contamination extent report and preliminary …...contamination extent report and preliminary injury...

CONTAMINATION EXTENT REPORT AND PRELIMINARY INJURY EVALUATION FOR THE CALCASIEU ESTUARY Prepared for: Damage Assessment Center National Oceanic and Atmospheric Administration Silver Spring, MD William Conner, Contracting Officer's Technical Representative Prepared by: Mark S. Curry, Michael T. Huguenin, Aaron J. Martin, and Todd R. Lookingbill Industrial Economics, Incorporated 2067 Massachusetts Avenue Cambridge, MA 02140 Contract 50-DGNC-1-00007 Task Order 56-DGNC-6-50107 June 16, 1997

FOREWORD This document reviews chemical contamination within the Calcasieu Estuary and fulfills the requirements of NOAA Task Order 56-DGNC-5-50107. The report consists of three major components. Part I presents the Resource Characterization. This section of the report assesses the overall extent of chemical contamination within the surface water, sediment, and fish and shellfish of the Calcasieu Estuary. Part II presents the Facility Review, which inventories the manufacturing processes, waste water treatment systems, and waste management practices of nine major industrial facilities within the Calcasieu Estuary. Finally, Part III contains the Injury Evaluation and Contaminant Review. This part of the report identifies contaminants that have the potential to injure the natural resources of the Calcasieu Estuary.

i

TABLE OF CONTENTS LIST OF ABBREVIATIONS PREFACE PART I: RESOURCE CHARACTERIZATION RESOURCE CHARACTERIZATION INTRODUCTION AND SUMMARY ...................CHAPTER 1 Overview of the Calcasieu Estuary .....................................................................................................1-1 Principle Findings................................................................................................................................1-3 Condition of the Calcasieu Estuary .......................................................................................1-3 Identifying Potential Sources of Contamination ...................................................................1-4 Data Set Variability................................................................................................................1-5 Organization of the Resource Characterization ..................................................................................1-6 RESOURCE CHARACTERIZATION METHODS................................................................CHAPTER 2 Study Area Segmentation....................................................................................................................2-1 Overview of Data Sources...................................................................................................................2-3 Other Data Sources ..............................................................................................................2-10 Data Aggregation Methods ...............................................................................................................2-10 Reportable Data -- Defining SQLs and EQLs.....................................................................2-11 Data Qualifiers .....................................................................................................................2-12 Surface Water and Sediment Data Tables...........................................................................2-13 LDEQ Ambient Water Data ................................................................................................2-14 BAYOU D'INDE ...........................................................................................................................CHAPTER 3 Overview of Bayou d'Inde...................................................................................................................3-1 Bayou d'Inde Segmenting Scheme......................................................................................................3-2 Surface Water Data Summary.............................................................................................................3-4

ii

TABLE OF CONTENTS (continued)

Volatile Organic Compounds (VOCs)................................................................................................3-4 Semivolatile Organic Compounds (SVOCs).........................................................................3-6 Polychlorinated Biphenyls (PCBs) and Pesticides................................................................3-7 Inorganic Elements ................................................................................................................3-7 Sediment Data Summary.....................................................................................................................3-9 Volatile Organic Compounds (VOCs) ..................................................................................3-9 Semivolatile Organic Compounds (SVOCs).......................................................................3-11 Total Petroleum Hydrocarbons (TPHs)...............................................................................3-13 Polychlorinated Biphenyls (PCBs)......................................................................................3-13 Pesticides..............................................................................................................................3-14 Inorganic Elements ..............................................................................................................3-15 BAYOU VERDINE.......................................................................................................................CHAPTER 4 Overview of Bayou Verdine ...............................................................................................................4-1 Bayou Verdine Segmenting Scheme...................................................................................................4-2 Surface Water Data Summary.............................................................................................................4-5 Volatile Organic Compounds (VOCs) ..................................................................................4-5 Semivolatile Organic Compounds (SVOCs).........................................................................4-7 Inorganic Elements ................................................................................................................4-8 Sediment Data Summary.....................................................................................................................4-9 Volatile Organic Compounds (VOCs) ..................................................................................4-9 Semivolatile Organic Compounds (SVOCs).......................................................................4-11 Total Petroleum Hydrocarbons (TPHs)...............................................................................4-13 Polychlorinated Biphenyls (PCBs) and Pesticides..............................................................4-13 Inorganic Elements ..............................................................................................................4-13 CALCASIEU RIVER AND SHIP CHANNEL .........................................................................CHAPTER 5 Overview of the Calcasieu River and Ship Channel...........................................................................5-1 Calcasieu River Segmenting Scheme..................................................................................................5-3

iii

TABLE OF CONTENTS (continued)

Surface Water Data Summary ..........................................................................................................................5-5 Volatile Organic Compounds (VOCs) ..................................................................................5-5 Semivolatile Organic Compounds (SVOCs).........................................................................5-8 Inorganic Elements ..............................................................................................................5-10 Sediment Data Summary...................................................................................................................5-12 Volatile Organic Compounds (VOCs) ................................................................................5-12 Semivolatile Organic Compounds (SVOCs).......................................................................5-13 Total Petroleum Hydrocarbons (TPHs)...............................................................................5-15 Polychlorinated Biphenyls (PCBs) and Pesticides..............................................................5-15 Inorganic Elements ..............................................................................................................5-15 FISH AND SHELLFISH RESOURCES....................................................................................CHAPTER 6 Overview of the Fish Sampling Program............................................................................................6-1 Study Area..............................................................................................................................6-1 Target Species ........................................................................................................................6-3 Compounds Analyzed............................................................................................................6-4 Health Advisories...................................................................................................................6-4 Analysis of Fish and Shellfish Tissue Data ........................................................................................6-6 Data Aggregation Methods....................................................................................................6-6 Principle Findings ..................................................................................................................6-7 Contaminant-Specific Results ...............................................................................................6-9 PART II: FACILITY REVIEW FACILITY REVIEW ...................................................................................................................CHAPTER 7 Data Sources and Methods..................................................................................................................7-1

iv

TABLE OF CONTENTS (continued) PPG Industries .....................................................................................................................................7-4 Site Description and History..................................................................................................7-4 Products and Production Processes .......................................................................................7-4 NPDES Summary ..................................................................................................................7-7 RCRA Summary ..................................................................................................................7-10 PPG Wastes..........................................................................................................................7-13 Conoco Incorporated .........................................................................................................................7-16 Site Description and History................................................................................................7-16 Products and Production Processes .....................................................................................7-16 NPDES Summary ................................................................................................................7-16 RCRA Summary ..................................................................................................................7-20 Conoco Wastes.....................................................................................................................7-22 Citgo Petroleum Corporation/Cit-Con Oil Corporation ...................................................................7-25 Site Description and History................................................................................................7-25 Products and Production Processes .....................................................................................7-25 NPDES Summary ................................................................................................................7-27 RCRA Summary ..................................................................................................................7-36 Citgo Wastes ........................................................................................................................7-42 CONDEA Vista Chemical Company................................................................................................7-43 Site Description and History................................................................................................7-43 Products and Production Processes .....................................................................................7-43 NPDES Summary ................................................................................................................7-43 RCRA Summary ..................................................................................................................7-49 Vista Wastes.........................................................................................................................7-55 Olin Chemicals ..................................................................................................................................7-56 Site Description and History................................................................................................7-56 Products and Production Processes .....................................................................................7-56 NPDES Summary ................................................................................................................7-56 RCRA Summary ..................................................................................................................7-60

v

TABLE OF CONTENTS (continued) OxyChem Petrochemicals .................................................................................................................7-64 Site Description and History................................................................................................7-64 Products and Production Processes .....................................................................................7-65 NPDES Summary ................................................................................................................7-65 RCRA Summary ..................................................................................................................7-67 OxyChem Wastes ................................................................................................................7-67 Westlake Polymers Corporation .......................................................................................................7-70 Site Description and History................................................................................................7-70 Products and Production Processes .....................................................................................7-70 NPDES Summary ................................................................................................................7-70 RCRA Summary ..................................................................................................................7-72 Firestone Synthetic Rubber and Latex Company .............................................................................7-74 Site Description and History................................................................................................7-74 Products and Production Processes .....................................................................................7-74 NPDES Summary ................................................................................................................7-74 RCRA Summary ..................................................................................................................7-77 W.R. Grace ........................................................................................................................................7-79 Site Description and History................................................................................................7-79 Products and Production Processes .....................................................................................7-79 NPDES Summary ................................................................................................................7-79 RCRA Summary ..................................................................................................................7-81 PART III: PRELIMINARY INJURY EVALUATION AND CONTAMINANT REVIEW INJURY EVALUATION AND CONTAMINANT REVIEW INTRODUCTION AND SUMMARY........................................................................................CHAPTER 8 Overview of Methods..........................................................................................................................8-1 Summary of Results: Injury Determination.......................................................................................8-2 Surface Water.........................................................................................................................8-2 Sediment.................................................................................................................................8-4 Fish and Shellfish...................................................................................................................8-4 Summary of Results: Contaminants of Concern................................................................................8-5

vi

TABLE OF CONTENTS (continued) SURFACE WATER INJURY EVALUATION AND CONTAMINANT REVIEW............CHAPTER 9 Surface Water Injury Assessment .......................................................................................................9-1 Water Contaminant Concentrations Exceeding Water Quality Criteria .........................................................................................9-2 Water Contaminant Concentrations Causing Sediments to Exhibit Hazardous Waste Characteristics .........................................................................9-5 Water Contaminant Concentrations Sufficient to Cause Injury to Ground Water, Air, Geologic, or Biological Resources .............................................................................................................9-5 Surface Water Contaminant Review...................................................................................................9-6 Summary ................................................................................................................................9-6 Methodology..........................................................................................................................9-6 Results and Discussion ........................................................................................................9-11 SEDIMENT INJURY EVALUATION AND CONTAMINANT REVIEW........................CHAPTER 10 Sediment-Dwelling Organism Injury Assessment............................................................................10-1 Sediment Contaminant Review.........................................................................................................10-2 Summary ..............................................................................................................................10-2 Methodology........................................................................................................................10-6 Results and Discussion ......................................................................................................10-10 FISH AND SHELLFISH INJURY EVALUATION AND CONTAMINANT REVIEW............................................................................................CHAPTER 11 Fish and Shellfish Injury Assessment ...............................................................................................11-1 Adverse Changes in Viability..............................................................................................11-1 FDA Action Levels or Tolerances.......................................................................................11-3 State-Imposed Consumption Limits ....................................................................................11-4 FACILITY REVIEW COMMENTS............................................................................................ Appendix A

ABBREVIATIONS AET Apparent effects threshold AWQC Ambient water quality criteria BOD Biological Oxygen Demand CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations ClCH Chlorinated hydrocarbons CPC Chloropivaloyl chloride CWA Clean Water Act D Dissolved DCB Dichlorobenzene DNT Dinitrotoluene DOI Department of the Interior EDC 1,2-Dichloroethane EQL Estimated quantitation limit EPA Environmental Protection Agency ER-M Effects Range-Median ER-L Effects Range-Low FCC Fluid cracking catalyst FDA Food and Drug Administration GPM Gallons per minute HCB Hexachlorobenzene HCBD Hexachlorobutadiene HCE Hexachloroethane I-10 U.S. Interstate 10 IPWMU In-plant waste management unit KCSRR Kansas City Southern Railroad l Liter LAB Linear Alkylbenzene Plant LAC Louisiana Administrative Code LCCC Lake Charles Chemical Complex LCCP Lake Charles Chemical Plant LDEQ Louisiana Department of Environmental Quality LDHH Louisiana Department of Health and Hospitals LOEL Lowest observed effect level LPA Low polynuclear-aromatic solvent MCB Monochlorobenzene MEK Methyl ethyl ketone mg Milligrams N Number of samples NA Not applicable NI Not investigated NH3N Ammonium nitride

A-2

ABBREVIATIONS (continued)

NOAA National Oceanic and Atmospheric Administration NPDES National Pollution Discharge Elimination System NRDA Natural Resource Damage Assessment PCBs Polychlorinated biphenyls PCE Pentachloroethane PDVSA Petroleo de Venezulea S.A. PEL Probable effects level Penta-CB Pentachlorobenzene Per Perchloroethylene PFU Propylene fractionation unit PPB Parts per billion PPM Parts per million PSQGs Provincial Sediment Quality Guidelines QA/QC Quality Assurance/Quality Control RCRA Resource Conservation and Recovery Act SQB Sediment quality benchmark SQC Sediment Quality Criteria SQL Sample Quantitation Limit SRU Sulfur recovery unit SVOCs Semivolatile organic compounds SWMU Solid waste management unit SWWTP Secondary waste water treatment plant TCB Trichlorobenzene TCCA Trichloroisocyanuric acid TCLP Toxicity Characteristic Leachate Procedure TDA Toluene diamine TDI Toluene diisocyanate TECB Tetrachlorobenzene TEL Threshold effects levels TOC Total organic carbon TPHs Total petroleum hydrocarbons TRC Total residual chlorine Tri Trichloroethylene TSS Total suspended solids U Unknown ug Micrograms USC United States Code VCM Vinyl chloride monomer VDC Vinylidene chloride VOCs Volatile organic compounds WBU Water bearing unit WTU Waste Treatment Unit

PREFACE The National Oceanic and Atmospheric Administration (NOAA) commissioned this report to evaluate existing chemical contamination data for the Calcasieu Estuary and determine whether the information indicates the potential for injury to the estuary's natural resources. NOAA plans to use the report to inform and guide decisions regarding the need for additional evaluations of potential injury to estuary resources. The report also will assist NOAA in determining whether a natural resource damage assessment (NRDA) should be initiated within the Calcasieu Estuary. The report focuses on chemical contamination in the estuary and the impacts of this contamination on natural resources. All readers should recognize, however, that the Calcasieu Estuary is located within a diversified watershed characterized by agricultural, municipal, industrial, and recreational uses. Because of these multiple uses, the estuary ecosystem is impacted by a wide range of physical, chemical, and biological stressors. Among these are agricultural runoff, erosion, stormwater drainage, and municipal wastewater. The estuary also is affected by septic system drainage, dredging, resource extraction, and industrial discharges. The impacts associated with all uses jointly influence the overall health of the estuary. This effort brings together several existing sources of Calcasieu Estuary contaminant data within a single, comparative framework. Although the underlying data were generated by different authors and for varying purposes, NOAA has determined that the data are of sufficient quality and form to support joint technical consideration as part of this preliminary investigation. To accommodate these multiple data sets, the report uses summary-level analytical methods. This includes dividing the estuary into segments and combining the relevant data from all sources into a profile for each area. Our approach relies on simple statistics such as ranges, means, and medians to characterize chemical concentrations within each segment. Accordingly, the approach is well-suited for the purposes of evaluating the general condition of estuary resources. One section of the report describes the activities of nine industrial facilities that operate within the estuary. Although these facilities are highlighted and discussed, they only represent a portion of the total number of facilities in the Calcasieu Estuary watershed. Similarly, the report focuses on industrial activities that have the potential to contaminate the estuary; however, many of the facilities within the estuary have taken actions to reduce releases to the environment. These efforts are designed to reduce the potential impacts of industrial activities on the estuary's natural resources. The preparation of this report does not, in itself, constitute the initiation of a NRDA. The report is not a preassessment as provided in 43 CFR 11, and it is not being used to establish the exact nature and extent of chemical contamination or to design restoration plans. The report does reference portions of the damage assessment regulations promulgated by the Department of the Interior (DOI) under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The DOI regulations are only used to frame discussions and generally

P-2

characterize the potential for natural resource injury within the estuary. NOAA's reference to these regulations in no way obligates the agency to follow the damage assessment guidelines established by DOI in this or any future estuary evaluation. If NOAA determines that a formal damage assessment is warranted, the agency will inform interested parties prior to the initiation of the NRDA. NOAA made a draft of this report available to all interested parties on September 12, 1996. In response to requests for the report, NOAA distributed the report to the interested public, natural resource trustees, industry, environmental groups, the news media, and the Calcasieu Estuary Task Force. The agency also invited comments and requested information regarding additional sources of estuary data. NOAA has reviewed the comments received and considered all issues identified by commentors in the preparation of this final report. Many of the comments are incorporated into the final report by reference. Other comments were beyond the scope of this preliminary effort but may be considered in any future estuary evaluations. Complete copies of all comments are maintained as a public record and are available to interested parties by contacting Mr. John Kern at:

NOAA Damage Assessment Center 9721 Executive Center Drive North

Koger Building, Suite 134 St. Petersburg, FL 33702

PART I

RESOURCE CHARACTERIZATION

1-1

RESOURCE CHARACTERIZATION INTRODUCTION AND SUMMARY CHAPTER 1 Part I (Chapters 1-6) characterizes the extent of chemical contamination within the Calcasieu Estuary. In conducting this resource characterization, we compiled data for each of the major areas of the estuary, including Bayou d'Inde, Bayou Verdine, and the Calcasieu River and Ship Channel. Within each of these areas, we reviewed the condition of the surface water, sediment, fish, and shellfish resources. The remainder of Chapter 1 provides a general overview of the Calcasieu Estuary and summarizes the principle findings and observations of our resource characterization. Chapter 1 concludes with a description of the organization of the resource characterization. Refer to Part III (Chapters 8-11) for a complete evaluation of the resource data with respect to potential natural resource injuries. OVERVIEW OF THE CALCASIEU ESTUARY The Calcasieu Estuary in southwest Louisiana is a humid subtropical woodland and wetland system characterized by intense industrial development. The primary hydrologic feature of the estuary is the Lower Calcasieu River and Ship Channel, which extends from the Gulf of Mexico to the saltwater barrier north of Lake Charles. Within the river and ship channel, principle components include Lake Charles, Prien Lake, Moss Lake, and Calcasieu Lake. Major tributaries to the system include Bayou d'Inde, Bayou Verdine, Contraband Bayou, and Choupique Bayou. These features are shown in Exhibit 1-1. Industrial development dominates much of the Calcasieu Estuary. Chemical manufacturing and petroleum refining companies first appeared in the Calcasieu during the early 1920s with the discovery of nearby petroleum and natural gas reserves. Access to water transportation provided further incentive for industrial development. From these early beginnings, the region's industrial base has continued to grow, and today the Calcasieu Estuary supports more than ten major petroleum refining and chemical manufacturing operations producing a wide range of industrial chemicals, petroleum products, and commercial feedstocks.

1-3

The Calcasieu Estuary appears to be impacted by industrial development. Facility discharges, storm water runoff, and accidental releases have contaminated the ground water and surface water in and around the industrial areas. Manufacturing activities also have contaminated sediments within Bayou d'Inde, Bayou Verdine, and the Calcasieu River. Further, fish and shellfish within the estuary contain many contaminants, prompting the state of Louisiana to issue consumption advisories for the Calcasieu Estuary. PRINCIPLE FINDINGS The resource characterization presents contamination data for the Calcasieu Estuary. The data can be used to evaluate the condition of the estuary, identify potential sources of contamination, and define contamination hot spots. The data also are useful to evaluate the likely contribution of the various industrial facilities. Several initial findings are summarized below. Condition of the Calcasieu Estuary Contamination from industrial development is apparent in the resources of the Calcasieu Estuary. Contaminant concentrations in sediment and surface water are highest in the areas of dense industrial activity: Bayou d'Inde, Bayou Verdine, and the Clooney Island, Coon Island, and Prien Lake portions of the Calcasieu River. Among the major industrial facilities discharging to the estuary PPG, Conoco, and Vista appear to contribute higher contamination burdens than the other firms. Increases in detection rates and the number of compounds detected are apparent near the Conoco and PPG outfalls. Similar patterns can be seen near the Vista facility. Cit-Con (operated and partially owned by Citgo), which discharges to Bayou d'Inde, also might be classified with these three dischargers; however, the facility's proximity to other firms obscures the relationship between increased contamination and specific firms. Fish and shellfish collected from the Calcasieu Estuary also carry chemical contamination. Three compounds, hexachlorobenzene, hexachlorobutadiene, and pentachlorobenzene, were measured in excess of 1 ppm in certain areas of the estuary, and as high as 11 ppm in one sample. Further, the Calcasieu Estuary fish data are consistent with the sediment and surface water results in that fish collected near the industrial areas are more contaminated than samples collected upstream near Lake Charles or downstream in Lake Calcasieu. The fish data show that out of the thirteen compounds analyzed, twelve were found at the highest concentration in Bayou d'Inde or the PPG Canal. Although fish tissue contamination was highest near the industrial area, the data also indicate that contamination is wide-spread throughout the estuary. Chemical contamination was evident in several species as far north as the salt water barrier and as far south as the Gulf of Mexico. These results are consistent with presumptions regarding fish mobility and

1-4

bioaccumulation. These results also suggest that the impacts of industrial pollution are wide-ranging within the estuary. Identifying Potential Sources of Contamination Bayou d'Inde Several compounds within Bayou d'Inde appear to be associated with PPG. These include hexachlorobenzene, hexachlorobutadiene, hexachlorocyclopentadiene, hexachloroethane, dichlorobenzene, trichloroethene, 1,2,4-trichlorobenzene, and vinyl chloride. These compounds were not detected in Bayou d'Inde reaches upstream of PPG, and each is a waste or product associated with PPG's chlorinated hydrocarbon manufacturing process. Specific compounds also can be associated with the Bayou d'Inde industrial complex, which contains Citgo/Cit-Con, Firestone, OxyChem, and Westlake. Compounds associated with this area include xylene, methylnaphthalene, and di-n-butylphthalate. Each of these compounds was detected near the industrial complex, but not upstream of the industrial area or in the PPG Canal further downstream. Bayou Verdine The majority of contamination in Bayou Verdine appears associated with two facilities: Vista and Conoco. At Vista, several contaminants were detected in the sediments or water. These include chloroethane, chloroform, 1,2-dichloroethane, vinyl chloride, fluoranthene, and phenanthrene. These compounds appear to enter the bayou through Vista's western discharge ditch. The other major contaminant input to Bayou Verdine occurs near Conoco. With the exception of chloroethane and vinyl chloride, the compounds found near Vista also were detected near Conoco. In addition, contaminants found in this portion of the bayou include several compounds that are not detected in upstream segments. These include xylene, tetrachloroethene, toluene, dibenzo(a,h)anthracene, dibenzo furan, naphthalene, bromoform, diesel, and gasoline. These compounds also are consistent with the wastes typically associated with Conoco's refinery processes. Moving beyond Bayou Verdine and into the Coon Island Loop of the Calcasieu River reveals many of the same contaminants identified near Conoco. PPG, however, also has known discharges to the Coon Island Loop.

1-5

Calcasieu River and Ship Channel Coon Island Loop and Prien Lake appear to be the most contaminated portions of the Calcasieu River and Ship Channel. Contamination in the Coon Island Loop is consistent with the compounds identified in Bayou Verdine and in PPG's solid waste management units and ground water. Inputs from upstream sources, including the Clooney Island Loop, do not appear to have a significant influence on Coon Island Loop contaminant concentrations. Prien Lake has openings directly across from Bayou d'Inde and the Coon Island Loop. Since we have not identified any major industrial outfalls within Prien Lake, it appears that contamination is entering from Bayou d'Inde and the Coon Island Loop. Further, the contaminants identified in Prien Lake are consistent with the compounds found in Coon Island Loop and Bayou d'Inde, especially those contaminants associated with PPG and Conoco. A detailed study of the area would be necessary, however, to provide a more definitive source determination for specific contaminants. Data Set Variability Our resource characterization contains data from eight independent studies of the Calcasieu Estuary. While reviewing these data, we noted differences among the analytical results of various contamination studies. Two particular patterns are described below. Study Dates The studies included in the resource characterization were conducted from 1987 to 1996, and while not directly comparable, may provide some insight into contamination trends over time. Our initial comparisons among the studies indicate that water column contamination may be decreasing. The studies that contain surface water data from 1987 and 1988 detected a greater number of contaminants than more recent studies. Differences in sample quantitation limits do not appear to strongly influence this result. Visual inspection of Calcasieu Estuary sediment data does not reveal decreasing contamination trends across time. Sample Location and Density In some cases, multiple studies collected samples from the same general location of the estuary. Although results across studies were generally consistent, several discrepancies were noted. These inconsistencies were noted especially in the Coon Island Loop and the Prien Lake areas of the Calcasieu River. Differences in sample location and density may explain these deviations.

