Hrs Documentation Record Cover Sheet

HRS DOCUMENTATION RECORD COVER SHEET

Name of Site: American Creosote DeRidder

EPA ID Number: LAN000604293

Contact Persons

Site Investigation: Brenda Nixon Cook, EPA Region 6 (214) 665-7436 (Name) (Telephone)

Documentation Record: Brenda Nixon Cook, EPA Region 6 (214) 665-7436 (Name) (Telephone)

Pathways, Components, or Threats Not Scored

1) Ground Water Pathway: The ground water migration pathway has not been scored. Temporary wells located on Central Manufacturing Company (CMC) property and ground water monitoring wells located on Burlington Northern Santa Fe (BNSF) Railroad property have shown elevated levels of total petroleum hydrocarbons (TPHs) and polycyclic aromatic hydrocarbons (PAHs) (Ref. 4, pp. 95-96; Ref. 6, pp. 42-45, 87, 120-121, 125; Ref. 7, pp. 53-54, 97, 302-306, 335 & 338-341). Based on information available at this time, further evaluation of the ground water migration pathway would not significantly affect the listing decision (Ref. 1, Sec. 2.2.3).

2) Surface Water Pathway: Ground Water to Surface Water Migration Component: The overland/flood migration component of the Surface Water Migration Pathway has been scored for the Human Food Chain Threat and Environmental Threat. The Ground Water to Surface Water Migration component has not been scored. Based on information available at this time, evaluation of this component would not significantly affect the listing decision (Ref. 1, Sec. 2.2.3).

3) Air Migration Pathway: Based on information available at this time, evaluation of the Air Migration Pathway would not significantly affect the listing decision (Ref. 1, Sec. 2.2.3).

4) Soil Exposure and Subsurface Intrusion Pathway: Based on information available at this time, further evaluation of the Soil Exposure and Subsurface Intrusion Pathway would not significantly affect the listing decision (Ref. 1, Sec. 2.2.3; Ref. 1a, Sec. 2.2.3).

These pathways and components are of concern to the U.S. Environmental Protection Agency (EPA) and may be considered during a future evaluation. HRS DOCUMENTATION RECORD

Name of Site: American Creosote DeRidder Date Prepared: July 2017

EPA ID Number: LAN000604293

EPA Region: 6

Street Address of Site*: Washington St/Post Plant Rd, DeRidder, Beauregard Parish (Ref. 12, p. 1). Section 3, Township 3 South, Range 9 West of the Louisiana Meridian (Ref. 4, p. 7; Ref. 5, p. 2; Fig. 1 of this HRS documentation record)

City, Parish, State, Zip Code: DeRidder, Beauregard Parish, Louisiana 70634

General Location in the State: American Creosote DeRidder is located in northern Beauregard Parish, south of the corporate limits of the city of DeRidder, Louisiana (Figure 1)

Topographic Map: DeRidder Quadrangle Louisiana – Beauregard Parish (Ref. 3, p. 1)

Latitude: 30o 49' 54.0948" North Longitude: 93o 16' 36.7068" West Physical Address location coordinates per CMC Access Agreement, and location of former facility operations (Ref. 7, p. 207; Ref. 40, p. 1)

Air Pathway Not Scored Ground Water Pathway Not Scored Soil Exposure and Subsurface Intrusion Pathway Not Scored Surface Water Pathway 100.00

HRS SITE SCORE 50.00

*The street address, coordinates, and contaminant locations presented in this HRS documentation record identify the general area the site is located. They represent one or more locations EPA considers to be part of the site based on the screening information EPA used to evaluate the site for NPL listing. EPA lists national priorities among the known "releases or threatened releases" of hazardous substances; thus, the focus is on the release, not precisely delineated boundaries. A site is defined as where a hazardous substance has been "deposited, stored, disposed, or placed, or has otherwise come to be located." Generally, HRS scoring and the subsequent listing of a release merely represent the initial determination that a certain area may need to be addressed under CERCLA. Accordingly, EPA contemplates that the preliminary description of facility boundaries at the time of scoring will be refined as more information is developed as to where the contamination has come to be located.

1 FIGURES

Figure 1 Facility Location Map Figure 2 Aerial Facility Sketch Figure 3 Sources with Site Inspection and Expanded Site Inspection Sampling Locations Map Figure 4 PPE Location and Overland Flow Pathways Figure 5 Level II Contamination Segments Figure 6 Surface Water Migration Pathway

NOTES TO THE READER

The following rules were used when citing references in the HRS (Hazard Ranking System) package.

1. Hazardous substances are listed by how they appear in the Superfund Chemical Data Matrix (SCDM).

2. Significant figures: Calculations are reported to two significant figures to the right of the decimal place when the HRS does not specify rounding.

3. Abbreviations/Conventions used to identify references and citations: Figure Fig. Number No. Reference Ref. Section Sec. Single Pages p. Multiple Pages pp. “.” Next Reference () Selected acronyms

2 ABBREVIATIONS

ACADIAN Acadian Engineers & Environmental Consultants Inc. ACRES Assessment, Cleanup and Redevelopment Exchange System ADJ CRQL Adjusted Contract Required Quantitation Limit AIRS/AFS US Air Facility System AOC Area of Concern ATSF Atchison, Topeka and Santa Fe Railway BGS Below Ground Surface BNSF Burlington Northern Santa Fe CERLA Comprehensive Environmental Response, Compensation, and Liability Act CERCLIS Comprehensive Environmental Response, Compensation, and Liability Information System CFS Cubic feet per second CLP Contract Laboratory Program CMC Central Manufacturing Company COC Contaminants of Concern CORRACTS Correction Action Report ERNS Emergency Response Notification System ERT Environmental Response Team ESI Expanded Site Inspection FIRM Flood Insurance Rate Map ft2 Square Feet ft3 Cubic Feet HRS Hazard Ranking System IASD Inactive and Abandoned Sites Division LDEQ Louisiana Department of Environmental Quality LDWF Louisiana Department of Wildlife and Fisheries mg/kg Milligram per Kilogram MSDS Material Safety Data Sheet NFRAP No Further Remedial Action Planned NPDES National Pollutant Discharge Elimination System NPL National Priorities List NWI National Wetlands Inventory QASP Quality Assurance Sampling Plan PAH Polycyclic Aromatic Hydrocarbons PPE Probable Point of Entry PPM Parts per Million RA Removal Action RCRA Resource Conservation and Recovery Act RECAP Risk Evaluation/Corrective Action RI/FS Remedial Investigation/Feasibility Study RL Reporting Limit ROW Right-of Way SCDM Superfund Chemical Data Matrix SFHA Special Flood Hazard Area SI Site Inspection SOP Standard Operating Procedure

3 SSID Site Spill Identifier Number START Superfund Technical Assessment and Response Team SVOA Semi-Volatile Organic Analysis TAL Target Analyte List TCL Target Compound List TDL Target Distance Limit TPH Total Petroleum Hydrocarbon TSD Treatment, Storage, Disposal USGS United States Geological Survey VOA Volatile Organic Analysis VOC Volatile Organic Compounds yd3 Cubic Yards

4 FIGURE REFERENCE SHEET

Figure 1: Facility Location Map Base Map Source*, USGS The National Map: National Boundaries Dataset, 3D Elevation Program, Geographic Names Information System, National Hydrography Dataset, National Land Cover Database, National Structures Dataset, and National Transportation Dataset; U.S. Census Bureau – TIGER/Line

* Map annotated by EPA START-3 on September 22, 2016 to depict site location and property boundary (Ref. 3, p. 1; Ref. 4, pp. 7 & 27; Ref. 5, pp. 2-3 & 5; Ref. 6, pp. 61 & 91-92; Ref. 7, pp. 12 & 80-82; Ref. 10, pp. 2-9; Ref. 12, p. 5; Ref. 13, pp. 10, 36-38; Ref. 15, p. 1; Ref. 17, p. 1; Ref. 19, p. 14; Ref. 20, pp. 17-18; Ref. 22, p. 5; Ref. 26, pp. 4 & 15).

Figure 2: Aerial Facility Sketch Base Map Source*, Esri**- with World Imagery Metadata From: DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community; National Hydrography Dataset

* Map annotated by EPA START-3 on September 23, 2016, to depict source locations (Ref. 4, pp. 22 & 28-37; Ref. 6, pp. 93-114; Ref. 10, pp. 10 & 13; Ref .16, p. 1; Ref. 21, pp. 117 & 119-120; Ref. 26, pp. 7-8 & 16-17).

** Source map image is Esri, and is used by EPA with Esri’s permission

Figure 3: Sources with Site Inspection and Expanded Site Inspection Sampling Locations Map Base Map Source*, Esri**- with World Imagery Metadata From: DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community; National Hydrography Dataset; and National Wetlands Inventory

* Map annotated by EPA START-3 on September 23, 2016, to depict source locations and sample locations (Ref. 4, pp. 22 & 35; Ref. 7, pp. 36-38, 40-44, 57, 63-67, 84, 121-150, 174-177, 180-194, 205, 537-560; Ref. 26, pp. 7-8 & 16-17; Ref. 39, pp. 79, 115-141, 154-162, 168 & 380-390).

** Source map image is Esri, and is used by EPA with Esri’s permission

Figure 4: PPE Location and Overland Flow Pathways Base Map Source* , Esri**- with World Imagery Metadata From: DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community; National Hydrography Dataset

* Map annotated by EPA START-3 on September 23, 2016, to depict the PPE, site drainage, overland flow, and sources (Ref. 4, pp. 13, 15-16, 22 & 28-37; Ref. 6, pp. 58-59, 71, 73, 76 & 93-114; Ref. 7, pp. 57-60, 84, 147, 149, 182, 205, 230-235, 337-338, 340-341, 537, 545-546; Ref. 9, p. 3; Ref. 10, pp. 10 & 13; Ref. 12, p. 2; Ref. 14, pp. 1-2; Ref. 15, p. 2; Ref. 16, p. 1; Ref. 17, p. 2; Ref. 21, pp. 5, 117 & 119; Ref. 26, pp. 7-8, 16-17 & 19-24; Ref. 28, pp. 6-7; Ref. 35, pp. 1-2; Ref. 36, pp.5, 7 & 9; Ref. 37, pp. 1-5; Ref. 39, pp. 53-54, 79, 138-141, 159-160, 162, 168, 380-381 & 210-215).

** Source map image is Esri, and is used by EPA with Esri’s permission

Figure 5: Level II Contamination Segments Base Map Source*, Esri**- with World Imagery Metadata From: DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community; National Hydrography Dataset; and National Wetlands Inventory

* Map annotated by EPA START-3 on September 23, 2016, to depict background and release sample locations, the PPE, and surface water pathway contamination, and wetland contamination (Ref .4, pp. 13, 15-16 & 28-37; Ref. 6, pp. 58-59, 71, 73, 76 & 93-114; Ref. 7, pp. 36-38, 40-41, 57-60, 63-67, 84, 121-150. 174-177, 180-194, 205, 230-235, 237-239, 260-263, 337-338, 340-341, 355-359 & 537-560; Ref. 9, p. 3; Ref. 10, pp. 10 & 13; Ref. 12, p. 2; Ref. 14, pp. 1-2; Ref. 15, p. 2; Ref. 16, p. 1; Ref. 17, p. 2; Ref. 21, pp. 5, 117 & 119; Ref. 26, pp. 16-17 & 19-24; Ref. 28, pp. 3-9; Ref. Ref. 31, p. 1; Ref. 32, p. 1; Ref. 33, pp. 2-3; Ref. 34, pp. 21-23; Ref. 35, pp. 1-2; Ref. 36, pp. 1-9, Ref. 37, pp. 1-5; Ref. 39, pp. 79, 96-113, 115-142, 147-150; 168, 180-236 & 380-390.

** Source map image is Esri, and is used by EPA with Esri’s permission

Figure 6: Surface Water Migration Pathway Base Map Source*, Esri**- with World Imagery Metadata From: DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community; National Hydrography Dataset; and National Wetlands Inventory

* Map annotated by EPA START-3 on September 23, 2016, for surface water flow, common drainage, facility boundary, wetland delineation maps, and national wetland inventory (Ref. 3, p .1; Ref. 4, pp. 7, 13, 15-16, 27, 32, 34 & 36; Ref. 5, pp. 2-3 & 5; Ref. 6, pp. 58-59, 61, 71, 73 & 91-114; Ref. 7, pp. 12, 80-82, 86, 149; Ref. 9, p. 3; Ref. 10, pp. 2-10 & 13; Ref. 12, pp. 2 & 5; Ref. 13, pp. 10, 36-38; Ref. 14, pp. 1-2; Ref. 15, pp. 1-2; Ref. 16, p. 1; Ref. 17, pp. 1-2; Ref. 19, p. 14; Ref. 20, pp. 17-18; Ref. 21, pp. 5 & 119-120; Ref. 22, p. 5; Ref. 26, pp. 4, 15 & 19-24; Ref. 28, pp. 3-18; Ref. 31, p. 1; Ref. 32, p. 1; Ref. 33, pp. 2-3; Ref. 34, pp. 21-23; Ref. 35, pp. 1-3; Ref. 36, pp. 1-9; Ref. 37, pp. 1-5).

** Source map image used by EPA with Esri’s permission

Map of Lousiana Legend US EPA Region 6 START-3 Facility Boundary / Figure 1. Facility Location Map American Creosote DeRidder 1:24,000 DeRidder, Beauregard Parish, Louisiana

CERCLIS No. LAN000604293 October 1, 2016 TDD No. 9/DYNAMAC-077-16-001 0 1,000 2,000 4,000 Feet Figure Reference Sheet included as part of the HRS Documentation Record. Creosote Pile Oil/Water Separator

Unlined Wastwater Pit Concrete Structure

Pit

Contaminated Soil

0 50 100 200 1:2,000 Feet

Map of Lousiana Legend US EPA Region 6 START-3 Sources / Figure 2. Aerial Facility Sketch 1:12,000 American Creosote DeRidder DeRidder, Beauregard Parish, Louisiana

CERCLIS No. LAN000604293 October 8, 2016 TDD No. 9/DYNAMAC-077-16-01

0 600 1,200 2,400 Feet The source of this map image is Esri, used by the EPA with Esri's permission. PPE Figure Reference Sheet included as part of the HRS Documentation Record.

Unnamed Stream (Perennial)

Unnamed Drainage Ditch/Stream (Intermittent)

Overland Flow Direction AC-26!( Source No. 5

Source No. 2

Source No. 4 AC-05 AC-04 !( !(

Source No. 3 AC-08 Source No. 1 !( !( !( AC-06 !( !( AC-25

Source No. 4 AC-10/AC-19 AC-11 !( AC-07/AC-19

AC-ESI-03 !( !( AC-ESI-04

!( AC-ESI-06 AC-12 AC-ESI-01 !( AC-ESI-05 !( !( !(

AC-ESI-02

AC-02 !(!( AC-01 0 50 100 200 1:2,000 Feet

AC-ESI-07/AC-ESI-11 !( AC-ESI-09 !(!( AC-ESI-08/AC-ESI-11 !( AC-ESI-10 !( ACSD15

Map of Lousiana Legend US EPA Region 6 !( Soil START-3

!( / Sediment Figure 3. Sources with Site Inspection and Expanded Site Inspection !( Sediment/Surface Water Sampling Locations Map 1:12,000 American Creosote DeRidder !( Surface Water DeRidder, Beauregard Parish, Louisiana

Sources CERCLIS No. LAN000604293 October 8, 2016 TDD No. 9/DYNAMAC-077-16-01

0 600 1,200 2,400 The source of this map image is Esri, used by the EPA with Esri's permission. Feet Figure Reference Sheet included as part of the HRS Documentation Record. Source No. 2 Source No. 5

Source No. 4

Source No. 3

Source No. 1 Source No. 4

PPE

1:2,000 0 50 100 200 Feet

Map of Lousiana Legend US EPA Region 6 PPE / START-3 Unnamed Stream Figure 4. PPE Location and Overland Flow Pathways Unnamed Drainage Ditch/Stream American Creosote DeRidder DeRidder, Beauregard Parish, Louisiana Overland Flow Direction

CERCLIS No. LAN000604293 October 8, 2016 Sources 1:12,000 TDD No. 9/DYNAMAC-077-16-01

0 600 1,200 2,400 The source of this map image is Esri, used by the EPA with Esri's permission. Feet Figure Reference Sheet included as part of the HRS Documentation Record. .! AC-ESI-03 .! .! AC-ESI-04 AC-02

Segment 2: Level II Contamination

!( AC-ESI-06 AC-12 !( AC-13 PPE !( AC-ESI-05 !( !( AC-ESI-02 !( !( Segment 1: Level II Contamination

AC-ESI-01 AC-14

0 25 50 100 1:1,000 Feet

Segment 2: Level II Contamination

Segment 1: Level II Contamination

Wetland Level II Contamination Segment 3: Level II Contamination

!( AC-ESI-07/AC-ESI-11

AC-ESI-09 !( !( AC-ESI-08/AC-ESI-11

Potential Contamination AC-ESI-10 !(

!( AC-15

Legend Map of Lousiana PPE US EPA Region 6 .! Background Sample / START-3 !( Release Sample

Level II Contamination Segments Figure 5. Level II Contamination Segments American Creosote DeRidder Potential Contamination DeRidder, Beauregard Parish, Louisiana

Wetland Level II Contamination CERCLIS No. LAN000604293 October 11, 2016 American Creosote DeRidder 1:5,000 TDD No. 9/DYNAMAC-077-16-01

0 250 500 1,000 The source of this map image is Esri, used by the EPA with Esri's permission. Feet Figure Reference Sheet included as part of the HRS Documentation Record. PPE

metto Cr al ee P k

15-Mile TDL B u nd ick Creek

Legend !( PPE / Surface Water Flow Map of Lousiana US EPA Region 6 Freshwater Emergent Wetland START-3 Freshwater Forested/Shrub Wetland Figure 6. Surface Water Migration Pathway Freshwater Pond American Creosote DeRidder DeRidder, Beauregard Parish, Louisiana Lake CERCLIS No. LAN000604293 October 8, 2016 Facility Boundary TDD No. 9/Dynamac-077-16-001

0 0.5 1 2 The source of this map image is Esri, used by the EPA with Esri's permission. Miles 1:75,000 Figure Reference Sheet included as part of the HRS Documentation Record. WORKSHEET FOR COMPUTING HRS SITE SCORE

s s2 1. Ground Water Migration Pathway Score (Sgw) NS NS

2a. Surface Water Overland/Flood Migration Component 100.00 10,000 (from Section 4.3 of the HRS Documentation Record)

2b. Ground Water to Surface Water Migration Component NS NS

2c. Surface Water Migration Pathway Score (Ssw) 100.00 10,000 Enter the larger of the line 2a and 2b as the pathway score

3. Soil Exposure and Subsurface Intrusion Pathway Score (Ssessi) NS NS

4. Air Migration Pathway Score (Sa) NS NS

5. Total of Sgw2 +Ssw2+Ssessi2+Sa2 10,000

6. HRS Site Score: Divide the value on line 5 by 4 and take the square 50.00 root.

NS = Not Scored

TABLE 4-1 -Surface Water Overland/Flood Migration Component Scoresheet

Factor Categories and Factors Maximum Value Value Assigned DRINKING WATER THREAT Likelihood of Release 1. Observed Release 550 550

2. Potential to Release by Overland Flow: 2a. Containment 10 2b. Runoff 2c. Distance to Surface Water 25 2d. Potential to Release by Overland Flow (Lines 2a X [2b+2c]) 500 NS

3 Potential to Release by Flood 3a. Containment (Flood) 10 3b. Flood Frequency 50 3c. Potential to Release by Flood (Line 3a X 3b) 500 NS

4. Potential to Release (Lines 2d + 3c, subject to a maximum of 500) 500 NS

5. Likelihood to Release (Higher of Lines 1 and 4) 550 550 NS

Waste Characteristics

6. Toxicity/Persistence *

7. Hazardous Waste Quantity *

8. Waste Characteristics 100 NS

Targets

9. Nearest Intake 50 NS

10. Population: 10a. Level I Concentrations ** NS 10b. Level II Concentrations ** NS 10c. Potential Contamination ** NS 10d. Population (Lines 10a+10b+10c) ** NS 11. Resources 5 NS

12. Targets (Lines 9+10d+11) ** NS

Factor Categories and Factors Maximum Value Value Assigned

DRINKING WATER THREAT (Concluded) Drinking Water Threat Score 13. Drinking Water Threat Score ([Lines 5 x 8 x 12]/82,500, subject to a maximum of 100) 550 NS HUMAN FOOD CHAIN THREAT Likelihood of Release 14. Likelihood of Release (Same value as Line 5) 550 550 Waste Characteristics 15. Toxicity/Persistence/Bioaccumulation * 5 x 108 16. Hazardous Waste Quantity * 100 17. Waste Characteristics 1,000 320 Targets 18. Food Chain Individual 50 20 19. Population: 19a. Level I Concentrations ** 0 19b. Level II Concentrations ** 0 19c. Potential Contamination ** 0.00006 19d. Population (Lines 19a+19b+19c) ** 0.00006 20. Targets ** 20.00006 (Value from Lines 18+19d) Human Food Chain Threat Score

21. Human Food Chain Threat Score 100 42.66 ([Lines 14 x 17 x 20]/82,500, subject to a maximum of 100)

ENVIORNMENTAL THREAT Likelihood of Release 22. Likelihood of Release (Same value as Line 5) 550 550

Waste Characteristics 23. Ecosystem Toxicity/Persistence/ Bioaccumulation * 5 x 108

24. Hazardous Waste Quantity * 100

25. Waste Characteristics 1,000 320

Targets

26. Sensitive Environments: 26a. Level I Concentrations ** 0 26b. Level II Concentrations ** 25 26c. Potential Contamination ** 5.7 15

Factor Categories and Factors Maximum Value Value Assigned 26d. Sensitive Environments (Lines 26a+26b+26c) ** 30.7

27. Targets (Value from Line 26d) ** 30.7

ENVIRONMENTAL THREAT 28. Environmental Threat Score ([Lines 22 x 25 x 27]/82,500subject to a maximum of 60) 60 60.00

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORE FOR A WATERSHED 29. WATERSHED SCORE (Lines 13 + 21 + 28, subject to a maximum of 100) 100 100.00

30. Component Score (S0,) (Highest score from Line 29 for all watersheds evaluated, subject to a maximum of 100) 100 100.00

Maximum value applies to waste characteristic category Maximum value applicable Do not round to the nearest integer

REFERENCE SHEET

Ref. No. Description of the Reference

1. U.S. EPA. Hazard Ranking System (HRS); Final Rule. Federal Register. Volume 55, Number 241.Washington, D.C. U.S. Government Printing Office, December 14, 1990. Title Page only. A complete version of this document is available online at: https://semspub.epa.gov/src/document/HQ/174028

1a. U.S. EPA. Addition of a Subsurface Intrusion Component to the Hazard Ranking System, 40 Code of Federal Regulations Part 300, 82 Federal Register 2760. January 9, 2017. Available online at https://www.regulations.gov/document?D=EPA-HQ-SFUND-2010-1086-0104. Total pages: 48.

2. U.S. EPA Superfund Chemical Data Matrix (SCDM) Query. SCDM Query by Substance and HRS Factor Values for Surface Water. URL: https://www.epa.gov/superfund/superfund- chemical-data-matrix-scdm. Accessed on January 27, 2017. Total Pages: 66.

2a. U.S. EPA. SCDM Addendum: Human Toxicity Factor Evaluation under the Subsurface Intrusion Component Addition to the Hazard Ranking System. March 2017. Total Pages: 2.

3. U.S. Geological Survey (USGS). 7.5’ Topographic Quadrangle. DeRidder Quadrangle Louisiana - Beauregard Parish. 2012. Total Pages: 1.

4. Acadian Engineers & Environmental Consultants, Inc. Voluntary Remedial Action Plan, American Creosote Site. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management System (EDMS). Document Search AI#44487. Document ID#2158339. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages 114.

5. Beauregard Parish Assessor – Brent Rutherford, CLA Property Search, Parcel Number: 0336102500. Central Manufacturing Co., Inc. URL: http://www.bpassessor.com/property-search Accessed on July 27, 2015. Total Pages: 9.

6. Acadian Engineers & Environmental Consultants, Inc. Risk Evaluation Corrective Action Program (RECAP), American Creosote Site. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management System (EDMS). Document Search AI#44487. Document ID# 2923943. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 209.

7. U.S. Environmental Protection Agency. Site Inspection Report. American Creosote DeRidder, DeRidder, Louisiana. Prepared by CSS-Dynamac for the U.S. Environmental Protection Agency. April 4, 2016. Total Pages: 584.

8. kei Soil Remediation Work Plan, American Creosote Site. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management System (EDMS). Document Search AI#44487. Document ID#78174. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 71.

9. Hunter, Charles. State Site Assessment Phase I. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management System (EDMS). Document Search AI#44487. Document ID#76794. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 5.

10. Hunter, Chuck. Property Ownership History Document. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management System (EDMS), Document Search AI#44487. Document ID#76882. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 65.

11. Acadian Engineers & Environmental Consultants, Inc. Limited Site Investigation Work Plan, American Creosote Site. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management System (EDMS). Document Search AI#44487. Document ID#1495371. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 10.

12. Hunter, Charles. State Site Assessment – Phase II. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management System (EDMS). Document Search AI#44487. Document ID#7379726. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 6.

13. U.S. Environmental Protection Agency Preliminary Assessment Report. American Creosote DeRidder, DeRidder, Louisiana. Prepared by CSS-Dynamac, March 3, 2015. Total Pages: 80.

14. State of Louisiana Department of Environmental Quality. Notification to Provide Information. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management Electronic Document Management System (EDMS). Document Search AI#44487. Document ID#76884 URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 4.

15. Hunter, Charles. LDEQ IASD Potential Hazardous Waste Site Primary Identification and Information. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management Search (EDMS). Document System AI#44487. Document ID#76894. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 2.

16. Hunter, Chuck. LDEQ Soil and Water Sampling Locations Map – 1992. Louisiana Department of Environmental Quality (LDEQ). . Electronic Document Management System (EDMS). Document Search AI#44487. Document ID#7380000. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 1.

17. Hunter, Chuck. Basic Site Information from Louisiana Site Remediation Information System (LASRIS). Louisiana Department of Environmental Quality (LDEQ) Electronic Document

Management System (EDMS). Document Search AI#44487. Document ID#1174738. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 3.

18. West-Paine Laboratories, Inc. Sample Analyses. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management System (EDMS). Document Search AI#44487. Document ID#7379999. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 42.

19. Remedial Investigation/Feasibility Study Agreement. State of Louisiana Department of Environmental Quality, Office of Legal Affairs and Enforcement Inactive and Abandoned Sites Division. Louisiana Department of Environmental Quality, Electronic Document Management System (EDMS). Document Search AI#44487. Document ID#7379728. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 18.

20. Cooperative Agreement for the American Creosote Site. State of Louisiana Department of Environmental Quality, Office of Legal Affairs and Enforcement. Louisiana Department of Environmental Quality, Electronic Document Management System (EDMS). Document Search AI#44487. Document ID# 7379711. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 18.

21. Porter, Ralph; Feth, Ellen; Knight, J. Barkely. Soil Pile Bioremediation Demonstration, Central Manufacturing and Santa Fe Railway Surface Creosote Site. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management System (EDMS). Document Search AI#44487. Document ID#7380751. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 124.

22. Acadian Engineers & Environmental Consultants, Inc. Voluntary Remedial Investigation Application Form. American Creosote Site. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management System (EDMS). Document Search AI#44487. Document ID#1456565. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 8.

23. State of Louisiana Department of Environmental Quality. American Creosote, DeRidder, Invoice No. 2003PR003. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management System (EDMS). Document Search AI#44487. Document ID#1519998. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 6.

24. State of Louisiana Department of Environmental Quality. Limited Site Investigation Work Plan Approval. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management System (EDMS). Document Search AI#44487. Document ID#1476642. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 3.

25. Acadian Engineers & Environmental Consultants, Inc. American Creosote Site, Amended Limited Site Investigation Work Plan. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management System (EDMS). Document Search AI#44487. Document

ID#1482094. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx Accessed July 2016. Total Pages: 16.

26. Acadian Engineers & Environmental Consultants, Inc. Corrective Action Plan, American Creosote Site. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management System (EDMS). Document Search AI#44487. Document ID#8806521. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx. Accessed July 2016. Total Pages: 26.

27. Using Qualified Data to Document an Observed Release and Observed Contamination. U.S. EPA, Office of Emergency and Remedial Response, Publication 9285.7-14FS. November 1996. Total Pages: 18.

28. U.S. Fish and Wildlife Service. National Wetlands Inventory. Wetlands Mapper V2 – Surface Waters and Wetlands, and Wetland Classification Codes – NWI Map Code Diagram. URL: https://www.fws.gov/wetlands/Data/Mapper.html & https://www.fws.gov/wetlands/documents/NWI_Wetlands_and_Deepwater_Map_Code_Diagra m.pdf. Accessed August 23, 2016. Total Pages: 18.

29. United States Geological Survey (USGS). National Water Information System: Web Interface, USGS 08014800 Bundick Creek near DeRidder, LA. Accessed at http://waterdata.usgs.gov/nwis/annual/?referred_module=sw&site_no=08014800&por _08014800_61729=198593,00060,61729,1956,2016&year_type=W&format=html_tab le&date_format=YYYY-MM- DD&rdb_compression=file&submitted_form=parameter_selection_list. Accessed September 15, 2016. Total Pages: 4.

30. NETROnline Environmental Report: American Creosote DeRidder, DeRidder, Beauregard Parish, Louisiana. Accessed at: http://environment.netronline.com/search/report.php?search_box=30.831693,%20-93.276863. Accessed August 5, 2016. Total Pages: 30.

31. Hook and Bullet. Beauregard Parish, LA – Fishing, Guides, Charters, Bait Information. URL: http://www.hookandbullet.com/cn/fishing-beauregard-la/. Accessed July 14, 2016. Total Pages: 2.

32. Sportfish Junkies. Lakes near DeRidder. URL: http://www.sportfishjunkies.com/search/lakes-- near--deridder-louisiana-united-states-of-america-1. Accessed September 20, 2016. Total Pages: 3.

33. Louisiana Sportsman. Fishing Bundick •Freshwater Fishing in Central Louisiana – Louisiana Sportsman Reports, LA. URL: http://www.louisianasportsman.com/lpca/index.php?section=reports&event=view&action=full_r eport&id=35581. Accessed September 20, 2016. Total Pages: 4.

34. Louisiana Department of Wildlife and Fisheries. Office of Fisheries, Inland Fisheries Section. Part VI-1A. Waterbody Management Plan Series. Bundick Lake. Lake History and Management Issues. November 2014.Total Pages: 28.

35. Horn, Keith, Staff Environmental Scientist, Office of Environmental Compliance, Louisiana Department of Environmental Quality. Letter to Ms. Brenda Nixon-Cook, Site Assessment Manager, EPA Region 6 Site Assessment Team. Re: Wetland Determination, American Creosote-DeRidder, LDEQ Agency Interest Number 44487, EPA CERCLA Number LAN000604293. August 8, 2016. Total Pages: 3.

36. State of Louisiana Department of Environmental Quality. Photographs taken by EPA START Contractor. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management System (EDMS). Document Search AI#44487. Document ID#10217299. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx. Accessed August 2016. Total Pages: 9.

37. State of Louisiana Department of Environmental Quality. Photographs Taken During Site Inspection. Louisiana Department of Environmental Quality (LDEQ) Electronic Document Management System (EDMS). Document Search AI#44487. Document ID#10217001. URL: http://edms.deq.louisiana.gov/app/doc/querydef.aspx. Accessed August 2016. Total Pages: 5.

38. Louisiana Department of Wildlife and Fisheries. Threatened and Endangered Table. URL: https://www.fws.gov/lafayette/pdf/LA_T&E_Species_List.pdf. Accessed July 2016. Total Pages: 11.

39. U.S. Environmental Protection Agency. Expanded Site Inspection Report. American Creosote DeRidder, DeRidder, Louisiana. Prepared by CSS-Dynamac for the U.S. Environmental Protection Agency. November 28, 2016. Total Pages: 396.

40. American Creosote Site Location. 30º 49’ 54.0948 North, 93º 16’ 36.7068 West. Google Earth. April 11, 2013. January 3, 2017. Total Pages: 1.

41. U.S. Department of Health and Human Services. Public Health Service. Agency for Toxic Substances and Disease Registry. Toxicological Profile For Wood Creosote, Coal Tar Creosote, Coal Tar, Coal Tar Pitch, and Coal Tar Pitch Volatiles. September 2002. Total Pages: 394.

42. Retort House. URLL http://www.booksupstairs.com/The-preservation-of-structural- timber/Retort-House.html. Accessed January 18, 2017. Total Pages: 5

43. U.S. Environmental Protection Agency. Office of Solid Waste. Wastewater Treatment Sludges From Wood Preserving Processes Using Creosote and/or Pentachlorophenol. April 26, 1984. Total Pages: 6.

44. Kinney, Sean. State of Louisiana Department of Wildlife and Fisheries. Letter of Fisheries. January 25, 2017. Total Pages: 5.

45. U.S. EPA. Region 6. Environmental Services Branch ESAT Data Form 1s for American Creosote DeRidder. Case# 45361. Total Pages: 273.

SITE DESCRIPTION:

The American Creosote DeRidder site as scored consists of 5 sources and a release of hazardous substances to the surface water pathway as a result of historical operations using creosote compounds, also known as liquid pitch oil, tar oil and coal tar solutions, in the wood preserving pressure treatment process (Ref. 4, pp. 8-9; Ref. 8, pp. 5, 52; Ref. 11, p. 3; Figures 2 and 3). The source locations are on two adjacent parcels with different owners; Central Manufacturing Company (CMC), and Burlington Northern Santa Fe (BNSF) owning the adjacent transportation corridor (Ref. 4, pp. 8-9; Ref. 8, p. 5).

American Creosote DeRidder is a 55-acre tract of land owned by CMC located in northern Beauregard Parish, south of the corporate limits of the City of DeRidder, Beauregard Parish, Louisiana (Ref. 4, pp. 7-8; Ref. 6, pp. 1-5; Figure 1). The area is characterized by a gently rolling topography, mild winters and hot/humid summers, and silty clayey sands and sandy silty clay soils (Ref. 4, p. 7). The area primarily consists of pine; however, a variety of oak and cypress are present in the low bottom areas through which drainage tributaries meander (Ref. 4, p. 7). The property is bounded in the north by a rural roadway, to the east by heavy brush, to the south by undeveloped land, and to the west by the Timber Rock Railroad spur, formerly the BNSF spur (Ref. 4, p. 7; Ref. 5, p. 5; Ref. 7, p. 208). The broader surroundings include commercial, industrial and residential uses (Figure 2). Additionally, the CMC property and former facility was once located in the now obsolete Bundick’s Creek and Game Fish Reserve Watershed Basin (Ref. 4, p. 7).

