THIRD FIVE-YEAR REVIEW REPORT FOR MADISONVILLE … · The Madisonville Creosote Works Superfund Site (MCW Site or Site) is located adjacent to the southern side of Louisiana State

THIRD FIVE-YEAR REVIEW REPORT FOR

MADISONVILLE CREOSOTE WORKS SUPERFUND SITE ST. TAMMANY PARISH, LOUISIANA

February 2014

Prepared by

U.S. Environmental Protection Agency Region 6

Dallas, Texas

rhueston

Redacted Version

Determinations

The remedy at the Madisonville Creosote Works Superfund Site currently protects human health and the environment. Long-term protectiveness of the remedial action will be assured by continuing to perform operation and maintenance (O&M) in accordance with the Operation and Maintenance Plan (O&M Plan), that the dense non-aqueous phase liquid (DNAPL) recovery trenches and the wastewater treatment plant (WWTP) are maintained, ground water monitoring data are evaluated to determine if the protection of ground water and the Upland Terrace Aquifer is occurring, security fencing around the DNAPL recovery trenches and WWTP is maintained, and institutional controls in the form of a deed notice continue to be enforced.

As a component of the next Five-Year Review to continue to evaluate long-term protectiveness and ensure that the remedy remains protective of human health, benzene in soil should be re-evaluated to determine the potential for benzene to cause a vapor intrusion risk.

Director Superfund Division, Region 6 U.S. Environmental Protection Agency

CONCURRENCES:

THIRD FIVE-YEAR REVIEW REPORT MADISONVILLE CREOSOTE WORKS SUPERFUND SITE

EPA ID NO. LAD981522998

/ . / ! ' . _ J J Concur By: . ,:'~~~ 'J. _/ ·I ~·u ... it-:._) '>(U")

Laufa Stankosky U.S. EPA, Region 6 Remedial Project Manager

Concur By (ltd&q dJ~Wh( ' Cathy Gilmore U.S. EPA, Region 6 Chief, LA, OK, NM Section, Superfund Remedial Branch

Concur By: _::> > IIf' Josep, Compton U.S EPA, Region 6 Site Attorney, Office of Regional Counsel

~ncj]~ M7rAPe)!Cke U.S. EPA, Region 6 Chief, Superfund Branch, Office of Regional Counsel

Concur By: __ +-'--""--"....:....:....___,_,~--f---'"'--------Pame a Phillips U.S. EPA, Region 6 Assoc iate Director, Superfund Division

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Table of Contents List of Acronyms ....................................................................................................................................... iii Executive Summary................................................................................................................................... 1 Five-Year Review Summary Form .......................................................................................................... 2 I. Introduction .................................................................................................................................... 5 II. Site Chronology ............................................................................................................................. 6 III. Background .................................................................................................................................... 7

A. Physical Characteristics ................................................................................................... 7 B. Land and Resource Use .................................................................................................. 7 C. History of Contamination ................................................................................................. 7 D. Initial Response ................................................................................................................ 8 E. Basis for Taking Action .................................................................................................... 9

IV. Remedial Actions ........................................................................................................................ 10 A. Remedy Selection........................................................................................................... 10 B. Remedy Implementation ................................................................................................ 11 C. System Operations/Operation and Maintenance ....................................................... 13

V. Progress Since the Last Five-Year Review ............................................................................ 13 VI. Five-Year Review Process ........................................................................................................ 14

A. Administrative Components .......................................................................................... 14 B. Community Involvement ................................................................................................ 14 C. Document Review........................................................................................................... 15 D. Data Review .................................................................................................................... 15 E. Site Inspection ................................................................................................................. 16 F. Interviews ......................................................................................................................... 17

VII. Technical Assessment ............................................................................................................... 17 A. Question A: Is the remedy functioning as intended by the decision documents?17 B. Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial

action objectives (RAOs) used at the time of remedy selection still valid? ........... 18 C. Question C: Has any other information come to light that could call into question the

protectiveness of the remedy? ..................................................................................... 21 D. Technical Assessment Summary ................................................................................. 21

VIII. Issues ........................................................................................................................................... 22 IX. Recommendations and Follow-up Actions ............................................................................. 22 X. Protectiveness Statement ......................................................................................................... 23 XI. Next Review ................................................................................................................................. 23

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Tables Table 1 - Chronology of Site Events Table 2 - Issues Identified Table 3 - Recommendations and Follow-up Actions Attachments Attachment 1 - Site Location Map and Site Layout Map Attachment 2 - Tables Summarizing Monthly Operational Report Data Attachment 3 - Announcement of the First Five-Year Review Attachment 4 - List of Documents Reviewed Attachment 5 - Applicable or Relevant and Appropriate Requirements Attachment 6 - Site Visit Checklist Attachment 7 - Site Inspection Photographs Attachment 8 - Interview Records Attachment 9 - Institutional Controls

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List of Acronyms

µg Microgram µg/L Microgram per liter AMP Air management plan ARAR Applicable or Relevant and Appropriate Requirement B(a)P Benzo(a)pyrene bgs Below Ground Surface BOD Biological oxygen demand BTEX Benzene, Toluene, Ethyl Benzene, and Xylenes CD Consent Decree CDC Centers for Disease Control and Prevention CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations COC Contaminant of Concern COD Chemical Oxygen Demand CWA Clean Water Act DNAPL Dense nonaqueous phase liquid DO Dissolved oxygen EDW Effluent discharge water EPA United States Environmental Protection Agency, Region 6 FS Feasibility Study FSP Field sampling plan HASP Health and Safety Plan HRS Hazard Ranking System IASD Inactive and Abandoned Sites Division IC Institutional Control IRIS Integrated Risk Information System J Estimated kg Kilogram L Liter LAC Louisiana Administrative Code LDEQ Louisiana Department of Environmental Quality LDNR Louisiana Department of Natural Resources LNAPL Light Non-Aqueous Phase Liquid LPAC Liquid Phase Activated Carbon LSWR Louisiana Solid Waste Regulations LTTD Low temperature thermal desorption m3 Cubic Meter MCL Maximum Contaminant Level MCW Madisonville Creosote Works MCWI Madisonville Creosote Works, Inc. mg/kg Milligrams per kilogram mg/L Milligrams per liter MW Monitoring Well NCP National Oil and Hazardous Substances Pollution Contingency Plan

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ND Non-detect NIOSH National Institute of Occupational Safety and Health NPL National Priorities List NRHP National Registry of Historic Places NTU Nephelometric turbidity unit O&M Operations and Maintenance OSHA Occupational Health and Safety Administration OU Operable unit PAH Polycyclic Aromatic Hydrocarbon PM-10 Particulate matter smaller than 10 micrometers (μm) in diameter PCOR Preliminary Close Out Report ppm Parts Per Million PRP Potentially Responsible Party QAPP Quality Assurance Project Plan RA Remedial Action RAC Response Action Contract RACR Remedial Action Completion Report RAO Remedial Action Objective RAWP Remedial Action Work Plan RCRA Resource Conservation and Recovery Act RD Remedial Design RI Remedial Investigation ROD Record of Decision RPM Remedial Project Manager SARA Superfund Amendments and Reauthorization Act SEMS, Inc. Southern Environmental Management & Specialties SH 22 Louisiana State Highway 22 Site Madisonville Creosote Works Superfund Site SVOC Semivolatile organic compound TBC To be considered U Not Present at or Above the Associated Limit VOC Volatile organic compound WWTP Wastewater treatment plant

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Executive Summary The Madisonville Creosote Works Superfund Site (MCW Site or Site) is located adjacent to the southern side of Louisiana State Highway 22 (SH 22), about three miles west of downtown Madisonville and 1.25 miles from the Madisonville city limits. The Site covers approximately 29 acres in Section 42, Township 7S, Range 10E, St. Tammany Parish, in southeastern Louisiana.

EPA signed the Record of Decision (ROD) for the Site on August 25, 1998. The selected remedy for Operable Unit (OU) 01 included (1) the excavation and treatment of contaminated soil and sediments using low temperature thermal desorption (LTTD) technologies, (2) installing a dense non-aqueous phase liquid (DNAPL) recovery trench system, and (3) constructing a DNAPL collection system and wastewater treatment plant. The remedial action (RA) activities began in January 1999 and concluded in May 2000 after the final inspection certifying that all cleanup activities associated with LTTD operations and DNAPL recovery trench construction were complete. Operation and maintenance (O&M) of the DNAPL collection system and wastewater treatment plant is ongoing. The MCW Site achieved construction completion with the signing of the Preliminary Close Out Report on June 16, 2000. The trigger for this five-year review was the site mobilization and the actual start of construction on January 11, 1999.

The assessment of this five-year review found that the remedy was constructed in accordance with the requirements of the ROD. The MCW Site is currently protective of human health and the environment. Long-term protectiveness of the remedial action will be assured by continuing to perform O&M in accordance with the Operation and Maintenance Plan (O&M Plan), that the DNAPL recovery trenches and the wastewater treatment plant (WWTP) are maintained, ground water monitoring data are evaluated to determine if the protection of ground water and the Upland Terrace Aquifer is occurring, security fencing around the DNAPL recovery trenches and WWTP is maintained, and institutional controls in the form of a deed notice continue to be enforced. However, as a component of the next Five-Year Review and to continue to evaluate long-term protectiveness, benzene in soil should be re-evaluated to determine the potential for benzene to cause a vapor intrusion risk.

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Five-Year Review Summary Form

SITE IDENTIFICATION

Site Name: Madisonville Creosote Works Superfund Site (Site)

EPA ID: LAD981522998

Region: 6 State: LA City/County: Madisonville/St. Tammany Parish

SITE STATUS

NPL Status: Final

Multiple OUs?

No

Has the site achieved construction completion?

Yes

REVIEW STATUS

Lead agency: EPA If “Other Federal Agency” was selected above, enter Agency name:

Author name (Federal or State Project Manager): Laura Stankosky

Author affiliation: EPA

Review period: April 2013 – February 2014

Date of site inspection: September 17, 2013

Type of review: Statutory

Review number: 3

Triggering action date: February 26, 2009

Due date (five years after triggering action date): February 26, 2014

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Five-Year Review Summary Form (continued)

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the Five-Year Review:

None.

Issues and Recommendations Identified in the Five-Year Review:

OU(s): Site Issue Category: Remedy Performance

Issue: Benzene is a compound found in creosote. The vapor intrusion potential of benzene at the Site was not evaluated during the Remedial Investigation.

Recommendation: The only buildings currently at the Site are the wastewater treatment plant and an air monitoring station maintained by the state. While these buildings are only occupied during the Site Managers periodic visits or state maintenance at the air monitoring station, if Site reuse included more continuously occupied buildings, vapor intrusion may pose a risk. As a component of the next Five-Year Review to continue to evaluate long-term protectiveness and ensure that the remedy remains protective of human health, benzene in soil should be re-evaluated to determine the potential for benzene to cause a vapor intrusion risk.

Affect Current Protectiveness

Affect Future Protectiveness

Implementing Party

Oversight Party

Milestone Date

No Yes EPA/State EPA/State March 2019

Protectiveness Statement(s)

Operable Unit: Site

Protectiveness Determination: Protective

Addendum Due Date (if applicable): Not Applicable

Protectiveness Statement: See Sitewide Protectiveness Statement

Sitewide Protectiveness Statement (if applicable)

Protectiveness Determination: Protective

Addendum Due Date (if applicable): Not Applicable

Protectiveness Statement: The remedy at the Madisonville Creosote Works Superfund Site currently protects human health and the environment. Long-term protectiveness of the remedial action will be assured by continuing to perform O&M in accordance with the O&M Plan, that the DNAPL recovery

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trenches and the WWTP are maintained, ground water monitoring data are evaluated to determine if the protection of ground water and the Upland Terrace Aquifer is occurring, security fencing around the DNAPL recovery trenches and WWTP is maintained, and institutional controls in the form of a deed notice continue to be enforced. However, as a component of the next Five-Year Review to continue to evaluate long-term protectiveness and ensure that the remedy remains protective of human health, benzene in soil should be re-evaluated to determine the potential for benzene to cause a vapor intrusion risk.

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Madisonville Creosote Works Superfund Site Madisonville, St. Tammany Parish, Louisiana

Third Five-Year Review Report

I. Introduction The purpose of the five-year review is to determine whether the remedy at a site is protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in Five-Year Review reports. In addition, Five-Year Review reports identify issues found during the review, if any, and identify recommendations to address them. The Agency is preparing this Five-Year Review report pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121(e), 42 U.S.C. § 9621(e) and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 400. CERCLA Section 121(e) states:

If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] [42 U.S.C. § 9604] or [106][42 U.S.C.§ 9606], the President shall take or require such action. The President shall report to the Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews.

The Agency interpreted this requirement further in the NCP; 40 Code of Federal Regulations §300.430(f)(4)(ii) states:

If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation of the selected remedial action.

The United States Environmental Protection Agency (EPA), Region 6, conducted the five-year review of the remedy implemented at the MCW Site, Madisonville, St. Tammany Parish, Louisiana. This review was conducted by the Remedial Project Manager (RPM) for the Site, supported by Louisiana Department of Environmental Quality project manager and Southern Environmental Management & Specialties (SEMS, Inc.) site manager, from April 2013 to November 2013. This report documents the results of the review. This is the third five-year review for the MCW Site. The triggering action for this statutory review is the completion of the second Five-Year Review completed on February 26, 2009. The five-year review is required due to the fact that hazardous substances, pollutants, or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure.

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II. Site Chronology A chronology of site events for the MCW Site is provided below in Table 1.

