Public Comment Letters and Response to Comments On

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COMBUSTION, INC. STJPERFUND SITE LIVINGSTON PARISH, LOUISIANA PUBLIC COMMENT LETTERS & RESPONSE TO COMMENTS ON THE PHASE I REMOVAL ACTION WORK PLAN LEGAL AGREEMENAND T

144173 State of Louisiana Department of Environmental Quality Edwin W. Edwards Kai David Midboe Governor Secretary November 18, 1992 MEMORANDUM TO: File FROM: Tim B. Knight, Program Manager Inactive and Abandoned Sites Division RE: Combustion, Inc. Superfund Site Response to Comments The Inactive and Abandoned Sites (IAS) Division of DEQ held a public comment period on the Removal Action Workplan. Phase I and the Legal Agreement for the Combustion, Inc. Superfund site. The comment period ran from July 27, 1992 through August 26, 1992. This document represents a compilation of 1) all public comment letters received, and 2) the IAS Division's responses to these comments.

OFFICE OF LEGAL AFFAIRS AND ENFORCEMENT INACTIVE AND ABANDONED SITES DIVISION P.O. BOX 82282 BATON ROUGE, LOUISIANA 70884-2282 TELEPHONE (504) 765-0487 FAX (504) 765-0484 AN EQUAL OPPORTUNITY EMPLOYER iAi«i.m*i State of Louisiana Department of Environmental Quality EdwinGoverno W. Edwardr s OCtOfcervM-ohorr - 8R, IQQ1992? Kai DaviSecretard Midboy e

Russell and Georgia Truax 11281 Truax Road Denham Springs, Louisiana 70726 Re: Combustion, Inc. Site Dear Mr. and Mrs. Truax: I am in receipt of your letter concerning the Combustion, Inc. Site (attached) . I appreciate you taking the time to review the proposed work to be done and sending your comments on the plan. I will attempt to address your questions in the order in which you presented them. 1. The individuals that actually perform the removal of hazardous substances are required by law to wear specific types of protective clothing for specific types of jobs. This is a requirement because these individuals are actually handling waste and are very close to it for their entire careers. It is normally a requirement of the employee's insurance company, as well. The fact that they are in this level of protection does not mean that the surrounding air is unsafe or that surrounding residents should be alarmed. Even though we do not expect dangerous levels of vapors to escape the site, a monitoring system will be in place to assure that any unexpected problems are detected and appropriate actions are taken. This system has been developed using health-based compliance levels for air emissions. 2. The chemicals of concern at the Combustion site are not the types or quantities of chemicals that are particularly volatile or explosive. The waste has the consistency and physical properties of used motor oil. The worst scenario envisioned, but not expected, is an open fire, similar to the recent fire that occurred at the site. This material is extremely difficult to ignitey—and—barring "another arson incident, is not expected. Additional 24 hour security on site during the Removal Action should eliminate ; the arson threat. -

OFFICE OF LEGAL AFFAIRS AND ENFORCEMENT INACTIVE AND ABANDONED SITES DIVISION P.O. BOX 82282 BATON ROUGE, LOUISIANA 70884-2282 fV TELEPHONE (504) 765-0487 FAX (504) 765-0484 \i W AN EQUAL OPPORTUNITY EMPLOYER , scycied paper I LA. DEPT. OF ENVIRONMENTAL QUALITY „ 0 , 2 ^ a/ne^ j^. al. j