The BNSF property is located near DeRidder, Louisiana, and comprises a section of the operating Right- of Way (ROW) that is approximately 2,000 feet south of the intersection of Post Plant Road and the rail corridor (Ref. 8, p. 5; Figure 1). This section of track continues in a southwestern direction toward the intersection of the rail corridor and Washington Street near the Westvaco Plant (Ref. 8, p. 5). The railroad corridor at this point is approximately 100 feet wide (Ref. 8, p. 5). The centerline of the track is the midpoint of the corridor (Ref. 8, p. 5)

The Shreveport Creosoting Company, a Delaware Corporation, operated a creosote timber facility from the early 1920’s to approximately 1945 on a parcel of land south of DeRidder, Beauregard Parish, Louisiana (Ref. 4, pp. 8 & 27-28). American Creosoting Company, Shreveport Creosoting Company’s parent company, relocated the creosote operations from this tract of land, although other wood treatment procedures are reported to have continued until 1956 or 1957 (Ref. 4, p. 8). In 1956, Union Camp Corporation acquired American Creosoting Company (Ref. 4, p. 8). Subsequent to the acquisition Union Camp Corporation renamed the operations to AmCre Corporation (Ref. 4, p. 8). In July 1964, Kerr McGee Oil acquired the stock of AmCre Corporation from Union Camp Corporation, at which time Kerr McGee changed the name of the company to Moss American and later to Kerr McGee Chemical Corporation (Ref. 4, pp. 8-9). From 1957 to 1992 the property remained dormant until its purchase by CMC in September 1992 who planned heavy industrial/commercial use on the (Ref. 4, p. 9; Ref. 8, p. 5; Ref. 9, p. 4; Ref. 10, p. 17).

The Shreveport Company’s facilities and operations used creosote compounds, also known as liquid pitch oil, tar oil and coal tar solutions, in the wood preserving pressure treatment process (Ref. 8, p. 52; Ref. 11, p. 3). The specific operations at the site consisted of dipping timber into creosote vats and the collection of spent creosote in an open pit, and also the discharge of untreated process wastewater into an open pit (Ref. 6, p. 93; Ref. 9, p. 2; Ref. 12, p .1). There is no historical data to indicate that site

operations included waste handling, disposal practices, or facility permits (Ref. 4, p. 8; Ref. 12, p. 1).

The property is currently void of any of these operations and consists of heavy timber cover and extensive overgrowth, including lower story overgrowth in and around the abandoned facility (Ref. 4. p. 9). Abandoned wood treatment facilities of the previous operations currently remain at the property (Ref. 4, p. 9). The American Creosote DeRidder property has been impacted by creosote related compounds from previous timber treatment operations at the property (Ref. 4, p. 9; Ref. 11, p. 3). Additionally, visual evidence reveals surface impact to the adjoining BNSF property and contiguous wetland stream bed area (Ref. 4, p. 9). The pathway of hardened creosote and underlying contaminated soils paralleling the east side of a one-track railroad spur owned by BNSF is approximately 400 feet long and 10-20 feet wide, and lies mostly within the BNSF 50-foot ROW from the track centerline (Ref. 14, pp. 1-2). The hardened creosote pathway appears to end at the point where an intermittent unnamed stream passes beneath the railroad spur from east to west (Ref. 14, pp. 1-2). The impact is visually apparent and has formed sections of asphaltic surficial patches (Ref. 8, p. 5).

The American Creosote DeRidder site, as scored, includes five sources: a concrete structure of a former retort house, a concrete foundation of a former vat, an unlined wastewater pit, aggregated areas of contaminated soil, and a pile of creosote solids (Ref. 7, pp. 38 & 40-43 Ref. 13, pp. 13 & 61-69). Contamination in the sources has been documented to include numerous hazardous substances, including total petroleum hydrocarbons (TPHs), numerous polycyclic aromatic hydrocarbons (PAHs), and metals (Ref. 7, pp. 38-48, 90-97, 222-226, 235-236 & 258-260). Metal and PAH surface water contamination is documented based on analyses of wetland sediment, surface water, and soil samples from the contiguous wetlands, the unnamed drainage ditch/stream area, railroad ROW, and tributary streams (Ref. 7, pp. 57-60, 64- 67, 90-97, 220-222, 226-237 & 336-341; Ref. 39, pp. 53-58, 64-65, 84- 88 & 180-236). Approximately 3,761 feet or 0.71 miles of contiguous wetland frontage is located within the zone of Level II contamination, and an estimated 29 miles of contiguous wetland frontage is located along the 15-mile target distance limit (TDL) outside of the zone of actual contamination (Figures 5 & 6). The surface water overland migration pathway is the pathway of concern being evaluated for this site. An observed release by chemical analysis has been documented to impact an unnamed drainage ditch/stream, an unnamed perennial stream, freshwater pond, and associated contiguous wetlands. Contaminates of Concern (COCs) for the surface water pathway include: acenaphthene, acenaphthylene, anthracene, arsenic, benzo (a) anthracene, benzo (a) pyrene, benzo (g,h,i) perylene, benzo (b) fluoranthene, benzo (k) fluoranthene, 1,1’-biphenyl, bis (2-ethylhexyl) phthalate, cadmium, carbazole, chromium, chrysene, cobalt, dibenzo (a,h) anthracene, dibenzofuran, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, lead, manganese, mercury, 1-methylnaphthalene, 2-methylnaphthalene, naphthalene, nickel, phenanthrene, pyrene, silver, thallium, and zinc.

FACILITY HISTORY

In 1991 the American Creosote DeRidder facility was entered into the Louisiana Department of Environmental Quality (LDEQ) Inactive and Abandoned Sites Division (IASD) (Ref. 14, p .1). LDEQ IASD contacted Westvaco, a company nearby that considered buying the property at the time, and had collected water and soil samples for analysis in February 1992 (Ref. 12, p. 2). Westvaco indicated to LDEQ IASD that the laboratory results showed low levels (< 5 parts per million [ppm]) of phenol contamination in the soils, with the water samples analyzed below detection limits for phenol (Ref. 12, p. 3; Ref. 15, p. 2; Ref. 16, p.1). During 1992 LDEQ IASD visited the property several times to assess

the location for contamination. During the site visit in October 1992, LDEQ IASD collected sediment samples from the pond and elevated levels, 0.5 to 1.08 percent, for eight of the target compound list (TCL) listed creosote constituents were detected (Ref. 17, p 2). Analytical results from the October 1992 samples collected detected high concentrations of PAHs per the West-Paine Laboratory results (Ref. 18, pp.17-18).

In 1993 LDEQ IASD completed a Phase I and Phase II State Site Assessment (SSA) and determined that high concentrations of creosote contamination were discovered in the unlined pit lying between the old Santa Fe (BNSF) railway track and the creosoting structure foundation (Ref. 12, p.3). Low level Total Phenols concentrations were also discovered in soil and surface water sampled surrounding the old foundation (Ref. 12, p. 3). LDEQ IASD moved to proceed with a Remedial Investigation/Feasibility Study (RI/FS) and Removal Action (RA) through a cooperative agreement with the responsible party identified at the time, CMC (Ref. 19, pp. 1-17). In October 1993 LDEQ IASD realized the contamination resided on two distinct properties, due to creosote contamination migrating from the former wood treatment facility to the adjacent property to the west (Ref. 8, p. 5). LDEQ IASD sent letters to the identified parties, Atchison, Topeka and Santa Fe Railway (ATSF), who owned the railway right-of way (ROW) corridor, and CMC who owned the property that held the former wood treating facility. In mid-1995 a cooperative agreement between LDEQ IASD, CMC and ATSF was entered into to perform interim measures as proposed in the Bio Pile Work Plan (Ref. 21, p. 2).

CMC, in cooperation with ATSF, from February 1994 to 1996 contracted with Louisiana State University, who prepared several versions of a bioremediation work plan to remediate the creosote contaminated soils at the site (Ref. 8, p. 5; Ref. 21, p. 5). The work plan proposed transporting contaminated soils to a soil pile remediation unit (SPRU) where the soils would be biologically treated (Ref. 21, p. 3). An approximate total of 1,250 cubic yards (yd3) of contaminated soil from the creosote wastewater holding pit and run-off contaminated soil adjacent to the Santa Fe railway ROW were proposed to be processed in the SPRU (Ref. 21, p. 5). In April 1994 in cooperation with ATSF, CMC personnel collected four samples of creosote material from the site for TPH analyses performed at the ATSF contracted laboratory, Radian Corporation (Ref. 21, p. 121). The four samples of tarry material were collected from the pit moving southwest toward the Santa Fe railway ROW (Ref. 21, p. 121). It was noted that the tarry material was only 1-2 inches thick and that the concentration of PAHs decreased when moving from the pit to the southwest location of the ROW at the Santa Fe railway corridor (Ref. 21, pp. 121 & 123). Laboratory results indicated TPH values that ranged from 2,040 to 44,700 milligram per kilogram (mg/kg) (Ref. 21, pp. 5 & 123).

By April 1996 the executed Cooperative Agreement between ATSF, CMC and LDEQ was dissolved, and ATSF (now BNSF) entered into its own cooperative agreement with LDEQ to begin its own soil remediation strategy (Ref. 8, p. 8). In mid-1996 Kei Consultants, hired by BNSF, submitted a Soil Remediation Work Plan to LDEQ IASD to address the railway corridor impacted by run-off creosote material associated with the adjacent former wood treatment facility, American Creosote DeRidder (Ref. 8). The estimated area of creosote impact to the BNSF railroad corridor extended 250 feet along the railway ROW and was approximately 20-25 feet wide (Ref. 8, p. 5). Impact from the former creosote operations to the adjacent property, was visually apparent by the surficial patches of asphalt that had formed (Ref. 8, p. 5). The noted contaminant of concern was TPH (Ref. 8, p. 8). The project objective was to excavate impacted soils from the BNSF property and transfer them to a suitable disposal site and perform site restoration at the excavated location (Ref. 8, p. 8). To date no remediation has taken place

along the railroad ROW.

In August 2002 Acadian Engineers & Environmental Consultant Inc. (Acadian), on behalf of CMC, performed a Limited Site Investigation at the American Creosote DeRidder site to delineate the horizontal and vertical extent of creosote contamination in order to determine potential remediation strategies (Ref. 11, p. 3). Acadian personnel collected soil samples from 25 locations placed across previously identified areas of impact, and 10 ground water samples from temporary ground water monitoring wells to assess the impact to shallow ground water (Ref. 11, pp. 5-7).

In September 2002 Acadian submitted a Voluntary Remedial Investigation (VRI) application to LDEQ IASD for the American Creosote DeRidder site (Ref. 22, pp. 3-8). The site was entered into the LDEQ Voluntary Remediation Program (VRP) on September 26, 2002 (Ref. 23, p. 1). The August 2002 Limited Site Investigation Work Plan represented CMC’s proposal to meet the site assessment requirements of the VRI application (Ref. 24, p. 1). Following LDEQ’s review of the August 2002 work plan and its meeting with Acadian staff, Acadian submitted a revised work plan to LDEQ Remediation Services Division (RSD) dated September 11, 2002 (Ref. 24, p .1). The work plan was approved as amended with the stipulation that Acadian would add sections to the work plan identifying and briefly describing the individual areas of concern (AOC) at the site (Ref. 24, p 1). In October 2002 Acadian submitted an Amended Limited Site Investigation Work Plan on behalf of CMC to LDEQ IASD detailing the four (4) primary AOCs to include: AOC 1 – Old Drip Area, AOC 2 – Wash Pit, AOC – 3 Ground Water, and AOC 4 – Surface Soils (Ref. 25, p. 6).

In late 2003 Acadian submitted a Voluntary Remedial Action Plan on behalf of CMC to LDEQ IASD to address the limited removal of impacted media (Ref. 4, pp. 6 & 10). The proposed methodology to address the impacted soil media was over-excavation of impacted areas and treatment of the impacted soil (Ref. 4, p. 18). No implementation of ground water remediation was required, yet continued monitoring was recommended (Ref. 4, p. 18). The limits of excavation proposed for the impacted soils were based on analytical results from soil samples collected from selected locations from within the identified following AOCs, and are described as follows (Ref. 4, pp. 11-15, 18 & 20-23):

• AOC #1 Old Railroad Spur – Five (5) soil samples were collected in AOC #1 and one (1) sample contained elevated levels of benzopyrene (sic) in excess of Risk Evaluation/Corrective Action (RECAP) screening standards for industrial soil (Ref. 4, pp. 11-12, 20-21 & 29). The proposed limits of excavation consisted of a 100 feet by 8 feet area to a two-foot depth, resulting in an in place volume of 59 yd3and an excavation/remediation volume of 77 yd3 (Ref. 4, pp. 21 & 33).

• AOC #2 Concrete Structure – Twelve (12) soil boring samples were collected within AOC #2 and three (3) contained elevated levels of benzopyrene (sic) in excess of RECAP screening standards for oil (Ref. 4, pp. 12-13, 21 & 30). The proposed limits of excavation consisted of approximately one (1) acre to a two (2) foot depth, resulting in a proposed excavation volume of 2,852 yd3 and an estimated 3,710 yd3 of soil to be remediated (Ref. 4, pp. 21 & 34).

• AOC #3 Abandoned Waste Pit – Two (2) soil boring samples were collected within AOC #3 and both contained elevated levels of benzopyrene (sic) (Ref. 4, pp. 14, 21-22 & 31). The proposed excavation consists of two separate excavation areas located within AOC #3 (Ref. 4, p. 22). The first proposed depth of excavation was until hard pan impacted soils are encountered beneath the

impacted media (Ref. 4, p. 22). The area of excavation is 3,300 square feet (ft2) and the depth is estimated at three feet resulting in a proposed excavated volume of 367 yd3 (Ref. 4 p. 22). The second proposed excavation is adjacent to the pit and consists of 7,710 cubic feet (ft3) of excavatable area to a depth of two feet resulting in a volume of 527 yd3 of proposed excavatable soil (Ref. 4, p. 22). The total proposed volume of excavation within AOC #3 is 894 yd3 and 1,162 yd3 of soil to be remediated (Ref. 4, pp. 22 & 35).

• AOC #4 Surface Soil – Samples from eight (8) soil borings were collected within AOC #4 and five revealed concentrations of benzopyrene (sic) in excess of RECAP screening standards for soil (Ref. 4 pp. 14-15, 22-23 & 32). The proposed excavation area consists of 35,700 ft2 (0.82 acres) at two feet depth resulting in a proposed excavation volume of 2,644 yd3 and 3,438 yd3 of soil to be remediated (Ref. 13, pp. 22-23 & 36).

The excavated soils were proposed to be remediated through biodegradation of the creosote related organic compounds (Ref. 4, pp. 23). Select microbes intended to remediate creosote related organic compounds would be used to inoculate and treat the impacted media (Ref. 4, p.25).

In 2005 CMC had Acadian submit a RECAP to LDEQ IASD (Ref. 6). The RECAP was performed within the concept of the Voluntary Remediation Program (VRP) to delineate the vertical and horizontal limits of the constituents of concern identified at the site (Ref. 6, p. 64). CMC proposed to perform the remediation and implement required institutional controls in accordance with LDEQ approval (Ref. 6, p. 88).

In April 2013 Acadian prepared and submitted a Corrective Action Plan (CAP) for the American Creosote site to LDEQ RSD (Ref. 26). The CAP was based upon the consideration that the creosote COCs upon the property are consistent with the topography, yet the limited pathways of exposure to the environment and others afford participation within the VRP (Ref. 26, p .5). It was the intention of the CAP and VRP to isolate and remediate the remaining source of potential impact at the CMC site (Ref. 26, p. 9). A solidification process was proposed to immobilize the source waste through solidification of residual weathered creosote remaining within the 7,500 square foot AOC, the total area to be remediated (Ref. 26, pp. 7-8 & 17). Acadian proposed placing restrictive use (future) covenants upon the property within the Beauregard Parish Property Records office and restricting access to the AOC and the adjacent abandoned creosote structure by erecting a six (6) foot galvanized chain link fence around the perimeter of the identified area (Ref. 26, p. 12). As of the date of this report no remediation has taken place at the American Creosote DeRidder site (Ref. 6, p. 11).

EPA conducted a Site Inspection (SI) at American Creosote DeRidder in June 2015 (Ref. 7, p. 22). Field operations during the SI included the collection of soil samples down to 15 feet below ground surface (bgs) to identify the source material and contamination at the site, of ground water samples to assess the migration of contamination in the ground water pathway, and of surface water samples and sediment samples to assess the migration of contamination in the surface water pathway (Ref 7, p. 69). Analytical data from the soil, ground water, and sediment samples indicated the presence of PAHs that exceeded background sample concentrations and met observed release criteria (Ref. 7, pp. 72-73). As in the proposed rule, observed releases may be established on either direct observation or chemical analysis of samples (Ref. 1, Sec. 4.1.2.1.1). In the case of direct observation, material containing hazardous substances must be seen entering the medium directly or must have been deposited in the medium (Ref.

1, Sec.4.1.2.1.1). An observed release is confirmed when a sample measurement equals or exceeds the sample quantitation limit and is at least three times above the background level, and available information attributes some portion of the release of the hazardous substance to the site (Ref. 1, Sec. 4.1.2.1.1).

During the May 2016 EPA Expanded Site Inspection (ESI) sediment and surface water samples were collected to identify and assess migration of contamination to the surface water pathway (Ref. 39, pp. 63 & 154-162). Analytical data from the surface water and sediment samples indicated the presence of PAHs that met the observed release criteria (Ref. 1, Sec. 4.1.2.1.1, Table 2-3, &; Ref. 39, pp. 64-65).

SO-Source Characterization

2.2 SOURCE CHARACTERIZATION

The sources evaluated at the American Creosote DeRidder site, for HRS purposes, are:

• Source 1: Concrete Structure (Other) • Source 2: Oil/Water Separator (Container) • Source 3: Unlined Wastewater Pit (Surface Impoundment, Not Buried/Backfilled) • Source 4: Aggregated Areas of Soil Contamination (Contaminated Soil) • Source 5: Creosote Solid (Pile)

SO-Source Characterization Source No.: 1

2.2.1 SOURCE IDENTIFICATION – SOURCE 1

The following information corresponds to the first source identified for this documentation record.

Number of source: 1

Name of source: Concrete Structure

Source Type: Other

Description and Location of Source: The concrete structure is located on the central western boundary of the property (Figure 2). The concrete structure is an abandoned surface structure that is a remnant of the former retort house basin that included the treatment cells and a sunken water retention basin, now dismantled tanks and vats, and creosote storage bins used in previous operations at the facility (Ref. 4, pp. 9, 12, 28 & 37; Ref. 6, pp. 64, 70 & 94; Ref. 7, pp. 139-144; Ref. 17, p. 2; Ref. 26, p. 5). Historically a retort house was built primarily to cover and protect the treating cylinders or retorts (Ref. 42, p. 1). In best construction it was made of steel, brick, or re-enforced concrete, although a wooden structure may have been used if minimum cost was desired (Ref. 42, p.1). At American Creosote DeRidder the retort house had a concrete foundation with 2.5 foot walls, and it is presumed that either a metal or wooden structure covered and protected the treating area below, since all that remains of the structure is the concrete foundation (Ref. 4, pp. 28 & 37; Ref. 7, pp. 38 & 139-144) To guard against loss of preservative due to leaks, or accident, the floor was sometimes made of solid concrete with appropriate drains to a sewer or underground tank, and depressed so that the level of the rails in the retorts would be the same as that of the outside tracks (Ref. 42, p. 1). At the former retort house at American Creosote this was observed and labeled the pit, or commonly referred to as the sunken water retention basin (Ref. 4, p. 38; Ref. 7, pp. 38 & 139-142). Additionally, the building was constructed so that free ventilation can be obtained to carry off the vapors which frequently arise during operations and to keep the temperature in the retort house from becoming oppressive to the workmen (Ref. 42, p. 1). Thus, it can again be presumed that the former retort house at American Creosote DeRidder had a wooden or metal structure that covered and protected the treating area.

The foundation of the old treatment unit retort vessel sits in heavy overgrowth approximately 150 feet east of a north/south Santa Fe railway spur and approximately 500 feet north of a railway culvert that receives storm water drainage from the area immediately around the old foundation (Ref. 7, pp. 139- 144; Ref. 21, pp. 5 & 120). The concrete structure that remains from the former retort house basin was considered part of the creosote processing facilities area, and an area of impact from previous facility operations (Ref. 6, pp. 65, 70 & 93-94; Ref. 7, pp. 143-144 & 170-172; Ref. 26, p. 5). A complete survey of the concrete structure was not completed during the EPA SI due to the amount of pine forest and thick shrub overgrowth (Ref. 7, p. 182). The approximate dimensions of the concrete structure from observations made during the EPA SI are 30 feet x 70 feet (Ref. 7, p. 182). There is approximately 24 inches of sediment deposited over time, along with abundant vegetative growth, within the remains of the contaminated concrete foundation of the former retort house structure (Ref. 7, pp. 139-144 & 181). Located within the concrete structure is a sunken pit with a concrete bottom, or commonly referred to as the water retention basin (Ref. 4, p. 37; Ref. 7, p. 182). The contaminated pit/water retention basin contains approximately five (5) feet of water that has accumulated over time, with no obvious sediment present at the bottom of the pit (Ref. 7, pp. 138-142 & 182).

SO-Source Characterization Source No.: 1

Based on a December 2003 Voluntary Remedial Action Plan prepared for the American Creosote DeRidder site by Acadian, the concrete structure, as indicated by historical figures was 155 feet in length, 30 feet in width and had a 2.5 foot high wall (Ref. 4, p. 37). As previously noted, a water retention basin was present within the concrete structure, and measured 10 feet in width, over 30 feet in length, and 7.5 feet deep (Ref. 4, pp. 24 & 37).

LDEQ stated in their Phase II State Site assessment that low level total phenol concentrations were discovered in soils and surface water sampled surrounding the old foundation (Ref. 12, p. 3). Additionally, in the Voluntary Remedial Action Plan the concrete structure, as indicated by historical mapping, was the location of the retort house (Ref. 4, p. 12; Ref. 6, pp. 70 & 93-94). The retort house was labelled an AOC by Acadian personnel and included as part of AOC #2, the wash pit area (Ref. 4, pp. 11-12, 28 & 30; Ref. 6, p. 65 & 94-114). AOC #2 had soil sampling performed to determine the horizontal and vertical extent of impact to the shallow soils (Ref. 4, pp. 11-12 & 30; Ref. 11, p. 3). Acadian personnel reported stained soils and residual weathered creosote within AOC #2 namely between the retort structure and the western boundary (Ref. 4, p. 13; Ref. 6, pp. 94-114, 147 & 163). Twelve (12) soil borings were performed within AOC #2, samples from three (3) of which revealed concentrations of benzopyrene (sic) in excess of RECAP screening standards for industrial soil standards; these are located to the west and south of the concrete structure (retort house) (Ref. 4, pp. 21, 30 & 42-76; Ref. 6, pp. 16-20, 26, 34, 37-41, 86, 94-114, 116 & 118-119).

Acadian’s proposed methodology for addressing the impacted soils around the concrete structure (retort house) was over-excavation of impacted areas and treatment of the impacted media (Ref. 4, p. 18). The proposed excavation within AOC #2 near the concrete structure (retort house) consisted of approximately one (1) acre at two (2) feet in depth resulting in a proposed excavation volume of 2,852 yd3, or 3,710 yd3 of soil to be remediated (Ref. 4, pp. 21 & 34). The excavated soils were proposed to be remediated through bio-degradation of the creosote related organic compounds (Ref. 4, p. 23). Soils from AOC #2 were to be placed within an earthen remediation cell adjacent to the concrete structure (Ref. 4, pp. 23 & 38). Select microbes intended to remediate creosote related organic compounds were to be used to inoculate and treat the impacted media (Ref. 4, p. 23).

A soil boring was advanced into the accumulated soil that is associated with the contaminated concrete structure using direct push technology at one (1) location within the confines of the structure walls during the June 2015 EPA SI (Ref. 7, pp. 23, 38 & 84). The boring was advanced to a maximum depth of 15 feet bgs using the procedure in the EPA Environmental Response Team (ERT) Standard Operating Procedure (SOP) 2012, modified for the actual unit used by the driller (Ref. 7, pp. 23, 181, 436-449). Grab soil samples were collected from each boring, from intervals of visual contamination or where photoionization detector (PID) readings for VOCs above background were detected (Ref. 7, p. 23-24, 394, 436-449). One (1) soil sample was collected from within the confines of the concrete structure at location AC25 from the 0-2 feet bgs interval (Ref. 7, pp. 38, 84, 537, 548 & 553; Figure 3).

A background soil sample, ACS01, was collected approximately 32 feet south of Post Plant Road and approximately 80 feet west of the railroad tracks (Ref. 7, pp. 36 & 84). The background sample location ACS01 is up gradient relative to ground water flow (Ref. 7, pp. 36 & 80). The background soil sample was collected using similar collection methods, and from a location where no designated operations were known to have taken place (Ref. 7, pp. 36-37; Ref. 6, pp. 93-94). Background soil samples were

SO-Source Characterization Source No.: 1

collected from four (4) intervals at either two (2) foot or three (3) foot intervals, as follows (Ref. 7, pp. 36-37):

• ACS01-02 (0-2 feet bgs) • ACS01-58 (5-8 feet bgs) • ACS01-25 (2-5 feet bgs) • ACS01-10 (8-10 feet bgs)

Soil samples were analyzed for TCL semi-volatile organic compounds (SVOCS) by EPA Contract Laboratory Program (CLP) Statement of Work (SOW) SOM02.2, and soil samples were also analyzed for Target Analyte List (TAL) inorganic total metals/mercury by EPA CLP SOW ISM02.2. Organic analyses were performed by KAP Technologies Inc. located in The Woodlands, Texas, and inorganic analysis were performed by Chemtech Consulting Group located in Mountainside, New Jersey. All data from analyses performed at KAP Technologies Inc. and Chemtech Consulting Group were reviewed and validated by the Houston EPA Laboratory (Ref. 7, pp. 27, 69-70, 265-266 & 356-357).

The soil sample results from within the concrete structure source area were compared to the concentrations in the corresponding foot interval from the background soil sample (Table 1). PAHs such as 1,1'-biphenyl, 2-methylnaphthalene, acenaphthene, acenaphthylene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (k) fluoranthene, carbazole, chrysene, dibenzo (a,h) anthracene, dibenzofuran, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, naphthalene, phenanthrene and pyrene were detected above background levels (Ref. 7, pp. 39, 94 & 265-266; Tables 1 & 2). While the increases in concentration are not required to associate the substance with the source, the levels detected in the soil samples are above background.

Metal concentrations were also detected in the 0-2 feet bgs soil sample to include arsenic, cadmium, cobalt, copper, lead, manganese, mercury, nickel and zinc at greater than background levels (Ref. 7, pp. 39, 94 & 356-357; Table 1 & 2). Again, while these increases in concentration are not required to associate the substances with the source, it does demonstrate the levels in the soil sample are significantly above background.

Additionally, a sample was collected by the Superfund Technical Assessment and Response Team (START) contractor, during the June 2015 EPA SI, from accumulated waste water that was associated with the contaminated wastes of the pit/sunken water retention basin in the foundation of the contaminated concrete structure (Ref. 7, p. 38). Waste water sample ACSW-06 was collected directly into sample containers and shipped to KAP Technologies Inc. located in The Woodlands, Texas, for organic analysis, and Chemtech Consulting Group located in Mountainside, New Jersey, for inorganic analysis. The waste water sample was analyzed for SVOCs by EPA CLP SOW SOM02.2 and for inorganic metals/mercury by EPA CLP SOW ISM02.2. All data from analyses performed at KAP Technologies Inc. and Chemtech Consulting Group were reviewed and validated by the Houston EPA Laboratory (Ref. 7, pp. 27, 69-70, 300-301 & 357-359).

Waste water sample ACSW-06 contained metals that included: arsenic, manganese, and zinc at concentrations equal to or greater than their corresponding adjusted contract required quantitative limits (ADJ CRQLs) (Ref. 7, pp. 39, 97 & 357; Table 3).

SO-Source Characterization Source No.: 1

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

The substances listed in Tables 2 and 3 are associated with Source No. 1 based on analytical results from a soil sample collected from within the concrete structure walls, and a waste water sample collected from the pit/sunken water retention basin in the foundation of the concrete structure during the June 2015 American Creosote DeRidder SI (Ref. 7, pp. 94, 97, 265-266, 300-301 & 356-357). Sampling was conducted following the procedures set forth in the Quality Assurance Sampling Plan (QASP) (Ref. 7, pp. 416-423).

PAHs such as 1,1'-biphenyl, 2-methylnaphthalene, acenaphthene, acenaphthylene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (k) fluoranthene, carbazole, chrysene, dibenzo (a,h) anthracene, dibenzofuran, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, naphthalene, phenanthrene and pyrene were detected in the soil sample collected from within the concrete structure walls (Ref. 7, pp. 94 & 265-266; Tables 1 & 2).

Also, numerous metals such as arsenic, cadmium, cobalt, copper, lead, manganese, mercury, nickel and zinc were detected in the soil sample collected from within the concrete structure walls, and the waste water sample collected from the pit/sunken water retention basin in the foundation of the concrete structure (Ref. 7, pp. 94, 97, 300-301 & 356-359; Tables 1 & 2).

SO-Source Characterization Source No.: 1 Table 1 – Background Soil Samples

S am ple Num be r: ACS0 1 -02 ACS0 1 -25 ACS0 1 -58 ACS0 1 -10 EPA Sample Number: F9DA0/MF9DA0 F9DA1/MF9DA1 F9DB9/MF9DB9 F9DE0/MF9DE0 Sample Location: AC01 AC01 AC01 AC01 S am ple Des cri pti on Background Background Background Background S am ple De pth 0 - 2 feet int erval 2 - 5 feet int erval 5 - 8 feet int erval 8 - 10 feet interval Bkgd - ADJ CRQL Bkgd - ADJ CRQL Bkgd - ADJ CRQL Bkgd - ADJ CRQL Result ADJ Result ADJ Result ADJ Result ADJ Flag or 3x Result Flag or 3x Result Flag or 3x Result Flag or 3x Result (µg/kg) CRQL (µg/kg) CRQL (µg/kg) CRQL (µg/kg) CRQL (µg/kg) (µg/kg) (µg/kg) (µg/kg) ANALYTE: SVOCs 1,1'-Biphenyl 200 U 200 200 (ADJ CRQL) 200 UJ 200 200 (ADJ CRQL) 180 U 180 180 (ADJ CRQL) 220 U 220 220 (ADJ CRQL) 2-Methylnaphthalene 200 UJ 200 200 (ADJ CRQL) 200 UJ 200 200 (ADJ CRQL) 180 UJ 180 180 (ADJ CRQL) 220 U 220 220 (ADJ CRQL) 2-Methylphenol 390 UJ 390 390 (ADJ CRQL) 390 UJ 200 200 (ADJ CRQL) 350 UJ 350 350 (ADJ CRQL) 430 U 430 430 (ADJ CRQL) 3,3'-Dichlorobenzidine 390 U 390 390 (ADJ CRQL) 390 UJ 390 390 (ADJ CRQL) 350 U 350 350 (ADJ CRQL) 430 U 430 430 (ADJ CRQL) 3-Nitroaniline 390 U 390 390 (ADJ CRQL) 390 UJ 390 390 (ADJ CRQL) 350 U 350 350 (ADJ CRQL) 430 U 430 430 (ADJ CRQL) Acenaphthene 200 U 200 200 (ADJ CRQL) 200 UJ 200 200 (ADJ CRQL) 180 U 180 180 (ADJ CRQL) 220 U 220 220 (ADJ CRQL) Acenapht hylene 200 U 200 200 (ADJ CRQL) 200 UJ 200 200 (ADJ CRQL) 180 U 180 180 (ADJ CRQL) 220 U 220 220 (ADJ CRQL) Anthracene 200 U 200 200 (ADJ CRQL) 200 UJ 200 200 (ADJ CRQL) 440 180 1,320 (3x Result) 220 U 220 220 (ADJ CRQL) Benzaldehyde 390 U 390 390 (ADJ CRQL) 390 UJ 390 390 (ADJ CRQL) 350 U 350 350 (ADJ CRQL) 430 U 430 430 (ADJ CRQL) Benzo (a) anthracene 200 U 200 200 (ADJ CRQL) 200 UJ 200 200 (ADJ CRQL) 180 U 180 180 (ADJ CRQL) 220 U 220 220 (ADJ CRQL) Benzo (a) pyrene 200 UJ 200 200 (ADJ CRQL) 310 (3,100)* J 200 930 (9,300)* (3x Result ) 110 (1,100)* LJ 180 330 (3,300)* (3x Result) 220 U 220 220 (ADJ CRQL) Benzo (b) fluoranthene 200 UJ 200 200 (ADJ CRQL) 190 (1,900)* LJ 200 570 (5,700)* (3x Result) 170 (1,700)* LJ 180 510 (5,100)* (3x Result) 140 (1,400)* LJ 220 420 (4,200)* (3x Result ) Benzo (g,h,i) perylene 200 UJ 200 200 (ADJ CRQL) 280 (2,800)* J 200 840 (8,400)* (3x Result ) 180 UJ 180 180 (ADJ CRQL) 220 U 220 220 (ADJ CRQL) Benzo (k) fluoranthene 200 U 200 200 (ADJ CRQL) 320 (3,200)* J 320 960 (9,600)* (3x Result ) 180 180 540 (3x Result) 220 U 220 220 (ADJ CRQL) Bis (2-ethylhexyl) phthalate 200 U 200 200 (ADJ CRQL) 200 UJ 200 200 (ADJ CRQL) 180 U 180 180 (ADJ CRQL) 120 (1,200)* LJ 220 360 (3,600)* (3x Result) Carbazole 390 U 390 390 (ADJ CRQL) 390 UJ 390 390 (ADJ CRQL) 350 U 350 350 (ADJ CRQL) 430 U 430 430 (ADJ CRQL) Chrysene 200 U 200 200 (ADJ CRQL) 200 UJ 200 200 (ADJ CRQL) 120 (1,200)* LJ 180 360 (3,600)* (3x Result) 220 U 220 220 (ADJ CRQL) Dibenzo (a,h) anthracene 200 UJ 200 200 (ADJ CRQL) 200 UJ 200 200 (ADJ CRQL) 180 UJ 180 180 (ADJ CRQL) 220 U 220 220 (ADJ CRQL) Dibenzofuran 200 U 200 200 (ADJ CRQL) 200 UJ 200 200 (ADJ CRQL) 180 U 180 180 (ADJ CRQL) 220 U 220 220 (ADJ CRQL) Fluoranthene 390 U 390 390 (ADJ CRQL) 390 UJ 390 390 (ADJ CRQL) 230 (2,300)* LJ 350 690 (6,900)* (3x Result) 430 U 430 430 (ADJ CRQL) Fluorene 200 U 200 200 (ADJ CRQL) 200 UJ 200 200 (ADJ CRQL) 180 U 180 180 (ADJ CRQL) 220 U 220 220 (ADJ CRQL) Indeno (1,2,3-cd) pyrene 200 U 200 200 (ADJ CRQL) 320 (3,200)* J 200 960 (9,600)* (3x Result ) 180 U 180 180 (ADJ CRQL) 220 U 220 220 (ADJ CRQL) Naphthalene 200 UJ 200 200 (ADJ CRQL) 200 UJ 200 200 (ADJ CRQL) 180 UJ 180 180 (ADJ CRQL) 220 U 220 220 (ADJ CRQL) Phenanthrene 200 U 200 200 (ADJ CRQL) 200 UJ 200 200 (ADJ CRQL) 140 (1,400)* LJ 180 420 (4,200)* (3x Result) 220 U 220 220 (ADJ CRQL) Pyrene 200 U 200 200 (ADJ CRQL) 200 UJ 200 200 (ADJ CRQL) 160 (1,897.6)* LJ 180 480 (5,692.8)* (3x Result) 220 U 220 220 (ADJ CRQL) ANALYTE: TO TAL METALS Bkgd - ADJ CRQL Bkgd - ADJ CRQL Bkgd - ADJ CRQL Bkgd - ADJ CRQL Result ADJ Result ADJ ADJ CRQL ADJ Result ADJ Flag or 3x Result Flag or 3x Result Flag or 3x Result Flag or 3x Result (mg/kg) CRQL (mg/kg) CRQL (mg/kg) CRQL mg/kg CRQL (mg/kg) (mg/kg) (mg/kg) (mg/kg) Antimony 0.89 U 0.89 0.89 (ADJ CRQL) 0.8 U 0.8 0.8 (ADJ CRQL) 0.98 0.98 2.94 (3x Result ) 0.027 U 0.82 0.82 (ADJ CRQL) Arsenic 2.4 0.44 7.2 (3x Result) 2 0.4 6 (3x Result) 1.1 (1.1)** J+ 0.49 3.3 (3.3)** (3x Result) 6.4 0.41 19.2 (3x Result ) Cadmium 0.44 U 0.44 0.44 (ADJ CRQL) 0.4 U 0.4 0.4 (ADJ CRQL) 0.49 U 0.49 0.49 (ADJ CRQL) 0.41 U 0.41 0.41 (ADJ CRQL) Chromium 10.3 0.89 30.9 (3x Result) 10.3 0.8 30.9 (3x Result) 2.7 0.98 8.1 (3x Result) 4.2 0.82 12.6 (3x Result) Cobalt 0.82 0.44 2.46 (3x Result ) 1.1 0.4 3.3 (3x Result) 0.84 0.49 2.52 (3x Result ) 1.2 0.41 3.6 (3x Result) Copper 3.7 0.89 11.1 (3x Result) 3.7 0.8 11.1 (3x Result) 1.4 0.98 4.2 (3x Result) 1.5 0.82 4.5 (3x Result) Lead 12.8 0.44 38.4 (3x Result ) 5.9 0.4 17.7 (3x Result) 4.7 0.49 14.1 (3x Result) 5.3 0.41 15.9 (3x Result) Manganese 18.9 1.3 56.7 (3x Result) 6.3 1.3 18.9 (3x Result) 3.9 1.5 11.7 (3x Result) 2.3 1.2 6.9 (3x Result) Mercury 0.02 (0.04)* LJ 0.11 0.06 (0.12)* (3x Result ) 0.12 U 0.12 0.12 (ADJ CRQL) 0.12 U 0.12 0.12 (ADJ CRQL) 0.11 U 0.11 0.11 (ADJ CRQL) Nickel 1.4 0.44 4.2 (3x Result) 1.8 0.4 5.4 (3x Result) 0.96 0.49 2.88 (3x Result ) 1.2 0.41 3.6 (3x Result) Silver 0.44 U 0.44 0.44 (ADJ CRQL) 0.4 U 0.4 0.4 (ADJ CRQL) 0.49 U 0.49 0.49 (ADJ CRQL) 0.41 U 0.41 0.41 (ADJ CRQL) Thallium 0.44 U 0.44 0.44 (ADJ CRQL) 0.4 U 0.4 0.4 (ADJ CRQL) 0.49 U 0.49 0.49 (ADJ CRQL) 0.41 U 0.41 0.41 (ADJ CRQL) Zinc 7.7 0.89 23.1 (3x Result) 3.7 0.8 11.1 (3x Result) 1.3 0.98 3.9 (3x Result) 1.8 0.82 5.4 (3x Result) K EY Bkgd - Background U - Not det ected at report ed quant it at ion limit ADJ CRQL - Adjust ed contract required quant it at ion limit J - Est imat ed value µg/kg - Concentrat ion in microgram per kilogram L -Report ed concent rat ion is below the contract required quant it at ion limit (CRQL) mg/Kg - Concentration in milligram per kilogram + - High biased. Actual concentration may be lower than the concentration reported Bol d - det ect ed above adjust ed contract required quant it at ion limit (CRQL) UJ - Estimated quantitation limit * - The det ect ed concent rat ion was adjust ed by using gui dance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8 & 14-15). After adjusting the value for the qualified data, the adjusted value has increased significantly from the original value reported. Although not required by t he HRS or fact sheet , qualified dat a are adjust ed to demonstrat e the relative increase in contamination. ** - The det ect ed concentrat ion was adjust ed by using guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8 & 18). Aft er adjust ing the value for the qualified data, the adjusted value remains as the original value reported. Although not required by the HRS or fact sheet, qualified data are adjusted to demonstrate the relative increase in contamination. Note: Unless otherwise flagged, bia s on adjust ed “J” data result s is unknown and treat ed as such. REF ER ENC ES Chain of Cust ody Ref. 7, p. 246 & 344 Ref. 7, p. 247 & 345 Ref. 7, pp. 249 & 362 Ref. 7, p. 249 & 363 Laborat ory Result s Ref. 7, pp. 218-219, 338 & 340-341 Ref. 7, pp. 219-220, 335, 339 & 341 Ref. 7, pp. 239-240, 355 & 358 Ref. 7, pp. 268-269, 357 & 358-359 Ref. 7, pp. 213-214, 217-219, 330-331, 334, 338 & 340- Ref. 7, pp. 213-214, 217, 219-220, 330-331, 334-335, 339 & Ref. 7, pp. 213-214, 217, 239-340, 350-351, 354-355 & 358; Ref. 7, pp. 253-254, 257, 268-269, 350-351, 354, 357 & 358- Data 341; Ref. 27, pp. 8 & 18; Ref. 45, pp. 1-5 & 199-201 341; Ref. 27, pp. 8 & 14-15; Ref. 45, pp. 6-10 & 202-204 Ref. 27, pp. 8, 14-15 & 18; Ref. 45, pp. 92-96 & 235-237 359; Ref .27, pp. 8 & 14; Ref. 45, pp. 179-183 & 268-270 33

