fourth five year review report - records collections · section 962l(c), as provided in the...

FOURTH FIVE-YEAR REVIEW REPORT FOR

PAB OIL & CHEMICAL SERVICES, INC. SUPERFUND SITE

VERMILION PARISH, LOUISIANA

May 12, 2017

Prepared by

U.S. Environmental Protection Agency

Region 6

Dallas, Texas

1997 2016

FOURTH FIVE-YEAR REVIEW REPORT P AB OIL & CHEMICAL SERVICES, INC. SUPERFUND SITE

EPA ID#: LAD980749139 VERMILION PARISH, LOUISIANA

This memorandum documents the U.S. Environmental Protection Agency's performance, determinations and approval of the PAB Oil & Chemical Services, Inc. Superfund site (Site) fourth five-year review under Section 12l(c) of the Comprehensive Environmental Response, Compensation, and Liability Act, 42 U.S. Code Section 962l(c), as provided in the attached Fourth Five-Year Review Report.

Summary of the Fourth Five-Year Review Report The Site is a former disposal facility for oil and gas exploration and production wastes. The Site's remedy consisted of dewatering and backfilling a saltwater pond and excavation and stabilization/solidification of contaminated soils and sludge with placement in an on-site disposal unit. Long-term response action activities are ongoing. They include monitoring and maintenance of the Site's cap and groundwater monitoring. Institutional controls are in place for the Site. The Site is not currently in use. There are no known exposures to contaminated media.

On February 17, 2012, EPA published a final oral non-cancer toxicity value, or reference dose (RID), of 7xI0-10

mg/kg-day for 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) in EPA's Integrated Risk Information System (IRIS). The above RID for TCDD is being utilized at Superfund sites to ensure protection of human health. As part of this Five Year Review, the dioxin levels achieved during the Site remedy were evaluated against the above RID to determine if additional remedial action was necessary. This evaluation indicated that the dioxin waste has been sufficiently treated and is protective for the Site.

Environmental Indicators Human Exposure Status: Current human exposure is under control Contaminated Groundwater Status: Contaminated groundwater migration is under control Sitewide Ready for Anticipated Use: Yes (10/16/2007)

Actions Needed The following actions must be taken for the remedy to be protective in the long term: None.

Determination I have determined that the remedy for the P AB Oil & Chemical Services, Inc. Superfund site is protective.

C~d~~ Date Director, Superfund Division U.S. Environmental Protection Agency Region 6

Michael Hebert

CONCURRENCES

FOURTH FIVE-YEAR REVIEW REPORT PAB OIL & CHEMICAL SERVICES, INC. SUPERFUND SITE

EPA ID#: LAD980749139 VERMILION PARISH, LOUISIANA

Date Remedial Project Manager

_,Ir 7 ;, 7

Blake Atkins Date Chief, Louisiana/New Mexico/Oklahoma Section

Jo . Meyer CH' e , Superfund Reme i

q-25-2017 Date

Date Branch, Office of Regional Counsel

Deputy Director, Superfund Division

ISSUES/RECOMMENDATIONS

FOURTH FIVE-YEAR REVIEW REPORT

PAB OIL & CHEMICAL SERVICES, INC. SUPERFUND SITE

EPA ID#: LAD980749139

VERMILION PARISH, LOUISIANA

Issues/Recommendations

OU(s) with Issues/Recommendations Identified in the Five-Year Review:

None

1

Table of Contents LIST OF ABBREVIATIONS & ACRONYMS .........................................................................................................3 I. INTRODUCTION...................................................................................................................................................4

Site Background .....................................................................................................................................................4 FIVE-YEAR REVIEW SUMMARY FORM ........................................................................................................5

II. RESPONSE ACTION SUMMARY ......................................................................................................................6 Basis for Taking Action .........................................................................................................................................6 Response Actions ...................................................................................................................................................6 Status of Implementation .......................................................................................................................................7 Institutional Control (IC) Review ..........................................................................................................................8 Systems Operations/Operation & Maintenance .....................................................................................................9

III. PROGRESS SINCE THE LAST REVIEW .......................................................................................................10 IV. FIVE-YEAR REVIEW PROCESS ....................................................................................................................13

Community Notification, Involvement & Site Interviews ...................................................................................13 Data Review .........................................................................................................................................................13 Site Inspection ......................................................................................................................................................14

V. TECHNICAL ASSESSMENT ............................................................................................................................15 QUESTION A: Is the remedy functioning as intended by the decision documents? .........................................15 QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and remedial action objectives

(RAOs) used at the time of the remedy selection still valid? ...............................................................................16 QUESTION C: Has any other information come to light that could call into question the protectiveness of the

remedy? ................................................................................................................................................................17 VI. ISSUES/RECOMMENDATIONS .....................................................................................................................17

OTHER FINDINGS .............................................................................................................................................17 VII. PROTECTIVENESS STATEMENT ................................................................................................................17 VIII. NEXT REVIEW ..........................................................................................................................................17

APPENDIX A – REFERENCE LIST ................................................................................................................... A-1 APPENDIX B – SITE FIGURES ...........................................................................................................................B-1 APPENDIX C – SITE CHRONOLOGY ...............................................................................................................C-1 APPENDIX D – PRESS NOTICE ........................................................................................................................ D-1 APPENDIX E – INTERVIEW FORMS ................................................................................................................ E-1 APPENDIX F – DATA REVIEW ......................................................................................................................... F-1 APPENDIX G – SITE INSPECTION CHECKLIST ............................................................................................ G-1 APPENDIX H – REMEDIAL ACTION AND SITE INSPECTION PHOTOS ................................................... H-1 APPENDIX I – DETAILED ARARs REVIEW TABLES ..................................................................................... I-1 APPENDIX J – DETAILED TOXICITY REVIEW ............................................................................................... J-1 APPENDIX K – CONVEYANCE NOTICE ........................................................................................................ K-1

Tables Table 1: Contaminants of Concern by Media .............................................................................................................6 Table 2: COC Remedial Goals ...................................................................................................................................7 Table 3: Summary of Planned and/or Implemented Institutional Controls (ICs) .......................................................9 Table 4: Annual O&M Costs ....................................................................................................................................10 Table 5: Protectiveness Determinations/Statements from the 2012 FYR ................................................................10

2

Table 6: Status of Recommendations from the 2012 FYR .......................................................................................10 Table C-1: Site Chronology ....................................................................................................................................C-1 Table I-1: Groundwater ARAR and TBC Review .................................................................................................. I-2 Table J-1: Review of Soil Remedial Goals – Commercial/Industrial ..................................................................... J-1

Figures Figure B-1: Site Location .......................................................................................................................................B-1 Figure B-2: Historic Site Features Map ..................................................................................................................B-2 Figure B-3: Site Map ..............................................................................................................................................B-3 Figure B-4: Institutional Control Map ....................................................................................................................B-4 Figure F-1: Nickel Concentrations in Well MW-2 ................................................................................................. F-2

3

LIST OF ABBREVIATIONS & ACRONYMS

ARAR Applicable or Relevant and Appropriate Requirement

AST Aboveground Storage Tank

BaP Benzo(a)pyrene

bgs Below Ground Surface

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CD-ROM Compact Disc-Read Only Memory

CFR Code of Federal Regulations

COC Contaminant of Concern

cPAHs Carcinogenic Polycyclic Aromatic Hydrocarbons

EPA United States Environmental Protection Agency

ESD Explanation of Significant Differences

FS Feasibility Study

FYR Five-Year Review

HI Hazard Index

HQ Hazard Quotient

IC Institutional Control

LAC Louisiana Administrative Act

LDEQ Louisiana Department of Environmental Quality

LDNR Louisiana Department of Natural Resources

MCL Maximum Contaminant Level

mg/kg Milligram per Kilogram

mg/L Milligram per Liter

msl Mean Sea Level

NCP National Contingency Plan

NPL National Priorities List

O&M Operation and Maintenance

OIG Office of Inspector General

OU Operable Unit

PAHs Polycyclic Aromatic Hydrocarbons

PCOR Preliminary Close-Out Report

pH Potential of Hydrogen

PRP Potentially Responsible Party

RAO Remedial Action Objective

RECAP Risk Evaluation/Corrective Action Program

RI Remedial Investigation

ROD Record of Decision

RPM Remedial Project Manager

RSL Regional Screening Level

SDWA Safe Drinking Water Act

SONRIS Strategic Online Natural Resources Information System

SVOCs Semi-Volatile Organic Compounds

TBC To-Be-Considered

TCDD Tetrachlorodibenzo-p-dioxin

UU/UE Unlimited Use/Unrestricted Exposure

VOCs Volatile Organic Compounds

µg/kg Microgram per Kilogram

µg/L Microgram per Liter

4

I. INTRODUCTION

The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy to

determine if the remedy is and will continue to be protective of human health and the environment. The methods,

findings and conclusions of reviews are documented in FYR reports such as this one. In addition, FYR reports

identify issues found during the review, if any, and document recommendations to address them.

The U.S. Environmental Protection Agency (EPA) is preparing this FYR pursuant to the Comprehensive

Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, 42 U.S.C. § 9621, consistent

with the National Contingency Plan (NCP)(40 CFR Section 300.430(f)(4)(ii)), and EPA policy.

This is the fourth FYR for the PAB Oil & Chemical Services, Inc. Superfund site (the Site). The triggering action

for this statutory review is the completion date of the previous FYR. The FYR has been prepared due to the fact

that hazardous substances, pollutants or contaminants remain at the Site above levels that allow for unlimited use

and unrestricted exposure (UU/UE).

The Site consists of one operable unit (OU), which addresses contaminated surface water, groundwater, soil and

sludge. The FYR will address the remedy for this OU.

The FYR was led by Michael Hebert, EPA Remedial Project Manager (RPM). Todd Thibodeaux of the Louisiana

Department of Environmental Quality (LDEQ) also participated in this FYR. The potentially responsible parties

(PRPs), known as the PAB Site Remediation Group, LLC (PAB Group), were notified of the initiation of the

FYR. The review began on August 16, 2016.

Appendix A includes a list of documents reviewed for this FYR. Appendix B includes site figures. Appendix C

includes a site chronology.

Site Background

The 16.7-acre Site is located on Route 167 in Vermilion Parish, Louisiana, about 3 miles north of the town of

Abbeville (Appendix B, Figure B-1). From 1978 to about 1983, PAB Oil operated a disposal facility for oil and

gas exploration and production wastes, including drilling muds and fluids. Operations included disposal of wastes

in pits and ponds that in combination with associated levees and berms, once covered nearly 82 percent of the Site

(Appendix B, Figure B-2). The Site currently consists of a capped disposal unit and a flat grassy area in the

location of the former saltwater pond (Appendix B, Figure B-3). The perimeter of the Site is fenced with barbed

wire to prevent trespassing with the exception of the eastern border that is bound by an abandoned canal and

dense vegetation. The Site is not currently in use.