5)VJjUL State of Louisiana Department of Environmental Quality Edwin W. Edwards Kai David Midboe Governor October 8, 1992 Secretary Ms. Gwendolyn S. Crumholt 30765 North Aberdeen Acres Road Denham Springs, Louisiana 70726 Re: Combustion, Inc. Site Dear Ms. Crumholt: I am in receipt of your two letters, as well as letters from your physicians concerning your family's medical condition as it relates to the Combustion, Inc. site (attached). We were also contacted by U.S. Senator John Breaux, via Governor Edwin Edwards regarding this matter. I have discussed the matter of immunodeficiency with officials from the U.S. Environmental Protection Agency, as well as the Environmental Epidemiology Section of the Louisiana Office of Public Health. Both parties advised that, while this is a serious condition, they do not believe this cleanup will aggravate the condition due to: 1. the nature of the contaminants at the site (low volatilization) and 2. the distance from your residence to the site As we have discussed, health-based compliance levels for air emissions have been established for areas surrounding the site during cleanup activities. These compliance levels were generated using very conservative assumptions every step of the way. Among these assumptions include a sensitive population surrounding the site. The sum of all activities, including material handling, transfer, storage, and loading cannot result in air emissions which wilexceel d be thhaltede health-base. d compliance levels. Otherwise, activities Under the Louisiana Environmental Quality Act, DEQ has the responsibility to investigate and clean up abandoned hazardous waste sites in the state. Federal and State law mandates that the cleanup actions be "protective of human health and the environment." The wastes at the Combustion site must be removed in the safest and most effective manner possible. I can assure you that we have done everything possible to ensure that the community actionsurroundin. g the site is not negatively impacted by this removal OFFICE OF LEGAL AFFAIRS AND ENFORCEMENT INACTIVE AND ABANDONED SITES DIVISION P.O. BOX 82282 BATON ROUGE. LOUISIANA 70884-2282 TELEPHONE (504) 765-0487 FAX (504) 765-0484 = -ycied paper AN EQUAL OPPORTUNITY EMPLOYER Ms. Gwendolyn S. Crumholt Page 2 October 8, 1992 If you have questions or comments regarding this matter, please contact me at (504) 765-0487, Dr. William R. Hartley with the Louisiana Office of Public Health in New Orleans at (504) 568-8537, or Dr. John Rauscher with EPA in Dallas at (214) 655-2198. Sincerely,

Tim B. Knight Program Manager Inactive and Abandoned Sites Division TBK/bb Attachment cc: U.S. Senator John Breaux Governor Edwin Edwards Dianne Dugas, LA Dept. of Health and Hospitals (j uu^cuuJCf (JJJL

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iAS DIVISION CU\hUL\ LOG* ^/?_c^,. THE CHILDics anoCAR [sloofescen/E CLINICjKeoicine , INC. Charles W. Daniel, M.D. Anita Hannie (Office Manager) August 11, 1992

Mrs. Gwen Crumholt 30765 North Aberdeen Acres Road Denham Springs/ LA 70726 Dear Mrs. Cruroholt: I am writing to you regarding Jennifer's chronic iung problems associated with immunodeficiency. Jennifer should not be exposed to any aerosols, indoor and outdoor pollution that can aggravate her condition. This includes smoke, insecticides and other environmental irritants. If you have any questions, please do not hesitate to call. Sincerely, f\ Charles W. Daniel, M.D.

5311 Dijon Drive Baton Rouge, LA 70809 Gonzales Phone: (504) W7-9064 Phone:(504)769-2003 Fax: (504) 767-3055 Ice- cdr

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State of Louisiana Department of Environmental Quality Kal Davld Midboe Edwin GovernoW. Edwardr s Secretary October 8, 1992

Mr. Joel E. Talley 11017 Burgess Avenue Denham Springs, Louisiana 70726 Re: Combustion, Inc. Site Dear Mr. Talley: I am in receipt of your August 18, 1992, letter (attached) concerning the Combustion, Inc. Site. I appreciate you taking the time to write concerning this issue. I have discussed the issue of Attention Deficit Disorder as it relates to the Combustion, Inc. Site with representatives from the Environmental Epidemiology Section of the Louisiana Office of Public Health. They are in the process of conducting a Health Evaluation of residents surrounding this site to attempt to identify health effects, if possible, from its operation. I have also forwarded a copy of your letter to them and asked them to take it into consideration in their deliberations (see attachment). If you have questions or comments regarding this matter, please contact me at (504) 765-0487 or Dianne Dugas with the Louisiana Office of Public Health in New Orleans at (504) 568-8537. Sincerely,