Table 1 - Chronology of Site Events

Event Date

Wood preserving operations begin at the site 1956-1957

Site discovery July 22, 1994

Initial residential water sampling March 14, 1996

Initiation of Remedial Investigation March 26, 1996

Proposed inclusion on the National Priorities List June 17, 1996

Open house with community concerning site activities September 10, 1996

Removal action September 23, 1996 – January 9, 1997

Ecological evaluation report November 12, 1996

Final NPL listing December 23, 1996

Feasibility Study initiated January 17, 1997

Open house with community concerning site activities February 6, 1997 Human Health Risk and Ecological Screening Risk Assessments

March 27, 1997

Community Relations Plan complete August 1997

RI report complete September 26, 1997

RI supplemental sampling report October 24, 1997

Feasibility Study completed November 18, 1997

Proposed Plan community meeting March 26, 1998

Open house with community concerning site activities March 28, 1998

Record of Decision issued August 25, 1998

Remedial Action initiated January 1999

Community bulletin provided February 11, 1999

Pre-final inspection April 20, 2000

Preliminary Close Out Report signed June 16, 2000

Official construction completion ceremony July 27, 2000

Groundwater maintenance and operation by EPA July 2000 – August 2001

State operation and maintenance begins September 1, 2001

Remedial Action Completion Report submitted September 28, 2001

First Five Year Review report signed March 1, 2004

Second Five Year Review report signed February 26, 2009

Mail-out of Third Five-Year Review fact sheet September 2013

Public Notice of Third Five-Year Review September 18, 2013

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III. Background

A. Physical Characteristics The Site is located adjacent to the southern side of Louisiana State Highway 22 (SH 22), about 3 miles west of downtown Madisonville and 1.25 miles from the Madisonville city limits. The MCW Site covers approximately 29 acres in Section 42, Township 7S, Range 10E, St. Tammany Parish, in southeastern Louisiana. The topography is gently sloping to the south of the property and includes two primary surface-water runoff receiving ditches. The southern ditch runs south on the west side of the property, then turns east and leads off property to the south stream. The north ditch runs parallel to SH 22, outside the north property line and leads to a culvert that flows north under SH 22 to an unnamed stream (north stream). An aerial photograph of the MCW Site and surrounding area (See Figure 1) and a site layout map (See Figure 2) are provided in Attachment 1. B. Land and Resource Use The area surrounding the Site is predominantly rural and wooded. During the site visit, three or more residences were noted adjacent to the Site on the west side of the Site and a new residential housing development was noted adjacent to the Site on the east side. Prior to the establishment of wood-treating operations, the MCW Site was primarily forested land, with a farmstead encompassing about 5.5 acres along the western property boundary. Wood-preserving operations at the Site began in 1956 or 1957 under the name Madisonville Creosote Works, Inc. As stated in the Feasibility Study report for the Site, the Louisiana Department of Environmental Quality (LDEQ) Inactive and Abandoned Sites Division (IASD) is aware of the presence of two protected or endangered species, the bald eagle (threatened) and the red-cockaded woodpecker (endangered), in the Madisonville area. The presence of either of these species at the MCW Site has not been documented by the LDEQ IASD. Other endangered species (that is, Gulf of Mexico sturgeon) potentially inhabit the vicinity of the MCW Site; however, no endangered species have been documented within the study area. During the Remedial Investigation (RI), an exceptionally large live oak (Quercus virginiana) tree was identified. The tree’s girth and spread of limbs were measured on February 6, 1997, to evaluate its eligibility for registration in The Live Oak Society. At 4 to 4.5 feet above ground surface, the tree’s girth was 16.2 feet and the limb spread was 102 feet. The minimum required 16-foot girth was exceeded, indicating that the tree was likely to be greater than 100 years old, making the tree eligible for registration. A registration form was completed and submitted to The Live Oak Society, thereby protecting the tree under the constitution and by-laws of the society. The district surrounding the Site is primarily zoned as rural, but large tracts within 1 mile of the Site are zoned for suburban use. Subdivisions have been developed or are under construction on these tracts, and other subdivisions are being planned. The property directly across SH 22 from the Site and several other tracts on SH 22 west of the Site are zoned for highway commercial use. C. History of Contamination During wood-treating operations, poles, ties, and lumber were treated by impregnating the wood with creosote in retort cylinders under elevated temperature and pressure. The waste streams generated during these operations included process water, cooling water, boiler water, and waste creosote. The process water and waste creosote were considered hazardous as defined by Resource Conservation and Recovery Act (RCRA) regulations, and the wastes were categorized as K001 and F034 waste, respectively. Waste code K001 applies to bottom

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sediment sludge from the treatment of wastewater from wood-preserving processes that use creosote. Waste code F034 applies to wastewater, process residuals, preservative dripping, and spent formulations from wood-preserving processes generated at plants that use creosote formulations. The cooling and boiler water were considered nonhazardous waste streams under RCRA.

Starting in 1974 or prior, the facility used two unlined process water ditches and two unlined ponds to convey and store process waste liquids and sludges. Waste creosote and wastewater drained from the treatment cylinders to the large process ditch. The small process ditch conveyed waste liquids from the large process ditch to former process water pond. The solids settled, and water overflowed through a depression in the earthen dike separating the ponds, and into an evaporation pond. The ponds and the process water ditches were closed as solid waste management units between 1984 and 1986 under an LDEQ-approved and inspected closure. A post-closure maintenance and monitoring plan was required due to the presence of ground water contamination.

D. Initial Response Based on the results from preliminary assessments and sampling, EPA initiated RI activities at the Site in March 1996 to determine the nature and extent of the contamination. In June 1996, EPA proposed that the Site be included on the National Priorities List (NPL). In December 1996, EPA announced that the Site had been added to the NPL. During the RI activities, a Time-Critical Removal Action (TCRA) was conducted concurrently. The 1996 EPA TCRA involved demolition, consolidation, and/or disposal of the following: 11 site buildings and their contents (including drums of oil waste); the process area (including 15 storage tanks and their contents, three treatment cylinders, asbestos insulation, mercury-contaminated debris, and the concrete pad); piles of treated wood; and steel railroad tracks leading from treatment cylinders to wood storage areas. In addition, a 6-foot-high chain-link fence with barbed wire fencing was installed along the SH 22 side of the highway. On-site soil contamination was defined by the layer of contaminated soil that was not more than 4 feet below ground surface (bgs). Off-site soil contamination was further delineated to no more than the banks of the north drainage ditch and the banks of the north and south streams. The layer of soil contamination that was in contact with surface water defines sediment contamination in the north drainage ditch, north stream, and south stream. The majority of the soil contamination was located within on-site areas. Surface water contamination was also found at the Site. Surface water contamination was affected by the creosote-contaminated soil and sediment sources. The source of surface water contamination was eliminated and no additional action was required once the contaminated soil and sediments were removed from the streams and ditches. The ground water within the shallow clayey-silt matrix, immediately beneath the on-site area, is contaminated. Creosote can be characterized as a DNAPL because it has a low solubility in water and will separate out and settle towards the bottom within a saturated zone. DNAPL contamination was found in this saturated zone, within the shallow clayey-silt matrix, approximately 15 to 25 feet bgs. The area of St. Tammany Parish is located in the Gulf Coastal plain physiographic province. The coastal plain sediments typically thicken and dip to the south and are structurally influenced by faulting and salt domes. The total sediment column thickness under the Site is about 14,000 feet. EPA delineated the site-specific geology and associated hydrogeology in order to address these areas of potential contamination. In descending order from the ground surface, the geological formations and saturated zones are described as the following:

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Surface soils or fill materials from approximately ground surface to 2 feet below ground surface; Shallow clayey-silt from approximately just below surface soils to 25 feet bgs (the first saturated zone is

located within this matrix); Intermediate clay/peat from approximately 25 to 30 feet bgs; Intermediate silt from approximately 32 to 35 feet bgs (the second saturated zone is located within this

matrix); and, Deep silty-clay from approximately 35 to 80 feet bgs (the third saturated zone, before the Upland Terrace

Aquifer, is located within this matrix). Information gathered during the RI geological and hydrogeological investigations revealed that the three saturated zones did not constitute viable aquifers because of their low hydraulic conductivity and slow recharge. Hence, the ground water at the MCW Site, composed of these three saturated zones, is not viable for domestic or industrial purposes. The groundwater in aquifers underlying southeastern Louisiana typically move from north to south. More specifically, the waters in the shallow subsurface layers described above (shallow clayey silt, intermediate silt, deep silty clay) are believed to run as follows: the water in the first shallow saturated zone layer is perched above the intermediate layer with flow directions and gradient varying from the southeast and northwest; water in the lower two saturated zones flows to the south-southwest. The eight major aquifers that underlie the site area (in descending order) are: the Shallow, Upper Ponchatoula, Lower Ponchatoula, Abita, Covington, Tchefuncte, Hammond, and Amite (USGS 1994). Of the eight major aquifers that underlie the site area, the viable aquifers, not associated with the saturated zones at the Site, for domestic and industrial water usage were identified during the RI and are listed as follows:

Shallow Aquifer, also known as the Upland Terrace Aquifer, from approximately 80 to 200 feet bgs; Upper Ponchatoula Aquifer from approximately 250 to 650 feet bgs; and, Lower Ponchatoula Aquifer from approximately 650 to 1,100 feet bgs.

On March 3, 1998, EPA released a Proposed Plan (US EPA, 1998) for a 30-day public comment period. The Proposed Plan provided a detailed summary and discussion of the risks present at the MCW Site, the remedial objectives established for the Site, and an analysis of remedial alternatives. The EPA held a Proposed Plan community meeting on March 26, 1998, to present EPA’s recommended course of action. An open house was conducted to share information with the community on activities relating to the MCW Site on March.28, 1998. Comments were received from the public and addressed in the responsiveness summary. The LDEQ submitted a letter July 13, 1998, addressing the Proposed Plan and concurring with the preferred alternative. The creosote contamination was the object of considerable public interest in Madisonville. As a result, the EPA Community Involvement Coordinator and the RPM conducted an active campaign to ensure that the residents were well-informed about the activities at the MCW Site. Community involvement activities included: public meetings and open house functions, updates to town officials, routine distribution of fact sheets and community bulletins, and a final close-out meeting and site tour when construction activities were completed. E. Basis for Taking Action Contaminants

Hazardous substances that have been released at the Site include (EPA, 1998): Soil Sediment Benzo[a]pyrene (B[a]P) Benzo[a]pyrene B[a]P equivalents B[a]P equivalents Heptachlor epoxide

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Groundwater Surface Water Benzo[a]pyrene Benzo[a]pyrene B[a]P equivalents B[a]P equivalents The principal threats at the MCW Site were the creosote polycyclic aromatic hydrocarbons (PAH), which includes Benzo[a]pyrene and B[a]P equivalents. Principal threat wastes are considered highly toxic and present a significant risk to human health or the environment should an exposure occur. The majority of the principal threats were located within the on-site soil areas (EPA 1998). Based on the data collected during the RI, it was determined that actual or threatened releases of hazardous substances from the MCW Site, if not addressed by implementing the remedy selected in the ROD, could present an imminent and substantial endangerment to public health, welfare, or the environment. The most significant threats included (1) the risk of carcinogenic and noncarcinogenic effects for a future on-site resident exposed to PAHs in the soil and ground water, (2) the risk of carcinogenic and non-carcinogenic effects for an off-site resident exposed to PAHs in the soil and ground water, and (3) the risk of carcinogenic and non-carcinogenic effects for a current or future on-site resident exposed to soils with PAHs. IV. Remedial Actions A. Remedy Selection

On August 25, 1998, the EPA Regional Administrator signed a ROD for the Site. Remedial Action Objectives (RAOs) were developed for site soil, sediment, surface water, and groundwater. The RAOs are shown below:

Soil: Prevent direct contact/ingestion with media exceeding the lifetime incremental cancer risk of 1x10-4 to

1x10-6 due to carcinogenic PAHs based on residential risk scenarios. Sediment: Prevent direct contact/ingestion with media exceeding the lifetime incremental cancer risk of 1x10-

4 to 1x10-6 due to carcinogenic PAHs based on residential risk scenarios. Surface Water: Prevent direct contact/ingestion with media exceeding the lifetime incremental cancer risk of

1x10-4 to 1x10-6 due to carcinogenic PAHs based on residential risk scenarios. Groundwater: Prevent migration of media contaminants into the Upland Terrace Aquifer which would result

in the Upland Terrace Aquifer exceeding the Maximum Contaminant Levels (highest permissible concentration of a substance allowed in drinking water) or lifetime incremental cancer risk of 1x10-4 to 1x10-6 due to carcinogenic PAHs based on residential risk scenarios.

The following benzo(a)pyrene (B[a]P) equivalents performance goals were set and must be met in order to achieve cleanup of the MCW Site:

Benzo(a)pyrene B[a]P equivalent concentrations of 3 milligrams per kilogram (mg/Kg) for all RAOs where residential risk scenarios are applicable.

B[a]P equivalent concentrations of 100 mg/Kg for all RAOs where recreational risk scenarios are applicable

The remedy selected in the ROD addressed contamination in the soil, sediment, surface water, and groundwater at the MCW Site by:

Low Temperature Thermal Desorption (LTTD) to address the principal threat wastes within the soil and sediment (thus eliminating the source of contamination for surface water);

Dense NonAqueous Phase Liquids (DNAPL) Recovery Trench System to contain and recover low level threat wastes within the groundwater;

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Institutional controls to ensure that future individuals will not be exposed to remaining low level site contaminants during its containment and recovery; and,

Ground water monitoring to ensure the effectiveness of the cleanup remedy.

