Explanation of Significant Differences Ruston Foundry Superfund … · 2020-06-03 · Foundry...

Explanation of Significant Differences

Ruston Foundry Superfund Site Alexandria, Louisiana

United States Environmental Protection Agency

Region 6 Superfund Division

November 2009

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Ruston Foundry Superfund Site November 2009 Explanation of Significant Differences Page 2 of 24

I. Introduction Site Name: Ruston Foundry Superfund Site (LAD985185107) Site Location: Alexandria, Rapides Parish, Louisiana Lead Agency: U. S. Environmental Protection Agency, Region 6 (EPA) Support Agency: Louisiana Department of Environmental Quality (LDEQ) This decision document presents the Explanation of Significant Differences (ESD) for the Ruston Foundry Superfund Site (Site), in Alexandria, Rapides Parish, Louisiana. The ESD is issued in accordance with Section 117(c) of the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), 42 U.S.C. § 9601 et seq., as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), Section 300.435(c)(2)(i) and 300.825(a)(2). This document will become part of the Administrative Record, which is developed in accordance with Section 113 (k) of CERCLA, 42 U.S.C. ' 9613 (k), and is available for review at the Rapides Parish Public Library in Alexandria, Louisiana, Rapides Parish, 411 Washington Street, Alexandria, LA 71301; and the Louisiana Department of Environmental Quality, Public Records Center, Galvez Building Room 127, 602 N. Fifth Street, Baton Rouge, Louisiana, 70802. The Director of the Superfund Division is delegated the authority to sign this ESD. II. Statement of Purpose This ESD documents results from the remedial action activities for the Ruston Foundry Superfund Site (Site) that support the Site’s unlimited use and unrestricted exposure scenario as well as the removal of institutional controls (ICs), operation and maintenance (O&M), and five-year reviews as components of the overall Site remedy as documented in the 2004 Explanation of Significant Differences (ESD) and the 2008 Contingency ESD. This ESD documents the information that significantly changes these components of the selected remedy while all other components of the remedy remain unchanged. III. Site History The Ruston Foundry Site is an abandoned metal foundry that operated from 1908 until 1985 and is located in an urban area with mixed development within the city limits of Alexandria, Louisiana. The nearest resident is located approximately 80 feet northwest of the Site and approximately 6,000 residents are located within a one-mile radius of the Site. There is a recreational park located approximately 1/4-mile southeast of the Site, and schools identified within one mile of the Site include Peabody Elementary, Peabody Magnet, Jones Street Junior High, Bolton High, South Alexandria Sixth Grade School, and Alma Redwine Primary School. The Site is bordered by a series of abandoned railroad tracks to the west, Chatlin Lake Canal to the northeast and east, and Mill Street Ditch to the south and southeast. A 1.62-acre portion of the Site is located just south of Mill Street Ditch. Residential property is located to the north,

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south, and east of the Site. Historical and active industrialized areas lie further west and north of the Site. Prior to remedial action, the 6.6-acre Site consisted primarily of dilapidated structures and building foundations overgrown with thick brush. Figure 1 is a Site map representing conditions prior to remedial action. Foundry operations resulted in metals contaminated waste which was dispersed throughout the property as fill material. As a result of this disposal activity, foundry-derived process wastes (slag, foundry sand piles, metal scrap, and castings) covered most of the Site and contaminated the soil. Figure 2 represents the areas where concentrations exceeded the cleanup levels prior to remedial action. During the 1990s, LDEQ and EPA conducted a series of Site investigations. On January 19, 1999, the Site was proposed to the National Priorities List (NPL), and on May 10, 1999, EPA formally announced the addition of the Site to the NPL in the Federal Register. IV. Selected Remedy Record of Decision (June 24, 2002) After review and response to comments, the Record of Decision was signed on June 24, 2002. The Remedial Action Objectives (RAOs) for the Site were to:

Table 1: Remedial Action Objectives (2002 ROD)

Media: Surface Soil and Sediment Media: other

RAO No. 1 - Prevent direct human contact (trespassers, adult recreators, and child recreators) with surface soils and waste piles containing lead at concentrations that would result in a greater than 5 percent chance that a child’s blood lead value would exceed 10 micrograms per deciliter. RAO No. 2 - Prevent direct human contact (trespassers, adult recreators, and child recreators) with surface soils and waste piles containing antimony at concentrations which have a hazard index greater than 1. RAO No. 3 - Prevent leaching and migration of lead from surface soils and waste piles into the ground water at concentrations exceeding 0.015 milligrams per liter. RAO No. 4 - Prevent leaching and migration of antimony from surface soils and waste piles into the ground water at concentrations exceeding 0.006 milligrams per liter.

RAO No. 5 - Prevent direct human contact with asbestos containing material at concentrations greater than 1 percent by weight.

