Final Close Out Report 

Ruston Foundry Superfund Site 

Alexandria, Rapides Parish Louisiana 

United States Environmental 

Protection Agency 

Region 6 

Superfund Division 

January 2010

 

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I. INTRODUCTION 

Site Name: Ruston Foundry Superfund Site (LAD985185107) 

Site Location: Alexandria, Rapides Parish, Louisiana 

Lead Agency: U. S. Environmental Protection Agency, Region 6 (EPA) 

Support Agency: Louisiana Department of Environmental Quality (LDEQ) 

Potentially 

Responsible Party: Kansas City Southern Railway Company (KCS) 

This Final Close Out Report (COR) documents that the U. S. Environmental Protection Agency 

(EPA), the Louisiana Department of Environmental Quality (LDEQ), and Kansas City Southern 

Railway Company (KCS) have completed construction activities for the Ruston Foundry 

Superfund Site in accordance with Close Out Procedures for National Priorities List Sites 

(OSWER Directive 9320.2-09A-P). The EPA, LDEQ, and KCS conducted a Pre-Final 

Construction Inspection on May 14, 2008; a Final Construction Inspection on June 17, 2008; a 

post construction inspection on August 22, 2008; and a post construction inspection on June 23, 

2009. The LDEQ and KCS conducted post construction inspections on July 22, 2009, and 

August 25, 2009. The EPA and LDEQ have determined that the PRP has completed the 

Remedial Action in accordance with the Record of Decision (ROD), subsequent Explanation of 

Significant Differences (ESDs), and the Remedial Design and Implementation Work Plan. All 

Site response actions, including remedial actions, were accomplished pursuant to, and in 

accordance with, the requirements of the Comprehensive Environmental Response, 

Compensation and Liability Act (CERCLA), 42 U.S.C. § 9601 et seq., and consistent with the 

National Contingency Plan (NCP), 40 CFR Part 300. 

II. SUMMARY OF SITE CONDITIONS

Site Background

Ruston Foundry operated from 1908 until 1985. From the beginning of operation until October 

1983, it was operated under the name Ruston Foundry and Machine Shops, Ltd. In 1983, the 

facility was reincorporated and began operating under the name Ruston Foundry and Machine 

Shops, Inc. In November 1990, the Ruston Foundry and Machine Shops, Inc. corporation 

charter was revoked by the Louisiana Secretary of State for failure to file its corporate annual 

report. 

The Ruston Foundry Superfund Site (Site) is located in an urban area with mixed development 

within the city limits of Alexandria. The Site encompasses approximately 6.6 acres that 

consisted primarily of dilapidated structures and building foundations overgrown with thick 

brush prior to remedial actions. The Site is bordered by a series of abandoned railroad tracks to 

the west, Chatlin Lake Canal to the northeast and east, and Mill Street Ditch to the south and 

southeast. Residential property is located to the north, south, and east of the Site. Historical and 

active industrialized areas lie further west and north of the Site. 

During the 1990s, LDEQ and EPA conducted a series of Site investigations. On January 19, 

1999, the Site was proposed to the National Priorities List (NPL), and on May 10, 1999, EPA 

formally announced the addition of the Site to the NPL in the Federal Register. 

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a. History of Federal and State Investigations and Removal Actions

LDEQ - The LDEQ Inactive and Abandoned Site Division conducted a Site investigation in 

June 1990, which included drum and surface soil sampling. Based on these sample results, 

LDEQ referred the Site to EPA as a candidate for an emergency response action. 

Site Assessments - 1990 Site Assessment (E&E, 1991) and 1994 Site Assessment (E&E, 1994) - 

In 1990, a Site Assessment (SA) was completed to determine sampling strategies for the Site. 

Sampling activities included onsite surface soil, drum contents samples, and air samples. 

Analytical results for the surface soil samples indicated the presence of elevated levels of six 

analyzed metals: arsenic, chromium, cobalt, lead, mercury, and zinc. Elevated concentrations of 

lead, and organic compounds benzene, ethylbenzene, toluene, m-xylene, and oxylene 

were detected in samples collected from the sludge materials contained in the drums. No 

organic vapors above background were detected in ambient air sampled in the vicinity of the 

drums. 

In February 1994, a second SA was completed to determine the type and volume of materials to 

be addressed by a removal action and evaluate disposal options for the Site. The volume of waste 

estimated for the twenty-two 55-gallon drums identified onsite was 1,210 gallons of liquid and 

sludge. The estimated waste volume for two slag piles was approximately 350 cubic yards (cy). 

Potential disposal options for the Site were listed as soil washing, gravimetric separation, 

ionization process, onsite heat leaching of the lead contaminated soils, onsite consolidation with 

stabilization of waste, and offsite transportation/disposal. 

Expanded Site Inspection - (E&E, 1998) - Based on the results of the SA activities, EPA 

initiated an evaluation of the Site for potential inclusion on the NPL. In March 1998, an 

Expanded Site Inspection was conducted to further characterize the Site and assess whether 

offsite target receptors had been impacted by Site contaminants (E&E, 1998). In both the onsite 

samples and offsite residential samples, metals were detected. 

Removal Assessment - Offsite (E&E, 1999a) - In 1999, the EPA conducted a removal 

assessment of the residential neighborhood bordering the Site. This assessment also included 

removing drums, repairing the fence, air sampling, and placing signs along the fence (E&E, 

1999a). Analytical results indicated the presence of lead and other metals at concentrations 

above background in several residential yards; however, no analytes except for lead were 

detected above risk-based screening levels. 

Time-Critical Removal Action - A removal assessment was performed from June 28 to July 3, 

1999, to prepare onsite drums for removal. Staged drums were transported and disposed offsite 

on August 11, 1999 (E&E, 1999b). 

b. Remedial Investigation and Feasibility Study

Based on the investigation of Site historical information, five potentially responsible parties were 

identified, and sent General Notice letters and 104(e) Information letters. Based on the 

responses to these letters, the EPA issued special notice waivers because the Agency determined 

that negotiations would not move the project forward in a timely manner. The Site RI/FS was 

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completed as an EPA fund-lead project. 

The EPA issued a work assignment to CH2M Hill in June 1999 to perform a RI/FS. Sampling 

for the remedial investigation (RI) was conducted December 1999 (CH2M Hill, 2000) and from 

September to November 2001 with the final report completed in February 2002 (CH2M Hill, 

2002a). The field investigation included surface soil grid sampling, sampling of soil/sediment 

on transects across the canals, sampling of waste piles, air monitoring, sampling of surface soil 

hot spots, sampling of surface water and sediment in the canals, stratigraphic profiling with cone 

penetrometer testing, subsurface soil grid sampling with direct-push and conventional drilling, 

monitor well installation, ground water sampling, and aquifer testing. 

Foundry operations resulted in metals contaminated waste which was dispersed throughout the 

property as fill material. As a result of this disposal activity, foundry-derived process wastes 

(slag, foundry sand piles, metal scrap, and castings) covered most of the Site and had 

contaminated the soil. Also present at the Site was an underground storage tank with unknown 

contents, asbestos containing material, and slag waste identified as a characteristic hazardous 

waste because it exceeded toxicity characteristic leaching procedure (TCLP) criteria for lead. 

Through the human health [March 2002; CH2M Hill, 2002c] and ecological risk assessments 

[October 2001; CH2M Hill, 2001], the identified contaminated media of most concern were 

surface soil and sediment that contain lead and antimony, and the exposure routes of most 

concern were direct contact and ingestion. Children were found to be the most sensitive and 

vulnerable to the effects of lead. 