The Site and surrounding area are flat and have a general surface elevation approximately 20 feet above mean sea

level (msl). The Site is located within the unconsolidated sediments of the Atlantic-Gulf Coastal Plain

physiographic province. There are three subsurface stratigraphic units: an upper clay unit ranging from 0 to 2 feet

below ground surface (bgs), a middle clay/silt/sand unit extending from 19 to 23 feet bgs and a lower sand/gravel

unit extending to depths of at least 110 feet bgs. Groundwater at the Site is encountered at approximately 30 feet

bgs in the upper Chicot Aquifer System, Abbeville Unit. Groundwater flow direction is generally northwest with

a gradient of 0.0001 feet/foot.

Primary land use near the Site is agricultural and residential. Since the previous FYR, several new single family

homes have been built north of the Site in the Vermilion Chateau Subdivision. The homes are connected to public

water.1 Most residences and businesses in the area use public water from the Vermilion Parish Water District,

which obtains its water from the Chicot aquifer. However, some residences and businesses rely on private water

1 The 2007 FYR noted that a representative of Keller Williams (real estate agent for the adjacent Vermilion Chateau

Subdivision) indicated public water would be supplied to the subdivision by Vermilion Parish Water District 1.

5

supplies. Sampling of residential wells during investigations in the early 1990s did not identify site-related

contamination in residential wells. The Louisiana Department of Natural Resources (LDNR) Strategic Online

Natural Resources Information System (SONRIS) database identifies seven water well registrations on, or in close

proximity to, the Site.2 Available records for these wells indicate that all but two of these registrations are

associated with groundwater monitoring wells for the Site. These two wells are both domestic wells - one well is

approximately 80 feet deep and is located on a neighboring property southwest of the Site (Appendix B, Figure B-

3 depicts the location of this well) and the other well is approximately 100 feet deep and is located several

hundred feet west of the Site along Route 167.

FIVE-YEAR REVIEW SUMMARY FORM

2 The LDNR SONRIS database, available at

http://www.dnr.louisiana.gov/index.cfm?md=navigation&tmp=iframe&pnid=0&nid=340, was accessed February 2017 for

this FYR evaluation.

SITE IDENTIFICATION

Site Name: PAB OIL & CHEMICAL SERVICES, INC.

EPA ID: LAD980749139

Region: 6 State: LA City/County: Abbeville/Vermilion Parish

SITE STATUS

NPL Status: Deleted

Multiple OUs? No

Has the site achieved construction completion?

Yes

REVIEW STATUS

Lead agency: EPA

Author name: Michael Hebert, with additional support provided by Skeo (EPA Contractor)

Author affiliation: EPA Region 6

Review period: 8/16/2016 – 7/19/2017

Date of site inspection: 11/29/2016

Type of review: Statutory

Review number: 4

Triggering action date: 7/19/2012

Due date (five years after triggering action date): 7/19/2017

http://www.dnr.louisiana.gov/index.cfm?md=navigation&tmp=iframe&pnid=0&nid=340

6

II. RESPONSE ACTION SUMMARY

Basis for Taking Action

Site investigations in the 1980s and early 1990s identified contaminated sludges, soil, sediment, surface water and

groundwater as actual or potential threats to human health and the environment. Contaminants detected in Site

media included volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs) and metals. The

risks posed by the contaminants stemmed from possible ingestion, dermal contact or migration into the

surrounding environment. EPA identified the sludges contained in the disposal pits as the principal threat at the

Site because these sludges, if left alone, would continue to be a potential threat to groundwater through leachate

migration and to human health and the environment through direct exposure.

The 1993 Record of Decision (ROD) identified the following contaminants of concern (COC) for surface water,

sludge and associated soil (Table 1). The ROD did not select groundwater COCs.

Table 1: Contaminants of Concern by Media

COC Media

beryllium, barium, benzene, toluene surface water

arsenic, barium, total carcinogenic

polycyclic aromatic hydrocarbons

(PAHs), non-carcinogenic PAHs

sludge and soil

Response Actions

EPA became aware of the Site in June 1980 following a citizen complaint of illegal discharges from the Site into

an off-site drainage ditch. As a result, EPA, LDNR and LDEQ conducted site inspections and preliminary

sampling. LDNR and LDEQ subsequently sent notices of violations to PAB Oil. PAB Oil reported that it stopped

receiving oil field waste in August 1982 because of its inability to meet the requirements of Statewide Order 29-

B. In November 1982, the State ordered PAB Oil to proceed with a closure plan for the Site. However, PAB Oil

went out of business in 1983, and the Site was abandoned.

Between 1984 and 1987, EPA conducted additional investigations at the Site. Based in part on the findings of

these investigations, EPA listed the Site on the National Priorities List (NPL) in March 1989.

EPA conducted a remedial investigation (RI)/feasibility study (FS) at the Site between June 1990 and September

1993. The main site features or potential source areas identified and investigated during the RI included three

open waste impoundments or pits (northwest pit, northeast pit and south pit) and their associated berms, two other

impoundment areas referred to as the saltwater pond and the northwest pond, four aboveground storage tanks

(ASTs) and associated underlying soil, site drainage/runoff areas, an abandoned canal that borders the eastern

edge of the Site, and other areas of suspected waste dumping (Appendix B, Figure B-2).

During the RI, EPA determined that a removal action was needed to address an immediate threat posed by

ignitable wastes contained in one of the ASTs that was structurally damaged. Under the authority of an

Administrative Order on Consent with EPA, several of the Site’s PRPs, now the PAB Group, removed the wastes

from all four ASTs, dismantled the tanks, and treated and disposed of the wastes off site. The PAB Group

completed the removal in February 1992. EPA finalized the RI, which also included a baseline risk assessment, in

September 1993.

EPA selected the Site’s remedy in a ROD, dated September 22, 1993. The ROD identified the following remedial

action objectives (RAOs) for the Site:

Prevent direct contact, ingestion and migration of the disposal pit sludges and associated soils.

Prevent direct contact with contaminated surface waters.

7

Prevent the potential for human exposure to contaminated groundwater.

The 1993 ROD identified the following major remedy components:

Removal and on-site treatment of all surface water with final discharge to site drainage ditches.

Excavation and biological treatment of organic contaminated sludges, soil and sediment.

Solidification/stabilization of contaminated material to address inorganics and, if necessary, any

remaining organic contamination.

Final disposal of treated residuals in an on-site disposal unit.

Long-term groundwater monitoring.

Long-term operation and maintenance (O&M).

Table 2 summarizes sludge, soil and sediment COC remedial goals identified in the 1993 ROD. The 1993 ROD

also identified remedial goals for surface water, but these remedial goals only applied during the surface water

treatment component of the remedial action.

Table 2: COC Remedial Goals

COC Remedial Goal Basis

Sludge, Soil and Sedimenta

Arsenic 10 milligrams per kilogram (mg/kg) State regulationb

Barium 5,400 mg/kg Risk-basedc

Total carcinogenic PAHs 3 mg/kg Risk-basedd

Non-carcinogenic PAHs Hazard index (HI) of 1 Risk-basede

Notes:

a) Table 11 of the 1993 ROD identified sludge and associated soil and sediment COCs and remedial goals.

b) Louisiana Statewide Order No. 29-B, Section 129.B.6, Pit Closure.

c) Exposure limit based on noncarcinogenic risk with an HI of 1.

d) The cleanup level of carcinogenic PAHs is based on a residential exposure scenario. The 3 mg/kg cleanup level is

expressed as a carcinogenic benzo(a)pyrene (BaP) equivalent, which corresponds to a risk of 3x10-5.

e) For noncarcinogenic PAHs, the ROD states that the following risk-based concentrations shall be used in order to

achieve an HI of 1: 16,500 mg/kg acenaphthene; 82,000 mg/kg anthracene; 11,000 mg/kg fluoranthene; 11,000 mg/kg

fluorene; 11,000 mg/kg naphthalene and 8,000 mg/kg pyrene. A conservative estimate of 8,000 mg/kg will be used as

a surrogate risk-based concentration for all other noncarcinogenic PAHs that do not have a reference dose.

EPA modified the selected remedy in a March 12, 1997 Explanation of Significant Differences (ESD). The ESD

eliminated the required biological treatment of excavated materials in the ROD. Extensive sampling of soil,

sediment and sludge during 1993 and 1995 pre-design investigations using updated laboratory methods found that

concentrations of carcinogenic polycyclic aromatic hydrocarbons (cPAHs) and PAHs were already well below

remedial goals. Biological treatment was deemed unnecessary as part of the remedial action. The sludge and soil

remedial action, therefore, addressed only arsenic and barium. All other aspects of the remedy remained the same.

Status of Implementation

In September 1994, EPA issued a Unilateral Administrative Order to the PAB Group, directing them to perform

the remedial design and remedial action. The PAB Group conducted the remedial action with EPA oversight. The

remedial action began in June 1997 with mobilization to the Site and ended in August 1998 with the completion

of disposal unit capping, grading and re-vegetation.

Initial remedial activities included dewatering and backfilling of the saltwater pond. Contractors for the PAB

Group removed approximately 6 million gallons of water, treated it in an electro-precipitation unit and discharged

it into a drainage ditch that leads to the drainage system along Highway 167. Treated water met discharge limits

established in the ROD.

8

Sediment samples collected from the saltwater pond bottom exhibited concentrations of barium and arsenic higher

than remedial goals. Therefore, PRP contractors removed the top 6 inches of the entire saltwater pond bottom

(about 7,000 cubic yards), solidified and stabilized the sediment and placed it in the consolidated pit area, or

disposal unit. Samples collected from the pond bottom were then re-analyzed. Concentrations of COCs in all

samples did not exceed remedial goals. PRP contractors then backfilled the pond to grade with clean soil and

added grass seed to re-vegetate.

The major component of the remedy was stabilization and solidification of the sludge pit material. PRP

contractors excavated the contaminated soil and sludge and combined it with reagent materials, including cement,

ferrous sulfate and organophilic clay, to stabilize the material. Contractors then placed the treated material back

into the consolidated pit area. Before placement of any material into the consolidated pit area, contractors sampled

the bottom of this structure and COC concentrations were lower than cleanup criteria. Approximately 25,000

cubic yards of material was treated in this manner.

PRP contractors brought the consolidated pit area up to grade using treated material and structural fill and then

installed a low permeability cap. The 3.6-acre cap consisted of 2 feet of compacted low permeability clay covered

by 2 feet of vegetative soil cover to prevent surface water infiltration. PRP contractors constructed a clay-lined

drainage ditch to convey stormwater runoff to two major drainage ditches, south and north of the Site. Upon

completion, PRP contractors surveyed the cap and installed settlement monuments on top of the cap.

