U.S. ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

 Evaluation Report 

EPA Should Improve Oversight of 

Long-Term Monitoring at 

PAB Oil and Chemical Services, 

Inc., Superfund Site in Louisiana 

Report No. 10-P-0229 

 September 21, 2010 
 

Report Contributors: Carolyn Copper 

 Patrick Milligan 

 Kathryn Hess 

 Denise Rice 

 Martha Chang 

Abbreviations 

EPA U.S. Environmental Protection Agency 

NPL National Priorities List 

OIG Office of Inspector General 

RPM Remedial Project Manager 

Cover photo: Monitoring well MW-7 at the remediated PAB Oil and Chemical Services, Inc., 

Superfund Site, Abbeville, Louisiana, March 2008. (EPA OIG photo) 
 

 

U.S. Environmental Protection Agency 10-P-0229 

September 21, 2010 Office of Inspector General 

At a Glance 

Catalyst for Improving the Environment 

Why We Did This Review 

The Office of Inspector 

General (OIG) is testing longterm monitoring results at 

Superfund sites the U.S. 

Environmental Protection 

Agency (EPA) has deleted 

from the National Priorities 

List (NPL). PAB Oil and 

Chemical Services, Inc., 

Superfund Site, in Abbeville, 

Louisiana, is one of eight sites 

being reviewed. In March 

2008, the OIG obtained 

ground water samples from 

the site and conducted an 

inspection. 

Background 

EPA placed PAB on the 

Superfund NPL in 1989. 

Recovery and disposal of oil 

and gas wastes had 

contaminated the site with 

arsenic, barium, and organic 

compounds. Remedial action 

included treating, 

consolidating, and capping the 

onsite soils and wastes. 

Region 6 deleted PAB from 

the NPL in 2000 after it met 

clean-up goals. 

For further information, 

contact our Office of 

Congressional, Public Affairs 

and Management at 

(202) 566-2391. 

To view the full report, 

click on the following link: 

www.epa.gov/oig/reports/2010/ 

20100921-10-P-0229.pdf 

EPA Should Improve Oversight of Long-Term 

Monitoring at PAB Oil and Chemical Services, Inc., 

Superfund Site in Louisiana 

What We Found 

Our independent ground water sampling results from the PAB Oil and Chemical 

Services, Inc., Superfund Site were consistent with Region 6’s valid historical 

results. However, we found that Region 6 accepted from the responsible parties’ 

contractor two types of invalid ground water data at PAB and included that invalid 

data in its analyses. For two wells, data were collected on stagnant water at the 

bottom of the wells, below screen openings where the water enters the wells. 

Consequently, data on both water quality and water levels were collected contrary 

to accepted procedures and were invalid. Ground water level measurements are 

needed to understand the direction ground water flows. Measures of water quality 

are needed to ensure that the contamination treatment actions are successful and 

ground water quality does not degrade. 

Region 6 said it was aware of the declined water level condition, but noted it had 

data from other wells that were sufficient to determine the direction of ground 

water flow and that the remedy was protective of human health and the 

environment. We agree that the invalid data did not have adverse implications for 

the Region’s protection decision because ground water flows past these two wells 

before flowing under the area where contaminated soils and wastes were capped. 

However, if ground water conditions were to change, the invalid data could 

impede the Region’s ability to determine whether the site’s clean-up remedy is 

still protective and whether the network of ground water monitoring wells remains 

effective. 

What We Recommend 

We recommended that Region 6 improve oversight at PAB by amending the site’s 

most recent Five-Year Review to identify invalid data, and by modifying the 

long-term monitoring plan to ensure collection and reporting of valid data on site 

conditions. The Region’s official response only partly addressed one 

recommendation and did not address the other. In a follow-up meeting, Region 6 

staff committed to completing actions that would meet the intent of both 

recommendations. We consider both recommendations to be “undecided with 

resolution efforts in progress.” In its final response to this report, Region 6 should 

provide a corrective actions plan for both recommendations, including estimated 

or actual milestone completion dates. 
 

 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

THE INSPECTOR GENERAL 

September 21, 2010 

MEMORANDUM 

SUBJECT:	 EPA Should Improve Oversight of Long-Term Monitoring at 

PAB Oil and Chemical Services, Inc., Superfund Site in Louisiana 

Report No. 10-P-0229 

FROM:	 Arthur A. Elkins, Jr. 

 Inspector General 

TO: Al Armendariz 

 Region 6 Administrator 

This is our report on the subject evaluation conducted by the Office of Inspector General (OIG) 

of the U.S. Environmental Protection Agency (EPA). This report contains the findings from our 

sampling at the PAB Oil and Chemical Services, Inc., Superfund Site and corrective actions the 

OIG recommends. Region 6 provided comments on our draft report. This report represents the 

opinion of the OIG and does not necessarily represent the final EPA position. Final 

determinations on matters in this report will be made by EPA managers in accordance with 

established resolution procedures. 

The estimated cost of this report – calculated by multiplying the project’s staff days by the 

applicable daily full cost billing rates in effect at the time, then adding the contractor costs – is 

$202,633. 