The overall site cleanup strategy was to clean up the MCW Site such that the areas of concern are made safe for residential and recreational usage. The RAOs were based on human health exposure pathways. Ecological habitat was limited on-site with limited ecological exposure pathways; therefore, ecological RAOs were not needed. Ecological exposure to off-site contamination in North and South ditches and streams was addressed with the selected remedy. B. Remedy Implementation The Remedial Design (RD) was completed by EPA’s contractor, Tetra-Tech, and submitted to EPA on September 28, 1998. Tetra-Tech performed Remedial Action (RA) activities for EPA under the Response Action Contract (RAC). Construction began on January 14, 1999. RA activities included the following:

Demolition of site structures, and construction of a wastewater treatment plant (WWTP) and on-site perimeter roads,

Installation of perimeter fence, meteorological station, and electrical service for air monitoring, Excavation of north ditch, north stream, south stream, and on-site contaminated soils, Construction of thermal desorption pad, contaminated soils building, WWTP building, storm water

holding basin, sound barrier wall, and secondary sound barrier, Thermal treatment of contaminated soils, hauling and disposing of hazardous and nonhazardous debris

off-site, backfilling excavated areas on-property, restoration and final grading of Site, planting of perimeter tree buffer, and improving the site storm water drainage, and

Modification design and construction of the DNAPL transfer and treatment system and revision of the O&M manual.

During the RA, excavation depths of on-site soils ranged from 2 to 4 feet bgs. Confirmation samples were collected and analyzed for semivolatile organics and reported as B[a]P equivalents. If the confirmation samples met the project RAO of 100 mg/kg, the area was released for backfill. All soils were excavated and processed through the LTTD unit. Soils were treated to B[a]P equivalents of 3.0 mg/Kg or less. Soils that did not meet this criterion were retreated. Treated soils were backfilled on-site. Confirmatory samples were collected from the bottom of the 2-foot excavation area. In each case where B[a]P equivalents were exceeded in a confirmation sample, the excavation for that square was continued to a 2 to 4 foot depth interval. Per the RD and field sampling plan (FSP), no confirmation samples were collected for areas excavated to the 4-foot depth (Tetra-Tech 1998). In addition to removing additional contamination in the 2 to 4 foot excavation area due to elevated confirmation results, soils that were visibly stained were excavated as well. Based on (1) the results of the confirmation samples for the 0 to 2 foot excavation areas, (2) the removal of all visibly stained soils in the 2 to 4 foot excavation area, and (3) the limits of excavation identified in the RI and RD, the removal of contaminated soils from the on-property areas has been accomplished (Tetra-Tech 2001). The “Basis of Design” in the RD indicated that stream segments identified for cleanup on the (1) north ditch, (2) north stream, and (3) south stream would be excavated 1 foot deep from bank to bank (Tetra-Tech 1998). This procedure was identified in the FSP; therefore, confirmation sampling was not conducted for the off-property areas. During the excavation of these off-property areas, Tetra-Tech personnel informed EPA of visible contaminants. At the time of identification, EPA authorized field changes to excavate additional quantities in those areas. All excavated areas were backfilled with imported soil. Based on (1) the excavation of all visible contamination and (2) the limits of contaminants identified within the RI and RD, the complete removal of off-property contaminated sediment has been accomplished (Tetra-Tech 1997, 1998).

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Treated Waste Sampling – Using the procedures identified in the Field Sampling Plan (FSP) and Quality Assurance Project Plan (QAPP) (Tetra-Tech 1999a, 1999b), Tetra-Tech field personnel conducted treated waste sampling during the execution of the RA. Treatment of contaminated materials at the MCW Site included both on- and off-property materials. The treated waste sampling results that failed to meet the waste treatment standards were re-treated and subsequently re-sampled. Based on the results, the complete effective thermal treatment of on- and off-property contaminated materials have been accomplished. Upland Terrace Aquifer Sampling – During remedial activities, monitoring wells RA-1 through RA-5 were initially installed. Wells RA-1 through RA-4 were completed in the 10-25 ft bgs interval and were later plugged and abandoned. Well RA-5 was completed in the lower portion of the Upland Terrace Aquifer from an interval of 166-181 ft bgs. To more completely monitor conditions in the lower Upland Terrace Aquifer, wells MW1 and MW-2 are screened at intervals of 140-160 ft bgs and 153-173 ft bgs, respectively. Using the procedures identified in the O&M manual, Tetra-Tech field personnel conducted ground water sampling from the Upland Terrace Aquifer utilizing monitoring well RA-5 and Water Wells no. 1 and no. 2 in June 2001, and residential well sampling in May 2001. Analysis of those samples yielded no contaminants above acceptable detection levels. Based on the sample results and the fact that no contamination of the Upland Terrace Aquifer has ever been detected during previous investigations, migration of media contaminants into the Upland Terrace Aquifer was proven to have been prevented at that time. DNAPL Recovery System – The DNAPL recovery and treatment system is composed of a system of trenches for the recovery of the DNAPL and a WWTP for treatment of the recovered fluids. Ten trenches were installed with the low ends being paired on the central portion of the trench field as shown in Figure 2. A vertical riser with an extraction pump is located at the low end of each trench. The pumps are run manually as needed to remove DNAPL with a minimal volume of associated groundwater. Extracted fluids are transferred from the trenches to the WWTP via a pipeline consisting of a 3-inch, stainless steel, inner pipeline with a 6-inch PVC outer casing. A diagram of the WWTP facilities is presented in Figure 3. At the WWTP, extracted fluids are collected at the equalization tank (T-1). The equalization tank equalizes flow from the DNAPL recovery system and decontamination sump extraction pump prior to discharge to the oil-water separator (OWS). Primary separation of DNAPL and suspended solids, via gravity, from the incoming waste water stream occurs in the equalization tank. The OWS tank (T-2) is the secondary treatment unit in the WWTP. The OWS tank separates DNAPL and light nonaqueous phase liquids (LNAPL) constituents not removed from the waste water entering the equalization tank from the field extraction pumps. DNAPL collected in the DNAPL chamber of the OWS is removed from the OWS tank by the DNAPL sump pump and transferred to the DNAPL storage tank (T-3). LNAPL collected in the LNAPL chamber of the OWS flows by gravity to the LNAPL storage tank (T-5). Water separated from the nonaqueous phase liquids (NAPL) constituents in the OWS tank flows via gravity from the OWS to the OWS effluent tank (T-7, not shown in Figure 4). The OWS effluent tank is a horizontal cylindrical tank 6 feet long by 4 feet in diameter with a capacity of 550 gallons. At predetermined levels in the OWS effluent tank, stored waste water from the OWS effluent tank is pumped to the sand filters (F-1, F-2, F-3). The sand filters remove suspended solids from the waste water stream. Effluent from the sand filters is pumped to two liquid phase activated carbon (LPAC) units (C-1A and C- 1B). The LPAC units are piped to allow operation in parallel or series, allowing continuous operation of the WWTP system during media change out and alternation of the lead-lag orientation of the units. The backwash tank (T-6) is used to store treated water from the LPAC units for use in backwashing the sand filters and LPAC units. The backwash tank is a vertical cylindrical tank 8 feet tall by 6 feet in diameter with a capacity of 5,500 gallons. Backwash water is removed from the backwash tank by the backwash pump. Effluent from the backwash tank drains by gravity through flow meter F-12 to either a discharge line in the North Ditch, or

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can be connected to a temporary storage device by employing 3-inch flex hose equipped with cam-lock fittings connected to the backwash tank manifold located outside on the northwest corner of the WWTP building. EPA conducted a pre-final inspection on April 20, 2000, and a final inspection on May 31, 2000. EPA determined that the RA was completed during the final inspection, and an official construction completion ceremony was held on July 27, 2000. C. System Operations/Operation and Maintenance After the construction phase of the RA was completed, EPA maintained ground water monitoring and operation of the underground recovery trench system for approximately one year. On September 2, 2001, LDEQ took over the maintenance duties of the MCW site, and official O&M activities began at that time. The contractors for LDEQ conduct weekly inspections and subsequent maintenance of the MCW site. The three active monitoring wells at the MCW Site are screened in the lower portion of the Upland Terrace Aquifer and are located in the northwest, central, and southwest portions of the Site. The well completed at the shallowest depth is monitored once per six months and the deeper wells are monitored once per year. Around the time of the second Five-Year Review, the LDEQ re-bid the O&M contract. The company that was awarded the O&M contract by the state required safety upgrades at the Site to protect worker health and safety. While the O&M costs are higher than estimated in the ROD, in addition to the safety upgrades, the contractor has implemented DNAPL Recovery System changes to improve DNAPL capture and improve the maintenance of the electrical components of the system.

V. Progress Since the Last Five-Year Review This section reviews the protectiveness statement and issues and recommendations from the last Five-Year Review, which was the second Five-Year Review for the MCW Site. The status of the recommendations made in that report are also reviewed and discussed. The protectiveness statement from the last Five-Year Review is given as follows: “At this time, based on the information available during the second five-year review, the selected remedy appears to be performing as intended. The selected remedy currently protects human health and the environment based on results from treated waste sampling and shallow groundwater sampling. However, for the remedy to be protective in the long term, DNAPL recovery trenches, the pump vaults, pumps, and WWTP need to be maintained, ground water monitoring data need to be collected and evaluated on a routine basis to ensure contamination of the ground water and the Upland Terrace Aquifer is not occurring, security fencing around the DNAPL recovery trenches and WWTP is maintained, and access restrictions need to continue to be enforced.” The previous Five-Year Review report stated that the remedy continues to be protective of human health and the environment in the short term. Five issues, however, were identified that could have potentially affected future protectiveness. A summary of the issues from the last 5-Year Review and actions taken at the MCW Site since the previous Five-Year Review are given below:

1) Issue – The effluent discharge limits from the WWTP have been occasionally exceeded.

Action – The LDEQ contractor now ensures that effluent criteria are met before release of the effluent. Any exceedences are now discussed in the monthly report along with measures to prevent reoccurrence.

2) Issue – DNAPL may stand in the recovery trench system piping because of plugging with the potential of related migration to the lower aquifers. Action – The LDEQ contractor has instituted a program for regular cleaning of the piping. Additionally, all electrical components have been moved out of the vaults and into the pump shed. This reduced issues caused by excess water or flooding in vaults. The pumps have been changed to pneumatic pumps. The

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pump risers are elevated above the ground water level so ground water does not enter as easily. 3) Issue – The ground water analytical data show that detection limits for PAHs are higher than their

maximum contaminant levels (MCLs). Action – LDEQ and its contractor worked with analytical laboratory to ensure that the detection/analytical levels are at or below the respective MCLS for PAHs.

4) Issue – Arsenic has been detected in the WWTP effluent at concentrations above the MCL, but it is not known what the groundwater concentrations are and whether the arsenic concentration in the ground water meets the RAOs. Action – Metals have been removed from routine analysis. Metals were not used in the wood treating process. The principal threat at the Site is the risk of carcinogenic and noncarcinogenic effects for a future on-site resident exposed to PAHs in the soil and ground water. The Notice of Conveyance (discussed further in Section VII.A.) describes that the Site was closed with contaminant levels present that are acceptable for industrial/commercial use.

5) Issue – The annual sampling of wells MW-1 and MW-2, and the semiannual sampling of well RA-5 has not been consistently carried out. Ground water monitoring was resumed approximately two years after the first Five-Year Review; however, after hurricane Katrina hit the southern Louisiana area the ground water monitoring schedule was disrupted. Action – The monthly report now notes if sampling could not be carried out due to catastrophic weather events and also notes when the wastewater treatment system is down for maintenance activities.

6) Issue – Naphthalene is now considered a carcinogenic compound which may change its toxicity characteristic. Action – In addition to the random naphthalene hits identified during the second five-year review period, naphthalene was identified in one sample for well RA-5 during this five-year review period. Naphthalene hits over the past ten (10) years have been random and only one hit was identified during this five-year review period with a very low measurement, Additional discussion and potential follow-up work is presented in Section VI.D.

VI. Five-Year Review Process A. Administrative Components

This third five-year review was led by Ms. Laura Stankosky, EPA RPM for the Site. LDEQ and state contractor personnel assisted in the review process. The representative from LDEQ was Mr. John Halk, State Project Manager for the Site. The LDEQ contractor for site O&M is SEMS, Inc.; present from SEMS Inc. for the five-year review site inspection were Brian Sullivan, Project Manager, Rick Tibbs, Site Manager, and Darren McKenzie, Field Technician.

From April 2013 through September 2013, the review team established the review schedule, which included the following components:

Document review Site inspection/technology review Interviews ARARs review Data review Five-Year Review Report development and review.

B. Community Involvement

The area around the MCW Site has experienced considerable growth since the last five-year review. A housing development was built adjacent to the Site on the east side. A fact sheet announcing initiation of the third Five-Year Review was mailed to an updated mailing list that included residents at an approximately one-mile

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radius from the Site. Additionally, fact sheets were left at the Madisonville Town Hall and at the library during the site visit. A notice was published in the St. Tammany Farmer on September 18, 2013.

Upon signature, the Five-Year Review will be placed in the information repository for the MCW Site and,

a copy will also be placed at the LDEQ office in Baton Rouge, Louisiana. A notice will be published in the St. Tammany News to summarize the findings of the review and announce the availability of the report at the information repositories.

During the site inspection interviews were conducted with both the Madisonville Town Clerk and the

reference librarian at the Madisonville Branch of the St. Tammany Parish Library, discussed further in Section VI.F, below. The site repository had been located at the Madisonville Town Hall after Hurricane Katrina severely damaged the old Madisonville Branch of the St. Tammany Parish Library. In preparation for Hurricane Isaac in 2012, the Madisonville Town Hall moved town documents out into storage for records preservation. Since Hurricane Isaac and after the passing of the former Town Clerk the site repository records have not been relocated. The EPA Community Involvement Coordinator will work with the reference librarian at the Madisonville Branch of the St. Tammany Parish Library to reestablish the site repository documents.

A copy of the first public notice announcing the five-year review start and the Community Notification

fact sheet are provided as Attachment 3 to this report.

C. Document Review

The five-year review included a review of relevant decision documents, implementation documents, remedy performance documents, and legal documents. The review included, among other documents, the: (1) ROD, (2) RD, (3) RA Report, (4) PCOR, (5) monthly reports, (6) O&M Plan, (7) previous Five-Year Reviews, and (8) Institutional Controls (ICs). Documents reviewed are provided in Attachment 4.