The EPA determined that it was appropriate to apply the presumptive remedy for metals in soil 

based on the soil and contaminant characteristics found at the Site and guidance provided in the 

directive, Presumptive Remedies for Metals-in-Soil Sites (EPA 540-F-98-054, OSWER-9355.0-

72FS, September 1999). Following the guidance, the EPA has a goal of resource conservation, 

thereby making reclamation/recovery the preferred treatment technology for metals-in-soil sites. 

This approach was determined to be inappropriate for the Site. Slag waste is the primary 

contaminated media/matrix encountered throughout the Site, and reclamation/recovery is 

generally not effective for treatment of slag waste. The concentration of metals in the slag is too 

low to warrant reclamation and recovery, and the physical and chemical nature of the slag 

material that binds the metals would make reclamation or recovery of metal from the waste 

physically and economically impractical. Therefore, the second preferred treatment technology 

alternative of immobilization (solidification/stabilization) was used. 

In addition to the no action alternative, required by the NCP for inclusion as a baseline of Site 

conditions for comparison, EPA evaluated presumptive remedies and an excavation and offsite 

disposal alternative. The Final Feasibility Study was completed in February 2002 (CH2M Hill, 

2002b).

c. Record of Decision dated June 24, 2002 

The ROD identified the selected remedy for the Ruston Foundry Site. The principal threat waste 

at the Site was to be addressed through the excavation and offsite disposal of contaminated soil 

and sediment, removal and offsite disposal of asbestos containing material and the underground 

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storage tank, and the excavation, treatment, and offsite disposal of hazardous wastes. The 

selected remedy was one of EPA’s presumptive remedies for the treatment of contamination at 

sites with metals contamination. 

The selected remedy was considered a comprehensive approach that addressed the Site as one 

operable unit. Due to the previous removal of drums, the remedy will address all current and 

potential future risks caused by soil, sediment, and hazardous waste contamination and, to the 

extent possible, leaching of Site contaminants into the ground water. The remedial measures 

will prevent exposure to hazardous waste and soil and sediment contaminated with hazardous 

substances such that the Site would no longer present an unacceptable risk to human health. The 

property would be suitable for recreational/residential land use, would allow for unlimited use 

and unrestricted exposure, and would not require five-year reviews, operation and maintenance 

or institutional controls. 

Through the Reuse Grant awarded by the Government in September 2000, the city of Alexandria 

developed a future reuse plan. It was anticipated that the selected remedy would provide 

community revitalization impacts because it would be compatible with Alexandria’s Site reuse 

plan and allow for restoration of the Site to beneficial uses. 

The major components of the original remedy were:

1. Stabilization - Approximately 1300 cubic yards (yd3

) of hazardous waste would be 

excavated and stabilized. The material would be stabilized until sampling verifies that it 

no longer exceeds the TCLP for lead. After verification, the waste would be disposed 

offsite at a Resource Conservation and Recovery Act (RCRA) regulated Subtitle D 

facility. 

2. Asbestos Containing Material (ACM) - Materials would be consolidated onsite, 

contained, and transported offsite to a disposal facility licensed to accept ACM. Methods 

to control airborne dispersion of asbestos would be implemented during remediation. 

The estimated total volume of material is 22 yd3. 

3. Underground Storage Tank (UST) - The UST, its contents, and the surrounding 

petroleum wastes would be characterized during the remedial design to determine 

whether the contents would be cleaned up under CERCLA or Oil Pollution Act authority. 

The surrounding polychlorinated biphenyl contaminated soils would be removed and 

disposed offsite in accordance with federal, state, and local regulations. The total volume 

of tank contents was estimated at 5,000 gallons. The volume of associated contaminated 

soil was included in the soil/sediment estimated volume of 15,000 yd3

. 

4. Building debris and water supply well - The onsite well would be plugged and 

abandoned in accordance with federal, state, and local regulations. Portions of the Site 

would be cleared, where necessary, and the existing buildings and foundations would be 

demolished, removed and disposed offsite. 

5. Soil/sediment - Approximately 15,000 yd3

 of lead and antimony contaminated soils and 

sediment would be excavated and disposed offsite in a RCRA Subtitle D facility. 

6. Air Monitoring - During remedial action, efforts would be made to control dust and runoff to limit the amount of materials that may migrate to a potential receptor. Air 

monitoring would be conducted during times of remediation to ensure that control 

measures are working to regulate Site emissions. 

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7. Short-term monitoring - Monitoring of the surface water and ground water during 

remedial action may be necessary to ensure that runoff control measures are working. 

d. Explanations of Significant Differences

d.1 Explanation of Significant Differences dated September 28, 2004 

The EPA issued the ESD on September 28, 2004, to document post-ROD changes. Post-ROD 

negotiations between EPA and KCS indicated that the use of stabilization may not be the most 

efficient and cost effective method for addressing the slag waste. In addition, post-ROD 

discussions between the city and the community resulted in changing the proposed future Site 

reuse from recreational to industrial. Based on this information, EPA issued an ESD in 

September 2004 to document future Site use as industrial and to include a contingency remedy 

for the hazardous waste. 

This new information significantly changed a component of the selected remedy and added a 

contingency remedy; however, it did not fundamentally alter the overall cleanup approach, 

which was stabilization and offsite disposal. The change in land use required revisions to the 

risk assessment, which in turn revised the soil/sediment cleanup levels, the estimated waste 

volume to be addressed, and the estimated remedial costs. That change in September 2004, also 

required future operation and maintenance (O&M) activities, Five-year Reviews, and 

Institutional Controls (ICs). Those revisions decreased the volume of estimated soil/sediment 

waste from 15,000 yd3

 to 1,766 yd3 and reduced the estimated cost of remedial action from 

$5,007,412 to $2,751,901. Because stabilization may not be the most efficient and cost effective 

method for addressing the slag waste, excavation and offsite disposal was added to the overall 

remedial approach as the contingency remedy. Excavation and Offsite Disposal was added as 

the contingency remedy because it was presented in the 2002 Proposed Plan as an alternative, 

was evaluated using the nine criteria, and was commented on during the public comment period. 

 

The major components of the 2004 ESD were:

1. Stabilization - Approximately 1300 yd3 of hazardous waste would be excavated and 

stabilized. The material would be stabilized until sampling verifies that it no longer 

exceeds the TCLP for lead. After verification, the waste would be disposed offsite at a 

RCRA regulated Subtitle D facility. 

2. Asbestos Containing Material (ACM) - Materials would be consolidated onsite, 

contained, and transported offsite to a disposal facility licensed to accept ACM. Methods 

to control airborne dispersion of asbestos would be implemented during remediation. 

The estimated total volume of material was 22 yd3

. 

3. Underground Storage Tank (UST) - The UST, its contents, and the surrounding 

petroleum wastes would be characterized during the remedial design to determine 

whether the contents will be cleaned up under CERCLA or Oil Pollution Act authority. 

The surrounding polychlorinated biphenyl contaminated soils would be removed and 

disposed offsite in accordance with federal, state, and local regulations. The total volume 

of tank contents was estimated at 5,000 gallons. 

4. Building debris and water supply well - The onsite well would be plugged and 

abandoned in accordance with federal, state, and local regulations. Portions of the Site 

would be cleared, where necessary, and the existing buildings and foundations would be 

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demolished, removed and disposed offsite. 

5. Soil/sediment - Approximately 1,766 yd3 of lead and antimony contaminated soils and 

sediment would be excavated and disposed offsite in a RCRA Subtitle D facility. 