Action Required 

In accordance with EPA Manual 2750, you are required to provide a written response to this 

report within 90 calendar days. Your response will be posted on the OIG’s public Website, 

along with our comments on your response. Your response should be provided in an Adobe PDF 

file that complies with the accessibility requirements of section 508 of the Rehabilitation Act of 

1973, as amended. If your response contains data that you do not want to be released to the 

public, you should identify the data for redaction. You should include a corrective actions plan 

for agreed-upon actions, including milestone dates. We have no objections to the further release 

of this report to the public. This report will be available at http://www.epa.gov/oig. 
If you or your staff have any questions regarding this report, please contact Wade Najjum, 

Assistant Inspector General, at (202) 566-0832 or najjum.wade@epa.gov; or Carolyn Copper, 

Director for Program Evaluation, Hazardous Waste Issues, at (202) 566-0829 or 

copper.carolyn@epa.gov. 
 

 

 

 

EPA Should Improve Oversight of Long-Term Monitoring at 10-P-0229 

PAB Oil and Chemical Services, Inc., Superfund Site in Louisiana 

Table of Contents 

Chapters 

1 Introduction ........................................................................................................ 1 

Purpose ....................................................................................................... 1 

Background ................................................................................................. 1 

 Noteworthy Achievements........................................................................... 1 

 Scope and Methodology.............................................................................. 2 

2 Region 6 Included Invalid Data in Ground Water Analyses ........................... 3
 

Invalid Water Quality Data........................................................................... 3 

Invalid Water Level Data ............................................................................ 4 

Conclusions ................................................................................................ 5 

 Recommendations ..................................................................................... 5 

EPA Region 6 Response to Draft Report and OIG Evaluation ................... 5 

Status of Recommendations and Potential Monetary Benefits ............................. 7 

Appendices 

A Details on Invalid Ground Water Level Data.................................................... 8 

B Details on Sampling Methodology, Data Analyses, 

and Results of Comparisons and Site Inspection ......................................... 11 

C EPA Region 6 Response to Draft Report and OIG Evaluation ....................... 13 

D Distribution ........................................................................................................ 21 
 10-P-0229 

Chapter 1

Introduction 

Purpose 

The Office of Inspector General (OIG) of the U.S. Environmental Protection 

Agency (EPA) is evaluating long-term monitoring at Superfund sites deleted from 

the National Priorities List (NPL). This evaluation is to determine whether EPA 

has valid and reliable data on the conditions of these sites. PAB Oil and Chemical 

Services, Inc., Superfund Site, in Abbeville, Louisiana, is one of eight sites being 

reviewed. At PAB, we collected ground water samples and conducted a site 

inspection. We compared our results to past results reported by EPA Region 6. 

Background 

PAB was a recovery and disposal facility for mud and saltwater generated in oil 

and gas exploration and production. Operations at PAB started in 1978 and lasted 

for approximately 5 years. Site activities resulted in arsenic, barium, and organic 

compound contamination of onsite soil and wastes. EPA placed PAB on the 

Superfund NPL in 1989. After determining that remedial action had achieved the 

clean-up goals, Region 6 deleted PAB from the NPL in January 2000. 

The 1993 Record of Decision stated that ground water would be monitored for 

30 years to ensure that the contamination treatment actions are successful and 

ground water quality does not degrade. The responsible parties’ 1998 monitoring 

plan called for ground water levels to be measured and ground water samples to 

be collected semiannually. The newest plan, approved by Region 6 in 2009, 

states that the responsible parties will measure water levels in nine monitoring 

wells once per year and, prior to 2012, sample four of the wells twice and one 

well once to assess ground water quality. 

The Comprehensive Environmental Response, Compensation, and Liability Act 

(also known as Superfund) requires that Region 6 review every 5 years the 

protection provided by the remedial action at sites where contaminants were left 

in place. This is called the Five-Year Review. Region 6 based its Five-Year 

Reviews at PAB on the information the responsible parties submitted in their 

monitoring reports. The next Five-Year Review is required in 2012. 

Noteworthy Achievements 

In 1991, the responsible parties conducted an emergency action to remove oil, 

water, and sludge from a large tank, which had damaged supports, and from three 

1 
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other smaller tanks. In 1994, Region 6 issued a unilateral administrative order 

requiring the responsible parties to perform the remedial action described in the 

1993 Record of Decision. In response, the responsible parties drained 

contaminated water from the onsite pond, removed contaminated pond sediments, 

and backfilled the area with clean soil. They then consolidated, stabilized, 

solidified, and capped the contaminated material onsite. 

Since completion of the remedial actions, Region 6 has conducted two required 

Five-Year Reviews at PAB. Region 6 concluded in both Five-Year Reviews that 

the clean-up remedy was protective of human health and the environment and will 

remain so provided actions identified in the Five-Year Reviews are implemented. 

Scope and Methodology 

We conducted the field work for this evaluation from January 2008 to August 

2010 in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the evaluation to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our evaluation objective. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions based on 

our evaluation objective. 

We reviewed site documents, including monitoring reports, the Record of 

Decision and related documents, and the Five-Year Review reports. We 

interviewed the site’s remedial project managers (RPMs) from Region 6 and the 

Louisiana Department of Environmental Quality. From the site records, we 

assembled historical water level and water quality data. We invalidated data 

collected when the water level measurement showed the level was below the 

bottom of the well’s screen opening. The screen opening is the perforated part of 

the well through which ground water enters the well. In the situation where the 

measured water level was below the screen opening, the measurement and any 

sample that may have been taken do not represent conditions in the ground water. 

See Appendix A for details on invalid ground water level data. 

We collected ground water samples and conducted a site inspection in March 

2008. We compared our ground water sampling results to the historical sampling 

results we determined to be valid. Our independent sampling results were 

consistent with Region 6’s valid historical results. We also compared our results 

to federal drinking water standards, the only applicable water quality standards. 