D. Data Review Review of the Monthly Operational Reports, covering the time period from January 2009 through September 2013, provided information on volumes of extracted and treated groundwater, chemical analytical results for groundwater sampled from monitoring wells at the MCW Site and treated groundwater (effluent). The extracted quantities taken from these monthly reports were tabulated as shown in Table 1 of Attachment 2. As shown in the table, monthly extraction volumes have ranged from no extraction due to maintenance and system upgrade to 24,000 gallons. The average monthly extraction volume is approximately 10,500 gallons. Monthly recovered DNAPL volumes have ranged from no recovery to 350 gallons in April 2010. The average monthly recovered DNAPL volume is approximately 139 gallons. The Monthly Operational Reports present the results of analytical sampling performed on the effluent from the wastewater treatment system. The O&M Manual for the Site dated, August 2004, and the updated O&M Project Specifications, dated July 2010, list sampling frequency for the effluent as well as parameters for analysis. The effluent is to be sampled once a month for semi-volatile organic compounds (SVOCs) and volatile organic compounds (VOCs), and other parameters (biological oxygen demand (BOD) 5-day, chemical oxygen demand (COD), chloride, sulfate, oil & grease, total dissolved solids, total suspended solids, turbidity, pH, and dissolved oxygen). Site data from January 2009 through September 2013 were reviewed; there were three (3) monthly reports that did not contain analytical results for the effluent water. During the months with no analytical data the collection and treatment system were off-line due to mechanical and/or maintenance activities. Those months were February and December 2009, and March 2010. For the parameters listed in Table 2 of Attachment 2, exceedences of the effluent limitations were seen for BOD, COD, and turbidity. The BOD and COD exceedences appear to be low frequency and random with no apparent pattern. Turbidity has been elevated 13 months out of the five-year review period, with most

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exceedences occurring during 2009 and 2010 after periods of maintenance activities. For SVOCs and VOCs, there were limited detections over this review period: 4/2009 – chloroform; 1/2011 – methylene chloride; 2/2011 – fluoranthene; All of these detections were well below effluent limitations. The presence of methylene chloride may be an artifact of sample collection, transport, laboratory storage, or analysis. Groundwater is sampled from RA-5 once every six months and from MW-1 and MW-2 once per year. For SVOCs and VOCs, there were limited detections over this review period. All detections were in well RA-5: 7/2011 – naphthalene; 6/2012 – bis(2-Ethylhexyl) phthalate and phenol; 12/2012 – phenol. Analysis of the data showed no discernible trends. The presence of bis(2-Ethylhexyl) phthalate, a common plasticizer, may be an artifact of sample collection, transport, laboratory storage, or analysis. There was one “J-flagged” hit of naphthalene on July 11, 2011 in the Well RA-5 ground water sample. A “J-flagged” analytical result if an estimated value for the analyte that is below the adjusted reporting limit but above the instrument reporting limit. The result was 5.38 J parts per billion (ppb); the detection level was 10 ppb. The remainder of the analytical results were “no measurable” naphthalene at the 10 ppb detection level for all other twice yearly results. Well RA-5 is sampled differently than the method used for Wells 1 and 2. Wells 1 and 2 are sampled via low flow (minimal drawdown) ground water sampling; Well RA-5 is sampled from a spigot at the WWTP building. RA-5 was connected to the WWTP at the end of the RA to be a water supply to the WWTP. There is a likely possibility that the low naphthalene hit may be due to contamination introduced the sampling process. The LDEQ Project Manager will work with his Site Manager to determine if naphthalene may be getting into the RA-5 sample from operation of the pump that powers the RA-5 well spigot or introduced through other routes. All of the operational components of RA-5 are associated with or located within the WWTP. The WWTP has tanks and containers treating the water from the DNAPL Recovery System vaults and also recovered creosote/DNAPL being storage awaiting disposal. LDEQ will look into sampling protocols, status of the WWTP during sampling, and possibly taking some extra RA-5 samples to determine a cause for the random low-level naphthalene hits. E. Site Inspection An inspection was conducted at the MCW Site on September 17, 2013. The completed site inspection checklist is provided in Attachment 5. Site inspection tasks included a visual inspection of site features including the WWTP facility, fences and gates, and the monitoring wells. During the site inspection site logs, documents, and records were reviewed. Photographs taken during the site inspection are provided in Attachment 6. The site inspection indicated that the remedy was effective and operating as intended. No concerns were noted. Site fencing restricts property access. The security fencing is in good shape and access is controlled through locked gates. Also, site vegetation is regularly mowed. The registered live oak tree appeared to be in good condition, as well as most of the planted trees located around the site’s boundary. The site inspection participants were: Ms. Laura Stankosky, EPA RPM for the Site; Mr. Bill Little, EPA Community Involvement Coordinator; Mr. John Halk, LDEQ Project Manager for the Site; and from the LDEQ contractor for the Site, SEMS, Inc, Brian Sullivan, Project Manager, Rick Tibbs, Site Manager, and Darren McKenzie, Field Technician. Issues specifically identified or evaluated during the site inspection included: 1) The vault covers have been modified due to worker safety concerns. The vault covers were very heavy and required two individuals for lifting the covers. The metal covers have been cut to be made smaller and wooden slat covers have been place on either side the metal cover. The wooden slat vault covers have small gaps in between the boards that may allow small terrestrial animals; rodents, lizards, snakes, etc., to fall through and into the vault; and 2) A housing development has been constructed adjacent to the Site to the east since the last Five-Year Review. A resident requested additional vegetation removal along the property fence line so that she would not have an obstructed view and to reduce the occurrence of rats, mice, and snakes living in brush so close to her home. The work was completed in August 2013.

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F. Interviews

In accordance with the community involvement requirements of the five-year review process, key individuals to be surveyed were identified by EPA. Completed survey forms for the following individuals are included in Attachment 7:

John Halk: State Project Manager – LDEQ Rick Tibbs: State Contractor Representative, Site Manager Joyce Core: Madisonville Town Clerk Maria Reyes: St. Tammany Parish Library, Madisonville Branch, Reference Librarian Janice Sapia: homeowner

Overall, the responses received were positive. Responding interviewees indicated they were not aware of

any trespassing or vandalism and they did not know of any negative impacts on the community. Both the Madisonville Town Clerk and the St. Tammany Parish Library, Madisonville Branch, Reference Librarian were new to the area and were not very familiar with the MCW Site but felt more informed after reviewing the fact sheet.

Ms. Sapia appreciated the additional vegetation clearing that was completed by the LDEQ contractor

separating her backyard from the Site. She indicated that some of her neighbors may also want their fence lines cleared. Her concerns about soil contamination were addressed during the interview.

After mail out of the fact sheet, EPA received several email inquiries from local homeowners unfamiliar

with the MCW Site. Responses to the inquiries were coordinated with LDEQ. While many of the homeowners expressed concerns living near the Site, one homeowner conveyed appreciation at the fast and thorough response from EPA and no feedback was received from most of the homeowner inquiries. VII. Technical Assessment A. Question A: Is the remedy functioning as intended by the decision documents? RA Performance

Based on the review of documents, data, ARARs, and the findings of the site inspection, the components of the selected remedy, listed in Section IV.A., are functioning as intended by the ROD (EPA, 1998). The RAOs required by the ROD included preventing the direct contact/ingestion with soil, sediment, surface water, and ground water containing creosote PAHs that are considered highly toxic and present a significant risk to human health or the environment should an exposure occur.

The LTTD addressed the principal threats wastes at the MCW Site. Cleanup of creosote liquid source

materials located in contaminated soil and sediment prevents direct contact/ingestion and removed this principal threat to human health and the environment. Operation of the DNAPL recovery system contains and recovers creosote source materials within the shallow saturated zone to prevent any migration of contaminants into the viable aquifers and continues to reduce and/or eliminate the source contaminants.

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System Operations/O&M

The MCW Site appears to be well run and functioning as intended. The first 5-Year Review described an issue with the trench collection pipes needing to be cleaned out and flushed. LDEQ used this opportunity for optimization and now has instituted a program to regularly inspect these pipes to prevent them from clogging. Significant electrical and pump work was performed in 2009 and 2010. Implementation of Institutional Controls and Other Measures

Institutional Controls (ICs) are generally defined as non-engineered instruments such as administrative and legal tools that do not involve construction or physically changing the Site and that help minimize the potential for human exposure to contamination and/or protect the integrity of a remedy by limiting land and/or resource use. ICs can be used for many reasons including restriction of site use, modifying behavior, and providing information to individuals (EPA, 2000a). ICs may include easements, covenants, restrictions or other conditions on deeds, and/or groundwater and/or land use restriction documents. The LDEQ filed a Conveyance Notice on August 11, 2004, with the St. Tammany Parish Clerk of Court Land Records (Instrument # 1448326) to provide notice of site conditions and that the MCW Site was closed with contaminant levels in place. The notice describes that at the completion of site remediation that an estimated 379,000 gallons of creosote constituents remained in the soil sand lens under the Site. It states that a collection system has operated since the commencement of the O&M phase and is currently operating; therefore, the amount of remaining creosote is undetermined. The notice describes that the Site was closed with contaminant levels present that are acceptable for industrial/commercial use. The notice notes that in accordance with Louisiana Administrative Code 33:I., Chapter 13, if land use changes from industrial to non-industrial, the responsible party shall notify the LDEQ within 30 days and the Site shall be reevaluated to determine if conditions are appropriate for the proposed land use. A copy of the Conveyance Notice is included in Attachment 8. Monitoring Activities

Groundwater monitoring activities were evaluated in the Data Review (See Section VI.D.). The Site ground water wells are monitored for VOC and SVOC constituents. Review of the data indicates that no site contamination has migrated below the saturated zones at the Site. Ground water will continue to be monitored as a part of the O&M activities.

Early Indicators of Potential Remedy Failure

No early indications of problems were noted. B. Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action

objectives (RAOs) used at the time of remedy selection still valid?

Changes in standards and To Be Considereds

The ROD (EPA, 1998) identified applicable or relevant and appropriate requirements (ARARs) for the MCW Site.

Chemical-specific ARARs – Chemical-Specific ARARs are usually health- or risk-based numerical values or methodologies that, when applied to site-specific conditions, establish numerical values. Each value establishes the acceptable amount or concentration of a chemical that may remain in or be discharged to the ambient environment. If more than one chemical-specific requirement exists for a contaminant of concern (COC), the most stringent requirement is identified as an ARAR for the RA.

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The 1998 ROD identified one chemical-specific ARAR for ground water: EPA’s National Primary Drinking Water Standards. Maximum contaminant levels (MCL) were identified as relevant and appropriate for the viable water aquifers located deeper beneath the contaminated saturated zone at the Site. The ROD determined that the shallow clayey-silt saturated zone, which contains the DNAPL and the LNAPL, is not considered a drinking water source due to insufficient yield. As part of the RA, the Upland Terrace Aquifer (located deeper beneath the shallow clayey-silt saturated zone), which is used as drinking water, is to be sampled to ensure contaminants from the shallow clayey-silt saturated zone do not migrate to the Upland Terrace Aquifer. No changes to the pertinent MCLs have occurred since the last Five Year Review. The O&M manual requires that three monitoring wells are to be sampled: RA-5 semiannually and monitoring wells MW-1 and MW-2 annually. The samples are to be analyzed for (1) SVOCs and (2) benzene, toluene, ethyl benzene, and xylenes (BTEX). The ground water analytical data from the second Five-Year Review showed detection levels for PAHs higher than their maximum contaminant levels (MCLs). LDEQ and its contractor worked with the analytical laboratory to ensure that the detection/analytical levels are at or below the respective MCLS for PAHs. The soil cleanup levels for the MCW Site were risk-based. Soils were cleaned up to 3 mg/kg B[a]P equivalent concentrations for the 0 to 2 foot level and 100 mg/kg B[a]P equivalent concentrations for the 2 to 4 foot level as documented in the RACR. The soil cleanup goal for B[a]P equivalent concentrations is based on risk assessment information, such as the cancer slope factor for B[a]P and exposure factors. In the case of a five-year review, only contaminants for which significant changes in risk assessment information reflect increased risk are pertinent, and then only if the selected remedy is no longer protective. No changes in the cancer slope factor for B[a]P have occurred since the 1998 ROD was issued; therefore, the original cleanup levels cited in the 1998 ROD remain protective. Benzene is a compound found in creosote. The vapor intrusion potential of benzene at the Site was not evaluated during the RI. The only buildings currently at the Site are the wastewater treatment plant and an air monitoring station maintained by the state. While these buildings are only occupied during the Site Manager’s periodic visits or state maintenance at the air monitoring station, if site reuse included more continuously occupied buildings, vapor intrusion may pose a risk. As a component of the next Five-Year Review to continue to evaluate long-term protectiveness and ensure that the remedy remains protective of human health, benzene in soil should be re-evaluated to determine the potential for benzene to cause a vapor intrusion risk. Location-specific ARARs – Location-Specific ARARs are restrictions placed on the concentrations of hazardous substances or the performance of activities solely because they are in special locations. Examples of locations that might prompt a location-specific ARAR include wetlands, sensitive ecosystems or habitat, flood plains, and areas of historical significance. The 1998 MCW ROD identified two location-specific ARARs for the off-site areas: (1) the Floodplain Management Order, Executive Order No. 11988, and (2) the Protection of Wetlands Order, Executive Order No. 11990. As documented in the RA Completion Report, neither the on-property nor the off-property portions of the MCW Site lie within the 100- or 500-year floodplain. Therefore, the Floodplain Management Order was determined as not applicable as an ARAR to the MCW RA. In addition, no on-property or off-property portion of the MCW Site has been identified as a wetland. Therefore, the Protection of Wetlands Order was not applicable as an ARAR to the MCW RA. No new location-specific ARARs have been promulgated that are applicable to the Site since the 1998 MCW ROD was issued.