RAO No. 6 - Prevent direct contact with the underground storage tank, its contents, and surrounding contaminated soils. RAO No. 7 - Prevent direct human contact (trespassers, adult recreators, and child recreators) with slag pile material with toxicity characteristic leaching procedure lead concentrations greater than 5 milligrams per liter and handle as hazardous waste in accordance with all applicable federal, state, and local regulations. RAO No. 8 - Prevent migration of contaminants to deeper soils and ground water through the former onsite water supply well and from the existing buildings, slabs, sump, and trash.

Because there are no Federal or State cleanup standards for soil contamination, the EPA established the RAO cleanup levels (CLs) based on the baseline human health risk assessment. The selected CLs will reduce the excess noncancer risk associated with exposure to

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contaminated wastes, the excess risk of exceeding 10 micrograms per deciliter blood lead level, and the potential for migration of contaminants into the ground water. This will be achieved by: • reducing the concentrations of the soil contaminated with antimony to 150 milligrams per

kilogram (mg/kg) and/or less than the Louisiana Synthetic Precipitation Leachate Procedure (LA SPLP);

• reducing the concentrations of the soil contaminated with lead to 500 mg/kg and/or less than the LA SPLP;

• removing Asbestos Containing Material and disposing of waste offsite; • removing the Underground Storage Tank, its contents and surrounding Polychlorinated

Biphenyl soils and disposing of waste offsite; • abandoning the onsite water supply well and disposing of building debris offsite; and, • stabilization of hazardous waste and disposing of the waste offsite. The major components of the original remedy. 1. Stabilization - Approximately 1,300 cubic yards (yd3) of hazardous waste will be

excavated and stabilized. The material will be stabilized until sampling verifies that it no longer exceeds the Toxicity Characteristic Leaching Procedure (TCLP) for lead. After verification, the waste will be disposed offsite at a Resource Conservation and Recovery Act (RCRA) regulated Subtitle D facility.

2. Asbestos Containing Material (ACM) - Materials will be consolidated onsite, contained,

and transported offsite to a disposal facility licensed to accept ACM. Methods to control airborne dispersion of asbestos will be implemented during remediation. The estimated total volume of material is 22 yd3.

3. Underground Storage Tank (UST) - The UST, its contents, and the surrounding

petroleum wastes will be characterized during the remedial design to determine whether the contents will be cleaned up under CERCLA or Oil Pollution Act (OPA) authority. The surrounding polychlorinated biphenyl (PCB) contaminated soils will be removed and disposed offsite in accordance with all federal, state, and local regulations. Total volume of tank contents is estimated at 5,000 gallons. The volume of associated contaminated soil is included in the soil/sediment estimated volume of 15,000 yd3.

4. Building debris and water supply well - The onsite well will be plugged and abandoned

in accordance with all federal, state, and local regulations. Portions of the Site will be cleared, where necessary, and the existing buildings and foundations will be demolished, removed and disposed offsite.

5. Soil/sediment - Approximately 15,000 yd3 of lead and antimony contaminated soils and

sediment will be excavated and disposed offsite in a RCRA Subtitle D facility. 6. Air Monitoring - During remedial action, efforts will be made to control dust and run-off

to limit the amount of materials that may migrate to a potential receptor. Air monitoring

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will be conducted during times of remediation to ensure that control measures are working to regulate Site emissions.

7. Short-term monitoring - Monitoring of the surface water and ground water during

remedial action may be necessary to ensure that runoff control measures are working.

The expected outcome of the remedy selected in the 2002 ROD was that the Site would no longer present an unacceptable risk to human health because the hazardous waste would be excavated, stabilized, and disposed offsite; contaminated soil and sediment would be excavated and disposed offsite; and the ACM and UST would be removed and disposed offsite. The property would be suitable for recreational/residential land use approximately one year after the start of the remedial action. Concentrations present in samples taken from the permanent ground water monitoring wells exceeded the MCL or LDEQ screening criteria for one constituent, bis(2-ethylhexyl)phthalate, which is a common plasticizer used in well construction material, and is most likely associated with Site monitoring well installation, not a condition of Site contamination. Although no groundwater contamination was identified, the remedy would also be protective of ground water by removing soil that exceeded the Louisiana screening criteria for concentrations protective of ground water. It was anticipated that the selected remedy would also provide community revitalization impacts because it would be compatible with Alexandria’s Site reuse plan. Because this remedy would not result in hazardous substances, pollutants, or contaminants remaining onsite above levels that allow for unlimited use and unrestricted exposure, a five-year review would not be required for this remedial action. In addition, no operation and maintenance or institutional controls would be necessary. Explanation of Significant Differences (September 28, 2004) After the ROD was signed, negotiations with the potentially responsible party (PRP), Kansas City Southern Railway (KCS), commenced. Post-ROD negotiations between EPA and KCS indicated that the use of stabilization may not be the most efficient and cost effective method for addressing the slag waste. In addition, post-ROD discussions between the city and the community resulted in changing the proposed future Site reuse from recreational to industrial. Based on this information, EPA issued an ESD in September 2004 to document Site future use as industrial and the addition of a contingency remedy for the hazardous waste. The change in land use required revisions to the baseline human health risk assessment (BHHRA), which in turn revised the soil/sediment cleanup levels, the estimated waste volume to be addressed, and the estimated remedial costs. This change also required future operation and maintenance (O&M) activities, Five-year Reviews, and Institutional Controls (ICs). The 2004 ESD identified Excavation and Offsite disposal as the contingency remedy, because it was presented in the 2002 Proposed Plan as an alternative, was evaluated using the nine criteria, and was commented on during the public comment period. A summary of the differences documented by the 2004 ESD are presented in Tables 2 and 3. All other components of the original selected remedy remain unchanged.