Our sampling results did not exceed the applicable standards. Appendix B 

provides details on our sampling methodology, data analyses, and results. 

We requested that Region 6 provide official comments on this report. The Region 

provided its response, provided in Appendix C, on August 20, 2010. 

2 
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Chapter 2

Region 6 Included Invalid Data in 

Ground Water Analyses 

Region 6 accepted from the responsible parties’ contractor two types of invalid 

ground water data at PAB and included that invalid data in its analyses. For two 

wells, data were collected on stagnant water at the bottom of the wells, below 

screen openings where the water enters the wells. Consequently, data on both 

water quality and water levels were collected contrary to accepted procedures and 

were invalid. Ground water level measurements are needed to understand the 

direction ground water flows. Measures of water quality are needed to ensure that 

the clean-up remedy is successful and ground water quality does not degrade. 

Region 6 said it was aware in 2003 of the declined water level condition, but 

noted it had data from other wells that were sufficient to determine the direction 

of ground water flow and that the remedy was protective of human health and the 

environment. We agree that the invalid data did not have adverse implications for 

the Region’s protection decision because ground water flows past these two wells 

before flowing under the area where contaminated soils and wastes were capped. 

However, if ground water conditions were to change, the invalid data could 

impede the Region’s ability to determine whether the site’s clean-up remedy is 

still protective and whether the network of ground water monitoring wells 

remains effective. 

Invalid Water Quality Data 

Region 6 included invalid ground water quality results in its 2002 and 2007 FiveYear Reviews of PAB. Six times, from 2001 through 2003, the contractor 

collected a water quality sample from a well (MW-3) even though the water level 

had dropped below the well’s screen opening, the part of the well through which 

water enters. This same sample collection error occurred again in 2007 for well 

MW-3, and for the first time in a second well, MW-4. In each of these cases, the 

contractor did not follow accepted procedures because the water sample was 

withdrawn from stagnant water at the bottom of the well and was not a 

representative ground water sample. Because the contractor did not obtain a 

representative ground water sample due to the low water level, the result was 

invalid. 

The Region 6 RPM told the OIG that he was aware of the declined water level in 

2003 but that he could determine remedy protectiveness using results from the 

other monitoring wells. The contractor sampled these other wells properly 

because their screen openings were set lower. Ground water flows past the two 

3 
 10-P-0229 

problem wells and then under the part of the site where soil and wastes were 

treated, consolidated, and capped. We agree that water quality data from these 

two wells are not necessary for determining whether the remedy remains 

protective. However, assessing the validity of the water quality data received 

from the responsible parties is a fundamental step in the Region’s oversight 

activities. Although the RPM stated that he was aware of the declined water level 

problem, the RPM has not marked the water quality data as invalid in the site 

records. 

Invalid Water Level Data 

Our analysis of the data that the responsible parties’ contractor submitted to 

Region 6 shows that most of the water level data collected since July 2000 from 

the two problem monitoring wells (MW-3 and MW-4) were invalid. Appendix A 

presents a data table and detailed description of invalid water level data. As 

noted, the data were invalid because at the time the responsible parties measured 

the water level, the level was below the well’s screen opening. Therefore, the 

measurement in the well did not represent the actual ground water level. The 

Region 6 RPM said that he first became aware of the problem with these two 

wells in 2003 when he was assigned the site. However, we found no evidence 

that the RPM marked the data as invalid in the site records or discussed the 

declined water level problem with the responsible parties and their contractor 

until we brought the problem to the RPM’s attention in 2009. 

Region 6 uses ground water level measurements to determine the direction 

ground water flows. A monitoring network aligned along the ground water flow 

direction is fundamental to decisions on the success of a clean-up remedy. If the 

direction changes, the network of wells used to monitor ground water quality also 

may need to change. 

The ground water levels at PAB declined about 5 feet from the start of the 

remedial investigation in 1991 to the middle of 2000, and have remained 

depressed (see table in Appendix A). Consequently, since July 2000, the 

measured level was below the well’s screen opening 11 of the 15 times the 

responsible parties’ contractor measured the water level in MW-3, and 14 of the 

15 times the water level was measured in MW-4,. These measurements are 

invalid because they do not represent the water level condition in the ground 

water. 

We agree at present with the RPM’s assessment that he can determine ground 

water flow conditions without measurements in these two wells. However, two 

long-term monitoring reports from the responsible parties’ contractor, from 2006 

and 2009, did not support the presumed northwest direction of ground water flow. 

Valid water level measurements in other years’ reports, dating back to the 

remedial investigation, supported the interpretation that ground water flow was 

toward the northwest. In 2006, the contractor reported that the direction had 

4 
 

 

10-P-0229 

shifted from the northwest to the southwest. In 2009, the contractor showed the 

direction ranging from the northwest to the east (see map in Appendix A). 

Region 6, as part of its oversight responsibilities, should have questioned the 

validity of these flow directions, removed the invalid data, and reevaluated the 

ground water flow direction. 

Conclusions 

We documented occurrences of invalid site condition data received by Region 6 

from the responsible parties’ contractor. The invalid water quality and water level 

data do not have adverse implications for the Region’s determination that the 

clean-up remedy protects human health and the environment. However, Region 6 

has not taken steps to keep invalid data from the site records and improve its 

oversight of the contractor’s site data. Not addressing the collection, receipt, or 

disclosure of invalid data may result in the Region being unable to detect future 

conditions that show the monitoring network is not effective or the remedy is not 

protective of human health and the environment. 