SO-Source Characterization Source No.: 1

Table 2 – Source 1 – Concrete Structure

Sample Number: ACS25-06 EPA Sample Number: F9DC7/MF9DC7 Sample Location: AC25 Sample Description Soil Inside Concrete Structure Sample Depth 0 - 2 foot interval Bkgd ( ACS01-02) Result ADJ CRQL ADJ CRQL Flag (µg/kg) (µg/kg) or 3x Result (µg/kg) ANALYTE: SVOCs 1,1'-Biphenyl 6,500 2,000 200 (ADJ CRQL) 2-Methylnaphthalene 40,000 (4,000)* J 2,000 200 (ADJ CRQL) Acenaphthene 12,000 200 200 (ADJ CRQL) Acenaphthylene 7,700 2,000 200 (ADJ CRQL) Anthracene 20,000,000 3,900,000 200 (ADJ CRQL) Benzo (a) anthracene 5,400,000 3,900,000 200 (ADJ CRQL) Benzo (a) pyrene 3,300,000 (3,300,000)* LJ 3,900,000 200 (ADJ CRQL) Benzo (b) fluoranthene 4,500,000 3,900,000 200 (ADJ CRQL) Benzo (g,h,i) perylene 43,000 (4,300)* J 2,000 200 (ADJ CRQL) Benzo (k) fluoranthene 5,100,000 3,900,000 200 (ADJ CRQL) Carbazole 6,700,000 (6,700,000)* LJ 3,900,000 390 (ADJ CRQL) Chrysene 7,100,000 3,900,000 200 (ADJ CRQL) Dibenzo (a,h) anthracene 23,000 2,000 200 (ADJ CRQL) Dibenzofuran 45,000 (4,500)* J 2,000 200 (ADJ CRQL) Fluoranthene 16,000,000 7,700,000 390 (ADJ CRQL) Fluorene 110,000 (11,000)* J 2,000 200 (ADJ CRQL) Indeno (1,2,3-cd) pyrene 53,000 (5,300)* J 2,000 200 (ADJ CRQL) Naphthalene 30,000 2,000 200 (ADJ CRQL) Phenanthrene 8,000,000 3,900,000 200 (ADJ CRQL) Pyrene 13,000,000 3,900,000 200 (ADJ CRQL) ANALYTE: TOTAL METALS Bkgd (ACS01-02) Result ADJ CRQL ADJ CRQL Flag (mg/kg) (mg/kg) or 3x Result (mg/kg) Arsenic 18.2 (10.46)* J 0.46 7.2 (3x Result) Cadmium 1.6 0.46 0.44 (ADJ CRQL) Cobalt 2.8 0.46 2.46 (3x Result) Copper 68.2 0.93 11.1 (3x Result) Lead 204 0.46 38.4 (3x Result) Manganese 784 1.4 56.7 (3x Result) Mercury 28.3 3 0.06 (0.12)** (3x Result) Nickel 8.8 0.46 4.2 (3x Result) Thallium 0.68 (0.37)* J+ 0.46 0.44 (ADJ CRQL) Zinc 180 0.93 23.1 (3x Result) KEY Bkgd - Background ADJ CRQL - Adjusted contract required quantitation lim it µg/kg - Concentration in microgram per kilogram mg/kg - Concentration in milligram per kilogram Bold - Concentration detected is elevated above background adjusted contract required quantitation lim it (CRQL). J - Estimated Value L - Reported concentration is below the contract required quantitation limit (CRQL) + - High biased. Actual Concentration is lower than the concentration reported * - The detected concentration was adjusted by using guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8, 13-15 & 18). After adjusting the value for the qualified data, the adjusted value remained as the original value reported or decreased significantly from the original value reported. Although not required by the HRS or fact sheet, qualified data are adjusted to demonstrate the relative increase in contamination over background. ** - The detected concentration was adjusted by using guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8 & 18). After adjusting the value for the qualified data, the adjusted value remains as the original value reported. Although not required by the HRS or fact sheet, qualified data are adjusted to demonstrate the relative increase in contamination. Note; Unless otherwise flagged, bias on adjusted “J” data results is unknown and treated as such. REFER ENC ES Chain of Custody Ref. 7, pp. 249 & 363 Laboratory Results Ref. 7, pp. 265-266, 356-359 Ref. 7, pp. 253-254, 257, 265-266, 350-351, 354 & 356-359; Ref. 27, pp. 8, 13-15 & 18; Data Ref. 45, pp. 159-168 & 256-258

SO-Source Characterization Source No.: 1

Table 3 – Source 1 – Pit within the Concrete Structure

Sample Number: ACSW-06 EPA Sample Number: F9DC9/MF9DC9 Sampling Location: AC06 Water From the Pit Inside the Concrete Sample Description Structure Result ADJ CRQL Flag (µg/L) (µg/L) ANALYTE: Metals Arsenic 3.7 1 Manganese 58.2 15 Zinc 8.3 (6.43)* J 2 KEY ADJ CRQL -Adjusted contract required quantitation limit µg/L - Concentration in micrograms per liter Bold - Concentration is detected above contract required quantitation limit (CRQL) J - Estimated Value * - The detected concentration was adjusted by using guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8 & 18). After adjusting the value for the qualified data, the adjusted value has decreased significantly from the original value reported. Although the results are qualified as estimated, the presence of the analytes is not in question. Note: Unless otherwise flagged, bias on adjusted “J” data results is unknown and treated as such. REFERENCES Chain of Custody Ref. 7, pp. 313 & 363 Laboratory Reports Ref. 7, pp. 300-301 & 357 -359 Ref. 7, pp. 295-296, 299-301, 350-351, Data 354, 357-359; Ref. 27, pp. 8 & 18; Ref .45, pp. 184-188 & 262-264

SO-Source Characterization Source No.: 1

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

Containment

Gas release to air: The air migration pathway was not scored; therefore, gas release to air containment was not evaluated.

Particulate release to air: The air migration pathway was not scored; therefore, particulate containment was not evaluated.

Release to ground water: The ground water pathway was not scored; therefore, ground water containment was not evaluated.

Release via overland migration: There is no evidence that the concrete structure of the former retort house had any containment features when in operation (Ref. 6, pp. 93-94). There is no historical data to indicate that site operations included waste handling, disposal practices, or facility permits (Ref. 4, p. 8; Ref. 12, p. 1; Ref. 26, p. 4). There is evidence of hazardous substance migration from Source No.1, to include the source itself the concrete structure, and the associated contaminated soil and waste water that has accumulated over time within the confines of the concrete structure and is in direct contact with the remaining concrete walls and pit/sunken water retention basin in the foundation of the structure (Ref. 6, pp. 70, 93-94 & 143). The containment factor value for Source No. 1 is 10 due to no observed maintained engineered cover or functioning and maintained run-on control system and runoff management system (Ref. 1, Table 4-2).

Because containment for this source is greater than zero, the following substances associated with the source can migrate via the Surface Water Migration Pathway (Ref. 1, Sec. 4.1.2.1.2.1.1):

• 1,1'-Biphenyl • Copper • 2-Methylnaphthalene • Dibenzo (a,h) anthracene • Acenaphthene • Dibenzofuran • Acenaphthylene • Fluoranthene • Anthracene • Fluorene • Arsenic • Indeno (1,2,3-cd) pyrene • Benzo (a) anthracene • Lead • Benzo (a) pyrene • Manganese • Benzo (b) fluoranthene • Mercury • Benzo (k) fluoranthene • Naphthalene • Cadmium • Nickel • Carbazole • Phenanthrene • Chrysene • Pyrene • Cobalt • Zinc

SO-Source Characterization Source No.: 1

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1.1. Hazardous Constituent Quantity – Tier A

The total Hazardous Constituent Quantity for Source 1 could not be adequately determined according to the HRS requirements; that is, the total mass of all CERCLA hazardous substances in the source and releases from the source is not known and cannot be estimated with reasonable confidence (Ref. 1, Sec. 2.4.2.1.1). Insufficient historical and current data (manifests, potentially responsible party [PRP] records, State records, permits, waste concentration data, etc.) are not available to adequately calculate the total or partial mass of all CERCLA hazardous substances in the source and the associated releases from the source. Therefore, there is insufficient information to calculate a total or partial Hazardous Constituent Quantity estimate for Source 1 with reasonable confidence. Scoring proceeds to the evaluation of Tier B, Hazardous wastestream quantity (Ref. 1, Section 2.4.2.1.1).

Hazardous Constituent Quantity Value (S): Not Calculated Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.2. Hazardous Wastestream Quantity – Tier B

The total Hazardous Wastestream Quantity for Source 1 could not be adequately determined according to the HRS requirements; that is, the total mass of all hazardous waste streams and CERCLA pollutants and contaminants for the source and releases from the source are not known and cannot be estimated with reasonable confidence (Ref. 1, Sec. 2.4.2.1.2). Insufficient historical and current data (manifests, potentially responsible party [PRP] records, State records, permits, waste concentration data, annual reports, etc.) are not available to adequately calculate the total or partial mass of all hazardous waste streams and CERCLA pollutants and contaminants for the source and the associated releases from the source. Therefore, there is insufficient information to adequately calculate or extrapolate a total or partial Hazardous Wastestream Quantity estimate for Source 1 with reasonable confidence. Scoring proceeds to the evaluation of Tier C, Volume (Ref. 1, Section 2.4.2.1.2).

Hazardous Wastestream Quantity Value (W): Not Calculated Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.3. Volume – Tier C

The concrete structure is an abandoned surface structure that is a remnant of the former retort house basin from previous operations at the facility (Ref. 4, pp. 9, 12 & 28; Ref. 6, pp. 64, 70 & 94; Ref. 7, pp. 143-144; Ref. 26, p. 17). The concrete structure that remains from the former retort house basin was considered part of the creosote processing facilities area (Ref. 6, pp. 65, 70 & 93; Ref. 7, pp. 143-144 & 170-172). A complete survey of the concrete structure was not completed during the EPA SI due to the amount of pine forest and thick shrub overgrowth (Ref. 7, p. 182). The approximate dimensions of the concrete structure from observations made during the EPA SI are 30 feet x 70 feet (Ref. 7, p. 182). There are approximately 24 inches of sediment on the top of the concrete (Ref. 7, p. 181). Located

SO-Source Characterization Source No.: 1

within the concrete structure is a pit with a concrete bottom (Ref. 7, p. 182). The pit contains approximately five (5) feet of water, and no sediment is present (Ref. 7, pp. 138-142 & 182).

Based on a December 2003 Voluntary Remedial Action Plan prepared for the American Creosote DeRidder site by Acadian, the concrete structure, as indicated by historical figures, was 155 feet in length, 30 feet in width and 2.5 feet deep (Ref. 4, p. 37). A water retention basin was present within the concrete structure, and measured 10 feet in width, over 30 feet in length, and 7.5 feet deep (Ref. 4, pp. 24 & 37).

Using a conservative estimate for the source area of the concrete structure of the former retort house basin of 30 feet in width x 70 feet in length x 2 feet deep, it occupied approximately 4,200 ft3 (Ref. 7, p. 181-182). The evaluation equation applied for the conversion of cubic feet (ft3) to cubic yards (yds3) is 1 yd3 = 27 ft3. The estimated capacity of the concrete structure is 155.56 yd3.

4,200 cubic feet (ft3) x (1 cubic yard (yd3) ÷ 27 cubic feet (ft3)) = 155.56 yd3

The hazardous waste quantity evaluation equation for source type other is V/2.5 (Ref. 1, Table 2-5). The source volume will be assigned a volume hazardous waste quantity value of 62.22.

155.56 yd3 ÷ 2.5 = 62.22

Volume of source No. 1 (yd3): 155.56 Reference(s): Ref. 1, Table 2-5 Volume Assigned Value: 62.22

2.4.2.1.4. Area – Tier D

Tier D, Area, is not applicable for source type other (Ref. 1, Sec. 2.4.2.1.3 and 2.4.2.1.4).

Area of Source No. 1 in square feet (ft2): Not Applicable Area Assigned Value: 0 References: Ref. 1, Sec. 2.4.2.1.4

2.4.2.1.5. Source Hazardous Waste Quantity Value

Source No. 1, Concrete Structure

Surface Water, Ground Water and Measures Air Pathways Tier A NC Tier B NC Tier C 62.22 Tier D 0 Assigned Source Hazardous 62.22 Waste Quantity Value (Ref. 1, Sec. 2.4.2.1.5)

SO-Source Characterization Source No.: 1

NC: Not Calculated

The highest value assigned to either Tier A, Tier B, Tier C, or Tier D is assigned as the Source No. 1 Hazardous Waste Quantity Value (Ref. 1, Sec. 2.4.2.1.5). The highest value assigned is Tier C.

Source No. 1 Hazardous Waste Quantity Value: 62.22

SO-Source Characterization Source No.: 2

2.2.1 SOURCE IDENTIFICATION – SOURCE 2

The following information corresponds to the second source identified for this documentation record.

Number of source: 2

Name of source: Oil/Water Separator

Source Type: Tanks/Containers other than Drums

Description and Location of Source: The oil/water separator is located just northwest of and in close proximity to the concrete structure (Figure 2; Ref. 6, pp. 93-94). Generally the oil/water separator received discharged sludges from work tank/storage tanks (Ref. 43, p. 3). Wastewater contaminated by oil/preservative solutions and sludges were discharged to a tank where oil/water separation took place (Ref. 43, pp. 3-4). The oil/water separation process treated effluent generated after completion of the wood treating process (Ref. 43, p. 4). At the American Creosote DeRidder facility the oil water separator is present in close proximity to the concrete structure, the former retort house, in order to receive discharge from the creosote processing (Figure 2). Although no water is intentionally added to the wood treating process, a substantial amount of water is release from the wood itself during hot oil/preservative solution steeping (Ref. 43, p. 4). Some of this wastewater is emitted to the air as stream during the steeping process, and some is entrained in the preservative solution or settles to the bottom of the wood treating tank (Ref. 43, p. 4). The oil/water separator receives contaminated wastewater effluent directly from the treating tank (Ref. 43, p. 4). Additionally, common practice may have been to add the bottom sludges from the storage tanks/work tanks to the oil/water separator (Ref, 43, p. 4).

The oil/water separator is a concrete structure and measures approximately 25 feet in length, five (5) feet across with a center wall at approximately two and a half (2.5) feet (Ref. 7, p. 181; Ref. 13, pp. 13, 19, 61-66 & 76-77). The concrete structure of the oil/water separator is completely covered in creosote- contaminated solids and contains stagnant water and approximately 5 -10 feet of vegetation from the surface to the bottom of the oil/water separator (Ref. 7, pp. 135, 173 & 181; Ref. 13, pp. 13, 61-66 & 76- 77). The oil/water separator is an abandoned concrete surface foundation structure that is a remnant of the former retort house basin from previous operations at the facility (Ref. 4, pp. 9, 12 & 28; Ref. 6, pp. 64, 70 & 94; Ref. 7, p. 135 & 173). The concrete structure that remains from the former retort house basin was considered part of the creosote processing facilities area, and an area of impact from previous facility operations (Ref. 6, pp. 65, 70 & 93-94; Ref. 7, pp. 135 & 173).

A waste water sample was collected from within the contaminated oil/water separator during the June 2015 EPA SI (Ref. 7, pp. 40 & 135). Waste water sample ACSW-04 was collected using a peristaltic pump with dedicated tubing, and low flowed directly into sample containers (Ref. 7, p. 135). The waste water sample was shipped to KAP Technologies Inc. located in The Woodlands, Texas, for organic analyses, and Chemtech Consulting Group located in Mountainside, New Jersey, for inorganic analyses (Ref. 7, p. 27). The waste water sample was analyzed for SVOCS by EPA CLP SOW SOM02.2, and for inorganic metals/mercury by EPA CLP SOW ISM02.2 (Ref. 7, pp. 25-27). All data from analyses performed at KAP Technologies Inc. and Chemtech Consulting Group were reviewed and validated by the Houston EPA Laboratory (Ref. 7, pp. 27, 69-70, 301-302 & 357-359).

SO-Source Characterization Source No.: 2

Waste water sample ACSW-04 contained elevated levels of PAHs including 1,1'-biphenyl, 2,4- dimethylphenol, 2-methylnaphthalene, 4-methylphenol, acenaphthene, anthracene, benzo (a) anthracence, benzo (a) pyrene, benzo (b) fluoranthene, benzo (g,h,i) perylene, benzo (k) fluoranthene, carbazole, chrysene, dibenzofuran, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, naphthalene, phenanthrene and pyrene in concentrations equal to or greater than their corresponding ADJ CRQLs (Ref. 7, pp. 40, 97 & 301-302; Table 4).

Metal concentrations for arsenic, cadmium, chromium, cobalt, copper, lead, manganese, mercury, nickel, thallium, and zinc were detected at concentrations equal to or greater than their corresponding ADJ CRQLs (Ref. 7, pp. 41, 97 & 357-359; Table 4).

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

Analysis of waste water from the oil/water separator detected numerous PAHS such as: 1,1'-biphenyl, 2,4-dimethylphenol, 2-methylnaphthalene, 4-methylphenol, acenaphthene, anthracene, benzo (a) anthracence, benzo (a) pyrene, benzo (b) fluoranthene, benzo (g,h,i) perylene, benzo (k) fluoranthene, carbazole, chrysene, dibenzofuran, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, naphthalene, phenanthrene and pyrene (Ref. 11, pp. 11, 40 & 301-302; Table 4). Metals such as arsenic, cadmium, chromium, cobalt, copper, lead, manganese, mercury, nickel, thallium, and zinc were also detected (Ref. 7, pp. 11, 40 & 357-359; Table 4).

SO-Source Characterization Source No.: 2

Table 4 – Source 2 - Oil/Water Separator

Sample Numbe r: ACSW-04 EPA Sample Numbe r: F9DD0/MF9DD0 Sampling Location: AC04 Sample Description Water from the Oil/Water Separator Result ADJ CRQL Fla g (µg/L) (µg/L) ANALYTE: SVOCs 1,1'-Biphenyl 12 5 2,4-Dimethylphenol 4.5 (4.5)* LJ 5 2-Methylnaphthalene 110 25 4-Methylphenol 7.3 LJ 10 Acenaphthene 75 5 Anthracene 42 5 Benzo (a) anthracene 13 5 Benzo (a) pyrene 6 5 Benzo (b) fluoranthene 7.5 5 Benzo (g,h,i) perylene 2.3 (2.3)* LJ 5 Benzo (k) fluoranthene 7.9 5 Carbazole 34 10 Chrysene 14 5 Dibenzofuran 61 5 Fluoranthene 91 10 Fluorene 69 5 Indeno (1,2,3-cd) pyrene 2.2 (2.2)* LJ 5 Naphthalene 220 25 Phenanthrene 150 25 Pyrene 54 5 ANALYTE: Total Metals Result ADJ CRQL Fla g (µg/L) (µg/L) Arsenic 17.4 1 Cadmium 10.8 1 Chromium 12.1 2 Cobalt 6.1 1 Copper 328 (262.4)* J 2 Lead 258 1 Manganese 1,020 15 Mercury 7.4 0.2 Nicke l 23.1 1 Thallium 8.6 1 Zinc 1,490 (1,150)* J 2 KEY ADJ CRQL - Adjusted contract required quantitation limit µg/L - Concentration in micrograms per liter Bold - Concentration is detected above contract required quantitation limit (CRQL) J - Estimated Value L - Reported concentration is below the contract required quantitation limit (CRQL). * - The detected concentration was adjusted by using guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8 & 18). After adjusting the value for the qualified data, the adjusted value has remained as the original value reported or decreased significantly from the original value reported. Although the results are qualified as estimated, the presence of the analytes is not in question. Note: Unless otherwise flagged, bias on adjusted “J” data results is unknown and treated as such. REFERENCES Chain of Custody Ref. 7, pp. 313 & 363 Laboratory Reports Ref. 7, pp. 301-302 & 357-359 Ref. 7, pp. 295-296, 299, 301-302, 350-351, 354 & 357- Data 359; Ref. 27, pp. 8, 13-15 & 18; Ref. 45, pp. 189-193 & 265-267

SO-Source Characterization Source No.: 2

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

Containment

Gas release to air: The air migration pathway was not scored; therefore, gas release to air containment was not evaluated.

Particulate release to air: The air migration pathway was not scored; therefore, particulate containment was not evaluated.

Release to ground water: The ground water pathway was not scored; therefore, ground water containment was not evaluated.

Release via overland migration: There is no evidence that the oil/water separator of the former retort house had any contaminant features when in operation (Ref. 6, pp. 93-94). There is no historical data to indicate that facility operations included waste handling, disposal practices, or facility permits (Ref. 4, p. 8; Ref. 12, p. 1; Ref. 26, p. 4). There is evidence of hazardous substance migration from Source No.2, to include the source itself, the oil/water separator that was observed to be completely covered in creosote solids, and stagnant water in direct contact with the contaminated source (Ref. 7, pp. 40-41, 94, 97 & 135; Ref. 13, pp. 13, 19, 61-66 & 76-77). The containment factor value for Source No. 2 is 10 due to no diking or no similar structure surrounding the container area (Ref. 1, Table 4-2).

Because containment for this source is greater than zero, the following substances associated with the source can migrate via the Surface Water Migration Pathway (Ref. 1, Sec. 4.1.2.1.2.1.1):

• 1,1'-Biphenyl • Cobalt • 2,4-Dimethylphenol • Copper • 2-Methylnaphthalene • Dibenzofuran • 4-Methylphenol • Fluoranthene • Acenaphthene • Fluorene • Anthracene • Indeno (1,2,3-cd) pyrene • Arsenic • Lead • Benzo (a) anthracene • Manganese • Benzo (a) pyrene • Mercury • Benzo (b) fluoranthene • Naphthalene • Benzo (g,h,i) perylene • Nickel • Benzo (k) fluoranthene • Phenanthrene • Cadmium • Pyrene • Carbazole • Thallium • Chromium • Zinc • Chrysene

SO-Source Characterization Source No.: 2

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1.1. Hazardous Constituent Quantity – Tier A

The total Hazardous Constituent Quantity for Source 2 could not be adequately determined according to the HRS requirements; that is, the total mass of all CERCLA hazardous substances in the source and releases from the source is not known and cannot be estimated with reasonable confidence (Ref. 1, Sec. 2.4.2.1.1). Insufficient historical and current data (manifests, potentially responsible party [PRP] records, State records, permits, waste concentration data, etc.) are not available to adequately calculate the total or partial mass of all CERCLA hazardous substances in the source and the associated releases from the source. Therefore, there is insufficient information to calculate a total or partial Hazardous Constituent Quantity estimate for Source 2 with reasonable confidence. Scoring proceeds to the evaluation of Tier B, Hazardous wastestream quantity (Ref. 1, Sec. 2.4.2.1.1).

Hazardous Constituent Quantity Value (S): Not Calculated Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.2. Hazardous Wastestream Quantity – Tier B

The total Hazardous Wastestream Quantity for Source 2 could not be adequately determined according to the HRS requirements; that is, the total mass of all hazardous waste streams and CERCLA pollutants and contaminants for the source and releases from the source is not known and cannot be estimated with reasonable confidence (Ref. 1, Sec 2.4.2.1.2). Insufficient historical and current data (manifests, potentially responsible party [PRP] records, State records, permits, waste concentration data, annual reports, etc.) are not available to adequately calculate the total or partial mass of all hazardous waste streams and CERCLA pollutants and contaminants for the source and the associated releases from the source. Therefore, there is insufficient information to adequately calculate or extrapolate a total or partial Hazardous Wastestream Quantity estimate for Source 2 with reasonable confidence. Scoring proceeds to the evaluation of Tier C, Volume (Ref. 1, Section 2.4.2.1.2).

Hazardous Wastestream Quantity Value (W): Not Calculated Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.3. Volume – Tier C

The oil/water separator is located just northwest and in close proximity to the concrete structure of the former retort house in order to receive discharge from the creosote processing that occurred within the former retort house (Figure 2; Ref. 6, pp. 93-94; Ref. 43, pp. 3-4). The oil/water separator is an abandoned concrete surface foundation structure that is a remnant of the former retort house basin from previous operations at the facility (Ref. 4, pp. 9, 12 & 28; Ref. 6, pp. 64, 70 & 94; Ref. 7, p. 135 & 173). The concrete structure that remains from the former retort house basin was considered part of the creosote processing facilities area (Ref. 6, pp. 65, 70 & 93; Ref. 7, pp. 135 & 173). The oil/water separator is a concrete structure and measures approximately 25 feet in length, five (5) feet across with a center wall at approximately two and a half (2.5) feet; it contains 5-10 feet of vegetation to the bottom

SO-Source Characterization Source No.: 2

(Ref. 7, pp. 40 & 181; Ref. 13, pp. 61-66 & 76-77). The concrete structure of the oil/water separator is completely covered in creosote soils and contains stagnant water; during sampling the concrete bottom was encountered at the approximate depth of 5 feet (Ref. 7, pp. 135, 173 & 181; Ref. 13, pp. 61-66 & 76-77).

Using a conservative estimate for the oil/water separator of the former retort house basin of 25 feet in length x 5 feet across x 5 feet deep, it occupied approximately 625 ft3 (Ref. 7, pp. 40 & 181; Ref. 13, pp. 76-77). The evaluation equation applied for the conversion of cubic feet (ft3) to cubic yards (yds3) is 1 yd3 = 27 ft3. The estimated capacity of the oil water separator is 23.15 yd3.

625 cubic feet (ft3) x 1 cubic yard (yd3) ÷ 27 cubic feet (ft3) = 23.15 yd3

The hazardous waste quantity evaluation equation other sources is V/2.5 (Ref. 1, Table 2-5). The volume source will be assigned a volume hazardous waste quantity value of 23.15.

23.15 yd3 ÷ 2.5 = 9.26

Volume of source (yd3): 23.15 Reference(s): Ref. 1, Table 2-5 Volume Assigned Value: 9.26

2.4.2.1.4. Area – Tier D

Tier D, Area, is not applicable for source type containers (Ref. 1, Sec. 2.4.2.1.3 and 2.4.2.1.4).

Area of Source No. 2 in square feet (ft2): Not Applicable Area Assigned Value: 0 References: Ref. 1, Sec. 2.4.2.1.4

2.4.2.1.5. Source Hazardous Waste Quantity Value

Source No. 2, Oil/Water Separator

Surface Water, Ground Water and Measures Air Pathways Tier A NC Tier B NC Tier C 9.26 Tier D 0 Assigned Source Hazardous 9.26 Waste Quantity Value (Ref. 1, Sec. 2.4.2.1.5) NC: Not Calculated

SO-Source Characterization Source No.: 2

The highest value assigned to either Tier A, Tier B, Tier C, or Tier D is assigned as the Source No. 2 Hazardous Waste Quantity Value (Ref. 1, Sec. 2.4.2.1.5). The highest value assigned is Tier C.

Source No. 2 Hazardous Waste Quantity Value: 9.26

SO-Source Characterization Source No.: 3

2.2.1 SOURCE IDENTIFICATION – SOURCE 3

The following information corresponds to the third source identified for this documentation record.

Number of source: 3

Name of source: Unlined Wastewater Pit

Source Type: Surface Impoundment Not Buried/Backfilled

Description and Location of Source: The unlined abandoned wastewater pit, or pond as commonly referred to, is located just west of the concrete (retort house) structure, and was the waste pit for the creosote operations at the facility (Figure 2; Ref. 4, pp. 14, 21, 28; Ref. 6, pp. 64 & 72, 93-94; Ref. 14, p. 1; Ref. 26, p. 5). The open unlined rectangular pit lies between the retort foundation and the Santa Fe track to the west, and served as a creosote wastewater holding pit for the creosote operations (Ref. 21, pp. 5 & 120). Typically, in the creosote processing the oil/preservative solutions recovered by the mechanical oil/water separator undergo a secondary wastewater treatment step by thermal dehydration/evaporation (Ref. 43, p. 4). The pond at American Creosote DeRidder undoubtedly served as the secondary wastewater treatment step by thermal dehydration/evaporation (Ref. 43, p. 4). The pit contains spent creosote wastewater that was sent to the pond for secondary treatment, and which now has contaminated the underlying soil (Ref. 9, p. 3). The unlined wastewater pit measures approximately 100 feet x 50 feet, with hardened creosote flanking the pit and adjacent to the pit (Ref. 4, pp. 28 & 31; Ref. 6, pp. 93-94; Ref. 13, p. 67-71 & 77; Ref. 14, p. 1). During the EPA December 2014 preliminary assessment (PA) the depth of the wastewater pit was taken from the southwest corner and measured approximately 8-10 inches deep (Ref. 13, p. 77).

LDEQ in cooperation with CMC and ATSF, from February 1994 to 1996, contracted with Louisiana State University who prepared several versions of a bioremediation work plan to remediate the creosote contaminated soils at the site (Ref. 8, p. 5; Ref. 21, p. 5). The work plan proposed transporting contaminated soils to a soil pile remediation unit (SPRU) where the soils would be biologically treated (Ref. 21, p. 3). An approximate total of 1,250 yd3 of contaminated soil from the creosote wastewater holding pit and run-off contaminated soil adjacent to the Santa Fe railway ROW were proposed to be processed in the SPRU (Ref. 21, p. 5). By April 1996 the executed cooperative agreement between ATSF, CMC and LDEQ had been dissolved (Ref. 8, p. 8).