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Action-Specific ARARs – Action-specific ARARs are usually (1) technology- or activity-based requirements or limitations on actions taken with respect to hazardous wastes or (2) requirements to conduct certain actions to address particular site circumstances. Such requirements are triggered by the particular remedial activities selected to implement a remedy. Because there are usually several alternative actions for any remedial site, very different requirements can come into play. Action-specific requirements do not in themselves determine a remedial alternative; rather, they indicate how a selected alternative must be achieved. The action-specific ARARs from the MCW RA applicable to O&M at the MCW Site are identified and discussed below:

Hazardous Waste Requirements – The rules and regulations for a hazardous waste management system were established by the LDEQ under LAC 33:V. Generators of hazardous waste in Louisiana must comply with the rules set forth by LDEQ in LAC 33:V. Chapter 11 (40 CFR 261 and 261). As documented in the RA Completion Report, all rules and regulations listed above for hazardous waste management were followed during the disposal of contaminated soil and debris. These hazardous waste rules and regulations also apply to the disposal of the DNAPL collected as part of the ground water treatment system.

Department of Transportation Regulations – As required by the U.S. Department of Transportation (49 CFR 171), hazardous materials cannot be transported in interstate and intrastate commerce, except in accordance with the requirements of 49 CFR 171, Subpart C. Hazardous wastes or environmentally hazardous substances transported within the state must comply with the applicable packaging, labeling, marking, and placarding requirements of 49 CFR 171, Subpart C and/or Louisiana Hazardous Material Regulations Subchapter C and the Department of Public Safety under LAC 33:V, Subpart 2, Chapter 101. As documented in the RACR, all waste transportation activities at the MCW Site were performed in accordance with the requirements listed above. These transportation requirements will also be applicable to the destruction of the accumulated DNAPL.

Water Quality Requirements – The Clean Water Act (33 U.S.C. 1251 to 1376), as amended by the Water Quality of Act of 1987 (Public Law 100-4-103), provides authority for each state to adopt water quality standards designed to protect beneficial uses of each water body and requires states to designate uses for each water body. All discharges from the MCW Site are required to meet storm water and wastewater discharge limitations and monitoring requirements established by the LDEQ. Even though the creosote wastes left in place were considered listed wastes, the ROD specified that that the treated wastewater would only need to comply with State of Louisiana effluent discharge criteria. As documented in the RA Completion Report, the storm water generated during the soil excavation activities was handled in accordance with LDEQ requirements. Storm water from clean, open excavations and non-excavated areas was discharged off-site through silt fencing material with no monitoring conducted. Storm water collected in open excavation areas that may have been contaminated was pumped into the storm water holding basin. The water was sampled and discharged in accordance with LDEQ requirements Treated effluent from the on-site ground water treatment system is discharged to a ditch. LDEQ established discharge limitation requirements and monitoring requirements for the effluent discharge. Overall, the treated effluent has met most discharge limitations. The LDEQ discharge limits have not changed since the last Five Year Review. All discharge limitation exceedences as documented in the monthly operating reports for 2009 through October 2013 are discussed in Section VI.D. with BOD5-day, COD, chloride, sulfate, oil & grease, total dissolved solids, total suspended solids, turbidity, pH, and dissolved oxygen results also listed in Table 3.

Overall, the DNAPL recovery system appears to be meeting most effluent discharge limitations. Recommended changes were described in the second Five-Year Review for the monthly operating reports. The monthly reports have been expanded in accordance with the reporting requirements detailed in the O&M manual. The monthly operating report has been expanded to address reported exceedences, to evaluate overall operation of the system and provide recommendations for corrective actions, if necessary; and address the validity and/or data qualifiers for laboratory data.

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Changes in Exposure Pathways, Toxicity, and Other Contaminant Characteristics There have been no changes in toxicity characteristics or other contaminant characteristics for the MCW Site that would impact the protectiveness of the remedy with the possible exception of naphthalene. Naphthalene is now considered a carcinogenic compound; however, naphthalene does not have a quantitative estimate of carcinogenic risk from oral or inhalation exposure. There has been no change to the standardized risk assessment methodology or land use that could affect the current protectiveness of the remedy. The exposure pathways evaluated in the ROD included trespassers, current and future residents, and recreational users. The ICs prevent the occurrence of the residential use scenario; the residential exposure pathway is no longer a reasonably anticipated future land use. An evaluation of possible vapor intrusion has been considered for this MCW Site. Vapor intrusion is the exposure pathway where volatile organic vapors are emitted from the soil into an enclosed area like a residence. This exposure pathway is not considered a risk at the Site at this time due to the lack of volatile organics detected in the groundwater and the distance from the Site of the nearest residences. The only buildings currently at the Site are the wastewater treatment plant and an air monitoring station maintained by the state. While these buildings are only occupied during the Site Manager’s periodic visits or state maintenance at the air monitoring station, if site reuse included more continuously occupied buildings, vapor intrusion may pose a risk. As a component of the next Five-Year Review to continue to evaluate long-term protectiveness and ensure that the remedy remains protective of human health, benzene in soil should be re-evaluated to determine the potential for benzene to cause a vapor intrusion risk. C. Question C: Has any other information come to light that could call into question the

protectiveness of the remedy?

The Madisonville area has been impacted by hurricanes in the past; impact to the geographical area continues to be a risk. There was minimal impact on the MCW Site from Hurricane Isaac in 2012. No new or previously unidentified risks were identified during the site inspection. No other information has come to light as part of this Third Five-Year Review for the Site that would call into question the protectiveness of the site remedy. D. Technical Assessment Summary According to the data reviewed, the site inspection, and the interviews, the remedy is functioning as intended by the ROD. There have been no changes in the physical conditions of the Site that would affect the protectiveness of the remedy. However, as a component of the next Five-Year Review to continue to evaluate long-term protectiveness and ensure that the remedy remains protective of human health, benzene in soil should be re-evaluated to determine the potential for benzene to cause a vapor intrusion risk. There is no other information that calls into question the protectiveness of the remedy.

22

VIII. Issues Table 7 summarizes the issues for the MCW Site. Table 7 - Issues

Issue

Currently Affects

Protectiveness (Yes/No)

Affects Future Protectiveness

(Yes/No)

Vapor Intrusion Potential – Benzene is a compound found in creosote. The vapor intrusion potential of benzene at the Site was not evaluated during the RI.

No Yes

IX. Recommendations and Follow-up Actions Table 8 summarizes the recommendations and follow-up actions for the MCW Site.

Table 8 - Recommendations and Follow-Up Actions

Issue Recommendations/ Follow-up Actions

Party Responsible

OversightAgency

Milestone Date

Affects Protectiveness?

(Yes/No) Current Future

Vapor Intrusion Potential

The only buildings currently at the Site are the wastewater treatment plant and an air monitoring station maintained by the state. While these buildings are only occupied during the Site Managers periodic visits or state maintenance at the air monitoring station, if Site reuse included more continuously occupied buildings, vapor intrusion may pose a risk. As a component of the next Five-Year Review to continue to evaluate long-term protectiveness and ensure that the remedy remains protective of human health, benzene in soil should be re-evaluated to determine the potential for benzene to cause a vapor intrusion risk.

LDEQ/EPA EPA 2019 No Yes

23

X. Protectiveness Statement The remedy at the Madisonville Creosote Works Superfund Site currently protects human health and the environment. Long-term protectiveness of the remedial action will be assured by continuing to perform O&M in accordance with the O&M Plan, that the DNAPL recovery trenches and the WWTP are maintained, ground water monitoring data are evaluated to determine if the protection of ground water and the Upland Terrace Aquifer is occurring, security fencing around the DNAPL recovery trenches and WWTP is maintained, and institutional controls in the form of a deed notice continue to be enforced. However, as a component of the next Five-Year Review to continue to evaluate long-term protectiveness and ensure that the remedy remains protective of human health, benzene in soil should be re-evaluated to determine the potential for benzene to cause a vapor intrusion risk. XI. Next Review

The Madisonville Creosote Works Superfund Site requires ongoing five-year reviews. The next, or fourth, five-year review shall be conducted no later than five years from the date of the Superfund Division Director’s signature of this Third Five-Year Review Report.

ATTACHMENTS

ATTACHMENT 1

Site Location Map and Site Layout Map

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Figure 1 Madisonville Creosote Works Site and Surrounding Area Aerial Photograph

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ATTACHMENT 2

Tables Summarizing Monthly Operational Report Data

NOTES:

NA1‐ No value, due to maintenance activities.

NA2 ‐ No value, due to storage capasity. Waiting for date to dispose DNAPL.

Month

Ending

Date

Extracted

Ground

Water

Treated and

Discharge

(gallons)

Recovered

DNAPL

(gallons)

10,227.85 25.005/31/2009

6/30/2009 125.00

1/31/2009 10,100.00 10,220.51

100.00

NA2

2/28/2009

3/31/2009

NA1 NA1

11,401.669,892.00

4/30/2009

200.00

NA1

7/31/2009 13,000.00

NA2

9,900.00

3,400.00

7,936.428/31/2009

10,548.46

8,000.00

3,845.53

658.33

150.00

25,535.36

137.50

200.00

187.50

150.00

200.00

100.00

14,537.23

23,374.10

11,114.95

38,871.37

10,881.02

13,883.93

175.00

300.00

9/30/2009

2/28/2010

3/31/2010

7,800.00

11,500.00

10,000.00

6,600.00

11,500.00

24,000.00

11/30/2009

12/31/2009

1/31/2010

16,500.00

10/31/2009

6/30/2010 4,200.00 4,032.64 250.00

7/31/2010 7,000.00 4,230.31 100.00

4/30/2010 9,000.00 11,000.26 350.00

5/31/2010 4,000.00 3,872.66 100.00

10/31/2010 10,600.00 13,826.71 150.00

11/30/2010 10,300.00 10,487.60 200.00

8/31/2010 10,000.00 26,175.22 150.00

9/30/2010 10,000.00 20,410.32 100.00

2/28/2011 8,700.00 8,494.37 200.00

3/31/2011 8,800.00 10,424.99 125.00

12/31/2010 7,200.00 7,171.50 150.00

1/31/2011 10,000.00 10,533.24 225.00

4/30/2011 9,700.00 11,247.16 150.00

5/31/2011 11,500.00 10,837.38 200.00

Month

Ending

Date

Extracted

Ground

Water

Treated and

Discharge

(gallons)

Recovered

DNAPL

(gallons)6/30/2011

8/31/2011

10/31/2011

12/31/2011

2/28/2012

4/30/2012

6/30/2012

8/31/2012

10/31/2012

12/31/2012

11,200.00 11,662.81 150.00

100.0012,582.9512,800.009/30/2011

11,000.00 11,116.46 150.00

7/31/2011 11,200.00 11,383.12 125.00

11,200.00 13,069.90 200.00

1/31/2012 11,000.00 11,084.70 250.00

12,000.00 12,009.08 75.00

11/30/2011 10,700.00 10,919.88 125.00

12,100.00 12,995.34 100.00

5/31/2012 14,200.00 13,961.18 100.00

9,500.00 10,010.56 300.00

3/31/2012 3,000.00 3,293.67 75.00

6,500.00 6,560.07 75.00

9/30/2012 14,000.00 14,645.53 150.00

4,000.00 4,996.11 25.00

7/31/2012 14,500.00 14,411.49 100.00

8,300.00 7,652.03 75.00

1/31/2013 4,000.00 4,616.91 25.00

11,500.00 11,579.61 100.00

11/30/2012 6,500.00 6,947.32 75.00

100.00

5/31/2013 13,000.00 13,249.10 100.00

2/28/2013 16,600.00 15,982.22 50.00

3/31/2013 18,000.00 18,700.83 100.00

Table 1 ‐ WWTP Volumes

8/31/2013 15,500.00 15,769.14 162.50

9/30/2013 18,000.00 15,542.24 125.00

6/30/2013 13,000.00 13,104.69 100.00

7/31/2013 16,500.00 17,287.90 62.50

4/30/2013 11,000.00 11,044.98

Sample ID EDW‐65 EDW‐66 EDW‐66 EDW‐67 EDW‐68 EDW‐69 EDW‐70 EDW‐71 EDW‐72 EDW‐73 EDW‐74 EDW‐75

Parameter (mg/L) Effluent Limit 1/13/2009 2/9/2009 3/4/2009 4/8/2009 5/5/2009 6/17/2009 7/21/2009 8/4/2009 9/15/2009 10/13/2009 11/11/2009 12/31/2009

BOD, 5 day 20 <6.00 NA1 <6.00 <6.00 18.7 12.9 19.5 11.7 8.09 22.5 18.5 NA1

COD 70 <5.00 NA1 <5.00 <5.00 13 29 54 36 56 30 72 NA1

Chloride ‐ 5.46 NA1 129 9.85 27.7 26.9 32.5 39 41.5 34.9 38.7 NA1

Oil & Grease 15 <5.56 NA1 8.67 9.7 5.1 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 NA1

Sulfate ‐ 12.1 NA1 7.27 12.1 <1.00 <1.00 <1.00 <1.00 <1.00 <1.00 <1.00 NA1

TDS ‐ 200 NA1 990 240 600 125 588 638 718 522 505 NA1

TOC 35 1.75 NA1 1.82 3.51 3.93 10 14.5 14 17.1 15.3 11.4 NA1

TSS 45 <4.00 NA1 <4.00 <4.00 20 <4.00 21 23.5 29.5 12.5 15 NA1

Turbidity(NTU) 50 0.54 NA1 23.5 0.068 118 2.75 124 24.1 91 27 24.2 NA1

pH 6.0‐8.5 7.5 NA1 7.54 7.62 7.42 7.02 6.52 6.5 6.24 6.29 6.21 NA1

D.O >5 5 NA1 5.1 5.2 5 5.2 5.2 5 5 5.3 5 NA1

Sample ID EDW‐75 EDW‐76 EDW‐77 EDW EDW‐78 EDW‐79 EDW‐80 EDW‐81 EDW‐82 EDW‐83 EDW‐84 EDW‐85


BOD, 5 day 20 6.6 <12.0 <12.0 NA1 <12.0 <12.0 <12.0 <12.0 <12.0 7.49 19.9 <6.00

COD 70 50 13 <5 00 NA1 16 15 18 17 12 32 43 <5 00

EDW ‐ 2009

EDW ‐ 2010

Table 2 EDW Analytical Data

COD 70 50 13 <5.00 NA1 16 15 18 17 12 32 43 <5.00

Chloride ‐ 24 31.4 30.7 NA1 35.5 19.6 18.6 22.4 20.1 35.6 58.6 10.7

Oil & Grease 15 <5.00 <5.00 <5.00 NA1 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 5.45