6. Air Monitoring - During remedial action, efforts would be made to control dust and runoff to limit the amount of materials that may migrate to a potential receptor. Air 

monitoring would be conducted during times of remediation to ensure that control 

measures are working to regulate Site emissions. 

7. O&M and ICs - The implementation of ICs and O&M would be necessary to restrict land 

use and ensure protectiveness. 

8. Five-Year Reviews - Because hazardous substances would remain on the Site above 

levels that allow for unlimited use and unrestricted exposure, reviews of the remedy 

would be conducted no less than every five years to ensure that the remedy functions as 

designed, and remains protective of human health and the environment. 

9. Contingency Remedy - Excavation and Offsite Disposal was added as a contingency for 

the hazardous waste. The implementation of this contingency was dependent on the 

completion of a treatability analysis of the stabilization process. 

d.2 Explanation of Significant Differences Contingency Remedy dated January 2, 2008 

As part of the Consent Decree negotiations and remedial design activities, the PRP, through a 

treatability evaluation, researched and reviewed options related to stabilization of the slag waste. 

Information gathered during the treatability evaluation was submitted by KCS in a letter dated 

September 13, 2007. The evaluation supported the use of the contingency remedy documented 

in the 2004 ESD as being a more efficient and cost effective approach for remediation of the 

hazardous slag waste. Therefore, the 2008 ESD was issued to document the information that 

significantly changes a component of the selected remedy and to invoke the Contingency 

Remedy as outlined in the 2004 ESD. The contingency remedy, Excavation and Offsite 

Disposal, included the removal of the 1,300 yd3 of hazardous slag waste from the Site with 

subsequent offsite disposal in a hazardous waste landfill. All other components of the remedy 

remain unchanged. 

The major components of the 2008 ESD were:

1. Hazardous Waste - Approximately 1300 yd3

 of hazardous waste would be excavated and 

disposed offsite at a RCRA regulated Subtitle C facility. 

2. Asbestos Containing Material (ACM) - Materials would be consolidated onsite, 

contained, and transported offsite to a disposal facility licensed to accept ACM. Methods 

to control airborne dispersion of asbestos would be implemented during remediation. 

The estimated total volume of material was 22 yd3

. 

3. Underground Storage Tank (UST) - The UST, its contents, and the surrounding 

petroleum wastes would be characterized during the remedial design to determine 

whether the contents would be cleaned up under CERCLA or Oil Pollution Act authority. 

 The surrounding polychlorinated biphenyl contaminated soils would be removed and 

disposed offsite in accordance with federal, state, and local regulations. Total volume of 

tank contents was estimated at 5,000 gallons. 

4. Building debris and water supply well - The onsite well would be plugged and 

abandoned in accordance with federal, state, and local regulations. Portions of the Site 

would be cleared, where necessary, and the existing buildings and foundations would be 

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demolished, removed and disposed offsite. 

5. Soil/sediment - Approximately 1,766 yd3 of lead and antimony contaminated soils and 

sediment would be excavated and disposed offsite in a RCRA Subtitle D facility. 

6. Air Monitoring - During remedial action, efforts would be made to control dust and runoff to limit the amount of materials that may migrate to a potential receptor. Air 

monitoring would be conducted during times of remediation to ensure that control 

measures are working to regulate Site emissions. 

7. O&M and ICs - The implementation of ICs and O&M would be necessary to restrict land 

use and ensure protectiveness. 

8. Five-Year Reviews - Because hazardous substances would remain on the Site above 

levels that allow for unlimited use and unrestricted exposure, reviews of the remedy 

would be conducted no less than every five years to ensure that the remedy is functioning 

as designed, and remains protective of human health and the environment. 

d.3 Explanation of Significant Differences dated November 9, 2009 

This ESD documented the results from the remedial action activities for the Site that support the 

Site’s unlimited use and unrestricted exposure scenario. Overall Site excavation and offsite 

disposal activities resulted in the removal of contaminated media to levels below the established 

cleanup levels for the recreational/residential scenario. Because the Site meets unlimited use and 

unrestricted exposure, the ESD removed the institutional controls, operations and maintenance, 

and five-year reviews as components of the overall Site remedy documented in the 2004 ESD 

and the 2008 Contingency ESD. Details related to the remedial action are found in the final 

Ruston Foundry Superfund Site Remediation Report dated March 9, 2009, and the Ruston 

Foundry Superfund Site Remediation Report Addendum dated September 10, 2009. These 

activities are summarized in Section II.g. 

e. Design Criteria

Prior to beginning remedial design and remedial action (RD/RA) activities, the EPA sent the 

identified PRPs general notice letters regarding Site liability and the opportunity to conduct the 

remedial design and remedial action activities. KCS stepped forward at this time and began 

negotiations with EPA. After a lengthy negotiation process, the Consent Decree was signed and 

later entered by the court on January 14, 2008. The Site RD/RA was completed as an EPA 

enforcement-lead project with LDEQ acting as the supporting agency, and KCS performing the 

work. 

Concurrently during negotiations, EPA, LDEQ, and KCS worked closely to develop and finalize 

the Remedial Design and Implementation Work Plan. Drafts were submitted in March 2004, 

September 2004, December 2007 (two), and February 2008. The final document submitted 

February 21, 2008 was accepted by EPA and LDEQ as final on February 28, 2008. 

The work plan included the following components: 

• Onsite consolidation of building debris, trash, and metal scrap. 

• Demolish standing structures, slabs and remnants, if necessary. 

• Clearing and grubbing areas requiring construction activity. 

• Distribution of wood chips on Superfund Site and/or adjacent KCS property. 

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• Establishing Areas of Interest (AOIs) that exceed 1400 milligrams per kilogram (mg/kg) 

lead and 820 mg/kg antimony, independent areas with TCLP or applicable synthetic 

precipitation leachate procedure test failures. 

• Identify, collect, and offsite disposal of regulated asbestos containing materials. 

• Excavate residual debris/lead soil within AOIs as necessary based on X-ray fluorescence 

(XRF) screening. 

• Load surface piles of slag into end dumps, transfer to a rail staging area, and load rail 

cars for offsite disposal. 

• Excavate up to 6 inches of surface soil from within each AOI as determined by XRF 

screening, collect verification samples and perform additional excavation from within the 

footprint if necessary. 

• Load excavated soil into end dumps and transport for disposal at an approved nonhazardous waste landfill. 

• Backfill excavated areas to pre-existing grade with clean soil. 

• Remove any liquids found in UST. 

• Excavate UST and dispose offsite at an appropriate licensed landfill. 

• Grout closed onsite well in accordance with prevailing Louisiana compliant methods and 

procedures. 

• Plug and abandon 5 onsite monitoring wells in accordance with prevailing Louisiana 

compliant methods and procedures. 

• Re-vegetate disturbed areas if needed. 

f. Community Involvement Activities

Throughout the Site’s history, the community has been interested and involved with Site activity. 

The EPA has kept the community and other interested parties updated on Site activities through 

informational meetings, fact sheets, and public meetings. Below is a brief summary of public 

outreach efforts. The EPA worked closely with the local Lower Third Neighborhood Group. 

$ NPL Listing: On January 19, 1999, EPA released a Site Update notifying the community 

that EPA and LDEQ were planning to propose the Site on the NPL in order to address 

Site contamination. This update also requested public comments on the NPL proposed 

package. The Site was placed on the NPL in May 1999, and a Site Update notifying the 

public was issued. 

