di) PixDi Reference

Mermentau 

River

>0-100 Large 

stream 

to River

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 River

2,570 cfs 0.03 0.001 0.00003 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 

 88 
SWOF/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 

 89 
SWOF/Environmental-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 ecobioaccumulation factor is used to 

determine the waste characteristics factor value for the environmental threat of the surface water

migration pathway (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 15 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/ecobioaccumulation factor value for the watershed is used to 

assign the value to this factor (Ref. 1, Section 4.1.4.2.1.4). 

 90 
SWOF/Environmental-Toxicity/Persistence/Bioaccumulation

Table 15- 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-12541 5 10,000 1 10,000 50,000 500,000,000

Arsenic 1, 3 - 5 10 1 10 50,000 500,000

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 10,000 1 10,000 50,000 500,000,000

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 1,000 1 1,000 50,000 50,000,000

Cadmium 3, 4 10,000 1 10,000 50,000 500,000,000

Carbazole 1, 3-6, OR 1,000 1 1,000 500 500,000

Chromium 1 10,000 1 10,000 500 5,000,000

Chrysene 1, 3-6, OR 1,000 1 1,000 5,000 5,000,000

Cobalt 1, 3, 5, 6 0 1 0 50 0

Copper 3-5 1,000 1 1,000 50,000 50,000,000

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 1,000 0.4 400 5,000 200,000

Dichloroethene, 1,2-cis2 3, 4 0 1 0 50 0

Dimethyl phenol, 2,4- 3 100 1 100 500 50,000

Ethylbenzene 1, 3, 4 100 0.4 40 50 2,000

Fluoranthene3 1, 3-6,OR 10,000 1 10,000 5,000 50,000,000

Fluorene 1, 3-6,OR 1,000 0.4 400 5,000 2,000,000

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

Isopropylbenzene4 1, 3 100 0.4 4 500 20,000

Lead 1, 3 1,000 1 1,000 50,000 50,000,000

Manganese 3-5 100 1 100 50,000 5,000,000

Mercury 1, 3, 5 10,000 1 10,000 50,000 500,000,000

Methyl phenol, 2- 3

Methyl phenol, 4- 3 100 0.0007 0.07 50 3.5

Methylcyclohexane 1, 3, 4

2-Methylnaphthalene 1, 3-6, OR 1000 0.4 400 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 50 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 10,000 0.4 4,000 50,000 200,000,000

Phenol 4 10,000 1 10,000 50,000 500

Pyrene 1, 3-6,OR 100 1 100 50,000 500,000,000

Styrene 3 100 0.4 40 50 2,000

Tetrachloroethene5 1, 3 100 0.4 40 50 2,000

Toluene 1, 3, 4 100 0.4 40 5,000 200,000

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 50,000 500,000

* 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

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 dichloroethylene, 1,2-cis- in the SCDM (Ref. 2, p. 4).

September 2016 91 
SWOF/Environmental-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 tetrachloroethylene 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

 92 
SWOF/Environmental-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 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 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)

 93 
SWOF/Environmental-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 value 

for the watershed are 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-, 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 the water characteristic 

product. The Waste Characteristic Product is the product of the Ecosystem Toxicity/Persistence/ Factor 

Value and the Hazardous Waste Quantity Factor Value subject to a maximum product of 1 x 108. This 

product is multiplied by the Ecosystem Bioaccumulation Potential Factor Value Subject to a maximum 

product of 1 x 1012. 

Using HRS Table 4-20 and Table 15 of this HRS documentation record, the Ecosystem 

Toxicity/Persistence value for Aroclor-1254, benzo(a)anthracene, benzo(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 Quantity 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 108

(Subject to a maximum product of 1.0 x 108

The Ecosystem Bioaccumulation Value for Aroclor-1254, benzo(a)anthracene, benzo(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 108) X (50,000) = 5 x 1012

 

(Subject to a maximum product of 1 x 1012) 

A Waste Characteristics Product Value of 1 x 1012 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 1012

Waste Characteristics Factor Value: 1,000 

 94 
SWOF/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

 95 
SWOF/Environmental-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 Mermentau River, across from 

PPE 1 and PPE 2, and are contiguous 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 established 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 River (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 

subject 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 zone of Level II contamination therefore, these 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 Table 4-24) 

 96 
SWOF/Environmental-Potential Contamination

4.1.4.3.1.3 Potential Contamination 

Wetlands

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, classified 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 Inventory (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 

(Wj)

Adjusted 

Dilution 

Weight (Dj)

(Wj + 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 

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SWOF/Environmental-Factor Category Value

4.1.4.3.1.4 Environmental Threat- Targets Factor Category Value 

The environmental threat target factor 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 environmental 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 threat (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 Calculation 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).

 98 
SWOF–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