Long-term groundwater monitoring and O&M activities began shortly after cap construction. The initial

groundwater sampling event occurred in July 1998. The groundwater monitoring network originally consisted of

12 groundwater monitoring wells - nine wells on the Site and three wells located off site (two upgradient and one

downgradient). In 2004, PRP contractors plugged and abandoned off-site monitoring wells MW-10, MW-11 and

MW-12 with EPA and LDEQ approval. Groundwater monitoring and O&M activities are ongoing.

EPA deleted the Site from the NPL on January 3, 2000.

Institutional Control (IC) Review

Decision documents did not require institutional controls as a component of the remedy for the Site. However, as

noted in the 2002 FYR, institutional controls are needed due to waste being left in place. The 2002 FYR identified

the need for institutional controls to restrict residential use of the property, drilling and/or excavation activities

that could breach the integrity of the cap, and the use of groundwater at the Site.

The PAB Group filed a conveyance notice for the Site with the Vermilion Parish Clerk of Court on October 16,

2007. The conveyance notice identifies the property as being subject to a response action under CERCLA and

places restrictions on excavation, drilling or other activities to depths that could create exposure to contaminated

media or interfere with the integrity of the disposal cell cap. It also restricts extraction of groundwater for any use

other than groundwater monitoring or remediation. Table 3 summarizes the institutional controls implemented at

the Site. Figure B-4 in Appendix B shows the area subject to the institutional controls. Appendix K contains the

full conveyance notice.

9

Table 3: Summary of Planned and/or Implemented Institutional Controls (ICs)

Media, engineered

controls, and areas

that do not support

UU/UE based on

current conditions

ICs

Needed

ICs Called

for in the

Decision

Documents

Impacted

Parcel(s)

IC

Objective

Title of IC Instrument

Implemented and Date

(or planned)

Disposal Area Soil,

Groundwater Yes No

R3459200 -

Tract 7A

(16.66 acres)

R3459200 -

Tract 7-C2

(0.052 acre)

R3459200 -

Tract 7-A2B

(0.039 acre)

Restrict excavation,

drilling or other

activities to depths that

could create exposure to

any contaminated media

or interfere with the

integrity of the clay

cover; restrict extraction

of groundwater for

consumption or any

other purpose other than

groundwater monitoring

and remediation; may

restrict use of the

property to commercial

or industrial uses

Conveyance Notice,

recorded with Vermilion

Parish, Louisiana Clerk

of Court on October 16,

2007

Systems Operations/Operation & Maintenance

The PAB Group is responsible for all long-term O&M and groundwater monitoring activities at the Site.

Monitoring activities were originally scheduled quarterly for the first year following completion of the remedial

action and semiannually from years 2 to 5. In 2003 and 2007, EPA approved reductions in O&M activities. In

September 2011, EPA approved the Revised Operations and Maintenance Plan, Addendum 1 (Revised O&M

Plan), prepared by the PAB Group, that documented all modifications to the original September 1998 O&M Plan.

The Revised O&M Plan describes the following activities and current schedule for implementation of these

activities:

Inspection of the cap for erosion or damage, with repair or reseeding as necessary – annually during the

1st quarter.

Inspection of the drainage ditches for damage, sediment accumulation and presence of debris, with repair

or cleanout as necessary – annually during the 1st quarter.

Inspection of the roadway for damage and erosion, with repair as necessary – annually during the 1st

quarter.

Inspection of site fencing, with repair as necessary – annually during the 1st quarter.

Mowing of site vegetation – twice per year in the 2nd and 4th quarters.

Surveying of the cap settlement monuments – once every two years in the 1st quarter.

Inspection of well condition and monitoring depth to groundwater in monitoring wells MW-1 through

MW-9 – annually.

Sampling of wells MW-2, MW-6, MW-8 and MW-9 for metals, VOCs, SVOCs and field parameters (pH,

conductivity and temperature) – twice prior to the next FYR in the 1st quarter.

Sampling of well MW-5 for metals, VOCs, SVOCs and field parameters (pH, conductivity and

temperature) – once prior to the next FYR in the 1st quarter.

The Revised O&M Plan indicated that the groundwater sampling and analysis protocol and schedule/frequency

will be evaluated after the 2012 FYR. The 2012 FYR recommended that MW-5 be sampled twice before the next

FYR. This recommendation was incorporated into the sampling schedule.

10

Currently, Project Navigator, Ltd. on behalf of the PAB Group is conducting O&M activities. Below is a

summary of major milestones that they conducted during this FYR period in addition to annual inspections and

mowing:

Monument settlement surveys occurred in February 2013 and February 2015. Groundwater sampling occurred in June 2014 and April 2016 at MW-2, MW-5, MW-6, MW-8 and MW-

9; resampling occurred in July 2014 for metals only.

The ROD projected an annual O&M cost of $86,000, but annual O&M costs were substantially lower during this

FYR period (Table 4). This cost reduction was attributed to a reduction in the number of monitoring wells being

sampled.

Table 4: Annual O&M Costs

Year Total Cost

(rounded to the nearest $1,000) 2012 $25,000

2013 $14,000

2014 $28,000

2015 $15,000

2016 $25,000 (estimate)

III. PROGRESS SINCE THE LAST REVIEW

This section includes the protectiveness determinations and statements from the last FYR (Table 5), issues and

recommendations from the last FYR and the current status of those recommendations (Table 6).

Table 5: Protectiveness Determinations/Statements from the 2012 FYR

OU # Protectiveness

Determination Protectiveness Statement

Sitewide Protective Based on the information available during the third five-year review, the selected

remedy for the PAB Oil & Chemical Services, Inc. Superfund site will remain

protective of human health and the environment in the long-term provided the action

items herein are addressed and corrective actions, as necessary, are implemented.

Table 6: Status of Recommendations from the 2012 FYR

OU # Issue Recommendation Current

Status

Current

Implementation Status

Description

Completion

Date (if

applicable)

Sitewide Groundwater Elevation

Drop Beneath the Site –

Since completion of the

remedial action in August

1998, shallow

groundwater levels have

dropped in elevation

across the Site. Review of

well construction data for

monitoring wells MW-5,

MW-6 and MW-7

indicates these wells are

constructed in such a way

that their screened

intervals penetrated less

Continue to monitor

changes in

groundwater elevation

data and compare it to

the well construction

data. If groundwater

elevations continue to

drop to the point that

screened intervals of

MW-5, MW-6 and/or

MW-7 no longer

penetrate the saturated

thickness of this

groundwater unit, one

or more of these wells

Completed The PAB Group

continues to collect


data annually. During

this FYR period, the

PAB Group measured

groundwater levels at

MW-5, MW-6 and MW-

7 within the screened

intervals of the wells,

which allowed collection

of groundwater samples

for laboratory analysis.

The PAB Group will

continue to collect

2/18/2013

11


Status

Current


Description

Completion

Date (if

applicable)

than 3 feet of the saturated

thickness of this

groundwater zone during

the third FYR period. A

continued drop in the


beneath the Site could

result in one or more of

the remaining wells no

longer being useful for

collection of groundwater

data. This condition could

jeopardize the

effectiveness of the Site’s


network, which is being

used to monitor the long-

term effectiveness of the

remedy.

may need to be

replaced. This will

ensure the monitoring

well network is

maintained in such a

way that it can be used

to collect valid

groundwater quality

and flow direction data

used in monitoring the

long-term effectiveness

of the remedy.


data and monitor the

adequacy of the well

network.

Sitewide Monitoring Well/Site

O&M - The site

inspection indicated

minor burrowing animal

activity adjacent to the

MW-4 well pad. If not

corrected, this condition

could cause localized

shifting of the ground

surface and jeopardize the

integrity of the Site’s


wells. Additionally, MW-

4 is situated in close

proximity to the Site’s

cap, and burrowing

animals could

compromise the integrity

of the cap.

Continue O&M

activities that eliminate

favorable conditions

for burrowing animals

in the vicinity of the

monitoring wells and

site cap. As required by

the O&M Plan,

continue site

maintenance activities

that limit excess

growth of trees and

other vegetation around

the wells and across the

Site. Routine

management of the

Site’s vegetation will

continue to help in

minimizing favorable

habitat for burrowing

animals and other

biological hazards,

such as snakes and

stinging insects.

Completed The PAB Group

continues to conduct

O&M in accordance with

the frequency and

schedule outlined in the

Revised O&M Plan.

Maintenance activities,

such as mowing,

continue on a regular

basis at the Site to

eliminate favorable

conditions for burrowing

animals in the vicinity of

the monitoring wells and

site cap.

2/18/2013

Sitewide Sampling Frequency of

Monitoring Well Network

– Localized groundwater

flow beneath the Site has

consistently trended to the

northwest. MW-5 is

situated downgradient of

the former tank battery

and the capped disposal

pits. As such, periodic

groundwater quality data

from this well is crucial in

Because MW-5 is a

downgradient sentinel

well for the

groundwater

monitoring network,

MW-5 should be

sampled at the same

time as wells MW-2,

MW-6, MW-8 and

MW-9. All five of the

above wells should be

sampled two times

Completed The PRP sampled

groundwater at MW-2,

MW-5, MW-6, MW-8

and MW-9 twice during

the FYR period;

sampling occurred in

June 2014 and April

2016. An additional

sampling event for

metals only occurred in

July 2014.

4/19/2016

12


Status

Current


Description

Completion

Date (if

applicable)

monitoring the long-term

effectiveness of the

remedy, as well as

detecting any changes in

groundwater quality prior

to it migrating off-site.

However, MW-5 is

currently only being

sampled at a frequency of

one time per FYR period.

within the next FYR

period as was the

schedule in the

previous FYR period.

MW-5 should be

sampled for field

parameters, metals,

VOCs, and SVOCs

during these sampling

events. If groundwater

quality data obtained

during future sampling

events suggest a

deterioration of

groundwater quality for

one or more of the

wells being monitored,

the sampling frequency

will need to be re-

evaluated and modified

accordingly.

Sitewide Perimeter Fence O&M -

Breaches in the fence

surrounding the Site were

noted during the second

FYR. The March 2012

site inspection indicated

that the fencing

surrounding the Site is

constructed of barbed

wire. Minor breaches

were noted in a localized

area along the fence, but

there was also evidence of

where Project Navigator,

Ltd. personnel have been

making repairs to the

fence and have installed

pipe barriers in a few of

the larger breaches in

order to limit trespassing

onto the Site.

Continue making

necessary repairs to the

perimeter fencing to

minimize trespassing

onto the Site.

Completed The PRP continues to

inspect the fence as part

of regular O&M at the

Site. Inspections of the

fence will continue and

the PRP will make

repairs, as necessary.

2/18/2013

Sitewide Statistical Analysis of

Groundwater Data -

Statistical analysis of

groundwater data was

recommended during the

first and second FYRs.