Recommendations 

We recommend that the Regional Administrator, Region 6: 

2-1 Issue an addendum to the 2007 Five-Year Review identifying the invalid 

data in the PAB site records, addressing how the invalid data affects the 

Region’s protectiveness determination, and establishing the valid ground 

water level and ground water quality records for PAB. 

2-2 Modify the long-term monitoring plan for PAB to include procedures that 

ensure the Region and the responsible parties collect and report valid 

information on site ground water level and ground water quality conditions. 

EPA Region 6 Response to Draft Report and OIG Evaluation 

Region 6’s response to the draft report did not address Recommendation 2-1. 

Also, the Region responded that it had updated its operation and maintenance 

plan, and as such, Recommendation 2-2 should be closed. In a follow-up 

meeting, OIG and Region 6 personnel discussed the Region’s response and 

reached agreement on issues that the Region must respond to in its final response 

to this report. Region 6’s official comments and OIG’s evaluation are 

summarized below and included in full in Appendix C. 

Given the Region’s official written response, Recommendation 2-1 is designated 

in the final report as “undecided with resolution efforts in progress.” In our 

follow-up meeting, regional staff affirmed the Region’s commitment to issuing an 

addendum to the 2007 Five-Year Review Report. In its 90-day response to this 

5 
 10-P-0229 

report, Region 6 should provide an actual or estimated milestone date for 

completion of Recommendation 2-1. 

In its official response to the report, Region 6 stated that because the operations 

and maintenance plan had been updated, Recommendation 2-2 should be 

designated as “closed.” We do not agree that this action fully addresses the 

recommendation. In our follow-up meeting with the Region, we discussed the 

additional needed actions. Region 6 staff committed to addressing the OIG’s 

concerns. This recommendation is designated as “undecided with resolution 

efforts in progress.” In its 90-day response, Region 6 should provide an 

acceptable corrective actions plan, along with any planned or completed 

milestone dates. 

6 
 

 

 

 

1 

10-P-0229 

Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Planned 

Completion 

Date 

Claimed 

Amount 

Agreed To 

Amount 

2-1 5 Issue an addendum to the 2007 Five-Year Review 

identifying the invalid data in the PAB site records, 

addressing how the invalid data affects the 

Region’s protectiveness determination, and 

establishing the valid ground water level and 

ground water quality records for PAB. 

U Regional Administrator, 

Region 6 

2-2 5 Modify the long-term monitoring plan for PAB to 

include procedures that ensure the Region and the 

responsible parties collect and report valid 

information on site ground water level and ground 

water quality conditions. 

U Regional Administrator, 

Region 6 

O = recommendation is open with agreed-to corrective actions pending 

C = recommendation is closed with all agreed-to actions completed 

U = recommendation is undecided with resolution efforts in progress 

7 
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Appendix A 

Details on Invalid Ground Water Level Data 

Our analysis of Region 6’s ground water level data for PAB shows that most of the water level 

data collected since July 2000 from two monitoring wells (MW-3 and MW-4) were invalid. 

We determined that the data were invalid because the reported water level was below the well’s 

screen opening. If the water level in the ground water is below the bottom of the screen opening, 

then ground water cannot flow into the well, and any water in the well is not representative of 

ground water conditions. 

Table A-1 presents the water level information as given in annual monitoring reports. The 

earliest data and information on the elevations of the well screen openings are from the 1993 

Remedial Investigation Report. As is shown in Table A-1, 14 of the 15 times the contractor 

measured water levels since July 2000, the level was below well MW-4’s screen opening. The 

same conditions were present at well MW-3 in 11 of the 15 times the contractor measured water 

levels. The low ground water level in the two monitoring wells rendered them unusable for most 

of the last 10 years. Table A-1 shows the invalid data in bold and italics. 

Some of the uncharacteristic ground water flow directions reported in site documents occurred 

because the responsible parties’ contractor included invalid data for wells MW-3 and MW-4. 

The 2009 annual monitoring report provides one example in which the contractor presented 

information on the ground water flow direction that was counter to the established direction 

toward the northwest. Figure A-1 shows the contractor’s ground water map from the 2009 

report. Region 6 should have questioned the validity of the map; not doing so demonstrated a 

lack of oversight by the Region of the PAB monitoring activities. 

8 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

10-P-0229 

Table A-1: Water Levels at PAB 

Water level elevation, in feet relative to mean sea level 

Date MW-1 MW-2 MW-3* MW-4* MW-5 MW-6 MW-7 MW-8 MW-9 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