Tim B. Knight Program Manager Inactive and Abandoned Sites Division TBK/bb Attachments

OFFICE OF LEGAL AFFAIRS AND ENFORCEMENT INACTIVE AND ABANDONED SITES DIVISION P.O. BOX 82282 BATON ROUGE, LOUISIANA 70884-2282 4% TELEPHONE (504) 765-0487 FAX (504) 765-0484 mw AN EQUAL OPPORTUNITY EMPLOYER recycled paper l 1 >r 14 1I Un \JM ~-fc-d E H •'• • •• » P IS'. "M I •S I • 4 l i » 1 1 ' ' O / ' . - . • fc u 1 n ———— / •^AriJs" tL-. 18, 1992 ! ENVIF ON?v JALTT «- i.AS D^SJOM Department of Environmental Quality Inactive £r,d Abandoned Sites Division Attention: Tim Knight LOG # P 0 Bex 82282 Baton Rouge LA 70804-2282 Dear Mr. Knight: I would like the following to go into the record for the Combustion, Inc. Waste Site Review. My family and I bsve lived about one mile from the site since 1976. The hazardous waste pit cayght on fire and burnec for days, if not weeks, at a time back in the late '70's and early '80's releasing God only knows what into the environment and the atmosphere. Our son was born July 31, 1977, and has Attention Deficit Disorder and a mild learning disorder. In the pest many children with this disorder were never diagnosed properly because the State Department of Education never acknowledge ADD as a disorder until- September 16, 1991 when 1t was forced to by the U.S. Department of Education. What I am getting to is Walker High School (located about one mile from the hazardous waste pit) had 7S seniors dropout of school (8H*). I understand this is one of the highest rates in the country. 1 would like to know if and how many of the total of these children that dropped out had a learning disorder that went undiagnosed. We are now seeing on TV News medical questions being raised about our GI's that returned from Kuwait that fought overseas during Desert Storm. Many of these men have suffered unexplained medical and neurological disorders due to smoke from the oilwell fires. I believe this same medical assumption should be no less applied to the children of Walker who were exposed to the smoke and fumes from this hazardous waste pit for years preceeding their grate- ful closure. Sincerely, E. Talley JETrpat CC: Calvin Fayard Flo Barker State of Louisiana Department of Environmental Quality Edwin W. Edwards October 8, 1992 Kai David Midboe Governor Secretary

Ms. Dianne Dugas Office of Public Health Environmental Epidemiology 234 Loyola Avenue, Suite 620 New Orleans, Louisiana 70112 Dear Ms. Dugas: Re: Combustion, Inc. Please see the attached letter from Joel E. Talley regarding the possible cause/effect relationship between high levels of Attention Deficit Disorder in Livingston Parish and the referenced abandoned hazardous waste site. As we recently discussed, it may be appropriate to consider this in the health assessment that is currently being undertaken in the area surrounding the site. Nevertheless, if you could respond directly to Mr. Talley, with a copy sent to my attention, it would be greatly appreciated. Please contact me at (504) 765-0487 if I can be of assistance in this matter. Sincerely,

Tim B. Knight Program Manager Inactive and Abandoned Sites Division TBK/bb

OFFICE OF LEGAL AFFAIRS AND ENFORCEMENT INACTIVE AND ABANDONED SITES DIVISION P.O. BOX 82282 BATON ROUGE. LOUISIANA 70834-2282 TELEPHONE (504) 765-0487 FAX (504) 765-0484

AN EQUAL OPPORTUNITY EMPLOYER '.SWX . State of Louisiana Department of Environmental Quality Edwin W. Edwards Kai David Midboe Governor Secretary October 8, 1992

