US Environmental Protection Agency

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

Re: Proposed Listing of SBA Shipyards, Inc. on the National Priorities List

LDEQ Agency Interest Number 1478

Castex Landing Road, Jennings, Jefferson Davis Parish, Louisiana

Dear Mr. Curry:

This letter is in response to the United States Environmental Protection Agency's (EPA's) request for

concurrence from the state of Louisiana before the SBA Shipyards, Inc. Site ("the site") can be proposed

for listing on the National Priorities List (NPL).

The Louisiana Department of Environmental Quality (LDEQ) has been actively involved with the site in

the past, providing technical assistance to the EPA in the assessment of the site. The LDEQ believes that

the site is eligible for proposed listing on the NPL by virtue of the nature of the volatile and semi-volatile,

and metals contamination that remains at the site, and the threat this contamination poses to the

Mermentau River, local residents, and waterway and wetland areas that are adjacent to the site.

Should the site be listed on the NPL, the LDEQ will continue to assist the EPA in making the necessary

cleanup decisions designed to protect public health and the environment in this part of Louisiana.

If you have any questions, please contact Mr. Gary Fulton, Administrator, LDEQ-Underground Storage

Tank and Remediation Division, at (225) 219-3505.

eggy

uD/fi/UJ .. rJ.atch, .1 Secretary rl f  , (J!fd-__ Louh,1Jna Department of Environmental Quality

htd

c: Chance McNeely, Assistant Secretary, OEC, LDEQ

Gary A. Fulton, Jr., Administrator, USTRD

Imaging Operations - IAS

Brenda Nixon Cook

Region 6 NPL Coordinator

U.S. Environmental Protection Agency

1445 Ross A venue

Dallas, Texas 75202-2733

Post Office Box 4312 • Baton Rouge, Louisiana 70821-4312 • Phone 225-219-3536 • Fax 225-219-3398 

www.deq.louisiana.gov 
TO: 

FROM: 

Peggy Hatch, Secretary

 

Department of Environmental Quality 

Chance McNeely, Assistant Secretary, OEC 

Department of Environmental Quality 

Gary A. Fulton, Jr., Administrator USTRD Department of Environmental Quality 

N[ vSUBJECT: Proposed Listing of SBA Shipyard, Inc. on the National Priorities List; 

LDEQ Agency Interest Number 1478 

Castex Landing Road, Jennings, Jefferson Davis Parish, Louisiana 

DATE: 

The US Environmental Protection Agency (EPA) has asked for state concurrence on the proposed 

listing ofSBA Shipyards, Inc. on the National Priorities List (NPL). We believe that this would be 

the best course of action for this inactive and abandoned site. What follows is a summary of the 

site. 

Location 

The SBA Shipyard facility (SBA) is situated on approximately 98 acres of land located on the 

Mermentau River in a rural industrial area, at 9040 Castex Landing Road, Jennings, Jefferson Davis Parish, Louisiana. The facility is bordered to the north by residents, south and west by wetlands, and to the east by the Mermentau River. Access to the property is restricted with fencing and locked gates. 

Prior Use

SBA used the site for construction, repair, retro-fitting and cleaning of barges since 1965. Except for 

portions of the property possibly used for livestock grazing there is no known industrial use of the 

site prior to 1965. Barges serviced by SBA typically held diesel, coal tar, crude oil, gasoline and 

asphalt. In 1993, SBA Shipyards leased approximately 30 acres of the facility to Leevac Marine. 

Since that time, Leevac Marine purchased that portion of the facility 

Wastes from the barge cleaning operations were managed in a waste management area that included 

four impoundments, a land treatment unit (L TU) and storage tanks. The wastes from barges 

consisted of petroleum hydrocarbons. The hydrocarbons were separated from the water into surface 
or dispose ofhazardous waste. However, in late 1989, SBA began remediation activities on the four 

impoundments that were in service since 1968. Visual indications of the possible presence of 

contamination were observed during subsurface investigations conducted by SBA contractors 

between November 1989 and February 1990. In addition, four monitor wells were also installed at 

the time. In 1990, SBA submitted a notification to LDEQ as generator of hazardous waste. 