Sulfate ‐ <1.00 <1.00 <1.00 NA1 <1.00 <1.00 <1.00 <1.00 <1.00 <1.00 <1.00 <1.00

TDS ‐ 515 518 562 NA1 515 425 308 480 432 572 572 180

TOC 35 3.98 4.81 4.11 NA1 5.31 8.2 4.71 4.11 4.42 7.38 12.8 3.44

TSS 45 13 10 13 NA1 22.5 24.5 24 <4.00 15 10.5 8.5 6

Turbidity(NTU) 50 45 45.3 82 NA1 19.6 21.4 69 66.5 53 82 9.72 8.95

pH 6.0‐8.5 6.5 6.52 6.45 NA1 6.39 6.23 6.18 6.8 6.18 6.68 NA1 6.22

D.O >5 5.2 5 5.1 NA1 5.1 5.1 5.1 5.1 5.1 5.1 5.1 5



BOD, 5 day 20 44.4 <6.00 12.9 <6.00 7.69 <6.00 <6.00 <6.00 <6.00 8.65 32.8 22.5

COD 70 5 15 11 32 17 12.2 8.25 <5.00 9.23 5.29 42.7 33.9

Chloride ‐ 5.18 47 27.6 27.9 20.3 6.55 5.95 5.47 5.81 7.94 30 41.8

Oil & Grease 15 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00

Sulfate ‐ 2.69 3.19 <1.00 6.17 <1.00 <1.00 1.52 1.86 <1.00 <1.00 <1.00 <1.00

TDS ‐ 95 392 290 445 458 285 250 182 152 255 652 628

TOC 35 1.57 10.1 4.67 1.4 13.6 4.05 2.29 2.38 3.16 1.59 17.8 18.3

TSS 45 <4.00 14.5 16.5 9.5 11.5 6 <4.00 <4.00 <4.00 <4.00 7.5 13.5

Turbidity(NTU) 50 1.34 38.5 20.8 10 13.8 11.4 4.59 3.05 5.04 9.65 46 54

pH 6.0‐8.5 6.63 6.51 6.48 6.33 6.56 6.69 6.59 6.64 6.72 6.3 6.59 6.47

D.O >5 4.9 5 5.2 5 5.2 5.1 5 5.2 5 5.2 5.1 5.1



BOD, 5 day 20 <6.00 <6.00 <6.00 7.32 19.7 <6.00 <6.00 <6.00 <6.00 <6.00 17 10.2

COD 70 <5.00 11.9 13.9 45.4 85.8 28.7 13.9 10.9 19.8 <5.00 31.9 26.7

Chloride ‐ 6.22 5.39 5.24 31.5 38 5.71 8.37 73 14.2 10.5 27.2 30.3

Oil & Grease 15 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00

Sulfate ‐ 12.5 2.53 3.54 <1.00 <1.00 2.81 2.32 <1.00 <1.00 <1.00 <1.00 <1.00

EDW ‐ 2011

EDW ‐ 2012

TDS ‐ 212 102 165 495 600 135 135 385 302 372 602 532

TOC 35 2.06 <1.00 <1.00 7.67 10.3 <1.00 <1.00 2.12 <1.00 <1.00 10.4 7.24

TSS 45 <4.00 <4.00 <4.00 22 12 <4.00 <4.00 <4.00 <4.00 4.5 33 28

Turbidity(NTU) 50 0.26 4.88 5.36 31.1 28.4 0.85 8.34 0.39 4.22 1.98 205 98.5

pH 6.0‐8.5 9.14 6.53 6.94 6.57 6.37 6.9 6.64 8.72 6.93 6.82 6.93 6.52

D.O >5 5 5 5.1 5.1 5.2 5.1 5.1 5.2 5.1 5.2 5.1 5

Sample ID EDW‐110 EDW‐111 EDW‐112 EDW‐113 EDW‐114 EDW‐115 EDW‐116 EDW‐117 EDW‐118

Parameter (mg/L) Effluent Limit 1/9/2013 2/20/2013 3/20/2013 4/24/2013 5/22/2013 6/12/2013 7/24/2013 8/21/2013 9/25/2013

BOD, 5 day 20 <6.00 <6.00 8.34 17 <6.00 18.4 <6.00 10 <6.00

COD 70 27.7 8.97 <5.0 51.3 15.9 84.8 <5.0 49.4 <5.0

Chloride ‐ 17.4 12.1 28.3 38.7 8.8 29.8 4.9 38.8 18.1

Oil & Grease 15 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00

Sulfate ‐ 5.19 4.04 <1.00 <1.00 12.6 <1.00 4.5 <1.00 2.52

TDS ‐ 245 340 612 495 222 555 120 628 380

TOC 35 2.77 2.04 5.29 8.02 1.44 10.7 <1.00 6.86 2.24

TSS 45 6 4.5 12.5 23 <4.00 33.5 <4.00 21 9.5

Turbidity(NTU) 50 15.8 19.1 47.4 49.6 1.3 144 3 80 49.8

pH 6.0‐8.5 6.98 6.83 6.77 6.95 8.45 6.7 6.59 6.6 6.51

D.O >5 5.10 5.00 5.20 5.00 5.20 5.00 5.10 5.20 5.00

NOTES:

NA1‐ No value, due tNA1‐ No value, due to maintenance activities.

NA2 ‐ No value, due NA2 ‐ No value, due to storage capasity. Waiting for date to dispose DNAPL.

EDW ‐ 2013

ATTACHMENT 3

Announcement of the Third Five-Year Review and Community Notification fact sheet

MADISONVILLE CREOSOTE WORKS SUPERFUND SITE PUBLIC NOTICE

U.S. EPA Region 6 Begins Five-Year Review of Site Remedy

September 2013

The U.S. Environmental Protection Agency Region 6 (EPA) has begun a five-year review of the

remedy implementation and performance for the Madisonville Creosote Works Superfund Site in

St. Tammany Parish, Louisiana. The five-year review will determine if the remedy for the site re-

mains protective of human health and the environment. Questions or concerns about the Superfund

Site and the remedy performance should be directed to Laura Stankosky/Remedial Project Manager

at 214.665.7525 (direct) or 1.800.533.3508 (toll-free). Upon completion, the five-year review re-

port will be made available to the public at the local information repository located at the Madi-

sonville Town Hall, 403 St. Francis Street, Madisonville, LA 70447-9779, phone: 985.845.7311;

and on the Internet at http://www.epa.gov/region6/6sf/6sf-5_year_reviews.htm. Additional infor-

mation about the Site is available on the Internet at http://www.epa.gov/region6/6sf/6sf-la.htm.

1

Checking up on Superfund sites: The five-year review After a Superfund National Priorities List (NPL)

site cleanup action is completed, the U.S. Environ-

mental Protection Agency (EPA) conducts regular

inspections, called five-year reviews, at selected

Superfund sites. The EPA has begun a five-year re-

view for the Madisonville Creosote Works Super-

fund Site (Site), St. Tammany Parish, Louisiana.

The Site consists of a defunct creosote wood treat-

ing facility and covers about 29 acres adjacent to the

southern side of Louisiana State Highway 22, about

3 miles west of downtown Madisonville and 1.25

miles from the Madisonville city limits. The cleanup

was completed in May 2000. Cleanup consisted of

Low Temperature Thermal Desorption (LTTD) to

address the creosote contamination within the soil

and stream sediment and to eliminate the source of

contamination for surface water. A recovery trench

system continues to be used to contain and recover

dense non-aqueous phase liquids within the ground

water. Institutional controls are in place to ensure

that future individuals will not be exposed to re-

maining low level Site contaminants. Ground water

monitoring is conducted to ensure the effectiveness

of the cleanup remedy. The site is currently in op-

eration & maintenance status. The Louisiana De-

partment of Environmental Quality (LDEQ)

operates the recovery trench system and performs

routine monitoring.

Since wastes remain onsite at the Site above levels

that allow for unrestricted use, EPA will perform

site reviews at a minimum of every five years to de-

termine if the cleanup at the site is still protecting

public health and the environment.

During the review, EPA studies information on the

site, including the cleanup and the laws that apply,

inspects the Site, and may interview people in the

nearby area. The EPA will consider any infor-

mation or concerns that people may have about the

Site during the review. If you are familiar with the

site, you may know things that can help the review

team. Here are some examples:

Broken fences, unusual odors, illegal

dumping, or other problems;

Buildings or land being used in new ways

around the Site;

Any unusual activities at the site such as van-

dalism or trespassing; and

How the cleanup at the site has helped the area.

This fact sheet will tell you more about five-year

reviews.

The five-year review: protecting you and the environment

The EPA's Remedial Project Manager (RPM) is

working with State and Federal scientists and en-

gineers to evaluate the site. The five-year review

began on September 17, 2013. The RPM will col-

lect information about the Site from a variety of

sources including historic information. The Site

will be inspected to see if the cleanup continues to

function properly and if it is well maintained. The

RPM will talk with local officials to see if they

have any concerns or if there have been any

changes in local policy or zoning that might affect

the original cleanup. People who live near the Site,

own businesses nearby, or work at the Site may al-

so be contacted to see if they have any information

or concerns about the Site. These people may be

contacted with a mailed survey, a phone call, or an

interview. The RPM plans to conduct interviews

with the local officials and members of the com-

EPA Begins Five-year Review of Site Remedy Madisonville Creosote Works St. Tammany Parish, Louisiana September 2013

The five-year review is: A regular inspection of a Superfund site;

Conducted at sites that need continued moni-

toring;

A way to determine if a cleanup is protecting

public health and the environment; and

A chance for you to tell EPA about site activi-

ties.

2

munity during September 2013. The RPM will

use the information collected to decide whether or

not the cleanup continues to be protective of hu-

man health and the environment.

A report will be made available to the public once

the five- year review is complete. The report will

include historical information on the site and

cleanup activities, site inspection results, data re-

view and analysis, conclusions and recommenda-

tions. A copy of the report will be made available

at Madisonville City Hall, St. Frances Street. You

will be notified when the report is finished.

What happens after the review?

The EPA will insure that if any problems are identi-

fied by the review, they will be addressed. Since

wastes or contaminants that prevent unlimited use

and unrestricted exposure remain onsite, EPA will

return every five years for another review. The EPA

and the State will also keep an eye on the site be-

tween reviews. If at any time you have concerns or

questions about the site, let EPA know. You can

contact EPA through the RPM, at 1.800.533.3508

(Toll-Free Number).

For more information, please contact...

Laura Stankosky, Remedial Project Manager

U.S. EPA Region 6

214.665.7525 or 1.800.533.3508 (toll-free)

[email protected]

Bill Little, Community Involvement

Coordinator/SEE

U.S. EPA Region 6

214.665.8131 or 1.800.533.3508 (toll-free)

[email protected]

For news media inquires, contact EPA Region 6

Press Office at 214.665.2208.

John Halk

Louisiana Department of Environmental Quality

Environmental Technology Division

P.O. Box 4314

Baton Rouge, LA 70821-4314

225.219.3200 ext. 3652

[email protected]

Information Repositories

Madisonville Town Hall

403 St. Francis Street

Madisonville, LA 70447-9779

985.845.7311

U.S. EPA on the Internet

U.S. EPA Headquarters http://www.epa.gov

U.S. EPA Region 6 http://www.epa.gov/region6

U.S. EPA Region 6 Superfund

http://www.epa.gov/earth1r6/6sf/6sf.htm

mailto:[email protected]



mailto:%[email protected]

mailto:%[email protected]

http://www.epa.gov/

http://www.epa.gov/region6

http://www.epa.gov/region6/superfund



ATTACHMENT 4

List of Documents Reviewed

Ecology and Environment, Inc. (E&E). 1997. “Remedial Investigation Report, Madisonville Creosote Works, Madisonville, St. Tammany Parish, Louisiana.” September. Louisiana Department of Environmental Quality (LDEQ). 1987. “RCRA Facility Assessment for Madisonville Wood Preserving Company, Madisonville, LA.” Southern Environmental Management & Specialists (SEMS) Monthly Operational Reports, Madisonville Creosote Works Superfund Site, Agency Interest No. 1344, January 1, 2009 through September 2013. Tetra-Tech EM Inc. (Tetra-Tech). 1997. “Madisonville Creosote Works Superfund Site, Final Feasibility Study Report.” November 18. Tetra-Tech. 1998. “Final Design, Madisonville Creosote Works Superfund Site, Madisonville, St. Tammany Parish, Louisiana.” September 28. Tetra-Tech. 1999a. “Field Sampling Plan for Remedial Action, Madisonville Creosote Works, Madisonville, St. Tammany Parish, Louisiana.” March 9. Tetra-Tech. 1999b. “Quality Assurance Project Plan for Remedial Action, Madisonville Creosote Works, Madisonville, St. Tammany Parish, Louisiana.” March 12. Tetra-Tech. 2000. “Interim Remedial Action Completion Report for the Madisonville Creosote Works, Madisonville, St. Tammany Parish, Louisiana.” June 12. Tetra-Tech. 2001. “Remedial Action Completion Report for the Madisonville Creosote Works, Madisonville, St. Tammany Parish, Louisiana.” September 28. Tetra-Tech. 2004. “First Five-Year Review for the Madisonville Creosote Works Superfund Site, Madisonville, St. Tammany Parish, Louisiana.” March 1, 2004. U.S. Environmental Protection Agency (EPA). 1998. “Superfund Record of Decision: Madisonville Creosote Works, EPA ID: LAD981522998, OU 01, Madisonville, LA.” EPA/ROD/R06-98/163. August 25. U.S. Environmental Protection Agency (EPA). 2001. “Comprehensive Five-Year Review Guidance”. June 2001. U.S. Environmental Protection Agency (EPA). 2009. Second Five-Year Review for the Madisonville Creosote Works Superfund Site, Madisonville, St. Tammany Parish, Louisiana.” February 26, 2009. U.S. Geological Survey (USGS). 1994. “Ground-Water Resources of Southern Tangipahoa Parish and Adjacent Areas, Louisiana.” Water Resources Investigations Report No. 92-4182.