Based on available data

during the third FYR, a

statistical analysis has not

been provided by the

PRP. However, review of

cumulative

Continue to present

cumulative

groundwater quality

data tables for metals

and evaluate

groundwater quality

data collected during

the scheduled

groundwater sampling

events. If future data

collected for one or

more wells suggests a

change in groundwater

Completed Annual O&M reports

continue to present

cumulative groundwater

data tables for metals and

continue to evaluate

groundwater data quality.

Changes in groundwater

quality have not been

identified; therefore,

statistical analysis of


is not warranted at this

time.

1/30/2015

13


Status

Current


Description

Completion

Date (if

applicable)


indicates that in most

cases site COCs have

remained below

maximum contaminant

levels (MCLs) during the

third FYR period.

quality, then a

statistical analysis of

the groundwater

quality data may

become warranted to

ensure groundwater

quality is not degrading

with time.

IV. FIVE-YEAR REVIEW PROCESS

Community Notification, Involvement & Site Interviews

A public notice was made available in the Friday, September 23, 2016 edition of the Abbeville Meridional

newspaper, stating that EPA will be conducting a FYR of the remedy and inviting the public to contact EPA for

more information. The results of the review and the report will be made available at the Site’s information

repository, located at Vermilion Parish Library – Abbeville Branch, 405 E. Saint Victor Street, Abbeville,

Louisiana 70510. A copy of the public notice is included in Appendix D.

During the FYR process, interviews were conducted to document any perceived problems or successes with the

remedy that has been implemented to date. The results of these interviews are summarized below. Appendix E

includes the completed interview forms.

Nine residents located adjacent to or near the Site were contacted about responding to the FYR interview

questions. None of the residents expressed interest in filling out the interview form or conducting an interview

over the phone, by email or in person.

The EPA RPM indicated that the PRP contractor is maintaining the Site adequately and submitting required status

reports on time. The implemented remedy is currently protective of human health and the environment. VOCs and

SVOCs have not been detected in groundwater samples and metals have been below maximum contaminant

levels (MCLs) for several years. Institutional controls are sufficient. Trespassing by people living south of the Site

is an ongoing issue. However, observations indicate that no trespassers have been exposed to any waste left in

place. Trespasser activities have not compromised the implemented remedy. EPA has not received any complaints

or inquiries concerning the Site.

The LDEQ representative indicated that the remedy appears to be going as planned. Reuse activities have not yet

occurred. The State is not aware of any projected changes in land use at the Site. The State is not aware of any

complaints or inquiries from residents regarding the Site. The State is not aware of any state laws that might affect

the protectiveness of the Site’s remedy.

The O&M contractor indicated that the remedy appears to be working with no problems with subsidence or

groundwater. The O&M contractor noted there have been no unexpected O&M difficulties beyond normal

maintenance items. During a sampling event in 2014, there appeared to be elevated metals concentrations in a

groundwater sample. However, upon further investigation the concentrations were shown to have come from an

excess of sediment (due to churning from bailing), which was not filtered before applying the preservative.

Confirmation sampling showed that the sediment was the likely source of the concentrations, and the recent

sampling event did not detect any COC above its respective MCL.

Data Review

This data review incorporates settlement monument survey data, groundwater elevation data and groundwater

quality data as originally presented in the 2013 through 2016 annual inspection and monitoring reports, prepared

14

by the PRP’s O&M contractor Project Navigator, Ltd. Appendix F includes a detailed data review. Key findings

from this review are highlighted below:

Monument settlement surveys conducted during this FYR period reported no significant change in

elevation of the capped disposal unit since the initial survey was conducted in 1998. Settlement is not a

concern at this time.

Groundwater flow direction is to the northwest, consistent with historic observations.

Groundwater elevation measurements continue to show that depth to groundwater in upgradient

monitoring wells MW-3 and M-4 is below the screened interval of these wells; however, neither well is

included in the groundwater sampling program at this time.

Metals are the only chemicals consistently detected in site groundwater. All metals were below MCLs

during the two most recent sampling events, which is consistent with data from the previous FYR.

Nickel, which does not have an MCL, exceeded the EPA tapwater Regional Screening Level (RSL) of

390 micrograms per liter (µg/L) twice during this FYR period in well MW-2. Nickel concentrations have

shown a slight increase during this FYR period. However, concentrations are lower than the maximum

concentration detected (780 µg/L) in 2005.

RI data concerning dioxin levels were reviewed as a result of the new 2012 RfD for TCDD. RI samples were

collected and analyzed for dioxins and furans from waste disposal pits, salt water ponds, and the tank battery. A

total of six waste disposal pit sludge samples reported toxicity equivalence to 2,3,7,8-tetrachlorodibenzo-p-dioxin

(TCDD) above 0.01 µg/kg, however, no sample had an equivalence factor greater than or equal to 1.00 µg/kg. No

2,3,7,8-TCDD was found in the salt water pond sediment. Two different dioxin isomers were detected in seven of

the nine samples collected from the salt water pond sediment and none of the samples had a toxicity equivalence

to 2,3,7,8-TCDD greater than 0.01 µg/kg. No 2,3,7,8-TCDD was found in any of the samples collected from the

tank battery soils. However, a total of four dioxin isomers were detected in nine of the eleven samples analyzed

with two samples reporting toxicity equivalence to 2,3,7,8-TCDD greater than 0.01 µg/kg. No tank battery soil

samples had an equivalence greater than or equal to 1.00 µg/kg.

All the waste disposal pit sludge, salt water pond sediment, and tank battery soils were stabilized/solidified with a

mixture of Portland cement, organo-phyllic clay, flyash, slag powder, and ferric chloride and placed in an on-site

capped disposal cell.

Site Inspection

The site inspection was conducted on 11/29/2016. Site inspection participants included Mike Hebert (Region 6

EPA), Philip Jen (Project Navigator, Ltd. – PRP O&M contractor), Earl Moran (ExxonMobil, a member of the

PAB Group), and Eric Marsh and Jill Billus (Skeo). The purpose of the inspection was to assess site status and the

protectiveness of the remedy. Appendix G includes a completed site inspection checklist. Appendix H includes

photographs taken during the site inspection.

The site inspection began at the entrance to the Site, which is a locked gate on the Site’s northwestern edge. A “no

trespassing” sign is located on the gate that includes a working phone number for the O&M contractor. The Site

was mowed about one month prior to the site inspection. There had been some heavy rains in the area the day

before the inspection.

Participants inspected the northern side of the Site, including site perimeter fencing and the Site’s northern

drainage ditch that runs east-west. Participants observed a damaged well vault, pad and bollards but since the well

is plugged and abandoned, no action is necessary. The northern drainage ditch was surrounded by heavy

vegetation; however, there were no signs of sediment build-up or standing water. Participants noted a gap in the

Site’s perimeter fencing near the Site’s northeast corner, allowing potential access to the Site by residents living

in a relatively new subdivision directly north of the Site. At least seven old tires had also been disposed of near

the fence line.

15

Participants examined the Site’s eastern drainage ditch and fencing running north-south. The fencing was

surrounded by heavy vegetation. The drainage ditch was in good condition with no standing water or sediment

build-up.

Participants inspected the capped portion of the Site. Participants inspected settlement monuments located on the

cap and nearby wells. The O&M contractor explained that settlement monuments have not moved since

installation. The well vaults were locked and labeled. The well locks were functioning. Participants observed a

burrow hole located beneath the MW-8 well near the northern edge of the cap. Separate burrow holes were

identified on the northern end of cap and in the northern drainage ditch. The O&M contractor explained that

burrowing animals were somewhat common at the Site. There was no evidence suggesting that burrowing animals

were a widespread problem. The O&M contractor fills in the animal burrows as soon as they are identified.

Participants then examined the southern perimeter of Site, which includes perimeter fencing and an east-west

drainage ditch. Fencing was in poor condition in a few places but surrounded by dense vegetation. Participants

observed standing water in one part of the drainage ditch. Participants identified a soccer ball on site near the

southern perimeter. There were no signs of persistent trespassing.

Participants then examined the western part of the Site and saltwater pond disposal area, which covers about 13

acres. No issues were identified.

Overall, the Site’s cap appeared to be in good condition, with minimal erosion and well-established vegetation.

Operational well vaults appeared to be in relatively good condition; paint on some well bollards and vaults was

cracked and peeling. The O&M contractor plans to repair the damaged fenced areas to prevent unauthorized

access.

After the site inspection, the EPA RPM and the EPA contractor performed research at the site information

repository. Site documents identified were from the early 1980s through 2007. Examples of documents identified

included: Administrative Record for the Record of Decision, Volumes 1-8 (1981 – 1993); the Deletion Docket

(1999); Administrative Record for the Explanation of Significant Differences (Volumes 1-3); PAB Oil

Administrative Record Update, removal-related documents, a public relations plan, the First Five-Year Review

(2002), the Five-Year Addendum to the First Five-Year Review and the Second Five-Year Review (2007). The

Third-Five Year Review was missing. The EPA RPM spoke to library staff about potentially replacing paper

copies of repository records with CD-ROMs.

The EPA contractor checked property records at the Vermilion Parish Clerk of Court at 100 North State Street,

Suite 101, in Abbeville. The conveyance notice filed for affected site properties in 2007 was identified. This is the

most recent document in place for the affected site properties owned by the PAB Group.

V. TECHNICAL ASSESSMENT

QUESTION A: Is the remedy functioning as intended by the decision documents?

Yes, the Site’s remedy is functioning as intended by the decision documents. The remedy was designed to prevent

direct contact, ingestion and migration of the disposal pit sludges and associated soils. As part of the remedial

action, the PRP consolidated and treated contaminated sludges and soils on site, placed treated material in the

disposal cell and covered it with a low-permeability cap. The cap is vegetated, well-maintained and monitored on

a regular basis. Significant settlement has not occurred. Animal burrows are periodically identified in the

vegetative soil cover on the cap but have not compromised the integrity of the cap. The PRP contractor fills in the

animal burrows as soon as they are identified.

Groundwater at the Site is monitored regularly. Metals are the only chemicals consistently detected in site

groundwater. All metals were below MCLs during the two most recent sampling events, which is consistent with

16

data from the previous FYR. Nickel, which does not have an MCL, exceeded the EPA tapwater RSL twice during

this FYR period in well MW-2. Nickel concentrations at MW-2 have shown a slight increase during this FYR

period. However, concentrations are lower than the maximum concentration detected in 2005. MW-5, located

downgradient of MW-2, did not report nickel above its RSL. The nickel observations appear to be localized.

Residences downgradient of the Site use public water supplied by the Vermilion Parish Water District 1.

The 2012 FYR identified a drop in groundwater levels as an issue of concern, but the data review did not identify

this as a concern during this FYR period. However, if groundwater levels for sampled wells fall below the bottom

of the well screen, the wells may need to be replaced in the future to ensure an adequate monitoring network is

maintained.