03/22/1991 -10.07 -10.38 -10.32 -10.32 -10.51 -10.52 -10.47 -10.34 

08/20/1991 -9.51 -9.81 -9.76 -9.77 -9.95 -9.99 -9.89 -9.79 

10/29/1991 -9.38 -9.71 -9.66 -9.65 -9.84 -9.85 -9.81 -9.68 

12/04/1991 -9.36 -9.68 -9.64 -9.63 -9.81 -9.85 -9.79 -9.65 

02/04/1992 -8.77 -9.10 -9.08 -9.05 -9.26 -9.23 -9.21 -9.08 

01/27/1999 -11.72 -12.06 -8.03 -12.02 -12.25 -12.25 -12.16 -12.05 

07/20/1999 -12.68 -13.00 -12.93 -12.94 -13.24 -13.23 -13.15 -12.98 

01/19/2000 -13.03 -13.35 -12.58 -13.31 -13.56 -13.55 -13.47 -13.34 

07/18/2000 -14.43 -14.73 -14.65 -14.65 -14.92 -14.96 -14.86 -14.72 

01/15/2001 -14.81 -15.23 -15.03 -15.47 -15.28 -15.37 -15.19 -15.07 

08/01/2001 -15.23 -15.52 -15.46 -15.22 -15.70 -15.77 -15.65 -15.51 

02/20/2002 -15.03 -15.22 -15.09 -15.64 -15.00 -14.23 -14.36 -15.31 

09/19/2002 -15.42 -15.72 -15.62 -14.92 -15.88 -15.93 -15.83 -15.70 

03/17/2003 -14.62 -14.95 -14.78 -14.92 -15.17 -15.17 -15.06 -14.92 

08/19/2003 -14.65 -14.94 -14.81 -14.89 -15.12 -15.18 -15.07 -14.93 

03/23/2004 -14.30 -14.60 -14.45 -14.50 -14.76 -14.84 -14.73 -14.59 

03/08/2005 -13.97 -14.28 -14.23 -14.23 -14.38 -14.54 -14.36 -14.25 

03/31/2006 -15.01 -15.08 -15.00 -14.96 -15.15 -15.30 -15.97 -15.06 

03/01/2007 -14.94 -15.26 -15.19 -15.22 -15.37 -15.46 -15.44 -15.25 

01/02/2008 -14.73 -15.03 -14.98 -14.96 -15.13 -15.25 -15.17 -15.02 

02/25/2009 -14.60 -14.92 -14.84 -14.90 -15.00 -15.12 -14.27 -14.91 

05/11/2009 -14.58 -14.89 -14.58 -14.63 -14.83 -14.84 not reported -14.87 

08/2009** -15.31 -15.41 -15.30 -15.27 -15.41 -15.63 -15.45 -15.39 

-10.31 

-9.76 

-9.64 

-9.62 

-9.07 

-12.02 

-12.95 

-13.30 

-14.66 

-15.05 

-15.47 

-15.26 

-15.66 

-14.88 

-14.90 

-14.54 

-14.24 

-15.01 

-15.22 

-15.02 

-14.87 

-14.66 

-15.34 

Elevation of the bottom of the well’s screen opening, in feet relative to mean sea level 

MW-1 MW-2 MW-3 MW-4 MW-5 MW-6 MW-7 MW-8 MW-9 

-96.1 -16.0 -14.7 -14.4 -16.8 -17.9 -16.9 -22.8 -20.4 

Sources: Remedial investigation and long-term monitoring reports for PAB. 

* Values recorded in bold and italics fall below the well’s screen opening, making them invalid. 

**	 Exact date of August 2009 measurements taken by responsible parties' contractor was not given in the site 

records. 

9 
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Figure A-1: February 2009 Water Levels for PAB Ground Water Wells 

EXPLANATION 

Property Boundary 

Line of Equal Groundwater Level (feet) 

Direction of Groundwater Flow 

Monitoring Well (Measured Groundwater 

Level in feet above mean sea level) 

Plugged and Abandoned Monitoring Well 

Source: Responsible parties’ map of measured ground water levels at PAB, February 2009. The 

map included invalid water levels at monitoring wells MW-3 and MW-4. The map's format was 

simplified by the OIG in the following ways: the incorrect symbol for MW-10 was corrected, yellow 

symbols were change to black for purposes of printing in black and white, and the explanation was 

shortened in length. 

10 
 

 

10-P-0229 

Appendix B 

Details on Sampling Methodology, Data Analyses, 

and Results of Comparisons and Site Inspection 

Sampling Methodology 

We acquired a qualified environmental contractor from the list of General Services 

Administration contractors to measure water levels, take water quality samples from six ground 

water monitoring wells, and conduct an inspection during March 3-7, 2008. We sampled a 

seventh well (MW-4) but invalidated the results because the water level was below the well’s 

screen opening (see Appendix A). OIG analysts were present to ensure that proper sampling, 

site inspection, and quality assurance protocols were followed. 

We followed the same sampling methods and protocols used in the long-term monitoring 

program. Before sampling, we measured water levels and then purged each well of three well 

casing volumes of water, or until we drained the well dry. We then sampled each well using a 

disposable bailer. Samples for dissolved metal analyses were passed through disposable filters 

attached directly to the bailer, pressurized using a hand-powered pump. We recorded 

temperature, pH, oxidation-reduction potential, dissolved oxygen concentration, and turbidity of 

the bailed water, after removing the samples for laboratory analyses. 

Two laboratories analyzed the samples for concentrations of volatile organic compounds, 

semivolatile organic compounds, and dissolved metals using EPA-approved methods. Due to the 

limitations of the scope of our evaluation, the laboratories did not analyze for other contaminants 

typically monitored in drinking water, such as nitrate. 

Data Analyses 

We analyzed our sampling results to determine whether Region 6 has been obtaining valid and 

reliable data on ground water conditions at PAB. First, we compared our results to historical 

data collected from 2000 through 2007 to determine whether our data were consistent with data 

Region 6 has been receiving from the responsible parties. OIG results greater than two standard 

deviations above average historical concentrations were deemed to be different from the 

historical data. We also evaluated our results in the context of applicable standards and their 

potential effect on Region 6’s protectiveness determination for PAB. This required us to identify 

all OIG results that exceeded federal drinking water standards. 

We did not include invalid data resulting from water levels that were below the bottom of the 

well’s screen opening at the time the measurement and sample were taken. This was the case for 

most of the water level and all of the water quality data from wells MW-3 and MW-4. We also 

did not include the data Region 6 contractors collected from well MW-4 in 2005 as part of the 

Hurricane Rita assessment, because the validity of the sample could not be determined as a water 

level was not measured. 