$ Community Relations Plan: The EPA released a community relations plan in November 

1998 that outlined a program to address community concerns and keep citizens informed 

about and involved in the remedial activities. 

 

$ EPA Open Houses and Status Fact Sheets: The EPA and LDEQ held several open 

houses and mailed out fact sheets to discuss Site activities: 3/22/99, 3/28/00, 9/25/00, 

10/24/00, 4/9/01, 10/09/01, 03/28/02, 6/24/02, 2/11/08. 

$ Reuse Meetings: The EPA participated in two meetings with the City of Alexandria 

regarding Site reuse: 2/12-13/01, 02/26-27/01. 

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$ Proposed Plan Fact Sheet and Public Meeting: The Proposed Plan was signed on 

March 18, 2002 and presented to the community on March 28, 2002. The formal 

proposed plan Public Meeting was held on April 18, 2002, and the comment period lasted 

from April 1, 2002 through April 30, 2002. A public notice was published on April 1, 

2002. 

$ Facilitated Meeting with community and PRP: On February 26, 2004, EPA met with the 

community, KCS, and the city to discuss the future remedial action at the Site. This 

meeting resulted in a change to future reuse plans which ultimately led to the 2004 ESD. 

$ 2004 ESD and Public Meeting: A Notice of Availability and a brief description of the 

ESD was published in the local paper on July 27, 2004. A public meeting was held on 

August 10, 2004, and the comment period lasted from July 28 through August 31, 2004. 

The final ESD with responsiveness summary was signed on September 28, 2004, a fact 

sheet was mailed in September 2004, and a public notice published on October 7, 2004. 

$ 2008 ESD: A Notice of Availability and a brief description of the ESD was published in 

the local paper on January 9, 2008. 

$ Remedial Action: A fact sheet was sent out in July 2008 to update the community on the 

progress made during remedial action. This fact sheet also invited the community to 

attend a close out ceremony at the Site along with a Site tour on July 15, 2008. A followup fact sheet was sent to the community in October 2009, informing them that remedial 

action has been completed and that the Site is available for future reuse. 

$ 2009 ESD: A Notice of Availability and a brief description of the ESD was published in 

the local paper on November 18, 2009. A fact sheet summarizing the ESD was mailed to 

the community on November 18, 2009. 

g. Implemented Remedial Action Construction Activities

The Consent Decree was entered by the court on January 14, 2008. A notice to proceed was 

issued to the PRP on January 22, 2008. The final Remedial Design and Implementation Work 

Plan was submitted by the PRPs on February 21, 2008, and was accepted by the Agencies as 

final on February 28, 2008. 

Prior to implementing the response actions, a Louisiana-licensed asbestos abatement contractor 

completed a survey of and sampled potentially asbestos containing materials (ACM) on January 

28, 2008. Following receipt of the results of the asbestos sampling program, a second more local 

licensed contractor filed the required notification form on February 19, 2008, completed the 

abatement work on March 5, 2008, and disposed of 30 yd3

 on March 7, 2008. 

The KCS construction contractor, E Environmental Inc., mobilized personnel, equipment and 

operations trailers to the Site on February 25, 2008. Between March 5 and 14, 2008, the areas of 

interest (AOIs) and slag piles were identified and marked. From March 14 through May 20, 

2008, clearing and grubbing, soil excavation, slag removal, confirmation sampling, backfilling, 

and seeding activities were completed.

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A preliminary project closeout meeting/Site walk was held on May 10, 2008, by EPA, LDEQ, 

and KCS. A punch list was created at that time. KCS completed hydroseeding, water system 

construction, and punch list items between May 11 and 20, 2008, along with a pre-final 

inspection with EPA and LDEQ on May 14, 2008. A formal Site closeout Site walk with the 

same parties was conducted on June 17, 2008. No additional punch list items were identified. 

While performing Site remedial activities, KCS determined that minimal effort and cost would 

be required to address Site contamination to levels well below the cleanup levels established for 

lead and antimony under an industrial scenario as described in the 2004 ESD. KCS was back at 

the Site on July 9, 2008, collecting soil samples from locations identified in the Remedial 

Investigation with lead concentrations between 500 mg/kg and 1400 mg/kg. In addition, KCS 

collected confirmation soil samples within AOIs that were excavated to native clay visually, to 

establish that lead concentrations were below 500 mg/kg. A single sample location south of the 

drainage ditch was above the unrestricted use standard of 500 mg/kg. KCS remobilized to the 

Site on August 18, 2008, to complete excavation of this area. Using visual removal as the 

criteria, contamination was excavated from approximately 0.9 acres followed by the collection of 

confirmation samples. The excavation area was backfilled and seeded. EPA and KCS conducted 

a final Site walk of the south supplemental excavation on August 22, 2008. This supplemental 

work was completed on August 24, 2008. The Preliminary Close Out Report was signed on 

September 3, 2008, documenting the completion of onsite construction. 

Review of the draft remedial action report noted that an area along the southern boundary, just 

north of the canal may not have been fully addressed. On May 15, 2009, EPA and KCS 

performed a Site inspection to verify whether field activities were completed in this area. Visual 

inspection of the area confirmed that additional excavation would be required. 

KCS mobilized to the Site during the week of May 25, 2009, and began clearing the canal bank. 

Excavation of contaminated soil and slag began during the week of June 1, 2009, and was 

completed on June 23, 2009. EPA and LDEQ were onsite June 23, 2009, to conduct a Site 

inspection with KCS. Seeding of the canal bank was completed on July 2, 2009, and later 

inspected jointly by LDEQ and KCS on July 22, 2009. During the inspection, it was noted that 

significant erosion had taken place due to heavy rains. These areas were repaired with riprap 

and inspected by KCS and LDEQ on August 25, 2009.

The major components of the remedy implemented during 2008 and 2009 are:

1. Soil/sediment - Approximately 7,220 yd3

 [6,140 yd3 from the northern portion, 1069.5 

tons (713 yd3) from the southern portion, and 550 tons (367 yd3) from the canal bank] of lead and 

antimony contaminated soil and sediment were excavated and disposed offsite in a RCRA 

Subtitle D facility. Excavation progressed to the underlying native clay with depths ranging 

from 6 inches to 4 ft below original ground surface. Excavation areas were backfilled and 

graded to drain. All confirmation sample results were below the lead and antimony cleanup 

levels consistent with unlimited use and unrestricted exposure.

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2. Excavation of hazardous slag waste - Approximately 745.94 tons of hazardous waste 

from the northern portion and 45 yd3 of hazardous waste from the canal bank were excavated and 

shipped to a permitted RCRA hazardous waste landfill. 

3. Asbestos Containing Material (ACM) - A Louisiana-licensed asbestos abatement 

contractor visually identified building debris that potentially contained asbestos. The contractor 

collected 6 samples of building debris material and mapped the area around the former foundry 

building where the debris was located. Asbestos was positively identified in three samples, two 

of cement board building debris and one of black flashing building debris. The ACM was 

localized about the former foundry building with no evidence of burial. Prior to excavation 

activities, the ACM debris was consolidated onsite, contained, and transported offsite to a 

disposal facility licensed to accept ACM. Methods to control airborne dispersion of asbestos 

were implemented during remediation. The final total volume of material disposed offsite was 

30 yd3. After removal of the ACM, the underlying soil within the ACM area was incorporated 

into the overall slag and soil excavation areas. At a minimum, 6 inches of soil were removed 

during remediation, and the area was backfilled with clean fill upon completion. 