Historical site investigations by LDEQ documented contamination at the unlined wastewater pit. During a site visit in October 1992, LDEQ IASD collected sediment samples from the pond and elevated levels, from 0.5 to 1.08 percent, for eight of the TCL listed creosote constituents were detected (Ref. 17, p 2). Analytical results from the October 1992 sample collection were found to contain high concentrations of PAHs per the West-Paine Laboratory results (Ref. 18, pp.17-18). Also, high creosote concentrations were discovered in the open unlined pit lying between the old Santa Fe railway tracks and the creosoting structure foundation by LDEQ (Ref. 12, p. 3). In 1993 LDEQ IASD completed a Phase I and Phase II State Site Assessment (SSA) and determined that high concentrations of creosote contamination were present in the unlined pit lying between the old Santa Fe railway track and the creosoting structure foundation (Ref. 12, p.3).

SO-Source Characterization Source No.: 3

The abandoned waste pit was an earthen creosote waste pit considered an area of impact, and the site feature of most concern by LDEQ and Acadian personnel, based on previous field observations (Ref. 4, p. 14; Ref. 6, pp. 65, 72 & 93-94). In the December 2003 Voluntary Remedial Action Plan Acadian designated the area surrounding the former waste pit and the pit itself, immediately to the west of the concrete (retort house) structure, as AOC #3 for investigative purposes (Ref. 4, p. 14). Site visual inspections revealed considerable stained surface soils and residual weathered creosote throughout AOC #3 in addition to the pit area (Ref. 4, p. 14; Ref. 6, pp. 65 & 148-149). AOC #3 had soil sampling performed to determine the horizontal and vertical extent of impact to the shallow soils (Ref. 4, pp. 14 & 31; Ref. 11, p. 3). Site visual inspections revealed considerable stained surface soils and residual weathered creosote throughout AOC #3 in addition to the pit area (Ref. 4, p. 14). Soil borings from AOC #3 revealed elevated concentrations of benzopyrene (sic) (Ref. 4, p. 21; Ref. 6, pp. 20-26, 86, 94-114, 116 & 119).

In the 2003 proposed Voluntary Remedial Action Plan, Acadian proposed methodology for addressing the impacted soils around the waste pit and the pit itself was over-excavation of impacted areas and treatment of the impacted media (Ref. 4, p. 18). The proposed limits of excavation within AOC #3 entailed the entire area and were based upon analytical results and the visual surface impact (Ref. 4, p. 21; Ref. 6, pp. 21-26, 86 & 94-114). The proposed, yet never started, excavation of AOC #3 was to consist of two (2) separate excavation areas (AOC #3a and AOC #3b) (Ref. 4, pp. 22 & 35). AOC #3a was the abandoned waste pit which proposed the depth of excavation until hard pan impacted soils were encountered beneath the impacted sludge media (Ref. 4, p. 22). The proposed area of excavation for AOC #3a was 3,300 ft2and the depth was estimated at three (3) feet to result in a proposed excavation volume of 367 yd3 (Ref. 4, p. 22). ACO #3b was to consist of the adjacent area to the pit that revealed elevated levels of benzopyrene (sic) and visible surface impact present (Ref. 4, p. 22). AOC #3b was proposed to consist of 7,110 ft2 of excavatable area at a depth of two (2) feet resulting in a volume of 527 yd3of proposed excavatable soil (Ref. 4, p. 22). The proposed total volume of excavation within AOC #3 was 894 yd3 or 1,162 yd3 to be remediated (Ref. 4, p. 22). To date no remediation has taken place at American Creosote DeRidder (Ref. 6, p. 11).

The proposed remediation of the waste sludge from the abandoned earthen pit was to place the excavated material within the concrete retort house structure adjacent to the pit (Ref. 4, pp. 22 & 37). Select microbes intended to remediate creosote related organic compounds were to be used to inoculate and treat the impacted media (Ref. 4, p. 23). To date no remediation has taken place at American Creosote DeRidder (Ref. 6, p. 11).

In April 2014 Acadian submitted a CAP that identified the area most necessary to be subjected to corrective action, a 7,500 square foot AOC, bound to the east by the westernmost portion of the abandoned concrete retort house basins and to the west by the western bankline of the abandoned waste pit (Ref. 26, pp. 6-7 & 16-17). The waste pit AOC dimensions included the pond area of 1,650 ft2 and the wetted pond area of 5,400 ft2 (Ref. 26, p. 7). The solidification/stabilization of creosote impacted soil was to take place in the waste pit and involved in-situ mixing with Portland cement (Ref. 26, pp. 8-9). Volumes to be removed from the wastewater pit area include 11,849 gallons of water from the wastewater pit prior to the solidification process, and 48.9 yd3 of pond volume (Ref. 26, pp. 8-9).

During the June 2015 EPA SI a sediment sample, ACSD-08, was collected from the eastern edge of the abandoned wastewater pit using a 3-feet direct push acetate sleeve (sample retrieval tube with a rubber-

SO-Source Characterization Source No.: 3

lined gasket top) and transferred directly to sample containers (Ref. 7, pp. 24, 41, 81, 133, 395 & 425- 435). The sediment sample was shipped to the designated CLP Laboratory for TCL SVOCs and TAL total metal/mercury chemical analysis (Ref. 7, p. 24). Sediment samples were submitted to KAP Technologies Inc. located in The Woodlands, Texas, for TCL Semi-Volatile Organic Analysis (SVOAs) by EPA CLP SOM02.2 organic analysis, and to Chemtech Consulting Group located in Mountainside, New Jersey, for TAL Total Metals and Mercury by EPA ISM02.2 inorganic analysis (Ref. 7, pp. 69-70).

The sediment sample results from location ACSD-08 detected concentrations of PAHs such as 1,1'- biphenyl, 2-methylnaphthalene, acenaphthene, acenaphthylene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (g,h,i) perylene, benzo (k) fluoranthene, carbazole, chrysene, dibenzo (a,h) anthracene, dibenzofuran, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, naphthalene, phenanthrene and pyrene were detected at concentrations equal to or greater than their corresponding ADJ CRQLs (Ref. 7, pp. 42, 96 & 258-259; Table 5).

Metal concentrations were also detected in the ACSD-08 sediment sample including arsenic, cadmium, chromium, cobalt, copper, lead, manganese, mercury, nickel, thallium and zinc equal to or greater than their corresponding ADJ CRQLs (Ref. 7, pp. 42, 96, 355 & 358; Table 5).

Additionally, a waste water sample, ACSW-08, was collected during the June 2015 EPA SI, from the abandoned wastewater pit (Ref. 7, pp. 41, 181 & 554). Waste water sample ACSW-08 was collected using a peristaltic pump with dedicated tubing, and low flowed directly into sample containers (Ref. 7, pp. 130-131). The sample was shipped to KAP Technologies Inc. located in The Woodlands, Texas, for organic analysis, and Chemtech Consulting Group located in Mountainside, New Jersey, for inorganic analysis (Ref. 7, p. 27). The sample was analyzed for SVOCS by EPA CLP SOW SOM02.2, and for inorganic TAL metals/mercury by EPA CLP SOW ISM02.2 (Ref. 7, pp. 25-27). All data from analyses performed at KAP Technologies Inc. and Chemtech Consulting Group were reviewed and validated by the Houston EPA Laboratory (Ref. 7, pp. 27, 69-70, 308-309 & 357-359)

Waste water sample ACSW-08 contained PAHS including: 2-methylnaphthalene, acenaphthene, anthracene, benzaldehyde, benzo (a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (g,h,i) perylene, benzo (k) fluoranthene, carbazole, chrysene, dibenzofuran, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, naphthalene, phenanthrene and pyrene at concentrations equal to or greater than their corresponding ADJ CRQLs (Ref. 7, pp. 41-42, 97 & 308-309; Table 6). Metals concentrations were also detected in the waste water sample collected from the wastewater pit at concentrations equal to or greater than their corresponding ADJ CRQLs including: arsenic, chromium, cobalt, copper, lead, manganese, nickel, and zinc (Ref. 7, pp. 41-42, 97 & 357-359).

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

Analyses of the sediment sample and waste water sample collected from location AC-08, located along the eastern edge of the unlined wastewater pit detected numerous PAHs including: 1,1'-biphenyl, 2- methylnaphthalene, acenaphthene, acenaphthylene, anthracene, benzaldehyde, benzo (a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (g,h,i) perylene, benzo (k) fluoranthene, carbazole, chrysene, dibenzo (a,h) anthracene, dibenzofuran, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, naphthalene, phenanthrene and pyrene (Ref. 7, pp. 41-42, 96-97, 259-259 & 308-309).

SO-Source Characterization Source No.: 3

Additionally, numerous metals were detected in the sediment sample and waste water sample collected from location AC-08 such as arsenic, cadmium, chromium, cobalt, copper, lead, manganese, mercury, nickel, thallium, and zinc (Ref. 7, pp. 41-42, 96-97, 355 & 357-359).

SO-Source Characterization Source No.: 3

Table 5 – Source 3 – Unlined Wastewater Pit

Sample Numbe r: ACSD08-06 EPA Sample Numbe r: F9DC1/MF9DC1 Sampling Location: AC08 Sample Description Sediment from Wastewater Pit Result ADJ CRQL Fla g (µg/k g) (µg/k g) ANALYTE: SVOCs 1,1'-Biphenyl 67,000 (67,000)* J 1,700 2-Methylnaphthalene 9,400,000 3,500,000 Acenaphthene 6,400,000 3,500,000 Acenaphthylene 4,700 1,700 Anthracene 18,000,000 3,500,000 Benzo (a) anthracene 2,800,000 (2,800,000)* LJ 3,500,000 Benzo (a) pyrene 34,000 (3,400)* J 1,700 Benzo (b) fluoranthene 38,000 (3,800)* J 1,700 Benzo (g,h,i) perylene 7,200 1,700 Benzo (k) fluoranthene 38,000 (3,800)* J 1,700 Carbazole 9,700,000 6,700,000 Chrysene 2,900,000 (2,900,000)* LJ 3,500,000 Dibenzo (a,h) anthracene 3,300 1,700 Dibenzofuran 7,100,000 3,500,000 Fluoranthene 12,000,000 6,700,000 Fluorene 9,500,000 3,500,000 Indeno (1,2,3-cd) pyrene 10,000 1,700 Naphthalene 25,000,000 3,500,000 Phenanthrene 26,000,000 3,500,000 Pyrene 6,300,000 3,500,000 ANALYTE: TOTAL METALS Result ADJ CRQL Fla g (mg/kg) (mg/kg) Arsenic 4.7 (2.8)* J 0.59 Cadmium 0.75 0.59 Chromium 3.7 1.2 Cobalt 1.3 0.59 Copper 34.1 1.2 Lead 55.4 0.59 Manganese 19.5 1.8 Mercury 3.4 0.78 Nicke l 3.6 0.59 Thallium 1.3 0.59 Zinc 93.9 1.2 KEY Bkgd - Background ADJ CRQL - Adjusted contract required quantitation limit µg/k g - Concentration in microgram per kilogram mg/Kg - Concentration in milligram per kilogram Bold - Concentration is detected above contract required quantitation limit (CRQ L) J - Estimated Value L -Reported concentration is below the contract required quantitation limit (CRQL) * - The detected concentration was adjusted by using guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8 & 14-15 & 18). After adjusting the value for the qualified data, the adjusted value has remained the original value reported or decreased significantly from the original value reported. Although the results are qualified as estimated, the presence of the analytes is not in question. Note: Unless otherwise flagged, bias on adjusted “J” data results is unknown and treated as such. REFERENCES Chain of Custody Ref. 7, pp. 273 & 362 Laboratory Reports Ref. 7, pp. 258-259, 355 & 358 Ref. 7, pp. 253-254, 257-259, 350-351, 354, 355 & 358; Ref. 27, pp. Data 8, 14 & 18; Ref. 45, pp. 97-107 & 238-240

SO-Source Characterization Source No.: 3

Table 6 – Source 3 – Unlined Wastewater Pit

Sample Number: ACSW-08 EPA Sample Number: F9DE1/MF9DE1 Sampling Location: AC08 Sample Description Waste Water From the Wastewater Pit Result ADJ CRQL Flag (µg/L) (µg/L) ANALYTE: SVOCs 2-Methylnaphthalene 3.8 (3.8)* LJ 5 Acenaphthene 6.6 5 Anthracene 6.7 5 Benzaldehyde 5.3 (5.3)* LJ 10 Benzo (a) anthracene 15 5 Benzo (a) pyrene 8.1 5 Benzo (b) fluoranthene 14 5 Benzo (g,h,i) perylene 3.2 (3.2)* LJ 5 Benzo (k) fluoranthene 15 5 Carbazole 5.4 (5.4)* LJ 10 Chrysene 16 5 Dibenzofuran 3.6 (3.6)* LJ 5 Fluoranthene 33 10 Fluorene 4.6 (4.6)* LJ 5 Indeno (1,2,3-cd) pyrene 3.4 (3.4)* LJ 5 Naphthalene 5 (5)* LJ 5 Phenanthrene 5.4 5 Pyrene 36 5 ANALYTE: METALS Result ADJ CRQL Flag (µg/L) (µg/L) Arsenic 5.9 1 Chromium 3 2 Cobalt 2.7 1 Copper 10.3 (8.2)* J 2 Lead 11.3 1 Manganese 488 15 Nickel 4.8 1 Zinc 47.4 (36.7)* J 2 KEY ADJ CRQL – Adjusted contract required quantitation limit µg/L - Concentration in micrograms per liter Bold - Concentration is detected abo ve contract required quantitation limit (CRQL) J - Estimated Value L - Reported concentration is below the contract required quantitation limit (CRQL) * - The detected concentration was adjusted by using guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8 & 18). After adjusting the value for the qualified data, the adjusted value has remained the original value reported or decreased significantly from the original value reported. Although the results are qualified as estimated, the presence of the analytes is not in question. Note: Unless otherwise flagged, bias on adjusted “J” data results is unknown and treated as such. REFERENCES Chain of Custody Ref. 7, pp. 313 & 345 Laboratory Reports Ref. 7, pp. 308-309 & 357-359 Ref. 7, pp. 295-296, 299, 308-309, 350-351, 354, 357- Data 359. Ref. 27, pp. 8, 13-15 & 18; Ref. 45, pp. 194-198 & 271-273

SO-Source Characterization Source No.: 3

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

Containment

Gas release to air: The air migration pathway was not scored; therefore, gas release to air containment was not evaluated.

Particulate release to air: The air migration pathway was not scored; therefore, particulate containment was not evaluated.

Release to ground water: The ground water pathway was not scored; therefore, ground water containment was not evaluated.

Release via overland migration: There is no evidence that the unlined wastewater pit had any contaminant features when in operation (Ref. 6, pp. 93-94). There is no historical data to indicate that facility operations included waste handling, disposal practices or facility permits (Ref. 4, p. 8; Ref. 12, p. 1; Ref. 26, p. 4). There is evidence of hazardous substance migration from Source No. 3, by direct observation of hardened creosote flanking the pond and adjacent to the pond indicative of wastewater overflow (Ref. 1, Table 4-2; Ref. 6, pp. 72 & 94-114; Ref. 13, pp. 19, 67-71 & 77). The containment factor value for Source No. 3 is 10 due to free liquids present with either no diking, unsound diking, or diking that is not regularly inspected and maintained, and no evidence of a liner, as the pond has been referred to as an earthen creosote waste pit, and an open unlined creosote wastewater pit (Ref. 1, Table 4-2; Ref. 6, p. 94; Ref. 14, p. 1).

Because containment for this source is greater than zero, the following substances associated with the source can migrate via the Surface Water Migration Pathway (Ref. 1, Sec. 4.1.2.1.2.1.1):

• 1,1'-Biphenyl • Cobalt • 2-Methylnaphthalene • Copper • Acenaphthene • Dibenzo (a,h) anthracene • Acenaphthylene • Dibenzofuran • Anthracene • Fluoranthene • Arsenic • Fluorene • Benzaldehyde • Indeno (1,2,3-cd) pyrene • Benzo (a) anthracene • Lead • Benzo (a) pyrene • Manganese • Benzo (b) fluoranthene • Mercury • Benzo (g,h,i) perylene • Naphthalene • Benzo (k) fluoranthene • Nickel • Cadmium • Phenanthrene • Carbazole • Pyrene • Chromium • Thallium • Chrysene • Zinc

SO-Source Characterization Source No.: 3

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1.1. Hazardous Constituent Quantity – Tier A

The total Hazardous Constituent Quantity for Source 3 could not be adequately determined according to the HRS requirements; that is, the total mass of all CERCLA hazardous substances in the source and releases from the source is not known and cannot be estimated with reasonable confidence (Ref. 1, Sec. 2.4.2.1.1). Insufficient historical and current data (manifests, potentially responsible party [PRP] records, State records, permits, waste concentration data, etc.) are not available to adequately calculate the total or partial mass of all CERCLA hazardous substances in the source and the associated releases from the source. Therefore, there is insufficient information to calculate a total or partial Hazardous Constituent Quantity estimate for Source 3 with reasonable confidence. Scoring proceeds to the evaluation of Tier B, Hazardous wastestream quantity (Ref. 1, Sec. 2.4.2.1.1).

Hazardous Constituent Quantity Value (S): Not Calculated Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.2. Hazardous Wastestream Quantity – Tier B

The total Hazardous Wastestream Quantity for Source 3 could not be adequately determined according to the HRS requirements; that is, the total mass of all hazardous waste streams and CERCLA pollutants and contaminants for the source and releases from the source is not known and cannot be estimated with reasonable confidence (Ref. 1, Sec. 2.4.2.1.2). Insufficient historical and current data (manifests, potentially responsible party [PRP] records, State records, permits, waste concentration data, annual reports, etc.) are not available to adequately calculate the total or partial mass of all hazardous waste streams and CERCLA pollutants and contaminants for the source and the associated releases from the source. Therefore, there is insufficient information to adequately calculate or extrapolate a total or partial Hazardous Wastestream Quantity estimate for Source 3 with reasonable confidence. Scoring proceeds to the evaluation of Tier C, Volume (Ref. 1, Sec. 2.4.2.1.2).

Hazardous Wastestream Quantity Value (W): Not Calculated Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.3. Volume – Tier C

The unlined abandoned wastewater pit is located just west of the concrete (retort house) structure (Figure 2; Ref. 6, p. 72). The unlined wastewater pit measures approximately 100 feet x 50 feet, with hardened creosote flanking the pit and adjacent to pit (Ref. 13, p. 67-71 & 77). During the EPA December 2014 preliminary assessment (PA) the depth of the wastewater pit was taken from the southwest corner and measured approximately 8 – 10 inches deep (Ref. 13, p. 77). The abandoned waste pit was an earthen creosote waste pit considered an area of impact, and the site feature of most concern by LDEQ and Acadian personnel based on previous field observations (Ref. 6, pp. 65, 72 & 93-94).

SO-Source Characterization Source No.: 3

Using the estimate for the unlined wastewater pit of 100 feet in length x 50 feet across x 8 inches deep, it occupied approximately 3,333.33 ft3 (Ref. 7, pp. 41 & 181-182; Ref. 13, pp. 13, 19 & 67-69 & 77). The evaluation equation applied for the conversion of cubic feet (ft3) to cubic yards (yds3) is 1 yd3 = 27 ft3. The estimated capacity of the oil water separator is 123.46 yd3.

3,333.33 cubic feet (ft3) x 1 cubic yard (yd3) ÷ 27 cubic feet (ft3) = 123.46 yd3

The hazardous waste quantity evaluation equation for a surface impoundment not buried/backfilled is V/2.5 (Ref. 1, Table 2-5). The volume source will be assigned a volume hazardous waste quantity value of 123.46.

123.46 yd3 ÷ 2.5 = 49.38 Volume of source (yd3): 123.46 Reference(s): Ref. 1, Table 2-5 Volume Assigned Value: 49.38

2.4.2.1.4. Area – Tier D

Tier D, Area, was not calculated for Source 3 since the volume was estimated. Therefore, according to HRS, the area is not calculated (Ref. 1, Sec. 2.4.2.1.3 and 2.4.2.1.4).

Area of Source No. 3 in square feet (ft2): Not Applicable Area Assigned Value: 0 References: Ref. 1, Sec. 2.4.2.1.4

2.4.2.1.5. Source Hazardous Waste Quantity Value

Source No. 3, Unlined Wastewater Pit

Surface Water, Ground Water and Measures Air Pathways Tier A NC Tier B NC Tier C 49.38 Tier D 0 Assigned Source Hazardous 49.38 Waste Quantity Value (Ref. 1, Sec. 2.4.2.1.5) NC: Not Calculated

The highest value assigned to either Tier A, Tier B, Tier C, or Tier D is assigned as the Source No. 3 Hazardous Waste Quantity Value (Ref. 1, Sec. 2.4.2.1.5). The highest value assigned is Tier C.

Source No. 3 Hazardous Waste Quantity Value: 49.38

SO-Source Characterization Source No.: 4

2.2.1 SOURCE IDENTIFICATION – SOURCE 4

The following information corresponds to the source identified for this documentation record.

Number of source: 4

Name of source: Aggregated Areas of Soil Contamination

Source Type: Contaminated Soil

Description and Location of Source: Areas of soil contamination at the site are being aggregated as Source No. 4. Source aggregation is done based on having more than two areas that could be considered individual sources as one discrete source when evaluating one or more pathways (Ref. 1, Sec. 4.2). Source aggregation for Source No. 4 is applied because all sources can be classified as the same source type, the sources affect the similar target populations, the sources have similar containment, the sources contain substances with similar waste characteristics factor values, and the sources are in the same watershed and floodplain (Ref. 1, Sec. 4.2).

Areas of soil contamination were observed at the site during the PA (Ref. 13, pp. 19, 58-60 & 76-77). This observation confirmed what was reported in 2003 during Acadian Engineers & Environmental Consultants environmental site investigation, and was considered AOC #4 (Ref. 4, pp. 11, 14-15, 22-23 & 32). Physical characteristics of the weathered creosote material are an approximate 1-4 inch thick layer on top of the surface soils, with textural characteristics of a dry hard mass (Ref. 6, pp. 154-155, 159 & 162; Ref. 26, p. 6).

In the Voluntary Remedial Action Plan Acadian designated contaminated surface soils as AOC #4, primarily downgradient of the old drip area, the wash pit area, and was approximately ½ acre in size (Ref. 4, pp. 11 & 14). AOC #4, contaminated surface soils, has a downgradient slope of 1.2 percent to the south (Ref. 4, pp. 11, 14 & 32). The area consists of hardwood trees and heavy underbrush (Ref. 4, p. 14). Historical plans and the Acadian site inspections indicate the area is void of any structures from the previous creosotes operations (Ref. 4, p. 14). Previous visual site inspections by LDEQ and Acadian personnel revealed considerable amounts of weathered creosote product on the ground surface primarily along the western property boundary (Ref. 4, p .14).

In September 2002, Acadian collected eight (8) soil borings through AOC #4 to a maximum depth of 0- 4 feet bgs, acquired by advancing a Shelby tube sampler in two (2) foot increments (Ref. 4, pp. 14-16 &

SO-Source Characterization Source No.: 4

32). The soil boring placement was based upon the downgradient topographic nature of the study area, the visual evidence of surface impact, the location of the western property boundary, and the bottom drainage basin located at the southern end of the study area (Ref. 4, pp. 14-15 & 32). Constituents which exceeded the LDEQ RECAP industrial soil screening standards and their corresponding TPH value are benzoanthracene (sic), benzopyrene (sic), benzofluoranthracene (sic), dibenzoanthracene (sic), idenopyrene (sic), and naphthalene (Ref. 4, pp. 19-20 & 42-76; Ref. 6, pp. 26-37, 86, 94-114, 116 & 118-119).

Acadian’s proposed methodology for addressing the impacted soils was over-excavation of impacted areas and treatment of the impacted media (Ref. 4, p. 18). The proposed excavation within AOC #4 consists of 35,700 ft2 (0.82) acres to two (2) foot depth resulting in a proposed excavation volume of 2,644 yd3 or 3,438 yd3 of soil to be remediated (Ref. 4, pp. 17, 22-23 & 36). The excavated soils were proposed to be remediated through bio-degradation of the creosote related organic compounds (Ref. 4, p. 23). Soils from AOC #4 were to be placed within an earthen remediation cell adjacent to the concrete structure (Ref. 4, pp. 23 & 38). Select microbes intended to remediate creosote related organic compounds were to be used to inoculate and treat the impacted media (Ref. 4, p. 23).

In April 2014 Acadian submitted a CAP that identified the area most necessary to be subjected to corrective action, a 7,500 ft2 AOC, bound to the east by the westernmost portion of the abandoned concrete retort house basins and to the west by the western bankline of the abandoned waste pit (Ref. 26, pp. 6-7 & 16-17). The graded surface dimensions were 5,400 ft2 (Ref. 26, p. 7). The solidification/stabilization of creosote impacted soil was to take place in the waste pit and involved in- situ mixing with Portland cement (Ref. 26, pp. 8-9). Volumes to be removed from the surface area and solidified in the wastewater pit were 100 yd3 (Ref. 26, pp. 8-9). The AOC encompasses the total area that would be remediated, which included the waste pit (Ref. 26, p. 8). The area of the waste pit is 1,650 ft2 and is located at the southwest end of the AOC (Ref. 26, p. 8). The AOC outside of the waste pit has an approximate area of 7,500 ft2 and this gives an approximate total volume of 2,700 ft3 (based on a six- inch removal depth) that would be placed into the waste pit for solidification (Ref. 26, p. 8).

Additionally, LDEQ in its Notice of Potential Liability to Kerr-McGee Chemical Corporation stated that a pathway of hardened creosote and underlying contaminated soils beginning along the west side of the pit and gently sloping southward downgradient from the pit paralleling the east side of a one track railroad spur owned by BNSF is approximately 400 feet long and 10-20 feet wide, and lies mostly within the BNSF 50-foot ROW from the track centerline (Ref. 14, pp. 1-2). The creosote pathway appears to end at the point where an intermittent unnamed stream passes beneath the railroad spur from east to west (Ref. 14, pp. 1-2).

During the June 2015 EPA SI soil samples were collected from four (4) random areas of soil contamination, these four source sample areas represent the aggregation for Source No. 4 (Ref. 1, Sec. 4.2; Ref. 7, pp. 43 & 84). Soil borings were advanced using direct push technology with borings advanced to a maximum depth of 15 feet bgs using the procedure in the EPA Environmental Response Team (ERT) Standard Operating Procedure (SOP) 2012, modified for the actual unit used by the driller (Ref. 7, pp. 23, 43-44, 84, 180-182 & 436-449). Grab soil samples were collected from each boring, from intervals of visual contamination or where photoionization detector (PID) readings for VOCs above background were detected (Ref. 7, p. 23-24, 189, 193-194, 394 & 436-449). The following samples were collected (Ref. 7, p. 43-47, 84, 129, 134, 136, 146, 180-183 & 541-544; Figure 3):

SO-Source Characterization Source No.: 4

• Sample Location AC-05, Sample ACS05-02 & Sample ACS05-25: collected east of the oil/water separator at 0 to 2 feet bgs and 2 to 5 feet bgs; • Sample Location AC-07, Sample ACS07-02, Sample ACS07-58 and Sample AC07-10: collected between the wastewater pit and oil/water separator at 0 to 2 feet bgs, 5 to 8 feet bgs and 8 to 10 feet bgs; • Sample Location AC-10, Sample ACS10-02, Sample ACS10-58 and Sample AC10-10: collected from an area of creosote at 0 to 2 feet bgs, 5 to 8 feet bgs and 8 to 10 feet bgs; • Sample Location AC-11, Sample ACS11-02 and Sample ACS11-10: collected south of facility operations at 0 to 2 feet bgs and 8 to 10 feet bgs; and • Sample Location AC-19, Sample ACS19-58 and Sample ACS19-10: duplicate samples of ACS07-58 and ACS10-10.

Soil samples were analyzed for TCL SVOCS by EPA CLP SOW SOM02.2 and for TAL total metals/mercury by EPA CLP SOW ISM02.2. Organic analyses were performed by KAP Technologies Inc. located in The Woodlands, Texas, and inorganic analysis were performed by Chemtech Consulting Group located in Mountainside, New Jersey. All data from analyses performed at KAP Technologies Inc. and Chemtech Consulting Group were reviewed and validated by the Houston EPA Laboratory (Ref. 7, pp. 27, 69-70, 220-230, 236-237, 259-260, 263-265, 335-341 & 355-359).

The soil sample results from the aggregate source areas of soil contamination were compared to the concentrations in the corresponding foot interval from the background soil sample (Table 1 & 7). PAHs such as 1,1'-biphenyl, 2-methylnaphthalene, acenaphthene, acenaphthylene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (g,h,i) perylene, benzo (k) fluoranthene, bis (2-ethylhexyl) phthalate, carbazole, chrysene, dibenzo (a,h) anthracene, dibenzofuran, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, naphthalene, phenanthrene and pyrene were detected above corresponding soil background levels (AC-01) (Table 1 & 7). COCs were detected above observed release criteria in the soil samples from zero (0) to ten (10) feet bgs (Ref. 7, pp. 44-48, 90-95, 222-229, 235-237, 259-260 & 263-268; Table 7). While the increase in concentration is not required to associate the substance with the source, it does demonstrate the level in the soil samples is significantly above background.

Metal concentrations were also detected in the soil samples including chromium, copper, lead, manganese, mercury, nickel silver, and zinc greater than background level (Ref. 7, pp. 44-48, 90-95, 335-336, 339-341 & 355-359; Table 7). Again, while this increase in concentration is not required to associate the substances with the source, it does demonstrate the level in the soil samples are significantly above background.

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

PAHs such as 1,1'-biphenyl, 2-methylnaphthalene, acenaphthene, acenaphthylene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (g,h,i) perylene, benzo (k) fluoranthene, bis(2-ethylhexyl)phthalate, carbazole, chrysene, dibenzo (a,h) anthracene, dibenzofuran, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, naphthalene, phenanthrene and pyrene were detected in the areas of soil contamination sampling (Table 7). These constituents were also detected in other sources at American Creosote DeRidder including the concrete structure, the oil/water separator and the unlined

SO-Source Characterization Source No.: 4

wastewater pit (Sources 1, 2 and 3, respectively) (Tables 3, 4, 5 & 6).

In addition, metal concentrations detected in the areas of soil contamination included chromium, copper, lead, manganese, mercury, nickel silver, and zinc (Table 7).