1-6

In the Coon Island Loop, for example, one of the studies (ChemRisk 1994) collected 124 multi-depth sediment samples. Three other studies (RTI, PRC 1994, and ChemRisk 1995) collected far fewer samples in this same geographic area. The study with 124 samples detected 28 volatile and semivolatile organic compounds within the Coon Island Loop. The three other studies detected less than half as many. Since sediment contamination can be highly variable within an area, the density of sample collection may help explain the greater number of contaminants detected in the ChemRisk (1994) study. Within Prien Lake, the LDEQ study identified 19 different volatile organic compounds in ambient water. Downstream in Moss Lake, however, LDEQ detected 26 volatile compounds. These results indicate that Moss Lake could be considered slightly more contaminated than Prien Lake. Yet, other studies of these areas (RTI and ChemRisk 1995) indicate that Prien Lake surface waters may be more contaminated than Moss Lake. A preliminary review indicates that the location from which samples were collected may provide some insight into these seemingly contradictory results. The studies that found Prien Lake to be more contaminated collected one or more samples from areas directly adjacent to inflows from Bayou d'Inde and the Coon Island Loop. A visual review of sample stations, however, indicates that the LDEQ samples were collected at more isolated portions of Prien Lake. ORGANIZATION OF THE RESOURCE CHARACTERIZATION Part I compiles and reviews resource contamination data for the Calcasieu Estuary and includes detailed summaries of the estuary's surface water, sediment, fish, and shellfish. This resource characterization is presented in Chapters 2 through 6. Chapter 2 presents the methods used to review and combine water column and sediment data for the estuary. Sediment and water data for Bayou d'Inde, Bayou Verdine, and the Calcasieu River and Ship Channel are then reviewed independently in Chapters 3, 4, and 5. Contamination data for fish and shellfish are reviewed in Chapter 6.

2-1

RESOURCE CHARACTERIZATION METHODS CHAPTER 2 Chapter 2 presents the methods used to identify, assemble, and evaluate surface water and sediment contaminant data for Bayou d'Inde, Bayou Verdine, and the Calcasieu River and Ship Channel.1 The first part of this chapter briefly describes our estuary segmentation scheme. Next, we present annotated reviews of the surface water and sediment data sources and discuss the selection criteria for these studies. The third section of this chapter describes our data aggregation methods. Finally, Chapter 2 describes the resource characterization summary tables found in Chapters 3 through 5. STUDY AREA SEGMENTATION This report reviews sediment and water data for three major areas within the Calcasieu Estuary: Bayou d'Inde, Bayou Verdine, and the Calcasieu River and Ship Channel. These areas are further sub-divided into segments based on various geographic, hydrologic, and discharge characteristics. In particular, we defined segments that facilitate the identification and attribution of incremental chemical inputs to specific facilities or groups of facilities. As a result, we defined segment boundaries based on point source discharge locations, potential for drainage of untreated flood and storm water, and visual inspection of area and facility maps. Through this process, we defined a total of seventeen segments within the Calcasieu Estuary. Bayou d'Inde is divided into four segments. These include three bayou segments and the PPG Canal. Bayou Verdine contains seven segments. Four of these are within the main course of the bayou while three are ditches that drain into the system. The Calcasieu River and Ship Channel, which extends from Lake Charles to the Gulf of Mexico, includes six segments. The Calcasieu Estuary study area and segments are shown in Exhibit 2-1. Detailed descriptions of each segment are included in Chapters 3 through 5.

1 Analytical methods for the fish and shellfish characterization are discussed in Chapter 6.

2-3

OVERVIEW OF DATA SOURCES Eight data sets are summarized and reviewed within this report. These include: 1. Toxics Study of the Lower Calcasieu River. RTI, 1990; 2. Bayou d'Inde Expanded Site Inspection. PRC, 1993; 3. Site Inspection for Bayou Verdine. PRC, 1994; 4. Results of Preliminary Sediment and Surface Water Sampling and Analysis in

Bayou Verdine and Coon Island Loop of the Calcasieu River. ChemRisk, 1994; 5. Report to Characterize Sediments in the Upper PPG Effluent Canal. ITC, 1994; 6. Bayou d'Inde, Lower PPG Canal, and Calcasieu River and Ship Channel Water

and Sediment Sampling Report. ChemRisk, 1995; 7. Focused Site Assessment, Bayou d'Inde. U.S. EPA, 1996. 8. Ambient Water Data for the Calcasieu Estuary. Louisiana Department of

Environmental Quality (LDEQ), 1987-1995. Each of these studies was selected based on three criteria. First, each of the research programs had to follow clearly defined quality assurance and quality control (QA/QC) guidelines. Second, each study needed to analyze a wide range of contaminants. Finally, studies were selected so that their combined geographic coverage extended across the entire Calcasieu Estuary. Annotated bibliographies describing each study's purpose, sampling coverage, and sampling dates are provided below. The geographic range for each of the data sets is further detailed in Exhibit 2-2.

Exhibit 2-2

GEOGRAPHIC COVERAGE OF DATA SOURCES

Study-Defined Segments Covered

Study Bayou d'Inde Bayou Verdine Calcasieu River/SC

PRC (1993) 1-4 -- --

ChemRisk (1995) 1-4 -- 14-15

ITC 3 -- --

RTI 1-4 5,7,10,11 12-17

ChemRisk (1994) -- 10-11 14

PRC (1994) -- 5-11 14

EPA (1996) 4 -- 14,16

LDEQ 4 -- 12-17

2-4

Toxics Study of the Lower Calcasieu River. Research Triangle Institute, March 1990. Study Abbreviation: RTI The Toxics Study of the Lower Calcasieu River summarizes the results of a toxics study conducted by EPA Region 6, the Louisiana Department of Environmental Quality, and the U.S. Geological Survey. The study area included the Lower Calcasieu River, Bayou d'Inde, Bayou Verdine, Prien Lake, Lake Charles, Moss Lake, and Calcasieu Lake. The objectives of the study were to:

• evaluate EPA's chronic toxicity test methods for aquatic life in marine and estuarine systems;

• determine the occurrence and extent of chronic toxicity within the estuary;

• determine and document the occurrence of effluent toxicity by selected industrial

discharges;

• determine the type, concentration, and extent of contaminants in water and sediment within the study area; and

• compare measured toxicological effects with sediment contaminants.

Water and sediment samples were collected from 35 locations in the Calcasieu Estuary in June and July of 1988. Water samples were mid-channel, mid-depth grabs. Each sediment sample was a composite from a transect consisting of three grab samples (river locations) or three randomly spaced grabs from a five square meter area (lake locations). Grab samples also were taken from 15 waste water effluents from 10 different industrial facilities. Samples were tested for volatile and semivolatile organic compounds, PCBs, pesticides, inorganic elements, anions, and conventional chemical and physical parameters. Toxicity testing of effluent, water, and sediment samples was performed using six different bioassay species and methods. In April 1989, additional water and sediment samples were collected from one existing and three new stations in Bayou d'Inde. According to the text of the study, these 1989 samples only were tested for volatile organic compounds; however, the data indicate that analyses for other chemicals (e.g., PCBs and inorganic elements) also were performed. The study's sediment and water data are included in our review of Bayou d'Inde, Bayou Verdine, and multiple segments of the Calcasieu River and Ship Channel.

2-5

Bayou d'Inde Expanded Site Inspection -- Final Report. PRC Environmental Management, Inc., September 28, 1993. Study Abbreviation: PRC (1993) The Bayou d'Inde Expanded Site Inspection was prepared for EPA as part of the CERCLA Hazard Ranking System screening process. The objectives of this study were to document contamination in Bayou d'Inde and to build on previously collected data by further defining site waste characteristics, contaminant sources, and exposure pathways. PRC collected samples from November 30 through December 4, 1992. Thirty-nine sediment and five surface water samples were collected from 34 locations throughout Bayou d'Inde and its tributaries (including Little Bayou d'Inde and Maple Fork Creek), the PPG canal, Browning-Ferris Industries Outfall 001, Prien Lake, the Calcasieu River, and the Calcasieu Ship Channel. Sediment samples were collected from near-shore and dredged channel locations. Samples were analyzed for volatile and semivolatile organic compounds, PCBs, pesticides, and inorganic elements. Sediment used for the VOC analysis was taken as a grab from a discrete sample interval; the remaining sample interval was homogenized for the SVOC, PCB, pesticide, and inorganic analysis. The study's sediment and water data are included in our review of Bayou d'Inde. Site Inspection for Bayou Verdine -- Final Report. PRC Environmental Management, Inc., 1994. Study Abbreviation: PRC (1994) The Site Inspection for Bayou Verdine was prepared for EPA. This study's objective was to document the presence of hazardous substances in surface water and sediments from PPG's North Dock, a section of Coon Island Loop, and Bayou Verdine (including the Kansas City Southern Railroad West Ditch, the Vista West Ditch, and the Faubacher Ditch). A total of 27 sediment and 23 surface water samples were collected from 27 stations within the study area from July 19 through July 22, 1993. Sediment samples were collected from near-shore and center channel areas with dedicated aluminum push tubes. Sediment samples were analyzed for volatile and semivolatile organic compounds, PCBs, pesticides, and inorganic elements. Sediment used for the VOC analysis was taken as a grab from the discrete sample interval; the remaining sample interval was homogenized for the SVOC, PCB, pesticide, and inorganic analysis. Water samples were only analyzed for volatile organic compounds. The study's sediment and water data are included in our review of Bayou Verdine and the Coon Island Loop.

2-6

Results of Preliminary Sediment and Surface Water Sampling and Analysis in Bayou Verdine and Coon Island Loop of the Calcasieu River Ship Channel. McLaren/Hart Environmental Engineering, ChemRisk Division, August 23, 1994. Study Abbreviation: ChemRisk (1994) This study was prepared for PPG Industries, Inc. The study's objective was to characterize the nature and extent of chemical contamination in Coon Island Loop (including the PPG dock facilities) and a section of Bayou Verdine (from Interstate 10 to the Coon Island Loop). ChemRisk established 58 sampling stations within the study area. Twelve stations were located in Bayou Verdine; 16 were located in the PPG dock area and turning basin (including two transects); 18 stations (comprising six transects) were located in the west arm of Coon Island Loop; and 12 stations (including five transects) were located in the east arm and south end of Coon Island Loop. ChemRisk collected 33 water samples from 25 stations from October 1 to October 15, 1993. Bayou Verdine, dock area, turning basin, and east and southern Coon Island Loop locations (17 stations) were sampled at one depth, approximately two-thirds the depth of the water. Coon Island Loop locations from the western arm (eight stations) were collected from the center of the dredged ship channel at two depths. All samples were collected with a Van Dorn water sampler. ChemRisk collected multi-depth sediment borings from 58 different locations, comprising 141 sediment samples. The sediment samples were collected from October 18 to November 1, 1993, with additional samples collected from Bayou Verdine and the PPG dock facilities from February 2 to February 3, 1994. All locations sampled during the October-November period (46 stations) were collected at multiple depths ranging from four inches to nine feet. Bayou Verdine samples reached a maximum depth of two feet. Supplemental locations sampled during the February period (12 stations) were collected from Bayou Verdine and the PPG dock area in the 0-1 foot range. ChemRisk used a vibratory corer for the October-November samples, and a two inch split PVC sampler for the February collections. Water and sediment samples were analyzed for volatile and semivolatile organic compounds, total petroleum hydrocarbons (i.e., diesel and gasoline), PCB's, chlorinated pesticides, inorganic elements, anions, ammonia, and conventional physical and chemical parameters. A grain size analysis also was performed on the sediment samples. The study's sediment and water data are included in our review of Bayou Verdine (PPG Reach) and the Coon Island Loop. We included samples from all depths within the calculations of contaminant concentration ranges, means, and medians.

2-7

Report to Characterize Sediments in the Upper PPG Effluent Canal. International Technologies, Corp., September 26, 1994. Study Abbreviation: ITC The Report to Characterize Sediments in the PPG Canal was prepared for PPG Industries, Inc. The study area consisted of the Upper PPG Canal (also referred to as the isolated portion of the PPG Canal), including the levees and the North and South Closures. The objectives were to estimate the volume and boundaries of contaminated sediment; to identify the types, concentrations, and distributions of constituents in the sediments; and to determine the effect of possible migration of contaminants into or out of the canal. Multi-depth sediment borings were collected from 29 different locations and comprise 75 sediment samples. Transects consisting of three to five sample stations were spaced at 900 foot intervals throughout the isolated portion of the canal; additional sample stations were placed in the canal's center approximately half way between each transect. Sediment samples were collected with a vibratory corer (25 stations) unless access limitations required the use of a split-barrel PVC tube (four stations). Cores ranged in depth from four to eight feet. Most samples were collected between May 9 and May 20, 1994, while sampling at three locations was performed on April 20, 1994. Samples were tested for volatile and semivolatile organic compounds and inorganic elements. In addition to the sediment sampling, 58 soil and seven groundwater samples were taken from twelve locations within the levees of the canal. The study's sediment data are included in our review of Bayou d'Inde (PPG Canal). We included samples from all depths within the calculations of contaminant concentration ranges, means, and medians. Bayou d'Inde, Lower PPG Canal, and Calcasieu River Ship Channel Water and Sediment Sampling Report. McLaren/Hart Environmental Engineering, ChemRisk Division, June 30, 1995. Study Abbreviation: ChemRisk (1995) The ChemRisk Sediment Sampling Report was prepared for PPG Industries, Inc. The objective of the study was to assess sediment and water quality in Bayou d'Inde, the Lower PPG Canal, and a portion of the Calcasieu Ship Channel. ChemRisk designated 41 sampling locations throughout the study area. Eight of the sample stations were located in the PPG canal and adjacent wetlands. Seventeen sample stations were located in Bayou d'Inde; 12 of these were located in the center of the bayou's channel, while five stations were located in shallow areas outside of the dredged channel. Within the Calcasieu Ship Channel, ChemRisk spaced five transects at about 2,500 foot intervals. Each transect consisted of three to four sample stations that spanned the width of the river. A total of 16 sample stations were defined within the Calcasieu Ship Channel.

2-8

ChemRisk collected 39 water samples from 35 different locations between June 1 and June 6, 1994. At stations that exhibited salinity stratification (four locations), ChemRisk collected two samples; one at three feet above the sediment and one in the middle of the fresh water layer. At all non-stratified (i.e., uniform salinity) stations, ChemRisk collected one sample at two-thirds the depth of the water. All samples were collected using a Van Dorn water sampler. ChemRisk collected 123 sediment samples from three depths at 41 different locations between June 13 and June 24, 1994. At sample stations located within the main channel of Bayou d'Inde and the Calcasieu Ship Channel (i.e., 20 locations), ChemRisk collected five foot sediment cores. Within the PPG Canal and the shallow stations of the river and bayou (i.e., 21 locations), 10 foot cores were collected. All samples were collected using a 3.5 inch diameter vibratory corer. Water and sediment samples were tested for volatile and semivolatile organic compounds, PCBs, chlorinated pesticides, total petroleum hydrocarbons (i.e., gasoline and diesel), total and dissolved inorganic elements, ammonia, major anions, and conventional chemical and physical parameters. The study's sediment and water data are included in our review of Bayou d'Inde, the Calcasieu Ship Channel/Prien Lake, and the Coon Island Loop. We included samples from all depths within the calculations of contaminant concentration ranges, means, and medians. Focused Site Investigation, Bayou d'Inde. U.S. EPA, July 1996. Study Abbreviation: EPA (1996) The Bayou d'Inde Focused Site Investigation was conducted by Fluor Daniel, Inc. for the U.S. EPA (Region 6) as part of the CERCLA site investigation process. The sampling was initiated in response to a proposed dredging permit within the lower 1,000 feet of Bayou d'Inde. The purpose of the study was to determine the extent of contamination within lower Bayou d'Inde. Project definition, data quality objectives, and the sampling and analysis plan were designed based on instructions from U.S. EPA, the U.S. Army Corps of Engineers, the U.S. Fish and Wildlife Service, the National Oceanic and Atmospheric Administration, the Louisiana Department of Wildlife and Fisheries, and the Louisiana Department of Environmental Quality. The March 1996 sampling effort collected 19 surface water and 63 sediment samples. The 19 surface water samples were collected from the Calcasieu River and Ship Channel in direct proximity to Bayou d'Inde. Sample locations were established at the confluence of Bayou d'Inde and at 500, 1,000, and 5,000 feet upstream and downstream. At each station, a Kemmerer bottle type sampling apparatus was used to collect discrete grab samples from the surface and at near-bottom depth. Samples were analyzed for volatile and semivolatile organic compounds, inorganic elements, PCBs, and pesticides. Samples collected in direct proximity to

2-9

the bayou (i.e., "1,000 feet) were compiled within Bayou d'Inde segment 4. The four samples collected beyond this range (i.e., at "5,000 feet) were included in the water tables for Coon Island Loop (segment 14) and Moss Lake (segment 16). The 63 sediment samples were collected via vibratory coring from the lower 1,250 feet of Bayou d'Inde. Six sample transects were established beginning at the confluence of Bayou d'Inde and extending up Bayou d'Inde at 250 foot intervals. Each transect contained three sample locations: centerline and "35 feet laterally (north and south). Centerline stations were cored to an approximate depth of 20 feet and contained four sample intervals; the off-center stations were cored to an approximate depth of 12 feet and contained three sample intervals. Three additional samples were selected from these cores based on sediment composition and color. All samples were analyzed for volatile and semivolatile organic compounds, inorganic elements, PCBs, and pesticides. Five samples were analyzed for dioxins and 36 samples were selected for TCLP analysis. All sediment samples fall within Bayou d'Inde segment 4. We included samples from all depths within the calculations of contaminant concentration ranges, means, and medians. Louisiana Department of Environmental Quality, Calcasieu Estuary Water Sampling Program. 1987-1996. Study Abbreviation: LDEQ The Louisiana Department of Environmental Quality (LDEQ) has measured ambient water conditions in the Calcasieu Estuary on a monthly basis since 1987. LDEQ collects water samples from seventeen discrete sampling locations within the estuary. Stations range from the saltwater barrier near Lake Charles to the southern end of Calcasieu Lake, and include Bayou d'Inde, Prien Lake, and portions of the Calcasieu River and Ship Channel. Over the history of the program, LDEQ has collected more than 2,000 water samples. These samples are analyzed for volatile organic compounds and conventional parameters such as dissolved oxygen and salinity. LDEQ does not analyze the data for semivolatile organics, pesticides, PCBs, or inorganic elements. Since the LDEQ water data include more than eight years of monitoring information, they provide insight into the estuary's historical contamination trends. Other studies referenced in this report provide data for a single point in time. Similarly, LDEQ limits its analysis to volatile organic compounds, whereas other studies measure a wide range of chemical groups. Because of these differences, the LDEQ data are not directly comparable to the other studies considered. Consequently, the LDEQ data are reported in separate summary tables within each of the estuary segments. Our discussion, however, incorporates the LDEQ data when appropriate to highlight both spatial and temporal contamination trends.

2-10

Other Data Sources Several additional studies contain analytical chemistry data for the Calcasieu Estuary but were not included in this document. Individuals seeking additional information on the Calcasieu Estuary may wish to consult the bibliographic listing of these studies presented in Exhibit 2-3. While these studies provide valuable information regarding the Calcasieu Estuary, many duplicated the geographic sampling coverage of data sets that are included in the report. When more than one data set was available for a given area, we selected one study based on QA/QC documentation and date of sampling. Studies that did not focus their sampling efforts within this report's study area also were excluded.

Exhibit 2-3

CALCASIEU ESTUARY STUDIES NOT INCLUDED IN THE RESOURCE CHARACTERIZATION

Calcasieu River Sediment Removal Study. U.S. Army Corps of Engineers, May 1994. Chemical, Tissue, and Physical Data from Water and Bottom Material in the Lower Calcasieu River, Louisiana.

U.S. Geological Survey, 1972-1982. Ecosystem Analysis of the Calcasieu River/Lake Complex (CALECO), Final Report. McNeese State University,

June 26, 1987. Reconnaissance Study of Water and Bottom Material Quality in the Lower Calcasieu River, Southwestern Louisiana, May 29-30, 1985. U.S. Geological Survey, 1989. Sabine National Wildlife Refuge Contaminants Study, 1986-1988. U.S. Fish and Wildlife Service, October 1991. Sampling and Analysis of Sediment in the Coon Island Loop of the Calcasieu River. NUS Corporation, May

1988. South Terminal Offshore Sediment Sampling Report. IT Corporation, October 1995. Supplemental Report of Findings of Sediment and Water Sampling in the Original East-West Segment of the PPG Canal and Marshes Adjacent to the PPG Canal. NUS Corporation, May 1990.

DATA AGGREGATION METHODS The data exhibits in Chapters 3 through 5 summarize sediment and water data for the Calcasieu Estuary. The original data sources followed varying procedures for defining sample quantitation limits, reporting detected compounds, and establishing data qualifiers. This section describes the procedures used to reconcile differences between the studies and to compile the data into summary format.

2-11

Reportable Data -- Defining SQLs and EQLs The resource characterization data summaries report detected compounds; that is, compounds that exceed the sample quantitation limit (SQL) or estimated quantitation limit (EQL) defined for a given sample. Both SQLs and EQLs are matrix-dependent, providing the lowest quantity of a substance that can be reasonably quantified given sample characteristics and the limits of detection for the methods of analysis. Sample quantitation limits are applied in site investigation and hazard ranking to define the analytical significance of observed contamination; EQLs are defined under standard EPA testing procedures. Within the resource characterization we refer to both quantitation limits as sample quantitation limits or SQLs. Sample quantitation limits, however, were not reported consistently across studies. In some cases, studies provided a single SQL for each sample. Others reported limits for each compound within a sample. These reporting differences were especially important for the interpretation of estimated concentrations. As a result, we developed the following hierarchy to identify and compile reportable contaminant concentrations. Sample/compound specific SQLs. Sample/compound specific SQLs are unique to each

sample and compound. When these were provided, each compound's concentration was compared directly to the reported SQL. Concentrations exceeding this SQL were included in the data summaries. The ITC study reported SQLs using this protocol. PRC (1993) and PRC (1994) followed this convention for most compounds.

General SQLs. General SQLs provide a single sample quantitation limit for individual

compounds. General SQLs are constant for each compound and do not vary across samples. To identify reportable concentrations, each measurement was compared to the applicable general SQL. General SQLs tended to be very low, apparently representing the lowest SQL for a given compound. As a result, this approach was conservative since it included concentrations that might not have been considered detected had sample/compound specific SQLs been provided. ChemRisk (1994) and ChemRisk (1995) reported general SQLs.

Inferred SQLs. When SQLs were not available, sample quantitation limits were

inferred. Studies where this occurred provided specific SQLs for undetected compounds, but did not provide SQLs for detected or estimated values. Inferred SQLs were derived from non-detect data for each chemical group. A subset of the PRC (1993) and PRC (1994) data required inferred SQLs. SQLs for inorganics, however, could not be derived due to the large number of detections. As a result, all inorganics from PRC (1994) and PRC (1995) are reported in the data summaries.

The RTI and EPA (1996) studies reported only positive detections (i.e., validated and qualified data in excess of quantitation limits). As a result, it was not necessary to evaluate data in these reports with respect to SQLs or equivalent.

2-12

Data Qualifiers Each of the studies qualified concentration data because of sample-specific anomalies or laboratory exceptions. Qualifiers also were used to identify estimated values. Because qualifier identifiers varied across studies, we developed standard qualifiers for the aggregated data. The standard qualifiers used in this report, and the equivalent identifier in the original data sets, are provided in Exhibit 2-4. Note that while this report qualifies the data, the impacts of these qualifiers are not evaluated.

Exhibit 2-4

DATA QUALIFIERS IN SUMMARY TABLES

Qualifier in Summary

Tables

Description of Qualifier

Study

Qualifier in Original Study

A Analyte found in blank ChemRisk (1994) B

ChemRisk (1995) B

PRC (1994) B

C Unknown qualifier ChemRisk (1994) F

ITC (1994) *

ITC (1994) M

PRC (1993) B

D Compound identified at secondary dilution factor ChemRisk (1995) D

ITC (1994) D

PRC (1994) D

E Concentration exceeded calibration range of GC/MS instrument

ChemRisk (1994) E

ITC (1994) E

PRC (1993) D

J Value is estimated ChemRisk (1994) J

ChemRisk (1995) J

ITC (1994) J

PRC (1993) J

PRC (1994) J

EPA (1996) J

L Value estimated due to interference ITC (1994) E (in metals

2-13

Exhibit 2-4

DATA QUALIFIERS IN SUMMARY TABLES

Qualifier in Summary

Tables

Description of Qualifier

Study

Qualifier in Original Study

results)

N Spiked sample recovery not within control limits ChemRisk (1994) N

ITC (1994) N

PRC (1994) N (in metals results)

NI Compound not included in study --- ---

P Greater than a 25% difference for detected concentrations between GC columns

ChemRisk (1995) P

PRC (1993) P

PRC (1994) P

S Value determined by method of standard additions ChemRisk (1994) S

ITC (1994) S

W Post-digestions spike for Furnace AA analysis is out of control limits, while sample absorbance is less than 50% of spike absorbance.