4. Underground Storage Tank (UST) - The UST was located and removed. Upon 

examination, the UST was determined to be steel with an estimated 500 gallon-capacity. The 

UST was found full of soil, and no staining was evident in the surrounding soil. The UST was 

decontaminated and disposed offsite. Surrounding soils were sampled and results met LDEQ 

UST cleanup levels. 

5. Building debris and water supply well - All 5 onsite wells were plugged and abandoned 

in accordance with federal, state, and local regulations. The Site was cleared (as necessary), and 

the existing metal buildings and concrete foundations were demolished. All steel material was 

decontaminated and recycled. All concrete was decontaminated and donated to a concrete 

recycling center. All other domestic trash dumped on the property was removed and disposed 

offsite. An estimated 43 tons of building debris and scrap metal and 550 yd3

 of concrete were 

recycled. 

6. Air Monitoring - During remedial action, efforts were made to control dust and run-off to 

limit the amount of materials that may migrate to a potential receptor. Air monitoring was 

conducted during times of remediation to ensure that control measures were working to regulate 

Site emissions. Monitors were placed upgradient, downgradient, and within the excavation areas 

as well as on personnel working within the exclusion zone. Air monitoring results did not 

exceed the Site-specific action levels for lead, antimony, or total suspended particulates. 

7. Backfill - Approximately 9,185 yd3

 of backfill (7,800 yd3 on the northern portion, 1,185 

yd3 on the southern portion, and 200 yd3 on the canal bank) were used to fill excavation areas and 

grade the Site for proper drainage. Backfill material was identified as suitable for the Site as 

sample results met the Site cleanup levels. 

h. Redevelopment Potential

The expected outcome of the remedy selected in the 2002 ROD was that the Site would no 

longer present an unacceptable risk to human health and the environment because the hazardous 

000087
Ruston Foundry Superfund Site January 2010 

Final Close Out Report Page 13 of 27 

waste would be excavated, stabilized, and disposed offsite; contaminated soil and sediment 

would be excavated and disposed offsite; and the ACM and UST would be removed and 

disposed offsite. The property would be suitable for recreational/residential land use 

approximately one year after the start of the remedial action. 

As documented in the Site’s remedial action documents, additional work was completed by KCS 

to meet the 2002 ROD cleanup levels for lead and antimony. Because the implemented remedy 

does not result in hazardous substances, pollutants, or contaminants remaining onsite above 

levels that allow for unlimited use and unrestricted exposure, a five-year review will not be 

required for this remedial action. In addition, no operation and maintenance or institutional 

controls restricting Site use or access will be necessary. 

The implemented remedy allows for reuse of the Site to beneficial uses. Through the Reuse 

Grant awarded by the Government in September 2000, the city of Alexandria, in coordination 

with the community, developed a future reuse plan. The implemented remedy is compatible with 

Alexandria’s Site reuse plan and is expected to support community revitalization activities. 

In support of the city’s redevelopment plan, KCS has provided access to the 30-acre property 

adjacent to the Ruston Foundry Site with the intention of deeding the property to the city once 

the city has completed its investigation. On February 17, 2009, the city completed a Phase 1 

investigation of this property. The city applied for and was granted a Brownfields Grant related 

to the 30-acre property on September 22, 2008. This grant will be used to assist with costs 

related to additional investigations of this property and support future redevelopment activities 

for the area. 

III. DEMONSTRATION OF CLEANUP ACTIVITY QUALITY ASSURANCE AND 

QUALITY CONTROL

The quality assurance/quality control (QA/QC) program for the Ruston Foundry Site was 

conducted in accordance with the work plan prepared to implement the remedial action 

construction activities. The following project plans and procedures were prepared for the 

remedial action and included in the final Remedial Design and Implementation Work Plan dated 

February 21, 2008. 

$ Site Management Practices 

$ Health and Safety Plan 

$ Field Sampling Methods and Procedures 

$ Quality Assurance Project Plan 

$ Data Management 

$ Pollution Control and Mitigation Practices 

$ Transportation, Disposal and Waste Management Practices 

The Remedial Design and Implementation Work Plan guided the cleanup activities such that 

quality assurance and quality control requirements for the Site were met. The EPA, in 

conjunction with LDEQ, conducted regular oversight throughout the implementation of the 

remedial action. In addition to conducting oversight of the project activities, EPA was in regular 

contact by phone and e-mails with the PRP and State project managers during construction 

activities. The EPA and LDEQ reviewed and commented on all project plans for the Site and 

000088
Ruston Foundry Superfund Site January 2010 

Final Close Out Report Page 14 of 27 

participated in the Pre-final and Final Construction Inspections. In addition, LDEQ reviewed 

and commented on the Preliminary Close Out Report. 

The quality assurance project plan incorporated EPA and State comments and requirements. The 

EPA and LDEQ reviewed the remedial action construction work for compliance with quality 

assurance and quality control (QA/QC) protocols. Construction activities at the Site were 

determined to be consistent with the ROD, ESDs, and the Remedial Design and Implementation 

Work Plan and specifications. Confirmatory inspections, independent testing, and evaluations of 

materials and workmanship were performed to evaluate and review the results of QA/QC 

activities. Deviations or non-adherence to QA/QC protocols or specifications were properly 

documented and resolved. 

All monitoring equipment was calibrated and operated in accordance with the manufacturer’s 

instructions. During sampling, equipment was properly decontaminated prior to each use. The 

EPA analytical methods were used for all confirmation and monitoring samples during RA 

activities. Contract laboratory program-like procedures and protocol were followed for soil and 

air analyses during the RA using a private laboratory contracted by the PRP. Air sample 

analyses followed EPA protocols in the Compendium of Methods for the Determination of Toxic 

Compounds in Ambient Air. The EPA and the State determined that analytical results were 

accurate to the degree needed to assure satisfactory execution of the RA. 

IV. MONITORING RESULTS 

While performing Site remedial activities, KCS determined that minimal effort and cost would 

be required to address Site contamination to levels well below the cleanup levels established for 

lead and antimony under an industrial scenario as described in the 2004 ESD. Areas of 

excavation included the removal of contaminated soil and slag (Figures 1 and 2), and 

confirmation sample results show levels of lead and antimony to be less than the cleanup levels 

required for unlimited use and unrestricted exposure as determined by the Site-specific risk 

assessment. Lead concentrations are less than 500 mg/kg, with the highest concentration left 

onsite at 342 mg/kg, and antimony concentrations are less than 150 mg/kg, with the highest 

concentration left onsite at 18.9 mg/kg. The concentrations are consistent with accepted 

unlimited use and unrestricted exposure scenarios. In addition, identified ACM, hazardous 

waste (slag), and the UST were removed and disposed offsite. Based on Site construction 

activity and subsequent confirmation sampling, all remedial action objectives have been met as 

well as the criteria for unlimited use and unrestricted exposure. The excavation areas were 

backfilled with suitable materials meeting Site-specific cleanup levels, graded for proper 

drainage, and seeded. 

Monitoring activities implemented during 2008 and 2009 remedial action are presented in the 

following paragraphs. 

1. Asbestos Containing Material (ACM) - A Louisiana-licensed asbestos abatement 

contractor visually identified building debris that potentially contained asbestos. The 

contractor collected 6 samples of building debris material and mapped the area around 

the former foundry building where the debris was located. Asbestos was positively 

identified in three samples, two of cement board building debris and one of black flashing 

000089
Ruston Foundry Superfund Site January 2010 

Final Close Out Report Page 15 of 27 

building debris. The ACM was localized about the former foundry building with no 

evidence of burial. Prior to excavation activities, the ACM debris was consolidated 

onsite, contained, and transported offsite to a disposal facility licensed to accept ACM. 