A locked and gated entrance, a no trespassing sign and barbed wire fencing deter trespassing at the Site. Fencing

was in poor condition in a few places during the site inspection but surrounded by dense vegetation which in

effect prevented access to the site and thus possible exposure to on-site contaminants. The O&M contractor plans

to repair the damaged fenced areas to prevent unauthorized access.

Institutional controls in the form of a conveyance notice are in place at the Site to restrict excavation, drilling or

other activities to depths that could create exposure to contaminated media or interfere with the integrity of the

disposal cell cap. The conveyance notice also restricts extraction of groundwater for any use other than

groundwater monitoring or remediation.

Groundwater monitoring since the completion of the Remedial Action has indicated that no contaminants are

migrating from the capped disposal cell.

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and remedial action objectives (RAOs) used at the time of the remedy selection still valid?

Yes, the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the remedy are still

valid.

There have been no changes to standards or to-be-considered (TBC) criteria for groundwater or soil since the

ROD and ESD (Appendix I). Based on a review of the updated Louisiana Administrative Code and metals

limitation criteria for pit closure, the arsenic applicable or relevant and appropriate requirement (ARAR) for pit

closure has not changed. MCLs for groundwater have not changed.

EPA selected health-based levels as the cleanup goals for barium and cPAHs in soil, sludge and sediment.

Toxicity values for several COCs have changed since the ROD, and in 2014 EPA updated default exposure

assumptions. To determine if the cleanup goals for soil, sludge and sediment remain protective for

commercial/industrial use, the cleanup goals were compared to EPA’s 2016 RSLs (Appendix J) since the RSLs

incorporate current toxicity values and standard default exposure factors.

The commercial/industrial screening-level risk evaluation demonstrates that the soil, sludge and sediment cleanup

levels remain valid as the concentrations are within or below EPA’s risk management range of 1 x 10-6 to 1 x 10-4

or below the noncancer hazard quotient (HQ) of 1.0 (Table J-1, Appendix J).

The 1994 ROD states that groundwater monitoring will continue for at least 30 years. Nearly 19 years have

passed since monitoring began in 1998 and only sporadic detections of metals have occurred. Metals are the only

chemicals consistently detected in site groundwater. All metals were below MCLs during the two most recent

sampling events, which is consistent with data from the previous FYR.

Prior to remediation at the Site, all source material samples did not contain any concentrations of dioxins with a

toxicity equivalence to 2,3,7,8-TCDD greater than 1.0 µg/kg, which was the ROD cleanup level for dioxins.

17

Some of the source material concentrations exceed the new industrial soil cleanup level of 0.720 µg/kg based on

the new 2012 RfD for TCDD. However, these source materials were stabilized/solidified and placed in an on-site

capped disposal cell. Groundwater monitoring since the completion of the Remedial Action has indicated that no

contaminants are migrating from the capped disposal cell. Therefore, the capped stabilized/solidified materials

that contained dioxins and furans are not threats to human health and the environment. No further action at this

time is required to ensure protectiveness of human health and the environment pursuant to the dioxin evaluation.

Changes in risk assessment methods do not affect the protectiveness of the remedy. There are no current

exposures to contamination. There have been no changes in site conditions that would suggest the presence of

new exposure pathways.

The remedy is meeting the RAOs identified in the ROD.

QUESTION C: Has any other information come to light that could call into question the protectiveness of the

remedy?

No other information has come to light that could call into question the protectiveness of the remedy.

VI. ISSUES/RECOMMENDATIONS

The remedy is functioning as intended; the exposure assumptions, toxicity data, and RAO’s are still valid; and

there is no additional data that jeopardizes the protectiveness of the remedy. There were no issues or

recommendations identified during this FYR that affects the protectiveness of the remedy.

OTHER FINDINGS

The following are recommendations that were identified during the FYR, but do not affect current and/or future

protectiveness:

The PRP should repair damaged fence areas during normal O&M inspections.

The PRP should repair and fill in animal burrows during normal O&M inspections.

VII. PROTECTIVENESS STATEMENT

Sitewide Protectiveness Statement

Protectiveness Determination: Protective

Protectiveness Statement:

The remedy is protective of human health and the environment because exposure pathways that could

result in unacceptable risks are currently being controlled, the remedy is functioning as intended,

contaminant levels remain below MCL’s in groundwater, and the necessary institutional controls are in

place to restrict future site use and the use of groundwater.

VIII. NEXT REVIEW

The next FYR Report for the PAB Oil & Chemical Services, Inc. Superfund site is required five years from the

completion date of this review.

A-1

APPENDIX A – REFERENCE LIST

2013 Annual Inspection and Monitoring Report, Operations and Maintenance Activities, PAB Oil & Chemical

Services, Inc. Site, Abbeville, Louisiana. Project Navigator, Ltd. May 30, 2013.


Services, Inc. Site, Abbeville, Louisiana. Project Navigator, Ltd. January 30, 2015.


Services, Inc. Site, Abbeville, Louisiana. Project Navigator, Ltd. June 17, 2015


Services, Inc. Site, Abbeville, Louisiana. Project Navigator, Ltd. September 23, 2016.

Conveyance Notice, recorded with Vermilion Parish, Louisiana Clerk of Court. October 16, 2007.

Explanation of Significant Differences. PAB Oil and Chemical Services, Inc., Vermilion Parish, Louisiana. EPA

Region 6. March 12, 1997.

First Five-Year Review Report for PAB Oil and Chemical Services, Inc. Superfund Site, Abbeville, Vermilion

Parish, Louisiana. EPA Region 6. July 22, 2002.

Record of Decision, PAB Oil and Chemical Services, Inc. Site, Vermilion Parish, Louisiana. EPA Region 6.

September 1993.

Revised Operations and Maintenance Plan, Addendum 1, PAB Oil & Chemical Services, Inc.

Abbeville, Louisiana. Project Navigator, Ltd. September 2011.

Remedial Investigation Study, PAB Oil and Chemical Services, Inc. Superfund Site, Abbeville, Vermillion

Parish, Louisiana. Volumes 1 and 2. EPA Region 6. January 1993.

Second Five-Year Review Report for the PAB Oil and Chemical Services, Inc. Superfund Site, Abbeville,

Vermilion Parish, Louisiana. EPA Region 6. July 2007.

Third Five-Year Review Report for PAB Oil and Chemical Services, Inc. Superfund Site, Abbeville, Vermilion

Parish, Louisiana. EPA Region 6. July 19, 2012.

B-1

APPENDIX B – SITE FIGURES Figure B-1: Site Location

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding EPA’s response actions at the Site.

B-2

Figure B-2: Historic Site Features Map

(Source: Second FYR Report, dated July 2007)

B-3

Figure B-3: Site Map

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding EPA’s response actions at the

Site.

B-4

Figure B-4: Institutional Control Map

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding EPA’s response actions at the

Site.

C-1

APPENDIX C – SITE CHRONOLOGY

Table C-1: Site Chronology

Event Date

EPA was made aware of the Site following a citizen complaint of illegal discharge

from the Site; EPA completed a preliminary assessment

1980

EPA completed the site inspection September 1, 1980

EPA proposed the Site for listing on the National Priorities List (NPL) June 24, 1988

EPA listed the Site on the NPL March 31, 1989

EPA began the remedial investigation/feasibility study (RI/FS) June 27, 1990

EPA issued an Administrative Order on Consent for the potentially responsible

party (PRP) group to conduct a removal action to address immediate threats at the

Site; the PRP group began a removal action

October 8, 1991

EPA completed a treatability study January 4, 1993

EPA completed the human health risk assessment and ecological risk assessment January 26, 1993

EPA completed the RI/FS and signed the Record of Decision (ROD); the selected

remedy included surface water treatment, excavation, biological treatment, residual

solidification/stabilization, on-site disposal, a clay cover and groundwater

monitoring

September 22, 1993

EPA issued a Unilateral Administrative Order to the PRPs directing them to

conduct the remedial design and remedial action

September 27, 1994

The PRP group began the remedial design November 17, 1994

The PRP group completed the removal action September 30, 1995

EPA issued an Explanation of Significant Differences (ESD) to remove biological

treatment as a required remedial action

March 12, 1997

The PRP group finished the remedial design May 30, 1997

The PRP group began the remedial action June 9, 1997

The PRP group finished the remedial action; EPA issued a preliminary close-out

report (PCOR)

August 28, 1998

EPA issued a Notice of Intent to delete the Site from the NPL August 31, 1999

EPA deleted the Site from the NPL January 3, 2000

EPA completed the first five-year review (FYR) July 26, 2002

EPA and the Louisiana Department of Environmental Quality (LDEQ) approved a

reduction in the number and frequency of operation and maintenance (O&M)

activities

December 2003

The PRP plugged and abandoned monitoring wells MW-10, MW-11 and MW-12 March 2004

EPA completed the second FYR July 24, 2007

The PRP submitted a memorandum that documented additional changes to the

O&M requirements

August 2007

The PRP filed a conveyance notice for the Site with the Vermilion Parish Clerk of

Court

October 16, 2007

The PRP conducted a groundwater sampling event and collected split groundwater

samples in conjunction with groundwater samples collected as part of an audit by

the EPA Office of Inspector General (OIG)

March 2008

EPA and LDEQ approved a revised O&M plan August/October 2009

The EPA OIG published its evaluation report for the Site September 2010

EPA completed the combined First FYR and Second FYR Addendum report in

response to the OIG report

February 2011

The PRP prepared a Revised Operations and Maintenance Plan, Addendum 1 September 2011

EPA completed the third FYR July 19, 2012

D-1

APPENDIX D – PRESS NOTICE

PAB OIL & CHEMICAL SERVICES, INC. Superfund Site

Public Notice

U. S. Environmental Protection Agency, Region 6

September 2016

The U.S. Environmental Protection Agency Region 6

(EPA) will be conducting the FOURTH five-year review of

remedy implementation and performance at the PAB OIL &

CHEMICAL SERVICES, INC. Superfund site (Site) in

Vermilion Parish, about three miles north of Abbeville,

LOUISIANA. The Site is fenced. It includes mostly flat,

open space with some trees. Nearby land uses include

homes and farms.

From 1978 to about 1983, a disposal facility for oil field

drilling mud and saltwater operated on site. The Site’s

remedy included surface water treatment, excavation,

treatment and on-site disposal of contaminated soil, sludge

and sediment beneath a clay cover, and groundwater

monitoring. The five-year review will determine if the

remedies are still protective of human health and the

environment. The five-year review is scheduled for

completion in July 2017.