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Table 2: Remedial Action Objectives (2004 ESD) Media: Surface Soil and Sediment Media: other RAO No. 1 - Prevent direct human contact (pregnant adult woman worker) with surface soils and waste piles containing lead at concentrations that would result in a greater than 5 percent chance that a fetus’s blood lead value would exceed 10 micrograms per deciliter. RAO No. 2 - Prevent direct human contact (adult workers) with surface soils containing antimony at concentrations which have a hazard index greater than 1.

RAO No. 3 - Prevent direct human contact with asbestos containing material at concentrations greater than 1 percent by weight. RAO No. 4 - Prevent direct contact with the underground storage tank, its contents, and surrounding contaminated soils. RAO No. 5 - Prevent direct human contact (pregnant adult woman worker and adult workers) with slag pile material with toxicity characteristic leaching procedure lead concentrations greater than 5 milligrams per liter and handle as hazardous waste in accordance with all applicable federal, state, and local regulations. RAO No. 6 - Prevent migration of contaminants to deeper soils and ground water through the former onsite water supply well and from the existing buildings, slabs, sump, and trash.

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Explanation of Significant Differences (January 2, 2008) As part of the Consent Decree negotiations and remedial design activities, the PRP, through a treatability evaluation, researched and reviewed options related to stabilization of the slag waste. Information gathered during the treatability evaluation, supports the use of the contingency remedy documented in the 2004 ESD as being a more efficient and cost effective approach for remediation of the hazardous slag waste. Therefore, the 2008 ESD was issued to invoke the Contingency Remedy as presented in the 2004 ESD. Tables 4, 5 and 6 summarize the supporting documentation presented in a detailed letter dated September 13, 2007, from KCS to EPA, and the Final Contingency ESD which invoked the use of Excavation and Offsite Disposal as the remedy for the Site.

Table 3: Comparison of the Differences between the 2002 ROD and 2004 ESD

Component 2002 ROD 2004 ESD Difference

Remedial Approach Stabilization and Offsite Disposal

Stabilization and Offsite Disposal with Excavation and Offsite Disposal Contingency for the Hazardous Waste

Addition of the Excavation and Offsite Disposal Contingency for the Hazardous Waste

Soil/Sediment Cleanup Levels

500 mg/kg lead 150 mg/kg antimony


Recreational Scenario verses Industrial Scenario

Soil/sediment Volume 15,000 yd3 1,766 yd3 13,234 yd3 decrease

O&M and ICs (present value cost estimated for 30 year time period)

No Cost

$397,299

$397,299 increase

Five-year Reviews (present value cost estimated for 30 year time period)

No Cost

$43,497

$43,497 increase

Remedial Cost Stabilization (1,300 yd3

hazardous waste) and Offsite Disposal Excavation and Offsite Disposal

$5,007,412

$2,751,901 $3,035,002

$2,255,511 decrease $1,972,410 decrease

Contingency Remedy 1,300 yd3 hazardous waste: Cost of Excavation and Offsite Disposal verses Stabilization and Disposal

Stabilization and Disposal $510,380

Excavation and Disposal $700,700

$190,320 increase

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Table 4: Comparison of the Stabilization option and the Contingency Remedy Issue Stabilization Excavation Small Hazardous Waste Volume versus Volume of Stabilization Materials: To stabilize the slag, the material must be reduced in size to increase surface area and then mixed with a stabilizing agent, such as Portland cement. The estimated mixing ratio may range from 1:1 up to 3:1, stabilization agent to slag. Even at the low end, an equal volume of stabilizing agent will require shipping to the Site as well as onsite storage.

Mixing Agent: equal volume transported to the Site and stored for use.

Mixing Agent: none required. All treatment done offsite at the disposal facility.

Additional Equipment, truck traffic, and Waste Handling: In order to reduce the size of the slag and appropriately mix it with the stabilization agent, additional equipment and handling will be required.

Equipment: A pug mill, or other appropriate equipment will be transported and stored onsite. Slag material handling increased: Slag will be excavated, reduced in size, mixed with stabilizing agent, and then transported offsite for disposal. Stabilizing agent handling: The stabilizing agent will be stored, mixed with the slag, and then transported offsite for disposal. Truck traffic: Increased truck traffic related to transportation of stabilization equipment and materials.

Equipment: no additional equipment necessary. Slag material handling: Slag will be excavated and transported offsite for disposal. No additional handling required. Stabilizing agent handling: No stabilizing agent required Truck Traffic: Truck traffic related to the transportation of excavation equipment.