Mr. Charles David Darby 30769 Milton Road Denham Springs, Louisiana 70726-1721 Re: Combustion, Inc. Site Dear Mr. Darby: I am in receipt of your August 20, 1992, letter (attached) concerning the Combustion, Inc. Site. I noted that many of the comments you raised pertained to the Remedial Investigation/Feasibility Study (RI/FS). The Department is currently attempting to facilitate an Expedited Removal Action by the Potentially Responsible Parties (PRP'S). The issue of the RI/FS, as well as off-site sampling will be raised again after the removal action. Therefore, I will address the issues you have raised that are pertinent to the current removal action plan. The comments will be addressed in the order they were received. The evacuation of the area during any emergency is the responsibility of the Sheriff's Office. The Department is assisting in the development of an evacuation plan that is acceptable to them. As part of this plan, residents within the evacuation radius will receive a quick reference sheet and a special assistance form. This special assistance form will be kept on file at the Sheriff's Office, along with a map marking the locations of those needing assistance during an evacuation. A multi-phased approach to this site has been selected for two reasons. First, we wanted to be able to get the worst materials out of the site quickly. Since everyone agreed that the oils would have to be removed under any plan, we have been able to gain the cooperation of the PRP'S in a very short period of time. If we attempted to negotiate the entire project through the end of the remediation, the tankage and surface oils would remain a fire threat for years to come. Second, the information we gain in the phasesremova.l action phase will assist us in the design of subsequent While we have stated that the first two phases of the project could take as long as eighteen months, we really expect that number to be closer to twelve, depending upon weather and the success of the oil OFFICE OF LEGAL AFFAIRS AND ENFORCEMENT INACTIVE AND ABANDONED SITES DIVISION P.O. BOX 82282 BATON ROUGE, LOUISIANA 70884-2282 TELEPHONE (504) 765-0487 FAX (504) 765-0484 AN EQUAL OPPORTUNITY EMPLOYER -,*,«-,-- Mr. Charles David Darby Page 2 October 8, 1992 removal technology. The reason so much time is needed is to assure that the job is being done safely and correctly. If you have questions or comments regarding this matter, please contact me at (505) 765-0487. Sincerely,