Subsurface contamination was observed at the SBA site by LDEQ on February 1990. In August 

1990, the LDEQ, Solid Waste Division (SWD) issued an Order (OC-159) to SBA to close the waste 

management units. A memo was written in July 1994 that either LDEQ HWD or EPA would handle 

closure activities ofthe SBA site. In 1994 the EPA Region 6 RCRA Enforcement Branch assumed 

the role for regulatory authority for the site and SBA hired a contractor to conduct a RCRA Facility 

Investigation (RFI). SBA submitted an RFI work plan in 1996. InDecember 2002 EPAissued Order 

and Agreement for Interim Measures/Removal Action (IM/RA) of Hazardous/Principal Threat 

Wastes at SBA Shipyards, Inc., pursuant to RCRA Section 3008(h). Until December 2012 the site 

remained under the USEPA Region 6 RCRA Enforcement Branch. Since then, numerous inquiries 

were made by LDEQ to obtain regulatory status update information. All were unsuccessful. 

On December 11, 2012 USEPA Region 6 CERCLA Assessment with a Superfund Technical 

Assessment and ResponseTeam (START) and LDEQ Underground Storage Tank and Remediation 

Division (USTRD) representatives conducted a site reconnaissance inspection at the SBA Shipyard 

for the purpose of assessing the site for inclusion on the National Priorities List as specified under 

the CERCLA. Tar-like material was observed in soils up to a depth of 3 to 4 feet below ground 

surface (bgs) near theonsite ditches. Evidence ofthe former pits andformerland treatment unit were 

not observed during the reconnaissance. Four monitoring wells were present on the westernportion 

ofthe property. A partially buried barge, an asphalt tank, and partially scrapped metal from a former 

10,000 barrel tank remained onsite. Also on site is a partially buried tug boat. The boiler on the tug 

was used as a source of steam for the vessel cleaning operations. Its forward and aft holds were 

found to be filled with refined crude, waste oil, or possibly a combination ofthe two for fueling the 

boiler. The hatches of these holds were not secured causing this stored oil to overflow the holds 

during rain events, and flow into a nearby coulee and swamp which feeds directly into the 

Mermentau River. 

Previous Investigations 

Starting in 1989, SBA made attempts to bio-remediate and close the impoundments. In 1991, the 

bioremediation was determined to be unsuccessful. Water and oil were pumped from Water 

Pit 1 to the storage tanks. The sludge in Water Pit 1 was solidified with fly-ash and lime. 

Approximately one-third of the material was placed in the L TU. The remaining material in Water 
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were removed from the site. As part of the IM/RA, the Oil Pit and wastes from the storage tanks 

were stabilized and solidified for off-site disposal. Approximately 750,000 gallons of 

uncontaminated pond water were pumped from the former Water Pit to thedrainage ditch that drains 

to the Mermentau River. 

The emptied Water Pit was then used to receive treated storm water from the partially buried barge. 

Pumpable oil materials were removed from the partially buried barge; which was then used to store 

contaminated storm water prior to treatment and discharge to the emptiedWater Pit.Water fromthe 

barge was treated by sand filtration, followed by granulated activated carbon (GAC). The treated 

water wasthen pumped to the Water Pit 1, analyzed for volatile organic compounds (VOCs), semivolatile organic compounds (SVOCs) and Total Suspended Solids(TSS) and discharged. The Water 

Pit was closed by excavating a six-foot gap in the berm to the "Mermentau River bottomland" 

directly east ofpit. The partially buried barge, an asphalt tank, and partially scrapped metal from a 

former 10,000 barrel tank remained onsite after the IM/RA activities were conducted. The IM/RA 

activities were complete in 2005. LDEQ conductedperiodic field investigations ofthe property since 

2005 to document facility conditions. Since 2012, tarlike material was observed byEPA and LDEQ 

in soils up to a depth of 3 to 4 feet below ground surface (bgs) near the on-site ditches. 

Current Status 

As of June 2015, we currently await the results ofthe USEPA Site Assessment to determine if the 

site will be added to the National Priorities List for remediation under CERCLA and the Superfund 

Amendment andReauthorization Act (SARA). USEPA in cooperationwith the UnitedStatesCoast 

Guard are currently conducting a removal action on the oil contents of the buried tug boat holds. 

Following thisremoval, the hatches ofthe tug will be sealed shut to prevent furtherfilling from rain. 

Currently the SBA Shipyard site in Jennings, Louisiana is ready to be proposed once EPAreceives a 

letter of concurrence from the Governor or his designee. The target date for receipt of the 

concurrence letter is July 30, 2015. The HRS package and allsupporting information is complete for 

SBA and it has received EPA Headquarters approval, once EPA receives a letter ofsupport the site 

will be included in the next NPL update (September 2015).