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Results of Comparisons and Site Inspection 

Aside from most of the data from two problematic wells (MW-3 and MW-4), our sampling 

results confirm that Region 6 had received valid data on ground water conditions at PAB. Our 

laboratory results showed no organic compounds or metals above safe levels for drinking water. 

Our results were consistent with those Region 6 had received in the long-term monitoring reports 

(2000 through 2007) and used in the 2007 Five-Year Review for PAB. Our site inspection in 

March 2008 showed that the responsible parties were properly maintaining the site in accordance 

with the EPA-approved operation and maintenance plan. We observed that the clay cap covering 

wastes was well maintained. We observed several breaches in the perimeter fence, which 

Region 6 also noted in its 2007 Five-Year Review. The responsible parties reported to Region 6 

in October 2008 that they had repaired the fence. 

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Appendix C 

EPA Region 6 Response to Draft Report 

and OIG Evaluation 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 6 

1445 ROSS AVENUE, SUITE 1200 

DALLAS TX 75202-2733 

August 20, 2010 

MEMORANDUM 

SUBJECT:	 Draft Evaluation Report: PAB Oil and Chemical Services, Inc. Site 

FROM: Al Armendariz 

Region 6 Administrator 

TO: Carolyn Cooper 

Director for Program Evaluation 

Hazardous Waste Issues 

On July 19, 2010, you provided me with a summary of concerns which led you to 

conclude that the Environmental Protection Agency (EPA) should improve oversight of longterm monitoring at the PAB Oil and Chemical Services, Inc. (PAB) Superfund site in Abbeville, 

Louisiana. 

The EPA continues to seek ways to improve its oversight of remedial activities at all of 

its Superfund sites, and certainly your comments have assisted us in this endeavor. We 

appreciate your agreement with our conclusion that the monitoring data issues did not affect the 

protectiveness finding of the remedy. 

We appreciate your comments concerning the PAB site and I look forward to your 

assistance in resolving any concerns regarding the long-term monitoring data issues at the site. 

Attachments 

OIG Response 1: The OIG acknowledges the Region’s commitment to resolving longterm monitoring issues at the site. 

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Region 6 Response to the Office of Inspector General’s (OIG) Draft Report on the LongTerm Oversight Monitoring at the PAB Oil Superfund Site 

This document transmits the Region 6 response and comments on the OIG’s draft 

evaluation report on the EPA oversight of long-term monitoring at PAB Oil and Chemical 

Services, Inc. Superfund Site in Abbeville, Louisiana. The EPA notes the OIG determined the 

oversight issues it identified at the PAB site did not affect the EPA’s remedy protectiveness 

determination. 

Region 6 would like to offer comments on a few specific issues that you raised in your 

evaluation. 

Region 6 Response 

Report Title: EPA Should Improve Oversight of Long-term Monitoring at PAB Oil and 

Chemical Services, Inc. Superfund Site in Louisiana 

Narrative Response: The title of the evaluation does not reflect the conclusions in the draft 

report. The draft report concluded that the invalid water quality and water level data identified 

by the OIG was not used by the EPA in assessing the protectiveness of the remedy. In addition, 

the draft report indicated that the invalid data does not have adverse implications concerning the 

determination of whether or not the remedy protects humans and the environment. The only 

finding in the draft report concerning the invalid data was the EPA did not address the invalid 

data in any correspondence related to the site. 

Proposed Revision: The title of the evaluation should be re-written. “EPA Should Clarify LongTerm Monitoring Data Issues at the PAB Oil and Chemical Services, Inc. Superfund Site in 

Louisiana” 

OIG Response 2: The OIG does not agree that revisions are needed. The OIG did not 

conclude that the oversight weaknesses we identified would never lead to an 

unacceptable outcome, and such a conclusion cannot be reached. Rather, the OIG 

concluded that improvements are needed to ensure that the oversight weaknesses we 

identified do not cause problems in the future. Specifically, the OIG states in the At a 

Glance: “if ground water conditions were to change, the invalid data could impede the 

Region’s ability to determine whether the site’s clean-up remedy is still protective and 

whether the network of ground water monitoring wells remains effective.” 

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At A Glance, What We Found: EPA included invalid data in its analyses. Paragraph 1, 2nd 

Sentence 

Narrative Response: In the second sentence of “At A Glance, What We Found”, you indicate 

that the EPA included invalid data in our analyses. This is contrary to the conclusions in the 

draft report. 

The draft report concluded that the invalid water quality and water level data identified by the 

OIG was not used by the EPA in assessing the protectiveness of the remedy. In addition, the 

draft report indicated that the invalid data does not have adverse implications concerning the 

determination of whether or not the remedy protects humans and the environment. The only 

finding in the draft report concerning the invalid data was the EPA did not address the invalid 

data in any correspondence related to the site. 

Proposed Revision: To make this sentence consistent with the conclusions of the draft report the 

phrase “and included that invalid data in its analyses” should be deleted from the 2nd sentence. 

OIG Response 3: The OIG does not agree with this comment and no change was 

made. The OIG did not conclude that the invalid data were not used in the 

protectiveness determination. The OIG concluded that the water quality data from the 

two problem wells were not needed to determine protectiveness, as “ground water flows 

past the two problem wells and then under the part of the site where soil and wastes 

were treated, consolidated, and capped.” 

Region 6 did not provide the OIG with any documentation that shows the invalid water 

quality data was excluded from its analyses. We did observe that Region 6 included 

invalid water quality data in the data table and discussion in the 2007 Five-Year Review. 