ChemRisk (1994) W

ITC (1994) W

+ Correlation coefficient for the MSA is less than 0.995

ITC (1994) +

Surface Water and Sediment Data Tables Chapters 3 through 5 contain analytical data summaries for Bayou d'Inde, Bayou Verdine, and the Calcasieu River and Ship Channel, respectively. Within each chapter, data are summarized separately for surface water and sediment. These data are subdivided into the segments identified in Exhibit 2-1. Data are reported at two levels. Summary-level data present overall contaminant information for Bayou d'Inde, Bayou Verdine, and the Calcasieu River and Ship Channel. These summary exhibits compare contaminant trends across the segments. The summary-level exhibits aggregate the primary-level data (described below) by combining information from each study included in a given segment. These exhibits list detected compounds alphabetically by chemical

2-14

group. The number of samples, number of detections, and concentration ranges are provided for each compound. Measurements are in parts per million and sediment samples are based on wet weight.2 Primary-level data provide detailed water and sediment concentration information for each segment. Data from each applicable analytical study are presented. As a result, primary-level exhibits provide contaminant distributions within each estuary segment, and facilitate comparisons across studies, and to a limited extent, across time. Each primary-level exhibit identifies the area sampled (i.e., Bayou d'Inde, Bayou Verdine, or the Calcasieu River and Ship Channel) and the segment name and number. Compounds are listed alphabetically by chemical group. For each compound, primary-level exhibits report the number of samples and number of detections. Concentration ranges, means, and medians are provided for each detected compound. When studies contained multi-depth samples, each was treated as an independent observation (i.e., each is used in the calculation of the mean, median, and range). All concentration measurements are in parts per million and sediment samples are based on wet weight. Data qualifiers are also appended when applicable, with associated explanatory footnotes provided at the end of each exhibit. Note that qualifiers are applied to the entire data range when any of the data within that range are qualified. Since a given qualifier may apply to only one or a small portion of the samples in a range, the qualifiers only provide a general indication of data quality and should be interpreted with caution. LDEQ Ambient Water Data The LDEQ ambient water data are reported independently of the other studies. This is done because the LDEQ data contain more than 2,000 samples from nearly ten years of sampling. In addition, LDEQ limits data analysis to volatile organic compounds. Because of these attributes, direct comparisons with the other studies were not appropriate. As a result, we have compiled the LDEQ data separately and present independent exhibits and discussion of these results. Where appropriate, however, the report incorporates important trends in the LDEQ data into the main discussion. The LDEQ data exhibits follow the same reporting format as the primary-level data.

2 A wet weight measurement basis was used because two of the studies (RTI and ITC) did not provide dry weight results. This approach maximized the number of reliable data sets available for this review while maintaining the ability to make cross-study comparisons.

3-1

BAYOU D'INDE CHAPTER 3 Chapter 3 presents the water column and sediment resource characterization for Bayou d'Inde. We begin this chapter with an overview of Bayou d'Inde's physical setting and dimensions. Next, we describe the analytical framework for the bayou, including the segments used to compile the Bayou d'Inde data. We then review water column contamination within Bayou d'Inde. The chapter's discussion and data tables summarize water column contamination by bayou segment and data source. Following the water column discussion, we analyze sediment contamination. Like the discussion of the water column, the sediment section reviews contamination and presents data tables for each of the bayou's segments and data sources. OVERVIEW OF BAYOU D'INDE Bayou d'Inde is a tidally influenced, perennial wetlands bayou originating in the western sector of Sulphur, Louisiana and flowing east to the Calcasieu Ship Channel. From the Interstate 10 bridge in Sulphur to the bayou's mouth at the Calcasieu Ship Channel, Bayou d'Inde is approximately 7 miles long. This portion of Bayou d'Inde ranges from 80 to 150 feet wide and up to 16 feet deep. The area around Bayou d'Inde is characterized by intense industrial development intermingled with undeveloped wooded and marsh land. Industries with NPDES permits for outfalls to the bayou include Citgo Petroleum Corporation, OxyChem Corporation, Firestone Synthetic Rubber and Latex Company, Westlake Polymers Corporation, Browning-Ferris Industries, and PPG Industries (PPG). The main industrial discharge to Bayou d'Inde is the PPG Canal, which enters the bayou approximately one mile upstream of the Calcasieu Ship Channel. From the PPG facility, the canal flows approximately 1.5 miles to Bayou d'Inde. The canal, which is bordered by marsh, is 75 to 100 feet wide, 5 to 10 feet deep, and has steep sides and a sandy to muddy bottom.

3-2

The PPG Canal is located in the southeast corner of the PPG complex (referred to as the South Terminal) and is designated Solid Waste Management Unit 14 in PPG's hazardous waste permit. The canal conveys cooling water from the PPG power plants, process water from PPG's chemical manufacturing operations, and surface drainage. Certain-Teed Products, Big Three Industries, and Jupiter Chemical also discharge wastewater into the PPG Canal. The canal's total design flow is 233 million gallons per day. In 1994, PPG constructed a bypass to isolate a heavily impacted portion of the existing canal. The isolated portion is approximately 2,500 feet long and extends from just south of the PPG bridge to a point near the Interstate 210 bridge. BAYOU D'INDE SEGMENTING SCHEME We divide Bayou d'Inde into four segments: upstream, industrial area, PPG Canal, and Lower Bayou d'Inde. Each of these segments is described below and is shown in Exhibit 3-1.

• Upstream (Segment 1) -- The upstream segment is approximately 1.75 miles in length and includes all of Bayou d'Inde upstream of a point approximately 1/2 mile downstream of the confluence of Bayou d'Inde and Little Bayou d'Inde. The boundary is approximately 1/3 mile upstream of the western-most major outfall on Bayou d'Inde (Citgo 001). The upstream segment also includes tributaries to Bayou d'Inde such as Little Bayou d'Inde and the portion of Maple Fork Creek north of Interstate 10.

• Industrial Area (Segment 2) -- The industrial area is approximately four

miles in length, extending from the terminus of the upstream segment (1/3 mile upstream of Citgo outfall 001) to a point approximately 300 feet upstream of the PPG Canal. This segment also includes the mouth of Maple Fork Creek, south of Interstate 10. Citgo, Firestone, OxyChem, Westlake Polymers, and Browning Ferris Industries have outfalls to Bayou d'Inde in this segment.

• PPG Canal (Segment 3) -- The PPG Canal is 1.5 miles long, extending

from the PPG plant complex to Bayou d'Inde. The isolated portion of the PPG Canal also is included within this segment. Data collected from this portion after 1994, when the bypass was constructed, are discussed separately.

• Lower Bayou d'Inde (Segment 4) -- Lower Bayou d'Inde extends from

the terminus of the industrial area (300 feet upstream of the PPG Canal) to the confluence of Bayou d'Inde and the Calcasieu Ship Channel. This segment, which is approximately 1.3 miles in length, receives discharge from the PPG Canal.

3-4

SURFACE WATER DATA SUMMARY Surface waters in Bayou d'Inde are most heavily impacted by volatile organic compounds (VOCs). VOCs were particularly evident in the industrial area and Lower Bayou d'Inde, although some also were detected in the upstream segment and PPG Canal. Semivolatile organic compounds (SVOCs) were detected in each of the four segments, but generally were not as prevalent as VOCs. Polychlorinated biphenyls (PCBs) were only occasionally detected in Bayou d'Inde water samples, and none of the studies found any pesticides. Inorganics were widely distributed throughout Bayou d'Inde. The remainder of this section discusses the surface water data in more detail. Exhibit 3-2 lists the studies containing water data for Bayou d'Inde and shows the geographic coverage of each study. Note that EPA (1996) collected water samples in the Calcasieu Ship Channel near the mouth of Bayou d'Inde. Samples collected in direct proximity to the bayou (i.e., "1,000 feet) were compiled within Bayou d'Inde segment 4. EPA (1996) samples collected beyond this range were compiled in other segments (e.g., Coon Island Loop, Moss Lake). Exhibit 3-3 provides summary-level data, excluding the LDEQ data, which are discussed separately. Exhibits 3-4 to 3-8 show primary-level data for each segment. Volatile Organic Compounds (VOCs) Surface water data for VOCs were available from RTI, PRC (1993), ChemRisk (1995), and EPA (1996). In general, a greater number of VOCs were detected in water samples from the industrial area and Lower Bayou d'Inde than the upstream segment and PPG Canal. Many of these VOCs were detected in the earlier RTI study, but not in the later PRC (1993) and ChemRisk (1995) studies. EPA (1996) did not detect VOCs in surface water samples.

Exhibit 3-2

GEOGRAPHIC COVERAGE OF BAYOU D'INDE WATER STUDIES

Upstream

Industrial Area

PPG Canal

Lower Bayou d'Inde

RTI U U U U

PRC (1993) U U U

ChemRisk (1995) U U U U

EPA (1996) U

LDEQ U

3-5

Upstream Six VOCs were detected in water samples from the upstream segment. These VOCs were chloroform, 1,2-dichloroethane, 1,1,2,2-tetrachloroethane, tetrachloroethene, 1,1,1-trichloroethane, and trichloroethene. Tetrachloroethene was measured at the highest concentration of any VOC in the upstream segment (0.0045 ppm). Industrial Area Fourteen VOCs were detected in water samples from the industrial segment. Six of these compounds also were detected in the upstream segment and were measured within similar concentration ranges in both portions of the bayou. The remaining eight compounds were not detected upstream. These compounds were benzene, bromodichloromethane, bromoform, dibromochloromethane, methylene chloride, toluene, 1,1,2-trichloroethane, and xylene. Bromoform and chloroform were the two most frequently detected VOCs in the industrial area and also were measured at the highest concentrations. Bromoform was detected in 11 of 15 samples with concentrations ranging from 0.005 ppm to 0.073 ppm. Chloroform had concentrations from 0.002 ppm to 0.011 ppm in 8 of 15 samples. PPG Canal Four VOCs (bromoform, carbon disulfide, chloroform, and dibromochloromethane) were detected in water samples from the PPG Canal. Chloroform was the most frequently detected compound (6 of 9 samples, 0.006-0.009 ppm), while carbon disulfide was measured at the highest concentration (0.062 ppm). Lower Bayou d'Inde Thirteen VOCs were detected in Lower Bayou d'Inde, ten of which also were detected in the industrial area immediately upstream. These ten compounds were bromodichloroethane, bromoform, chloroform, dibromochloromethane, 1,2-dichloroethane, 1,1,2,2-tetrachloroethane, tetrachloroethene, 1,1,1-trichloroethane, 1,1,2-trichloroethane, and trichloroethene. All ten VOCs had higher mean concentrations in Lower Bayou d'Inde than in the industrial area. Bromoform, chloroform, and dibromochloromethane were the three most frequently detected VOCs in Lower Bayou d'Inde, and bromoform was measured at the highest concentration of any VOC (0.189 ppm).

3-6

Three VOCs (carbon disulfide, 1,2-dichloroethene, and vinyl chloride) were found in water samples from Lower Bayou d'Inde but not upstream. However, carbon disulfide also was detected in the PPG Canal, which discharges into Lower Bayou d'Inde. EPA (1996), which only sampled in Lower Bayou d'Inde and a portion of the Calcasieu River and Ship channel, did not detect any VOCs. LDEQ VOC Data LDEQ has collected water samples on a monthly basis from a single location in Lower Bayou d'Inde since 1987. These data are summarized in Exhibit 3-8. LDEQ has collected and analyzed 91 samples from this station, detecting a total of 26 different VOCs. Although some of the VOCs were found very infrequently, LDEQ detected 18 compounds in at least 10 percent of the 91 samples. Furthermore, eight compounds were detected in over 50 percent of the samples. These eight compounds include bromodichloromethane, bromoform, chloroform, 1,2-dichloroethane, 1,1,2,2-tetrachloroethane, tetrachloroethene, 1,1,1-trichloroethane, and trichloroethene. The two most frequently detected compounds were chloroform and 1,2-dichloroethane (79 percent and 77 percent of the samples, respectively). LDEQ measured concentrations for three VOCs at greater than 0.1 ppm. These VOCs include bromoform, chlorobenzene, and trans-1,3-dichloropropene. The maximum concentration measured for any of the compounds was 0.185 ppm for bromoform. Semivolatile Organic Compounds (SVOCs) Surface water data for SVOCs were available from RTI, PRC (1993), ChemRisk (1995), and EPA (1996). In general, relatively few SVOCs were detected in surface water from the bayou compared to the total number of SVOCs tested. Further, SVOCs found in the bayou were generally detected by RTI and not by the later PRC (1993), ChemRisk (1995), and EPA (1996) studies. Upstream In the upstream segment, only one SVOC (naphthalene) was detected. The concentration of naphthalene measured in the upstream segment was 0.005 ppm. Naphthalene also was detected in surface water from each of the other three segments of the Bayou d'Inde, including the PPG canal.

3-7

Industrial Area In the industrial area, four SVOCs, including naphthalene, were detected. Concentrations of naphthalene ranged from 0.005 ppm to 0.016 ppm. The remaining three detected compounds were bis(2-ethylhexyl)phthalate (0.006 ppm), nitrobenzene (0.011 ppm), and n-nitrosodiphenlyamine (0.019 ppm), none of which were detected upstream. PPG Canal Three SVOCs were detected in the PPG Canal. These compounds were diethyl phthalate (0.014 ppm), hexachlorobutadiene (0.009 ppm), and naphthalene (0.005 ppm). Diethyl phthalate was detected only in the canal, while hexachlorobutadiene and naphthalene also were found in Bayou d'Inde. Lower Bayou d'Inde Three SVOCs were detected in Lower Bayou d'Inde. These compounds were bis(2-ethylhexyl)phthalate (0.12-0.05 ppm), hexachlorobutadiene (0.003-0.008 ppm), and naphthalene (0.005 ppm). Hexachlorobutadiene was not detected upstream of Lower Bayou d'Inde, but was found in the PPG Canal, indicating possible inputs from the canal. Polychlorinated Biphenyls (PCBs) and Pesticides Surface water data for PCBs and pesticides were available from RTI, PRC (1993), ChemRisk (1995), and EPA (1996). Two Aroclor compounds (Aroclor-1242 and Aroclor-1254) were detected by the RTI study in the industrial area and in the PPG Canal. Each compound was detected in one of five RTI samples from the industrial area and in the only RTI sample from the canal. The highest concentration was measured at 0.0015 ppm for Aroclor-1254 in the canal sample. PCBs were not detected in Lower Bayou d'Inde, nor were PCBs detected in water by the later PRC (1993), ChemRisk (1995), and EPA (1996) studies. No pesticides were found in water samples from the bayou. Inorganic Elements The number of inorganic elements detected in water samples varied little among segments. Mercury, selenium, and thallium were among the numerous inorganic elements detected in Bayou d'Inde and the PPG Canal. Mercury was detected in one sample from the PPG Canal (0.00024 ppm), but was not found in any sample from the bayou. Selenium was detected in one sample from the upstream segment (0.001 ppm), but not in downstream segments or the PPG Canal.

3-8

Thallium was detected in 3 of 8 samples from the industrial area, 2 of 22 samples from Lower Bayou d'Inde, and 1 of 8 samples from the canal. The maximum concentration for thallium was measured at a concentration of 0.0465 ppm in Lower Bayou d'Inde. Thallium was not detected in either of two samples from the upstream segment.

3-9

SEDIMENT DATA SUMMARY VOCs and SVOCs were more prevalent in sediment samples from Lower Bayou d'Inde and the PPG Canal than from the upstream segment or industrial area of Bayou d'Inde. Further, significantly higher VOC and SVOC concentrations were detected in the PPG Canal than in other segments. PCBs were generally more prevalent and found at higher concentrations in the upstream and industrial areas than in Lower Bayou d'Inde or the PPG Canal. Although detected pesticides varied among segments, significantly more pesticides were detected in the PPG Canal than in other segments. Pesticide concentrations also were higher in the canal than in other segments. Inorganic elements were widely distributed throughout the bayou. The remainder of this section discusses the sediment data in more detail. Exhibit 3-9 lists the studies containing sediment data for Bayou d'Inde and shows the geographic coverage of each study. Data collected from the Upper PPG Canal after it was isolated are considered separately. Exhibit 3-10 provides summary-level data for Bayou d'Inde, and Exhibits 3-11 to 3-14 show primary-level data for each segment.

Exhibit 3-9

GEOGRAPHIC COVERAGE OF BAYOU D'INDE SEDIMENT STUDIES

Upstream

Industrial Area

PPG Canal

PPG Canal (Isolated Portion)

Lower Bayou d'Inde

RTI U U U U

PRC (1993) U U U U

ITC (1994) U

ChemRisk (1995) U U U U

EPA (1996) U

Volatile Organic Compounds (VOCs) Sediment data for VOCs were available from RTI, PRC (1993), ITC (1994), ChemRisk (1995), and EPA (1996). In general, sediment samples from the PPG Canal contained the greatest number of VOCs and had the highest concentrations. In the bayou, the prevalence of VOCs increased from the upstream segment to Lower Bayou d'Inde.

3-10

Upstream Acetone (0.033-0.16 ppm), 2-butanone (0.048 ppm), methylene chloride (270 ppm), and 1,1,1-trichloroethane (2.8 ppm) were detected in sediment samples from the upstream segment. All four compounds also were detected in downstream segments. Industrial Area Seven VOCs were detected in the industrial area, four of which were not found upstream. These four were carbon disulfide (0.005-0.008 ppm), chlorobenzene (0.03 ppm), 1,1,2,2-tetrachloroethane (1.7 ppm), and xylene (0.045-0.133 ppm). Of these compounds, carbon disulfide was the most frequently detected (4 of 39 samples). Xylene was detected in the industrial area and in Lower Bayou d'Inde, but not in the PPG Canal. The three VOCs also detected in the upstream segment were acetone, methylene chloride, and 1,1,1-trichloroethane. PPG Canal More VOCs (16) were detected in the PPG Canal than in any other segment, and several of the compounds were measured at high concentrations. Ten of the 16 compounds were detected at concentrations greater than 1 ppm. Further, concentrations of four VOCs (1,1,2,2-tetrachloroethane, tetrachloroethene, 1,1,1-trichloroethane, and trichloroethene) exceeded 1,000 ppm. Chlorobenzene and tetrachloroethene were the most frequently detected compounds (8 of 31 samples and 7 of 31 samples, respectively). These results include samples from the Upper PPG Canal before that portion of the canal was isolated. PPG Canal (Isolated Portion) ITC collected samples from the Upper PPG Canal after the bypass was constructed in 1994. ITC detected 15 VOCs in the isolated portion of the canal, all of which were measured at concentrations greater than 1 ppm, up to a maximum concentration of 8,900 ppm for tetrachloroethene. The compounds detected in the isolated portion are generally the same as those detected by RTI, PRC (1994), and ChemRisk (1995), which collected samples from throughout the canal before the construction of the bypass. Many of these compounds were detected at higher concentrations and in a greater percentage of the samples in the isolated portion than in the canal as a whole, indicating that the isolated portion is particularly heavily impacted by VOCs.

3-11

Lower Bayou d'Inde EPA (1996) detected more VOCs (7) than any other study within Lower Bayou d'Inde. Across studies a total of twelve VOCs were detected in Lower Bayou d'Inde. These compounds were acetone, benzene, 2-butanone, carbon disulfide, chlorobenzene, 1,2-dichloroethane, 1,2-dichloroethene, methylene chloride, tetrachloroethene, toluene, 1,1,1-trichloroethane, and xylene. Four of these compounds (1,2-dichloroethane, 1,2-dichloroethene, tetrachloroethene, and toluene) were not found upstream of Lower Bayou d'Inde, but all four were detected in the PPG Canal. Benzene was detected in one sample from Lower Bayou d'Inde and was not detected in any other area of the bayou. Of the seven VOCs also detected upstream, chlorobenzene, and 1,1,1-trichloroethane were detected with significantly greater frequency or at much higher concentrations in Lower Bayou d'Inde. Chlorobenzene was detected in 28 of 102 samples (0.006-0.55 ppm) in Lower Bayou d'Inde compared to only 1 of 39 samples from the industrial area (0.03 ppm). Furthermore, 1,1,1-trichloroethane was measured at 4.4 ppm and 4.9 ppm in Lower Bayou d'Inde compared to 0.43 ppm and 0.7 ppm in the industrial area. Both compounds were prevalent in the PPG Canal, further indicating possible contaminant inputs from the canal. Semivolatile Organic Compounds (SVOCs) Sediment data for SVOCs were available from the RTI, PRC (1993), ITC (1994), ChemRisk (1995), and EPA (1996) studies. In general, SVOCs were detected more frequently and at greater concentrations in Lower Bayou d'Inde and the PPG Canal than in the upstream segment or industrial area. Upstream Segment Bis(2-ethylhexyl)phthalate was the only SVOC detected in the upstream segment (0.44-2.6 ppm). Bis(2-ethylhexyl)phthalate also was detected in the other three Bayou d'Inde segments, including the PPG Canal. Industrial Area Bis(2-ethylhexyl)phthalate (0.8 ppm), chrysene (0.39 ppm), di-n-butylphthalate (0.019 ppm), 2-methylnaphthalene (0.34-12.4 ppm), naphthalene (0.98 ppm), phenanthrene (0.47-15.9 ppm), and pyrene (0.33-0.57 ppm) were detected in the industrial area. Only bis(2-ethylhexyl)phthalate was detected upstream.

3-12

PPG Canal Twenty-one SVOCs were detected in the PPG Canal, many of which were measured at high concentrations. Twelve of the 21 compounds were measured at concentrations greater than 10 ppm, and concentrations of eight SVOCs (1,2-dichlorobenzene, 1,3-dichlorobenzene, 1,4-dichlorobenzene, hexachlorobenzene, hexachlorobutadiene, hexachlorocyclopentadiene, hexachloroethane, and 1,2,4-trichlorobenzene) exceeded 100 ppm. Concentrations in the parts per thousand were measured for hexachlorobenzene (1.25-3,900 ppm), hexachlorobutadiene (0.69-53,000 ppm), hexachloroethane (0.71-3,500 ppm), and 1,2,4-trichlorobenzene (0.43-2,800 ppm). Hexachlorobenzene and hexachlorobutadiene were also the most prevalent SVOCs in the canal, detected in more than 40 percent of the samples. These results include samples from the Upper PPG Canal before that portion of the canal was isolated. PPG Canal (Isolated Portion) ITC collected samples from the isolated portion of the canal after the bypass was constructed in 1994. Results from these samples are similar to results from RTI, PRC (1994), and ChemRisk (1995), which collected samples from throughout the canal before the construction of the bypass. Eleven SVOCs were detected in the isolated portion, and six were measured at concentrations greater than 100 ppm. Concentrations for hexachlorobenzene, hexachlorobutadiene, and hexachloroethane exceeded 1,000 ppm and ranged as high as 48,000 ppm. Hexachlorobutadiene was the most prevalent compound, detected in more than 75 percent of the samples, and hexachlorobenzene and 1,2,4-trichlorobenzene were detected in more than 20 percent of the samples. Lower Bayou d'Inde Significantly more SVOCs were detected in Lower Bayou d'Inde (26) than in the industrial area immediately upstream (7). Eleven of the 26 compounds were not detected upstream of Lower Bayou d'Inde, but were detected in the PPG Canal, indicating possible inputs from the canal. These 11 compounds were benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, 1,2-dichlorobenzene, 1,3-dichlorobenzene, 1,4-dichlorobenzene, fluoranthene, fluorene, hexachlorobenzene, hexachlorobutadiene, and 1,2,4-trichlorobenzene. Eight additional compounds were not detected upstream of Lower Bayou d'Inde or in the PPG canal. These eight were acenaphthene, anthracene, benzo(g,h,i)perylene, benzo(k)fluoranthene, dibenzo(a,h)anthracene, carbazole, indeno(1,2,3-cd)pyrene, and isophorone. Finally, the remaining seven SVOCs detected in Lower Bayou d'Inde also were found in the industrial area upstream. Of these compounds, bis(2-ethylhexyl)phthalate, chrysene, naphthalene, phenanthrene, and pyrene were found in the PPG canal as well.

