Public Comment Letters and Response to Comments On
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385 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 , </-f2 -J. 1AS DIVISION #——————6 - o/n CUJL, X/KU (LJLlCLYV'LL^ " UA> 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 ••••' '• w rn /7> rTi p n n r—•• F-~>" ;> » • — •ii i -.i^. i.—- i 1r i1 . • ;i j •\.. • •; i j• ^ •;i» \: \- • lt5 xli; Lb L! 'J L±. I ;: 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 Or ba^L fa fa 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 dis- order 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 under- stand 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.