Methods to control airborne dispersion of asbestos were implemented during 

remediation. The final total volume of material disposed offsite was 30 yd3. After 

removal of the ACM, the underlying soils within the ACM area were incorporated into 

the overall slag and soil excavation areas. At a minimum, 6 inches of soil were removed 

during remediation, and the area was backfilled with clean fill upon completion. 

2. Slag - Slag piles were visually identified, outlined and surveyed. Slag was found in two 

large piles, large pieces near and around the southern machine shop slab, and 

sporadically in smaller pieces throughout the former process area. Slag was either 

handpicked and moved with wheelbarrows or shoveled using heavy equipment. After 

removal of the slag, the underlying soils were incorporated into the overall soil 

excavation areas. At a minimum 6 inches of soil were removed during remediation, and 

the area was backfilled with clean fill upon completion. Approximately 745.94 tons of 

hazardous waste from the northern portion and 45 yd3 of hazardous waste from the canal 

bank were excavated and shipped to a permitted RCRA hazardous waste landfill. 

3. Slag Staging Area - The staging pad was built using clay formed with a dozer and 

compacted with a vibratory roller. Three foot high clay dikes were constructed around 

three sides and a hay-bale/drainage fabric filter dike was installed on the fourth (north) 

side to filter rainwater and preclude water ponding. Two layers of 10 millimeter (mil) 

polyethylene liner were then placed on the pad bed. A layer of native clay was added on 

top of the polyethylene to create a composite protective layer. Upon slag removal, the 

clay layer and underlying liner were removed and disposed removing all potentially 

contaminated materials. The staging pad area was backfilled with clean material and 

graded for drainage. 

4. Underground Storage Tank (UST) - The UST was plumbed at two ends and found about 

2 feet below ground level. It appeared to be an open top, at-grade vessel with an 

approximate 500-gallon capacity. The vessel most likely was buried during previous Site 

operations. The UST was filled with soil and a few gallons of rainwater. No staining 

was evident in the surrounding soil; however, the rainwater had a petroleum-like odor. 

Two soil samples were collected from the base of the excavation area and analyzed for 

total petroleum hydrocarbons by EPA Method 8015 diesel range organics and kerosene. 

Results were below LDEQ UST standards. The UST was decontaminated and disposed 

offsite. The surrounding soil was incorporated into the overall soil excavation areas. 

5. Silt Fencing/hay Bales - Erosion control measures were used to minimize silt loss and 

contaminant migration. Hay bales were staked periodically along the drainage cut on the 

haul road’s north side to minimize silt loss. Silt fencing was also placed along the entire 

northern perimeter of drainage canal to minimize silt loss to the drainage canal. 

000090
Ruston Foundry Superfund Site January 2010 

Final Close Out Report Page 16 of 27 

6. Water Supply Well - All 5 onsite monitoring wells, designated MW-1 through MW-5, 

were closed by a licensed Louisiana contractor in accordance with LDEQ State 

requirements. 

7. Building Debris - The concrete slabs were broken with jackhammers, stockpiled with the 

excavator, and pressure washed to remove loose soil. After decontamination, an 

estimated 550 yd3 of concrete was transported offsite and donated to a local concrete 

recycler. All other domestic trash dumped on the property was removed and disposed 

offsite. Remnants of four remaining structures and a large amount of miscellaneous 

scrap metal were consolidated into piles, power washed, and loaded onto trailers. 

Approximately 43 tons of steel and other metal debris were transferred to Alexandria 

Scrap Iron for recycling. 

8. Transport by Rail - Gondola cars were loaded to a depth of no more that 1.5 feet from the 

top of the cars. Tarps were used to prevent loss of material during transport. Prior to 

transport, cars were visually inspected and decontaminated as necessary. 

9. Transport by Truck - Trucks were loaded to appropriate capacity. Tarps were used to 

prevent loss of material during transport. Prior to transport, trucks were visually 

inspected and decontaminated as necessary. 

10. Tree Chipping - Approximately 5 acres of the Site and 4 Acres of the adjacent (offsite) 

KCS land was cleared, grubbed, and the wood chipped. Two composite wood chip 

samples (one from inside the restricted area and one immediately north of the restricted 

area) were submitted to Pace Analytical Services, Inc. (Pace) of St. Rose, Louisiana and 

analyzed for lead and antimony. The results of the two composite samples indicated both 

lead and antimony were below Site-specific cleanup levels. Lead was detected in both 

samples at a concentration of 0.629 mg/kg and 2.37 mg/kg. Antimony was reported as 

non-detected concentrations at reporting limits of 5.17 mg/kg and 4.23 mg/kg. The wood 

chips were later redistributed onsite. 

11. Confirmation Samples - Five-point composites were collected from 25ft by 25ft grids 

used across the northern portion of the property. These grid locations were supplemented 

with six additional confirmation sample locations in areas where soil and slag locations 

overlapped. The southern portion of the property was sampled based on sample locations 

from the RI and the estimated location of the historic foundry building footprint. 

Soil was initially removed in approximately 3-inch lifts. Upon removal of the uppermost 

three-inch lift of soil, x-ray fluorescence (XRF) screening was conducted for lead using a 

Niton XLi Spectrometer. Based on the XRF screening results, additional soil was 

removed to the next lower three-inch lift wherever necessary. The EPA and KCS project 

managers recognized quickly that the variable distribution of lead encountered in foundry 

fill material made the sequence of excavating soil in 3-inch lifts with XRF sampling time 

consuming. Therefore, a joint decision by EPA and KCS was made to simply excavate 

the AOIs visually to native clay and discontinue XRF screening. 

000091
Ruston Foundry Superfund Site January 2010 

Final Close Out Report Page 17 of 27 

After numerous analyses of the native clay, it was confirmed that lead and antimony were 

found at background concentrations within the native clay which underlies the foundry 

waste material. In addition, since antimony results were consistently below background, 

sampling for antimony was discontinued. The decision was made to visually excavate 

directly to clay in each AOI and adjoining areas where slag pile debris was removed or 

was co-mingled with AOIs. In some cases, rather than collect second or third rounds of 

confirmation samples, visual observation of the native clay was sufficient to demonstrate 

clean conditions. As such, some of the smaller AOIs and former slag pile areas did not 

initially have lab tests representing clay, as the lead and antimony content of the clay 

characteristics had been previously confirmed and the visual observation approach was 

determined to be acceptable to all parties. 

At the completion of the excavation activities, data were reviewed and it was noted that 

the remedial actions had potentially addressed all locations that exceeded the cleanup 

levels for unlimited use and unrestricted exposure either through clear and grub actions 

or AOI excavations. KCS re-mobilized to the Site in July 2008 to collect additional 

confirmation samples at 17 locations throughout the Site which had exhibited lead 

concentrations between 500 mg/kg and 1400 mg/kg based upon RI data. Each of the 

former RI sampling points was located using the survey coordinates published in the RI 

Report. The locations sampled represent the lead exceedences between 500 and 1400 

mg/kg in areas not expressly identified as AOIs/slag piles. In addition, the three AOIs 

that did not have a quantitative verification of clean soil after switching to visual clean 

protocols were sampled to confirm results were below the Site-specific cleanup levels. 

Of the 17 samples collected in July 2008, one sample location, located south of the canal, 

had a concentration higher than 500 mg/kg lead. The area was excavated to native clay 

and 6 confirmation samples were collected. All sample results were below the lead 

cleanup level. 