Site ingress/egress and size: The acreage requiring remedial work is approximately 4.98, and access to the Site by vehicle is across a bridge of unknown stability and strength.

Equipment: Equipment for excavation, stabilization, and size reduction will be required. Additional equipment and storage of stabilizing materials limits available space for maneuverability. Bridge: The bridge is old and its load bearing capacity is unknown. Increased stress related to increased equipment and truck traffic required for slag stabilization.

Equipment: Equipment for excavation will be required. Bridge: Increased stress related to excavation equipment.

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Table 4 (continued): Comparison of the Stabilization option and the Contingency Remedy Safety: There are safety concerns related to onsite activities.

Equipment: Increased equipment operation for stabilization. Stabilizing Agent: Increased handling and storage of material. Truck Traffic: Increase truck traffic for transportation of stabilization agent and equipment. Dust exposure: Increase potential for exposure due to increased handling of stabilizing agent and slag. Maneuverability: Reduction in available Site space due to increased storage and use of stabilization equipment. Bridge: Ingres/Egress of additional heavy loads (stabilization materials and equipment) over the bridge which has unknown stability and strength characteristics.

Equipment: No increased equipment operation for stabilization. Stabilizing Agent: No increased handling and storage of material. Truck Traffic: Truck traffic for transportation of excavation equipment. Dust exposure: potential for exposure due to handling of slag. Maneuverability: Available Site space is not reduced due to increased storage and use of stabilization equipment. Bridge: Ingres/Egress of excavation equipment over the bridge which has unknown stability and strength characteristics.

Safety: There are safety concerns related to offsite areas.

Truck Traffic: Increase truck traffic through the neighborhood for transportation of stabilization agent and equipment. Dust exposure: Increase potential for exposure due to increased handling of stabilizing agent and slag.

Truck Traffic: No additional truck traffic through the neighborhood for transportation of stabilization agent and equipment. Dust exposure: No additional increase in the potential for exposure due to increased handling of stabilizing agent and slag.

Remedy Efficiency: Estimated time of remedial action can be reduced.

Additional handling and mixing of the slag and stabilization agent can increase the amount of time required to meet the RAOs.

The direct offsite disposal of slag, without onsite treatment, can reduce the amount of time required to meet the RAOs.

Cost Effectiveness: Cost is reduced for both options by the use of rail rather than trucks. Use of Rail also reduces safety concerns for both onsite and offsite areas.

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Notes: 1. 1300 yd3 of Hazardous Slag Waste 2. Stabilization assumed to double volume: stabilized material estimated to be 2600 yd3 and using a conversion factor of 1.15, the estimated tons of material is 2990 tons. 3. 1300 yd3 x 1.15 conversion factor = 1495 tons 4. No cost for transportation as KCS would use their railway.

Table 5: Comparison of the Differences between the 2004 ESD and 2008 ESD

Component 2004 ESD 2008 ESD Difference

Remedial Approach Stabilization and Offsite Disposal (hazardous waste)

Excavation and Offsite Disposal (hazardous waste)

No Onsite Stabilization

Remedial Cost Stabilization and Offsite Disposal (hazardous waste) Excavation and Offsite Disposal (hazardous waste)

Stabilize1: $33/yd3 = $42,900 Transport2: $56/ton = $167,440 Dispose2: $96/ton = $287,040 Transport3: $246/ton = $367,770Disposal3: $214/ton = $319,930

Transport4: $0/ton = $0 Disposal3: $75/ton = $112,125

$575,575

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Table 6: Summary of the Final Selected Remedy presented in the 2008 ESD

Component Description

Remedial Approach Excavation and Offsite Disposal

Cleanup Levels and Estimated Volume

Approximately 1,766 yd3 of lead and antimony contaminated soil and sediment exceeding the industrial scenario cleanup levels of 1400 mg/kg lead and 820 mg/kg antimony will be excavated and disposed offsite.

Slag Waste Approximately 1,300 yd3 of hazardous slag waste will be excavated and disposed offsite at a permitted RCRA hazardous waste landfill.

Operation and Maintenance (O&M)

Annual O&M activities will include, but are not limited to, Site inspection and maintenance, IC inspection and enforcement, and Site reports.

Five-year Reviews

Because waste will be left onsite above levels that allow for unlimited use and unrestricted exposure, Five-year Reviews will be conducted no less than every five years to ensure that the remedy is functioning as designed, and remains protective of human health and the environment.

Institutional Controls (ICs)

Because waste will be left onsite above levels that allow for unlimited use and unrestricted exposure, an IC will be put in place to ensure that the property remains zoned industrial and is only used for that purpose. A conveyance notice will be filed with the property deed describing the Site conditions and the land use restrictions to control exposure to contamination left onsite. The restrictions would prohibit any unauthorized excavation or use of contaminated soil and limit future use of the property for industrial purposes. Enforcement of the IC will be the responsibility of the State and the local governing authorities.