Region 6 did not include water level data in the Five-Year Review report. As discussed 

in the report, the monitoring reports submitted to Region 6 by the responsible parties’
 

contractor included invalid water level data, which sometimes led to interpretations of
 

the direction of ground water flow that differed from the conceptual model that ground 

water flow was uniformly to the northwest. Region 6 has provided no evidence that it 

conducted its own analyses of the ground water flow direction that excluded the invalid 

water level data. As such, the monitoring reports stand as the analyses of record for 

water level information and ground water flow direction for the site. 

While the OIG recognizes that the inclusion of invalid water quality data did not have 

negative implications for Region 6’s 2007 decision on site protectiveness, this cannot be 

guaranteed in the future. The OIG must disclose that invalid data were included and 

recommend improvements in Region 6’s oversight so that this does not happen in the 

future. The OIG believes Region 6 would want to be aware of weaknesses in its 

oversight and address those weaknesses so that human health and the environment 

remain protected. 

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Chapter 1, Introduction, Background: Page 1, Paragraph 3 

Narrative Response: This section uses the term “Reviews” without a specific explanation. It is 

clear to us that you mean Five Year Reviews, but someone unfamiliar with EPA activities might 

not understand the context of this term. 

Proposed Revision: While redundant, it is suggested that you use the full term, “Five Year 

Review” instead of the term “Reviews”. 

OIG Response 4: The OIG agrees and has made this change throughout the final 

report. 

Chapter 1, Introduction, Noteworthy Achievements: Page 2, Paragraph 2 

Narrative Response: This section uses the term “Reviews” without a specific explanation. It is 

clear to us that you mean Five Year Reviews, but someone unfamiliar with EPA activities might 

not understand the context of this term. 

Proposed Revision: While redundant, it is suggested that you use the full term, “Five Year 

Review” instead of the term “Reviews”. 

OIG Response 5: The OIG agrees and has made this change throughout the final 

report. 

Chapter 1, Introduction, Scope and Methodology: Page 2, Paragraph 1 

Narrative Response: It is our understanding that the OIG initiated the performance evaluation 

for the PAB Oil site on May 29, 2007. 

OIG Response 6: The OIG does not agree with this comment. Although EPA was 

notified in May 2007 and sites were selected in August 2007, we did not begin our field 

work at PAB until January 2008, which is when we sent our technical directive to the 

OIG contractor in preparation for our sampling. 

Chapter 2, Region 6 Included Invalid Data in Groundwater Analyses, Page 3 

Narrative Response: The title of this section does not reflect the conclusions indicated in the 

draft report. 

The draft report concluded that the invalid water quality and water level data identified by the 

OIG was not used by the EPA in assessing the protectiveness of the remedy. In addition, the 

draft report indicated that the invalid data does not have adverse implications concerning the 

determination of whether or not the remedy protects humans and the environment. The only 

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finding in the draft report concerning the invalid data was the EPA did not address the invalid 

data in any correspondence related to the site. 

Proposed Revision: To make the title consistent with the conclusions of the draft report it should 

be changed to “Region 6 should clarify the use of various data in Groundwater Analyses” . 

OIG Response 7: The OIG does not agree with this comment and no change was made 

to the chapter title. See OIG Response 3. 

Chapter 2, Region 6 Included Invalid Data in Groundwater Analyses: Page 3, Paragraph 

1, 1st sentence 

Narrative Response: The first sentence in this section states that the EPA included the invalid 

data in its analyses. This is contrary to the conclusions in the draft report. 

The draft report concluded that the invalid water quality and water level data identified by the 

OIG was not used by the EPA in assessing the protectiveness of the remedy. In addition, the 

draft report indicated that the invalid data does not have adverse implications concerning the 

determination of whether or not the remedy protects humans and the environment. The only 

finding in the draft report concerning the invalid data was the EPA did not address the invalid 

data in any correspondence related to the site. 

Proposed Revision: To make this sentence consistent with the conclusions of the draft report the 

phrase “and included that invalid data in its analyses” should be deleted from the 1st sentence. 

OIG Response 8: Phrase was not deleted. See OIG Response 3. 

OIG Response 9: Region 6 did not provide specific concurrence to Recommendation 

2-1 in this August 2010 response. In response to an earlier draft in April 2010, Region 6 

stated it “will identify the invalid data in an addendum to the 2007 Five Year Review 

Report.” In the exit conference held between the OIG and Region 6 personnel on 

August 30, 2010, the Remedial Project Manager reaffirmed Region 6’s commitment to 

issuing an addendum to the 2007 Five-Year Review Report. 

This recommendation is designated as “undecided” in the final OIG report. In its 

90-day response to this report, Region 6 should provide an actual or estimated milestone 

date for completion of Recommendation 2-1 or state its nonconcurrence if it does not 

agree. 

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Chapter 2, Region 6 Included Invalid Data in Groundwater Analyses Recommendations, 

Page 5, Paragraph 2-2 

Narrative Response: This recommendation indicates that the long-term monitoring plan for the 

site should be modified to ensure the responsible parties collect and report valid information on 

site groundwater level and groundwater quality conditions. 

Pursuant to our response to the OIG on May 19, 2009, EPA had the responsible party update the 

groundwater monitoring procedures in the Operations and Maintenance Plan. The updated 

Operations and Maintenance Plan was completed on August 17, 2009. A copy of the updated 

Operations and Maintenance Plan was provided to the OIG on September 1, 2009. A copy of the 

updated Operations and Maintenance Plan is attached to these comments to facilitate your 

review. 