Tim B. Knight Program Manager Inactive and Abandoned Sites Division TBK/bb Attachment cc: Governor Edwin Edwards U.S. EPA Secretary William Reilly Attorney General Richard leyoub 30769 Milton Poad Denham Springs, 70726-1721 (504) 664-5763 r~ August 20, 1992 I > • .") | I • !• »•' !'.r. Tim Knight [ ^J L_ ^ j Dept. of Environmental Quality ! - . j Inactive and Abandoned Sites Div. { _ ; ?. O. Box 82282 j -•••-- - ...... i Baton Rouge, LA 70884-2282 i———— ——.... Re: Removal Action, Dubose/Combustion ••<&-> i Hazardous Waste Site }uOo? 5 "2-V-72 - 2- Dear Mr. Knight: As per instructions on the fact sheet issued by. the Louisiana Department of Environmental Quality (LDEQ) this letter is addressed to you. If my memory serves me right, I've only seen you twice in my life. The first, a year or so back when you and Todd Thibodeaux came by ny house and introduced yourselves as employees of the LDEQ. The other time was at the public meeting on July 21, 1992, at the Walker High School. Todd Thibodeaux, I've seen less than ten times. Now, Kr. Knight, you are the program manager and Mr. Thibodeaux is the site manager. This I cannot comprehend, due to the fact that you two are in charge of the removal action, at the so noted site. Don't you think the public has the right to know your qualifications? In my 23 years around this site, I feel we have been denied our right to know and not only our right to know, but our Civil Rights and possibly our Human Rights. This brings up another question: How old were you and Mr. Thibodeaux 20 years ago? Mr. Knight, this is not an attack on your or Mr. Thibodeaux's character or qualifications; I know nothing about either. There are many questions about the remedial investigation and feasibility study. Why were there so few off-site tests? Why just the most convenient areas? Why not the old well on my property? Is it true that LDEQ and ERM Southwest split samples and used the same laboratory to analyze them? The remedial investigation and feasibility study were very inadequate this increasing the fear in many of the property owners' minds that live near and next to the process area. There are a number of elderly people who have lived next tc, cr near the site for years and are on special medications. This could cause many problems should they have to be evacuated. Some are already becoming very nervous about this removal action. The anxiety and stress could have very dangerous effects on these people's health. I know this has no meaning to the LDEQ or Head of State or they would have closed this site 20 years ago. Some people have suggested setting up some type of housing away from the site area. I don't believe any of these people that have lived here for years will in ar.y vay leave their hcr.es. In this day and time many people don't feel it is safe to leave their property overnight let alone for an extended period of time. The thought of this Removal Action Phase I taking 18 months is truly unbelievable. What type of equipment is going to be used? If I understand correctly, people are going to work 10 hours a day, 6 days a week. They must be going to use a 12" hacksaw, hammer, and chisel and a block and tackle - why so long? As you probably know, Mr. Knight, I can't see any logic in a two or possible three phase plan for this cleanup. Just a superficial cleanup does nothing but improve the cosmetics of the site. If this complete site can't be cleaned in 18 months working 10 hours a day, 6 days a week, DEQ has problems and our problem continues. In looking back over 23 years, I can see where we have never had any representation. The Department of Natural Resources, Department of Environmental Affairs, Wildlife and Fisheries, Rivers and Stream Commission, Department of Environmental Quality, Environmental Protection Agency, Louisiana Department of Health have been more representative of the people operating Dubose Oil Co., or Combustion, Inc., industry and the Potentially Responsible Parties (PRP's). At times there seems to be a conspiracy against the people that have spoken out against the Dubose/Combustion Inc. site: the time taken to even start a partial cleanup - the secret meetings - denials to enter the process area - having to go to the library for information - knowing most people could not understand what they were reading. Onetime Harold Ethridge told me, if I fought the bureaucracy, the bureaucracy would fight back. It has always been my understanding that in a true democracy, there is no bureaucracy. People employed by the State of Louisiana whom I have dealt with, have always had the attitude, "Hey, I work for the State and not for you, we have the first and last say - there is nothing in between!!" Well, they could be right. The so called bureaucracy has taken my health and my home and that does not leave me or my family very much. However, with luck I'll be around a little longer. Mr. Knight, I believe its very obvious that the PRP's and the big business control every phase of government. So regardless of what I say or you say, they will control the so called cleanup of the Dubose/ Combustion, Inc., site. The taxpayers will pay for it directly and indirectly. With all of this in mind, we should have independent observers that do not have any connection with the PRP's, DEQ, EPA, big business, or governmental agencies. The people cut here deserve that right. Sincerely,

arles Darby cc: Governor Edwin Edwards U.S. Secretary EPA William Reilly Attorney General Richard leyoub State of Louisiana Department of Environmental Quality Edw.n W.Edwards Governor October 8, 1992

Ms, Bonnie L. Lewis, Ph.D. H.E.L.P. Chair Communications Committee Post Office Box 874 Livingston, Louisiana 70754 Re: Combustion, Inc. Site Dear Ms. Lewis: We appreciate the opportunity to meet with you and other members of your community last week. It was obvious that your members have taken considerable time in reviewing the work plan and have offered constructive comments worthy of serious consideration in your letter of August 24, 1992 (Attached). In responding to your comments, we conducted legal and technical research, as well as consulted with representatives from DEQ management, Livingston Parish, the Environmental Protection Agency (EPA) , the Potentially Responsible Parties (PRP's) , and other State agencies, as appropriate. I will begin by discussing our involvement with the evacuation plan. The actual authority for conducting an evacuation belongs to the Livingston Parish Sheriff's Office, not DEQ. However, recognizing the community's concern about a possible emergency, DEQ assisted in developing an evacuation plan that is responsive to the situation at Combustion and also acceptable to the Sheriff's Office from an "implementability" standpoint. The truck access is another issue involving agencies other than DEQ. Although DEQ will give final approval to the plan, the transportation route must be negotiated by the PRP's and Parish of Livingston. I will utilize the same numbering system used in your letter to address your comments. Responses to the issues raised are as follows:

OFFICE OF LEGAL AFFAIRS AND ENFORCEMENT INACTIVE AND ABANDONED SITES DIVISION P.O. BOX 82282 BATON ROUGE, LOUISIANA 70884-2282 f% TELEPHONE (504) 765-0487 FAX (504) 76S-04S4 mW AN EQUAL OPPORTUNITY EMaOYER Ms. Bonnie Lewis Page 2 October 8, 1992 EVACUATION PLAN 1. We do not believe that expanding the radius of evacuation is warranted due to several reasons: The chemicals of concern at Combustion are not the types or quantities of chemicals that are particularly volatile or explosive. The waste has the consistency and physical properties of used motor oil. The worst scenario envisioned/ but not expected, is an open fire, similar to the recent fire that occurred at the site. This material is extremely difficult to ignite, and barring another arson incident, is not expected. Additional 24 hour security on-site during the Removal Action should eliminate the arson threat. The Sheriff's Office indicated that the proposed evacuation radius was consistent with the areas they evacuated during the fire and was more than sufficient. The radius in the evacuation plan will remain one (1) mile. However, the Sheriff's Office has the option to extend this radius if an emergency warrants expansion. 2. Additional wind socks will be a useful tool, not only for an evacuation, but also for the citizens to know the wind direction during any stage of the removal action. This will be added to the evacuation plan. 3. We do not believe that sending residents the entire Emergency Response Plan or a workbook is warranted. However, a quick reference sheet which incorporates the most important points of the plan will help to facilitate a successful evacuation in an emergency. Also, a form for people to fill out regarding individuals that may need special attention for any reason will be an asset. These two items should be sufficient to give residents the information they need about the evacuation plan. The reference sheet and form will be mailed to all residents within the evacuation radius prior to Removal Action work starting on site. 4. A map, with some type of decal or sign on the house or mailbox will also be useful in facilitating a successful evacuation. This concept, in some form, will be implemented prior to Removal Action work starting on site. 5. An alternate evacuation site is a logical suggestion. In our discussion with the Parish officials, it was suggested that the Denham Springs High School Gymnasium may be a good option from a prevailing wind standpoint. We will be contacting the schools that are ultimately chosen in order to gain their consent. Ms. Bonnie Lewis Page 4 October 8, 1992 If you have questions or comments regarding this matter, please contact me at (504) 765-0487. Sincerely,

Tim B. Knight Program Manager ... Inactive and Abandone d Sitet s Division TBK/bb Attachment LOUISIANA ENVIRONMENTAL ACTION NETWORK P.O. BOX 66323 BATON ROUGE.LA. 70896 (504) 928-1315

TO. TELECOPIER NUMBER- ( )- - 0

FROM: LEAN AU8 2 4 1992 LA. DEPT. OF ENVIRONMENTAL QUALITY ->-^ 1AS DIVISION LOG * TRANSMISSION-DATE - 0 1$ / TIME: NO. OF PAGES:

IF A PROBLEMS IS ENCOUNTERED WITH A COPY OF THIS TRANSMISSION, PLEASE CALL (504) 928-1315 Tim Knight August 24, 1992 Dept. of Environmental Quality Inactive and Abandoned Sites Division P.O. Box 82282 Baton Rouge, Louisiana RE: COMBUSTION WORK PLAN FOR REMOVAL ACTION, PHASE I Dear Mr. Knight, H.E.L.P. (Help Our Environment in Livingston Parish) would like to make the following comments about the Combustion Work Plan for Removal Action, Phase I. EVACUATION PLAN 1. The area for evacuation should be a 1-mile radius immediately surrounding the site, and additional evacuation to include all residents 2- miles downwind . 2. Extra wind socks are needed for people living close to the process area and the pond site so they can quickly see which way the wind is blowing. 3. Everyone in the evacuation area should receive: a) a copy of the Combustion Emergency Response Plan b) a brief and easy-to-read reference sheet c) an easy to read booklet which: •highlights the most important points. *has a worksheet for each family to make decisions for what each family member is to do for a variety of scenarios. d) a form for people to fill out and return indicating where there may be people needing special attention during evacuation c.g; children home alone, elderly, handicapped and people with physical problems such as asthma, et cetra. 4. A map needs to prepared which show all residents in the evacuation area, with a different symbol indicating which persons require special attention, (possibly a decal on the persons mailbox) A copy of this map should be made available to the sheriffs department, the on-site team, and the fire department. . 5. There needs to be alternate evacuation sites should Walker High School be downwind from the point of excursion. One possible site is the Livingston gymnasium. 6. Information and or training on chemicals which could be involved in an emergency should be provided to: a) the designated hospital's emergency room b) the school board At least two emergency drills need to be successfully completed before the plan is implemented. Successful completion will be determined by the State Police and Livingston Parish Sheriff. The department should be composed of officers who have completed the 40 hour special hazardous materials training program also, the relevant Fire Departments, who have completed the 40 hour hazardous materials training. 8. If the involved law enforcement department and fire departments do not have staff who have completed the 40-hour hazardous materials training program, they should be paid for by the clean-up firms or DEQ and completed before the emergency drills are conducted. REMOVAL PLAN £ 9. Sludges, oils, and wateiAto be taken out at the same time, using a large hose put in the pond with a pump attached. Before pumping is started, the pond should be covered with foam. The pond should then be pumped from the bottom up, without breaking the integrity of the form covering. Then cover the soil and foam with water when the draining is complete. Leave this surface intact until Phase n, when soil removal will occur. This will insure needed protection from air emissions. 10. The removal plans should eliminate the need to drive past any schools. 11. The need of a road being built along the powerline needs to be looked at due to the condition of Burgess Road. Burgess Road is too narrow, curvey, and has too many bumps and potholes. The road can not be suffiently maintained for all the heavy truck traffic that it will encounter. Burgess Road is too dangerous for oversized vehicles. 12. If the trucks are permitted to travel Burgess, then the road should be closed to through traffic during the hours of work. State Police should also escorts trucks to Walker City limits, where Walker Police can then monitor the trucks to the interstate. We would like a point-by-point response to each of our comments prior to final approval of the plan. You may contact any of the following person, who will take responsibility for notifying the rest of our members. Bonnie Lewis 664-6248 Flo Barker 664-9307 Joy Hughes 686-7684 Thank you for this oppurtunity to comment. Sincerely yours, Bonnie L. Lewis, Ph.D. H.E.L.P. Chair, Communications Committee ' State of Louisiana Department of Environmental Quality Kai Edwin GovernoW. Edwardr * October 8, 1992 Ms. Ramona Stevens LouisianField Liaisoa Environmentan l Action Network 16326 Lessie Lane Prairieville, Louisiana 70769 Re: Combustion, Inc. Site Dear Ms. Stevens: I am in receipt of your recent letter (attached) concerning the Combustion, Inc. Site. These comments will be addressed in the order in which you submitted them. Our responses are as follows: AIR MONITORING PLAN 1. The target air contaminants have not been evaluated using the operating temperature of the centrifuge. Health-based compliance levels for air emissions have been established for areas surrounding the site during cleanup activities. The sum of all activities, including material handling, transfer, storage, and loading cannot result in air emissions which exceed these compliance levels. Otherwise, activities will be halted. 2. The action levels listed in the removal action work plan are in compliance with the Louisiana Air Toxics Standards. See the attached memorandum from the Air Quality Division regarding this matter. • 3. The compliance points for air emissions are located at the nearest downwind residences. These samples will be analyzed in every case. If these samples exceed the health-based compliance levels, the project will be immediately halted and the upwind and fenceline samples will be analyzed. The purpose of the upwind and fenceline samples is to identify the source of the emission and to evaluate corrective action measures. No samples will be allowed to exceed the allowed holding times for the given parameters. 4. The work plan specifies that lead analyses will be conducted during any event that may result in the increase in lead-laden particulates. This will include soil excavation, pond excavation, underground tank removal, travel on unprotected roadway, etc. OFFICE OF LEGAL AFFAIRS AND ENFORCEMENT INACTIVE AND ABANDONED SITES DIVISION P.O. BOX 82282 BATON ROUGE. LOUISIANA 70884-2282 4Pfr TELEPHONE (504) 765-0487 FAX (504) 7654)484 \i