3-13

1,3-Dichlorobenzene, hexachlorobenzene, and hexachlorobutadiene were the three most frequently detected compounds in sediment samples from Lower Bayou d'Inde, and hexachlorobenzene and hexachlorobutadiene were measured at the highest concentrations (264 ppm and 77 ppm, respectively). EPA (1996) detected more SVOCs (21) than any other study within Lower Bayou d'Inde. Total Petroleum Hydrocarbons (TPHs) Sediment data for TPHs were available only from ChemRisk (1995). Diesel and gasoline were not detected in the upstream segment, but were found in the industrial area, PPG Canal, and Lower Bayou d'Inde. Both were detected slightly more frequently in the industrial area than in the PPG Canal or Lower Bayou d'Inde. However, concentrations of diesel and gasoline were highest in the canal and were slightly higher in Lower Bayou d'Inde than in the industrial area, indicating possible inputs from the canal. Polychlorinated Biphenyls (PCBs) Sediment data for PCBs were available from RTI, PRC (1993), ChemRisk (1995), and EPA (1996). In general PCBs were detected more frequently and at higher concentrations in the upstream and industrial segments than in Lower Bayou d'Inde or the PPG Canal. Upstream Aroclors 1248, 1254, and 1260 were detected in the upstream segment. Each was detected in 10 to 15 percent of the samples, with Aroclor-1254 exhibiting the highest concentration (1.71 ppm). Industrial Area In the industrial area, Aroclors 1242, 1254, and 1260 were detected. Aroclor-1242 (0.07-2.15 ppm in 3 of 39 samples) was not detected upstream of the industrial area, and Aroclor-1254 (4.73 ppm) had a significantly higher frequency of detection in the industrial area (16 of 39 samples) than upstream (3 of 21 samples). Aroclor-1260 was detected in two samples from the industrial area with concentrations of 0.08 ppm and 2.7 ppm. PPG Canal No PCBs were detected in sediment samples from the PPG Canal.

3-14

Lower Bayou d'Inde In one sample ChemRisk (1995) detected every Aroclor tested, and concentrations for all of the Aroclors were measured at the quantitation limit, indicating a possible reporting error. Only Aroclor-1254 was detected in another study; EPA (1996) detected Aroclor 1254 in 6 of 64 samples (0.053-0.195 ppm). Pesticides Sediment data for pesticides were available from RTI, PRC (1993), ChemRisk (1995), and EPA (1996). In general, pesticides were more prevalent in the PPG Canal and Lower Bayou d'Inde than in the upstream segment or industrial area. Upstream Six pesticides were detected in the upstream segment. These compounds were delta-BHC (0.0017-0.0025 ppm), alpha-chlordane (0.003 ppm), gamma-chlordane (0.0024-0.0027 ppm), 4,4'-DDD (0.004-0.008 ppm), 4,4'-DDE (0.0106-0.0108 ppm), and dieldrin (0.017 ppm). Gamma-chlordane, delta-BHC, 4,4'-DDD, and 4,4'-DDE were detected in the highest proportion of samples (2 of 21 samples each). Industrial Area Five pesticides were detected in the industrial area, including gamma-BHC (0.0019 ppm), 4,4'-DDT (0.039 ppm), dieldrin (0.081 ppm), endrin (0.027-0.29 ppm), and toxaphene (5 ppm). Only endrin was detected in more than one sample (2 of 39), and dieldrin was the only pesticide detected upstream. PPG Canal Sixteen pesticides were detected in the PPG Canal. Eight of the sixteen were detected in more than one sample, and the most frequently detected compound was alpha-chlordane (5 of 31 samples). Nine of the sixteen pesticides were measured at concentrations greater than one part per million. These nine were, aldrin (0.034-1.72 ppm), alpha-BHC (6.37 ppm), delta-BHC (0.07-2.89 ppm), gamma-BHC (4.02 ppm), alpha-chlordane (0.038-2.59 ppm), 4,4'-DDD (7.84 ppm), dieldrin (0.019-4.31 ppm), endosulfan sulfate (3.58 ppm), and toxaphene (50 ppm). Exhibit 3-13 shows pesticides generally were detected in the canal only by the PRC (1993) study. RTI only detected one pesticide (toxaphene), and ChemRisk (1995) did not find any pesticides in 24 samples from the canal.

3-15

Lower Bayou d'Inde In one sample ChemRisk (1995) detected every pesticide tested, and concentrations for all of the pesticides were measured at the quantitation limit, indicating a possible reporting error. Only aldrin, beta-BHC, alpha-chlordane, gamma-chlordane, 4,4'-DDT, endosulfan II, and heptachlor were detected in other sediment samples from Lower Bayou d'Inde. Of these seven compounds, three (aldrin, endosulfan II, and heptachlor) were not detected upstream of Lower Bayou d'Inde, but were found in the PPG Canal. All three were detected in at least 4 of 102 samples. Three of the seven compounds (4,4'-DDT, alpha-chlordane, and gamma-chlordane) also were found upstream of Lower Bayou d'Inde. 4,4'-DDT (0.0033-0.93 ppm), was found at the same frequency in Lower Bayou d'Inde (3 of 95 samples) as in the industrial area (1 of 29 samples), but was not detected in the PPG Canal. Alpha-chlordane and gamma chlordane were not detected in the industrial area but were found further upstream. Both compounds were found in the PPG Canal, again indicating possible inputs from the canal. Beta-BHC was detected in 5 of 102 samples in Lower Bayou d'Inde (0.0017-0.1 ppm), but was not detected upstream or in the PPG Canal. Inorganic Elements Inorganic elements generally were evenly distributed throughout Bayou d'Inde sediments, and mercury, arsenic, beryllium, and selenium were among the numerous inorganics detected. Mercury was found throughout Bayou d'Inde with mean concentrations generally increasing from the upstream segment down through Lower Bayou d'Inde. Mercury was detected in 10 of 21 samples in the upstream segment (0.1-1.1 ppm), 24 of 39 samples from the industrial area (0.08-10.6 ppm), and 46 of 102 samples from Lower Bayou d'Inde (0.003-19.5 ppm). Mercury also was prevalent in the PPG canal. RTI, PRC (1994), and ChemRisk (1995) detected mercury in 13 of 31 samples from the canal before the bypass was constructed (0.19-2.7 ppm), and ITC (1994) found mercury in 32 of 75 samples from the isolated portion of the canal (0.11-5 ppm). The highest mercury reading (19.5 ppm) was measured in Lower Bayou d'Inde by the EPA (1996) study. Arsenic, beryllium, and selenium also were detected throughout Bayou d'Inde. The detection frequencies and concentration ranges for arsenic did not vary significantly between segments, and the maximum arsenic concentration measured 8.87 ppm in the PPG Canal (EPA (1996)). Beryllium was detected most frequently in the upstream segment (8 of 21 samples), but the range of beryllium concentrations did not vary significantly between reaches. The maximum concentration of beryllium was measured at 2 ppm in Lower Bayou d'Inde.

3-16

Selenium was detected most frequently in the upstream segment (7 of 21 samples) and Lower Bayou d'Inde (27 of 102 samples). The maximum concentration of selenium measured 2 ppm in the upstream segment, but the range of concentrations did not vary significantly between segments.

4-1

BAYOU VERDINE CHAPTER 4 Chapter 4 presents the water column and sediment resource characterization for Bayou Verdine. We begin this chapter with an overview of Bayou Verdine's physical setting and dimensions. Next, we describe the analytical framework for the bayou, including the segments used to compile the Bayou Verdine data. We then review water column contamination within Bayou Verdine. The chapter's discussion and data tables summarize water column contamination by bayou segment and data source. Following the water column discussion, we analyze sediment contamination. Like the discussion of the water column, the sediment section reviews contamination and presents data tables for each of the bayou's segments and data sources. OVERVIEW OF BAYOU VERDINE Bayou Verdine is a wetland bayou located southwest of the city of Westlake and north to northwest of the city of Lake Charles in Calcasieu Parish, Louisiana. The bayou's headwaters originate in the farmland areas north of Mossville, Louisiana, and it generally flows southeast before entering the Calcasieu River at the northern tip of the Coon Island Loop. Bayou Verdine is approximately three to eight feet deep and has an estimated average rate of flow of approximately eight cubic feet per second in its southern reaches. It is the only major tributary to Coon Island Loop. The area around Bayou Verdine is characterized by mixed residential, commercial, and heavy industrial use, although industry predominates in the southern section of the bayou. Industries permitted to discharge wastewater into the bayou include CONDEA Vista Company (Vista); Conoco, Incorporated (Conoco); and PPG Industries (PPG). In the 1950s Bayou Verdine south of Interstate 10 was rerouted when Olin Corporation built the West Pond over the original bayou channel. The former route of Bayou Verdine downstream of Interstate 10 was to the east of its present course and emptied into Coon Island Loop near its present mouth.

4-2

In addition to water and sediment samples taken from Bayou Verdine, this chapter also presents data from three drainage ditches that carry discharges from Vista and Conoco to the bayou. The Vista West Ditch is the furthest upstream of the three ditches. It passes through the Vista and Conoco properties and discharges into the bayou near Trousdale Road. The Faubacher Ditch passes through the Vista and Conoco properties east of the Vista West Ditch. It begins in a residential area east of the Conoco plant boundary and flows west through Conoco's land treatment area and Vista's Lake Charles Chemical Plant. It then turns south and flows into Bayou Verdine at the Conoco refinery, north of the Kansas City Southern Railroad (KCSRR). The KCSRR West Ditch runs along the KCSRR tracks and discharges into the bayou where the railroad crosses the water, south of the mouth of the Faubacher Ditch. Conoco Outfall 004 discharges into the KCSRR West Ditch. BAYOU VERDINE SEGMENTING SCHEME We divide Bayou Verdine into seven segments: upstream, Vista West Ditch, Trousdale reach, Faubacher Ditch, KCSRR West Ditch, Interstate 10 reach, and Lower Bayou Verdine. Each of these segments is described below and is shown in Exhibit 4-1. In the discussions of sediment and water data we refer to segments 5, 7, 10, and 11 as bayou segments (i.e., they make up the main course of the bayou). We refer to segments 6, 8, and 9 as ditch segments.

• Upstream (Segment 5) -- The upstream segment encompasses all of Bayou Verdine upstream of a point approximately 300 feet upstream of Trousdale Road, near Conoco. Segment 5 is approximately 2 miles in length.

• Vista West Ditch (Segment 6) -- This segment encompasses the entire

Vista West Ditch, terminating at the ditch's mouth at Bayou Verdine. The Vista West Ditch is approximately 1 mile in length.

• Trousdale Reach (Segment 7) -- The Trousdale reach is two-thirds of a

mile long and extends from the terminus of the upstream segment (300 feet upstream of Trousdale Road) to a point approximately 100 feet upstream of where the Faubacher Ditch enters Bayou Verdine. This segment receives discharge from the Vista West Ditch.

• Faubacher Ditch (Segment 8) -- This segment is just over one mile long

and encompasses the entire Faubacher Ditch from the ditch's origin upstream of the Conoco property boundary to Bayou Verdine.

4-4

• KCSRR West Ditch (Segment 9) -- The 1.5 mile KCSRR West Ditch

extends from the Conoco property boundary to the ditch's confluence with Bayou Verdine.

• Interstate 10 Reach (Segment 10) -- The Interstate 10 (I-10) reach

extends from the terminus of the Trousdale reach (100 feet upstream of where Faubacher Ditch flows into Bayou Verdine) to the northwest corner of the Olin Tailings Pile. This segment receives discharge from the Faubacher and KCSRR West Ditches. The I-10 reach is three-quarters of a mile in length.

• Lower Bayou Verdine (Segment 11) -- Lower Bayou Verdine extends

from the terminus of the I-10 reach at the northwest corner of the Olin Tailings Pile to the mouth of Bayou Verdine at the northern point of the PPG dock facilities in Coon Island Loop. Lower Bayou Verdine is just over one-half mile in length.

4-5

SURFACE WATER DATA SUMMARY Relatively few VOCs and SVOCs were detected in surface water samples from Bayou Verdine. The SVOCs detected generally were evenly distributed throughout the bayou, and VOCs were slightly more prevalent in the I-10 reach and Lower Bayou Verdine than in the upstream and Trousdale segments. Inorganic elements were distributed throughout the bayou, although slightly more inorganics were detected in the I-10 reach and Lower Bayou Verdine than in the upstream and Trousdale segments. No TPHs, PCBs or pesticides were detected in water samples from Bayou Verdine. The remainder of this section discusses the surface water data in greater detail. Exhibit 4-2 lists the studies containing water data for Bayou Verdine and shows the geographic coverage of each study. None of the studies collected water samples from the KCSRR West Ditch. Exhibit 4-3 provides summary-level data for Bayou Verdine, and Exhibits 4-4 to 4-9 provide primarily-level data for each segment.

Exhibit 4-2

GEOGRAPHIC COVERAGE OF BAYOU VERDINE WATER STUDIES

Upstream

Vista West Ditch

Trousdale Reach

Faubacher Ditch

KCSRR West Ditch

I-10 Reach

Lower Bayou

Verdine

RTI U U U U

PRC (1994) U U U U U U

ChemRisk (1994) U U

Volatile Organic Compounds (VOCs) Surface water data for VOCs were available from RTI, PRC (1994), and ChemRisk (1994). In general, relatively few VOCs were detected in water samples from Bayou Verdine. Upstream 1,2-Dichloroethane (0.124-0.14 ppm), 1,1,2-trichloroethane (0.01 ppm), and vinyl chloride (0.003 ppm) were detected in water samples from the upstream segment. Vinyl chloride was not detected in any other segment of Bayou Verdine. 1,2-Dichloroethane was found throughout the bayou but was measured at the highest concentrations in the upstream segment. In addition, 1,2-Dichloroethane was detected in Coon Island Loop and was measured at concentrations up to 0.14 ppm in the loop.

4-6

1,1,2-Trichloroethane also was found throughout the bayou. 1,1,2-Trichloroethane concentrations were highest in the upstream segment and Trousdale reach. Vista West Ditch 1,2-Dichloroethane was the only VOC detected in the Vista West Ditch. It was detected in both samples from the ditch, but concentrations were lower than in the Trousdale reach downstream. Trousdale Reach Chloroform (0.001 ppm), 1,2-dichloroethane (0.053-0.063 ppm), and 1,1,2-trichloroethane (0.005-0.012 ppm) were detected in the Trousdale reach. Concentrations of 1,2-dichloroethane were lower than in the upstream segment, but higher than in the Vista West Ditch. 1,1,2-Trichloroethane concentrations in the Trousdale reach were similar to the upstream segment. Chloroform was not detected upstream or in the Vista West Ditch. Faubacher Ditch No VOCs were detected in the three water samples collected from the Faubacher Ditch. Interstate 10 Reach Bromoform (0.004-0.008 ppm), chloroform (0.001 ppm), 1,2-dichloroethane (0.019-0.053 ppm), and 1,1,2-trichloroethane (0.0022 ppm) were detected in the I-10 reach. Bromoform was found in 4 of 9 samples from the I-10 reach, but was not detected upstream or in the Faubacher Ditch. The remaining three compounds were all detected upstream of the I-10 reach. 1,2-Dichloroethane was found in all nine water samples collected in the I-10 reach, but concentrations in the samples were lower than in upstream segments. 1,1,2-Trichloroethane concentrations were also measured at lower concentrations than in either upstream segment, and chloroform concentrations were similar in the I-10 and Trousdale reaches

4-7

Lower Bayou Verdine Six VOCs were detected in Lower Bayou Verdine. These compounds were bromoform (0.007-0.033 ppm), 2-butanone (0.028 ppm), dibromochloromethane (0.002 ppm), 1,1-dichloroethane (0.027 ppm), 1,2-dichloroethane (0.013-0.042 ppm), and 1,1,2-trichloroethane (0.001 ppm). Of these six, 2-butanone, dibromochloromethane, and 1,1-dichloroethane were not detected upstream of Lower Bayou Verdine. Within Lower Bayou Verdine, bromoform and 1,2-dichloroethane were the most frequently detected VOCs (3 of 9 and 7 of 9 samples, respectively), and concentration ranges of each were similar to the I-10 reach immediately upstream. 1,1,2-Trichloroethane was detected less frequently (1 of 9 samples) and at a lower concentration (0.001 ppm) in Lower Bayou Verdine compared to the upstream segments. LDEQ VOC Data LDEQ did not collect water samples from Bayou Verdine. Semivolatile Organic Compounds (SVOCs) Surface water data for SVOCs were available from RTI and ChemRisk (1994). No data were available for SVOCs from any of the three drainage ditches. In general, relatively few SVOCs were detected in water samples from Bayou Verdine compared to the total number of SVOCs tested. Upstream Diethyl phthalate (0.4 ppm) and phenol (0.007 ppm) were detected in the single water sample from the upstream segment. Trousdale Reach Acenaphthylene (0.36 ppm), anthracene (1.3 ppm), and phenol (0.016 ppm) were detected in the single water sample from the Trousdale reach. Only phenol was detected upstream, and the phenol concentration measured in the Trousdale reach was greater than in the upstream segment.

4-8

Interstate 10 Reach Four VOCs (anthracene, bis(2-ethylhexyl)phthalate, phenol, and pyrene) were detected in the I-10 reach. Two of these compounds, pyrene (0.003-13.7 ppm) and bis(2-ethylhexyl)phthalate (0.069 ppm) were not detected in the upstream segments. Anthracene (0.73-0.79 ppm) and phenol (0.011-0.013 ppm) both were detected upstream, and concentrations of these compounds were similar to or below upstream measurements. Lower Bayou Verdine Diethyl phthalate (0.44 ppm), phenol (0.003 ppm), and pyrene (2.64 ppm) were detected in water samples from Lower Bayou Verdine. Phenol and Pyrene also were detected in the I-10 reach immediately upstream. Phenol concentrations were lower than in the I-10 and Trousdale reaches, and pyrene was within the same concentration range as the I-10 reach. Diethyl phthalate was detected in the upstream segment but not in the Trousdale or I-10 reaches. Inorganic Elements Surface water data for inorganic elements were available from the RTI and ChemRisk (1994) studies. In general inorganics were distributed throughout Bayou Verdine. Arsenic was among the inorganic elements detected, but beryllium, mercury, thallium, and selenium were not found in Bayou Verdine. Arsenic was detected in water samples from each of the four segments of the bayou itself. The maximum concentration of arsenic was measured at 0.004 ppm in the only sample from the Trousdale reach. Exhibits 4-8 and 4-9 show that although arsenic was identified in water samples from the RTI study, ChemRisk (1994) did not detect arsenic in any of six samples from the bayou.

4-9

SEDIMENT DATA SUMMARY VOCs and SVOCs were detected more frequently in the I-10 reach and Lower Bayou Verdine than in the upstream and Trousdale segments. Further, many of the SVOCs detected in sediment samples from the I-10 reach and Lower Bayou Verdine were measured at high concentrations. Diesel and gasoline were only tested for in the I-10 reach and Lower Bayou Verdine. Concentrations of diesel and gasoline were greater in the I-10 reach than in Lower Bayou Verdine. PCBs and pesticides generally were not detected in Bayou Verdine, and inorganic elements were distributed throughout the study area. The remainder of this section discusses the sediment data in greater detail. Exhibit 4-10 lists the studies containing sediment data for Bayou Verdine and shows the geographic coverage of each study. Exhibit 4-11 provides summary-level data for the bayou, and Exhibits 4-12 to 4-18 contain primary-level data for each segment.

Exhibit 4-10

GEOGRAPHIC COVERAGE OF BAYOU VERDINE SEDIMENT DATA

Upstream

Vista West Ditch

Trousdale Reach

Faubacher Ditch

KCSRR West Ditch

I-10 Reach

Lower Bayou

Verdine

RTI U U U U

PRC (1994) U U U U U U U

ChemRisk (1994) U U

Volatile Organic Compounds (VOCs) Sediment data for VOCs were available from all three studies that sampled in the bayou; RTI, PRC (1994), and ChemRisk (1994). In the bayou, VOCs were detected most frequently in the I-10 reach and Lower Bayou Verdine. VOCs also were detected in the Vista West Ditch, yet no compounds were detected in the Trousdale reach, which receives discharge from the ditch. Upstream Acetone (0.048 ppm) was the only VOC detected in sediment samples from the upstream segment.

4-10

Vista West Ditch Ten VOCs were detected in the Vista West Ditch. These compounds were acetone (0.12 ppm), benzene (0.01 ppm), 2-butanone (0.02 ppm), chlorobenzene (0.04 ppm), chloroethane (0.03 ppm), chloroform (0.02 ppm), 1,1-dichloroethane (0.04 ppm), 1,2-dichloroethane (0.01-0.05 ppm), 1,1,2-trichloroethane (0.02-0.1 ppm), and vinyl chloride (0.012-0.121 ppm). Vinyl chloride was detected in all three samples. 1,1,2-Trichloroethane and 1,2-dichloroethane each were detected in two of the three samples. Trousdale Reach No VOCs were found in four samples from the reach. Faubacher and KCSRR West Ditch VOCs generally were not detected in the Faubacher and KCSRR West Ditches. 2-Butanone was the only compound found in any of four samples from the Faubacher Ditch (0.01 ppm), and the only VOC detected in either of two samples from the KCSRR ditch was acetone (0.05 ppm). Interstate 10 Reach Five VOCs were detected in sediment samples from the I-10 reach. These compounds were acetone (0.029-0.43 ppm), 2-butanone (0.013-0.018 ppm), methylene chloride (0.001-0.013 ppm), tetrachloroethene (0.017-0.19 ppm), and xylene (0.012-0.11 ppm). No VOCs were detected in the Trousdale reach immediately upstream, but acetone and 2-butanone were detected in the Faubacher and KCSRR ditches, indicating possible inputs from the ditches. Methylene chloride, tetrachloroethene, and xylene were not detected upstream of the I-10 reach or in any of the ditches. Lower Bayou Verdine ChemRisk (1994) detected nine VOCs in eleven sediment samples from Lower Bayou Verdine. These compounds were acetone (0.012-0.27 ppm), benzene (0.022 ppm), 2-butanone (0.013-0.029 ppm), carbon disulfide (0.005-0.006 ppm), chlorobenzene (0.028 ppm), methylene chloride (0.005-0.009 ppm), tetrachloroethene (0.006-0.009 ppm), toluene (0.012 ppm), and xylene (0.005-0.093 ppm). These compounds only were detected by the ChemRisk (1994) study. RTI and PRC (1994) did not detect VOCs in Lower Bayou Verdine.

4-11

Four of the nine compounds (benzene, carbon disulfide, chlorobenzene, and toluene) were not detected immediately upstream. The remaining compounds (acetone, 2-butanone, methylene chloride, tetrachloroethene, and xylene) all were found at similar or higher concentrations in the I-10 reach. Semivolatile Organic Compounds (SVOCs) Sediment data for SVOCs were available from RTI, PRC (1994) and ChemRisk (1994). In general, SVOCs were detected more frequently in the I-10 reach and Lower Bayou Verdine than in the upstream or Trousdale segments. SVOCs also were detected in all three ditches and were most prevalent in the KCSRR ditch that flows into the I-10 reach. Upstream Three SVOCs were detected in the upstream segment. These compounds were chrysene (0.58 ppm), isophorone (24.6 ppm), and pyrene (0.88 ppm). None of the three was detected in more than one sample. Vista West Ditch Benzo(a)anthracene (2.2 ppm), benzo(b)fluoranthene (2.63 ppm), chrysene (6.6 ppm), fluoranthene (1.49 ppm), and phenanthrene (3.41 ppm) were detected in the Vista West Ditch. None of the compounds were detected in more than one sample. Phenanthrene also was detected in the Trousdale reach immediately downstream. Trousdale Reach Five SVOCs were detected in the Trousdale reach. These five were benzo(a)pyrene (0.013 ppm), isophorone (47.6 ppm), 2-methylnaphthalene (2.98 ppm), phenanthrene (5.15 ppm), and pyrene (0.6 ppm). Three of these compounds (benzo(a)pyrene, 2-methylnaphthalene, and phenanthrene) were not detected in the upstream segment; however, phenanthrene was found in the Vista West Ditch, indicating possible inputs from the ditch. Faubacher Ditch Five SVOCs were detected in sediment samples from the Faubacher Ditch, including benzo(a)anthracene (12.6 ppm), chrysene (4.1-33 ppm), fluoranthene (6.3 ppm), phenanthrene (22 ppm), and pyrene (4.05-18 ppm).