SO-Source Characterization Source No.: 4 Table 7 – Source 4 – Areas of Creosote Solids and Soil Contamination

Sample Number: ACS05-02 ACS05-25 ACS07-02 ACS07-58 ACS19-58 (Duplicate of ACS07-58) EPA Sample Number: F9DA4/MF9DA4 F9DA5/MF9DA5 F9DA6/MF9DA6 F9DA7/MF9DA7 F9DB6/MF9DB6 Sample Location: AC05 AC05 AC07 AC07 AC19 Sample Description Concrete Structure Concrete Structure Between Pond & Concrete Structure Between Pond & Concrete Structure Creosote Area Sample Depth 0 - 2 foot interval 2 - 5 foot interval 0 - 2 foot interval 5 - 8 foot interval 5 - 8 foot interval

Bkgd (A C01 -02) – Bkgd (A CS01 -25) – Bkgd (A C01-02) - Bkgd (A CS01 -58) - ADJ Bkgd (A CS01 -58) - ADJ ADJ ADJ ADJ Result ADJ CRQL Result ADJ CRQL Result ADJ CRQL Result CRQL Result ADJ CRQL ADJ CRQL Flag CRQL Flag CRQL Flag CRQL Flag CRQL Flag (µg/kg) or 3x Result (µg/kg) or 3x Result (µg/kg) or 3x Result (µg/kg) or 3x Result (µg/kg) (µg/kg) or 3x Result (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg)

ANALYTE: SVOCs 1,1'-Biphenyl 230 U 230 200 (ADJ CRQL) 200 U 200 200 (ADJ CRQL) 190 U 190 200 (ADJ CRQL) 64,000 (6,400)* J^ 180 180 (ADJ CRQL) 74,000 (7,400)* J 2,000 180 (ADJ CRQL) 2-Methylnaphthalene 320 (32)* J 320 200 (ADJ CRQL) 200 UJ 200 200 (ADJ CRQL) 160 (1 60)* LJ 190 200 (ADJ CRQL) 240,000 (24,000)* J^ 180 180 (ADJ CRQL) 61,000,000 39,000,000 180 (ADJ CRQL) Acenaphthene 470 230 200 (ADJ CRQL) 200 U 200 200 (ADJ CRQL) 190 U 190 200 (ADJ CRQL) 200,000 (20,000)* J^ 180 180 (ADJ CRQL) 60,000,000 39,000,000 180 (ADJ CRQL) Acenaphthylene 2,900 230 200 (ADJ CRQL) 200 U 200 200 (ADJ CRQL) 1,300 190 200 (ADJ CRQL) 8,400 (840)* J^ 180 180 (ADJ CRQL) 10,000 2,000 180 (ADJ CRQL) Anthracene 1,900 230 200 (ADJ CRQL) 200 U 200 200 (ADJ CRQL) 2,800 190 200 (ADJ CRQL) 140,000 (14,000)* J^ 180 1,320 (3x Result) 39,000,000 (39,000,000)* LJ 39,000,000 1,320 (3x Result) Benzo (a) anthracene 8,100 (810)* J 230 200 (ADJ CRQL) 150 (150)* LJ 200 200 (ADJ CRQL) 24,000 (2,400)* J 3,800 200 (ADJ CRQL) 22,000 (2,200)* J 180 180 (ADJ CRQL) 81,000 (8,100)* J 2,000 180 (ADJ CRQL) Benzo (a) pyrene 22,000 (2,200)* J 230 200 (ADJ CRQL) 330 (33)* J 200 930 (9,300)** (3x Result) 16,000 (1,600)* J 3,800 200 (ADJ CRQL) 6,400 (640)* J 180 330 (3,330)** (3x Result) 34,000 (3,400)* J 2,000 330 (3,300)** (3x Result) Benzo (b) fluoranthene 35,000 (3,500)* J 230 200 (ADJ CRQL) 470 (47)* J 200 570 (5,700)** (3x Result) 22,000 (2,200)* J 3,800 200 (ADJ CRQL) 15,000 (1,500)* J 180 510 (5,100)** (3x Result) 58,000 (5,800)* J 2,000 510 (5 ,100)** (3x Result) Benzo (k) fluoranthene 12,000 (1,200)* J 230 200 (ADJ CRQL) 400 200 960 (9,600)** (3x Result) 20,000 (2,000)* J 3,800 200 (ADJ CRQL) 3,600 (360)* J 180 540 (3x Result) 27,000 2,000 540 (3x Result) Carbazole 690 440 390 (ADJ CRQL) 390 U 390 390 (ADJ CRQL) 280 (280)* LJ 370 390 (ADJ CRQL) 240,000 (24,000)* J^ 350 350 (ADJ CRQL) 120,000 (12,000)* J 3,800 350 (ADJ CRQL) Chrysene 1,5000 (1,500)* J 230 200 (ADJ CRQL) 280 200 200 (ADJ CRQL) 20,000 (2,000)* J 3,800 200 (ADJ CRQL) 14,000 (1,400)* J 180 360 (3,600)** (3x Result) 69,000 (6,900)* J 2,000 360 (3,600)** (3x Result) Dibenzofuran 410 230 200 (ADJ CRQL) 200 U 200 200 (ADJ CRQL) 160 (160)* LJ 190 200 (ADJ CRQL) 160,000 (16,000)* J^ 180 180 (ADJ CRQL) 54,000,000 39,000,000 180 (ADJ CRQL) Fluoranthene 16,000 (1,600)* J 440 390 (ADJ CRQL) 390 U 390 390 (ADJ CRQL) 35,000 7,500 390 (ADJ CRQL) 670,000 (67,000) J 350 690 (6,900)** (3x Result) 93,000,000 (9,300,000)* J 76,000,000 690 (6,900)** (3x Result) Fluorene 230 U 230 200 (ADJ CRQL) 200 U 200 200 (ADJ CRQL) 190 U 190 200 (ADJ CRQL) 220,000 (22,000)* J^ 180 180 (ADJ CRQL) 62,000,000 39,000,000 180 (ADJ CRQL) Indeno (1,2,3-cd) pyrene 16,000 (1,600)* J 230 200 (ADJ CRQL) 320 200 960 (9,600)* (3x Result) 7,800 (780)* J 3,800 200 (ADJ CRQL) 3,700 (370)* J 180 180 (ADJ CRQL) 13,000 2,000 180 (ADJ CRQL) Naphthalene 1,200 (120)* J 230 200 ADJ CRQL) 200 UJ 200 200 (ADJ CRQL) 530 190 200 ADJ CRQL) 450,000 (45,000) J^ 180 180 (ADJ CRQL) 290,000,000 39,000,000 180 (ADJ CRQL) Phenanthrene 2,000 230 200 (ADJ CRQL) 200 U 200 200 (ADJ CRQL) 410 190 200 (ADJ CRQL) 900,000 (90,000)* J^ 180 420 (4,200)** (3x Result) 170,000,000 39,000,000 420 (4,200)** (3x Result) Pyrene 230 U 230 200 (ADJ CRQL) 150 (150)* LJ 200 200 (ADJ CRQL) 58,000 (4,890.4)* J 3,800 200 (ADJ CRQL) 38,000 (3,204)* J 180 480 (5,692.8)* * (3 x Result) 41,000,000 39,000,000 480 (5,692.8)** (3x Result) ANALYTE: TOTAL METALS Bkgd (A C01 -02) - Bkgd (A CS01 -25) - Bkgd (A C01 -02) - Bkgd (A CS01 -58) - Bkgd (A CS01 -58) - ADJ ADJ ADJ ADJ Result ADJ CRQL Result ADJ CRQL Result ADJ CRQL Result ADJ CRQL Result ADJ CRQL ADJ CRQL Flag CRQL Flag CRQL Flag CRQL Flag CRQL Flag (mg/kg) or 3x Result (mg/kg) or 3x Result (mg/kg) or 3x Result (mg/kg) or 3x Result (mg/kg) (mg/kg) or 3x Result (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg) Chromium 9.5 0.83 30.9 (3x Result) 16.6 0.84 30.9 (3x Result) 11 0.79 30.9 (3x Result) 11.4 0.89 8.1 (3x Result) 11.2 0.87 8.1 (3x Result) Copper 24.5 0.83 11.1 (3x ADJ CRQL) 3.3 0.84 11.1 (3x Result) 4.8 0.79 11.1 (3x ADJ CRQL) 2.80 0.89 4.2 (3x Result) 2.8 0.87 4.2 (3x Result) Manganese 254 1.2 56.7 (3x ADJ CRQL) 11.6 1.3 18.9 (3x Result) 42.9 1.2 56.7 (3x ADJ CRQL) 13 1.3 11.7 (3x Result) 12.8 1.3 11.7 (3x Result) Mercury 3.9 0.51 0.11 (ADJ CRQL) 0.11 U 0.11 0.12 (ADJ CRQL) 0.022 UJ 0.11 0.11 (ADJ CRQL) 0.11 U 0.11 0.12 (ADJ CRQL) 0.11 U 0.11 0.12 (ADJ CRQL) Nickel 5.7 0.42 4.2 (3x Result) 2.1 0.42 5.4 (3x Result) 2.8 0.39 4.2 (3x Result) 0.92 0.44 2.88 (3x Result) 0.71 (0.53)* J+ 0.43 2.88 (3x Result) Silver 0.7 0.42 0.44 (ADJ CRQL) 0.42 U 0.42 0.4 (ADJ CRQL) 0.39 U 0.39 0.44 (ADJ CRQL) 0.44 U 0.44 0.49 (ADJ CRQL) 0.43 U 0.43 0.49 (ADJ CRQL) Zinc 49.1 0.83 23.1 (3x Result) 3.3 0.84 11.1 (3x Result) 14.5 0.79 23.1 (3x Result) 2.5 0.89 3.9 (3x Result) 1.6 0.87 3.9 (3x Result) KEY Bkgd - Background J - Estimated value ADJ CRQL – Adjusted contract required quantitation limit L -Reported concentration is below the contract required quantitation limit (CRQL) µg/kg - Concentration in microgram per kilogram UJ - Estimated quantitation limit mg/kg - Concentration in milligram per kilogram ^ - High biased. Actual concentration may be lower than the concentration reported B old - Concentration detected above background adjusted contract required quantitation limit (CRQL) UJ - Estimated quantitation limit U - Not detected at reported quantitation limit + - High biased. Actual concentration may be lower than the concentration reported * - The detected concentration was adjusted by using guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8 & 13-15 & 18). After adjusting the value for the qualified data, the adjusted value has remained the same as the original value reported or decreased significantly from the original value reported. Although not required by the HRS or fact sheet, qualified data are adjusted to demonstrate the relative decrease in contamination over background. ** - The detected concentration was adjusted by using guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8 & 14-15). After adjusting the value for the qualified data, the adjusted value has increased significantly from the original value reported. Although not required by the HRS or fact sheet, qualified data are adjusted to demonstrate the relative increase in contamination. Note: Unless otherwise flagged, bias on adjusted “ J” data results is unknown and treated as such. REFERENCES Chain of Custody Ref. 7, pp. 247 & 345 Ref. 7, pp. 247 & 345 Ref. 7, pp. 247 & 345 Ref. 7, pp. 247 & 345 Ref. 7, pp. 274 & 362 Laboratory Results Ref. 7, pp. 222-223, 335, 339 & 341 Ref. 7, pp. 223-224, 335-336, 339 & 341 Ref. 7, pp. 224-225, 336, 339 & 341 Ref. 7, pp. 225-226, 336, 339 & 341 Ref. 7, pp. 235-236, 355 & 358 Ref. 7, pp. 213-214, 217, 222-223, 330-331, 334-335, 339 & 341; Ref. 7, pp. 213-214, 217, 223-224, 330-331, 334-336, 339 & Ref. 7, pp. 214-214, 217, 224-225, 330-331, 334, 336, 339 & 341; Ref. 7, pp. 213-214, 217, 225-226, 330-331, 334, 336, 339 & 314; Ref. Ref. 7, pp. 213-214, 217, 235-236, 350-351, 354-355 & 358; Ref. 27, pp. 8, 14- Data Ref. 27, pp. 8 & 13-15; Ref .45, pp. 11-15 & 205-207 341; Ref. 27, pp. 8 & 14-15; Ref. 45, pp. 16-20 & 208-210 Ref. 27, pp. 8 & 13-15; Ref. 45, pp. 21-30 & 211-213 27, pp. 8 & 13-15; Ref .45, pp. 31-34 & 214-216 15 & 18; Ref .45, pp. 65-74 & 226-228

SO-Source Characterization Source No.: 4 Table 7 (continued) – Source 4 – Areas of Creosote Solids and Soil Contamination

Sample Number: ACS07-10 ACS10-02 ACS10-58 ACS10-10 EPA Sample Number: F9DC2/MF9DC2 F9DA8/MF9DA8 F9DA9/MF9DA9 F9DC5/MF9DC5 Sample Location: AC07 AC10 AC10 AC10 Sample Description Between Pond & Concrete Structure Creosote Area Creosote Area Creosote Area Sample Depth 8 - 10 foot Interval 0 - 2 foot interval 5 - 8 foot interval 8 - 10 foot interval Bkgd (ACS01-10) – Bkgd (AC01-02) - Bkgd (ACS01-58) - Bkgd (ACS01-10) - ADJ ADJ ADJ Result ADJ CRQL Result ADJ ADJ CRQL Result ADJ CRQL Result ADJ CRQL CRQL Flag CRQL (µg/kg) Flag CRQL or 3x Result (µg/kg) Flag or 3x Result (µg/kg) or 3x Result (µg/kg) Flag CRQL or 3x Result (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) ANALYT E: S VOCs 1,1'-Biphenyl 86,000 (8,600)* J 1,900 220 (ADJ CRQL) 210 U 210 200 (ADJ CRQL) 520 200 180 (ADJ CRQL) 44,000 (4,400)* J 2,100 220 (ADJ CRQL) 2-M ethylnaphthalene 69,000,000 19,000,000 220 (ADJ CRQL) 320 210 200 (ADJ CRQL) 4,000 (400)* J 2,000 180 (ADJ CRQL) 27,000,000 11,000,000 220 (ADJ CRQL) Acenaphthene 50,000,000 19,000,000 220 (ADJ CRQL) 600 210 200 (ADJ CRQL) 4,800 (480)* J 2,000 180 (ADJ CRQL) 21,000,000 11,000,000 220 (ADJ CRQL) Acenaphthylene 13,000 1,900 220 (ADJ CRQL) 860 210 200 (ADJ CRQL) 290 200 180 (ADJ CRQL) 7,200 2,100 220 (ADJ CRQL) Anthracene 30,000,000 19,000,000 220 (ADJ CRQL) 4,200 (420)* J 4,100 200 (ADJ CRQL) 5,000 (500)* J 2,000 1,320 (3x Result) 60,000,000 (6,000,000)* J 11,000,000 220 (ADJ CRQL) Benzo (a) anthracene 140,000 (14,000)* J 1,900 220 (ADJ CRQL) 19,000 (1,900)* J 4,100 200 (ADJ CRQL) 1,800 200 180 (ADJ CRQL) 6,400,000 (6,400,000)* LJ 11,000,000 220 (ADJ CRQL) Benzo (a) pyrene 60,000 (6,000)* J 1,900 220 (ADJ CRQL) 13,000 (1,300)* J 4,100 200 (ADJ CRQL) 1,700 200 330 (3,300)** (3x Result) 19,000 2,100 220 (ADJ CRQL) Benzo (b) fluoranthene 74,000 (7,400)* J 1,900 420 (4,200)** (3x Result) 23,000 (2,300)* J 4,100 200 (ADJ CRQL) 2,500 200 510 (5,100)** (3x Result) 21,000 2,100 420 (4,200)** (3x Result) Benzo (g,h,i) perylene 16,000 1,900 220 (ADJ CRQL) 7,100 (710)* J 4,100 200 (ADJ CRQL) 920 200 180 (ADJ CRQL) 5,500 2,100 220 (ADJ CRQL) Benzo (k) fluoranthene 58,000 (5,800)* J 1,900 220 (ADJ CRQL) 20,000 (2,000)* J 4,100 200 (ADJ CRQL) 1,200 200 540 (3x Result) 19,000 2,100 220 (ADJ CRQL) Carbazole 22,000,000 (22,000,000)* LJ 38,000,000 430 (ADJ CRQL) 860 400 390 (ADJ CRQL) 2,500 390 350 (ADJ CRQL) 69,000 (6,900)* J 4,100 430 (ADJ CRQL) Chrysene 13,000,000 (13,000,000)* LJ 19,000,000 220 (ADJ CRQL) 22,000 (2,200)* J 4,100 200 (ADJ CRQL) 1,800 200 360 (3,600)** (3x Result) 44,000 (4,400)* J 2,100 220 (ADJ CRQL) Dibenzo (a,h) anthracene 6,800 1,900 220 (ADJ CRQL) 2,600 210 200 (ADJ CRQL) 420 200 180(ADJ CRQL) 2,200 2,100 220 (ADJ CRQL) Dibenzofuran 43,000,000 19,000,000 220 (ADJ CRQL) 490 210 200 (ADJ CRQL) 5,300 (530)* J 2,000 180 (ADJ CRQL) 19,000,000 11,000,000 220 (ADJ CRQL) Fluoranthene 65,000,000 38,000,000 430 (ADJ CRQL) 50,000 (5,000)* J 8,000 390 (ADJ CRQL) 11,000 (1,100)* J 3,900 690 (6,900)** (3x Result) 28,000,000 20,000,000 430 (ADJ CRQL) Fluorene 51,000,000 19,000,000 220 (ADJ CRQL) 420 210 200 (ADJ CRQL) 5,400 (540)* J 2,000 180 (ADJ CRQL) 25,000,000 11,000,000 220 (ADJ CRQL) Indeno (1,2,3-cd) pyrene 20,000 1,900 220 (ADJ CRQL) 8,600 (860)* J 4,100 200 (ADJ CRQL) 1,100 200 180 (ADJ CRQL) 6,700 2,100 220 (ADJ CRQL) Naphthalene 140,000,000 19,000,000 220 (ADJ CRQL) 1,200 210 200 (ADJ CRQL) 7,100 (710)* J 2,000 180 (ADJ CRQL) 110,000,000 11,000,000 220 (ADJ CRQL) Phenanthrene 94,000,000 19,000,000 220 (ADJ CRQL) 4,800 (480)* J 4,100 200 (ADJ CRQL) 19,000 (1,900)* J 2,000 420 (4,200)** (3x Result) 63,000,000 11,000,000 220 (ADJ CRQL) Pyrene 36,000,000 19,000,000 220 (ADJ CRQL) 42,000 (3,541.3)* J 4,100 200 (ADJ CRQL) 6,300 (531.2)* J 2,000 480 (5,692.8)** (3x Result) 15,000,000 11,000,000 220 (ADJ CRQL) ANALYT E: TO TAL M ET ALS Bkgd (AC01-02) - Bkgd (ACS01-58) – Bkgd (ACS01-10) - ADJ Bkgd (ACS01-10) - ADJ ADJ Result Result ADJ CRQL ADJ CRQL Result ADJ CRQL Result ADJ CRQL Flag CRQL ADJ CRQL Flag Flag CRQL Flag CRQL (mg/kg) or 3x Result (mg/kg) (mg/kg) or 3x Result (mg/kg) or 3x Result (mg/kg) or 3x Result (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg) Chromium 3 0.8 12.6 (3x Result) 18.8 0.84 30.9 (3x Result) 11.5 0.81 8.1 (3x Result) 4 0.86 12.6 (3x Result) Lead 3.4 0.4 15.9 (3x Result) 39.1 0.42 38.4 (3x Result) 5.1 0.4 14.1 (3x Result) 3.6 0.43 15.9 (3x Result) M anganese 3.3 1.2 6.9 (3x Result) 96.4 1.2 56.7 (3x Result) 10.9 1.2 11.7 (3x Result) 6.1 1.2 6.9 (3x Result) M ercury 0.11 U 0.11 0.11 (ADJ CRQL) 1.9 0.11 0.06 (0.12)** (3x Result) 0.12 U 0.12 0.12 (ADJ CRQL) 0.095 U 0.095 0.11 (ADJ CRQL) Zinc 0.8 U 0.8 5.4 (3x Result) 28.8 0.84 23.1 (3x Result) 3.1 0.81 3.9 (3x Result) 0.86 U 0.86 5.4 (3x Result) KEY Bkgd - Background Bold - Concentration detected above background adjusted contract required quantitation limit (CRQL) ADJ CRQL – Adjusted contract required quantitation limit U - Not detected at reported quantitation limit µg/k g - Concentration in microgram per kilogram J - Estimated value mg/kg - Concentration in milligram per kilogram L -Reported concentration is below the contract required quantitation limit (CRQL) * - The detected concentration was adjusted by using guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8 & 13-15 & 18). After adjusting the value for the qualified data, the adjusted value has remained the same as the original value reported or decreased significantly from the original value reported. Although not required by the HRS or fact sheet, qualified data are adjusted to demonstrate the relative decrease in contamination over background. ** - The detected concentration was adjusted by using guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8 & 14-15). After adjusting the value for the qualified data, the adjusted value has increased significantly from the original value reported. Although not required by the HRS or fact sheet, qualified data are adjusted to demonstrate the relative increase in contamination. Note: Unless otherwise flagged, bias on adjusted “J” data results is unknown and treated as such. REFERENCES Chain of Custody Ref. 7, pp. 274 & 362 Ref. 7, pp. 247 & 345 Ref. 7, pp. 247 & 345 Ref. 7, pp. 274 & 362 Laboratory Results Ref. 7, pp. 259-260, 355-356 & 358 Ref. 7, pp. 226-227, 336, 339 & 341 Ref. 7, pp. 227-228, 336, 339 & 341 Ref. 7, pp. 263-264, 356 & 358-359 Ref. 7, pp. 253-254, 257, 259-260, 350-351, 354, 355-356; Ref. 27, pp. 8 Ref. 7, pp. 213-214, 217, 226-227, 330-331, 334, 336, 339 & Ref. 7, pp. 213-214, 217, 227-228, 330-331, 334, 336, 339 & Ref. 7, pp. 253-254, 257, 263-264, 350-351, 354, 356 & 358-359; Ref. Data & 14; Ref. 45, pp. 108-117 & 241-243 341; Ref. 27, pp. 8 & 14-15; Ref, 45, pp. 35-44 & 217-219 341; Ref. 27, pp. 8 & 13-15; Ref. 45, pp. 45-54 & 220-222 27, pp. 8 & 14; Ref. 45, pp. 139-148 & 250-252

SO-Source Characterization Source No.: 4 Table 7 (continued) – Source 4 – Areas of Creosote Solids and Soil Contamination

Sample Number: ACS19-10 (Duplicate of ACS10-10) ACS11-02 ACS11-58 EPA Sample Number: F9DB7/MF9DB7 F9DB0/MF9DB0 F9DC6/MF9DC6 Sample Location: AC19 AC11 AC11 Sample Description Creosote Area Creosote Area Creosote Area Sample Depth 8 - 10 feet interval 0 - 2 feet interval 5 - 8 feet interval Bkgd (ACS01-10) - Bkgd (AC01-02) – Bkgd (ACS01-58) – ADJ Result ADJ CRQL ADJ CRQL Result ADJ CRQL Result ADJ CRQL ADJ CRQL (µg/kg) Flag (µg/kg) or 3x Result (µg/kg) Flag CRQL or 3x Result (µg/kg) Flag (µg/kg) or 3x Result (µg/kg) (µg/kg) (µg/kg) (µg/kg) ANALYT E: S VOCs 1,1'-Biphenyl 120,000 (12,000)* J 190 220 (ADJ CRQL) 190 U 190 200 (ADJ CRQL) 25,000 2,400 180(ADJ CRQL) 2-M ethylnaphthalene 6,000,000 3,800,000 220 (ADJ CRQL) 140 (140)* LJ 190 200 (ADJ CRQL) 3,800,000 1,200,000 180 (ADJ CRQL) Acenaphthene 5,800,000 3,800,000 220 (ADJ CRQL) 890 190 200 (ADJ CRQL) 3,000,000 1,200,000 180 (ADJ CRQL) Acenaphthylene 190 UJ 190 220 (ADJ CRQL) 2,100 190 200 (ADJ CRQL) 4,900 2,400 180 (ADJ CRQL) Anthracene 3,800,000 3,800,000 220 (ADJ CRQL) 12,000 9,600 200 (ADJ CRQL) 1,900,000 1,200,000 1,320 (3x Result) Benzo (a) anthracene 130,000 (13,000)* J 190 220 (ADJ CRQL) 38,000 9,600 200 (ADJ CRQL) 1,400,000 1,200,000 180 (ADJ CRQL) Benzo (a) pyrene 84,000 (8,400)* J 190 220 (ADJ CRQL) 36,000 9,600 200 (ADJ CRQL) 14,000 2,400 330 (3,300)** (3x Result) Benzo (b) fluoranthene 73,000 (7,300)* J 190 420 (4,200)** (3x Result) 50,000 9,600 200 (ADJ CRQL) 17,000 2,400 510 (5,100)** (3x Result) Benzo (g,h,i) perylene 13,000 (1,300)* J 190 220 (ADJ CRQL) 14,000 900 200 (ADJ CRQL) 4,700 2,400 180 (ADJ CRQL) Benzo (k) fluoranthene 51,000 (5,100)* J 190 220 (ADJ CRQL) 49,000 9,600 200 (ADJ CRQL) 16,000 2,400 540 (3x Result) Bis(2-ethylhexyl)phthalate 190 UR 190 360 (3,600)** (3x Result) 660 190 200 (ADJ CRQL) 2,400 U 2,400 180 (ADJ CRQL) Carbazole 95,000 (9,500)* J 360 430 (ADJ CRQL) 1,700 370 390 (ADJ CRQL) 23,000 4,600 350(ADJ CRQL) Chrysene 28,000 (2,800)* J 190 220 (ADJ CRQL) 34,000 9,600 200 (ADJ CRQL) 37,000 2,400 360 (3,600)** (3x Result) Dibenzo (a,h) anthracene 9200 (920)* J 190 220 (ADJ CRQL) 11,000 9,600 200 (ADJ CRQL) 2,000 (2,000)* LJ 2,400 180 (ADJ CRQL) Dibenzofuran 4,900,000 3,800,000 220 (ADJ CRQL) 790 190 200 (ADJ CRQL) 3,300,000 1,200,000 180 (ADJ CRQL) Fluoranthene 11,000,000 (1,100,000)* J 360 430 (ADJ CRQL) 85,000 (8,500)* J 19,000 390 (ADJ CRQL) 6,100,000 2,300,000 690 (6,900)** (3x Result) Fluorene 6,200,000 3,800,000 220 (ADJ CRQL) 950 190 200 (ADJ CRQL) 4,100,000 1,200,000 180 (ADJ CRQL) Indeno (1,2,3-cd) pyrene 16,000 (1,600)* J 190 220 (ADJ CRQL) 18,000 9,600 200 (ADJ CRQL) 5,800 2,400 180 (ADJ CRQL) Naphthalene 29,000,000 3,800,000 220 (ADJ CRQL) 200 190 200 (ADJ CRQL) 6,000,000 1,200,000 180 (ADJ CRQL) Phenanthrene 17,000,000 3,800,000 220 (ADJ CRQL) 35,000 9,600 200 (ADJ CRQL) 12,000,000 1,200,000 420 (4,200)** (3x Result) Pyrene 4,600,000 3,800,000 220 (ADJ CRQL) 140,000 9,600 200 (ADJ CRQL) 3,300,000 1,200,000 480 (5,692.8)** (3x Result) ANALYT E: TO TAL M ET ALS Bkgd (ACS01-10) - Bkgd (AC01-02) – Bkgd (ACS01-58) – Result ADJ CRQL ADJ CRQL Result ADJ CRQL ADJ CRQL Result ADJ CRQL ADJ CRQL Flag Flag Flag (mg/kg) (mg/kg) or 3x Result (mg/kg) (mg/kg) or 3x Result (mg/kg) (mg/kg) or 3x Result (mg/kg) (mg/kg) (mg/kg) Chromium 4.5 0.83 12.6 (3x Result) 13.3 0.79 30.9 (3x Result) 9.2 0.82 8.1 (3x Result) Copper 0.79 (0.79)* LJ 0.83 4.5 (3x Result) 3.6 0.79 11.1 (3x Result) 1.4 0.82 4.2 (3x Result) Lead 3.3 0.42 15.9 (3x Result) 5.7 0.39 38.4 (3x Result) 4.2 0.41 14.1 (3x Result) M anganese 4.4 1.2 6.9 (3x Result) 15.1 1.2 56.7 (3x Result) 5.6 1.2 11.7 (3x Result) M ercury 0.1 U 0.1 0.11 (ADJ CRQL) 0.041 (0.041)* LJ 0.1 0.06 (0.12)** (3x Result) 0.11 U 0.11 0.12 (ADJ CRQL) Nickel 0.42 U 0.42 3.6 (3x Result) 2.4 0.39 4.2 (3x Result) 0.57 (0.42)* J+ 0.41 2.88 (3x Result) Zinc 1.3 0.83 5.4 (3x Result) 11.6 0.79 23.1 (3x Result) 0.82 U 0.82 3.9 (3x Result) KEY BKGD - Background U - Not detected at reported quantitation limit ADJ CRQL – Adjusted contract required quantitation limit J - Estimated value µg/k g - Concentration in microgram per kilogram L -Reported concentration is below the contract required quantitation limit (CRQL) mg/kg - Concentration in milligram per kilogram R - Result is not useable Bold - Concentration detected above background adjusted contract required quantitation limit (CRQL) '+ - High biased. Actual concentration may be lower than the concentration reported * - The detected concentration was adjusted by using guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8 & 13-15 & 18). After adjusting the value for the qualified data, the adjusted value has remained the same as the original value reported or decreased significantly from the original value reported. Although not required by the HRS or fact sheet, qualified data are adjusted to demonstrate the relative decrease in contamination over background. ** - The detected concentration was adjusted by using guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8 & 14-15). After adjusting the value for the qualified data, the adjusted value has increased significantly from the original value reported. Although not required by the HRS or fact sheet, qualified data are adjusted to demonstrate the relative increase in contamination. Note: Unless otherwise flagged, bias on adjusted “J” data results is unknown and treated as such. REFERENCES Chain of Custody Ref. 7, pp. 249 & 362 Ref. 7, pp. 247 & 345 Ref. 7, pp. 274 & 362 Laboratory Reports Ref. 7, pp. 236-237, 355 & 358 Ref. 7, pp. 228-229, 336-337 & 339-341 Ref. 7, pp. 264-265, 356 & 358-359 Ref. 7, pp. 213-214, 217, 350-351, 354-355 & 358; Ref. 27, pp. 8, 14-14 & 18; Ref. 7, pp. 213-214, 217, 228-229, 330-331, 334, 336-337 & 339-341; Ref. 27, Ref. 7, pp. 253-254, 257, 350-351, 354, 356 & 358-359; Ref. 27, pp. 8, 15 & 18; Data Ref. 45, pp. 75- 84 & 229-231 pp. 8,13, 15 & 18; Ref. 45, pp. 55-64 & 223-225 Ref. 45, pp. 149-158 & 253-255 62

SO-Source Characterization Source No.: 4

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

Containment

Gas release to air: The air migration pathway was not scored; therefore, gas release to air containment was not evaluated.

Particulate release to air: The air migration pathway was not scored; therefore, particulate containment was not evaluated.

Release to ground water: The ground water pathway was not scored; therefore, ground water containment was not evaluated.

Release via overland migration: Source area No. 4 receives surface runoff and drainage from former facility operations to include the drip area, washout area, creosote processing basin area, and the waste pit (Ref. 6, pp. 65 & 93). There is no historical data to indicate that facility operations included waste handling, disposal practices or facility permits (Ref. 4, p. 8; Ref. 12, p. 1; Ref. 26, p. 4). The containment factor value for Source No. 4 is 10 due to evidence of hazardous substance migration from the source area, and no observed maintained engineered cover or functioning and maintained run-on control system and runoff management system (Ref. 1, Table 4-2).

Because containment for this source is greater than zero, the following substances associated with the source can migrate via the Surface Water Migration Pathway (Ref. 1, Sec. 4.1.2.1.2.1.1):

• 1,1'-Biphenyl • Dibenzo (a,h) anthracene • 2-Methylnaphthalene • Dibenzofuran • Acenaphthene • Fluoranthene • Acenaphthylene • Fluorene • Anthracene • Indeno (1,2,3-cd) pyrene • Benzo (a) anthracene • Lead • Benzo (a) pyrene • Manganese • Benzo (b) fluoranthene • Mercury • Benzo (g,h,i) perylene • Naphthalene • Benzo (k) fluoranthene • Nickel • Bis(2-ethylhexyl)phthalate • Phenanthrene • Carbazole • Pyrene • Chromium • Silver • Chrysene • Zinc • Copper

SO-Source Characterization Source No.: 4

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1.1. Hazardous Constituent Quantity – Tier A

The total Hazardous Constituent Quantity for Source 4 could not be adequately determined according to the HRS requirements; that is, the total mass of all CERCLA hazardous substances in the source and releases from the source is not known and cannot be estimated with reasonable confidence (Ref. 1, Sec. 2.4.2.1.1). Insufficient historical and current data (manifests, potentially responsible party [PRP] records, State records, permits, waste concentration data, etc.) are not available to adequately calculate the total or partial mass of all CERCLA hazardous substances in the source and the associated releases from the source. Therefore, there is insufficient information to calculate a total or partial Hazardous Constituent Quantity estimate for Source 4 with reasonable confidence. Scoring proceeds to the evaluation of Tier B, Hazardous wastestream quantity (Ref. 1, Sec. 2.4.2.1.1).

Hazardous Constituent Quantity Value (S): Not Calculated Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.2. Hazardous Wastestream Quantity – Tier B

The total Hazardous Wastestream Quantity for Source 4 could not be adequately determined according to the HRS requirements; that is, the total mass of all hazardous waste streams and CERCLA pollutants and contaminants for the source and releases from the source is not known and cannot be estimated with reasonable confidence (Ref. 1, Sec. 2.4.2.1.2). Insufficient historical and current data (manifests, potentially responsible party [PRP] records, State records, permits, waste concentration data, annual reports, etc.) are not available to adequately calculate the total or partial mass of all hazardous waste streams and CERCLA pollutants and contaminants for the source and the associated releases from the source. Therefore, there is insufficient information to adequately calculate or extrapolate a total or partial Hazardous Wastestream Quantity estimate for Source 4 with reasonable confidence. Scoring proceeds to the evaluation of Tier C, Volume (Ref. 1, Sec. 2.4.2.1.2).

Hazardous Wastestream Quantity Value (W): Not Calculated Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.3. Volume – Tier C

SO-Source Characterization Source No.: 4

In September 2002, Acadian collected eight (8) soil borings through AOC #4 based upon the downgradient topographic nature of the study area, the visual evidence of surface impact, the location of the western property boundary, and the bottom drainage basin located at the southern end of the study area (Ref. 4, pp. 14-16 & 32). TPH constituents in the collected soil samples exceeded the LDEQ RECAP industrial soil screening standards and their corresponding TPH values (Ref. 4, pp. 19-20 & 42- 76; Ref. 6, pp. 26-37, 86, 94-114, 116 & 118-119). Acadian’s proposed methodology for addressing the impacted soils was over-excavation of impacted areas and treatment of the impacted media (Ref. 4, p. 18). The proposed excavation within AOC #4 consists of 35,700 ft2 (0.82) acres to a two (2) foot depth resulting in a proposed excavation volume of 2,644 yd3 or 3,438 yd3 of soil to be remediated (Ref. 4, pp. 17, 22-23 & 36).

In the 2003 Voluntary Remedial Action Plan, Acadian designated contaminated surface soils as AOC #4, primarily downgradient of the old drip area and the wash pit area, and was approximately ½ acre in size (Ref. 4, pp. 11 & 14). Historical plans and the Acadian site inspections indicate the area is void of any structures from the previous creosote operations (Ref. 4, p. 14). Previous visual site inspections by LDEQ and Acadian personnel revealed considerable amounts of weathered creosote product on the ground surface primarily along the western property boundary (Ref. 4, p .14).

In April 2014 Acadian submitted a CAP that identified the area most necessary to undergo corrective action, a 7,500 ft2 AOC, bound to the east by the westernmost portion of the abandoned concrete retort house basins and to the west by the western bankline of the abandoned waste pit (Ref. 26, pp. 6-7 & 16- 17). The AOC outside of the waste pit has an approximate area of 7,500 ft2, and based on a six (6) inch removal depth that would be placed into the waste of solidification, an approximate total of 3,750 ft3 (Ref. 26, p. 8) .

Additionally, LDEQ in its Notice of Potential Liability to Kerr-McGee Chemical Corporation stated that the pathway of hardened creosote and underlying contaminated soils beginning along the west side of the pit and gently sloping southward downgradient from the pit paralleling the east side of a one track railroad spur owned by BNSF is approximately 400 feet long and 10-20 feet wide, and lies mostly within BNSF 50 foot ROW from the track centerline (Ref. 14, pp. 1-2). In a 1996 Soil Remediation work plan it was noted that visual evidence revealed surface impact to the adjoining property and stream bed (Ref. 4, p. 9). The creosote impact extends approximately 250 feet along the eastern ROW and is approximately 20-25 feet wide (Ref. 8, p. 5). During the 2016 ESI no visual observation of creosote surface impact was evident to the adjoining property, but an observed release by chemical analysis was documented revealing the same PAHs detected in the sources having impacted the contiguous site wetlands and adjoining streams (Ref. 39, pp. 53-58, 65 & 84-88).

Source No. 4 hazardous waste quantity evaluated two source areas of contaminated soil that have been aggregated based on having the same source type and having similar characteristic (Ref. 1, Sec. 4.2). The first area of contaminated soil being evaluated consists of the area between the concrete structure (Source No. 1) and the unlined wastewater pit (Source No. 3), and will adequately cover sample locations AC-05, AC-07, and AC-10 (Contaminated Soil Area 1) (Figure 3; Ref. 4, pp. 14, 22 & 35; Ref. 26, pp. 7-8, 16-17 & 19-20). The second area of contaminated soil being evaluated consists of a patch of contaminated soil located along the BNSF ROW adjacent to the western property boundary of CMC and north of a stream bed, and will include sample location AC-11 ( Contaminated Soil Area 2) (Figure 3; Ref. 4, pp. 9, 32; Ref. 14, pp. 1-2).

SO-Source Characterization Source No.: 4

Contaminated Soil Area 1

Using the estimate for the areas of soil contamination for the locations surrounding the facility of operations from the 2014 CAP, of 7,500 ft2, and based on a six (6) inch removal depth, the volume of contaminated soils would be 3,750 ft3 (Ref. 4, pp. 14, 22, 35; Ref. 26, pp. 8, 16-17 & 19-20). The evaluation equation applied for the conversion of cubic feet (ft3) to cubic yards (yds3) is 1 yd3 = 27 ft3. The estimated capacity of the contaminate soils surrounding the facility operations is 138.89 yd3.

3,750 cubic feet (ft3) x 1 cubic yard (yd3) ÷ 27 cubic feet (ft3) = 138.89 yd3

Contaminated Soil Area 2

Additionally, using the estimate for the area of soil contamination to the adjoining property paralleling the east side of a one track railroad spur owned by BNSF and a stream bed 400 feet long, 10 feet wide and based on a six (6) inch removal depth the area of contaminated soils would be 2,000 ft3 (Ref. 4, p. 9; Ref. 14, pp. 1-2). The evaluation equation applied for the conversion of cubic feet (ft3) to cubic yards (yds3) is 1 yd3 = 27 ft3. The estimated capacity of the contaminated soil along the track railroad spur owned by BNSF and stream bed is 74.07 yd3.

2,000 cubic feet (ft3) x 1 cubic yard (yd3) ÷ 27 cubic feet (ft3) = 74.07 yd3

Source No. 4 Volume (Contaminated Soil Area 1 & 2)

The total estimated volume of the contaminated soil surrounding the facility operations, along the track railroad spur owned by BNSF and the stream bed is 212.96 yd3.