Ms. Rantona Stevens Page 3 October 8, 1992 Additional 24 hour security on site should eliminate the arson threat. In our meeting with the Sheriff's Department, they indicated that the proposed evacuation radius was consistent with the areas that they evacuated during the fire, and was more than sufficient. Our discussions with EPA indicate that they do not normally have an evacuation plan of any kind for a site of this nature. The radius of evacuation will remain 1 mile in the plan. However, the Sheriff's Office has the option to extend this radius if an emergency warrants expansion. The issue of emergency drills was discussed at length with the Parish officials at a recent meeting. Attending were Sheriff's Office, Civil Defense, Police Jury, and Fire Department officials. The Sheriff's Office would be responsible for such a drill. The consensus was that a drill was not needed due to the nature of the materials, the fact that a real evacuation has already taken place, and the risk of problems with injury/panic during a drill is probably greater than the risk of an evacuation. A final issue yet to be resolved is the issue of training for local emergency response teams, such as the fire department. We have advised the PRP's that whomever responds to emergency situations at the site must have the appropriate level of training required by law. We will follow up on this issue as soon as the appropriate laws can be researched and interpreted. At our recent meeting with Parish officials, it was felt that wind socks would be an asset during an evacuation. This will become part of the plan. Also, it was decided that a backup evacuation shelter should be provided. This, too, will become part of the plan. Both shelters will be in the final information sheet to be provided to residents before the job begins. I appreciate you taking the time to research the plan and offer these constructive comments. If you have questions or comments regarding this matter, please contact me at (504) 765-0487. Sincerely,

Tim B. Knight Program Manager Inactive and Abandoned Sites Division TBK/bb Attachments Louisiana Environmental Action Network______P.O. BOK 66323 Baton Rouge, Louisiana 70896 (504) 928-1315

Department of Environmental Quality Inactive and Abandoned Sites Division Attn: Tim B. Knight P. 0. Box 82282 Baton Rouge LA 70884-2282 Re: Comments Combustion Inc. Removal Plan Dear Mr. Knight, Louisiana Environmental Action Network (LEAN) is a statewide non-profit environmental group. LEAN is submitting these comments at the request of our members in and around the surrounding area of the Combustion Inc Sites. LEAN requests a copy of the response to comments and that we be informed of any changes to the original plan before the final plans are signed.- - - - • ------——-—--- If vou have anv questions please feel free to call me at (504) 622-4992.

Working "for a Cleaner Environment, Ramona Stevens **—-OL. Field Liaison LEAN D SEP__ 2 JU LA.DEPT.OF ENVIRONMENTAL QUALITY tAS DIVISION __• LOG » -/a- COMMENTS REGARDING THE "AIR MONITORING PLAN" FOR COMBUSTION INC., WASTE SITE BY EAGLE ENVIRONMENTAL HEALTH, INC. 1. Chapter 1, Pg. 1-1, Section 1.1, 2nd Para. Has the Target Air Contaminants been evaluated using the operating temperature of the centrifuge? 2. Table 3-2, Pg. 3-3, Action Levels Are the "Action Levels" listed in compliance with the Louisiana Air Toxic standards of LDEQ? If not, they should be because Superfund Cleanups has to adhere to these standards if they are in a rule. 3. Chapter 3, Pg. 3-6, Section 3.2, Item 3.2.1, 2nd Para. All samples should be analyzed at once. There should not be any archived samples collected at this site. 4. Chapter 3, Pg. 3-6, Section 3.2, Item 3.2.1, 3rd Para. Lead analysis from particulates generated at" the site should be done on a daily basis, except when rainfall is occurring. There are numerous children which live in the area that must be protected. Truck and Traffic on the roads must be considered. /—',