Review of the draft remedial action report noted an area along the southern border just 

north of the canal that may not have been fully addressed. A Site inspection confirmed 

further excavation was necessary. At the completion of this supplemental work, 10 

confirmation samples were taken and analyzed for lead. All sample results were below 

the lead cleanup level. 

Approximately 7,220 yd3

 [6,140 yd3 from the northern portion, 1069.5 tons (713 yd3)

from the southern portion, and 550 tons (367 yd3) from the canal bank] of lead and 

antimony contaminated soil were excavated and disposed offsite in a RCRA Subtitle D 

facility. Excavation progressed to the underlying native clay with depths ranging from 6 

inches to 4 ft below original ground surface. Excavation areas were backfilled and 

graded to drain. All confirmation sample results were below the lead and antimony 

cleanup levels consistent with unlimited use and unrestricted exposure. 

12. Backfill - Six (6) composite samples were taken of the stockpiled native clay placed on 

the adjacent KCS property by the city of Alexandria during drainage ditch construction. 

Two (2) composite samples were collected from an offsite borrow source used for 

000092
Ruston Foundry Superfund Site January 2010 

Final Close Out Report Page 18 of 27 

backfill during the 2008 and 2009 remedial activity. All samples were analyzed for 

RCRA metals. Results were consistent with background, and specifically met the 

cleanup levels for lead and antimony. Approximately 9,185 yd3 of backfill (7,800 yd3 on 

the northern portion, 1,185 yd3 on the southern portion, and 200 yd3 on the canal bank) 

were used to fill excavation areas and grade Site for proper drainage. 

13. Air - During remedial action, efforts were made to control dust and run-off to limit the 

amount of materials that may migrate to a potential receptor. Work areas were 

continually wetted down to control potential dust emissions. Air monitoring was 

conducted during times of remediation using 1) Site meteorological monitoring for wind 

speed and direction; 2) perimeter air monitoring for antimony, lead and particulate; 3) 

real-time onsite particulate air monitoring; and 4) personal worker air sampling for 

antimony, lead, and particulates. Monitors were placed upgradient, downgradient, and 

within the excavation areas as well as on personnel working within the exclusion zone. 

Air monitoring results did not exceed the Site-specific action levels for lead, antimony, or 

total suspended particulates. 

Air sampling at the perimeter monitoring stations was conducted 24 hours a day, except 

those days when remedial activities were halted, using high volume air samplers to 

collect total suspended air particulate for analysis of antimony and lead and to collect 

particulate matter with an aerodynamic diameter less than or equal to 10 micrometers in 

size (PM10). The highest detected concentration of lead (0.34 micrograms per cubic 

meter (μg/m3

) was below the Site-specific action levels of 20.8 μg/m3 over a 24-hour 

period, 7.3 μg/m3 over a 72 hour period, and 1.5 μg/m3 remedial action average. 

Antimony was not detected in any perimeter air sample, with the exception of two sample 

results, above the 0.2 μg/m3

 Site-specific action level. On March 20, 2008, detection 

limits for antimony for Station 2 (duplicate) and Station 4 were 0.81 and 0.91 μg/m3

, 

respectively, due to the shortened day of monitoring and the lesser volume of air 

sampled. The highest PM10 concentration detected (62 μg/m3

) was below the 100 μg/m3

Site-specific action level. 

Real-time air monitoring for inhalable particulate matter was performed throughout the 

project using the hand-held DustTrak aerosol monitor (model 8520). The highest realtime concentration of PM10 in air was 2.02 milligrams per cubic meter (mg/m3

) which is 

well below the 5 mg/m3

 worker safety action level for onsite particulates. 

Key individuals determined to inhale higher amounts of antimony, lead, and particulate 

were monitored during the work day. Worker safety action levels for antimony, lead, and 

total suspended particulates in personal worker samples were 500 μg/m3

, 30 μg/m3, and 

10 mg/m3, respectively. Antimony was not detected in any personal sampler, the highest 

detected result for lead was 4.9 μg/m3 which is below the action level of 30 μg/m3

, and 

the highest detected result for particulate matter was 2 mg/m3

 which is below the action 

level of 10 mg/m3

. 

 

000093
Ruston Foundry Superfund Site January 2010 

Final Close Out Report Page 19 of 27 

V. SUMMARY OF OPERATION AND MAINTENANCE

The cleanup of the Site complies with and meets the requirements for unlimited use and 

unrestricted exposure. Because of this, the Site does not require operation and maintenance, 

institutional controls, or five-year reviews. 

VI. SUMMARY OF REMEDIATION COSTS

The cost estimate to implement the remedial action at the Site has been modified from the 

original estimate provided in the ROD through each ESD (Table 1). The original estimate for 

Stabilization and Offsite Disposal as presented in the ROD was $5,007,412. This was later 

revised to an estimated $2,751,901 for Stabilization and Offsite Disposal or $3,035,002 for 

Excavation and Offsite Disposal due to a change in land use from recreational/residential to 

industrial and the addition of the contingency remedy. The estimated remedy cost was further 

revised in the 2008 ESD based on the treatability evaluation presented by KCS which noted rail 

would be used for transportation at no cost and that the disposal fee provided by the landfill 

would be closer to $75/ton rather than the estimated $214/ton. This reduced the estimated cost 

from $3,035,002 to $2,459,427. The final revision to the estimated remedy cost was documented 

in the 2009 ESD, which removed the requirements for O&M, ICs, and Five-year reviews. This 

reduced the cost from $2,459,427 to $2,018,631. 

Table 1: Comparison of Remedy Cost Estimates 

Document Component Cost 

ROD Stabilization and Offsite Disposal $5,007,412 

ESD 2004 Stabilization and Offsite Disposal 

Contingency: 

Excavation and Offsite Disposal 

$2,751,901 

$3,035,002 

ESD 2008 Excavation and Offsite Disposal $2,459,427 

ESD 2009 Excavation and Offsite Disposal $2,018,631 

000094
Ruston Foundry Superfund Site January 2010 

Final Close Out Report Page 20 of 27 

All remedial action activities were completed by KCS. During the remedial action EPA 

provided oversight of all activities and subsequent review of final reports. Costs related to these 

actions are provided in Table 2. 

Table 2: Actual Cost for the Remedial Action

Activity Cost 

Mobilization $60,165 

Bridge Work $33,650 

Analytical $20,137 

Backfill $45,707 

Disposal $247,339 

Transportation $130,060 

Demobilization $16,842 

Equipment $413,316 

Labor $1, 011,912 

Subtotal $1,979,128 

Oversight $58,800 

Total $2,037,928 

VII. PROTECTIVENESS 

This Site meets all the site completion requirements as specified in “Close Out Procedures for 

National Priorities List Sites” (EPA OSWER Directive 9320.2-09A-P, January 2000). 

Specifically, confirmatory sampling results for lead and antimony are below the cleanup criteria 

of 500 mg/kg and 150 mg/kg respectively, and all cleanup actions specified in the ROD and 

subsequent ESDs have been implemented. Therefore, contamination above Site-specific healthbased levels have been removed such that the Site no longer presents an unacceptable risk to 

human health and the environment and is available for unlimited use and unrestricted exposure. 

A bibliography of all reports relevant to the completion of this Site under the Superfund program 

is included in Section X. 