138.89 yd3 + 74.07 yd3 = 212.96 yd3

The hazardous waste quantity evaluation equation for contaminated soil is V/2,500 (Ref. 1, Table 2-5). The volume source will be assigned a volume hazardous waste quantity value of 0.09.

212.96 yd3 ÷ 2,500 = 0.09

Volume of source (yd3): 212.96 Reference(s): Ref. 1, Table 2-5 Volume Assigned Value: 0.09

2.4.2.1.4. Area – Tier D

Tier D, An area was not calculated for Source 4 since the volume was estimated. Therefore, according to HRS, the area is not calculated (Ref. 1, Sec. 2.4.2.1.3 and 2.4.2.1.4).

Area of Source No. 4 in square feet (ft2): Not Applicable Area Assigned Value: 0 References: Ref. 1, Sec. 2.4.2.1.4

SO-Source Characterization Source No.: 4

2.4.2.1.5. Source Hazardous Waste Quantity Value

Source No. 4, Areas of Creosote Solids and Soil Contamination

Surface Water, Ground Water and Measures Air Pathways Tier A NC Tier B NC Tier C 0.09 Tier D 0 Assigned Source Hazardous 0.09 Waste Quantity Value (Ref. 1, Sec. 2.4.2.1.5) NC: Not Calculated

The highest value assigned to either Tier A, Tier B, Tier C, or Tier D is assigned as the Source No. 4 Hazardous Waste Quantity Value (Ref. 1, Sec. 2.4.2.1.5). The highest value assigned is Tier C.

Source No. 4 Hazardous Waste Quantity Value: 0.09

SO-Source Characterization Source No.: 5

2.2.1 SOURCE IDENTIFICATION – SOURCE 5

The following information corresponds to the fifth source identified for this documentation record.

Number of source: 5

Name of source: Creosote Solids

Source Type: Pile

Description and Location of Source: A pile of weathered creosote waste located north of former facility operations in the locality of the old railroad spur on CMC property (Ref. 4, pp. 28-29; Ref. 7, pp. 44, 48, 84, 145, 182-183 & 549; Figure 3). Areas of creosote solids and soil contamination were observed at the site during the PA (Ref. 13, pp. 19, 58-60 & 76-77). This observation confirmed what was reported in 2003 during Acadian Engineers & Environmental Consultants environmental site investigation, and was considered AOC #1, the old drip area (Ref. 4, pp. 11-12, 20-21 & 29). Physical characteristics of the weathered creosote material are an approximate 1-4 inch thick layer on top of the surface soils, with textural characteristics of a dry hard mass (Ref. 6, pp. 154-155, 159 & 162; Ref. 26, p. 6).

In the Voluntary Remedial Action Plan Acadian designated the old drip area as AOC #1, which consisted of the former railroad spur (Ref. 4, pp. 11 & 28; Ref. 6, pp. 65 & 93). Previous visual site inspections of this area by LDEQ and Acadian personnel revealed surface conditions indicative of previous creosote spillage (Ref. 4, p. 11; Ref .6, pp. 140-141). In September 2002 subsurface sampling in the old drip area along the old railroad spur was performed (Ref. 4, p 11). Acadian personnel performed five (5) soil borings and acquired six (6) soil samples from the five (5) discrete locations, acquiring soil from either ground surface to two (2) feet bgs or from two (2) feet to four (4) feet bgs (Ref. 4, pp. 11 & 29; Ref. 6, pp. 69-70). The soil sampling was performed in an effort to determine the horizontal and vertical extent of impact to the shallow soils (Ref. 4, p. 12). Three (3) soil borings were performed in the approximate center of the abandoned railroad spur, and one (1) soil boring was performed approximately 30 feet from the abandoned railroad spur centerline in an effort to assess the potential for horizontal migration of previous spillage (Ref. 4, pp. 12 & 29). Hazardous substance associated with the old drip area, AOC #1, included acenaphthylene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (g,h,i) perylene, benzo (k) fluoranthene, chrysene, dibenzo (a,h) anthracene, fluoranthene, indeno (1,2,3-cd) pyrene, phenanthrene and pyrene (Ref. 4, pp. 11-12 & 48).

Of the five (5) soil samples collected within AOC#1, along the old railroad spur, one (1) sample revealed concentrations of benzopyrene (sic) in excess of RECAP screening standards for industrial soil (Ref. 4, pp. 20 & 29). Due to limiting amount of analytical data by which to establish isocontours, the proposed limits of excavation were primarily established based upon property features and characteristics (Ref. 4, p. 20). The previously identified visual area of impact was the drip area of the old railroad spur consequently resulting in residual surface spillage of creosote (Ref. 4, p. 20). Due to this, the limits of excavation for AOC#1 were limited to the immediate area of the abandoned railroad spur (Ref. 4, pp. 20-21 & 33). The proposed excavation consisted of a 100 foot x 8 foot area at a two (2) foot depth resulting in an in-place volume of 59 cubic yards and an excavation/remediation volume of 77 cubic yards (Ref. 4, pp. 21 & 33).

SO-Source Characterization Source No.: 5

During the June 2015 EPA SI a waste sample was collected from one (1) pile of weathered creosote solids located in the old drip area, which consisted of the former railroad spur (Figure 3; Ref. 4, pp. 28- 29; Ref. 7, pp. 44 & 84). The waste sample was collected using a trowel and transferred directly to the sample containers using the procedure in the EPA Environmental Response Team (ERT) Standard Operating Procedure (SOP) 2012, modified for the waste sample collected (Ref. 7, pp. 23-24, 44, 84, 182 & 436-449). The following waste sample was collected (Ref. 7, p. 44, 84, 145 & 549; Figure 3):

• Sample Location AC-26, Sample ACS26-06; collected from a creosote pile at 0 to 2 feet bgs

The waste sample was analyzed for TCL SVOCS by EPA CLP SOW SOM02.2 and for TAL total metals/mercury by EPA CLP SOW ISM02.2. Organic analyses was performed by KAP Technologies Inc. located in The Woodlands, Texas, and inorganic analysis was performed by Chemtech Consulting Group located in Mountainside, New Jersey. All data from analyses performed at KAP Technologies Inc. and Chemtech Consulting Group were reviewed and validated by the Houston EPA Laboratory (Ref. 7, pp. 27, 69-70, 220-230, 225-237, 259-260, 263-265, 335-341 & 355-359).

The waste sample of weathered creosote solids from the source area of the former railroad spur detected PAHs such as 2-methylnaphthalene, acenaphthylene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (k) fluoranthene, carbazole, chrysene, dibenzo (a,h) anthracene, dibenzofuran, fluoranthene, naphthalene, phenanthrene and pyrene were detected above release criteria (Ref. 7, pp. 48, 95 & 266-268; Table 8). While the increase in concentration is not required to associate the substance with the source, it does demonstrate the level in the waste sample is significantly above ADJ CRQLs.

Metal concentrations were also detected in the soil samples including chromium, copper, lead, manganese, mercury, nickel, and zinc greater than release criteria (Ref. 7, pp. 48, 95 & 357-358; Table 8). Again, while this increase in concentration is not required to associate the substances with the source, it does demonstrate the level in the soil samples are significantly above ADJ CRQLs.

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

PAHs such as 2-methylnaphthalene, acenaphthylene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (k) fluoranthene, carbazole, chrysene, dibenzo (a,h) anthracene, dibenzofuran, fluoranthene, naphthalene, phenanthrene and pyrene were detected in an area of creosote solids sampling located in the approximate area of the old drip area, which consisted of the former railroad spur (Table 8). These constituents were also detected in other sources at American Creosote DeRidder including the concrete structure, the oil/water separator and the unlined wastewater pit (Sources 1, 2 and 3, respectively) (Tables 3, 4, 5 & 6).

In addition, metal concentrations detected in the area of creosote solids included chromium, copper, lead, manganese, mercury, nickel, and zinc (Table 8).

69 SO-Source Characterization Source No.: 5

Table 8 – Source 5 – Creosote Pile

Sample Number: ACS26-06 EPA Sample Number: F9DC8/MF9DC8 Sample Location: AC26 Sample Description Creosote Pile Sample Depth 0 - 2 feet interval Result ADJ CRQL Flag (µg/kg) (µg/kg) ANALYTE: SVOCs 2-Methylnaphthalene 300 210 Acenaphthylene 1,500 210 Anthracene 2,900 210 Benzo (a) anthracene 16,000 10,000 Benzo (a) pyrene 16,000 10,000 Benzo (b) fluoranthene 26,000 10,000 Benzo (k) fluoranthene 24,000 10,000 Carbazole 1,100 410 Chrysene 25,000 10,000 Dibenzo (a,h) anthracene 3,200 210 Dibenzofuran 540 210 Fluoranthene 31,000 20,000 Naphthalene 960 210 Phenanthrene 2,500 210 Pyrene 32,000 10,000 ANALYTE: TOTAL METALS Result ADJ CRQL Flag (mg/kg) (mg/kg_ Chromi um 4.4 0.8 Copper 48.8 0.8 Lead 67 0.4 Manganese 254 1.2 Mercury 0.26 0.1 Nickel 5.3 0.4 Zi nc 57.8 0.8 KEY ADJ CRQL – Adjusted contract required quantitation limit µg/kg - Concentration in microgram per kilogram mg/kg - Concentration in milligram per kilogram Bold - Concentration detected above adjusted contract required quantitation limit (CRQL) REFERNCES Chain of Custody Ref. 274 & 363 Laboratory Reports Ref. 7, pp. 266-268 & 357-359 Ref. 7, pp. 253-254, 257, 350-351, 354 & 357- Data 359; Ref. 45, pp. 169-178 & 259-261

70 SO-Source Characterization Source No.: 5

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

Containment

Gas release to air: The air migration pathway was not scored; therefore, gas release to air containment was not evaluated.

Particulate release to air: The air migration pathway was not scored; therefore, particulate containment was not evaluated.

Release to ground water: The ground water pathway was not scored; therefore, ground water containment was not evaluated.

Release via overland migration: Source area No. 5 is a pile of creosote solid observed during the PA and sampled during the SI (Ref. 7, pp. 44, 84, 145 & 549; Ref. 13, pp. 19, 58-60 & 76-77). There is no historical data to indicate that facility operations included waste handling, disposal practices or facility permits (Ref. 4, p. 8; Ref. 12, p. 1; Ref. 26, p. 4). The containment factor value for Source No. 5 is 10 due to no observed maintained engineered cover or functioning and maintained run-on control system and runoff management system, or any observed associated containment features (Ref. 1, Table 4-2).

Because containment for this source is greater than zero, the following substances associated with the source can migrate via the Surface Water Migration Pathway (Ref. 1, Sec. 4.1.2.1.2.1.1):

• 2-Methylnaphthalene • Dibenzo (a,h) anthracene • Acenaphthylene • Dibenzofuran • Anthracene • Fluoranthene • Benzo (a) anthracene • Lead • Benzo (a) pyrene • Manganese • Benzo (b) fluoranthene • Mercury • Benzo (k) fluoranthene • Naphthalene • Carbazole • Nickel • Chromium • Phenanthrene • Chrysene • Pyrene • Copper • Zinc

71 SO-Source Characterization Source No.: 5

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1.1. Hazardous Constituent Quantity – Tier A

The total Hazardous Constituent Quantity for Source 5 could not be adequately determined according to the HRS requirements; that is, the total mass of all CERCLA hazardous substances in the source and releases from the source is not known and cannot be estimated with reasonable confidence (Ref. 1, Sec. 2.4.2.1.1). Insufficient historical and current data (manifests, potentially responsible party [PRP] records, State records, permits, waste concentration data, etc.) are not available to adequately calculate the total or partial mass of all CERCLA hazardous substances in the source and the associated releases from the source. Therefore, there is insufficient information to calculate a total or partial Hazardous Constituent Quantity estimate for Source 5 with reasonable confidence. Scoring proceeds to the evaluation of Tier B, Hazardous wastestream quantity (Ref. 1, Sec. 2.4.2.1.1).

Hazardous Constituent Quantity Value (S): Not Calculated Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.2. Hazardous Wastestream Quantity – Tier B

The total Hazardous Wastestream Quantity for Source 5 could not be adequately determined according to the HRS requirements; that is, the total mass of all hazardous waste streams and CERCLA pollutants and contaminants for the source and releases from the source is not known and cannot be estimated with reasonable confidence (Ref. 1, Sec. 2.4.2.1.2). Insufficient historical and current data (manifests, potentially responsible party [PRP] records, State records, permits, waste concentration data, annual reports, etc.) are not available to adequately calculate the total or partial mass of all hazardous waste streams and CERCLA pollutants and contaminants for the source and the associated releases from the source. Therefore, there is insufficient information to adequately calculate or extrapolate a total or partial Hazardous Wastestream Quantity estimate for Source 5 with reasonable confidence. Scoring proceeds to the evaluation of Tier C, Volume (Ref. 1, Sec. 2.4.2.1.2).

Hazardous Wastestream Quantity Value (W): Not Calculated Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.3. Volume – Tier C

72 SO-Source Characterization Source No.: 5

Hazardous Waste Volume Quantity Value (V): 0 Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.4. Area – Tier D

Insufficient historical and current data (manifests, potentially responsible party [PRP] records, State records, permits, waste concentration data, annual reports, etc.) are available to adequately calculate the volume associated with the creosote pile and the associated releases from the source. There is insufficient data (lack of creosote pile dimensions) to reasonably or accurately estimate a Hazardous Waste Quantity score based on Area – Tier D. However, visual site inspections by LDEQ and Acadian personnel revealed surface conditions indicative of creosote spillage (Ref. 4, p. 11; Ref .6, pp. 140-141). During the June 2015 EPA SI, a waste sample was collected from a pile of weathered creosote solids located in the old drip area, which consisted of the former railroad spur (Figure 3; Ref. 4, pp. 28-29; Ref. 7, pp. 44 & 84). At Sample location AC-26, sample ACS26-06, collected from a creosote pile at 0 to 2 feet bgs, documented the presence of PAHs such as 2-methylnaphthalene, acenaphthylene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (k) fluoranthene, carbazole, chrysene, dibenzo (a,h) anthracene, dibenzofuran, fluoranthene, naphthalene, phenanthrene and pyrene (Ref. 7, pp. 48, 95 & 266-268; Table 8); therefore, the Source Hazardous Waste Quantity area is estimated to be greater than zero, but exact value is unknown (Ref. 1, Sec. 2.4.2.1.4).

Hazardous Waste Area Quantity Value (A): >0 Are the data complete for hazardous constituent quantity for this area? No

2.4.2.1.5. Source Hazardous Waste Quantity Value

Source No. 5, Creosote Solids

Surface Water, Ground Water and Measures Air Pathways Tier A NC Tier B NC Tier C 0 Tier D >0 Assigned Source Hazardous >0 Waste Quantity Value (Ref. 1, Sec. 2.4.2.1.5) NC: Not Calculated

The highest value assigned to either Tier A, Tier B, Tier C, or Tier D is assigned as the Source No. 5 Hazardous Waste Quantity Value (Ref. 1, Sec. 2.4.2.1.5). The highest value assigned is Tier D.

Source No. 5 Hazardous Waste Quantity Value: >0

73 SO - Summary Other Possible Sources

SITE SUMMARY OF SOURCE DESCRIPTIONS

Containment Source Hazardous Waste Quantity Air Value Soil Exposure Surface Water and Subsurface Air Migration Gas Intrusion Particulate Source Pathway Ground Surface No. Pathway Water Water 1 62.22 NS NS 10 NS NS 2 9.26 NS NS 10 NS NS 3 49.38 NS NS 10 NS NS 4 0.09 NS NS 10 NS NS 5 >0 NS NS 10 NS NS Total 120.95 NS: Not Scored

Other Possible Sources

Other possible sources at American Creosote DeRidder include the former structures in the wash pit area (Ref. 4, p .11; Ref. 6, p. 65; Ref. 25, p. 6). The wash pit was identified as an area of concern in the Voluntary Remedial Action Plan submitted by Acadian in December 2003 (Ref. 4, pp. 11-14 & 28; Ref. 6, pp. 65 & 93-94). The wash pit area was acknowledged and characterized as AOC #2 (Ref. 4, p. 11; Ref, 6, pp. 65 & 93-94).

The wash pit area, AOC #2, entailed an approximate seven (7) acre study area (Ref. 4, p. 12; Ref. 6, p. 70). The study area consists of the concrete structure, addressed as Source No. 1, which historical mapping indicates was the location of the Retort House (Ref. 4, p. 12; Ref. 6, p. 70). Additionally, AOC #2 consists of several other features as shown on historical plans and boring location map (Ref. 4, pp. 12, 28-30; Ref. 6, p. 70). Historical mapping indicates that these structures consisted of three (3) 30 foot storage tank, one (1) unknown structure, one (1) water tower, one (1) shop building, three (3) abandoned water wells, and one (1) deep water well (Ref. 4, pp. 12 & 28; Ref. 6, p. 70). Site visual inspections by LDEQ and Acadian personnel revealed stained surface soils and residual weathered creosote within AOC #2, namely between the retort structure and the western boundary of AOC #2 (Ref. 4, pp. 12-13). In September 2002 subsurface sampling in the wash pit area was performed (Ref. 4, p 13). Twelve (12) soil borings were performed throughout AOC #2 (Ref. 4, pp. 13 & 30; Ref. 6, p. 71). The soil boring placement was based upon previous visual site inspection findings and the nature of the topographical features within AOC #2; namely the considerable down gradient slope from the identified structure to the south (Ref. 4, p. 13; Ref. 6, pp. 144 & 150). Acadian personnel collected 13 soil samples from 12 discrete locations, acquiring soil from either ground surface to two (2) feet bgs or from two (2) feet to four (4) feet bgs or from six (6) feet to seven (7) feet bgs (Ref. 4, p. 13; Ref. 6, p. 71). Hazardous substances associated with the wash pit area, AOC #2, included acenaphthene, acenaphthylene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (g,h,i) perylene, benzo (k) fluoranthene, chrysene, dibenzo (a,h) anthracene, fluoranthene, fluorene, indeno (1,2,3-cd)

74 SO - Summary Other Possible Sources

pyrene, phenanthrene and pyrene (Ref. 4, pp. 11, 12-13, 21, 53 & 72).

Additionally, the laboratory analytical values of the soil samples acquired during the 2002 sampling event exceeded LDEQ RECAP for industrial screening standards and the corresponding TPH values for benzoanthracene (sic), benzopyrene (sic), benzoflouranthracene (sic), dibenzoanthracene (sic), idenopyrene (sic) and naphthalene (Ref. 4, pp. 19-20; Ref. 6, pp. 86 & 95-114). The proposed methodology for addressing the impacted media was over excavation of the impacted areas and treatment of the impacted media (Ref. 4, p. 18).

75 SWO F – Surface Water Overland Flow/Flood Migration Component General Considerations

SURFACE WATER MIGRATION PATHWAY

4.1 OVERLAND/FLOOD MIGRATION COMPONENT

4.1.1.1 Definition of Hazardous Substance Migration Path for Overland/Flood Component General Considerations

One probable point of entry (PPE) has been identified: • The PPE is in a segment of contiguous Palustrine Freshwater Forested/Shrub wetland that contains discernible flow from an adjoining unnamed drainage ditch/stream (Ref. 6, p. 94; Ref. 7, p. 84; Ref. 10, p. 10; Ref. 16, p. 1; Ref. 28, pp. 6-9; Ref. 35, pp. 1-2; Ref. 39, pp. 79, 96-103; Figure 4). The PPE segment is located approximately mid-point on the western side of the CMC property and based on property features, characteristics, and the nature of the topography, the contiguous wetland and adjoining drainage ditch/stream are down gradient to the south from identified sources (Ref. 3, p. 1; Ref. 4, pp. 13, 20-21: Ref. 6, pp. 58 & 94; Ref. 12, p. 2; Ref. 39, pp. 96-103; Figure 1 & 4). The unnamed drainage ditch/stream adjoining the contiguous designated wetlands passes beneath the railroad spur, via a culvert, from east to west (Ref. 14, pp. 1-2; Ref. 28, pp. 6-8; Ref. 35, pp. 1-2; Ref. 39, pp. 96-103 & 105-106).

The migration route of all sources is southwest toward the railroad tracks, based on the topography of the property, and eventually all flow toward, and into the contiguous wetlands and adjoining unnamed drainage ditch/stream with discernible flow (Ref. 10, p. 10; Ref. 17, p. 2; Ref. 21, pp. 5 & 119-120; Ref. 28, pp. 3-9; Ref. 35, p. 1; Ref. 36, pp. 5, 7 & 9; Figure 5). From the PPE within the contiguous wetlands with discernible flow from an adjoining unnamed drainage ditch/stream, flow passes through a culvert beneath the railroad spur to the west, where the continuous stream flows into an unnamed perennial stream with adjoining contiguous wetlands. Flow continues southwest into a freshwater pond which contains emergent aquatic vegetation along the shoreline. The freshwater pond is bisected by Crosby Road but is continuously connected by culverts (Ref. 14, pp. 1-2; Ref. 21, pp. 119-120; Ref. 28, pp. 6-9; Ref. 35, pp. 1-3; Ref. 37, pp. 1-2 & 5; Ref. 39, pp. 102-103 & 105-113). Surface water subsequently discharges from the freshwater pond which contains contiguous wetland into an adjoining unnamed perennial stream on a slightly northwesterly path until the unnamed perennial stream encounters the Kansas City Southern Railroad ROW (Ref. 28, p. 5). The unnamed perennial stream with contiguous wetlands then flows south along the Kansas City Southern Railroad ROW to Palmetto Creek (Ref. 28, pp. 4-5). From Palmetto Creek which contains contiguous wetlands, surface water flows southeasterly till it merges into Bundick Creek (Ref. 28, pp. 3-4). The remainder of the 15-mile Target Distance Limit (TDL) for the surface water migration pathway is located in Bundick Creek which also contains contiguous wetlands (Figure 6).

Surface Water Pathway Description for Each Source Source Pathway Description PPE No 1 A Concrete Structure located on the central western PPE: A segment of contiguous Palustrine Freshwater boundary of the property, north of the drainage Forested/Shrub Wetlands that contains discernible ditch/stream adjoining the designated wetland area (Ref. flow from an adjoining unnamed drainage 4, pp. 9, 28 & 30; Ref. 6, pp. 70 & 93-94; Ref. 16, p. 1; ditch/stream (Ref. 28, pp. 6-9; Ref. 35, pp.1-2; Ref.

76 SWO F – Surface Water Overland Flow/Flood Migration Component General Considerations

Surface Water Pathway Description for Each Source Source Pathway Description PPE No Ref. 21, pp. 5 & 120; Ref. 28, pp. 6-7; Figure 2). Distance 36, pp. 1-7). to PPE is approximately 500 feet (Ref. 4, p. 30; Ref. 6, p. 94; Ref. 16, p. 1; Ref. 21, p. 120; Figure 2, 3 & 4) 2 The oil/water separator is located just northwest and PPE: A segment of contiguous Palustrine Freshwater adjacent to the concrete structure, north of the drainage Forested/Shrub Wetlands that contains discernible ditch/stream adjoining the designated wetland area(Ref. flow from an adjoining unnamed drainage 4, pp. 9, 28 & 30; Ref. 6, pp. 93-94; Ref. 28, pp. 6-7; ditch/stream (Ref. 28, pp. 6-9; Ref. 35, pp. 1-2; Ref. Figure 2).Distance to the PPE is approximately 560 feet 36, pp. 1-7). (Ref. 4, p. 30: Ref. 6, p. 94; Figure 2, 3 & 4) 3 The open unlined abandoned rectangular wastewater pit PPE: A segment of contiguous Palustrine Freshwater lies between the retort foundation and the Santa Fe track Forested/Shrub Wetlands that contains discernible to the west, north of the drainage ditch/stream adjoining flow from an adjoining unnamed drainage the designated wetland area (Ref. 4, pp. 14, 28 & 31; Ref. ditch/stream (Ref. 28, pp. 6-9; Ref. 35, pp. 1-2; Ref. 6, pp. 72 & 93-94; Ref. 16, p. 1; Ref. 21, pp. 5 & 120; 36, pp. 1-7). Ref. 28, pp. 6-7; Figure 2). Distance to the PPE is approximately 415 feet (Ref. 6, p. 94; Ref. 16, p. 1; Ref. 21, p. 120; Figure 2, 3 & 4) 4 Areas of soil contamination, primarily downgradient of PPE: A segment of contiguous Palustrine Freshwater the old drip area, the wash pit area, north of the drainage Forested/Shrub Wetlands that contains discernible ditch/stream adjoining the designated wetland area (Ref. flow from an adjoining unnamed drainage 4, pp. 11, 14 & 32; Ref. 6, pp. 72 & 94; Ref. 28, pp. 6-7; ditch/stream (Ref. 28, pp. 6-9; Ref. 35, pp. 1-2; Ref. Figure 2). Distance to the PPE from sample location 36, pp. 1-7). ACS-14 is approximately 0 feet (Ref. 4, p. 32, Ref. 6, p. 94; Figure 2, 3 & 4) 5 A pile of weathered creosote waste located north of PPE: A segment of contiguous Palustrine Freshwater for mer facility operations and the drainage ditch/stream Forested/Shrub Wetlands that contains discernible adjoining the designated wetland area (Ref. 7, pp. 43-44, flow from an adjoining unnamed drainage 48, 84, 145, 182-183, 205 & 549; Figure 2). Distance to ditch/stream (Ref. 28, pp. 6-9; Ref. 35, pp. 1-2; Ref. the PPE from sample location AC-26 is approximately 36, pp. 1-7). 690 feet (Ref. 7, pp. 84, 145, 182, 205; Figure 2, 3 & 4).

Definition of In-Water Segments

The in-water segment of the 15-mile TDL begins at the most upstream point of the PPE, from which the 15-mile TDL starts, and ends along Bundick Creek. The PPE is located in contiguous palustrine freshwater forested/shrub wetlands with discernible flow from an adjoining unnamed ditch/stream (Figure 5; Ref. 28, p. 7; Ref. 35, pp. 1 & 3). The beginning of the in-water segment is in the contiguous palustrine freshwater forested/shrub wetland and the adjoining unnamed drainage ditch/stream with discernible flow that flows continuous for approximately 200 feet, passing beneath a railroad spur to the west, flowing into an unnamed perennial stream which contains contiguous wetlands (Ref. 28, p. 6-7; Ref. 35, p. 1-3). The unnamed perennial stream which contains contiguous wetlands flows approximately 790 feet southwest into a freshwater pond which contains emergent aquatic vegetation along its shoreline. The freshwater pond is bisected by Crosby Road but is continuously connected by culverts (Ref. 28, p. 6-7; Ref. 35, pp. 1-3). Surface water flows approximately 725 feet across the freshwater pond, with emergent aquatic vegetation along the shoreline, subsequently discharging into an unnamed perennial stream which also contains contiguous wetlands (Ref. 28, p. 6; Ref. 35, pp. 1-3). The unnamed perennial stream adjoining which contains contiguous palustrine freshwater forested/shrub wetlands flows approximately 0.41 miles on a slightly northwesterly path till the stream encounters the

77 SWO F – Surface Water Overland Flow/Flood Migration Component General Considerations

Kansas City Southern Railroad ROW (Ref. 28, p. 5). The unnamed perennial stream which contains contiguous wetlands then flows south along the Kansas City Southern Railroad ROW approximately 1,900 feet to Palmetto Creek. Palmetto Creek flows southeasterly and is bordered by contiguous palustrine freshwater forested/shrub wetlands until it merges into Bundick Creek in approximately 4.50 miles (Ref. 28, pp. 4-5). The remainder of the 15-mile TDL for the surface water migration pathway is located in Bundick Creek which also contains contiguous palustrine freshwater forested/shrub wetlands (Figure 6; Ref. 28, pp. 4-7; Ref. 35, pp 1-3).

Segment 1

The contiguous palustrine freshwater forested/shrub wetlands and adjoining unnamed drainage ditch/stream with discernible flow, which includes the PPE, flows continuously for approximately 200 feet passing beneath the railroad spur, via a culvert, to the west flowing into a perennial unnamed stream with adjoining contiguous wetlands (Figure 5; Ref. 28, pp. 6-7; Ref. 35, pp. 1-3). No published average stream flow data is available for this segment. Based on visual observation, it appears that this portion has an average stream flow of less than 10 cubic feet per second (cfs) and is a minimal stream and receives a dilution weight of 1 (Ref. 1, Table 4-13; Figures 5 & 6; Ref. 14, p. 2; Ref. 21, p. 120).

Segment 2

The unnamed perennial stream with adjoining wetlands that the unnamed drainage ditch/stream encounters flows for approximately 790 feet southwest into a freshwater pond, with emergent aquatic vegetation along the shoreline (Figure 5; Ref. 28, pp. 6-7; Ref. 35, pp. 1-3). No published average stream flow data is available for this segment. Based on visual observation, it appears that this portion has an average flow of less than 10 cfs and is a minimal stream and receives a dilution weight of 1 (Ref. 1, Table 4-13; Figures 5 & 6; Ref. 28, pp. 6-7).

Segment 3

The freshwater pond with emergent aquatic vegetation is bisected by Crosby Road but continuously connected by culverts. It is approximately 2.11 acres in size, with surface water flowing approximately 725 feet across the water body (Figures 5 & 6; Ref. 28, p. 6; Ref. 35, pp. 1-3). The freshwater pond receives surface water from the northeast from the perennial unnamed stream, and discharges surface water to the west into an unnamed perennial stream (Figures 5 & 6; Ref. 28, pp. 5-6). No published average flow data is available for this segment. Based on visual observation and the average flow rates assigned to Segment 2 and Segment 4, both unnamed perennial streams flowing and discharging from the freshwater pond, also with no published flow rate data, it appears this portion will also have an average flow of less than 10 cfs and receives a dilution weight of 1 (Ref. 1, Table 4-13; Figures 5 & 6; Ref. 28, pp. 5-6).

Segment 4

The unnamed perennial stream with contiguous wetlands, receiving discharge from the freshwater pond, flows approximately 0.40 miles on a slightly northwesterly path until the stream encounters the Kansas City Southern Railroad ROW (Figure 5 & 6; Ref. 28, pp. 4-5). The unnamed perennial stream with contiguous wetlands then flows south along the Kansas City Southern Railroad ROW approximately

SWO F – Surface Water Overland Flow/Flood Migration Component General Considerations

1,900 feet to Palmetto Creek (Figure 5 & 6; Ref. 28, pp. 4-5). No published average stream flow data is available for this segment. Based on visual observation, it appears that this portion has an average flow of less than 10 cfs and is a minimal stream and receives a dilution weight of 1 (Ref. 1, Table 4-13; Figure 6; Ref. 28, pp. 4-5).

Segment 5

Palmetto Creek, bordered by contiguous wetlands, flows southeasterly approximately 4.51 miles until it merges into Bundick Creek (Figure 6; Ref. 28, p. 3). No published average stream flow data is available for Palmetto Creek. The flow rate at the target location was extrapolated using the flow data from Bundick Creek. This segment will be set to equal the flow at the upstream gauging station and will be considered to be a moderate to large stream and will be assigned a dilution value of 0.01 (Ref. 1, Table 4-13; Figure 6).

Segment 6

The remainder of the 15-mile TDL surface water migration pathway ends along Bundick Creek which is also bordered by contiguous wetlands (Figure 6; Ref. 28, p. 3). A United States Geological Survey (USGS) gauging station 08080204, located in Beauregard Parish near DeRidder, Louisiana, has an average annual flow rate for Bundick Creek as measured for water years 1957 through 2015 of 150.88 cfs (Ref. 29, pp. 1-4). USGS gauging station, 08080204 is located on Bundick Creek approximately 1.68 miles upstream from the confluence of Palmetto Creek and Bundick Creek at latitude 30°49'07" North and longitude 93°13'48" West (Ref. 29, p. 1). A moderate to large stream with an average stream flow rate greater than 100 cfs to 1,000 cfs receives a dilution value of 0.01 (Ref. 1, Table 4-13; Figure 6). 4.1.2.1 Likelihood of Release 4.1.2.1.1 Observed Release Chemical Analyses

Site Inspection (SI) – June 2015

Background sediment sample, ACSD-02, was collected on CMC property up gradient from previous facility operations, at location AC-02, along the northern boundary of the property near to where Post Plant Road and the railroad tracks intersect, and along the drainage pathway identified along the BNSF ROW (Ref. 7, p. 150 & 182, 551; Ref. 15, p. 2; Ref. 17, p. 2; Ref. 35, p. 2; Ref. 36, pp. 8-9; Figure 3). Sediment sample location AC-02 was considered a background sample for sediments, as it was collected up gradient relative to known former designated facility operations (Ref. 4, p. 28; Ref. 6, p. 93; Figure 3).

Sediment sample (ACSD-12 and ACSD-15) were collected during the June 2015 EPA SI to assess the migration and observed release by chemical analysis of contamination in the surface water drainage pathway and designated wetlands as previously identified along the BNSF ROW from the former operations at the American Creosote DeRidder facility and associated PPE (Figures 3 & 4). The following samples were collected:

SWOF Likelihood of Release/Observed Release

• ACSD-12 - collected just north of the culvert/ditch along the railroad ROW, along the contiguous wetlands (Ref. 7, p. 57; Figure 3). • ACSD-15 – collected down gradient of former facility operations, southwest of the property boundary (Ref. 7, p. 60; Figure 3);

Samples collected from locations AC-02, AC-12, and AC-15 were sent to KAP Technologies Inc. located in The Woodlands, Texas, for organic analyses, and samples were sent to Chemtech Consulting Group located in Mountainside, New Jersey, for inorganic analyses. Sediment samples were analyzed for CLP SVOCs by EPA CLP SOW SOM02.2 and for TAL total metals/mercury by EPA CLP SOW ISM02.2. All data analyses performed at KAP Technologies Inc. and Chemtech Consulting Group were reviewed and validated by the Houston EPA Laboratory (Ref. 7, pp. 25-26, 69-70, 237-239, 260-263, 355-356 & 358).

Analytic results for sediment samples collected from locations AC-12 and AC-15 during the June 2015 EPA SI were compared to results for their representative background sample location (AC-02), also collected during that specific sampling event. See Table 9 for the background sediment sample and observed release sample concentrations.

The release sediment samples (AC-12 and AC-15) contained concentrations of PAHs and metals that met observed release criteria. These were: 2-methylnaphthalene, acenaphthene, acenaphthylene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (g,h,i) perylene, benzo (k) fluoranthene, carbazole, chrysene, dibenzo (a,h) anthracene, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, and pyrene. All were above ADJ CRQLs or three times the concentration in background sediment ADJ CRQLs (Ref. 1, Table 2-3; Figure 5; Table 9).

Expanded Site Inspection (ESI) – May 2016

Background sediment samples (AC-ESI-SD03 and AC-ESI-SD04) and one (1) collocated background surface water sample (AC-ESI-SW03) were collected up gradient of the PPE along separate, individual perennial streams on Ingevity property, and away from American Creosote DeRidder former facility operations (Ref. 39, pp. 37, 133-137, 157-158 & 382-383; Figures 3 & 5). Sediment sample AC-ESI- SD03 analyses included certain semi-volatile constituents above reporting limits, while analytical results of sediment sample AC-ESI-SD04 included one semi-volatile constituent above reporting limit (Ref. 39, pp. 37-38, 84, 88 & 216-221; Table 10).