4-12

KCSRR West Ditch SVOCs were detected more frequently and at higher concentrations in the KCSRR West Ditch (9 compounds) than in the other two ditches (5 compounds each). The nine compounds detected in the KCSRR ditch were anthracene (11 ppm), benzo(a)anthracene (12-34 ppm), benzo(a)pyrene (11-20 ppm), benzo(b)fluoranthene (12-26 ppm), chrysene (27-59 ppm), fluoranthene (23 ppm), fluorene (14 ppm), phenanthrene (32-95 ppm), and pyrene (30-80 ppm). Interstate 10 Reach More SVOCs (21) were detected in sediment samples from the I-10 reach than from any other segment of the bayou, and many were measured at high concentrations relative to the other segments. Thirteen of the 21 compounds were measured at concentrations greater than 10 ppm. Further, three compounds chrysene (0.86-221 ppm), phenanthrene (3.2-135 ppm), and pyrene (0.94-162 ppm) all were detected at concentrations greater than 100 ppm. Chrysene and pyrene were the two most frequently detected SVOCs in the I-10 reach (8 and 9 of the 13 samples, respectively). Fifteen of the 21 SVOCs detected in the I-10 reach were not detected upstream. Five of these compounds (anthracene, benzo(a)anthracene, benzo(b)fluoranthene, fluoranthene, and fluorene) were detected in the Faubacher or KCSRR ditch, indicating possible inputs from the ditches. The remaining 10 SVOCs were neither detected upstream of the I-10 reach nor in the ditches that discharge into the reach. Only 6 of the 21 compounds were detected upstream of the I-10 reach, but concentrations for these compounds generally were higher in the I-10 reach than upstream. Four of these compounds (benzo(a)pyrene, chrysene, Phenanthrene, and pyrene) were also detected in the Faubacher and KCSRR ditches, again indicating possible inputs from these ditches. Lower Bayou Verdine Seventeen SVOCs were detected in Lower Bayou Verdine, and many were measured at high concentrations relative to the other bayou segments. Ten of the 17 were measured at concentrations greater than 10 ppm, and chrysene (0.5-120 ppm) and pyrene (0.48-120 ppm) had concentrations greater than 100 ppm. Chrysene and pyrene also were the two most prevalent SVOCs in Lower Bayou Verdine, detected in 6 and 8 of 16 samples, respectively. All seventeen of the SVOCs detected in Lower Bayou Verdine also were detected in the I-10 reach immediately upstream. In general, these compounds were detected less frequently and concentrations did not range as high in Lower Bayou Verdine compared to the I-10 reach.

4-13

Total Petroleum Hydrocarbons (TPHs) Sediment data for diesel and gasoline were available only from ChemRisk (1994), which collected samples in the I-10 reach and Lower Bayou Verdine. Diesel and gasoline concentrations were greater in the I-10 reach (30-6,300 ppm and 110-60,000 ppm, respectively) than in Lower Bayou Verdine (0.66-4.9 ppm and 0.29-4.4 ppm, respectively). Diesel and gasoline also were prevalent in Coon Island Loop and were measured at concentrations up to 6,300 ppm and 14,000 ppm, respectively in the loop. Polychlorinated Biphenyls (PCBs) and Pesticides Sediment data for PCBs and pesticides were available from RTI, PRC (1994), and ChemRisk (1994). In Lower Bayou Verdine, Aroclor-1254 and gamma-BHC each were detected in one sample (0.06 ppm and 0.004 ppm, respectively). No PCBs or pesticides were detected in other Bayou Verdine segments. Inorganic Elements Sediment data for inorganic elements were available from RTI, PRC (1994), and ChemRisk (1994). In general, inorganics were evenly distributed throughout Bayou Verdine and the three ditches. Among the numerous inorganics detected were mercury, arsenic, beryllium, selenium, and thallium. Mercury was detected in the Trousdale, I-10, and Lower Bayou Verdine reaches. The maximum concentration of mercury was measured at 0.37 ppm in Lower Bayou Verdine. Among the bayou segments, mercury was detected most frequently in the I-10 reach (4 of 13 samples). Mercury also was found in both samples from the KCSRR West Ditch (concentrations, 0.12 ppm and 0.32 ppm). Mercury was not detected in the other two ditches or in the upstream segment. Arsenic was detected throughout the bayou and ditches. It was detected in approximately 40 percent of the sediment samples in each of the bayou and ditch segments and was measured at concentrations ranging from 2 ppm to 5 ppm. Beryllium was detected in all four bayou segments, but was detected most frequently (2 of 4 samples) and was measured at the highest concentrations (1.04 ppm and 2 ppm) in the Trousdale reach. Beryllium also was detected in two of three sediment samples from the Vista West Ditch, which flows into the Trousdale reach near the segment's upstream boundary. The frequency of detection of beryllium generally decreased downstream from the Trousdale reach through Lower Bayou Verdine.

4-14

Selenium was detected in the I-10 reach and Lower Bayou Verdine and measured at concentrations ranging from 1.8 ppm to 7.2 ppm. It was also detected in both sediment samples from the KCSRR West Ditch, which flows into the I-10 reach. Selenium was not detected in either of the two bayou segments upstream of the I-10 reach or in the Vista West or Faubacher Ditches. Thallium was detected in only two samples from Bayou Verdine, one from the Trousdale reach and the other from Lower Bayou Verdine. Thallium was measured at 0.5 ppm in each of the samples.

5-1

CALCASIEU RIVER AND SHIP CHANNEL CHAPTER 5 Chapter 5 presents the water column and sediment resource characterization for the Calcasieu River and Ship Channel. We begin this chapter with an overview of the area's physical setting and dimensions. Next, we describe the analytical framework for the river, including the segments used to compile the data. We then review water column contamination within the Calcasieu River and Ship Channel. The chapter's discussion and data tables summarize water column contamination by river segment and data source. Following the water column discussion, we analyze sediment contamination. Like the discussion of the water column, the sediment section reviews contamination and presents data tables for each of the river's segments and data sources. OVERVIEW OF THE CALCASIEU RIVER AND SHIP CHANNEL The Calcasieu River is the principal conduit in the Calcasieu Estuary. This report focuses on the lower portion of the Calcasieu River, which extends from the Gulf of Mexico to the saltwater barrier upstream of Lake Charles, a total distance of approximately forty miles. The Calcasieu River has been substantially altered to accommodate ship traffic. The Calcasieu Ship Channel, which was first dredged in 1937, has isolated several sections of the original river. The ship channel also removed the river's natural saltwater barrier, allowing saltwater to migrate upstream from the Gulf of Mexico. Today, the river is brackish below the saltwater barrier near Lake Charles, and it is not used as a drinking water source. The ship channel has been deepened several times and is maintained at a depth of approximately 45 feet. From the estuary's northernmost point at the saltwater barrier, the river generally flows southwest into Lake Charles. Much of the land around this shallow lake has been developed for residential, commercial, and industrial use. Several storm drainage canals discharge into the eastern portion of the lake.

5-2

From Lake Charles, the Calcasieu River flows west to Clooney Island Loop and then southwest to Coon Island Loop. Clooney Island Loop is characterized by industrial development and marshland. Olin Corporation's tailings pond occupies the land on the southern and western sides of the loop and on Clooney Island itself. Olin's plant complex is located on the northern side and discharges into Clooney Island Loop. Between Clooney and Coon Island Loops, Bayou Contraband, which receives municipal wastewater from the city of Lake Charles, flows into the Calcasieu River. Coon Island Loop connects with the ship channel at the southern end of Coon Island. The western arm of Coon Island Loop is referred to as Coon Island Reach and is an active shipping channel ending at a turning basin at the northern end of the island. The eastern arm of Coon Island Loop is approximately three to ten feet deep and does not accommodate commercial shipping. The area around Coon Island Loop is characterized by intense industrial development and marshland. Olin Corporation's tailings pond occupies the land on the eastern side of Coon Island Loop, and PPG Industries is located on the western side. The only major tributary to Coon Island Loop is Bayou Verdine, which flows into the northern tip of the loop at PPG's dock facilities and the turning basin. Beyond Coon Island Loop, the ship channel flows southwest, and partially isolates the Prien Lake portion of the original river. The northern part of Prien Lake receives inflow from the ship channel, and the lake's outflow discharges back into the ship channel downstream of the mouth of Bayou d'Inde. There is also a connection between the ship channel and Prien Lake across from the mouth of Bayou d'Inde. After the confluence of the Prien Lake portion of the original river and the Calcasieu Ship Channel, the Calcasieu River flows south through Moss Lake and past Calcasieu Lake before discharging into the Gulf of Mexico. Much of the land in this area of the river is undeveloped marshland, but Himont, Citgo, and W.R. Grace all have outfalls to the river between Prien Lake and Moss Lake. Olsen Bayou flows into Moss Lake, and the Intracoastal Waterway intersects the Calcasieu River near Choupique Island, downstream of Moss Lake. Lake Calcasieu is located downstream of Choupique Island. The lake is a coastal lagoon system that is predominantly less than six feet deep. Originally, the Calcasieu River passed through the lake; however, when the ship channel was dug a spoil bank was constructed to separate the river/ship channel from the lake. Calcasieu Lake is still connected to the Calcasieu River and Ship Channel at its northern and southern ends, but river flow largely bypasses the lake. The Sabine National Wildlife Refuge lies along the western side of the Calcasieu River and Ship Channel in the Calcasieu Lake area. Extensive water exchange occurs between the marshes in the Sabine Refuge, Sabine Lake, and Calcasieu Lake via an interior canal system.

5-3

CALCASIEU RIVER SEGMENTING SCHEME We divide data for the Calcasieu River into six segments. From north to south, these segments include: Lake Charles, Clooney Island Loop, Coon Island Loop, Prien Lake, Moss Lake, and Calcasieu Lake. Each of these segments is described below and is shown in Exhibit 5-1.

• Lake Charles (Segment 12) -- The Lake Charles segment extends from the furthest upstream sampling station to the eastern point of the Port of Lake Charles; total distance is approximately eight miles.

• Clooney Island Loop (Segment 13) -- The Clooney Island Loop segment

extends from the eastern point of the Port of Lake Charles to the midpoint between the Clooney Island and Coon Island Loops, including Clooney Island Loop itself. This segment is four miles in length and includes the Olin and Conoco dock facilities and receives discharges from Bayou Contraband and Olin Corporation outfalls.

• Coon Island Loop (Segment 14) -- The Coon Island Loop segment

extends from the midpoint between the Coon and Clooney Island Loops to the confluence of the Coon Island Loop and the Calcasieu River and Ship Channel, directly across from Prien Lake. The segment, which is just over three miles in length, includes Coon Island Loop itself and receives discharges from Bayou Verdine and PPG outfalls. The PPG dock facilities also are included in this segment.

• Prien Lake (Segment 15) -- This reach extends from the confluence of

the Coon Island Loop and the Calcasieu River and Ship Channel to the southern confluence of Prien Lake and the ship channel. This segment includes both the Prien Lake portion of the original river and the ship channel. Bayou d'Inde flows into this reach. The Prien Lake segment is approximately three miles in length.

• Moss Lake (Segment 16) -- The Moss Lake segment is approximately six

miles in length and extends from the confluence of Prien Lake and the ship channel to the southern end of Moss Lake. This segment receives discharges from Citgo and W.R. Grace.

• Calcasieu Lake (Segment 17) -- This reach extends from the end of Moss

Lake to the Gulf of Mexico, approximately 14 miles.

5-5

SURFACE WATER DATA SUMMARY The surface waters of the Calcasieu River and Ship Channel contain VOCs and SVOCs. Coon Island Loop and Prien Lake, in particular, exhibit greater numbers of VOCs and SVOCs than other portions of the river. Further, inorganics, which are widely distributed throughout the estuary, occur in slightly greater numbers in the Coon Island Loop, Prien Lake, and Moss Lake segments. PCBs and pesticides were not detected in water samples from the Calcasieu River and Ship Channel. The remainder of this section discusses the surface water data in more detail. Exhibit 5-2 lists the studies containing water data for the Calcasieu River and Ship Channel and shows the geographic coverage of each study. Exhibit 5-3 provides summary-level data, excluding the LDEQ data which are discussed separately. Exhibits 5-5 to 5-16 show primary-level data for each individual segment.

Exhibit 5-2

GEOGRAPHIC COVERAGE OF CALCASIEU RIVER AND SHIP CHANNEL WATER STUDIES

Lake Charles

Clooney Island Loop

Coon Island Loop

Prien Lake

Moss Lake

Calcasieu Lake

RTI U U U U U U

ChemRisk (1994) U

ChemRisk (1995) U U

PRC (1994) U

EPA (1996) U U

LDEQ U U U U U U

Volatile Organic Compounds (VOCs) Surface water data for VOCs were available from RTI, ChemRisk (1994 and 1995), PRC (1994), EPA (1996), and LDEQ. The LDEQ data are discussed separately at the end of this section.

5-6

Lake Charles Two VOCs (styrene and xylene) were detected only in the Lake Charles segment of the river. Styrene and xylene were measured at 0.0003 ppm and 0.0015 ppm, respectively. Bromoform, which was detected in all river reaches, was found at the lowest concentration in Lake Charles (0.006 ppm). Clooney Island Loop Tetrachloroethene was detected in the Clooney Island Loop at a concentration of 0.001 ppm. Tetrachloroethene, however, was not detected in the segments immediately upstream or downstream of Clooney Island (Lake Charles and Coon Island Loop, respectively). The compound was detected further downstream in the Prien Lake (0.0022 ppm) and Moss Lake (0.001 ppm) segments. Bromoform was detected in all three samples from this segment; concentrations ranged from 0.004 to 0.005 ppm. Coon Island Loop Toluene, 1,2-dichloroethane, 1,1,2,2-tetrachloroethane, 1,1,2-trichloroethane, acetone and bromoform were detected in Coon Island Loop. 1,2-Dichloroethane was the most prevalent compound, detected in 24 of 36 samples with a maximum concentration of 0.14 ppm. The other detected compounds were found less frequently and at lower concentrations. Of the compounds detected, only bromoform was found in upstream reaches. Within Coon Island Loop, detected compounds differed between studies (Exhibit 5-7). For example, 1,1,2,2-tetrachloroethane, 1,1,2-trichloroethane, and acetone were detected by ChemRisk (1994), but not by other studies. Furthermore, bromoform and toluene were detected only by RTI. Of the six VOCs detected in Coon Island Loop, only 1,2-dichloroethane was found in more than one study. RTI, PRC (1994), and ChemRisk (1994) all found 1,2-dichloroethane in the majority of samples. EPA (1996) did not detect any VOCs in Coon Island Loop. Prien Lake More VOCs (9) were detected in the Prien Lake segment than in any other portion of the river, although none was detected in more than 4 of 18 samples. Four of these compounds (bromodichloromethane, chloroform, dibromochloromethane, and trichloroethene) were not detected upstream of Prien Lake, but all four were detected in Lower Bayou d'Inde, indicating contaminant inflows from the bayou. Four VOCs were found in both the Prien Lake and Coon Island Loop segments. Three of these compounds (1,2-dichloroethane, 1,1,2,2-tetrachloroethane, and 1,1,2-trichloroethane) were

5-7

measured at lower concentrations in the Prien Lake segment. The fourth compound, bromoform, was found at the highest concentration in the Prien Lake segment (0.041 ppm). Exhibit 5-8 suggests that Prien Lake results vary among studies. RTI detected all nine of the VOCs found in the Prien Lake segment, but ChemRisk (1995) only detected 1,2-dichloroethane. This difference may be the result of historic contamination; the RTI samples were collected in 1988, six years before the ChemRisk study. Alternatively, sample quantitation limits (SQLs) may have differed between the studies. Since a visual inspection of the data, however, did not indicate major differences in SQLs, additional research would be necessary to reconcile the differences between these studies. Moss Lake All three of the compounds detected in the Moss Lake segment (bromoform, chloroform, and tetrachloroethene) also were detected in the Prien Lake segment immediately upstream. The concentrations measured for all three compounds were within the same range as in the Prien Lake segment. Calcasieu Lake Bromoform was the only compound detected in the Calcasieu Lake segment. Bromoform concentrations (0.001 ppm in each of two samples) were less than in the Moss lake segment (0.005-0.006 ppm). LDEQ VOC Data LDEQ data for the Calcasieu River and Ship Channel is provided in Exhibits 5-11 to 5-16. Twenty-seven different VOCs were detected in the approximately 2,000 LDEQ water samples from the Calcasieu River and Ship Channel. The LDEQ's large sample size may be one explanation for the wide variety of VOCs detected. Alternatively, if water column contamination has decreased over time, historic conditions could increase the number of detections in the LDEQ data due to the duration of the sampling program. While most compounds were detected infrequently, chloroform and 1,2-dichloroethane were prevalent throughout the river and ship channel. 1,2-Dichloroethane was detected in a minimum of 19 percent of the water samples from each river segment. The compound was detected most frequently in samples from the Coon Island Loop, Prien Lake, and Moss Lake

5-8

segments of the river (77 percent, 40 percent, and 62 percent of the samples, respectively). The highest concentration of 1,2-dichloroethane (0.199 ppm) was measured in a water sample from the Prien Lake segment. Chloroform also was frequently detected in all of the river segments. The compound was detected most frequently in samples from the Coon Island Loop (77 percent) and Moss Lake (62 percent) segments. The lowest detection rates were in the Lake Charles and Calcasieu Lake portions of the river (15 percent and 21 percent of the samples, respectively). Other frequently detected VOCs are listed in Exhibit 5-4. Each of the compounds included in Exhibit 5-4 were detected in more than five percent of the LDEQ samples in every river segment. The Coon Island Loop and Moss Lake segments contained a greater number of VOCs meeting the five percent criteria than other river segments. The Prien Lake segment was third, followed by Clooney Island, Calcasieu Lake, and Lake Charles. The VOC trend across segments apparently contradicts the RTI, ChemRisk (1994 and 1995), and PRC (1994) studies, which identified Prien Lake as the segment with the greatest number of VOCs. As discussed above, however, LDEQ's historic data set may partially influence this result. The location of sample stations also may provide an explanation for this difference. A visual inspection of each study's sample locations indicates that ChemRisk (1995) took samples from areas of the Prien Lake segment that may be heavily influenced by Bayou d'Inde. LDEQ, however, sampled two locations within the lake, one of which appears to monitor water quality near a recreation area on the east side of the lake. This location may not be as heavily influenced by inflows from Bayou d'Inde, and therefore help explain some of the variation between study results. Semivolatile Organic Compounds (SVOCs) Surface water data for SVOCs were available from RTI, ChemRisk (1994 and 1995), and EPA (1996). In general few SVOCs were detected in surface waters. Lake Charles and Clooney Island Loop Two SVOCs (diethyl phthalate and phenol) were detected in water samples from the Lake Charles and Clooney Island Loop segments. Concentrations of diethyl phthalate ranged from 0.37 ppm to 0.7 ppm in both segments, and phenol concentrations ranged from 0.002 ppm to 0.003 ppm. Diethyl phthalate was detected throughout the Calcasieu River and Ship Channel, and phenol was found in all but the Prien Lake segments.

5-9

Exhibit 5-4

VOCs DETECTED IN MORE THAN FIVE PERCENT OF THE LDEQ WATER SAMPLES FROM EACH CALCASIEU RIVER AND SHIP CHANNEL SEGMENT

Lake Charles Clooney Island Loop Coon Island Loop Prien Lake Moss Lake Calcasieu Lake

Benzene --- --- Chloroform --- 1,2-Dichloroethane --- --- --- Toluene --- --- ---

--- --- Bromoform Chloroform --- 1,2-Dichloroethane --- 1,1,2,2-Tetrachloroethane Tetrachloroethene --- --- --- Trichloroethene

--- --- Bromoform Chloroform Dibromochloromethane 1,2-Dichloroethane Methylene Chloride 1,1,2,2-Tetrachloroethane Tetrachloroethene Toluene 1,1,1-Trichloroethane Trichloroethene

--- --- Bromoform Chloroform --- 1,2-Dichloroethane Methylene Chloride 1,1,2,2-Tetrachloroethane Tetrachloroethene --- --- 1,1,2-Trichloroethane Trichloroethene

--- Bromodichloromethane Bromoform Chloroform Dibromochloroethane 1,2-Dichloroethane Methylene Chloride 1,1,2,2-Tetrachloroethane Tetrachloroethene --- 1,1,1-Trichloroethane 1,1,2-Trichloroethane Trichloroethene

--- --- Bromoform Chloroform --- 1,2-Dichloroethane Methylene Chloride 1,1,2,2-Tetrachloroethene Tetrachloroethene --- --- --- ---

5-10

Coon Island Loop Bis(2-ethylhexyl)phthalate and di-n-butyl phthalate were detected in the Coon Island Loop at concentrations of 0.01 ppm and 0.14 ppm, respectively. Neither compound was found upstream in the Lake Charles or Clooney Island Loop portions of the river. Diethyl phthalate and phenol also were found in the Coon Island Loop at similar concentrations as in the two upstream segments. Prien Lake Five SVOCs were detected in the Prien Lake portion of the river, and two of these compounds (naphthalene and n-nitroso di-n-propylamine) were not detected in other river segments. The highest naphthalene concentration measured was 0.14 ppm, while the highest concentration of n-nitroso di-n-propylamine was 0.012 ppm. The other three SVOCs (bis(2-ethylhexyl)phthalate, diethyl phthalate, and di-n-butyl phthalate) all were detected in the Coon Island Loop immediately upstream. Concentrations of bis(2-ethylhexyl)phthalate and di-n-butyl phthalate were greater in the Prien Lake segment than in the Coon loop, but the diethyl phthalate concentration was lower than in upstream segments. Moss Lake and Calcasieu Lake Di-n-butyl phthalate was detected in Moss Lake and measured at a greater concentration (0.5 ppm) than in the Prien Lake and Coon Island Loop segments. The compound was not detected in the Calcasieu Lake portion of the river. Diethyl phthalate and phenol were detected in both segments. Phenol concentrations were slightly higher than in upstream portions of the river, while concentrations of diethyl phthalate were slightly lower. Inorganic Elements Surface water data for inorganic elements were available from RTI, ChemRisk (1994 and 1995), and EPA (1996). In general inorganic elements were evenly distributed throughout the river, although slightly more inorganics were detected in the Coon Island Loop, Prien Lake, and Moss Lake segments than in the other reaches. Arsenic, mercury, and selenium were among the numerous inorganic elements detected. Arsenic was detected in the Lake Charles (0.0013 ppm), Coon Island Loop (0.001-0.006 ppm), and Moss Lake (0.0067-0.0124 ppm) segments of the river. Arsenic was not detected in the other river reaches.

5-11

Mercury was detected in two water samples from the Prien Lake segment (0.0001 ppm) and one sample from the Moss Lake segment (0.0003 ppm). In the Prien Lake segment, mercury was detected in two of five samples from the RTI study, but not in any of the thirteen ChemRisk (1995) samples. Aside from Prien Lake and Moss Lake, mercury was not detected in water from other river segments. Selenium was detected in a single ChemRisk (1994) sample from the Coon Island Loop segment and measured at a concentration of 0.033 ppm. Selenium was not detected in other river reaches.

5-12

SEDIMENT DATA SUMMARY VOC and SVOC contamination in the Calcasieu River and Ship Channel sediments varied greatly by segment. Within the river and ship channel, VOCs were only found in sediment samples from the Lake Charles, Coon Island Loop, and Prien Lake segments. Although more VOCs were detected in Coon Island Loop than in other segments, this trend may be partially a result of the large number of samples collected in the loop compared to the other segments. SVOCs also were more prevalent in Coon Island Loop than in other segments. Unlike VOCs, however, the prevalence of SVOCs in the loop is reflected in several studies with varying numbers of samples. Inorganic elements were generally evenly distributed throughout the river, but slightly more inorganics were detected in Coon Island Loop than in other reaches. PCBs and pesticides were generally not detected in the Calcasieu River and Ship Channel. The remainder of this section discusses the sediment data in more detail. Exhibit 5-17 lists studies containing sediment data for the Calcasieu River and Ship Channel and shows the geographic coverage of each study. As the exhibit shows, more sediment data are available from the Coon Island Loop than other portions of the river. The four studies listed in the exhibit contain 142 samples from the Coon Island Loop compared to 38 samples in the Prien Lake segment and no more than four samples from other segments. Exhibit 5-18 provides summary-level data for the Calcasieu River and Ship Channel, and Exhibits 5-19 to 5-24 show primary-level data for each individual segment.