ATTACHMENT 5

Site Inspection Checklist

Page 1 of 11

Site Inspection Checklist

I. SITE INFORMATION

Site name: Madisonville Creosote Works Superfund Site

Date of inspection: 9-17-2013

Location and Region: St. Tammany Parish, LA EPA ID: LAD981522998

Agency, office, or company leading the five-year review:

EPA, Region 6

Weather/temperature:

87º F and sunny

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 Rick Tibbs Site Manager 9-17-2013 Name Title Date

Interviewed: by email at office by phone Phone no. (98)5-502-7342

Problems, suggestions: Report attached

2. O&M Staff Name Title Date

Interviewed: by mail at office by phone Phone no


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, etc.). Fill in all that apply. Agency Louisiana Department of Environmental Quality

Contact John Halk Project Manager 9-17 -2013 Name Title Date

Interviewed: by email at office by phone Phone no. 225-219-3652


III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

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__________________________________________________________________________ ____________________________________________________________________

Page 2 of 11

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__________________________________________________________________________ _________________________________________________________________________________

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 Remarks__________________________________________________________________________ _________________________________________________________________________________

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

Page 3 of 11

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 Other: _the site requires no O&M_____N/A_____________________________________________

_________________________________________________________________________________

2. O&M Cost Records Readily available Up to date Funding mechanism/agreement in place Original O&M cost estimate____________________ Breakdown attached

Total annual cost by year for review period if available

From_ January 2009_____ To_ December 2009____ _$220,800____

Date Date Total cost From_ January 2010_____ To_ December 2010____ _$220,800____




Date Date Total cost

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: __fencing is not required; the property owner has the site fenced to prevent illegal dumping on the property_______________________________________________________________________

B. Other Access Restrictions

1. Signs and other security measures Location shown on site map N/A Remarks__ Property surrounded by chain link fence. Fencing with barbed wire is partially surrounding the wastewater treatment plant ____________________________________________

Page 4 of 11

C. Institutional Controls (ICs)

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) _Monitored during site maintenance visits._______ Frequency _Tens days/month (minimum)________________________________________________ Responsible party/agency ___LDEQ____________________________________________________ Contact _John Halk_______ _Project Manager_______ _9/17/13 _225-219-3652_________ 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__A housing development was built adjacent to the site, along the east side of the site._A homeowner in the development was interviewed as part of the five-year review process.___________ _________________________________________________________________________________

VI. GENERAL SITE CONDITIONS

A. Roads Applicable N/A

1. Roads damaged Location shown on site map Roads adequate N/A Remarks__ Dirt roads around the perimeter of the site are in good condition. Walked and verified.___ _________________________________________________________________________________

Page 5 of 11

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 Areal extent______________ Depth____________ Remarks____________________________________________________________ __________________________________________________________________

2. Cracks Location shown on site map Cracking not evident Lengths____________ Widths___________ Depths__________ Remarks____________________________________________________________ __________________________________________________________________

3. Erosion Location shown on site map Erosion not evident Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________

4. Holes Location shown on site map Holes not evident Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________

5. Vegetative Cover Grass Cover properly established No signs of stress Trees/Shrubs (indicate size and locations on a diagram) Remarks__________________________________________________________________________ _________________________________________________________________________________

6. Alternative Cover (armored rock, concrete, etc.) N/A Remarks__________________________________________________________________________ _________________________________________________________________________________

7. Bulges Location shown on site map Bulges not evident Areal extent______________ Height____________ Remarks__________________________________________________________________________ _________________________________________________________________________________

8. Wet Areas/Water Damage Wet areas/water damage not evident Wet areas Location shown on site map Areal extent______________ Ponding Location shown on site map Areal extent______________ Seeps Location shown on site map Areal extent______________ Soft subgrade Location shown on site map Areal extent______________ Remarks__________________________________________________________________________ _________________________________________________________________________________

9. Slope Instability Slides Location shown on site map No evidence of slope instability Areal extent______________ Remarks__________________________________________________________________________ _________________________________________________________________________________

Page 6 of 11

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__________________________________________________________________________ _________________________________________________________________________________

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 Location shown on site map No evidence of settlement Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________

2. Material Degradation Location shown on site map No evidence of degradation Material type_______________ Areal extent_____________ Remarks__________________________________________________________________________ _________________________________________________________________________________

3. Erosion Location shown on site map No evidence of erosion Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________

4. Undercutting Location shown on site map No evidence of undercutting Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________

5. Obstructions Type_____________________ No obstructions Location shown on site map Areal 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 Areal extent______________ Remarks__________________________________________________________________________ _________________________________________________________________________________

D. Cover Penetrations Applicable N/A

Page 7 of 11

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 Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs Maintenance N/A Remarks__________________________________________________________________________ _________________________________________________________________________________

3. Monitoring Wells (within surface area of landfill) Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs Maintenance N/A Remarks___________________________________________________________ _________________________________________________________________

4. Leachate Extraction Wells Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs Maintenance N/A 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 Good condition Needs Maintenance 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

Page 8 of 11

1. Siltation Areal extent______________ Depth____________ N/A Siltation not evident Remarks__________________________________________________________________________ _________________________________________________________________________________

2. Erosion Areal extent______________ Depth____________ Erosion not evident Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Outlet Works Functioning N/A Remarks__________________________________________________________________________

_________________________________________________________________________________

4. Dam Functioning N/A Remarks__________________________________________________________________________

_________________________________________________________________________________

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 Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________

2. Vegetative Growth Location shown on site map N/A Vegetation does not impede flow Areal extent______________ Type____________ Remarks__________________________________________________________________________ _________________________________________________________________________________

3. Erosion Location shown on site map Erosion not evident Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________

4. Discharge Structure Functioning N/A Remarks__________________________________________________________________________ _________________________________________________________________________________

VIII. VERTICAL BARRIER WALLS Applicable N/A

1. Settlement Location shown on site map Settlement not evident Areal extent______________ Depth____________ Remarks__________________________________________________________________________ _________________________________________________________________________________

Page 9 of 11

2. Performance Monitoring Type of monitoring__________________________ Performance not monitored Frequency_______________________________ Evidence of breaching Head differential__________________________ Remarks__________________________________________________________________________ _________________________________________________________________________________

IX. GROUNDWATER/SURFACE WATER REMEDIES Applicable 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_All electrical components have been moved out of the vaults and into the pump shed. This reduced issues caused by excess water or flooding in vaults. The pumps have been changed to pneumatic pumps. The pump risers are elevated above the ground water level so ground water does not enter as easily.______________________________________________________________________

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

Good condition Needs Maintenance 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


_________________________________________________________________________________

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


_________________________________________________________________________________

3. Spare Parts and Equipment

Readily available Good condition Requires upgrade Needs to be provided Remarks__________________________________________________________________________

_________________________________________________________________________________

C. Treatment System Applicable N/A

Page 10 of 11

1. Treatment Train (Check components that apply) Metals removal Oil/water separation Bioremediation Air stripping Carbon adsorbers

Filters___sand and carbon _______________________________________________________ Additive (e.g., chelation agent, flocculent)_____________________________________________ Others____ Equalization tank, creosote holding tank___________________________________ Good condition Needs Maintenance 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___Carbon has been changed twice since the last Five-Year Review____________________ _________________________________________________________________________________

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_ The middle well vaults produce more creosote; these vaults are checked more frequently, generally weekly. The vault covers have been modified due to worker safety concerns. The vault covers were very heavy and required two individuals for lifting the covers. The metal covers have been cut to be made smaller and wooden slat covers have been place on either side the metal cover._____________

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__Small creosote spill noted. Sorbent was noted on top of spill for its removal.___________ _________________________________________________________________________________

6. Monitoring Wells (pump and treatment remedy) Properly secured/locked Functioning Routinely sampled Good condition All required wells located Needs Maintenance N/A Remarks__________________________________________________________________________ _________________________________________________________________________________

D. Monitoring Data Applicable N/A

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 Applicable N/A

1. Monitoring Wells (natural attenuation remedy) Properly secured/locked Functioning Routinely sampled Good condition All required wells located Needs Maintenance N/A Remarks__________________________________________________________________________ _________________________________________________________________________________

Page 11 of 11

X. OTHER REMEDIES

If there are remedies applied at the site which are 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 to accomplish (i.e., to contain contaminant plume, minimize infiltration and gas emission, etc.). _The goal of the remedy is to collect DNAPL and treat ground water collected from the field. ______ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________

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 appears to be adequate. The wooden slat vault covers have small gaps in between the boards that may allow small terrestrial animals; rodents, lizards, snakes, etc., to falls through and into the vault. Discussed installing a wire mesh, i.e., hog wire, to reduce the chance that small animals may fall into the vaults with the LDEQ project manager._________________________________________ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________

C. Early Indicators of Potential Remedy Problems

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. _No indictors of potential remedy problems were noted during the site inspection.________________ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. __N/A_______________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________ ____________________________________________________________________

Madisonville Creosote Works Superfund Site EPA ID: LAD981522998 Third Five-Year Review

INSPECTION TEAM ROSTER

NAME ORGANIZATION TITLE

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ATTACHMENT 6

Site Inspection Photographs

Site Inspection Photographs September 17, 2013

Madisonville Creosote Works Superfund Site Five-Year Review

Description: Registered Live Oak.

Description: Highway 22, Wastewater Treatment Plant (WWTP) and fence line along north side of

site.



Description: WWTP staining on floor from small spills/leak.

Description: Wastewater treatment plant programmable logic controllers (PLC) screen.



Description: Influent equalization tank (T1).

Description: TIGG carbon filtration tanks and creosote holding tank in background to left



Description: PEP sand filtration tanks and Oil/water Separator to right (T2)

Description: Pump vault.



Description: Vault cover showing where metal covers have been cut to be made smaller and wooden slat covers have been place on either side the metal cover.

Description: Open vault cover.



Description: Open pump vault.

Description: Interior of compressor pump shed, all electrical components have been moved out of the vaults and into the pump shed.



Description: Site as viewed to the east; note fence area cleared at request of resident.

Description: Site as viewed to the west.

ATTACHMENT 7

Interview Records

Page 1 of 4

INTERVIEW RECORD

Site Name: Madisonville Creosote Works Superfund Site

Site Location: Approx. 3 miles west of Madisonville on Hwy 22

EPA ID No.: LAD981522998

Type: □ Telephone x Visit □ Other

Time: 10:00a Date: 9/17/2013

Contact Made By:

Name: Laura Stankosky Title: EPA RPM Organization: EPA Region 6

Telephone No: 214-665-7525

E-Mail: [email protected]

Street Address: 1445 Ross Avenue, Suite 1200

City, State, Zip: Dallas, TX 75202

Individual Contacted:

Name: John Halk, CHMM Title: State Project Mgr. Organization: LDEQ Underground Storage Tanks and Remediation Division


E-Mail Address: [email protected]

Street Address: 602 N. Fifth St.

City, State, Zip: Baton Rouge, LA 70821

Summary Of Conversation

1. What is your overall impression of the site/project (general sentiment)?

I believe the site has been functioning well given the age of the current recovery system and due in large part to the current operator, who has been at the site for many years. . The State has been in charge of treating groundwater at the site since September 2001, we continue to remove creosote from the shallow groundwater zone at a consistent rate.

2. What effects have post-construction site activities in the last five years had on the surrounding community?

Minimal to no impact; we operate exclusively within the site boundaries and do not impede off-site activities. The site pre-dates much of the current development of subdivisions in the vicinity; so it appears as an open field for the most part to area residents.

Page 2 of 4

Interview Record continued


Site Location: 3 miles west of Madisonville on Hwy 22


3. Are you aware of any community concerns regarding the ongoing operation and maintenance activities at the site? If so, please give details.

We have addressed aesthetic concerns with Ms. Janice Sapia, who resides in Coquille Subdivison adjacent to the east fence line. She requested that we bush hog next to the fence and clear vegetation along the fence that abuts her backyard. We have recently been contacted by other residents in the area during the recent 5 Year Review to address any questions they had regarding the site. LDEQ plans to bush hog the eastern fence line which abuts the backyards of the 10 Coquille Subdivision houses.

4. Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or emergency response from local authorities? If so, please provide details.

No

5. Do you feel well informed about the site’s activities and progress?

As state project manager, I am responsible for the operation and maintenance program at the site. We have been managing O&M for a number of years. We maintain an existing contract with SEMS to perform O&M operations. As manager, I am in frequent contact with the site operator and make periodic inspections at the site to observe operations.

6. Have there been routine communications or activities (site visits, inspections, reporting activities, etc.) conducted by your office regarding the site? If so, please give purpose and results?

Yes, as manager of the O&M activities, I maintain contacts with the contractor, make periodic inspections and document with field inspection reports, and re-bid contracts every 3 years. I also review contractor monthly operational reports and respond with a letter on those reports. I correspond with the site operator and contract manager on a routine basis to resolve any issues.

7. Have there been any complaints, violations, or other incidents related to the site requiring a response by your office? If so, please give details of the events and results of the response.

No safety related incidents have occurred on the site since the last 5 year review. We had some damage to the treatment building roof that was repaired during Hurricane Isaac and we have done some improvements to the vault openings to increase safety. As stated previously, we are addressing aesthetic concerns along the east fenceline

Page 3 of 4



Site Location:


8. Is the remedy functioning as expected? How well is the remedy performing?

The groundwater treatment operations are performing as expected, given the current design.