Additionally, sediment samples (AC-ESI-SD01, AC-ESI-SD02, AC-ESI-SD05, AC-ESI-SD06, AC- ESI-SD07, AC-ESI-SD08, AC-ESI-SD09, AC-ESI-SD10 and AC-ESI-SD11) and surface water samples (AC-ESI-SD05, AC-ESI-SD06, AC-ESI-SD09 and AC-ESI-SD10) collected during the May 2016 EPA ESI were compared to their respective background sediment samples (AC-ESI-SD03 and AC-ESI- SD04) and surface water sample (AC-ESI-SW03), also collected during that specific sampling event (Ref. 39, pp. 53-58, 85-88, 115-132, 138-141, 154-161, 380-381, 384-390)(Tables 10, 11 & 12).

Samples collected from locations AC-ESI-01, AC-ESI-02, AC-ESI-03, AC-ESI-04, AC-ESI-05, AC- ESI-06, AC-ESI-07, AC-ESI-08, AC-ESI-09, AC-ESI-10 and AC-ESI-11 were sent to the U.S. EPA Laboratory in Houston, TX for analysis, data review and data validation for TCL SVOAs by EPA

SWOF Likelihood of Release/Observed Release

method EPA CLP OLM04.2 – GC/MA (Low Level) and TCL SVOAs by EPA CLP OLM04.2 – GC/MS (Low Level) (Ref. 39, pp. 28, 63 & 180-236).

Observed release sample concentrations were compared to the greater of the two background reporting limits or to three times above background limit concentrations. No semi-volatiles or inorganics were detected in the designated background surface water sample AC-ESI-SW03 (Ref. 39, pp. 88 & 228- 230). See Table 10 for background sediment samples and Table 12 for background surface water sample, and their respective observed release sample concentrations (Tables 11 & 12).

Nine (9) sediment samples (AC-ESI-SD01, AC-ESI-SD02, AC-ESI-SD05, AC-ESI-SD06, AC-ESI- SD07, AC-ESI-SD08, AC-ESI-SD09, AC-ESI-SD10, and AC-ESI-SD11) were collected during the May 2016 EPA ESI to assess the migration and observed release by chemical analysis of contamination in the surface water pathway from the former operations at the American Creosote DeRidder facility and associated PPE (Figures 3 & 4). The following samples were collected:

• AC-ESI-SD01 - collected along the unnamed drainage ditch/stream in contiguous wetlands, the PPE (Ref. 39, pp. 53-54, 79 85, 140-141, 160, 380 ; Figure 3); • AC-ESI-SD02 - collected at the culvert along the unnamed drainage ditch/stream in the contiguous wetlands, along the PPE (Ref. 39, pp. 53-54, 79, 85, 138-139, 160, 381; Figure 3); • AC-ESI-SD05 - collected at the discharge area of the culvert along the unnamed drainage ditch/stream in contiguous wetland (Ref. 39, pp. 54-55, 79, 85, 130-132, 157, 384; Figure 3); • AC-ESI-SD06 - collected along the unnamed drainage ditch/stream in contiguous wetlands prior to entering the unnamed perennial stream (Ref. 39, pp. 54-55, 79, 86, 127-129, 156-157, 385; Figure 3); • AC-ESI-SD07 - collected down gradient of the PPE where the unnamed perennial stream flow enters into a freshwater pond bisected by Crosby Road (Ref. 39, pp. 56, 79, 86, 124-126, 156, 386; Figure 3); • AC-ESI-SD08 - collected from the bisected freshwater pond, at the point prior to where surface water passes through culverts from the east side of Crosby road to west side of Crosby Road (Ref. 39, pp. 56-57, 79, 86, 121-123, 155, 387; Figure 3); • AC-ESI-SD09 – collected where surface water enters, via culverts, the bisected freshwater pond on the west side of Crosby Road (Ref. 39, pp. 56-57, 79, 87, 118-120, 155, 388; Figure 3); • AC-ESI-SD10 – collected where the surface water discharges from the freshwater pond bisected by Crosby Road (Ref. 39, pp. 56-58, 79, 87, 115-117, 154, 389; Figure 3); and • AC-ESI-SD11 – a duplicate sample collocated with sediment sample AC-ESI-SD07, and collected down gradient of the PPE where the unnamed perennial stream flow enters into a freshwater pond bisected by Crosby Road (Ref. 39, pp. 56, 58, 79, 87, 156, 390; Figure 3).

The sediments contained numerous PAHs that met observed release criteria including: 1- methylnaphthalene, 2-methylnaphthalene, acenaphthene, acenaphthylene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (g,h,i) perylene, benzo (k) fluoranthene, chrysene, dibenzo (a,h) anthracene, dibenzofuran, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, naphthalene, phenanthrene and pyrene all above reporting limits or three times the concentration in background sediment samples (Ref. 1, Table 2-3; Tables 10 & 11).

SWOF Likelihood of Release/Observed Release

Three (3) surface water samples (AC-ESI-SW05, AC-ESI-SW06, and AC-ESI-SW10) collocated with their respective sediment samples were also collected during the May 2016 EPA ESI, to identify and assess the migration and observed release of contamination in the surface water pathway from the former American Creosote DeRidder facility (Figure 3 & 4). The following samples were collected:

• AC-ESI-SD05 - collected at the discharge area of the culvert along the unnamed drainage ditch/stream in contiguous wetlands (Ref. 39, pp. 54-55, 79, 85, 130-132, 157, 384; Figure 3); • AC-ESI-SD06 - collected along the unnamed drainage ditch/stream in contiguous wetlands prior to entering the unnamed perennial stream (Ref. 39, pp. 54-55, 79, 86, 127-129, 156-157, 385; Figure 3); and • AC-ESI-SD10 – collected where the surface water discharges from the freshwater pond bisected by Crosby Road (Ref. 39, pp. 56-58, 79, 87, 115-117, 154, 389; Figure 3)

The surface water samples collected along the surface water migration pathway contained concentrations of PAHs that met observed release criteria include: benzo (a) pyrene, and fluoranthene (Ref. 1, Table 2-3; Table 12).

Chemical analyses of the sediment and surface water samples collected at and along the PPE, along the unnamed drainage ditch/stream adjoining the contiguous wetlands, and along the surface water migration pathway provide analytical evidence of an observed release of hazardous substances in the media significantly above background and attribution of at least part of the increase to the site.

SWOF Likelihood of Release/Observed Release

Table 9 – Site Inspection Background and Release Sediment Samples

Sample Numbe r: ACSD02-06 ACSD12-06 ACSD15-06 EPA Sample Numbe r: F9DB8/MF9DB8 F9DC3/MF9DC3 F9DC4/MF9DC4 Sampling Location: AC02 AC12 AC15 Sediment from Culvert/Ditch in Sample Description Sediment Background Sediment from SW Property Boundary Wetland ADJ Bkgd - ADJ CRQL Result Result ADJ CRQL Result ADJ CRQL Fla g CRQL or 3x Result Fla g Fla g (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) ANALYTE: SVOCs 2-Methylnaphthalene 23 3.4 69 (3x Result) 370 210 60 3.7 Acenaphthene 22 3.4 66 (3x Result) 510 210 24 3.7 Acenaphthylene 3.4 UJ 3.4 3.4 (ADJ CRQL) 1,100 210 29 (2.9)** J 3.7 Anthracene 27 (270)* J 3.4 81 (810)* (3x Result) 2,600 210 1,500 190 Benzo (a) anthracene 16 3.4 48 (3x Result) 4,600 2,100 2,700 1,900 Benzo (a) pyrene 39 3.4 117 (3x Result) 2,200 2,100 970 190 Benzo (b) fluoranthene 210 (2,100)* J 170 630 (6,300)* (3x Result) 3,900 2,100 2,000 190 Benzo (g,h,i) perylene 39 3.4 117 (3x Result) 3,500 210 480 190 Benzo (k) fluoranthene 190 170 570 (3x Result) 3,200 2,100 1,500 190 Bis (2-ethylhexyl)phthalate 170 U 170 170 (ADJ CRQL) 200 (200)** LJ 210 190 U 190 Carbazole 340 U 340 340 (ADJ CRQL) 710 410 370 U 370 Chrysene 28 3.4 84 (3x Result) 7,900 2,100 4,400 1,900 Dibe nzo (a,h) anthracene 3.4 U 3.4 3.4 (ADJ CRQL) 2,000 210 250 190 Fluoranthene 170 (1,700)* J 34 510 (5,100)* (3x result) 7,400 4,100 4,200 3,700 Fluorene 170 U 170 170 (ADJ CRQL) 520 210 32 3.7 Indeno (1,2,3-cd) pyrene 27 3.4 81 (3x Result) 4,100 210 580 190 Naphthalene 310 (3,100)* J 34 930 (9,300)* (3x Result) 1,200 210 560 190 Pyrene 44 (521.8)* J 3.4 132 (1,565.5)* (3x Result) 9,100 2,100 5,300 1,900 KEY Bkgd - Background U - Not detected at reported quantitation limit ADJ CRQL – Adjusted contract required quantitation limit J - Estimated value µg/k g - Concentration in microgram per kilogram L -Reported concentration is below the contract required quantitation limit (CRQL) mg/Kg - Concentration in milligram per kilogram UJ - Estimated quantitation limit Bold - Concentration detected significantly above background level (at or above adjusted contract required quantitation limit (CRQL) or 3 times or more background concentration if analyte is present in background sa mp le). * - The detected concentration was adjusted by using guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8 & 14-15). After adjusting the value for the qualified data, the adjusted value has increased significantly from the original value reported. ** - The detected concentration was adjusted by using guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8 & 14). After adjusting the value for the qualified data, the adjusted value remained as the original value reported or decreased significantly from the original value reported. Note: Unless otherwise flagged, bias on adjusted “J” data results is unknown and treated as such. REFERENCES Chain of Custody Ref. 7. pp. 248 & 362 Ref. 7, pp. 273 & 362 Ref. 7, pp. 273 & 362 Laboratory Reports Ref. 7, pp. 237-239, 355 & 357 Ref. 7, pp. 260-262, 356 & 358 Ref. 7, pp. 262-263, 356 & 358-359 Ref. 7, pp. 213-214, 217, 237-239, 350-351, 354-355 & 357; Ref. 7, pp. 253-254, 257, 260-262, Ref. 7, pp. 253-254, 257, 262-263, Ref. 27, pp. 8 & 14-15; Ref. 45, pp. 85-91 & 232-234 350-351, 354, 356 & 358; Ref. 27, 350-351, 354, 356 & 358-359; Ref. 27, Data pp. 8 & 14; Ref. 45, pp. 118-127 & pp. 8 & 14; Ref. 45, pp. 128-138 & 244-246 247-249

SWOF Likelihood of Release/Observed Release

Table 10 – Expanded Site Inspection Background Sediment Samples

Sample Number: AC-ESI-SD03 AC-ESI-SD04 EPA Laboratory ID: 1605035-03 1605035-04 Sample Location: AC-ESI-03 AC-ESI-04 Sample Location Background - Up Gradient Drainage Background - Up Gradient Drainage Tributary Description Tributary Bkgd – RL or Bkgd – RL or Result RL Result RL Flag 3x Result Flag 3x Result (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) ANALYTE: SVOCs 1-Methylnaphthalene U 63 63 (RL) U 72.1 72.1 (RL) 2-Methylnaphthalene U 63 63 (RL) U 72.1 72.1 (RL) Acenaphthene U 63 63 (RL) U 72.1 72.1 (RL) Acenaphthylene U 63 63 (RL) U 72.1 72.1 (RL) Anthracene 89.4 63 268.2 (3x) U 72.1 72.1 (RL) Benzo (a) anthracene U 252 252 (RL) U 288 288 (RL) Benzo (a) pyrene U 252 252 (RL) U 288 288 (RL) Benzo (b) fluoranthene 859 252 2,577 (3x) U 288 288 (RL) Benzo (g,h,i) perylene U 252 252 (RL) U 288 288 (RL) Benzo (k) fluoranthene 496 252 1,488 (3x) U 288 288 (RL) Carbazole U 252 252 (RL) U 288 288 (RL) Chrysene 429 252 1,287 (3x) U 288 288 (RL) Dibenz (a,h) anthracene U 252 252 (RL) U 288 288 (RL) Dibenzofuran U 252 252 (RL) U 288 288 (RL) Fluoranthene 261 63 783 (3x) U 72.1 72.1 (RL) Fluorene U 63 63 (RL) U 72.1 72.1 (RL) Indeno (1,2,3-cd) pyrene U 252 252 (RL) U 288 288 (RL) Naphthalene 154 63 462 (3x) U 72.1 72.1 (RL) Phenanthrene 105 63 315 (3x) U 72.1 72.1 (RL) Pyrene 309 63 927 (3x) U 72.1 72.1 (RL) KEY Bkgd - Background Bold - detected above Reporting Limit RL = Reporting Limit U - Undetected µg/kg - Concentration in microgram per kilogram REFERENCES Chain of Custody Ref. 39, p. 255 Ref. 39, p. 255 Laboratory Reports Ref. 39, pp. 216-218 Ref. 39, pp. 219-221 Data Ref. 39, pp. 175-176, 216-218 & 252-253 Ref. 39, pp. 175-176, 219-221 & 252-253

SWOF Likelihood of Release/Observed Release Table 11 – Expanded Site Inspection Release Sediment Samples

Sample Number: AC-ESI-SD01 AC-ESI-SD02 AC-ESI-SD05 AC-ESI-SD06 AC-ESI-SD07 EPA Laboratory ID: 1605035-01 1605035-02 1605035-05 1605035-06 1605032-01 Sample Location: AC-ESI-01 AC-ESI-02 AC-ESI-05 AC-ESI-06 AC-ESI-07 Drainage overland flow - Cul vert/ditch in the Drainage overland flow - Contiguous Sample Location Culvert/ditch in the contiguous wetlands at Discharge area of the Perennial stream prior to entry contiguous wetlands, along wetlands prior to entering the Description the PPE culvert in contiguous into the fresh water pond the PPE perennial stream wetlands Result RL Result RL Result RL Result RL Result RL Flag Flag Flag Flag Flag (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) ANALYTE: SVOCs 1-Methylnaphthalene 5,740 730 U 685 U 121 485 351 U 97.4 2-Methylnaphthalene 5,640 730 U 685 150 121 2,540 351 U 97.4 Acenaphthene 24,400 730 U 685 U 121 471 351 U 97.4 Acenaphthylene 11,900 730 3,750 685 815 121 1,450 351 271 97.4 Anthracene 191,000 7,300 6,290 685 1,250 121 81,700 3,510 1,070 97.4 Benzo (a) anthracene 851,000 (85,100)* J 292,000 108,000 27,400 13,200 4,820 27,800 14,100 1,630 390 Benzo (a) pyrene 406,000 292,000 118,000 27,400 14,000 4,820 29,000 14,100 3,080 390 Benzo (b) fluoranthene 847,000 292,000 188,000 27,400 31,300 4,820 60,700 14,100 7,660 3,900 Benzo (g,h,i) perylene 146,000 29,200 45,400 27,400 7,910 4,820 11,400 11,200 2,510 779 Benzo (k) fluoranthene 607,000 292,000 140,000 27,400 17,600 4,820 29,600 14,100 4,270 3,900 Carbazole 225,000 (22,500)* J 29,200 U 2,740 U 482 28,400 (2,840)* J 14,100 U 390 Chrysene 1,200,000 (120,000)* J 292,000 137,000 27,400 18,400 4,820 36,500 14,100 3,360 390 Dibenzo (a,h) anthracene 93,000 29,200 19,400 2,740 4,050 3,620 5,540 1,410 1,140 390 Dibenzofuran 22,800 2,920 U 2,740 U 482 3,700 1,410 U 390 Fluoranthene 3,370,000 730,000 110,000 6,850 17,800 1,210 34,800 3,510 1,580 97.4 Fluorene 27,300 730 U 685 U 121 7,910 351 U 97.4 Indeno (1,2,3-cd) pyrene 188,000 29,200 57,100 27,400 9,160 4,820 10,300 1,410 2,740 390 Naphthalene 6,150 730 U 685 446 121 3,110 351 154 97.4 Phenanthrene 1,120,000 73,000 1,550 685 834 121 16,400 3,510 339 97.4 Pyrene 1,960,000 (165,261)* J 73,000 135,000 6,850 21,200 1,210 40,000 3,510 2,340 97.4 KEY Bold - Detected significantly abo ve background level (at or above Reporting Limit or 3 times or more background concentration if analyte is present in background sample). Bkgd - Background RL - Reporting limit U - Undetected µg/kg - Concentration in microgram per kilogram J - The identification of the analyte is acceptable; the reported value is an estimate. * - The detected concentration was adjusted by using guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8 & 14-15). After adjusting the value for the qualified data, the adjusted value has decreased significantly from the original value reported. Note: Unless otherwise flagged, bias on adjusted “J” data results is unknown and treated as such. REFERENCES Chain of Custody Ref. 39, p. 255 Ref. 39, p. 255 Ref. 39, p. 255 Ref. 39, p. 255 Ref. 39, p. 254 Laboratory Reports Ref. 39, pp. 210-212 Ref. 39, pp. 213-215 Ref. 39, pp. 222-224 Ref. 39, pp. 225-227 Ref. 39, pp. 180-182 Ref. 39, pp. 175-176, 210-212 & 252-253; Ref. 39, pp. 175-176, 213- Ref. 39, pp. 175-176, 222- Ref. 39, pp. 175-176, 225-227 & Ref. 39, pp. 175-176, 180-182 Data Ref. 27, pp. 8 & 14-15 215 & 252-253 224 & 252-253 252-253; Ref. 27, pp. 8 & 14 & 252-253

SWOF Likelihood of Release/Observed Release Table 11 (continued) – Expanded Site Inspection Release Sediment Samples

Sample Number: AC-ESI-SD08 AC-ESI-SD09 AC-ESI-SD10 AC-ESI-SD11 EPA Laboratory ID: 1605032-02 1605032-03 1605032-04 1605032-05 Sample Location: AC-ESI-08 AC-ESI-09 AC-ESI-10 AC-ESI-11 Sample Location Freshwater Pond - Discharge Point Freshwater Pond - Entry Point Freshwater Pond - Discharge Duplicate Sample at Location AC- Description (East of Crosby Road) (West of Crosby Road) Point (West of Crosby Road) ESI-SD07 Result RL Result RL Result RL Result RL Flag Flag Flag Flag (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) (µg/kg) ANALYTE: SVOCs 1-Methylnaphthalene 243 124 U 84 U 86 166 111 2-Methylnaphthalene 659 124 U 84 U 86 480 111 Acenaphthene 476 124 U 84 U 86 268 111 Acenaphthylene 1,160 124 U 84 U 86 480 111 Anthracene 2,700 124 92.4 84 227 86 2,300 111 Benzo (a) anthracene 29,100 4,960 U 336 U 344 2,780 443 Benzo (a) pyrene 36,500 4,960 378 336 513 482 4,900 2,210 Benzo (b) fluoranthene 63,400 49,600 1,190 336 1,740 688 13,500 2,210 Benzo (g,h,i) perylene 14,400 4,960 U 336 468 447 4,160 2,210 Benzo (k) fluoranthene 37,400 37,200 416 336 1,030 688 7,430 2,210 Carbazole 669 (66.9)* J 496 U 336 U 344 U 443 Chrysene 29,700 4,960 521 336 769 344 6,060 2,210 Dibenzo (a,h) anthracene 9,660 4,960 U 336 U 344 2,180 2,100 Dibenzofuran 602 496 U 336 U 344 U 443 Fluoranthene 29,100 1,240 464 (46.4)* J 84 645 86 2,660 111 Fluorene 367 124 U 84 U 86 261 111 Indeno (1,2,3-cd) pyrene 17,700 4,960 U 336 547 516 5,680 2,210 Naphthalene 1,630 124 134 84 U 86 1,380 111 Phenanthrene 2,150 124 161 (16.1)* J 84 153 86 925 111 Pyrene 41,900 1,240 494 84 796 86 4,070 111 KEY Bold - Detected significantly above background level (at or above Reporting Limit or 3 times or more background concentration if analyte is present in background sample). Bkgd - Background RL - Reporting limit U - Undetected µg/kg - Concentration in microgram per kilogram J - The identification of the analyte is acceptable; the reported value is an estimate. * - The detected concentration was adjusted by using guidance document "Using Qualified Data to Document an Observed Release and Observed Contamination" (Ref. 27, pp. 8 & 14-15). After adjusting the value for the qualified data, the adjusted value has decreased significantly from the original value reported. Note: Unless otherwise flagged, bias on adjusted “J” data results is unknown and treated as such. REFERENCES Chain of Custody Ref. 39, p. 254 Ref. 39, p. 254 Ref. 39, p. 254 Ref. 39, p. 254 Laboratory Reports Ref. 39, pp. 183-185 Ref. 39, pp. 186-188 Ref. 39, pp. 189-191 Ref. 39, pp. 192-194 Ref. 39, pp. 175-176,183-185 & 252- Ref. 39, pp. 175-176, 186-188 & Ref. 39, pp. 175-176, 189-191 & Ref. 39, pp. 175-176, 192-194 & Data 253; Ref. 27, pp. 8 & 14 252-253; Ref. 27, pp. 8 & 15 252-253 252-253 86

SWOF Likelihood of Release/Observed Release Table 12 – Expanded Site Inspection Background and Release Surface Water Samples

Sample Number: AC-ESI-SW03 AC-ESI-SW05 AC-ESI-SW06 AC-ESI-SW10 EPA Laboratory ID: 1605035-07 1605035-08 1605035-09 1605032-09 Sample Location: AC-ESI-03 AC-ESI-05 AC-ESI-06 AC-ESI-10 Unnamed drainage Discharge area of the culvert ditch/stream in Freshwater Pond - Sample Location Background - Up Gradient of PPE along along the unnamed drainage contiguous wetlands prior Discharge Point (West Description Perennial Stream ditch/stream in contiguous to entering the unnamed of Crosby Road) wetlands perennial stream Bkgd – RL or Result RL Result RL Result RL Result RL Flag 3x Result Flag Flag Flag (µg/L) (µg/L) (µg/L) (µg/L) (µg/L) (µg/L) (µg/L) (µg/L) (µg/L) ANALYTE: SVOCs Benzo (a) pyrene U 0.2 0.2 (RL) U 0.2 0.6 0.2 0.3 0.2 Fluoranthene U 0.5 0.5 (RL) 0.8 0.5 1.3 0.5 U 0.5 KEY Bkgd - Background Bold - Detected above Reporting Limit RL = Reporting Limit U - Undetected µg/L - Concentration in microgram per liter REFERENCES Chain of Custody Ref. 39, p. 255 Ref. 39, p. 255 Ref. 39, p. 255 Ref. 39, p. 254 Laboratory Reports Ref. 39, pp. 228-230 Ref. 39, pp. 231-233 Ref. 39, pp. 234-236 Ref. 39, pp. 204-206 Ref. 39, pp. 175-176, 231- Ref. 39, pp. 175-176, Ref. 39, pp. 175-176, Data Ref, 39, pp. 175-176, 228-230 & 252-253 233 & 252-253 234-236 & 252-253 204-206 & 252-253

SWOF Likelihood of Release/Observed Release

Attribution

The Shreveport Creosoting Company operated a creosote timber facility from the early 1920’s to approximately 1945 on a parcel of land south of DeRidder, Beauregard Parish, Louisiana (Ref. 4, pp. 8 & 27-28). American Creosoting Company, Shreveport Creosoting Company’s parent company, relocated the creosote operations from this tract of land, although other wood treatment procedures are reported to have continued until 1956 or 1957 (Ref. 4, p. 8). From 1957 to 1992 the property remained dormant until its purchase by CMC in September 1992 who planned heavy industrial/commercial use (Ref. 4, p. 9; Ref. 8, p. 5; Ref. 9, p. 4; Ref. 10, p. 17).

The Shreveport Creosoting Company’s facilities and operations used creosote compounds, also known as liquid pitch oil, tar oil and coal tar solutions, in the wood preserving pressure treatment process (Ref. 8, p. 52; Ref. 11, p. 3). The specific operations at the facility consisted of dipping timber into creosote vats, the collection of spent creosote in an open pit, and the discharge of untreated process wastewater into an open pit (Ref. 6, p. 93; Ref. 9, p. 2; Ref. 12, p .1). There is no historical data to indicate that site operations included waste handling, disposal practices, releases or facility permits (Ref. 4, p. 8; Ref. 12, p. 1).

The site is currently void of any of these operations and consists of heavy timber and extensive overgrowth and lower story overgrowth in and around the abandoned site (Ref. 4. p. 9). Abandoned wood treatment facilities from the previous operations currently remain at the site (Ref. 4, p. 9). The American Creosote DeRidder site has been impacted by creosote related compounds from previous timber treatment operations at the site (Ref. 4, p. 9; Ref. 11, p. 3). Site investigations indicate that creosote from the previous facility operations appears to have impacted the CMC property at various locations identified to include the old drip area, wash pit, ground water, and surface soils (Ref. 4, pp. 9 & 11; Ref. 6, pp. 93-114). Additionally, visual evidence reveals surface impact to the adjoining property and stream bed (Ref. 4, p. 9). The creosote impact extends along the eastern BNSF ROW and railroad spur (Ref. 6, pp. 9 & 59; Ref. 8, p. 5). The impact is visually apparent and has formed sections of surficial asphaltic patches (Ref. 8, p. 5). Also, physical characteristics of the weathered creosote material are an approximately 1 inch to 4 inches thick layer on top of the surface soils, with textural characteristics of a dry hard mass (Ref. 26, pp. 6 & 18). The creosote at the site has hardened and dried and has acquired characteristics more similar to a tar or asphalt versus non-weathered creosote (Ref. 26, pp. 6 & 18).

COCs at the site that are being scored are constituents associated with the previous wood preservation facility that used creosote related compounds during wood processing operations (Ref. 4, p. 9; Ref. 6, pp. 8 & 59; Ref. 8, p. 5; Ref. 9, p. 2; Ref. 11, p. 3; Ref. 17, p. 2; Ref. 25, p. 5). The COCs at the site are CERCLA hazardous substances. Previous site investigations documented PAHs as known or suspected constituents to have been released (Ref. 6, pp. 8 & 59; Ref. 22, p. 6). Potential chemical hazards in the soil at the site are TPH in the form of diesel, and PAHs to include: 1,1 biphenyl, 2-methylnaphthalene, acenaphthene, acenaphthylene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (k) fluoranthene, bis (2-ethylhexyl) phthalate, chrysene, dibenzo (a,h) anthracene, dibenzofuran, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, naphthalene, phenanthrene and pyrene (Ref. 6, pp 13-41, 116, 118-119 & 121). Also, potential chemical hazardous found in the ground water at the site are TPH in the form of diesel, and PAHs to include: 1,1 biphenyl, 2,4-dimthylphenol, 2- methylnaphthalene, acenaphthene, acenaphthylene, aniline, anthracene, benzo (a) anthracene, benzo (a)

SWOF Likelihood of Release/Observed Release

pyrene, benzo (b) fluoranthene, benzo (k) fluoranthene, chrysene, dibenzo (a,h) anthracene, dibenzofuran, diethyl phthalate, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, naphthalene, phenanthrene and pyrene (Ref. 6, pp. 42-45 & 120-121).

During the operational period American Creosote DeRidder used creosote compounds, also known as liquid pitch oil, tar oil, and coal tar solutions, in the wood preserving pressure treatment process (Ref. 8, p. 52; Ref. 11, p. 3). The major chemicals in coal tar creosote, coal tar, and coal tar pitch are polycyclic aromatic hydrocarbons (PAHs), phenol, and cresols (Ref. 41, p. 23). Major components of wood creosote consist mainly of phenol, cresol, guaiacol, and xylenol, with phenols having been previously detected on site (Ref. 12, p. 3; Ref. 15, p. 2; Ref. 16, p.1; Ref. 41, p. 241). Common PAH components of coal tar pitch are acenaphthene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (g,h,i) perylene, benzo (b) fluoranthene, benzo (k) fluoranthene, 1,1 biphenyl, carbazole, chrysene, dibenzo (a,h) anthracene, dibenzofuran, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, 1-methylnaphthalene, 2-methylnaphthalene, naphthalene, phenanthrene and pyrene, which have been detected in site sources and releases to the surface water pathway (Ref. 41, pp. 245-248; Tables 2, 4-7, 8, 9, 11, & 12). Wastes from the former creosote operations were handled in the drip area (Source No. 4 and Source No. 5), waste pit (Source No. 3), washout area (Source No. 4) and creosote processing basin area (Source No. 1 and Source No. 2) (Ref. 4, pp. 11-15 7 28; Ref. 6, pp. 65 & 93). All wastes managed at the facility consisted of creosote compounds, and there is no historical data to indicate that facility operations included waste handling, disposal practices, or facility permits (Ref. 4, pp. 8-9; Ref. 8, p. 5; Ref. 12, p. 1; Ref. 26, p. 4). The American Creosote DeRidder site is considered to pose “a long term” threat to human health, safety and/or sensitive environmental receptors (Ref. 6, p. 79).

Eleven (11) sediment samples (ACSD-12, ACSD-15, AC-ESI-SD01, AC-ESI-SD02, AC-ESI-SD05, AC-ESI-SD06, AC-ESI-SD07, AC-ESI-SD08, AC-ESI-SD09, AC-ESI-SD10, and AC-ESI-SD11) were collected down gradient of former facility operations, along the contiguous palustrine freshwater forested/shrub wetland with discernible flow from an adjoining unnamed drainage ditch/stream, along the contiguous palustrine freshwater forested/shrub wetland and adjoining unnamed perennial stream, and from a freshwater pond with emergent aquatic vegetation along the shoreline that is bisected by Crosby Road but continuously connected by culverts, to determine the migration of contamination in the surface water pathway from the concrete structure (Source 1), oil/water separator (Source 2), unlined wastewater pit (Source 3), areas of soil contamination (Source 4), and creosote solids (Source 5) from the former American Creosote DeRidder operations (Figure 5; Ref. 7, pp. 57, 60 & 84; Ref. 28, pp.4-7; Ref. 35, pp. 1-3; Ref. 36, pp. 1-9; Ref. 37, pp. 1-5; Ref. 39, pp. 53-58, 85-88, 115-132, 138-141, 154- 161, 380-381, 384-390).

Three (3) surface water samples (AC-ESI-SW05, AC-ESI-SW06, and AC-ESI-SW10) were collected from the wetland at the unnamed drainage ditch/ stream contiguous and from the freshwater pond bisected by Crosby Road to assess the migration of contamination in the surface water pathway from the former American Creosote DeRidder operations (Figure 5; Ref. 39, pp. 54-58, 79, 85-87, 115-117, 127- 132, 154, 156-157, 384-385 & 389). In the release surface water samples located down gradient of former American Creosote DeRidder operations benzo (a) pyrene and fluoranthene were detected and met observed release criteria (Table 12).

Facilities located within a one (1) mile radius of the American Creosote DeRidder site were identified. It was determined that these facilities, although potentially, are unlikely to be contributing to the release of

SWOF Likelihood of Release/Observed Release

hazardous substance at the site based on background samples collected, and directional location and gradient from the site (Ref. 7, pp. 36-38, 84, 89 & 96; Ref. ; Ref. 30, pp. 7, 11, 13, 16, 22 & 25; Ref .39, pp. 37-38, 79, 84 & 88). The following types of facilities within a one (1) mile radius of American Creosote DeRidder are:

• Two (2) RCRA CORRACTS facilities (Ref. 30, pp 2 & 7-8) ; • One (1) Emergency Response Notification System (ERNS) facility (Ref. 30, pp 2 & 11-12 ); • Two (2) U.S. Toxic Release Inventory facilities (Ref. 30, pp 2 & 13-15 ); • Seven (7) US RCRA Generator facilities (Ref. 30, pp 2 & 16-20 ); • Four (4) National Pollutant Discharge Elimination System (NPDES) facilities (Ref. 30, pp 2 & 22-24); and • Four (4) US Air Facility System (AIRS/AFS) facilities (Ref. 30, pp 2 & 25-28)

There are no identified National Priorities List (NPL) sites, CERCLIS List sites, CERCLIS No Further Remedial Action Planned (NFRAP) sites, Resource Conservation and Recovery Act (RCRA) non- Correction Action Report (CORRACTS) Treatment, Storage, Disposal (TSD) facilities, Federal Institutional Control/Engineering Control Registry sites, U.S. Assessment, Cleanup and Redevelopment Exchange System (ACRES) (Brownfields), Louisiana (LA) Underground Storage Tanks or LA Leaking Underground Storage Tanks located within a one (1) mile radius of American Creosote DeRidder (Ref. 30, pp. 2, 4-6, 9-10, 21& 29-30).

Background sediment sample location AC-02 collected north of the property near where Post Plant Road and the railroad tracks intersect contained concentrations above the analytical ADJ CRQLs for 2- methylnaphthalene, acenaphthene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (g,h,i) perylene, benzo (k) fluoranthene, chrysene, cobalt, copper, fluoranthene, indeno (1,2,3-cd) pyrene, naphthalene, and phenanthrene (Table 9). Additionally, background sediment sample location AC-ESI-03, collected along an unnamed perennial stream up gradient of the surface water pathway from the former American Creosote DeRidder site, contained PAH concentrations of anthracene, benzo (b) fluoranthene, benzo (k) fluoranthene, chrysene, fluoranthene, naphthalene, phenanthrene and pyrene above analytical report limits (Ref. 39, pp. 37, 84 & 216-218). Background sediment sample location AC-ESI-04 also collected along a separate unnamed perennial stream up gradient of the surface water pathway did not contain any contaminants of concern associated with the site (Ref. 39, pp. 38, 84 & 219-221).

Comparison to background sediment and surface water sample results indicates that the significant increase in the concentrations of specific PAHs are attributable at least in part to a release from the site. The hazardous substances in the observed release samples are the same constituents found in site sources. Observed release hazardous substances to the surface water pathway include acenaphthene, acenaphthylene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (g,h,i) perylene, benzo (b) fluoranthene, benzo (k) fluoranthene, carbazole, chrysene, , dibenzo (a,h) anthracene, dibenzofuran, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, methylnaphthalene, 1-, methylnaphthalene, 2-, naphthalene, phenanthrene, and pyrene (Tables 9, 10, 11 & 12).

Observed Release Factor Value: 550

SWOF Human Food Chain – Toxicity/Persistence/Bioaccumulation

4.1.3.2 HUMAN FOOD CHAIN THREAT - WASTE CHARACTERISTICS

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation

The human food chain waste characteristics section provides the toxicity, persistence and bioaccumulation factor values for hazardous substances that are available to migrate or have migrated from sources at the site to surface water in the watershed via the overland/flood hazardous substances migration path for the watershed (Ref. 1, Sec. 4.1.3.2.1), the hazardous waste quantity value for the watershed (Ref, 1, Sec. 4.1.3.2.2), and the calculation of the human food chain threat-waste characteristics factor category value (Ref. 1, Sec. 4.1.3.2.3). The highest combined toxicity, persistence and bioaccumulation factor is used to determine the waste characteristics factor value for the human food chain threat from the surface water migration pathway (Ref. 1, Sec. 4.1.3.2.1.4).

Hazardous substances that meet the criteria for an observed release to surface water and all hazardous substances associated with the sources that have a surface water containment factor value greater than 0 for the watershed are presented in Table 13 below. Each hazardous substance eligible to be evaluated is assigned a toxicity/persistence/bioaccumulation factor value. The hazardous substances with the highest toxicity/persistence/bioaccumulation are benzo (a) pyrene, cadmium, dibenzo (a,h) anthracene, and mercury.