Proposed Revision: Since the Operations and Maintenance Plan has been updated as 

recommended in the draft report, we suggest that this recommendation be designated as 

“closed”. 

OIG Response 10: The OIG does not agree with this comment and did not change the status of 

Recommendation 2-2 to closed. The OIG acknowledges that the operation and maintenance plan 

was updated on August 17, 2009, and Region 6 provided the plan to us on September 1, 2009. 

The updated plan mentions the problem with the water level being too low for two wells and that 

the responsible parties’ contractor was conducting quarterly monitoring to “provide an optimum 

timeframe to gauge these specific wells (i.e., when the water table is above the screened 

intervals).” We recognize that this is a reasonable first step that would help the responsible 

parties and their contractor better understand the problem. However, the action does not 

completely address OIG Recommendation 2-2, which calls for “procedures that ensure the 

Region and the responsible parties collect and report valid information on site ground water level 

and ground water quality conditions.” 

The water level was below the bottom of well MW-4’s screen opening all four times it was 

measured in 2009 and three of the four times for MW-3, according to the monitoring report 

submitted to Region 6 on March 10, 2010. We agree with the monitoring report conclusion that 

“the existing network of wells on the site is sufficient to establish groundwater gradient without 

the use of these two wells,” as long as flow conditions remain uniformly to the northwest. 

However, to fully meet the intent of OIG Recommendation 2-2, procedures should be established 

and followed for identifying when the water level is too low and for how this will be 

documented. These procedures are especially important because another monitoring well, 

MW-2, has a screen set high enough that it too is in danger of being unusable if water levels 

were to drop further. 

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OIG Response 10, continued: 

In the exit conference held between the OIG and Region 6 personnel on August 30, 2010, we 

discussed the nature of these needed procedures. The Region 6 remedial project manager 

committed to meeting the intent of OIG Recommendation 2-2 by updating the 2009 operation 

and maintenance plan. 

Recommendation 2-2 is designated in the final OIG report as “undecided with resolution 

efforts in progress.” In its 90-day response, the Region should provide an acceptable 

corrective actions plan or state the reasons for maintaining its current proposed actions. 

Status of Recommendations and Potential Monetary Benefits, Page 6, Recommendation 2-2 

Narrative Response: This recommendation indicates that the long-term monitoring plan for the 

site should be modified to ensure the responsible parties collect and report valid information on 

site groundwater level and groundwater quality conditions. 

Pursuant to our response to the OIG on May 19, 2009, EPA had the responsible party update the 

groundwater monitoring procedures in the Operations and Maintenance Plan. The updated 

Operations and Maintenance Plan was completed on August 17, 2009. . A copy of the updated 

Operations and Maintenance Plan was provided to the OIG on September 1, 2009. A copy of the 

updated Operations and Maintenance Plan is attached to these comments to facilitate your 

review. 

Proposed Revision: Since the Operations and Maintenance Plan has been updated as 

recommended in the draft report, we suggest that this recommendation be designated as 

“closed”. 

OIG Response 11: The OIG does not agree with this comment. See OIG Response 10 

for our reasons for considering the August 2009 revision of the operation and 

maintenance plan to be inadequate for meeting OIG Recommendation 2-2. Based on the 

discussion held in the August 30, 2010, exit conference, we expect Region 6 to include 

plans to update the 2009 operation and maintenance plan in its response to this final 

report. The recommendation resolution is designated as “undecided with resolution 

efforts in progress.” 

Appendix B, Details on Invalid Groundwater Level Data, Page 9, Paragraph 3, Last 

sentence 

Narrative Response: This sentence indicates that the EPA should have questioned the validity of 

a February 2009 map generated by the responsible parties and by not doing so, demonstrated a 

problem in its oversight of the PAB monitoring activities. 

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As indicated in EPA’s response to the OIG on May 19, 2009, EPA’s oversight was not flawed 

since EPA did not use invalid data in determining the ground water flow direction based upon 

the February 2009 water level data. However, the only issue was EPA did not have the 

responsible party revise the February 2009 map to not utilize the invalid data. 

Proposed Revision: Delete the sentence “Region 6 should have questioned the validity of the 

map; by not doing so, Region 6 demonstrated a problem in its oversight of the PAB monitoring 

activities” and replace it with the following sentence - “While Region 6 determined that the 

groundwater flow direction based upon the February 2009 water levels was consistent with the 

historical northwest direction, Region 6 should have required the responsible party to revise the 

map to not include the invalid water level data.” 

OIG Response 12: The OIG does not agree with these suggested changes. The OIG 

has no evidence that Region 6 questioned or was aware that there was a problem with 

the validity of the map. Region 6’s acknowledgement that it did not have the 

responsible party revise the map does not address the OIG’s finding that the cause for 

this was lack of the Region’s awareness or oversight. 

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Appendix D 

Distribution 

Office of the Administrator 

Assistant Administrator, Office of Solid Waste and Emergency Response 

Regional Administrator, Region 6 

Principal Deputy Assistant Administrator, Office of Solid Waste and Emergency Response 

Director, Office of Superfund Remediation and Technology Innovation, Office of Solid Waste 

and Emergency Response 

Agency Follow-up Official (the CFO) 

Agency Follow-up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for External Affairs and Environmental Education 

Audit Follow-up Coordinator, Office of Solid Waste and Emergency Response 

Audit Follow-up Coordinator, Region 6 

Inspector General 

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