The report will be made available to the public at the

following local information repository:

Vermilion Parish Library – Abbeville Branch

405 E. Saint Victor Street

Abbeville, Louisiana 70510

(337) 893-2674

Site status updates are available on the Internet at

www.epa.gov/superfund/pab-oil-chemical-service

All media inquiries should be directed

to the EPA Press Office at (214) 665-2200

For more information about the Site, contact:

Mike Hebert / Remedial Project Manager

(214) 665-8315

or 1-800-533-3508 (toll-free)

or by email at [email protected]

Mike McCorkhill / Community Involvement Coordinator

(214) 665-8553

or 1-800-533-3508 (toll-free)

or by email at [email protected]

https://www.epa.gov/superfund/pab-oil-chemical-service

mailto:[email protected]

mailto:[email protected]

E-1

APPENDIX E – INTERVIEW FORMS

PAB OIL & CHEMICAL SERVICES,

INC. Superfund Site

Five-Year Review Interview Form

Site Name: PAB OIL & CHEMICAL

SERVICES, INC.

EPA ID No.: LAD980749139

Interviewer Name: Eric Marsh Affiliation: Skeo

Subject Name: Michael A. Hebert Affiliation: EPA

Time: N/A Date: 10/25/2016

Interview Location: via questionnaire

Interview Format (circle one): In Person Phone Mail Other: Email

Interview Category: EPA Remedial Project Manager

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as

appropriate)?

The PRP’s consultant maintains the Site and submits required status reports on time. No detectable VOCs and

SVOCs have been observed in groundwater samples. Metal concentrations in the groundwater have been

below MCLs for several years.

2. What have been the effects of this Site on the surrounding community, if any?

No apparent negative effects of the Site on the surrounding community have been observed or reported.

3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial

activities since the implementation of the cleanup?

EPA Region 6 has not received any complaints or inquiries concerning the Site.

4. What is your assessment of the current performance of the remedy in place at the Site?

The implemented remedy is currently protective of human health and the environment.

5. Are you comfortable with the status of the institutional controls at the Site? If not, what are the associated

outstanding issues?

The Conveyance Notification currently filed appears to be sufficient at this time to ensure protectiveness of

the remedy.

6. Are you aware of any community concerns regarding the Site or the operation and management of its

remedy? If so, please provide details.

EPA Region 6 has not received any complaints or inquiries concerning the Site.

7. Do you have any comments, suggestions or recommendations regarding the management or operation of the

Site’s remedy?

E-2

The PRP’s consultant is adequately maintaining the Site. The only issue has been trespassing by people living

south of the Site. However, there has not been any observations regarding trespassing that would indicate that

trespassers were exposed to any waste left in place or that trespasser activities have compromised the

implemented remedy.

8. Do you consent to have your name included along with your responses to this questionnaire in the Five-Year

Review report?

Yes.

E-3


INC. Superfund Site



SERVICES, INC.



Subject Name: Todd Thibodeaux Affiliation: LDEQ

Subject Contact Information: [email protected]

Time: N/A Date: 02/06/2017



Interview Category: State Agency


appropriate)?

All the above seem to have gone or is going as planned, except for reuse activities. Nothing for reuse is

forseen in the future.


The remedy seems to be working fine.

3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial

activities from residents in the past five years?

No.

4. Has your office conducted any site-related activities or communications in the past five years apart from

routine activities? If so, please describe the purpose and results of these activities.

No.

5. Are you aware of any changes to state laws that might affect the protectiveness of the Site’s remedy? If so,

please explain.

No.

6. Are you comfortable with the status of the institutional controls at the Site? If not, what are the associated

outstanding issues?

Yes.

7. Are you aware of any changes in projected land use(s) at the Site?

No.

8. Do you have any comments, suggestions or recommendations regarding the management or operation of the

Site’s remedy?

E-4

No.


Review report?

Yes.

E-5


INC. Superfund Site



SERVICES, INC.



Subject Name: Philip Jen Affiliation: Project Navigator, Ltd.

Subject Contact Information:

Time: N/A Date: 11/29/2016



Interview Category: O&M Contractor


appropriate)?

The overall project since I have worked on it (since 2007) has been good. The remedy appears to be working

with no problems with subsidence or groundwater.


The current performance of the remedy in place appears to be working.

3. Do you feel that the recommendations from the 2012 Five-Year Review have been adequately addressed?

Please explain.

No action was required from the 2012 review.

4. What are the findings from the monitoring data from the past five years? What are the key trends in

contaminant levels that are being documented over time at the Site?

The monitoring data has shown that there has been no indication of COC migration or cap settling.

5. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and activities.

Alternatively, please describe staff responsibilities and the frequency of site inspections and activities if there

is not a continuous on-site O&M presence.

There is not a continuous on-site O&M presence.

6. Have there been any significant changes in site O&M requirements, maintenance schedules or sampling

routines since start-up or in the last five years? If so, do they affect the protectiveness or effectiveness of the

remedy? Please describe changes and impacts.

There have been no significant changes in site O&M in the last five years.

7. Have there been unexpected O&M difficulties or costs at the Site since start-up or in the last five years? If so,

please provide details.

In general, there have been no unexpected O&M difficulties beyond normal maintenance items. During a

sampling event in 2014 there appeared to be an elevated concentration in a groundwater sample. However,

E-6

upon further investigation the concentration was shown to have come from an excess of sediment (due to

churning from bailing) which was not filtered before applying the preservative (HCl). As such, concentrations

of metals may have been leached into the water. Confirmation sampling showed that the sediment was the

likely source of the concentrations and the recent sampling event did not produce any COC above its

respective MCLs.

8. Have there been opportunities to optimize O&M activities or sampling efforts? Please describe changes and

any resulting or desired cost savings or improved efficiencies.

No opportunities to further reduce O&M activities or sampling efforts have been implemented.

9. Please provide a general summary of O&M costs for the past five years in the table below:

Annual O&M Costs

Year Total Cost (rounded to the nearest $1,000)

2012 $25,000

2013 $14,000

2014 $28,000

2015 $15,000

2016 $25,000 (estimate)

10. Do you have any comments, suggestions or recommendations regarding O&M activities and schedules at the

Site?

No additional comments.


Review report?

Yes.

F-1

APPENDIX F – DATA REVIEW

This data review incorporates settlement monument survey data, groundwater elevation data and groundwater

quality data as originally presented in the 2013 through 2016 annual inspection and monitoring reports, prepared

by the PRP’s O&M contractor Project Navigator, Ltd.

Monument Settlement Surveys

Monument settlement surveys conducted every two years monitor changes in the cap’s elevation to determine if

settlement has occurred. The surveys include collection of elevation data at three settlement monuments (A, B and

C) installed within the cap and a comparison of the data to 1998 baseline elevations. During this FYR period,

elevations varied by no more than 0.02 feet from baseline. Settlement is not occurring at this time.

Groundwater Elevation Data

Annual groundwater elevation measurements continue to show that depth to groundwater in monitoring wells

MW-3 and MW-4 is below the screened interval of these wells. These observations are consistent with

measurements observed at the Site since 2000. MW-3 and MW-4 are upgradient wells that are not included in the

current groundwater sampling program. All other shallow zone wells, including MW-5, MW-6 and MW-7, have

reported groundwater elevations within the screened intervals of the wells during the FYR period and have

allowed for collection of groundwater samples, as warranted. However, if water levels for sampled wells fall

below the bottom of the screen, the wells may need to be replaced in the future. Data collected during this FYR

period also indicate that groundwater flow direction in the uppermost aquifer unit at the Site is to the northwest,

consistent with historic observations.

Groundwater Quality Data

Groundwater sampling occurred in June 2014 and April 2016 at MW-2, MW-5, MW-6, MW-8 and MW-9;

resampling occurred at the same wells in July 2014 for metals only. This data review compares results to federal

MCLs. For those chemicals without MCLs (silver, nickel and zinc), this data review compares concentrations to

EPA tapwater regional screening levels, or RSLs, and LDEQ Risk Evaluation/Corrective Action Program

(RECAP) values. This appendix includes a summary of analytical results. Figure B-3 in Appendix B depicts well

locations.

Elevated concentrations of metals were reported in several wells during the June 2014 sampling event, with

several metals exceeding their applicable MCLs. The elevated concentrations were inconsistent with prior

sampling results for the Site. The PRP contractor believed the elevated concentrations were related to suspension

of sediment in the samples from the sampling procedure (bailing) as well as lack of sediment filtration. To verify

the elevated results, the PRP contractor re-sampled wells MW-2, MW-5, MW-6, MW-8 and MW-9 in July 2014

for metals only. The PRP contractor filtered the samples prior to them being sent for off-site analysis. Split

samples were collected and sent to two different laboratories.

The analytical results from samples collected during the July 2014 resampling event indicated that metal

concentrations were below their respective MCLs for each well as reported by both laboratories, a finding which

is consistent with historical analytical results. The data suggest that the elevated metals in the June 2014 event

were likely due to the presence of excessive sediment in the samples. Routine sampling conducted in April 2016

reported results similar to historical results. All metals were either non-detect or were below MCLs during the

April 2016 sampling event.

For those metals without MCLs (silver, nickel and zinc), concentrations were compared to EPA RSLs and LDEQ

RECAP values. Nickel concentrations in MW-2 exceeded the nickel RSL3 of 390 µg/L twice during this FYR

3 RSL is for nickel soluble salts. RSLs were viewed at https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables-

may-2016, accessed 1/9/17.

https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables-may-2016


F-2

period (487 µg/L in July 2014 and 530 µg/L in April 2016). Nickel in MW-2 also exceeded the LDEQ RECAP

value of 73 µg/L in both split samples from July 2014 and in April 2016. An increasing trend in nickel

concentrations was observed during the FYR period at MW-2; however, concentrations are lower than the

maximum concentration detected (780 µg/L) in 2005 (Figure F-1). MW-2 is located immediately downgradient of

the capped disposal cell. All other detections of silver, nickel and zinc were below their respective RSLs and

LDEQ RECAP values.

The 1994 ROD noted that sporadic presence of groundwater contaminants was not believed to be a result of site

activities. This belief was based on the fact that the naturally occurring inorganic contaminants detected

sporadically in groundwater were also detected in similar concentrations in the upgradient background well and

because the natural soils underlying the sludge pits do not appear to be contaminated with inorganics.

Figure F-1: Nickel Concentrations in Well MW-2

Note: Highest detected concentrations from samples collected between March 2005 and April 2016 used in the above chart.

No site-related VOCs or SVOCs were detected above MCLs during any sampling event during this FYR period.

Most VOCs and SVOCs were not detected. The exceptions include estimated (J) concentrations of toluene (0.56 J

µg/L) observed in MW-2 and benzene (0.82 J µg/L) in MW-6 during the June 2014 sampling event.