9. What do the monitoring data show? Are there any trends that show contaminant levels are decreasing?

Monitoring of on-site groundwater deep wells do not show evidence of creosote migration to the deep groundwater zone. As for recovery of shallow groundwater contaminated with creosote, we have averaged approximately 150 gallons per month of creosote recovery from the system during the last 3 years; overall trends of recovery show some decrease but it is dependent on how much water we treat each month, which is variable, and allowing the system to rest, which tends to lead to increased accumulation of DNAPL into the pore space.

10. Is there a continuous on-site O&M presence? If so, please describe staff and activities. If there is not a continuous on-site presence, describe staff and frequency of site inspections and activities.

No, the site operation is not continuous. We operate approximately 10-14 days out of the month; the site operator visits the site every day however to check on the site when not in pumping mode.

The site is securely locked when the operator is not on-site.

11. Have there been any significant changes in the 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.

No

12. Have there been unexpected O&M difficulties or costs at the site since start-up or in the last five years? If so, please give details.

No

Page 4 of 4



Site Location:

EPA ID No.:

13. Have there been opportunities to optimize O&M, or sampling efforts? Please describe changes and resultant or desired cost savings or improved efficiency.

We have modified the opening of the vaults to increase safety concerns when working around the vaults and make it easier to set up and operate the system. In the past, we have also eliminated the electrical connections originally located inside the vaults and went to a air-driven pump sytem. This increased safety as well as efficiency, since there was significant down time when electrical pumps were used due to pump failures.

In the future, we may put risers on the existing groundwater extraction pipes so that the covers to the vaults do not have to be pulled each time work is done.

14. Do you have any comments, suggestions, or recommendations regarding the site’s management or operation?

No.

Page 1 of 3

INTERVIEW RECORD


Site Location: Madisonville, La.

EPA ID No.:

LAD981522998

Type: □ Telephone □ Visit □ Other

Visit

Time:

10:30

Date:

9/17/13

Contact Made By:

Name:

Laura Stankosky

Title:

Project Manager

Organization: EPA Region 6

Telephone No:


Street Address: 1445 Ross Ave. (6sf-lp)

City, State, Zip: Dallas, Texas 75202


Name: Rick Tibbs Title: Site Manager Organization: SEMS INC.



Street Address: 335 W. Saint Mary dr.

City, State, Zip: Covington, La. 70433



Good

2. What effects have post-construction site activities in the last five years had on the surrounding community?

None


None

Page 2 of 3






No


Yes

6. Have there been routine communications or activities (site visits, inspections, reporting activities, etc.) conducted by your office regarding the site? If so, please give purpose and results?

Yes

7. Have there been any complaints, violations, or other incidents related to the site requiring a response by your office? If so, please give details of the events and results of the responses.

None

8. Is the remedy functioning as expected? How well is the remedy performing?

Yes

9. What do the monitoring data show? Are there any trends that show contaminant levels are decreasing?

Think we have a slight decrease, but recovery is steady.

Page 5 of 3





10. Is there a continuous on-site O&M presence? If so, please describe staff and activities. If there is not a continuous on-site presence, describe staff and frequency of site inspections and activities.

Yes, there is an ongoing O&M and a Daily presence. We have an excellent, professional staff and crew handling the operations, maintenance, site upkeep and recovery.

11. Have there been any significant changes in the 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.\

None

12. Have there been unexpected O&M difficulties or costs at the site since start-up or in the last five years? If so, please give details.

None

13. Have there been opportunities to optimize O&M, or sampling efforts? Please describe changes and resultant or desired cost savings or improved efficiency.

Operations are the same, have become more efficient over time

14. Do you have any comments, suggestions, or recommendations regarding the site’s management or operation? Do you feel that operations are sufficient?

Recovery is working and steady. Don’t feel that the small changes I as the operator would want to do, would justify the cost.

Page 1 of 2

INTERVIEW RECORD


Site Location: Madisonville, St. Tammany Parish, LA


Type: □ Telephone X Visit □ Other

Time: 10:00am Date: 9/17/13

Contact Made By:

Name: Bill Little/Laura Stankosky

Title: CIC/ RPM Organization: EPA






Name: Ms. Joyce Core Title: Town Clerk Organization: City of Madisonville

Telephone No: : (985) 845-7311

E-Mail Address:

Street Address: 403 St. Francis Street



Ms. Core was not too familiar with the site. She had just recently started with the city.

2. What effects have post-construction site activities in the last five years had on the surrounding

Community?

She has received no negative or positive information about the site.

Page 2 of 2





3. Are you aware of any community concerns regarding the ongoing operation and maintenance activities at the site?

No.


No


Ms. Core feels more informed about the site from the interview process and now that she has been supplied the fact sheet that was mailed out to the surrounding community.


Not at this time..

Page 1 of 2

INTERVIEW RECORD





Time: 1:30 pm Date: 9/17/13

Contact Made By:








Name: Maria Reyes Title: Reference Librarian Organization: St. Tammany Parish Library

Telephone No: : 985-845-4819


Street Address: St. Tammany Parish Library/ Madisonville Branch

City, State, Zip: 1123 Main St., Madisonville, LA 70447



The Madisonville Branch of the St. Tammany Parish Library had been open only since the beginning of September 2013, after being closed since August 2005 due to flooding and damage sustained during Hurricane Katrina. Ms. Reyes has recently moved into the area and is not yet familiar with the site.


community?

N/A

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Ms. Reyes was not aware of any community concerns with the site.


Ms. Reyes was not aware of any events, incidents at the site.


The fact sheet has helped Ms. Reyes become more familiar.


Ms. Reyes requested that the Administrative Record be sent to the library on multiple DVD’s for the inclusion in the repository. The Library is brand new, opened within the past two weeks; it has numerous computer access stations that would allow the public to review site repository documents electronically. Ms. Reyes indicated that she would work with Joyce Core, Town Clerk, on trying to locate the old site repository records so that the blotter size maps might also be available for public review.

Page 1 of 2

INTERVIEW RECORD





Time: 2:30 pm Date: 9/17/13

Contact Made By:








Name: Mrs. Janice Sapia Title: Homeowner Organization

Telephone No: :

E-Mail Address:

Street Address



She indicated that everything looks good; they are doing a great job keeping the fence line clear. Will they eventually be able to take the fence down?

Answer given during interview - The property is owned by a private individual and that would have to be a decision made by the property owner.


Community?

Can they clear the area by the fence line for all of my neighbors, so they can have a view of the property?

Answer given during interview - Each individual wanting the fence line cleared should contact the Louisiana Department of Environmental Quality project manager, John Halk, and he can make the arrangement to have that done. Trees and vegetation on your side of the fence line is not part of the site and LDEQ does not have the authority to perform clearing. Ms. Sapia indicated that it is common space, and that is controlled by the Management Company of the Housing Development.

(k)(6) (k)(6)

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3. Are you aware of any community concerns regarding the ongoing operation and maintenance activities at the site?

We would like access to the area so the children could play in the open area.

Answer given during interview - That would have to be a decision made by the property owner.

We are concerned about dead trees falling on our homes. Ms. Sapia walked us outside to show us the tree with which she is concerned.

Answer given during interview - The particular tree Ms. Sapia showed us was on the housing development side of the fence line. Removal of trees on the housing development side of the fence would be either the homeowner’s responsibility or the housing development responsibility, as applicable. Any dead trees on the Site would be addressed by contacting LDEQ, john Halk. if they pose a danger of causing damage.


No


Yes


She feels safe next to the site.

ATTACHMENT 8

Institutional Controls

State of Louisiana I I

Department of Environmerital Quality I

KATHLEEN BABINEAUX BLANCO GOVERNOR

MIKE D. McDANIEL, Ph.D. SECRETARY

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August 23, 2004

Laura Stankosky US EPA - Region 6 Superfund- Louisiana/Oklahoma (6SF-LP) 1445 Ross A venue Dallas, TX 75202

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i RE: Madisonville Wood Preserving Company, AI #1344

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Conveyance Notice

Dear Ms. Stankosky:

Please find enclosed a copy of the Conveyance Notice (or the Madisonville Wood Preserving Company, AI #1344, site. The instrument ~as filed by Donald L. Norwood, Registered Ageqt, with. the St. Tammany Clerk of Coury Land Records on August 11, 2004. I

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Please contact me·at (225) 219-3198 with any questions. !All correspondence must include the AI number and be submitted in triplicate to: :

Keith L. Casanova, Administrator Remediation Services Division P.O. Box 4314 Baton Rouge, LA 70821-4314.

Sincerely,

William N. Perry Environmental Scientist Supervisor Remediation Services Division

c: LDEQ File Scanning Room 144-IAS

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OFFICE OF ENVIRONMENTAL ASSESSMENT 1:. p,, \ ··" P. 0. BOX 4314 o BATON ROUGE, LOUISIANA 70821-4314 o TELEPHONE: (225) 219-3236 o FAX: (225) 219-3239

AN EQUAL OPPORTUNITY EMPLOYER

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CONVEYANCE NOTIFICATION

Madisonville Creosote Works, Inc .. a.k.a. ' :~A·eaal#~. ~:::~~f!ii:. --~-~-- Madisonville Wood Preserving Company

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Madisonville Wood Preserving Company, Inc hereby notifies the public that the following described Area of Investigation (AOI) located at 1421 West Hwy 22, Madisonville, LA, and with Agency Interest Number 1344 was closed with contaminant levels present that are acceptable for industrial/commercial use of the property as described in the Louisiana Department of Environmental Quality's (LDEQ) Risk Evaluation/Corrective Action Program (RECAP), Section 2.9. In accordance with LAC 33:!., Chapter 13, if1and use changes from · industrial to non-industrial, the responsible party shall notify the LDEQ within 30 days and the AOI shall be reevaluated to determine ifconditions are appropriate for the proposed land use.

This AOI was closed in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), 42 U.S. C. § 9601 et seq., as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and the Louisiana Administrative Code, Title 33: Chapter 12. Information regarding the AOI is avail~ble in the LDEQ public record and may be obtained by contacting the LDEQ Records Manager at .(225) 219-31.68. Inquiries regarding the contents ofthe AOI maybe directed to the current LDEQ Remediation Services Division (RSD) Team Leader at P.O. Box 4314, Baton Rouge, LA, 70821-4314. . ..

AOI Description:

The site covers approximately 29 acres in Section 42, Township 7S, Range lOE, St. Tammany Parish, in southeastern Louisiana. The property is south of Louisiana State Highway 22, about 3 miles west of downtqwn Madisonville and 1.25 miles from the Madisonville city limits. The _approximate geographical center of the property is at 30°25'38" north latitude and 90:'11 '55" west iongitude as measured from the U.S. Geological Survey (USGS), 15~minute series topographic quadrangle for Madisonville, Louisiapa.-

Legal Description of the Property:

A CERTAIN PIECE OR PORTION OF GROUND situated in Section 42, Township 7 South, Range 10 East, St. Tammany Parish, Louisiana, and more. fully described_ according to map and plat of survey by H. C. Sanders & Associates, dated July 6, 1979, revised July 10, 1979, as ' . . follows, to ."Yi~:

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Frgw~the;S~TlitJ;iwest,<;;qfilerJ?.fSection 42, go South 75 degrees East 1419.0 feet to an 1-1/8 inch . ., . , ... ._,,. :, ·, ff : ,,· . \ \2'. . . :/-'''"'"'''' -csolidjr6n.oaifthenc.~;Nqtth;14 degrees 15 minutes East 912.86 ft;:et (Title-914.0 feet) to an l-"ii1cliifon;p~ip¢;.the~~e·':N~rti{f4 degrees 44 minutes East 121.3 feet (Title-North 14 degrees 15

.-<~~p4t6~;:e.~~fl1~9.~o~~t;,~tf~9:'.~:7/8-inch iron pipe located on the southerly right-of-way line of

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Louisiana Highway 22 (formerly U. S. Highway 190); thence go along the southerly right-ofway line of said highway North 61 degrees 47 minutes West 102.0 feet (Title-North 62 degrees West 100.0 feet) to an l-inch iron pipe; thence North 62-degrees 08 minutes West 125.0 feet (Title-North 62 degrees West) to an 1/2-inch square iron rod and the point of beginning. From the point ofbegi:nillng, continue along the southerly right-of-way line of Louisiana Highway 22 North 62 degrees 08 minutes West 205.7 feet (Title-North 62 degrees West) to an 1-1/8 inch iron pipe; thence South l3 degrees 27 minutes West 38.2 feet (Title-South 10 degrees West) to an 1-118 inch iron pipe located in the center of an old abandoned highway; thence South 51 degrees 29 minutes 30 seconds East 218.68 feet (Title-South 52 degrees 12 minutes East) along the center line of said old abandoned highway to a point; thence North 14 degrees 15 minutes East 79.7 feet to an 1/2-inch square iron rod located on the southerly right-of-way line of Louisiana Highway 22 and point of beginning.

Constituents ofConcern Remaining:

At the completion of the US Environmental Protection Agency (EPA) remediation, an estimated 379,099 gallons of creosote constituents remained in the soil sand lens under the site. A collection system has operated since the commencement ofthe operation and maintenance phase; therefore, the amount of remaining creosote is undetermined.

I . Siggature of Person Filing Parish Record

Donald L. Norwood

Typed Name and Titie ofPerson Filing Parish Record

August 11, 2004

Date:

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(A true copy ofth~ docillnent certified by the parish clerk of court must be sent to the Remediation S~rvices Division, Post Office Box 4314, Baton Rouge, Louisiana 70821-4314.)

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MACISONVLLE CREOSOTE WORKS· MACISONVIli..E, ST. TAMMANY, LOUISIANA

PLOT PLAN. ON-PROPERTY AREAS Start of Long-Term DNAPL

Recovery Operations

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