VIII. FIVE-YEAR REVIEW

Based on confirmation sample results, hazardous substances above health based levels have been 

removed from the Ruston Foundry Superfund Site, which allows for unlimited re-use of the Site 

property. Therefore, neither a policy nor a statutory review will be necessary for the Site to 

ensure that the remedy is, or will be, protective of human health and the environment. Pursuant 

to CERCLA section 121(c), 42 U.S.C. ' 9621(c), and as provided in the current guidance on 

Five-Year Reviews: EPA 540-R-01-007, OSWER No. 9355.7-03B-P, Comprehensive Five-Year 

Review Guidance, June 2001, EPA will not need to conduct a statutory five-year review for the 

Ruston Foundry Superfund Site. 

000095
IX. AUTHORIZING SIGNATURES

This COR documents Site completion and signifies the end of all response actions at the Ruston

Foundry Site. This document was finalized with the concurrence ofthe Louisiana Department of

Environmental Quality (Appendix A).

Ruston Foundry Superfund Site

Final Close Out Report

Date: II1 Z1/lI ~---

0

January 2010

Page 21 of27

000096
Ruston Foundry Superfund Site January 2010 

Final Close Out Report Page 22 of 27 

X. BIBLIOGRAPHY 

CH2M Hill, 2000. Pre-Remedial Investigation Sampling Event, Ruston Foundry Site. 

March, 2000. 

CH2M Hill, 2001. Final Ecological Risk Assessment, Ruston Foundry Site, Alexandria, Rapides 

Parish, Louisiana. Remedial Action Contract Work Assignment 930-RICO-061F. October 2001. 

CH2M Hill, 2002a. Final Remedial Investigation, Ruston Foundry Site, Alexandria, Rapides 

Parish, Louisiana. Remedial Action Contract Work Assignment 930-RICO-061F, 2 vols. 

February 2002. 

CH2M Hill, 2002b. Final Feasibility Study, Ruston Foundry Site, Alexandria, Rapides Parish, 

Louisiana. Remedial Action Contract Work Assignment 930-RICO-061F. February 2002. 

CH2M Hill, 2002c. Final Human Health Risk Assessment, Ruston Foundry Site, Alexandria, 

Rapides Parish, Louisiana. Remedial Action Contract Work Assignment 930-RICO-061F. 

March 2002. 

Ecology and Environment, Inc., 1991. Site Assessment Report, Ruston Foundry. 

February 28, 1991. 

Ecology and Environment, Inc., 1994. Site Assessment Report, Ruston Foundry. May 18, 1994. 

Ecology and Environment, Inc., 1998. Expanded Site Inspection Report for Ruston Foundry. 

September 1998. 

Ecology and Environment, Inc., 1999a. Removal Assessment Report for Ruston Foundry - 

Offsite. September 20, 1999. 

Ecology and Environment, Inc., 1999b. Time-Critical Removal Report for Ruston Foundry - 

Onsite. June 28, 1999. 

Kansas City Southern Railway, 2007. ESD Treatability Study, Ruston Superfund Site. 

September 13, 2007. 

Kansas City Southern Railway, 2008. Remedial Design and Implementation Work Plan. 

February 21, 2008. 

Kansas City Southern Railway, 2009. Ruston Foundry Superfund Site Remediation, Final 

Report. March 9, 2009. 

000097
Ruston Foundry Superfund Site January 2010 

Final Close Out Report Page 23 of 27 

Kansas City Southern Railway, 2009. Ruston Foundry Superfund Site Remediation, Final 

Report-Addendum. September 10, 2009. 

U.S. Environmental Protection Agency, 1999. Metals-In-Soil, Presumptive Remedy. 

EPA/540/F-98/054. OSWER Directive 9355.0-72FS. September 1999. 

U.S. Environmental Protection Agency, 2002. Record of Decision. June 24, 2002. 

U.S. Environmental Protection Agency, 2004. Explanation of Significant Differences. 

September 28, 2004. 

U.S. Environmental Protection Agency, 2008. Explanation of Significant Differences 

Contingency Remedy. January 2, 2008. 

U.S. Environmental Protection Agency, 2009. Explanation of Significant Differences. 

November 9, 2009. 

000098
Ruston Foundry Superfund Site January 2010 

Final Close Out Report Page 24 of 27 

Appendix A 

Louisiana Department of Environmental Quality Concurrence Letter 

000099
000100
A1 289859.260 

A2 289881.800 A3 289908.570 A4 289928.820 A5 289953.480 A6 289977.060 A7 290001.360 B1 289850.850 B2 289874.560 B3 289898.250 B4 289921.260 B5 289945.820 B6 289969.870 B7 289994.100 B8 290017.620 B11 290089.060 C1 289842.790 C2 289867.140 C3 289890.850 C4 289914.730 C5 289938.640 C6 289962.570 C7 289986.750 C8 290010.080 C11 290081.600 C12 290105.340 D1 289835.190 D2 289859.290 D3 289883.340 D4 289907.100 D5 289931.060 D6 289954.840 D7 289978.420 D8 290002.450 D9 290026.510 D10 290050.050 D11 290073.930 D12 290097.810 E1 289826.130 E2 289851.940 E3 289875.800 E4 289899.540 E5 289923.530 E6 289947.240 E7 289971.290 E8 289994.960 E9 290018.740 E10 290042.760 E11 290066.520 E12 290090.250 F1 289817.330 

EPA # NORTHING EASTING ELEVATION

D 2 RA 290257.607 3299451.239 74.79

D 3 RA 290223.390 3299534.542 74.80

DPG2 289898.000 3299529.000 74.54G2RA 290049.000 3299396.000 76.02H2RA 289977.000 3299373.000 76.95H3RA 289952.000 3299444.000 77.22HS11 289973.000 3299372.000 77.06HS12 289983.000 3299380.000 76.71I1RA 289921.092 3299291.231 74.7312RA 289910.000 3299356.000 76.4613RA 289885.000 3299428.000 76.70J2RA 289844.000 3299341.000 76.00J3RA 289828.000 3299417.000 69.62J4RA 289797.000 3299475.000 73.68K3RA 289733.642 3299373.483 75.04SGP101 289980.254 3299595.233 73.69SGP102 289968.555 3299600.801 73.44SGP201 289945.281 3299543.293 73.79SGP301 290115.754 3299462.664 76.96SGP302 290139.750 3299469.614 76.49SEͲ3 289913.684 3299551.213 73.58SEͲ2 289956.746 3299551.911 73.61SEͲ1 289960.470 3299582.329 73.34N W Ͳ1 290193.599 3299453.622 75.11N W Ͳ3 290225.076 3299466.990 74.96N W Ͳ2 290215.390 3299441.012 75.38S Ͳ1 289719.728 3299248.160

S Ͳ2 289709.097 3299281.481

S Ͳ3 289711.508 3299323.125S Ͳ4 289661.391 3299352.697S Ͳ5 289679.599 3299403.940S Ͳ6 289628.763 3299397.979S Ͳ7 289575.053 3299402.542S Ͳ8 289530.878 3299369.933

000101
000102
Concurrence Page for the Ruston Foundry

Final Close Out Report

~~Bud y , Section Chief

LA/NM/OK Section

~~. Donald Williams, Deputy Associate Director

Remedfal }3ranch

/////;:;;t c; '~0J- , - ,/.~);:!<// / ///.,J;,... / #.····y/·'T, L-~/ 7 ,,'. . ~/v

Charles Faultry, Ass ciate Director

Remedial Branch

coif {I ( "-,oOl 0

Date

Date

:L/d-'

I Date

Date

Pam Phillips, Deputy Dftrector Date

Superfund Division

Re~onal Cou,nsel Superfund Branch

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Amy S inas, Assistant Regional Counsel

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Director, Superfund Division

000103