Exhibit 5-17

GEOGRAPHIC COVERAGE OF CALCASIEU LAKE AND SHIP CHANNEL SEDIMENT STUDIES

Lake Charles

Clooney Island Loop

Coon Island Loop

Prien Lake

Moss Lake

Calcasieu Lake

RTI U U U U U U

ChemRisk (1994) U

ChemRisk (1995) U U

PRC (1994) U

Volatile Organic Compounds (VOCs) Sediment data for volatile organic compounds in Calcasieu River and Ship Channel sediment were available from RTI, ChemRisk (1994 and 1995), and PRC (1994). VOCs were only detected in the Lake Charles, Coon Island Loop, and Prien Lake segments. Each of these segments is discussed below.

5-13

Lake Charles Two VOCs (methylene chloride and 1,1,2,2-tetrachloroethane) were detected in the Lake Charles segment. The concentration measured for 1,1,2,2-tetrachloroethane (13 ppm) was the highest VOC concentration measured in the river and ship channel. The compound was not detected in any of the segments downstream of Lake Charles. Coon Island Loop Eleven VOCs were detected in sediment samples from the Coon Island Loop segment. These eleven VOCs were acetone, 2-butanone, carbon disulfide, chlorobenzene, 1,2-dichloroethane, ethylbenzene, methylene chloride, 1,1,2-trichloroethane, vinyl chloride, and xylene. Three of these compounds (1,2-dichloroethane, 1,1,2-trichloroethane, and vinyl chloride) have been identified at high concentrations in the soil and groundwater of the adjacent PPG facility. No VOCs were detected in Clooney Island Loop, immediately upstream of the Coon Island Loop, and only methylene chloride was detected in the Lake Charles segment further upstream. VOC concentrations in the loop were generally less than 0.1 ppm. Exhibit 5-21 indicates that sampling density may influence the number of compounds identified by each study. The ChemRisk (1994) study, for example, collected 124 multi-depth sediment samples and detected 11 VOCs. The RTI, PRC (1994), and ChemRisk (1995) studies, however, collected a combined total of 18 samples and only detected three VOCs. Since sediment contamination often varies substantially within an area, the density of sample collection may help explain the apparent differences in site conditions identified by the studies. Prien Lake Four VOCs (carbon disulfide, chlorobenzene, methylene chloride, and 1,1,1-trichloroethane) were detected in the Prien Lake segment of the river and ship channel. 1,1,1-Trichloroethane (0.3 ppm) was not detected upstream of the Prien Lake segment, but carbon disulfide, chlorobenzene, and methylene chloride all were detected in the Coon Island Loop segment immediately upstream. Carbon disulfide and chlorobenzene generally were measured at lower concentrations in the Prien Lake segment than in Coon Island Loop. No VOCs were detected downstream of the Prien Lake segment. Semivolatile Organic Compounds (SVOCs) Sediment data for SVOCs in Calcasieu River and Ship Channel sediment were available from RTI, PRC (1994), and ChemRisk (1994 and 1995). SVOCs were detected in the Lake Charles, Clooney Island Loop, Coon Island Loop, and Prien Lake segments. SVOCs were not detected in the Moss Lake and Calcasieu Lake segments, which are therefore omitted from the discussion. In general, SVOCs were detected most frequently in the Coon Island Loop portion of the Calcasieu River and Ship Channel.

5-14

Lake Charles Two SVOCs (isophorone and naphthalene) were detected in sediment from the Lake Charles segment. The concentration measured for isophorone was 53.2 ppm, and naphthalene had a concentration of 0.82 ppm. Clooney Island Loop Only one SVOC (isophorone) was detected in Clooney Island Loop. Isophorone also was detected in the Lake Charles segment immediately upstream, and the concentrations of isophorone in the two segments were similar (57.6 ppm in the loop and 53.2 ppm in Lake Charles). Coon Island Loop Twenty SVOCs were detected in Coon Island Loop, 19 of which were measured at concentrations greater than 1 ppm. Concentrations of 14 compounds were measured at more than 10 ppm, and three compounds (isophorone, chrysene, and pyrene) had concentrations greater than 100 ppm. The maximum concentrations for isophorone, chrysene, and pyrene were 102 ppm, 130 ppm, and 120 ppm, respectively. Chrysene and pyrene were also the two most frequently detected SVOCs in Coon Island Loop. Of the SVOCs detected in the Coon Island Loop, only isophorone and naphthalene were found upstream in either the Lake Charles or Clooney Island Loop segments. Concentrations of both compounds were within similar ranges in these upstream segments. Exhibit 5-21 shows that isophorone was detected only in sediment samples from the RTI study and not in any of the 136 samples from other studies. Exhibit 5-21 also indicates that study-specific sampling densities, which appeared to have a large impact on Coon Island Loop VOC detections, have less of an impact on SVOC results. The ChemRisk (1994) study, which collected 124 samples within Coon Island Loop, detected seventeen SVOCs. The RTI study with only three samples, however, detected eight different compounds. Further, detection rates in the RTI study equaled or exceeded the rates of detection in the higher density ChemRisk (1994) study. Prien Lake Three SVOCs (bis(2-ethylhexyl)phthalate, hexachlorobenzene, and naphthalene) were detected in the Prien Lake portion of the river and ship channel. Bis(2-ethylhexyl)phthalate and naphthalene also were detected in the Coon Island Loop segment, immediately upstream. The

5-15

third compound, hexachlorobenzene, was found in only one sample from the Prien Lake segment (6 ppm). Hexachlorobenzene was not detected upstream of Prien Lake, but was detected in Lower Bayou d'Inde, indicating possible contaminant inputs from the bayou. Total Petroleum Hydrocarbons (TPHs) Sediment data for diesel and gasoline were available from ChemRisk (1994) and ChemRisk (1995), which collected samples from the Prien Lake and Coon Island Loop segments. Both compounds were detected more frequently and at higher concentrations in the Coon Island Loop segment. Maximum concentrations in Coon Island Loop were in parts per thousand, while concentrations in the Prien Lake segment did not exceed 26 ppm. Polychlorinated Biphenyls (PCBs) and Pesticides PCBs and pesticides were generally not detected in sediment samples from the Calcasieu River and Ship Channel. In the Coon Island Loop segment, Aroclor-1254 was detected in two samples (concentrations 0.16 ppm and 0.26 ppm) and Aroclor-1260 in one sample (concentration, 0.27 ppm). No PCBs were detected in other segments of the river. DDT was detected in one sample from the Prien Lake segment at a concentration of 0.16 ppm. No pesticides were detected in any other segment of the river. Inorganic Elements In general, inorganic elements were distributed throughout the Calcasieu River and Ship Channel. Arsenic, beryllium, mercury, and selenium were among the numerous inorganics detected in sediment from the river and ship channel. Beryllium was detected in every river segment (concentrations, 1-3 ppm), and arsenic was detected in all but the Lake Charles segment (concentrations, 1-11.1 ppm). Mercury was only detected in sediment samples from three segments: Lake Charles, Coon Island Loop, and Prien Lake. In the Lake Charles segment mercury was detected in two of four samples (0.11 to 0.14 ppm). Mercury was detected in 33 of 142 sediment samples from the Coon Island Loop segment (0.1 to 0.66 ppm), but was not found in Clooney Island Loop immediately upstream. In the Prien Lake segment mercury was detected in 12 of 38 samples (0.11 ppm to 1.5 ppm). Mercury was detected frequently in Bayou Verdine, indicating possible inputs from the bayou to Coon Island Loop. Selenium was detected in 3 of 142 sediment samples from the Coon Island Loop segment (concentrations, 0.62-1.4 ppm). Selenium was not detected in the other portions of the river.

6-1

FISH AND SHELLFISH RESOURCES CHAPTER 6 This chapter reviews fish and shellfish resource contamination within the Calcasieu Estuary. We begin with a discussion of the fish and shellfish sampling program that provided data for this analysis, including the program's study area, target species, and contaminants of interest. We also summarize the past and current consumption advisories affecting recreational fishing in the estuary. Following this background discussion, we compile and review the data collected by the sampling program since 1987. OVERVIEW OF THE FISH SAMPLING PROGRAM Beginning in 1987, the Louisiana Department of Health and Hospitals (LDHH) and the Louisiana Department of Environmental Quality (LDEQ) began analyzing the Calcasieu Estuary's aquatic organisms to determine the extent and severity of chemical contamination within the estuary. These studies found high levels of hexachlorobenzene (HCB) and hexachlorobutadiene (HCBD) in the region's fish and shellfish. Subsequently, LDEQ and LDHH issued fish consumption and contact recreation advisories for a large portion of the Calcasieu Estuary. The results of the 1987 tissue analysis also prompted LDEQ to implement a more comprehensive sampling program. In June of 1989, LDEQ turned the fish sampling program, currently known as the Calcasieu River Estuary Biological Monitoring Program, over to PPG Industries. Study Area PPG currently collects aquatic organisms from eleven stations throughout the Calcasieu Estuary. Stations are located in the Calcasieu River, Lake Charles, Prien Lake, the PPG Canal, lower Bayou d'Inde, Calcasieu Lake, and the Gulf of Mexico. Bayou Verdine and upper Bayou d'Inde (above the PPG Canal) are not included in the sampling program. The approximate locations of each sampling station are shown in Exhibit 6-1.

6-3

Other chapters of this report aggregate data into pre-defined segments. The fish and shellfish data, however, are presented using the eleven stations identified in Exhibit 6-1.1 Target Species

PPG has sampled fish and shellfish on a quarterly basis since June of 1989. The study targets seven species of fin fish and four species of shellfish. Each is collected depending on the location of the sampling station and availability. Each of the target species is considered characteristic of the Calcasieu Estuary and is important to the recreational or commercial fishery. Target species include both marine and freshwater fishes and include representatives of benthic and piscivorous food chains. Target species, their anticipated seasonal abundance within the estuary, and the total number of samples collected during the 1989-1995 period are listed in Exhibit 6-2.

Exhibit 6-2

TARGET SPECIES AND TOTAL NUMBER OF SAMPLES

1989 - 1995

Common Name

Scientific Name

Seasonal Target Species Sampling

Spring Summer Fall Winter TOTAL

Spotted Seatrout Sand Seatrout Southern Flounder Red Drum Black Drum Blue Catfish Channel Catfish

Cynoscion nebulosus Cynoscion arenarius Paralichthys lethostigma Sciaenops ocellatus Pogonias cromis Ictalurus furcatus Ictalurus punctatus

35 1

18 97 27 61 10

160 65 35 46

206 0

14

157 25 43

165 47 1

19

4 0

11 111 31 38 11

356 91

107 419 311 100 54

Blue Crab White Shrimp Brown Shrimp

Callinectes sapidus Penaeus setiferus Penaeus aztecus

468

U

585 U U

381 U

330 1764

Oyster Crassostrea virginicia U U U U

Notes Individual White Shrimp, Brown Shrimp, and Oyster were not counted. A check-mark (U) indicates these species' anticipated seasonal abundance.

Source Calcasieu River Estuary Biological Monitoring Program, Annual Report, April 1994 - January 1995

(Year 6), Environmental Science and Engineering, June 1995.

1 Unlike the sediment and water data presented elsewhere, there is only one fish sampling study and relatively few sampling locations. As a result, many of the data aggregation issues associated with the sediment and water samples were avoided, and we were able to maintain the study's native sampling stations and preserve the resolution of the original fish data.

6-4

Compounds Analyzed Fish and shellfish samples currently are analyzed for twelve chlorinated hydrocarbon compounds (including HCB and HCBD) and seven Aroclor mixtures. Exhibit 6-3 lists the compounds analyzed by the Calcasieu River Estuary Biological Monitoring Program.

Exhibit 6-3

COMPOUNDS ANALYZED IN FISH AND SHELLFISH 1989 - 1995

Hexachlorobenzene Hexachlorobutadiene Pentachloroethane Hexachloroethane 1,2-Dichlorobenzene 1,3-Dichlorobenzene 1,2,3-Trichlorobenzene 1,2,4-Trichlorobenzene 1,3,5-Trichlorobenzene 1,2,3,4-Tetrachlorobenzene 1,2,4,5-Tetrachlorobenzene Pentachlorobenzene Polychlorinated biphenyls (As Aroclor mixtures 1016, 1221, 1232,

1242, 1248, 1254, 1260)

Source Calcasieu River Estuary Biological Monitoring Program, Annual Report, April 1994 - January 1995 (Year 6), Environmental Science and Engineering, June 1995.

Health Advisories Data from the monitoring program are collected to characterize the extent and severity of chemical contamination in the Calcasieu Estuary. These data also are used to advise the public of the health risks associated with consumption of the region's fish and shellfish. Since 1987, a total of seven fish consumption and contact recreation health advisories have been posted for the estuary. These advisories are summarized in Exhibit 6-4. The current advisory for Bayou d'Inde prescribes limited fish consumption. Outside of Bayou d'Inde the advisory is informational, advising the public about trace chemical contamination in the estuary's fish and shellfish so that they may make informed decisions about the quantity of Calcasieu Estuary fish they consume. Most of the consumption advisories listed in Exhibit 6-4 were issued due to HCB and HCBD contamination. More recently, PCBs have been added to the list of contaminants of concern. Historically, the Louisiana Department of Health and Hospitals (LDHH) based these advisories on an "action level" of 60 parts per billion for HCB and HCBD in edible tissues of fish and shellfish. LDHH currently bases state-issued advisories on site-specific human health risk analysis. LDHH issues and maintains consumption advisories based on guidelines entitled "Protocol for Issuing Health Advisories and Bans Based on Chemical Contamination of

6-5

Fish/Shellfish in Louisiana" (1996). During the April 1994 to January 1995 sampling year, 14 station/species composites (e.g., Blue Catfish at station 4) had mean HCB or HCBD concentrations that exceeded the historic action level.

Exhibit 6-4

CALCASIEU ESTUARY HEALTH ADVISORIES

Location Effective Dates

Advisory Contaminants of Concern

Bayou d'Inde 1/17/87 - 4/6/92 Fish Consumption. Do not eat fish or shellfish.

HCB HCBD

4/7/92 - Present Fish Consumption. Limit consumption to 2 meals per month.

HCB HCBD PCBs

7/24/87 - Present Contact Recreation. Swimming and water sports advisory based on dermal absorption from water and sediment.

VOCs

Prien Lake 1/16/87 - 4/6/92 Fish Consumption. Do not eat fish or shellfish.

HCB HCBD

Calcasieu River Above Interstate

210 to Moss Lake Saltwater Barrier to

Gulf of Mexico Saltwater Barrier to

Gulf of Mexico

1/16/87 - 4/6/92

2/24/89 - 4/6/92

4/7/92 - Present

Fish Consumption. Do not eat fish or shellfish. Fish Consumption. Do not eat Speckled Seatrout or Sand Seatrout. Fish Consumption. Informational health advisory for all fish and shellfish.

HCB HCBD HCB HCBD HCB HCBD PCBs

Notes HCB Hexachlorobenzene HCBD Hexachlorobutadiene PCBs Polychlorinated biphenyls Source Louisiana Department of Environmental Quality, Louisiana Department of Health and Hospitals.

6-6

ANALYSIS OF FISH AND SHELLFISH TISSUE DATA This section summarizes fish and shellfish tissue contaminant data for the Calcasieu Estuary. Data included in this section were collected from 1989 to 1995, and are summarized from the Calcasieu River Estuary Biological Monitoring Program's Annual Report for Year 6.2,3 Exhibit 6-5 provides a brief summary of the tissue data. Full data compilations are presented at the end of this chapter in Exhibits 6-6 through 6-16. Data Aggregation Methods Exhibits 6-6 through 6-16 present tissue contaminant data for each of the Calcasieu River Estuary Biological Monitoring Program's eleven sampling locations, sub-organized by contaminant and species. Each exhibit contains aggregate statistics and seasonal averages. Aggregate statistics are summed across all data for the 1989 to 1995 period and present contaminant ranges, means, and 90 percent confidence intervals for each species. The number of observations (N) in Exhibits 6-6 through 6-16 does not represent the actual number of fish or shellfish or the number of composites sampled from a location. Instead, the Calcasieu River Estuary Biological Monitoring Program calculates an average concentration based on the total number of species/contaminant composites collected at a location during a given quarter; the number of samples (N) represents the number of quarterly averages used to calculate the aggregate mean concentration in the exhibits. The number of quarterly averages for a species/contaminant combination cannot exceed 24 (the number of quarters in the program to date). Since this method obscures the actual number of samples composited, refer to Exhibit 6-2 above for the actual number of aquatic organisms sampled between 1989 and 1995. All contaminant data are reported in parts per billion (ppb), wet weight, and are collected from edible portions of fish and shellfish. Non-detect samples are reported at their detection limits. These conventions are followed because LDEQ and LDHH use the Calcasieu River Estuary Biological Monitoring Program's analytical data to evaluate human exposure and health impacts. The data exhibits only include tissue samples from fish meeting legal catch requirements as defined by the Louisiana Department of Wildlife and Fisheries. The Calcasieu River Estuary Biological Monitoring Program, however, does collect fish and shellfish below the legal size limit on occasion. These below-limit specimens were excluded from the data exhibits because they tend to dilute overall concentrations when averaged with fish of legal size. When warranted, however, individual specimens that do not meet legal catch requirements are noted in the results discussion.

2 The data in this report reflect the Calcasieu River Estuary Biological Monitoring Program's Year 1 through Year 6 sampling results. After NOAA released a draft of this report, the monitoring program's Year 7 sampling data were released. In addition, in comments to this report, PPG Industries provided a review of the first two quarters of Year 8 sampling data.

3 Data for hexachloroethane in Red Drum were taken from the Year 5 Annual Report due to data omissions in the Year 6 report. As a result, these data only cover 1989 to 1994.

6-7

Principle Findings This section summarizes the principle findings of the fish and shellfish tissue analysis. Particular emphasis is placed on maximum contaminant concentrations and spatial trends. Exhibit 6-5, which presents maximum contaminant concentrations measured at each of the eleven sampling stations, provides the basis for this discussion; however, data from Exhibits 6-6 through 6-16 also are summarized where applicable. Exhibit 6-5 indicates that Bayou d'Inde and the PPG Canal contain the most contaminated fish and shellfish in the Calcasieu system. Of the thirteen contaminants measured, twelve were found at the highest concentrations in the PPG Canal or in the lower portion of Bayou d'Inde. Further, all contaminants measured in excess of 1 ppm were collected from Bayou d'Inde or the PPG Canal. The contaminants with the highest concentration included hexachlorobenzene (1.2 ppm), hexachlorobutadiene (11.6 ppm), and pentachlorobenzene (2.2 ppm), all of which were in samples collected from Bayou d'Inde or the PPG Canal. Although fish tissue contamination is highest in Bayou d'Inde and the PPG Canal, Exhibit 6-5 and the data in Exhibits 6-6 through 6-16 also indicate that certain compounds are found in fish throughout the estuary. Hexachlorobutadiene, 1,2-dichlorobenzene, 1,3-dichlorobenzene, and 1,2,3,4-trichlorobenzene were measured at or above 100 ppb as far south as Calcasieu Lake and the Gulf of Mexico. Four contaminants (Aroclor 1254, 1,2-dichlorobenzene, 1,2,4-dichlorobenzene, and 1,2,3,4-trichlorobenzene) also were measured at or above the 100 ppb level upstream of Bayou d'Inde. These results are consistent with presumptions regarding fish mobility and bioaccumulation. These results also emphasize the wide-distribution of contaminated fish and shellfish within the estuary. Species analysis indicates that Blue Catfish and Channel Catfish are the most contaminated species within the estuary. Out of the thirteen contaminants measured, catfish had the highest concentrations for eleven. Blue Crab and Spotted Seatrout samples contained the highest measured concentrations for the two remaining contaminants (1,2,3-trichlorobenzene and 1,2,4-trichlorobenzene, respectively). Other species that exhibited high levels of contamination with less frequency include Red Drum, Southern Flounder, and Oyster.

6-8

Exhibit 6-5

MAXIMUM CONTAMINANT CONCENTRATIONS ACROSS STATIONS PPB Edible Tissue (wet weight)

Station Number

1 2 3 4 5 6 7 8 9 10 11

Hexachlorobenzene 7 36 958 1,230 329 126 74 68 40 50 7

Hexachlorobutadiene 30 76 8,730 11,600 700 252 219 269 126 314 5

Aroclor 1254 20 131 367 314 293 186 112 46 57 42 33

Pentachloroethane 5 5 97 73 11 5 5 13 4 7 3

Hexachloroethane 5 5 122 176 9 6 5 11 9 7 5

1,2-Dichlorobenzene 63 127 400 84 106 246 180 72 163 440 248

1,3-Dichlorobenzene 26 26 400 36 63 44 26 71 40 126 26

1,2,3-Trichlorobenzene 2 7 100 100 29 4 5 13 8 18 2



1,2,3,4-Tetrachlorobenzene 100 36 304 532 146 43 42 117 99 99 73

1,2,4,5-Tetrachlorobenzene 12 8 46 147 32 14 5 16 27 15 88

Pentachlorobenzene 6 17 1,770 2,240 529 55 30 52 38 60 19

Station Identification 1 Calcasieu River above salt water barrier 7 Moss Lake 2 Lake Charles 8 Calcasieu Lake near West Pass, North Turner's Bay 3 PPG Discharge Canal 9 Lower Calcasieu Lake, south of Comisary Point 4 Bayou d'Inde -- PPG Canal to the Calcasieu River 10 Calcasieu Lake, West Cove 5 Calcasieu River near Bayou d'Inde 11 Near-shore Gulf of Mexico 6 Prien Lake

6-9

In 1994, PPG isolated a portion of the PPG Canal suspected of containing significant sediment contamination. At the time the Year 6 results were released, the Calcasieu River Estuary Biological Monitoring Program had conducted three scheduled quarterly samplings of the estuary since the completion of the bypass. In the Year 6 Annual Report, the Calcasieu River Estuary Biological Monitoring Program presents the results of a nonparametric comparison of pre- and post-bypass contamination levels. This analysis concludes that hexachlorobenzene concentrations are significantly lower for three species now that the by-pass is in place (95 percent confidence). Analysis of hexachlorobutadiene found that seven species had significantly lower concentrations after the canal by-pass was constructed (95 percent confidence). Findings of no significant difference in pre- and post-bypass concentrations were identified in eight species for hexachlorobenzene, and in four species for hexachlorobutadiene.4 Contaminant-Specific Results This section analyzes fish and shellfish tissue data by contaminant. The discussion, which is more detailed than the summary results above, identifies contaminant trends and highlights spatial variations within species. Exhibits 6-6 through 6-16, which are located at the end of this chapter, provide the basis for this discussion. Hexachlorobenzene (HCB) The maximum HCB concentration was measured at 1,230 ppb in a Blue Catfish sample from Bayou d'Inde (station 4). The PPG Canal (station 3) also was contaminated by HCB, with mean concentrations in excess of 100 ppb for all species except Spotted Seatrout. Outside of Bayou d'Inde HCB concentrations were lower, with mean concentrations above the bayou ranging from non-detect to 7 ppb, and mean concentrations below the bayou ranging from non-detect to 25 ppb. Hexachlorobutadiene (HCBD) The maximum HCBD concentration was measured at 11,600 ppb in a Blue Catfish sample from Bayou d'Inde (station 4). This was the highest measured concentration of any contaminant at any sampling station in the estuary. Mean concentrations for all species in Bayou d'Inde and the PPG Canal (except Blue Crab) exceeded 100 ppb, and frequently exceeded 1,000 ppb. Individual samples in the bayou and canal exceeding 1,000 ppb were measured in Southern Flounder, Red Drum, Blue Catfish, Channel Catfish, Spotted Seatrout, and White Shrimp. The highest HCBD concentration for Red Drum was measured at nearly 4,000 ppb in a below-legal

4 In comments to a draft of this report, PPG Industries presents additional analysis of pre- and post-bypass fish tissue concentrations using data collected through the first two quarters of Year 8. Interested parties may obtain PPG's comments and analysis by contacting NOAA at the address listed in the Preface to this report.