Asbestos Containing Waste (ACM)

Material will be consolidated onsite, contained, and transported offsite to a disposal facility licensed to accept ACM. Methods to control airborne dispersion of asbestos will be implemented during remediation. The estimated total volume of material is 22 yd3.

Underground Storage Tank (UST)

The UST, its contents, and the surrounding petroleum wastes will be characterized and disposed offsite. The surrounding polychlorinated biphenyl (PCB) contaminated soils will be removed and disposed offsite in accordance with all federal, state, and local regulations. Total volume of tank contents is estimated at 5,000 gallons.

Building Debris and Wells

The wells will be plugged and abandoned in accordance with all federal, state, and local regulations. Portions of the Site will be cleared, where necessary, and the existing buildings and foundations will be demolished, removed and disposed offsite.

Air Monitoring

During remedial action, efforts will be made to control dust and run-off to limit the amount of materials that may migrate to a potential receptor. Air monitoring will be conducted during times of remediation to ensure that control measures are working to regulate Site emissions.

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V. Basis for the Document The PRP, Kansas City Southern Railway (KCS), began remedial action in February 2008 and completed onsite construction in August 2008. The Preliminary Close Out Report was signed on September 3, 2008, documenting the completion of onsite construction. Review of the draft remedial action report noted that an area along the southern boundary, just north of the canal may not have been fully addressed. On May 15, 2009, EPA and KCS performed a Site inspection to verify whether field activities were completed in this area. Visual inspection of the area confirmed that additional excavation would be required. KCS mobilized to the Site during the week of May 25, 2009, and began clearing the canal bank. Excavation of contaminated soil and slag began during the week of June 1, 2009, and was completed on June 23, 2009. EPA and LDEQ were onsite June 23, 2009, to conduct a Site inspection with KCS. Seeding of the canal bank was completed on July 2, 2009, and later inspected jointly by LDEQ and KCS on July 22, 2009. During the inspection, it was noted that significant erosion had taken place due to heavy rains. These areas were repaired with riprap during the week of August 24, 2009. Implemented Remedial Action Construction Activities Site work plans were followed to ensure that the cleanup activities met all quality assurance and quality control requirements for the Site. The EPA, in conjunction with LDEQ, conducted regular oversight throughout the implementation of the remedial action. In addition to conducting oversight of the project activities, EPA was in regular contact by phone and e-mails with the KCS and LDEQ project managers during construction activities. The EPA and LDEQ reviewed and commented on all project plans for the Site and participated in the Pre-Final and Final Site Inspections. In addition, LDEQ reviewed and commented on the Preliminary Close Out Report. While performing Site remedial activities, KCS determined that minimal effort and cost would be required to address Site contamination to levels well below the cleanup levels established for lead and antimony under an industrial scenario as described in the 2004 ESD. Areas of excavation included the removal of contaminated soil and slag (Figures 3 and 4), and confirmation sample results show levels of lead and antimony to be less than the cleanup levels required for unlimited use and unrestricted exposure as determined by the Site-specific risk assessment. Lead concentrations are less than 500 mg/kg, with the highest concentration left onsite at 342 mg/kg, and antimony concentrations are less than 150 mg/kg, with the highest concentration left onsite at 18.9 mg/kg. The concentrations are consistent with accepted unlimited use and unrestricted exposure scenarios. In addition, identified ACM, hazardous waste (slag), and the UST were removed and disposed offsite. Based on Site construction activity and subsequent confirmation sampling, all RAOs have been met as well as the criteria for unlimited use and unrestricted exposure. The excavation areas were backfilled with suitable materials meeting Site-specific cleanup levels, graded for proper drainage, and seeded.

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Because the Site is available for unlimited use and unrestricted exposure, institutional controls, operation and maintenance, and five year reviews are no longer required or necessary to ensure protection of human health and the environment. The major components of the remedy implemented during 2008 and 2009 are: 1. Soil/sediment - Approximately 7,220 yd3 [6,140 yd3 from the northern portion, 1069.5 tons (713 yd3) from the southern portion, and 550 tons (367 yd3) from the canal bank] of lead and antimony contaminated soil and sediment were excavated and disposed offsite in a RCRA Subtitle D facility. Excavation progressed to the underlying clay with depths ranging from 6 inches to 4 ft below original ground surface. Excavation areas were backfilled and graded to drain. All confirmation sample results were below the lead and antimony cleanup levels consistent with unlimited use and unrestricted exposure. 2. Excavation of hazardous slag waste - Approximately 745.94 tons of hazardous waste from the northern portion and 45 yd3 of hazardous waste from the canal bank were excavated and shipped to a permitted RCRA hazardous waste landfill. 3. Asbestos Containing Material (ACM) – A Louisiana-licensed asbestos abatement contractor visually identified building debris that potentially contained asbestos. The contractor collected 6 samples of building debris material and mapped the area around the former foundry building where the debris was located. Asbestos was positively identified in three samples, two of cement board building debris and one of black flashing building debris. The ACM was localized about the former foundry building with no evidence of burial. Prior to excavation activities, the ACM debris was consolidated onsite, contained, and transported offsite to a disposal facility licensed to accept ACM. Methods to control airborne dispersion of asbestos were implemented during remediation. The final total volume of material disposed offsite was 30 yd3. After removal of the ACM, the underlying soil within the ACM area was incorporated into the overall slag and soil excavation areas. At a minimum, 6 inches of soil were removed during remediation, and the area was backfilled with clean fill upon completion. 4. Underground Storage Tank (UST) - The UST was located and removed. Upon examination, the UST was determined to be steel with an estimated 500 gallon-capacity. The UST was found full of soil, and no staining was evident in the surrounding soil. The UST was decontaminated and disposed offsite. Surrounding soils were sampled and results met Site cleanup levels as well as LDEQ UST cleanup levels. 5. Building debris and water supply well - All 5 onsite wells were plugged and abandoned in accordance with federal, state, and local regulations. The Site was cleared (as necessary), and the existing metal buildings and concrete foundations were demolished. All steel material was decontaminated and recycled. All concrete was decontaminated and donated to a concrete recycling center. All other domestic trash dumped on the property was removed and disposed offsite. An estimated 43 tons of building debris and scrap metal and 550 yd3 of concrete were recycled.