780

560

685

376

122 118

487530

0

100

200

300

400

500

600

700

800

900

Nic

kel

(µ

g/L

)

Sample Date

MW-2 Nickel Concentrations

Nickel (µg/L) RSL (390 µg/L)

F-3

Data Review Summary Tables4

4 Source: 2016 Annual Inspection and Monitoring Report, prepared by Project Navigator, Ltd, dated September 23, 2016.

G-1

APPENDIX G – SITE INSPECTION CHECKLIST

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site Name: PAB OIL & CHEMICAL SERVICES,

INC. Date of Inspection: 11/29/2016

Location and Region: Abbeville, LOUISIANA, R6 EPA ID: LAD980749139

Agency, Office or Company Leading the Five-Year

Review: EPA Region 6

Weather/Temperature: Cloudy/~70 degrees

Fahrenheit

Remedy Includes: (Check all that apply)

Landfill cover/containment Monitored natural attenuation

Access controls Groundwater containment

Institutional controls Vertical barrier walls

Groundwater pump and treatment

Surface water collection and treatment

Other:

Attachments: Inspection team roster attached Site map attached

II. INTERVIEWS (check all that apply)

1. O&M Site Manager Philip Jen, Project

Navigator, Ltd.

Name

Title

Date

Interviewed at site at office by phone Phone:

Problems, suggestions Report attached: Interview completed via emailed questionnaire; see Appendix E.

2. O&M Staff

Name

Title

Date

Interviewed at site at office by phone Phone:

Problems/suggestions Report attached:

3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency

response office, police department, office of public health or environmental health, zoning office,

recorder of deeds, or other city and county offices). Fill in all that apply.

Agency

Contact

Name

Title

Date

Phone No.


Agency

Contact Name

Title

Date

Phone No.


Agency

Contact

Name

Title

Date

Phone No.


Agency

Contact

Name

Title

Date

Phone No.

G-2


Agency

Contact

Name

Title

Date

Phone No.


4. Other Interviews (optional) Report attached:

III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)

1. O&M Documents

O&M manual Readily available Up to date N/A

As-built drawings Readily available Up to date N/A

Maintenance logs Readily available Up to date N/A

Remarks:

2. Site-Specific Health and Safety Plan Readily available Up to date N/A

Contingency plan/emergency response

plan

Readily available Up to date N/A

Remarks: The O&M contractor maintains the health and safety plan.

3. O&M and OSHA Training Records Readily available Up to date N/A

Remarks:

4. Permits and Service Agreements

Air discharge permit Readily available Up to date N/A

Effluent discharge Readily available Up to date N/A

Waste disposal, POTW Readily available Up to date N/A

Other permits: Readily available Up to date N/A

Remarks:

5. Gas Generation Records Readily available Up to date N/A

Remarks:

6. Settlement Monument Records Readily available Up to date N/A

Remarks:

7. Groundwater Monitoring Records Readily available Up to date N/A

Remarks:

8. Leachate Extraction Records Readily available Up to date N/A

Remarks:

9. Discharge Compliance Records

Air Readily available Up to date N/A

Water (effluent) Readily available Up to date N/A

G-3

Remarks:

10. Daily Access/Security Logs Readily available Up to date N/A

Remarks:

IV. O&M COSTS

1. O&M Organization

State in-house Contractor for state

PRP in-house Contractor for PRP

Federal facility in-house Contractor for Federal facility

2. O&M Cost Records

Readily available Up to date

Funding mechanism/agreement in place Unavailable

Original O&M cost estimate: $86,000 Breakdown attached

Total annual cost by year for review period if available

From: 01/01/2012

Date

To: 12/31/2012

Date

$25,000

Total cost

Breakdown attached

From: 01/01/2013

Date

To: 12/31/2013

Date

$14,000

Total cost

Breakdown attached

From: 01/01/2014

Date

To: 12/31/2014

Date

$28,000

Total cost

Breakdown attached

From: 01/01/2015

Date

To: 12/13/2015

Date

$15,000

Total cost

Breakdown attached

From: 01/01/2016

Date

To: 12/31/2016

Date

$25,000

(estimate)

Total cost

Breakdown attached

3. Unanticipated or Unusually High O&M Costs during Review Period

Describe costs and reasons:

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A

A. Fencing

1. Fencing Damaged Location shown on site map Gates secured N/A

Remarks: Barbed wire fencing is damaged in several locations, including along the southern boundary;

the front gate is secured.

B. Other Access Restrictions

1. Signs and Other Security Measures Location shown on site map N/A

Remarks: A no trespassing sign is posted on the front gate.

C. Institutional Controls (ICs)

G-4

1. Implementation and Enforcement

Site conditions imply ICs not properly implemented Yes No N/A

Site conditions imply ICs not being fully enforced Yes No N/A

Type of monitoring (e.g., self-reporting, drive by): Site inspections

Frequency: annually

Responsible party/agency: PRP (PAB Group)

Contact

Name Title Date Phone no.

Reporting is up to date Yes No N/A

Reports are verified by the lead agency Yes No N/A

Specific requirements in deed or decision documents have been met Yes No N/A

Violations have been reported Yes No N/A

Other problems or suggestions: Report attached

2. Adequacy ICs are adequate ICs are inadequate N/A

Remarks:

D. General

1. Vandalism/Trespassing Location shown on site map No vandalism evident

Remarks:

2. Land Use Changes On Site N/A

Remarks:

3. Land Use Changes Off Site N/A

Remarks: New homes have been built adjacent to the northern site boundary.

VI. GENERAL SITE CONDITIONS

A. Roads Applicable N/A

1. Roads Damaged Location shown on site map Roads adequate N/A

Remarks:

B. Other Site Conditions

Remarks:

VII. LANDFILL COVERS Applicable N/A

A. Landfill Surface

1. Settlement (low spots) Location shown on site map Settlement not evident

Area extent: Depth:

Remarks:

2. Cracks Location shown on site map Cracking not evident

Lengths: Widths: Depths:

G-5

Remarks:

3. Erosion Location shown on site map Erosion not evident

Area extent: Depth:

Remarks:

4. Holes Location shown on site map Holes not evident

Area extent: Depth:

Remarks: An animal burrow, less than 1 foot deep, was observed on the northern end of the cap. An

additional animal burrow was observed under the well pad of MW-8.

5. Vegetative Cover Grass Cover properly established

No signs of stress Trees/shrubs (indicate size and locations on a diagram)

Remarks:

6. Alternative Cover (e.g., armored rock, concrete) N/A

Remarks:

7. Bulges Location shown on site map Bulges not evident

Area extent: Height:

Remarks:

8. Wet Areas/Water

Damage

Wet areas/water damage not evident

Wet areas Location shown on site map Area extent:

Ponding Location shown on site map Area extent:

Seeps Location shown on site map Area extent:

Soft subgrade Location shown on site map Area extent:

Remarks:

9. Slope Instability Slides Location shown on site map

No evidence of slope instability

Area extent:

Remarks:

B. Benches Applicable N/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in

order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)

1. Flows Bypass Bench Location shown on site map N/A or okay

Remarks:

2. Bench Breached Location shown on site map N/A or okay

Remarks:

3. Bench Overtopped Location shown on site map N/A or okay

Remarks:

G-6

C. Letdown Channels Applicable N/A

(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side

slope of the cover and will allow the runoff water collected by the benches to move off of the landfill

cover without creating erosion gullies.)

1. Settlement (Low spots) Location shown on site map No evidence of settlement

Area extent: Depth:

Remarks:

2. Material Degradation Location shown on site map No evidence of degradation

Material type: Area extent:

Remarks:

3. Erosion Location shown on site map No evidence of erosion

Area extent: Depth:

Remarks:

4. Undercutting Location shown on site map No evidence of undercutting

Area extent: Depth:

Remarks:

5. Obstructions Type: No obstructions

Location shown on site map Area extent:

Size:

Remarks:

6. Excessive Vegetative Growth Type:

No evidence of excessive growth

Vegetation in channels does not obstruct flow

Location shown on site map Area extent:

Remarks:

D. Cover Penetrations Applicable N/A

1. Gas Vents Active Passive

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

2. Gas Monitoring Probes



Remarks:

3. Monitoring Wells (within surface area of landfill)


G-7


Remarks:

4. Extraction Wells Leachate



Remarks:

5. Settlement Monuments Located Routinely surveyed N/A

Remarks:

E. Gas Collection and Treatment Applicable N/A

1. Gas Treatment Facilities

Flaring Thermal destruction Collection for reuse

Good condition Needs maintenance

Remarks:

2. Gas Collection Wells, Manifolds and Piping


Remarks:

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)

Good condition Needs maintenance N/A

Remarks:

F. Cover Drainage Layer Applicable N/A

1. Outlet Pipes Inspected Functioning N/A

Remarks:

2. Outlet Rock Inspected Functioning N/A

Remarks:

G. Detention/Sedimentation Ponds Applicable N/A

1. Siltation Area extent: Depth: N/A

Siltation not evident

Remarks:

2. Erosion Area extent: Depth:

Erosion not evident

Remarks:

3. Outlet Works Functioning N/A

Remarks:

4. Dam Functioning N/A

Remarks:

G-8

H. Retaining Walls Applicable N/A

1. Deformations Location shown on site map Deformation not evident

Horizontal displacement: Vertical displacement:

Rotational displacement:

Remarks:

2. Degradation Location shown on site map Degradation not evident

Remarks:

I. Perimeter Ditches/Off-Site Discharge Applicable N/A

1. Siltation Location shown on site map Siltation not evident

Area extent: Depth:

Remarks:

2. Vegetative Growth Location shown on site map N/A

Vegetation does not impede flow

Area extent: Type:

Remarks:

3. Erosion Location shown on site map Erosion not evident

Area extent: Depth:

Remarks: Animal burrows were observed in the northern drainage ditch.

4. Discharge Structure Functioning N/A

Remarks: Corrugated pipe under access road appeared clear.

VIII. VERTICAL BARRIER WALLS Applicable N/A

1. Settlement Location shown on site map Settlement not evident

Area extent: Depth:

Remarks:

2. Performance Monitoring Type of monitoring:

Performance not monitored

Frequency: Evidence of breaching

Head differential:

Remarks:

IX. GROUNDWATER/SURFACE WATER REMEDIES Applicable – Monitoring Only N/A

A. Groundwater Extraction Wells, Pumps and Pipelines Applicable N/A

1. Pumps, Wellhead Plumbing and Electrical

Good condition All required wells properly operating Needs maintenance N/A

Remarks:

2. Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances

G-9


Remarks:

3. Spare Parts and Equipment

Readily available Good condition Requires upgrade Needs to be provided

Remarks:

B. Surface Water Collection Structures, Pumps and Pipelines Applicable N/A

1. Collection Structures, Pumps and Electrical


Remarks:

2. Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances


Remarks:

3. Spare Parts and Equipment

Readily available Good condition Requires upgrade Needs to be provided

Remarks:

C. Treatment System Applicable N/A

1. Treatment Train (check components that apply)

Metals removal Oil/water separation Bioremediation

Air stripping Carbon adsorbers

Filters:

Additive (e.g., chelation agent, flocculent):

Others:


Sampling ports properly marked and functional

Sampling/maintenance log displayed and up to date

Equipment properly identified

Quantity of groundwater treated annually:

Quantity of surface water treated annually:

Remarks:

2. Electrical Enclosures and Panels (properly rated and functional)

N/A Good condition Needs maintenance

Remarks:

3. Tanks, Vaults, Storage Vessels

N/A Good condition Proper secondary containment Needs maintenance

Remarks:

G-10

4. Discharge Structure and Appurtenances

N/A Good condition Needs maintenance

Remarks:

5. Treatment Building(s)

N/A Good condition (esp. roof and doorways) Needs repair

Chemicals and equipment properly stored

Remarks:

6. Monitoring Wells (pump and treatment remedy)


All required wells located Needs maintenance N/A

Remarks:

D. Monitoring Data

1. Monitoring Data

Is routinely submitted on time Is of acceptable quality

2. Monitoring Data Suggests:

Groundwater plume is effectively contained Contaminant concentrations are declining

E. Monitored Natural Attenuation

1. Monitoring Wells (natural attenuation remedy)


All required wells located Needs maintenance N/A

Remarks:

X. OTHER REMEDIES

If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical

nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

XI. OVERALL OBSERVATIONS

A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed.

Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant

plume, minimize infiltration and gas emissions).

The remedy was designed to prevent direct contact, ingestion and migration of the disposal pit sludges and

associated soils. Contaminated soil and sludge were consolidated and treated on site, placed in the

disposal cell and covered with a low-permeability cap. The cap is vegetated, well-maintained and

monitored on a regular basis. Animal burrows are periodically identified in the vegetative soil cover on

the cap but have not compromised the integrity of the cap. The PRP contractor fills in the animal burrows

as soon as they are identified. Damage to the perimeter fence was also noted during the site inspection; the

PRP contractor will fix damage to continue to restrict unauthorized access. Groundwater at the Site is

monitored regularly. Chemicals of concern were below MCLs during the most recent sampling event.

Institutional controls are in place. The remedy is effective and functioning as designed.

B. Adequacy of O&M

Describe issues and observations related to the implementation and scope of O&M procedures. In

particular, discuss their relationship to the current and long-term protectiveness of the remedy.

O&M procedures appear adequate at this time.

C. Early Indicators of Potential Remedy Problems

G-11

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high

frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised

in the future.

There are no indicators of potential remedy problems.

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.

None at this time.

Site Inspection Participants:

Mike Hebert, EPA RPM

Philip Jen, Project Navigator (PRP contractor)

Earl Moran, ExxonMobil (PAB Remediation Group, L.L.C.)

Eric Marsh, Skeo (EPA contractor)

Jill Billus, Skeo (EPA contractor)

H-1

APPENDIX H – REMEDIAL ACTION AND SITE INSPECTION PHOTOS

Remedial Action Photos: 1997

Remedial action access road.

Saltwater pond.

H-2

Dewatered pond area.

Cap construction.

H-3

Site Inspection Photos: November 28, 2016

Gated entrance to the Site with no trespassing sign.

Former saltwater pond area with cap in the background, looking east.

H-4

Burrow area along northern drainage ditch.

Vegetated cap and settlement monuments, looking northeast.

H-5

Vegetated cap looking east.

Burrow hole beneath the MW-4 well pad.

H-6

Cap settlement monument 3.

Eastern drainage ditch, facing south at the northeast corner of the Site; no fencing blocks site entrance.

H-7

Fencing along northern site boundary and off-site borrow lake.

Tire dump area in the northeast corner of the Site.

H-8

Monitoring well MW-8, unlocked for the site inspection.

Former saltwater pond area looking west from cap.

H-9

Damaged fencing along southern boundary.

Monitoring well MW-5.

H-10

Monitoring well MW-7 along southern boundary; residential area in the background.

Southern drainage ditch outside of southern site boundary.

I-1

APPENDIX I – DETAILED ARARs REVIEW TABLES

CERCLA Section 121(d)(1) requires that Superfund remedial actions attain “a degree of cleanup of hazardous

substance, pollutants, and contaminants released into the environment and of control of further release at a

minimum which assures protection of human health and the environment.” The remedial action must achieve a

level of cleanup that at least attains those requirements that are legally applicable or relevant and appropriate. In

performing the FYR for compliance with ARARs, only those chemical-specific ARARs that address the

protectiveness of the remedy are reviewed.

Surface Water ARARs

The 1993 ROD selected the following ARARs and TBCs for surface water:

Federal water quality standards established under the Clean Water Act (Section 303, Clean Water Act,

1987, as amended)

State water quality standards established under Title 33 of the Louisiana Administrative Act [LAC]

Chapter 11)

Because the surface water treatment process is complete and no surface water is currently collected, treated or

discharged, these standards are no longer relevant.

Air ARARs

The 1993 ROD selected the following ARARs for air:

National Ambient Air Quality Standards (40 Code of Federal Regulations [CFR] 50.6)

These air quality standards were relevant and appropriate when applied to the vapors and particulate

matter released during the excavation, treatment and consolidation of wastes. Because waste excavation,

treatment and consolidation are complete, these standards are no longer relevant.

Soil ARARs

The 1993 ROD stated that the source of the arsenic remedial goal for soil and sediment of 10 mg/kg was State of

Louisiana Statewide Order 29-B, Section 129.B.6, Pit Closure. In December 2000, Section 129 was restructured

and pit closure is now addressed in Sections 311 through 313 of the June 2010 Louisiana Administrative Code

(http://dnr.louisiana.gov/assets/OC/43XIX_June2010.pdf). Based on review of the updated code and metals

limitation criteria for pit closure, the arsenic ARAR for pit closure has not changed.

Groundwater ARARs

The 1993 ROD stated that groundwater data in the long-term groundwater monitoring program would be

compared to appropriate drinking water standards. However, the 1993 ROD did not identify groundwater

chemicals of concern (COC) or chemical-specific groundwater ARARs for the Site. During the 2007 FYR, EPA

noted that the drinking water standards established under the Safe Drinking Water Act (SDWA) ((40 CFR 141.11)

were applicable requirements for the Site.

Under the SDWA, MCLs serve as the applicable regulatory treatment standard for groundwater unless more

stringent standards are promulgated. Table I-1 lists the MCLs in effect at the time of the 2007 FYR for those

COCs historically detected in groundwater.

Chemical-specific standards have also been developed under the Louisiana Department of Environmental Quality

(LDEQ) Risk Evaluation/Corrective Action Program (RECAP) that was promulgated on June 20, 2000, and

finalized on October 20, 2003. However, the 2007 FYR notes that because the 1993 ROD was approved by

LDEQ prior to the effective date, RECAP is not an ARAR for the Site.

http://dnr.louisiana.gov/assets/OC/43XIX_June2010.pdf

I-2

Although not an ARAR, the RECAP groundwater screening standards for metals historically detected at

the Site have been included as evaluation criteria and are presented in Table I-1. There have been no changes to

MCLs or the RECAP values since the 2007 FYR first included these criteria.

Table I-1: Groundwater ARAR and TBC Reviewa

Contaminant

2007 FYR

ARAR or evaluation value

(mg/L)

Current ARAR or TBC value

(mg/L) ARAR or TBC Change

Federalb Statec Federale Statef

Antimony 0.006 0.006 0.006 0.006 No change

Arsenic 0.010 0.010 0.010 0.010 No change

Barium 2 2 2 2 No change

Beryllium 0.004 0.004 0.004 0.004 No change

Cadmium 0.005 0.005 0.005 0.005 No change

Chromium (total) 0.1 0.1 0.1 0.1 No change

Copper 1.3 1.3 1.3 1.3 No change

Lead 0.015 0.015 0.015 0.015 No change

Mercury 0.002 0.002 0.002 0.002 No change

Nickel NSd 0.073 NS 0.073 No change

Selenium 0.05 0.05 0.05 0.05 No change

Silver NS 0.018 NS 0.018 No change

Thallium 0.002 0.002 0.002 0.002 No change

Zinc NS 1.1 NS 1.1 No change

Notes:

a) The ROD did not identify groundwater ARARs. However, the 2007 FYR noted that the federal MCLs were applicable

requirements for the Site. This ARAR review compares the COCs and MCLs identified in the 2007 FYR with current MCLs for

those same COCs.

b) Maximum contaminant level (MCL) in effect at the time of the 2007 FYR.

c) LDEQ RECAP value in effect at the time of the 2007 FYR.

d) NS = No standard established; EPA RSLs for nickel (390 µg/L), silver (94 µg/l) and zinc (6,000 µg/L) used for data evaluation.

e) Current MCLs available at https://www.epa.gov/ground-water-and-drinking-water/table-regulated-drinking-water-contaminants

(accessed 11/8/16).

f) LDEQ RECAP values available at

http://www.deq.louisiana.gov/portal/DIVISIONS/UndergroundStorageTankandRemediationDivision/RemediationServices/RECAP

/RECAPDocument2003.aspx (accessed 11/8/16). mg/L = milligrams per liter

https://www.epa.gov/ground-water-and-drinking-water/table-regulated-drinking-water-contaminants

http://www.deq.louisiana.gov/portal/DIVISIONS/UndergroundStorageTankandRemediationDivision/RemediationServices/RECAP/RECAPDocument2003.aspx

http://www.deq.louisiana.gov/portal/DIVISIONS/UndergroundStorageTankandRemediationDivision/RemediationServices/RECAP/RECAPDocument2003.aspx

J-1

APPENDIX J – DETAILED TOXICITY REVIEW

Table J-1: Review of Soil Remedial Goals – Commercial/Industrial

COC

Soil

Remedial

Goal

(mg/kg)

Industrial RSLa

Riskb HQc

10-6 Risk Hazard Quotient

(HQ) = 1.0

Arsenic 10 3 480 3.3 x 10-6 0.02

Barium 5,400 NA 220,000 NA 0.02

Total cPAHs 3d 0.29e NA 1.0 x 10-5 NA Notes:

a) Current EPA RSLs, dated May 2016, are available at https://www.epa.gov/risk/regional-screening-levels-rsls-generic-

tables-may-2016 (accessed 11/08/16).

b) The cancer risks were calculated using the following equation, based on the fact that RSLs are derived based on 1 x 10-6

risk: Cancer risk = (cleanup goal ÷ cancer-based RSL) × 10-6.

c) The noncancer HQ was calculated using the following equation: HQ = (cleanup goal ÷ noncancer RSL).

d) Expressed as a benzo(a)pyrene (BaP) equivalent.

e) RSLs for benzo(a)pyrene used.

NA = EPA has not finalized a carcinogenic or noncarcinogenic toxicity value for this compound

Bold = risk exceeds EPA’s risk management range of 10-6 to 10-4 or HQ exceeds 1

mg/kg = milligrams per kilogram



K-1

APPENDIX K – CONVEYANCE NOTICE