6-10

limit specimen. A Spotted Seatrout sample and a Blue Catfish sample from Prien Lake (station 6) were measured at 140 and 252 ppb respectively. Also of note was the degree to which HCBD was detected in samples below Bayou d'Inde. Maximum concentrations of 219, 269, 126, and 314 ppb were detected in Spotted Seatrout and Sand Seatrout between Moss Lake (station 7) and Calcasieu Lake's West Cove (station 10). HCBD was detected in lower concentrations above Bayou d'Inde. Polychlorinated biphenyls (PCBs) The Calcasieu River Estuary Biological Monitoring Program analyzes tissue samples for PCBs as Aroclor mixtures 1016, 1221, 1232, 1242, 1248, 1254, and 1260. Of the seven Aroclors analyzed, 1254 is the only mixture commonly detected (Aroclor 1260 was detected in only one sample). Therefore, this discussion and the data exhibits only present concentrations for Aroclor 1254. The maximum Aroclor 1254 concentration was measured at 367 ppb in a Channel Catfish sample from the PPG Canal (station 3). Mean concentrations in the PPG Canal for all species except Southern Flounder exceeded 100 ppb. Although PCB contamination is most evident in Bayou d'Inde and the PPG Canal, Aroclor 1254 was also detected both above and below Bayou d'Inde. Mean concentrations above the bayou ranged from 10-53 ppb, reaching a high of 131 ppb in a Spotted Seatrout in Lake Charles (station 2). Mean concentrations below the bayou ranged from approximately 10-39 ppb, with a maximum concentration of 112 ppb in a Moss Lake Blue Crab (station 7). Spotted Seatrout and Blue Crab samples were measured at 186 and 157 ppb respectively in Prien Lake (station 6). Pentachloroethane (PCE) Pentachloroethane was not detected outside of the PPG Canal and Bayou d'Inde. The maximum PCE concentration was measured at 97 ppb in a Blue Catfish sample from the PPG Canal (station 3). Hexachloroethane (HCE) The maximum hexachloroethane concentration was measured at 176 ppb in a Blue Catfish sample from Bayou d'Inde (station 4). HCE was not detected above 11 ppb in any sample outside of Bayou d'Inde and the PPG Canal.

6-11

1,2-Dichlorobenzene (1,2-DCB) 1,2-DCB contamination was wide-spread throughout the Calcasieu Estuary, especially below Bayou d'Inde. The maximum 1,2-DCB concentration of 440 ppb was measured in an Oyster sample taken from Calcasieu Lake's West Cove (station 10). This is noteworthy in that it is the only contaminant where the maximum concentration was recorded outside of Bayou d'Inde or the PPG Canal. Other measurements below Bayou d'Inde in excess of 100 ppb include: 180 and 131 ppb in Moss Lake (station 7), 239 ppb in a below-legal limit sample from West Pass in Calcasieu Lake (station 8), 195 ppb in a below-legal limit sample from Lower Lake Calcasieu (station 9), 162 ppb in a below-legal limit sample from Calcasieu Lake's West Cove (station 10), and 248 ppb in the Gulf of Mexico (station 11). Above Bayou d'Inde (station 2), concentrations of 113, 127, and 299 ppb were measured in Spotted Seatrout, White Shrimp, and below-legal limit Black Drum samples respectively. A Spotted Seatrout sample from Prien Lake (station 6) measured 246 ppb. Within Bayou d'Inde, the highest 1,2-DCB concentration was measured at 106 ppb in a Blue Crab. In the PPG Canal, a Channel Catfish sample was measured at 400 ppb. 1,3-Dichlorobenzene (1,3-DCB) The maximum 1,3-DCB concentration was measured at 400 ppb in a Channel Catfish from the PPG Canal. 1,3-DCB was detected in lower concentrations outside of the PPG Canal. 1,2,3-Trichlorobenzene (1,2,3-TCB) The maximum 1,2,3-TCB concentration was measured at 100 ppb in two Blue Crab samples, one from the PPG Canal and one from Bayou d'Inde. 1,2,3-TCB was not detected above Bayou d'Inde; 30 ppb was the maximum concentration (Blue Crab) below Bayou d'Inde. 1,2,4-Trichlorobenzene (1,2,4-TCB) 1,2,4-TCB was the most frequently detected of the trichlorobenzene isomers. The maximum concentration was measured at 351 ppb in a Spotted Seatrout sample from the PPG Canal. Mean concentrations in the PPG Canal ranged from 20 ppb for Southern Flounder to 185 ppb for Spotted Seatrout. Two Blue Crab samples from Bayou d'Inde and the PPG Canal were measured at 272 ppb. Above Bayou d'Inde, a Blue Catfish sample from Lake Charles (station 2) was measured at 110 ppb. 1,2,4-TCB was generally detected at lower levels below Bayou d'Inde.

6-12

1,3,5-Trichlorobenzene (1,3,5-TCB) The maximum 1,3,5-TCB concentration was measured at 840 ppb in a Blue Catfish sample from Bayou d'Inde. Other notable concentrations include measurements of 589 ppb in a Channel Catfish and 498 ppb in a Red Drum, both from the PPG Canal. Concentrations were seasonal, peaking in the winter. 1,3,5-TCB contamination was confined to the PPG Canal and Bayou d'Inde. 1,2,3,4-Tetrachlorobenzene (1,2,3,4-TECB) The maximum 1,2,3,4-TECB concentration was measured at 532 ppb in a Blue Catfish sample from Bayou d'Inde. Mean concentrations in the PPG Canal ranged from 45-125 ppb. 1,2,3,4-TECB was noteworthy in that it was observed in concentrations in excess of 100 ppb in seven of the eleven sampling stations. Only HCBD and 1,2-DCB were identified at more stations at concentrations of 100 ppb or more. Samples containing in excess of 100 ppb occurred both above (station 2) and below (stations 8,9,10) Bayou d'Inde. 1,2,4,5-Tetrachlorobenzene (1,2,4,5-TECB) The maximum 1,2,4,5-TECB concentration was measured at 147 ppb in a Blue Catfish sample from Bayou d'Inde (a Red Drum below-legal catch limits was measured at 208 ppb in the PPG Canal). The highest 1,2,4,5-TECB concentration below Bayou d'Inde was measured at 88 ppb in a Spotted Seatrout sample from the Gulf of Mexico (station 11). Concentrations above Bayou d'Inde did not exceed 12 ppb. Pentachlorobenzene (Penta-CB) Penta-CB was the most commonly detected chlorinated compound. The maximum concentration was measured at 2,240 ppb in a Blue Catfish sample from Bayou d'Inde. The mean concentration for Blue Catfish in Bayou d'Inde exceeded 1,200 ppb with an upper 90 percent confidence limit of 2,256 ppb. Other species within Bayou d'Inde also contained Penta-CB, with individual samples frequently measured in the 200-1,700 ppb range. Within the PPG Canal, mean concentrations for all species exceeded 100 ppb. Penta-CB concentrations were lower above and below Bayou d'Inde.

PART II

FACILITY REVIEW

7-1

FACILITY REVIEW CHAPTER 7 Part II (Chapter 7) reviews the operations and waste disposal activities of nine chemical manufacturers and petroleum refineries in the Calcasieu Estuary. As requested by Task Order 56-DGNC-5-50107, these facilities include PPG Industries, Conoco, Citgo/Cit-Con, Vista, Olin, OxyChem, Westlake, Firestone, and W.R. Grace. The location of each facility is shown in Exhibit 7-1. In addition to the nine specified facilities, the estuary receives waste water from numerous permitted sources as well as urban and agricultural stormwater runoff. Therefore, the report's focus on these firms is not a comprehensive inventory or review of all discharges within the Calcasieu Estuary. Further, Part II of the report does not establish or limit the potential liability of any firm within the Calcasieu Estuary that has or continues to release to the environment. Part II contains ten sections. The first section discusses the data sources and methods used to compile the facility reviews. Each of the nine remaining sections contains an independent and self-contained review of each industrial facility. These reviews follow a similar structure. First, we provide a brief site history for the facility and inventory the principle products and production processes. We then summarize waste water information such as treatment processes, effluent monitoring results, and the facility's compliance record. The last section of each review characterizes hazardous waste generation and contamination at the facility. DATA SOURCES AND METHODS Data for the facility reviews were collected from EPA Region 6 in Dallas, Texas and the Louisiana Department of Environmental Quality (LDEQ) in Baton Rouge, Louisiana. At EPA, we reviewed files from the CERCLA and RCRA file rooms. At LDEQ, we reviewed files at the Water Quality Management, Ground Water, and Hazardous Waste Divisions. We also used a variety of petroleum refining and chemical industry reference sources.

7-3

The majority of information contained in the facility reviews comes from six sources:

• RCRA Facility Investigations; • NPDES permits; • Facility Profile Sheets; • Effluent studies; • Plant studies; • Chemical manufacturing references, and; • Industry comments on the draft report.

Data availability varied considerably across facilities. Typically, the volume and quality of information reflected facility size and complexity. As a result, the largest volume of data existed for PPG, Citgo, Conoco, and Vista. Less information was available for Olin, Firestone, Westlake, OxyChem, and W.R. Grace. Although each review is generally parallel in structure, data availability and firm complexity were important determinants in the specific content of all reviews. Eight of the firms included in this facility review provided comments on and updates to a draft of this report. All technical industry comments regarding the information in Part II have been considered and incorporated into the report as appropriate. It was not always possible, however, to verify specific comments using in-house documentation. In these cases, we incorporate the comment by reference and include the full text of the comment in Appendix A. NOAA may also consider industry comments in any future studies of the Calcasieu Estuary. Part II presents the facility reviews in the following order: (1) PPG Industries (2) Conoco Incorporated (3) Citgo Petroleum Corporation / Cit-Con Oil Corporation (4) CONDEA Vista Company (5) Olin Chemicals (6) OxyChem Petrochemicals (7) Westlake Polymers Corporation (8) Firestone Synthetic Rubber and Latex Company (9) W.R. Grace

7-4

PPG INDUSTRIES1

Site Description and History PPG Industries owns and operates a chemical manufacturing facility located on the west bank of the Calcasieu River at Coon Island Loop in Calcasieu Parish, Louisiana. The current PPG location originally served as a base for shipbuilding and lumber production. In the early 1940s, the U.S. government purchased the site and constructed a plant to manufacture magnesium during World War II. Matheson Alkali Works, the predecessor to Olin Chemical Company, operated the facility for the government until 1947. At that time, Southern Alkali Corporation, a joint subsidiary of Pittsburgh Plate Glass and American Cyanamid, purchased the facility to manufacture chlorine and caustic soda. PPG subsequently acquired full ownership of the subsidiary, and in 1968, changed the corporation's name to PPG Industries.

The PPG plant currently occupies approximately 700 acres. The facility is roughly bounded by Coon Island Loop on the east, Bayou Verdine to the northeast, U.S. Interstate 10 on the north, and U.S. Interstate 210 on the southwest. PPG began manufacturing chlorine at the facility in October of 1947. In 1960, PPG began manufacturing chlorinated hydrocarbons with the addition of a 1,2-Dichloroethane (EDC) unit. Since that time, PPG has expanded its operations on several occasions, including the addition of a mercury cell unit in 1968, a chlorine facility in 1978, and a vinyl chloride complex in 1981. The PPG facility is divided into three main operating areas based on the type of chemical production. These include the Chlor-Alkali plant (Plant A), the Derivatives area (Plant B), and the Chlor-Alkali/Silicas area (Plant C). Other areas of the facility include the North Dock and South Terminal, which are used to store and transfer finished product to ships and barges. These areas, as well as PPG's RCRA solid waste management units, are shown in Exhibit 7-2. Products and Production Processes

PPG currently produces chlorine, sodium hydroxide, precipitated silicas, and a wide range of chlorinated hydrocarbons such as ethylene dichloride (EDC) and vinylidene chloride (VDC). PPG's production processes are highly integrated, with many of the products being co-produced or serving as feedstocks in the production of other compounds. EDC is particularly important, serving as the primary intermediate for 1,1-dichloroethene, perchloroethylene, and trichloroethylene among others. Exhibit 7-3 lists the products produced at the PPG facility. PPG's primary products, their feedstocks, and production methods, are briefly outlined in Exhibit 7-4.

1 See Appendix A Comment 1(a).

7-6

Exhibit 7-3

COMPOUNDS PRODUCED AT THE PPG FACILITY

Chlorine Sodium hydroxide (caustic soda)

Hydrogen Hydrochloric acid Methyl chloroform Precipitated silicas

1,2-Dichloroethane (EDC) Vinyl chloride monomer (VCM)

1,1-Dichloroethene (Vinylidene chloride or VDC) Ethyl chloride

1,1,1-Trichloroethane 1,1,2-Trichloroethane

Tetrachloroethene Trichloroethene

trans-1,2-Dichloroethene Chloropivaloyl chloride (CPC)

Perchloroethylene (Per) Trichloroethylene (Tri)

Source Summary of Sitewide Characterization, Phase II Draft Sitewide RFI Report. International Technology Corporation, January 1995.

PPG Industries Facility Profile Sheet, Draft Report. DPRA, August

31, 1995.

Exhibit 7-4

PPG's PRIMARY PRODUCTION PROCESSES

Product Process Feedstocks

1,2-Dichloroethane (EDC) Oxyhydrochlorination Ethylene Hydrogen chloride

Vinyl chloride monomer (VCM) Pyroltic dehydrochlorination EDC

1,1,2-Trichloroethane Chlorination VCM

1,1-Dichloroethene (Vinyldene chloride or VDC)

Dehydrochlorination 1,1,2-Trichloroethane Sodium hydroxide

Perchloroethylene (Per) Chlorination EDC

Trichloroethylene (Tri) Chlorination EDC

Source PPG Industries Facility Profile Sheet, Draft Report. DPRA, August 31, 1995. Manufacture of Chlorinated Organics. Chem Systems, Inc., July 1981. Chlorinated Hydrocarbon Manufacture: An Overview. Acurex Corporation, January 11, 1980.

7-7

NPDES Summary PPG holds NPDES permit LA0000761 which authorizes PPG to discharge process waste water via designated outfalls to Bayou d'Inde (Outfall 001), the Calcasieu River (Outfalls 002 and 003), and Bayou Verdine (Outfall 004). PPG also has several internal process sewers that are subject to permit conditions (Outfalls 101, 201, 301, 401, 501). PPG's permit includes discharge limits for total suspended solids (TSS), biological oxygen demand (BOD), pH, total organic carbon (TOC), total residual chlorine (TRC), mercury, copper, lead, and a wide range of volatile and semivolatile organic compounds.2 Although PPG's permit has historically required monitoring for total chlorinated hydrocarbons, specific testing for hexachlorobenzene (HCB) and hexachlorobutadiene (HCBD) was not required until 1991. Outfall 001 is PPG's main effluent route, discharging treated process waste water generated by the plant's primary production units, including waste water from organic chemical production. Outfall 001 discharges into the PPG Canal and Bayou d'Inde. Historically, wastes were delivered to outfall 001 by PPG's 201 sewer. This sewer originates in Plant C (Chlor-Alkali/Silicas), flows through Plant B (Derivatives), and empties into a neutralization basin just upstream of the PPG Canal. The 201 sewer collects process wastes from Plant C (Chlor-Alkali/Silicas), incinerator scrubbers, and the plant's waste treatment unit (WTU). The WTU's steam strippers treat process wastes received from Plant B (Derivatives). Around 1993, the 201 sewer was designated a RCRA solid waste management unit and was replaced by an above ground piping system. PPG's 101 sewer also discharges to Outfall 001, contributing chlor-alkali, mercury cell, and caustic waste water from Plant A (Chlor-Alkali). The 101 and 201 sewer discharges mix via the neutralization basin before entering the PPG Canal. The average combined discharge of Outfall 001 is approximately 160,000 gallons per minute (gpm). This includes approximately 7,000 gpm from the 201 sewer, 23,100 gpm from Plant A and the 101 sewer, and an additional 129,000 gpm of once-through cooling water from the Plant A powerhouses. The Silicas Ditch enters the PPG Canal further downstream and contributes approximately 720 gpm. Outfalls 002 and 003 discharge plant runoff, catch basin effluent, washdown, and storage tank overflow to the Coon Island Loop of the Calcasieu River. Outfall 003 also discharges small volumes of once-through cooling water. Outfall 003 has a flow rate of approximately 375 gpm.3 Outfall 004 discharges into Bayou Verdine. In addition to plant runoff, catch basin effluent, washdown, and storage tank overflow, Outfall 004 is the primary discharge for once-through cooling water from Plant A. Outfall 004 has a flow rate of approximately 25,000 gpm.

2 See Appendix A Comment 1(b).

3 See Appendix A Comment 1(c).

7-8

Effluent Monitoring The authors of the Toxics Study of the Lower Calcasieu River (RTI 1990) collected and analyzed effluent from PPG Outfalls 001 and 004 in 1988. Heavy metals and organic compounds were identified in PPG's outfalls during these tests. Exhibit 7-5 shows all of the compounds detected during the 1988 sampling. Several of the contaminants found in the 001 effluent also were found at high concentrations in the sediments of the PPG Canal. These include: 1,2-dichloroethane, 1,1,2,2-tetrachloroethane, trichloroethene, and tetrachloroethene. One contaminant from Outfall 004, 1,2-dichloroethane, was also found in the sediments of Bayou Verdine and the Coon Island Loop near PPG (although 1,2-dichloroethane contamination was found in other areas of Bayou Verdine as well).

Exhibit 7-5

RESULTS OF PPG EFFLUENT TESTS, 1988

Outfall Parameter Concentration (ppm)

001 Zinc Iron Aluminum Manganese Barium Chlorodibromomethane Bromoform Chloroform 1,2-Dichloroethane 1,1,2,2--Tetrachloroethane Trichloroethene Tetrachloroethene

0.010 0.193 0.167 0.089 0.141 0.021 0.218 0.021 0.012 0.008 0.004 0.014

004 Zinc Iron Aluminum Manganese Barium Bromoform 1,2-Dichloroethane Di-N-Butylphthalate

0.117 0.163 0.109 0.155 0.091 0.004 0.006 0.003

Source Toxics Study of the Lower Calcasieu River. RTI, March 1990.

7-9

NPDES Compliance History Exhibit 7-6 summarizes PPG's NPDES compliance history for chlorinated hydrocarbons and heavy metals through May of 1995. Miscellaneous spills and accidents also are included when contaminants were discharged directly to surface waters. Permit exceedances for TSS, BOD, pH, TOC, and TRC are not included in this review. Exhibit 7-6 identifies several waste water outfalls that have been upgraded or renamed. The current internal sewer systems (Outfalls 101, 201, 301, 401, and 501) have been in place since 1988.

Exhibit 7-6

PPG NPDES COMPLIANCE HISTORY

Date Location/Outfall Parameter 10/79 011

017 018 019

Mercury Lead

ClCH ClCH

1/81 Unknown Mercury 7/81 - 12/81 Unknown Mercury 11/81 014 Lead 1981/1982 Pond overflow to 001 Lead wastes 3/82 - 8/82 001, 005, 011, 014, 017, 019, 024 Lead 5/82 001, 010, 017, 018, 118 ClCH, Lead (multiple violations) 7/83 - 10/83 001, 005, 011 Mercury 6/83 Unknown ClCH 8/83 001, 011, 018 ClCH 2/9/84 Unauthorized discharge Vinyl chloride, 1,100 lbs. 5/18/84 Unauthorized discharge Vinyl chloride, 3,000 lbs. 1/22/85 Spill to 013 and 001 Trichloroethylene, 4,300 lbs. 2/3/85 Spill to 001 Sodium hydroxide (50%), 2,300 lbs. 4/26/85 Spill 1,1,1-Trichloroethane, 50 lbs. 4/22/87 Spill to Coon Island Loop EDC, 3,200 lbs. 11/87 Unauthorized discharge ClCH, 424 lbs. 1/88 Spill EDC, Perchloroethylene, Trichloroethylene,

1,1,2,2-Tetrachloroethylene 2/88 201 ClCH 11/17/88 Unauthorized Release to

Calcasieu River Waste water containing 2,485 lbs. F024

Hazardous Waste 12/23/88 Sabine Water Pond 11,950 lbs. ClCH contaminated waste water 12/23/88 Spill to 301 ClCH, 383 lbs, 12/88 101 Mercury 1/89 101

201 Mercury

Copper (multiple violations) 2/89 201 Nickel; Copper 2/7/89 Spill to Bayou Verdine Sodium hydroxide, 1,000 lbs. 2/89 201 ClCH

Copper 4/89 201 Copper 5/89, 6/89 201 ClCH 9/89 201 ClCH

10/89

201

Copper ClCH

7-10

Exhibit 7-6

PPG NPDES COMPLIANCE HISTORY Date Location/Outfall Parameter

11/89 201 ClCH 6/9/90 Spill to Coon Island Loop Sodium hypochlorite, 3,488 lbs. 7/16/90 Spill to Coon Island Loop Sodium hypochlorite, 75,600 lbs. 12/22/90 Spill to PPG Canal

Spill to Coon Island Loop Sodium hypochlorite, 160 lbs.

EDC blend, 55 lbs. 1/91 201 ClCH 6/91 Spill to 001 Ethylene glycol, 3.4 lbs.

Ethylene glycol, 170 lbs. Ethylene glycol, 17 lbs.

Ethylene glycol, 170 lbs. Sodium hydroxide, 200-8,300 lbs.

7/91 001 Sodium dichlormate, 24.8 lbs. 11/91 - 2/92 101, 201 Mercury 7/92 101 Mercury 9/10/92 Spill to Sabine Water Pond ClCH contaminated water, 1,029 lbs. 2/27/93 Spill to PPG Canal EDC, 2,480 lbs. 4/93 001 ClCH 7/93 501 HCB 8/93 501 HCB 12/93 501 HCB 1/94 501 HCB

HCBD 4/94 Spill to Coon Island Loop EDC, 60 lbs. 7/94 501 HCB Notes ClCH Total Chlorinated Hydrocarbons EDC Ethylene Dichloride (1,2-Dichloroethane) HCB Hexachlorobenzene HCBD Hexachlorobutadiene Source PPG Industries Facility Profile Sheet, Draft Report. DPRA, August 31, 1995.

RCRA Summary RCRA corrective actions under permit number LAD008086506 have been ongoing at the PPG facility since the early 1980s. Over PPG's operating lifetime, chlorinated organic compounds, process materials, and solid wastes have been released to the ground and stored or managed in holding ponds, landfills, and storage tanks. These releases have resulted in soil and groundwater contamination throughout the PPG facility. Primary areas of contamination include the derivatives plant, surge pond, and South Terminal area. Contamination, primarily volatile organic compounds, has been detected in the 10, 20, 36-50, 70-80, and 120 foot water bearing units (WBUs). Perchloroethylene, trichloroethylene, and EDC have also been detected in the Chicot Aquifer. PPG has identified twenty-three solid waste management units (SWMUs) at its Lake Charles facility (Exhibit 7-2). Historical and ongoing releases from these SWMUs have contaminated groundwater, sediments, and surface waters in and around the PPG plant. Given the hydrogeolgic conditions at the PPG facility, it is possible that contaminants from any of these

7-11

SWMUs could potentially migrate to surface waters. This section, however, focuses on three SWMUs that have documented releases to surface waters. PPG Canal The PPG Canal (SWMU 14) originates in the southeast corner of the PPG facility and flows southwest to Bayou d'Inde. The canal's sediments are heavily contaminated with HCB and HCBD as well as other volatile and semivolatile organic compounds. In 1993, PPG estimated that four to six pounds per day of HCB and HCBD were being discharged from canal sediments and plant processes to the water column and Bayou d'Inde. In 1994, PPG rerouted the canal around its most contaminated segment. The isolated segment is now designated as SWMU 15. PPG believes that the canal by-pass has reduced HCB and HCBD discharges by 99 percent. Preliminary results from the fish and shellfish sampling program (Year 6 report) indicate that the canal by-pass may be reducing HCB and HCBD concentrations in some species (see Chapter 6 for a complete discussion of these results). South Terminal Landfill The South Terminal area (SWMU 12) covers approximately three acres in the extreme southeast corner of the plant, adjacent to the Coon Island Loop. The South Terminal consists of barge dock A and a landfill. Historically, the South Terminal area supported several earthen ponds and impoundments, which received and stored chlorinated hydrocarbon wastes, heavy still bottoms, slurry, water treatment sludge, drier resins, and plant scrap. The South Terminal also received dredge spoil from the Coon Island Loop. The ponds were unlined from 1960 to 1976. The ponds and impoundments were closed and removed in the early 1980s. Chlorinated hydrocarbon contamination has been detected in the soils and groundwater of the South Terminal area. The most prevalent compounds are shown in Exhibit 7-7. Compounds not included in the exhibit but that were measured in concentrations greater than five parts per million in soil include: 1,2-dichloroethene, tetrachloroethene, and chloroform.