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6. Air Monitoring - During remedial action, efforts were made to control dust and run-off to limit the amount of materials that may migrate to a potential receptor. Air monitoring was conducted during times of remediation to ensure that control measures were working to regulate Site emissions. Monitors were placed upgradient, downgradient, and within the excavation areas as well as on personnel working within the exclusion zone. Air monitoring results did not exceed the Site-specific action levels for lead, antimony, or total suspended particulates. 7. Backfill – Approximately 9,185 yd3 of backfill (7,800 yd3 on the northern portion, 1,185 yd3 on the southern portion, and 200 yd3 on the canal bank) were used to fill excavation areas and grade the Site for proper drainage. Backfill material was identified as suitable for the Site as sample results met the Site cleanup levels. VI. Description of Significant Differences This ESD documents the removal of institutional controls, operation and maintenance, and five-year reviews as components of the overall Site remedy as documented in the 2004 ESD and the 2008 Contingency ESD. Table 7 lists only those components affected by these changes, and Table 8 summarizes the final remedial action for the Ruston Foundry Superfund Site as documented in this ESD.

Table 7: Comparison of the Differences between the 2008 ESD and the 2009 ESD

Component 2008 ESD 2009 ESD Difference

Soil/Sediment Cleanup Levels



Industrial Scenario verses Recreational/Residential Scenario

Soil/Sediment Volume 1,766 yd3 7,220 yd3 5,454 yd3 increase

Slag Volume 1,300 yd3 694 yd3 606 yd3 decrease

O&M and ICs (present value cost estimated for 30 year time period)

$397,299

Not Necessary due to meeting unlimited use and unrestricted exposure scenario.

$397,299 decrease

Five-year Reviews (present value cost estimated for 30 year time period)

$43,497

Not Necessary due to meeting unlimited use and unrestricted exposure scenario.

$43,497 decrease

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Table 8: Summary of the Final Selected Remedy presented in the 2009 ESD

Component Description

Remedial Approach Excavation and Offsite Disposal

Cleanup Levels and Estimated Volume

Approximately 7,220 yd3 [6,140 yd3 from the northern portion, 1069.5 tons (713 yd3) from the southern portion, and 550 tons (367 yd3) from the canal bank] of lead and antimony contaminated soil and sediment exceeding the recreational/residential scenario cleanup levels of 500 mg/kg lead and 150 mg/kg antimony were excavated and disposed offsite. Backfill meeting Site cleanup levels was imported and used to grade the Site. This activity satisfies RAOs 1 and 2.

Slag Waste

Approximately 745.94 tons of hazardous waste from the northern portion and 45 yd3 of hazardous waste from the canal bank were excavated and shipped to a permitted RCRA hazardous waste landfill. Backfill meeting Site cleanup levels was imported and used to grade the Site. This activity satisfies RAO 5.

Asbestos Containing Waste (ACM)

Approximately 30 yd3 of ACM was consolidated onsite, contained, and transported offsite to a disposal facility licensed to accept ACM. Methods to control airborne dispersion of asbestos were implemented during remediation as necessary. This activity satisfies RAO 3.

Underground Storage Tank (UST)

The UST, its contents, and the surrounding soils were characterized and disposed offsite. This activity satisfies RAO 4.

Building Debris and Wells

All 5 onsite wells were plugged and abandoned in accordance with federal, state, and local regulations. The Site was cleared (as necessary), and the existing buildings and foundations were demolished. All steel material was decontaminated and recycled. All concrete was decontaminated and donated to a concrete recycling center. An estimated 43 tons of building debris and scrap metal and 550 yd3 of concrete were recycled. This activity satisfies RAO 6.

Air Monitoring

During remedial action, efforts were made to control dust and run-off to limit the amount of materials that may migrate to a potential receptor. Air monitoring was conducted during times of remediation to ensure that control measures were working to regulate Site emissions. Data indicated that Site activities did not exceed Site-specific action levels for protection of workers or surrounding residents.