SWOF Human Food Chain – Toxicity/Persistence/Bioaccumulation

Table 13 – Human Food Chain Threat – Toxicity/Persistence/Bioaccumulation Summary

Toxicity/ Toxicity/Persistence Toxicity Persistence Persistence Bioaccumulation / Bioaccumulation Hazardous Substance Source No. Factor Factor Reference Factor Value Factor Value ** Factor Value Value Value* (Table 4-12) (Table 4-16) Acenaphthene 1, 2, 3, 4, OR 10 0.4 4 500 2,000 Acenaphthylene 1, 3, 4, 5, OR 1 0.4 0.4 500 200 1, 2, 3, 4, 5, Anthracene 10 0.4 4 50,000 200,000 OR Arsenic 1, 2, 3 10,000 1 10,000 5 50,000 1, 2, 3, 4, 5, Benzo (a) anthracene 1,000 1 1,000 50,000 50,000,000 OR 1, 2, 3, 4, 5, Benzo (a) pyrene 10,000 1 10,000 50,000 500,000,000 OR Benzo (g,h,i) perylene 2, 3, 4, OR 0 1 0 50,000 0 1, 2, 3, 4, 5, Benzo (b) fluoranthene OR 1, 2, 3, 4, 5, Benzo (k) fluoranthene 1,000 1 1,000 50,000 50,000,000 OR Biphenyl, 1,1'- 1, 2, 3, 4 Bis (2-ethylhexyl) phthalate 4 100 1 100 50,000 5,000,000 Cadmium 1, 2, 3 10,000 1 10,000 50,000 500,000,000 1, 2, 3, 4, 5, Carbazole 10 0.07 0.7 500 350 OR Chromium 2, 3, 4, 5 10,000 1 10,000 5 50,000 1, 2, 3, 4, 5, Chrysene 100 1 100 5 500 OR Cobalt 1, 2, 3 10,000 1 10,000 50 500,000 Ref. 1, Copper 1, 2, 3, 4, 5 100 1 100 50,000 5,000,000 Tables 4-12, 4-16; Ref. Dibenzo (a,h) anthracene 1, 3, 4, 5 OR 10,000 1 10,000 50,000 500,000,000 1a, Section 1, 2, 3, 4, 5, Dibenzofuran 1,000 0.4 400 500 200,000 2.4.1.1; Ref. OR 2, pp. 1-65; 1, 2, 3, 4, 5, Ref. 2a, pp. Fluoranthene1 100 1 100 5,000 500,000 OR 1, 2 Fluorene 1, 2, 3, 4, OR 100 1 100 500 50,000 Indeno (1,2,3-cd) pyrene 1, 2, 3, 4, OR 1,000 1 1,000 50,000 50,000,000 Lead 1, 2, 3, 4, 5 10,000 1 10,000 5,000 50,000,000 Manganese 1, 2, 3, 4, 5 10,000 1 10,000 500 5,000,000 Mercury 1, 2, 3, 4, 5 10,000 1 10,000 50,000 500,000,000 Methylnaphthalene, 1- OR 1, 2, 3, 4, 5, Methylnaphthalene, 2- 1,000 0.07 70 50,000 3,500,000 OR 1, 2, 3, 4, 5, Naphthalene 1,000 0.07 70 50,000 3,500,000 OR Nickel 1, 2, 3, 4, 5 10,000 1 10,000 5 50,000 1, 2, 3, 4, 5, Phenanthrene 1 0.4 0.4 5,000 2,000 OR 1, 2, 3, 4, 5, Pyrene 100 1 100 50,000 5,000,000 OR Silver 4 100 1 100 50 5,000 Thallium 2, 3 10,000 1 10,000 500 5,000,000 Zinc 1, 2, 3, 4, 5 10 1 10 500 5,000

92 SWOF Human Food Chain – Toxicity/Persistence/Bioaccumulation

*Persistence values assigned are based on Palmetto Creek which has perennially flowing water, and thus classified as a River. ** Bioaccumulation values are food chain values assigned based on the surface water category of fresh water (Ref. 28, pp. 3-9). 1Fluoranthene is listed as benzo (j,k) fluoranthene in the SCDM (Ref. 2, p. 16). OR – Observed Release documented substance.

93 SWOF Human Food Chain – Toxicity/Persistence/Bioaccumulation

The hazardous substances with the highest Toxicity/Persistence/Bioaccumulation Factor Values are benzo (a) pyrene, cadmium, dibenzo (a,h) anthracene, and mercury (Ref. 1, Table 4-16; Ref. 2, pp. 12, 22, 36 & 48).

Toxicity/Persistence/Bioaccumulation Factor Value: 500,000,000

SWOF Human Food Chain – Hazardous Waste Quantity

4.1.3.2.2 Hazardous Waste Quantity

Source Hazardous Waste Is Source Hazardous Quantity Value Constituent Quantity Data Source Number (Section 2.4.2.1.5) Complete? (yes/no) 1 62.22 No 2 9.26 No 3 49.38 No 4 0.09 No 5 >0 No TOTAL 120.95

The sum of the source hazardous waste quantity values is assigned as the Hazardous Waste Quantity Factor Value (Ref.1, Sec. 2.4.2.2 and Table 2-6). The sum of the source hazardous waste quantity values for Surface Water Pathway, rounded to the nearest integer, is 121. For a hazardous waste quantity range of greater than 100 to 10,000 a value of 100 is assigned from Ref. 1, Table 2-6 for the migration pathway. Also, according to Section 2.4.2.2 of the HRS, a surface water pathway hazardous waste quantity factor value of 100 can be assigned because the hazardous constituent quantity data is not adequately determined for one or more sources, and targets for the surface water pathway are subject to actual contamination at Level II concentrations (Ref. 1, Sec. 2.4.2.2, Table 2-6; Section 4.1.4.3.1.2 of this HRS documentation record).

Sum of Values: 121 Hazardous Waste Quantity Assigned (Ref 1, Section 2.4.2.2, Table 2-6): 100

SWOF Human Food Chain – Hazardous Waste Quantity

4.1.3.2.3 Waste Characteristics Factor Category Value

The waste characteristics factor category value is assigned based on the Waste Characteristics Product. The Waste Characteristics Product is the product of the Toxicity/Persistence Factor Value and the Hazardous Waste Quantity Factor Value subject to a maximum of 1 X 108. This product is multiplied by the Bioaccumulation Potential Factor Value subject to a maximum value of 1 x 1012. The hazardous substances with the highest Toxicity/Persistence/Bioaccumulation Factor Value for the watershed, benzo (a) pyrene, cadmium, dibenzo (a,h) anthracene, and mercury, will be used (Ref. 1, Sec. 4.1.3.2.1.4).

Toxicity/Persistence Factor Value: 10,000 Hazardous Waste Quantity Factor Value: 100

(Toxicity/Persistence x Hazardous Waste Quantity): 10,000 x 100 = 1 x 106 (Subject to a maximum product of 1.0 x 108)

Bioaccumulation Potential Factor Value: 50,000 (Toxicity/Persistence x Hazardous Waste Quantity) x Bioaccumulation Potential Factor Value:

(1 x 106) x (50,000) = 5.0 x 1010 (Subject to a maximum product of 1.0 x 1012)

A Waste Characteristics Product value of 5.0 x 1010 receives a waste characteristic factor category value of 320 (Ref. 1, Table 2-7)

Hazardous Waste Quantity Assigned Value: 100 Waste Characteristics Factor Category Value: 320

SWOF Human Food Chain – Targets

4.1.3.3 HUMAN FOOD CHAIN THREAT – TARGETS

Recreational fishing exists along Palmetto Creek with largemouth bass, bream, bluegill, crappie, perch, striped bass, bullhead, catfish, rainbow trout, and redear sunfish species being caught (Ref. 31, p. 1; Ref. 32, p. 1; Ref. 44, pp. 1-5). Additionally, Bundick Creek is fished recreationally with lamprey, paddlefish, gars, bowfin, herring, carps, minnows, suckers, pike, catfish, perch, New Word silverside, topminnows, livebearer, crappie, bream, sunfish, bass, drum and croakers, and pygmy sunfish caught or known to occur (Ref. 33, pp. 2-3; Ref. 34, pp. 21-23; Ref. 44, pp. 1-5).

4.1.3.3.1 Food Chain Individual

A food chain individual factor of 20 is assigned based on an observed release (from chemical analysis) of acenaphthene, acenaphthylene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (g,h,i) perylene, benzo (k) fluoranthene, carbazole, dibenzo (a,h) anthracene, dibenzofuran, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, 2-methylnaphthalene, naphthalene, phenanthrene, and pyrene with a Bioaccumulation Factor Value of 500 or greater to sediments and surface water in the watershed, and also based on a fishery being present within the 15-mile TDL of the in water segment (Ref. 1, Sec. 4.1.3.3.1; Ref. 2, pp. 2, 4, 6, 10, 12, 14, 16, 18, 20, 24, 34, 36, 38, 40, 42, 50, 52, 56 & 58; Figure 6; Tables 9, 11 & 12).

Food Chain Individual Factor Value (Ref. 1, Sec. 4.1.3.3.1): 20

SWOF Human Food Chain – Targets

4.1.3.3.2 Population

The Population Factor for the watershed is based on three factors: Level I concentrations, Level II concentrations, and potential human food chain contamination.

4.1.3.3.2.1 Level I Concentrations

There are no Level I concentrations established because a portion of the fishery is not within the boundaries of the observed release, the fishery is not closed within the boundaries of the observed release, and no tissue samples were collected from an essentially sessile, benthic, human food chain organism from the watershed within the 15-mile target distance limit of the in water segment (Ref. 1, Sec. 4.1.3.3.2.1).

4.1.3.3.2.2 Level II Concentrations

No Level II concentrations have been established for fisheries or portions of fisheries, within the watershed (Ref. 1, Sec. 4.1.3.3.2.2). Recreational fishing does not occur within the unnamed drainage ditch/stream, unnamed perennial stream, or the freshwater pond (bisected by Crosby Road but continuously connected by culverts) where an observed release by chemical analysis is evident in the sediment and surface water media of a hazardous substance significantly above background and attributed to the site (Ref. 39, pp. 65 & 84-88; Table 10 & 11).

4.1.3.3.2.3 Potential Human Food Chain Contamination

Fishing was not observed or known to occur along the unnamed drainage ditch/stream, unnamed perennial stream, the freshwater pond (bisected by Crosby Road but continuously connected by culverts), and the unnamed perennial stream receiving discharge from the freshwater pond flowing toward the Kansas City Southern Railroad ROW, along the Kansas City Southern Railroad ROW, and eventually into Palmetto Creek.

Recreational fishing is conducted within Palmetto Creek and Bundick Creek (Ref. 31, p. 1; Ref. 32, p. 1; Ref. 33, pp. 2-3; Ref. 34, pp. 21-23; Ref. 44, pp. 1-5). The Louisiana Department of Wildlife and Fisheries (LDWF) does not keep records on pounds of fish caught and consumed annually per body of water; therefore it will be assumed that at least more than zero (>0) and less than 100 (<100) pounds per year are consumed annually from Palmetto Creek, and Bundick Creek (Ref. 1, Table 4-18; Ref. 34, pp. 21-23).

No gauging stations are located along Palmetto Creek. Additionally, no published average stream flow data is available for Palmetto Creek. The flow rate at the target location was extrapolated using the flow data for Bundick Creek. According to gauging station 08080204 located on Bundick Creek, upstream from the confluence of Palmetto Creek and Bundick Creek, the average annual flow rate as measured for water years 1957 through 2015 is 150.88 cfs (Ref. 29, pp. 1-4). This segment will be set to equal the flow at the upstream gauging station and will be considered to be a moderate to large stream, and will be assigned a dilution value of 0.01 (Ref. 1, Table 4-13; Figure 6).

SWOF Human Food Chain – Targets

The United States Geological Survey (USGS) gauging station 08080204, located in Beauregard Parish near DeRidder, Louisiana, approximately 1.68 miles upstream from the confluence of Palmetto Creek and Bundick Creek, at latitude 30°49'07" North and longitude 93°13'48" West, has an average annual flow rate for Bundick Creek as measured for water years 1957 through 2015 of 150.88 cfs (Ref. 29, pp. 1-4). The flow rate for Bundick Creek falls into the moderate to large stream category, with an average stream flow rate greater than 100 cfs and less than 1,000 cfs, thus being assigned a dilution value of 0.01 (Ref. 1, Table 4-13).

Table 14 – Fishery Identification Study

Type of Identity Annual Average Population Dilution Surface of Production Annual Value Weight Pi x Di Reference Water Fishery (pounds) Flow (Pi) (Di) Body

Palmetto Moderate Ref.1, Tables 4- Creek >0-100 to Large 150.88 cfs 0.03 0.01 0.0003 13, 4-18; Ref. Stream 29, pp. 1-4

Moderate Ref.1, Tables 4- Bundick >0-100 to Large 150.88 cfs 0.03 0.01 0.0003 13, 4-18; Ref. Creek Stream 29, p. 1-4

Sum (Pi x Di): 0.0006 (Sum of Pi x Di) x 1/10: 0.00006

Potential Human Food Chain Contamination Factor Value: 6.0 x 10-5

SWOF Human Food Chain – Targets Factor Category Value

4.1.3.3.2.4 Calculation of Population Factor Value

The population factor value is equal to:

Level I Concentrations (0) + Level II Concentrations (0) + Potential Human Food Chain Contamination (0.00006) = 0.00006.

A value of 6.0 x 10-5 is assigned as the Population Factor Value.

Population Factor Value: 6.0 x 10-5

4.1.3.3.3. Calculation of Human Food Chain Threat – Targets Factor Category Value

The Human Food Chain Threat – Targets Threat Category value is calculated by summing the food chain individual and population factor values for the watershed:

Food Chain Individual Factor Value (20) + Population Factor Value (0.00006) = 20.00006

Target Factor Category Value: 20.00006

4.1.3.4. Calculation of Human Food Chain Threat Score for a Watershed

The Human Food Chain Threat Score is calculated by multiplying the human food chain threat factor category values for the likelihood of release, waste characteristics, and targets for the watershed (Ref. 1, Sec. 4.1.3.4).

Likelihood of Release (550) x Waste Characteristics (320) x Targets (20.00006) = 3,520,011 (rounded to the nearest integer).

This product is then divided by 82,500:

3,520,011 ÷ 82,500 = 42.66

The resulting value, subject to a maximum of 100, is assigned as the Human Food Chain Threat Score.

Human Food Chain Threat Score: 42.66

100

SWOF Environme ntal – Toxicity/Persistence/Bioaccumulation

4.1.4.2 ENVIRONMENAL THREAT – WASTE CHARACTERISTICS

4.1.4.2.1 Ecosystem Toxicity/Persistence/Bioaccumulation

The environmental threat waste characteristics section provides the ecosystem toxicity, persistence and bioaccumulation factor values for hazardous substances that are available to migrate from sources at the site to surface water in the watershed via the overland/flood hazardous substances migration path for the watershed (Ref. 1, Sec. 4.1.4.2.1), the hazardous waste quantity value for the watershed (Ref. 1, Sec. 4.1.4.2.2), and the calculation of the environmental threat – waste characteristics factor category value. The highest combined ecosystem toxicity, persistence and ecobioaccumulation factor is used to determine the waste characteristics factor value for the environmental threat of the surface water migration pathway (Ref. 1, Sec. 4.1.4.2.3).

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SWOF Environme ntal – Toxicity/Persistence/Bioaccumulation

Table 15 – Ecosystem Toxicity/Persistence/EcoBioaccumulation Factor Summary

Eco Eco Toxicity/Persistence Persistence Toxicity/ Toxicity Bioaccumulation /Bioaccumulation Hazardous Substance Source No. Factor Persistence Reference Factor Factor Value ** Factor Value (Table Value* Factor Value Value 4-16) (Table 4-12) Acenaphthene 1, 2, 3, 4, OR 10,000 0.4 400 500 200,000 Acenaphthylene 1, 3, 4, 5, OR 0 0.4 0 500 0 1, 2, 3, 4, 5, Anthracene 10,000 0.4 4,000 50,000 200,000,000 OR Arsenic 1, 2, 3 10 1 10 50,000 500,000 1, 2, 3, 4, 5, Benzo (a) anthracene 10,000 1 10,000 50,000 500,000,000 OR 1, 2, 3, 4, 5, Benzo (a) pyrene 10,000 1 10,000 50,000 500,000,000 OR Benzo (g,h,i) perylene 2, 3, 4, OR 0 1 0 50,000 0 1, 2, 3, 4, 5, Benzo (b) fluoranthene OR 1, 2, 3, 4, 5, Benzo (k) fluoranthene 0 1 0 50,000 0 OR Biphenyl, 1,1'- 1, 2, 3, 4, Bis (2-ethylhexyl) phthalate 4 1,000 1 1,000 50,000 50,000,000 Cadmium 1, 2, 3 10,000 1 10,000 50,000 500,000,000 1, 2, 3, 4, 5, Carbazole 1,000 0.07 70 500 35,000 OR Chromium 2, 3, 4, 5 10,000 1 10,000 500 5,000,000 Chrysene 1, 2, 3, 4, OR 1,000 1 1,000 5,000 5,000,000 Cobalt 1, 2, 3 0 1 0 500 0 Ref. 1, Copper 1, 2, 3, 4, 5 1,000 1 1,000 50,000 50,000,000 Tables 4- 12, 4-16; Dibenzo (a,h) anthracene 1, 3, 4, 5, OR 0 1 0 50,000 0 Ref. 2, pp. 1, 2, 3, 4, 5, Dibenzofuran 1,000 0.4 400 500 200,000 1-65 OR 1, 2, 3, 4, 5, Fluoranthene1 10,000 1 10,000 5,000 50,000,000 OR Fluorene 1, 2, 3, 4, OR 1,000 1 1,000 5,000 5,000,000 Indeno (1,2,3-cd) pyrene 1, 2, 3, 4, OR 0 1 0 50,000 0 Lead 1, 2, 3, 4, 5 1,000 1 1,000 50,000 50,000,000 Manganese 1, 2, 3, 4, 5 100 1 100 50,000 5,000,000 Mercury 1, 2, 3, 4, 5 10,000 1 10,000 50,000 500,000,000 Methylnaphthalene, 1- OR 1, 2, 3, 4, 5, Methylnaphthalene, 2- 100 0.07 7 50,000 350,000 OR 1, 2, 3, 4, 5, Naphthalene 1,000 0.07 70 50,000 3,500,000 OR Nickel 1, 2, 3, 4, 5 100 1 100 50,000 5,000,000 1, 2, 3, 4, 5, Phenanthrene 10,000 0.4 4,000 50,000 200,000,000 OR 1, 2, 3, 4, 5, Pyrene 10,000 1 10,000 50,000 500,000,000 OR Silver 4 10,000 1 10,000 50 500,000 Thallium 2, 3 100 1 100 500 50,000 Zinc 1, 2, 3, 4, 5 10 1 10 50,000 500,000

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SWOF Environme ntal – Toxicity/Persistence/Bioaccumulation

* Persistence values assigned are based on Palmetto Creek, which is perennially flowing water, and thus classified as a River. ** Bioaccumulation values are food chain values assigned based on the surface water category of fresh water (Ref. 28, pp. 3-8). 1Fluoranthene is listed as benzo (j,k) fluoranthene in the SCDM (Ref. 2, p. 16). OR – Observed Release documented substance.

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SWOF Environme ntal – Toxicity/Persistence/Bioaccumulation

The contaminants with the highest Ecosystem Toxicity/Persistence/Bioaccumulation Factor Values are benzo (a) anthracene, benzo (a) pyrene, cadmium, mercury, and pyrene (Ref. 1, Table 4-21; Ref. 2, pp. 10, 12, 22. 48 & 58).

Ecosystem Toxicity/Persistence/Bioaccumulation Factor Value: 500,000,000

104

SWOF Environme ntal – Hazardous Waste Quantity

4.1.4.2.2 Hazardous Waste Quantity

Source Hazardous Waste Is Source Hazardous Quantity Value Constituent Quantity Data Source Number (Section 2.4.2.1.5) Complete? (yes/no) 1 62.22 No 2 9.26 No 3 49.38 No 4 0.09 No 5 >0 No TOTAL 120.95

The sum of the source hazardous waste quantity values is assigned as the Hazardous Waste Quantity Factor Value (Ref. 1, Sec. 2.4.2.2 and Table 2-6). The sum of the source hazardous waste quantity values for Surface Water Pathway, rounded to the nearest integer, is 121. For a hazardous waste Quantity range of greater than 100 to 10,000 a value of 100 is assigned from Ref. 1, Table 2-6 for the migration pathway (Ref. 1, Sec. 2.4.2.2, Table 2-6). Also, according to Section 2.4.2.2 of the HRS, a surface water pathway hazardous waste quantity factor value of 100 can be assigned because the hazardous constituent quantity data is not adequately determined for one or more sources, and targets for the surface water pathway are subject to actual contamination at Level II concentrations (Ref. 1, Sec. 2.4.2.2, Table 2-6; Section 4.1.4.3.1.2 of this HRS documentation record).

Sum of Values: 121 Hazardous Waste Quantity Factor Value (Ref. 1, Sec. 2.4.2.2, Table 2-6): 100

105

SWOF Environme ntal – Hazardous Waste Quantity

4.1.4.2.3 Waste Characteristics Factor Category Value

A Waste Characteristics Factor Category Value is assigned based on the Waste Characteristic Product. The hazardous substances with the highest ecosystem toxicity/persistence/bioaccumulation factor value for the watershed are benzo (a) anthracene, benzo (a) pyrene, cadmium, mercury, and pyrene (Ref. 1, Sec. 4.1.4.2.3). These values are used to determine the Waste Characteristic Product. The Waste Characteristic Product is the product of the Ecosystem Toxicity/Persistence/Bioaccumulation Factor Value and the Hazardous Waste Quantity Factor Value subject to a maximum product of 1 x 108. This product is multiplied by the Ecosystem Bioaccumulation Potential Factor Value subject to a maximum product of 1 x 1012.

Using HRS Table 4-20 and Table 15 in Section 4.1.4.2.1 of this HRS documentation record, the Ecosystem Toxicity/Persistence for benzo (a) anthracene, benzo (a) pyrene, cadmium, mercury, and pyrene is 10,000.

A Hazardous Waste Quantity Factor Value of 100 is assigned (Ref. 1, Sec. 2.4.2.2, Table 2-6; Section 4.1.4.2.2 of this HRS documentation record).

Ecosystem Toxicity/Persistence Factor Value = 10,000 Hazardous Waste Quantity Factor Value = 100 10,000 x 100 = 1.0 x 106 (Subject to a maximum product of 1.0 x 108)

The Ecosystem Bioaccumulation Factor Value for benzo (a) anthracene, benzo (a) pyrene, cadmium, mercury, and pyrene is 50,000 (Ref. 2, pp. 10, 12, 22, 48 & 58).

Ecosystem Bioaccumulation Factor Value = 50,000

(Ecosystem Toxicity/Persistence x Hazardous Waste Quantity) x Bioaccumulation Factor Value:

(1 x 106) x 50,000 = 5 x 1010 (Subject to a maximum product of 1 x 1012)

A Waste Characteristics Product Value of 5 x 1010 receives a Waste Characteristic Factor Value of 320 (Ref. 1, Table 2-7).

(Ecosystem Toxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value) x Bioaccumulation Factor Value: 5 x 1010 Waste Characteristics Factor Value: 320

106

SWOF Environme ntal – Targets

4.1.4.3 ENVIRONMENTAL THREAT – TARGETS 4.1.4.3.1 Sensitive Environments 4.1.4.3.1.1 Level I Concentrations

Level I concentrations cannot be established in the contiguous wetlands and adjoining unnamed drainage ditch/stream, the unnamed perennial stream, or the freshwater pond.

Level I Concentrations Factor Value: 0

107

SWOF Environme ntal – Level II Concentrations

4.1.4.3.1.2 Level II Concentrations

Wetlands were identified by LDEQ personnel and the National Wetland Inventory (NWI) contiguously along the 15-TDL for the surface water migration pathway. Wetlands as identified by NWI are as follows: PSS1A designation: palustrine scrub-shrub broad-leave deciduous nontidal temporary flooded; PFO1A designation: palustrine forested broad-leave deciduous nontidal temporarily flooded; and PUBHh designation: palustrine unconsolidated bottom nontidal permanently flooded diked/impounded, with documented emergent aquatic vegetation that clearly meets the HRS wetland definition (Ref. 28, pp. 5-9; Ref. 35, pp. 1-3; Ref. 36, pp. 1-9; Ref. 37, pp. 1-5).

The PPE is a segment of contiguous Palustrine Freshwater Forested/Shrub wetland that contains discernible flow from an adjoining unnamed drainage ditch/stream (Ref. 6, p. 94; Ref. 7, p. 84; Ref. 10, p. 10; Ref. 16, p. 1; Ref. 28, pp. 5-9; Ref. 35, pp. 1-2; Ref. 39, pp. 79, 96-103; Figure 4). The PPE is located approximately mid-point on the western side of the CMC property and based on property features, characteristics, and the nature of the topography, the contiguous wetlands and adjoining drainage ditch/stream are down gradient to the south from identified sources (Ref. 3, p. 1; Ref. 4, pp. 13, 20-21: Ref. 6, pp. 58 & 94; Ref. 12, p. 2; Ref. 39, pp. 96-103; Figure 1 & 4). The continuous unnamed drainage ditch/stream adjoins the contiguous designated wetlands and passes beneath the railroad spur, via a culvert, from east to west (Ref. 14, pp. 1-2; Ref. 28, pp. 5-9; Ref. 35, pp. 1-2; Ref. 39, pp. 96-103 & 105-106).

Level II concentrations have been established in the contiguous wetlands and the adjoining unnamed drainage ditch/stream, the unnamed perennial stream, and the freshwater pond by chemical analysis of wetland samples that met observed release criteria (Tables 10, 11 & 12). The total frontage of wetlands subject to Level II contamination is approximately 3,761 feet (Figure 5; Ref. 28, pp. 6-7 & 8-11; Ref. 35, pp. 1-2; Ref. 36, pp. 1-9; Ref. 37, pp. 1-5). The total wetland frontages measured are divided into three segments (Ref. 28, pp. 10-14). The wetland frontage of Segment 1, from the PPE in the wetland near Sample ACS-14 to surface water sample AC-ESI-02 also in the wetland is determined by the perimeter of that portion of the wetland subject to Level II concentrations, the perimeter of which is approximately 117 feet (Figure 5; Ref. 28, pp. 7 & 10; Ref. 35, p. 1; Ref. 36, pp. 1-9). The wetland frontage of Segment 2 is determined by the distance, approximately 1,834 feet, measured along the contiguous wetlands and the adjoining unnamed drainage ditch/stream, continuing along the unnamed perennial stream to the freshwater pond with emergent aquatic vegetation. The total frontage for Segment 2 is the sum of the wetland along the right descending bank (921 feet) and the left descending bank (913 feet) of the contiguous wetlands and the adjoining unnamed drainage ditch/stream, and continuing along the unnamed perennial stream to the freshwater pond with emergent aquatic vegetation (Figure 5; Ref. 28, pp. 6-7 & 10-11; Ref. 35, p. 1; Ref. 37, pp. 1-4). The wetland frontage of Segment 3 is determined by the frontage of the contiguous wetland along the shoreline of the freshwater pond with emergent aquatic vegetation and bisected by Crosby Road but continuously connected by culverts (AC- ESI-07, AC-ESI-08, AC-ESI-09, AC-ESI-10 and AC-ESI-11). Approximately 1,810 feet of wetland frontage surrounds the freshwater pond from the point of entry from the unnamed perennial stream to sample location AC-ESI-10 (Figure 5; Ref. 28, pp. 6 & 13-14; Ref. 35, pp. 1-2; Ref. 37, p. 5). The perimeter of the contiguous wetlands and the adjoining unnamed drainage ditch/stream along the PPE (Segment 1), the frontage along the contiguous wetlands and adjoining unnamed drainage ditch/stream, continuing along the unnamed perennial stream to the freshwater pond with emergent aquatic vegetation (Segment 2), and the perimeter of the freshwater pond from the point of entry from the unnamed

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SWOF Environme ntal – Level II Concentrations perennial stream to sample location AC-ESI-10 (Segment 3) were all measured on a scaled map that included the NWI map overlay, and are included with the NWI maps reference (Ref. 28, pp. 10-14).

The total frontage of wetlands subject to Level II contamination measures 3,761 feet or approximately 0.71 miles (Figures 5 and 6). A value of 25 is assigned from Table 4-24 of the HRS for a length of wetlands from 0.1 to 1 mile (Ref. 1, Sec. 4.1.4.3.1.2).

Threatened and endangered species have been reported within the general area; however, it is not known if their habitats overlap the zone of Level II contamination. Therefore, these other sensitive environments will not be evaluated (Ref. 38, p. 3).

To obtain the Level II concentration factor, the sum of the sensitive wetlands value and sensitive environments value are added to obtain the Level II Concentration Factor Value (Ref. 1, Sec. 4.1.4.3.1.3).

Sensitive Wetlands Value (25) + Sensitive Environments Value (0) = 25

Level II Concentration Factor Value (Ref. 1, Sec. 4.1.4.3.1.2 and Table 4-24): 25

109

SWOF Environme ntal – Potential Contamination

4.1.4.3.1.3 Potential Contamination

Palustrine scrub-shrub broad-leaved deciduous wetlands and palustrine forested broad-leaved deciduous wetlands, as identified on NWI that are nontidal temporarily flooded, are located along the frontage of the unnamed perennial stream receiving discharge from the freshwater pond that flows until encountering the Kansas City Southern Railroad ROW, then flows south along the Kansas City Southern Railroad ROW until encountering Palmetto Creek (Ref. 28, pp. 4-5 & 9).

In addition, palustrine scrub-shrub broad-leaved deciduous wetlands and palustrine forested broad- leaved deciduous wetlands, as identified on NWI that are nontidal temporary flooded, are located along the frontage of Palmetto Creek (Ref. 28, pp. 3-4 & 9). Also, palustrine forested broad-leaved deciduous nontidal temporary flooded wetlands, and areas of palustrine forested broad-leaved deciduous nontidal seasonally flooded wetlands are located along the frontage of Bundick Creek (Ref. 28, p. 3 & 9).

The wetlands subject to potential contamination are located along the unnamed perennial stream, Palmetto Creek and Bundick Creek meet the criteria as defined in 40 CFR 230.3, to be classified in the palustrine system and subcategories of frosted and scrub-shrub wetlands (Ref. 28, pp. 3-5 & 9). The wetlands along the unnamed perennial stream, Palmetto Creek and Bundick Creek were measured on a scaled map that included the NWI map overlay, and are included with the NWI maps reference (Ref. 28, pp. 15-18). Due to wetlands being contiguous along the entire 15-mile TDL, the length of each in-water segment was measured and multiplied by two to give the total wetland frontage along each individual segment subject to potential contamination. The length of the unnamed perennial stream was measured in two separate lengths for a total length of approximately 0.76 miles, for a total contiguous wetland frontage of approximately 1.52 miles (Ref. 28, pp. 15-16). The length of Palmetto Creek to the confluence with Bundick Creek is approximately 4.51 miles, for a total wetland frontage of approximately 9.02 miles (Ref. 28, p. 17). The length of Bundick Creek from the confluence with Palmetto Creek to the end of the 15-mile TDL is approximately 9.41 miles, for a total wetland frontage of approximately 18.82 miles (Ref. 28, p. 18).

Type of Surface Wetland Frontage Wetland Value Reference Water Body (miles) (Ref. 1, Table 4-24) Ref. 28, pp. 15-16; Unnamed Perennial Stream 1.52 50 Figure 6 Ref. 28, p. 17; Palmetto Creek 9.02 250 Figure 6 Ref. 28, p. 18; Bundick Creek 18.82 450 Figure 6

To obtain the Potential Contamination Factor Value, the sum of the sensitive environments is added to the wetland value, which is then multiplied by the assigned surface water dilution weight for each in- water segment. This value is then divided by 10 to obtain the Potential Contamination Factor Value (Ref. 1, Sec. 4.1.4.3.1.3).

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SWOF Environme ntal – Potential Contamination

Sum of Sensitive Wetland Adjusted Type of Surface Environment Frontage Dilution (Wj + Sj)Dj Water Body Values (Sj) Value (Wj) Weight (Dj) Unnamed Perennial Stream 0 50 1 50 Palmetto Creek 0 250 0.01 2.5 Bundick Creek 0 450 0.01 4.5

Potential Contamination Factor Value 57.0 ÷ 10 = 5.7

Sum of Sensitive Environment Values + Wetland Frontage Values: 0 Potential Contamination Factor Value: 5.7

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SWOF Environme ntal – Targets Factor Category Value

4.1.4.3.1.4 Environmental Threat – Targets Factor Category Value

The environmental threat target factor category value for the watershed is the sum of the values for the Level I Concentrations Factor Value , Level II Concentrations Factor Value, and Potential Contamination Factors Value (Ref. 1, Sec. 4.1.4.3.1.4).

Level I (0) + Level II (25) + Potential Contamination (5.7) = 30.7

Target Factor Category Value: 30.7

4.1.4.4 Calculation of Environmental Threat Score

The Environmental Threat Score is calculated by multiplying the environmental threat factor category values for the likelihood of release, waste characteristics, and targets for the watershed (Ref. 1, Sec. 4.1.4.4 and 4.1.4.3.1.4).

Likelihood of Release (550) x Waste Characteristics (320) x Targets (30.7) = 5,403,200 (rounded to the nearest integer).

This product is then divided by 82,500:

5,403,200 ÷ 82,500 = 65.49

The resulting value, subject to a maximum of 60, is assigned as the Environmental Threat Score.

Environmental Threat Score: 60.0

4.1.5 Calculation of Overland/Flood Migration Component Score for a Watershed

The overland/flood migration component score for the watershed is calculated by summing the scores for the Drinking Water Threat Score, Human Food Chain Threat Score, and Environmental Threat Score assigned as the Surface Water Overland/Flood Migration Component Score for a Watershed (Ref. 1, Sec. 4.1.5).

Drinking Water (0) + Human Food Chain (42.66) + Environmental (60) = 102.66

The resulting value, subject to a maximum of 100, is assigned as the Watershed Score.

Watershed Score: 100

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SWOF Environme ntal – Targets Factor Category Value

4.1.6 Calculation of Overland/Flood Migration Component Score

The highest Surface Water Overland/Flood Migration Component Score for the Watershed evaluated (in this case, only one watershed was evaluated) is selected and assigned as the Surface Water Overland/Flood Migration Component Score for the site, subject to a maximum of 100 (Ref. 1, Sec. 4.1.6).

Component Score: 100

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SWOF Pathway Score

4.2 GROUND WATER TO SURFACE WATER MIGRATION COMPONENT

This component was not scored because an observed release was documented for the overland flow/flood component.

Ground Water to Surface Water Factor Value: NS

4.3 CALCULATION OF SURFACE WATER MIGRATION PATHWAY SCORE

The overland/flood migration component was scored and this value is assigned to the surface water migration pathway score.

Surface Water Migration Pathway Score: 100

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