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VII. Support Agency Comments The LDEQ has been consulted and provided the opportunity to comment on this ESD in accordance with the NCP §§ 300.435 (c)(2) and 300.435 (c)(2)(i) and CERCLA § 121 (f). The LDEQ supports the changes in the selected remedy to better reflect the completed remedial actions and future use of the Site (Appendix A). VIII. Statutory Determinations The EPA has determined that these significant changes comply with the statutory requirements of CERCLA § 121, 42 U.S.C. § 9621, are protective of human health and the environment, comply with Federal and State requirements that are applicable or relevant and appropriate to the remedial action, are cost-effective, and utilize permanent solutions and alternative treatment technologies to the maximum extent practicable. This remedy does not satisfy the statutory preference for treatment as a principal element of the remedy (i.e., reduces the toxicity, mobility, or volume of hazardous substances, pollutants, or contaminants as a principal element through treatment). The hazardous waste was excavated and disposed offsite at a RCRA hazardous waste landfill. Excavation and Offsite Disposal is protective of human health and the environment; complies with applicable or relevant and appropriate requirements, including meeting land disposal restrictions; provides for long-term effectiveness and permanence due to contamination removal; reduces material mobility, although not provided through treatment; and is cost effective. The completed remedial action was easily implemented because it utilized conventional equipment used and accepted in the construction industry. Implementation of excavation with offsite disposal provided for public protectiveness through the use of rail as a transport mechanism rather than trucks, reduced construction time, and increased efficiency in meeting the RAOs. IX. Public Participation This ESD will become part of the Administrative Record (NCP 300.825(a)(2)), which is developed in accordance with Section 113 (k) of CERCLA, 42 U.S.C. § 9613 (k), and which is available for review at the Rapides Parish Public Library, 411 Washington Street, Alexandria, Louisiana, 71301; and the Louisiana Department of Environmental Quality, Public Records Center, Galvez Building Room 127, 602 N. Fifth Street, Baton Rouge, Louisiana, 70802. As required by NCP § 300.435(c)(2)(i)(B), a Notice of Availability and a brief description of the ESD will be published in the local paper.

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TT

T T

T

TT

TL &

A R

ailro

ad C

ompa

ny (in

activ

e)

Miss

ouri P

acific

Rail

road

(inac

tive)

Louis

iana P

ine Pr

oduc

ts

1.62 a

cres

Chicago, Rock

Island & Pacific RR

Boga

n Stre

et

Ruston Street

12th Street

13th Street

Rusto

n Stre

et#

Bridge

Concrete SlabAbandonedWell Head

DilapidatedMetal Building

Concrete Slab

DilapidatedWood FrameBuilding

Concrete Slab

#Bridge

$Z

Ruston Foundry andMachine Shops

4.98 acres

Mill Stree

t Ditch

ChatlinLake

Canal

Canal

T FenceRailroad

LEGENDRuston Foundry Site Boundary

Water Flow DirectionPre-Existing Railroad

Ruston Property Boundary

%% % % %

50 0 50 100 Feet

N

EW

S

Figure 1Site Map

Ruston Foundry SiteAlexandria, LA

006048

LEGEND

> 500

Superfund Site Boundary

Railroad Lease Boundary

Ruston Property Boundary

Superfund Site Boundary

Railroad

Fence LineL

& A

Rai

lroad

(in

activ

e)

Mis

sour

i Pac

ific

Railr

oad

(inac

tive)

BOGA

N S

TREE

T

RUSTON STREET

12TH STREET

13TH STREET

NOTES:

50 0 50 100 Feet

Sept 15, 2003

N

Ruston Superfund Site

Concentration

Total Lead in Shallow Soil and Debris > (500 ppm)

aerial photography date: 2001Source: USEPA RI data

006049

A1 289859.260 3299290.860 75.23 F2 289844.190 3299417.150 73.25A2 289881.800 3299298.070 75.62 F3 289868.290 3299424.680 75.19A3 289908.570 3299307.060 75.42 F4 289891.960 3299432.210 73.79A4 289928.820 3299312.380 76.06 F5 289915.700 3299440.200 74.27A5 289953.480 3299320.730 75.69 F6 289939.640 3299447.560 74.04A6 289977.060 3299328.640 75.60 F7 289963.530 3299455.110 74.09A7 290001.360 3299336.170 76.13 F8 289987.310 3299462.580 74.09B1 289850.850 3299314.550 76.56 F9 290011.000 3299470.000 74.36B2 289874.560 3299322.020 76.01 F10 290035.080 3299477.760 74.77B3 289898.250 3299330.360 76.24 F11 290058.790 3299485.300 75.57B4 289921.260 3299336.950 76.68 F12 290082.650 3299492.630 76.56B5 289945.820 3299344.510 76.77 G1 289810.950 3299432.580 71.63B6 289969.870 3299352.100 76.70 G2 289834.470 3299440.200 73.19B7 289994.100 3299359.880 76.69 G3 289860.750 3299448.640 74.75B8 290017.620 3299367.600 75.89 G4 289884.250 3299456.100 73.33B11 290089.060 3299390.640 75.55 G5 289908.460 3299463.990 74.04C1 289842.790 3299338.230 76.45 G6 289932.200 3299471.380 74.10C2 289867.140 3299345.730 76.15 G7 289955.930 3299479.050 73.21C3 289890.850 3299353.290 76.62 G8 289979.860 3299486.620 74.01C4 289914.730 3299360.600 76.22 G9 290003.700 3299494.140 74.58C5 289938.640 3299368.510 76.63 G10 290027.500 3299501.690 75.68C6 289962.570 3299376.190 76.22 G11 290051.360 3299509.330 75.91C7 289986.750 3299383.680 75.31 G12 290074.920 3299516.920 76.84C8 290010.080 3299391.580 75.94 H1 289803.720 3299456.730 72.96C11 290081.600 3299414.030 75.62 H2 289829.110 3299464.670 73.80C12 290105.340 3299421.570 76.18 H3 289852.910 3299472.330 73.94D1 289835.190 3299361.370 75.84 H4 289876.790 3299480.060 74.05D2 289859.290 3299369.630 76.55 H5 289900.800 3299487.560 74.15D3 289883.340 3299377.040 76.78 H6 289924.590 3299495.050 73.93D4 289907.100 3299384.720 76.46 H7 289948.440 3299502.730 73.75D5 289931.060 3299392.340 76.17 H8 289972.270 3299510.290 74.74D6 289954.840 3299399.830 75.57 H9 289995.950 3299517.880 75.27D7 289978.420 3299407.310 75.59 H10 290019.860 3299525.340 75.28D8 290002.450 3299414.840 75.20 H11 290043.640 3299532.990 75.19D9 290026.510 3299422.420 75.10 H12 290067.530 3299540.380 75.62D10 290050.050 3299430.080 75.59 I1 289798.090 3299481.270 72.83D11 290073.930 3299437.650 75.38 I2 289821.770 3299488.760 73.90D12 290097.810 3299445.170 76.88 I3 289845.540 3299496.300 73.66E1 289826.130 3299384.770 75.40 I4 289869.140 3299503.790 73.55E2 289851.940 3299392.990 76.04 I5 289893.080 3299511.490 74.23E3 289875.800 3299401.000 76.79 I6 289916.770 3299519.060 74.30E4 289899.540 3299408.420 75.51 I7 289940.780 3299526.450 74.37E5 289923.530 3299416.210 74.95 I8 289964.540 3299533.930 74.54E6 289947.240 3299423.800 74.62 I9 289988.260 3299541.540 74.62E7 289971.290 3299431.270 74.99 I10 290012.240 3299549.120 74.69E8 289994.960 3299438.870 74.93 I11 290036.120 3299556.730 74.85E9 290018.740 3299446.380 74.75 I12 290059.720 3299564.340 74.68E10 290042.760 3299454.060 74.85 J1 289791.730 3299505.600 73.28E11 290066.520 3299461.600 75.19 J2 289814.050 3299512.540 73.45E12 290090.250 3299469.250 77.05 J3 289837.610 3299519.860 73.83F1 289817.330 3299407.210 70.96 J4 289861.70 3299527.73 74.00

EPA # N O RT H ING EA STIN G ELEV A TIOND2 RA 290257.607 3299451.239 74.79D3 RA 290223.390 3299534.542 74.80DPG2 289898.000 3299529.000 74.54G2RA 290049.000 3299396.000 76.02H2RA 289977.000 3299373.000 76.95H3RA 289952.000 3299444.000 77.22HS11 289973.000 3299372.000 77.06HS12 289983.000 3299380.000 76.71I1RA 289921.092 3299291.231 74.7312RA 289910.000 3299356.000 76.4613RA 289885.000 3299428.000 76.70J2RA 289844.000 3299341.000 76.00J3RA 289828.000 3299417.000 69.62J4RA 289797.000 3299475.000 73.68K3RA 289733.642 3299373.483 75.04SGP101 289980.254 3299595.233 73.69SGP102 289968.555 3299600.801 73.44SGP201 289945.281 3299543.293 73.79SGP301 290115.754 3299462.664 76.96SGP302 290139.750 3299469.614 76.49SE‐3 289913.684 3299551.213 73.58SE‐2 289956.746 3299551.911 73.61SE‐1 289960.470 3299582.329 73.34NW ‐1 290193.599 3299453.622 75.11NW ‐3 290225.076 3299466.990 74.96NW ‐2 290215.390 3299441.012 75.38S ‐1 289719.728 3299248.160S ‐2 289709.097 3299281.481S ‐3 289711.508 3299323.125

S ‐4 289661.391 3299352.697

S ‐5 289679.599 3299403.940S ‐6 289628.763 3299397.979S ‐7 289575.053 3299402.542

S ‐8 289530.878 3299369.933

006050

006051


Appendix A Letter from LDEQ

006052

006053

006054

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