7-12

Exhibit 7-7

MAXIMUM CONCENTRATIONS DETECTED IN

SOUTH TERMINAL SOILS AND GROUNDWATER, 1993

Compound

Soil (ppm)

Ground Water (ppm)

Hexachlorobenzene (HCB) 158 0.7

Hexachlorobutadiene (HCBD) 1,660 8.9

1,2-Dichloroethane 264 4,560

1,1-Dichloroethene 55 11,280

Trichloroethene 1,460 4,570

Tetrachloroethylene 11,600 1,980

Trichloroethane 2,960 2,030

Tetrachloroethane 4,420 338

Hexachloroethane 166 0.5

Pentachloroethane 153 17

Source Field Investigation to Evaluate the Subsurface Discharge of Constituents from the South Terminal Area Into the Coon Island Reach of the Calcasieu River Ship Channel. IT Corp., January 1993.

In 1993, PPG estimated that approximately 2.9 pounds of chlorinated hydrocarbons were discharged via the groundwater to the Coon Island Loop each day. According to PPG, tetrachloroethane accounted for almost 50 percent of the release. Other compounds included trichloroethane, trichloroethene, tetrachloroethene, dichloroethane, and vinyl chloride. Nearly all of this discharge emanated from the unconfined aquifer. PPG's Riverside Powerhouse has also been identified as a potential source of chlorinated hydrocarbon contamination to the PPG Canal.4

North Dock The North Dock (SWMU 13) covers approximately three acres and is located in the northeast corner of the plant, adjacent to the Coon Island Loop and Bayou Verdine. The North Dock is the plant's primary loading facility and includes barge docks B through E, numerous storage tanks, and transfer pipelines. The North Dock sediments are primarily contaminated with EDC, perchloroethylene, trichloroethylene, vinyl chloride, and tetrachloroethene. Dock E sediment toxicity tests conducted in 1993 resulted in 100 percent mortality.

4 See Appendix A Comment 1(d).

7-13

North Dock discharges to the surface water are primarily through product and raw material releases during barge on-loading and off-loading and accidental spills. Additional discharges have occurred from the 003 outfall which is contaminated with chlorinated hydrocarbons. The soil and groundwater in the North Dock area are also heavily contaminated from accidental spills and leaking underground transfer pipelines. Contaminants from these long-term releases have been detected in all WBUs down to the Chicot Aquifer. The 10 and 20 foot WBUs are in direct hydrologic communication with Bayou Verdine. The 10 foot WBU discharges to Bayou Verdine via two contamination plumes. The first of these plumes extends into the northern end of the North Dock area and is laden with EDC. The second plume extends into the southern end of the North Dock area and is contaminated with perchloroethylene and trichloroethylene. In 1994, PPG estimated groundwater releases to Bayou Verdine from the North Dock area (Exhibit 7-8). PPG believes that remedial groundwater pumping has significantly reduced these discharges from their 1987 rates. Additional contamination is migrating beneath Bayou Verdine and the Coon Island Loop5

PPG Wastes PPG produces chlorinated hydrocarbons through the reaction of hydrocarbon compounds and hydrogen chloride in the presence of a catalyst. This process results in a wide variety of saturated and unsaturated chlorohydrocarbon waste, as well as crude product, by-products, and unreacted raw materials. The composition of these waste streams can vary significantly depending on production process, reaction temperature, catalyst, and feedstock purity. PPG has specified the facility's hazardous wastes in RCRA permits and inspections. These waste categories and the RCRA defined wastes included in each category are listed in Exhibit 7-9.

5 See Appendix A Comment 1(e).

7-14

Exhibit 7-8

ESTIMATED NORTH DOCK DAILY SUBSURFACE DISCHARGES TO BAYOU VERDINE -- 1994

Daily Discharge Contaminant Average (ug/l) Maximum (ug/l) Average (lbs/day)

Hexachlorobutadiene North Plume South Plume

7

NA

14 NA

3.54E-6

NA

Trichloroethene North Plume South Plume

10

10,820

20

37,600

1.26E-6 5.39E-3

Tetrachloroethene North Plume South Plume

750

19,750

1,500

87,250

3.37E-4 1.11E-2

1,2-Dichloroethane North Plume South Plume

58,410

720

200,700

1,980

4.51E-2 3.00E-4

Vinyl Chloride North Plume South Plume

NA

1,600

NA

8,630

NA

8.30E-4

1,1,1-Trichloroethane North Plume South Plume

NA 40

NA 80

NA

8.14E-6

1,1-Dichloroethane North Plume South Plume

5

470

10

800

1.75E-7 2.82E-4

Chloroethane North Plume South Plume

NA 60

NA 120

NA

2.75E-5

trans-1,2-Dichloroethylene North Plume South Plume

1,930

28,380

3,850

72,800

8.67E-4 1.30E-2

TOTAL 1.22E-1

Source Interim Corrective Measures, North Dock Monitoring/Recovery System Evaluation Report. International Technology Corporation, May 1994.

7-15

Exhibit 7-9

RCRA WASTES IDENTIFIED IN PPG PERMITS AND INSPECTION REPORTS

Waste Code Associated Wastes

U002 Acetone, 2-Propanone

U043 Chloroethene

U077 1,2-Dichloroethane

U076 1,1-Dichloroethane

U078 1,1-Dichloroethylene

U079 1,2-Dichloroethylene

U080 Dichloromethane

U159 Methyl Ethyl Ketone

U210 Tetrachloroethylene

U226 Methyl Chloroform

U227 1,1,2-Trichloroethane

U228 Trichloroethylene

U359 Ethylene Glycol

F001, F002 Tetrachloroethylene, Methylene chloride, Trichloroethylene, 1,1,1-Trichloroethane, 1,1,2-Trichloroethane, Chlorobenzene, 1,1,2-Trichloro-1,2,2-Trifluoroethane, Ortho-dichlorobenzene, Trichlorofluoromethane

F005 Toluene, Methyl ethyl ketone, Carbon disulfide, Isobutanol, Pyridine, 2-Ethoxyethanol, Benzene, 2-Nitropropane

F0024, F0025, K018, K019, K020, K028

Chloromethane, Dichloromethane, Trichloromethane, Carbon tetrachloride, Chloroethylene, 1,1-Dichloroethane, 1,2-Dichloroethane, Trans-1,2-Dichloroethylene, 1,1-Dichloroethylene, 1,1,1,2-Tetra-chloroethane, 1,1,2,2-Tetrachloroethane, Tetrachloroethylene, Pentachloroethane, hexachloroethane, Allyl chloride (3-Chloropropene), Dichloropropane, Dichloropropene, 2-Chloro-1,3-butadiene, Hexachloro-1,3-butadiene, Hexachlorocyclopentadiene, Hexachlorocyclohexane, Benzene, Chlorobenzene, Dichlorobenzenes, 1,2,4-Trichlorobenzene, Tetrachlorobenzene, Pentachlorobenzene, Hexachlorobenzene, Toluene, Naphthalene, Chloroform, Vinyl chloride, Vinylidene chloride

K030, K073 Hexachlorobenzene, Hexachlorobutadiene, Hexachloroethane, 1,1,1,2-Tetrachloroethane, 1,1,2,2-Tetrachloroethane, Ethylene dichloride, Chloroform, Carbon tetrachloride, Hexachloroethane, Trichloroethane, Tetrachloroethylene, Dichloroethylene

K095, K096 1,1,2-Trichloroethane, 1,1,1,2-Tetrachloroethane, 1,1,2,2-Tetrachloroethane, 1,2-Dichloroethane, 1,1,1-Trichloroethane, 1,1,2-Trichloroethane

K106, D009 Mercury

Source PPG Industries Facility Profile Sheet, Draft Report. DPRA, August 31, 1995.

7-16

CONOCO INCORPORATED Site Description and History Conoco Incorporated has owned and operated the Conoco Lake Charles Refinery since the early 1940s. The facility is located immediately north of U.S. Interstate 10. Westlake, Louisiana is located immediately east and northeast of the property, and Bayou Verdine borders Conoco on the west. The facility lies in the 100 year flood plain, and is therefore protected by a system of dikes. In 1984, Conoco sold an operating division located northwest of the current refinery (Conoco Chemicals) to CONDEA Vista Chemical Company. The Conoco facility is divided roughly into three areas. These include the refinery, the landfarm, and the dock area. The refinery area includes Conoco's production facilities and an associated tank farm. The refinery comprises the majority of the Conoco plant. The landfarm lies immediately north of Conoco and abuts the city of Westlake. The landfarm is no longer active, but historically stored the facility's hazardous wastes. The Conoco dock area provides access to water transportation via the Clooney Island Loop of the Calcasieu River. The dock area is located southeast of the refinery and is physically separated from the rest of the Conoco plant by U.S. Interstate 10. Products and Production Processes Conoco currently has a crude oil capacity of 220,000 barrels per day. Products include: propane, butane, gasoline, kerosene, diesel, lube oil feedstocks, and petroleum coke. Recovered sulfur is processed into sulfuric acid. Manufacturing processes employed at the plant include atmospheric and vacuum distillation, reforming, catalytic cracking, polymerization, alkylation coking, and coke cleaning. Wastes associated with these products and production processes are discussed in the RCRA Summary. NPDES Summary Conoco holds NPDES permit LA0003026 which authorizes the facility to discharge process waste water and plant runoff to Bayou Verdine and the Calcasieu River. Conoco's process waste water is collected in facility sewers and treated at the waste water treatment plant prior to discharge. Plant runoff from process areas is collected in holding tanks and routed to the waste water treatment facility prior to discharge. Runoff from nonprocess areas of the facility is discharged directly to receiving waters. Conoco's outfalls to Bayou Verdine are designated 001, 002, 004, 006, 007, 008, and 009. Outfalls 003 and 005 discharge to the Calcasieu River. Each of these outfalls is discussed below.

7-17

Outfall 001 and 002 Outfalls 001 and 002 are Conoco's primary waste water outlets. These outfalls discharge treated process water, process area runoff, ballast, crude tank draw, utility water, cooling tower blowdown, and sanitary waste water. Untreated runoff is also discharged through Outfall 002 during periods of heavy rain. Outfalls 003 and 004 Outfall 003 collects and discharges ground water seepage, hydrostatic test water, and storm water from Conoco's East Tank Farm to the Calcasieu River. Outfall 004 discharges hydrostatic test water, and plant runoff from the west central plant area to Bayou Verdine. Both outfalls are monitored for TOC, oil, grease, and pH. Outfall 005 and 009 Outfalls 005 and 009 were designed to discharge sanitary waste water. Soon after designating these outfalls, Conoco began routing the designated waste streams to the plant's waste water treatment facility for discharge thought Outfall 001. Conoco subsequently requested the deletion of Outfalls 005 and 009 from the facility's NPDES permit. Outfall 006 Outfall 006 discharged water from the river solids settling pond. Conoco obtained a portion of the facility's process water from the Sabine River. The settling pond received sediment-laden water that was not suitable for refinery processes. Discharges consisted of clarified underflow. In 1995, Conoco requested that Outfall 006 be deleted from the facility's permit. Outfalls 007 and 008 Outfalls 007 and 008 are internal systems that transport sanitary effluent to the facility's activated sludge unit. These wastes are subsequently processed by the waste water treatment system prior to being discharged through Outfall 001. Effluent Monitoring The authors of the Toxics Study of the Lower Calcasieu River (RTI 1990) collected and analyzed effluent from Conoco outfall 001 in 1988. Several heavy metals, including selenium, manganese, barium, and zinc were detected in the effluent. Organic compounds detected in Conoco's waste stream included acenaphthene, pyrene, phenols, and dimethyl-disulfide. In

7-18

1989, Conoco also conducted effluent analysis at Outfall 001. Similar to the RTI analysis, Conoco detected selenium, barium, and zinc. Unlike the RTI study, however, Conoco did not detect any organic compounds. Detection limits for organics in the Conoco study generally ranged from 5 to 20 parts per billion. Exhibit 7-10 summarizes the results of the 1988 and 1989 sampling programs.

Exhibit 7-10

RESULTS OF CONOCO EFFLUENT TESTS OUTFALL 001

Date

Parameter

Concentration (ppm)

1988 Selenium Selenium (D) Zinc Zinc (D) Iron Iron (D) Aluminum Manganese Manganese (D) Barium Barium (D) Bis (2-Ethylhexyl) Phthalate Acenaphthene Pyrene Phenols Dimethyl-Disulfide

0.126 0.105 0.065 0.013 0.699 0.053 0.604 0.233 0.206 0.099 0.059 0.023 0.010 0.006 0.029 0.072

1989 Selenium Zinc Barium

0.102 0.168 0.116

Notes D Dissolved Source Toxics Study of the Lower Calcasieu River. RTI, March

1990.

NPDES Compliance History Conoco's NPDES compliance history was only available for the period January 1981 through March 1992. Overall, NPDES violations were numerous during this period; however, the majority of permit exceedances were for TSS, BOD, pH, and fecal coliform. Conoco also had frequent violations for oil and grease. Between 1986 and 1992, Conoco reported violations

7-19

of the oil and grease permit limit more than 20 times, with an average excursion of more than 540 pounds per day. The discharge limit for phenols was exceeded on one occasion in 1987 (+7 lbs./day). Conoco also conducts toxicity testing using sheepshead minnow and mysidopsis bahia. Toxicity was first measured in Conoco's effluent in the mid-1980s. By 1990, continuing toxicity prompted monthly biomonitoring requirements and the design of a toxicity reduction program. Between 1990 and 1992, effluent toxicity problems persisted, and as of the last date in the compliance history (March 1992), Conoco had not corrected the toxicity problem. Specific information on the source of the toxicity was not available. Conoco also has reported numerous spills at the Lake Charles refinery. In addition to production area discharges, spills have occurred during the loading and unloading of barges at Conoco's dock area. Exhibit 7-11 reports spills that may have been released directly or indirectly to surface waters.

Exhibit 7-11

SPILLS REPORTED AT CONOCO

Date Location Parameter Deviation

11/81 Spills to Calcasieu River and Bayou Verdine

Multiple spills of contaminated waste water, product, oil, sump wastes.

U

4/86 Spill to Clooney Island Loop Kerosene 2-5 barrels

6/86 Spill to Clooney Island Loop Kerosene 10-15 barrels

8/87 Spill to Clooney Island Loop Diesel U

11/87 Spill to Clooney Island Loop Oil 3-5 gal.

12/87 Spill to Clooney Island Loop Diesel 2-5 barrels

2/88 Spill to Clooney Island Loop Naphtha 1-2 barrels


7/88 Spill to Clooney Island Loop Slop oil 2-3 barrels

8/88 Spill to drainage ditch Oil 5 gal.


6/91 U Diesel 122 barrels

1993/1994 Underground Pipeline Spill with Releases to Clooney Island Loop

1,2-Dichloroethane (EDC) 1.6 million lbs.

Notes U Unknown Source Conoco Incorporated Facility Profile Sheet, Draft Report. DPRA, September 11, 1995.

7-20

RCRA Summary Conoco holds RCRA permit LAD990683716. Historically, Conoco managed hazardous wastes on-site, at the plant's landfarm and surface impoundment. Although Conoco's land-disposal units are now inactive, releases to the soil and ground water have occurred. Constituents identified in Conoco's soils and ground water include: chromium, copper, barium, benzene, toluene, xylene, 1,2-dichloroethane, 1,1,1-trichloroethane, and ethylbenzene. Primary sources of these releases are the North and South Landfarms and the In-Plant Waste Management Unit. Other waste management units with the potential for off-site impacts include the slop oil tanks, waste tanks, and the Oily Waste Disposal Area. These waste management units are discussed in detail below. Land Treatment Unit -- North and South Landfarms The Land Treatment Unit is located on the north side of the Conoco facility and is abutted by residential development immediately to the east. The Land Treatment Unit was constructed in 1969 and is unlined, but has a natural clay bottom. According to a 1987 RCRA Facility Assessment, there is high potential for release from the unit to ground water and surface water. The Land Treatment Unit consists of two areas. These include the North Landfarm (7 acres) and the South Landfarm (11 acres). The North Landfarm received hazardous wastes, including separator bottoms (K051), waste water treatment sludge, sloppy oil emissions solids (K049), dissolved air flotation sludge (K048), and leaded tank bottoms (K052). The wastes deposited at the South Landfarm are considered nonhazardous. The landfarms have not received waste since 1988. Contaminants detected in shallow ground water from the landfarms include: barium (0.757 ppm), chromium (0.024 ppm), lead (0.062 ppm), xylene (0.006 ppm), total organic carbon (6.8 ppm), and total organic halides (0.45 ppm). Soil samples have identified phenol (482 ppm), toluene (0.33 ppm), and naphthalene (1,700 ppm). Contaminants identified in the North Landfarm's wastes, including maximum concentrations, are summarized in Exhibit 7-12. In-Plant Waste Management Unit (IPWMU) The IPWMU was an unlined surface impoundment constructed in 1945 to store copper-chromium wastes and catalytic polymerization catalyst. In 1987, a RCRA Facility Assessment indicated that the IPWMU had high potential to release to ground water. Furthermore, Bayou Verdine flows within 500 feet of the unit. Wastes were removed from the IPWMU in 1987, and an equalization tank has been constructed over the site.6


7-21

Exhibit 7-12

COMPOUNDS DETECTED IN LANDFARM WASTES

Metals, Oil & Grease, Chloride Volatile Organic Compounds Semi-Volatile Organic Compounds

Parameter Maximum

Concentration (ppm)

Parameter

Maximum Concentration

(ppm)

Parameter


(ppm)

Oil & Grease 2,700.00 Benzene 7.70 Phenol 3.80

Chloride 1,100.00 Toluene 21.00 Naphthalene 140.00

Arsenic 0.30 Chlorobenzene 2.00 Phenanthrene 59.00

Barium 16.00 Ethylbenzene 8.50 Anthracene 28.00

Beryllium 0.11 Styrene 3.70 Fluoranthene 24.00

Cadmium 0.67 Total Xylenes 17.00 Pyrene 31.00

Cobalt 0.50 Methyl Ethyl Ketone 2.10 Benzo(a)Anthracene 8.00

Chromium 0.09 Chrysene 25.00

Lead 2.10 Benzo(b)Fluoranthene 13.00

Nickel 3.30 Benzo(k)Fluoranthene 13.00

Selenium 0.40 Benzo(a)Pyrene 7.00

Vanadium 1.00 Dibenzo(a,h,)Anthracene 1.40

Mercury 0.010 2-Methyl Naphthalene 280.00

1-Methyl Naphthalene 400.00

Source Conoco Lake Charles Refinery Preliminary RCRA Facility Investigation. Remediation Technologies, Inc, May 1990.

7-22

The contents of the IPWMU produced a phosphoric acid waste water that has contaminated area soils and ground water. In the past, toluene, xylene, methyl ethyl ketone, and 1,1-dichloroethane have been detected in ground water beneath the IPWMU. Exhibit 7-13 summarizes available ground water data. Slop Oil Tanks (T-120, T-104, and T-114) and Waste Tanks (T-6, T-7, and T-8) The waste and slop tanks collect and store crude desalter slop oil, oil from water draws, or gas tank bottom waters. Waste analysis of tank contents have found heavy metals, volatile organics, and semivolatile organics nearly identical to those found in the landfarms and IPWMU. Past releases have occurred from the slop oil tanks. The 1987 RCRA Facility Investigation indicated that a moderate risk of release to ground water currently exists, but that potential for release to surface water is low. Oily Waste Disposal Area The Oily Waste Disposal Area consisted of several 200 foot long trenches covering about 1.4 acres. The area, which is now closed and partially covered by a concrete pad, stored coker blowdown sludge. All visible contamination was removed in 1983; however, past ground water and surface water impacts are probable. Conoco Wastes Conoco generates, handles, treats, and disposes of large volumes of petroleum refining wastes. Past waste management practices have resulted in releases to the environment. Exhibit 7-14 summarizes the wastes generated at Conoco along with constituents typically found in these wastes.

7-23

Exhibit 7-13

COMPOUNDS DETECTED IN GROUND WATER AT THE IPWMU (ppm)

Parameter 1988 1991 1994

Barium 2.500 0.800 0.040

Chromium 0.120 0.170 0.010

Copper 0.070 ND ND

Lead ND 0.450 0.007

Silver 0.050 ND ND

Benzene 0.042 0.054 ND

Ethylbenzene 0.011 0.039 ND

Toluene 0.014 0.310 ND

Xylene 0.033 0.160 ND

1,1-Dichloroethane 0.011 0.008 ND

1,1,1-Trichloroethane 0.0072 NA NA

Note ND Not Detected NA Not Analyzed Source Conoco Incorporated Facility Profile Sheet, Draft Report. DPRA, September 11,

1995. Site Inspection for Bayou Verdine, Final Report. PRC, May 16, 1994. Comprehensive Monitoring Evaluation Inspection Report, Conoco Petroleum

Refinery. LDEQ, February 21-22, 1995.

7-24

Exhibit 7-14

CONOCO WASTES

Wastes Waste Constituents

Tertiary Dissolved Air Flotation Sludge Activated Sludge Unit Waste Solids Waste Water Treatment Basin Sludge Primary Dissolved Air Flotation Sludge (K048) API Separator Sludge (K051) CPI Separator Bottoms Slop Oil Emulsion Solids (K049) Oily Tank Bottoms Leaded Tank Bottoms (K052) Decanter Tank Tar Sludge (K087) Halogenated Solvents (F001) Acid Tank Sludge Gasoline Tank sludge Oily Coke Sludge Process Unit Cleanout Sludge Cooling Tower Basin Sludge Cat-Poly Catalyst Spent Sulfuric Acid Plant Catalyst FCC Catalyst Filter Media Demineralizer Resin Treated Process Waste Water Storm Water Runoff Asbestos Insulating Materials Dry Coke Fines

Heavy Metals Benzene Carbon Disulfide Chlorobenzene Chloroform 1,2-Dichloroethane 1,4-Dioxane Ethyl Benzene Ethylene Dibromide Methyl Ethyl Ketone Styrene Toluene Xylene Benzenethiol Cresols 2,4-Dimethylphenol 2,4-Dinitrophenol 4-Nitrophenol Phenol Anthracene Benzo(a)Anthracene Benzo(b)Anthracene Benzo(k)Fluoranthene Benzo(a)Pyrene Bis(2-Ethylhexyl)Phthalate Butyl Benzyl Phthalate Chrysene Dibenz(a,h)Acridine Dibenz(a,h)Anthracene Dichlorbenzenes diethyl Phthalate 7,12-Dimethylbenz(a)Anthracene Dimethyl Phthalate Di(n)Butyl Phthalate Di(n)Octyl Phthalate Fluoranthene Indene Methyl Chrysene 1-Methyl Naphthalene Naphthalene Phenanthrene Pyrene Quinoline

Source Conoco Lake Charles Refinery Preliminary RCRA Facility Investigation. Remediation Technologies, Inc, May 1990.

7-25

CITGO PETROLEUM CORPORATION / CIT-CON OIL CORPORATION Site Description and History Citgo Petroleum Corporation owns and operates the Lake Charles Manufacturing Complex located approximately six miles southwest of Lake Charles, Louisiana. In the early 1940s, Cities Service Company constructed a petroleum refinery to produce aviation fuel. Cities Service Company later added a butadiene plant, a lubricating oil plant (1949), a petrochemical plant (1950s), and a butyl rubber plant (1963). In 1982, Cities Service Company was acquired by Occidental Petroleum Corporation. Southland Corporation subsequently acquired certain refining and marketing assets, including the Lake Charles Refinery and Lube Plant (i.e., Citgo and Cit-Con), from Occidental in 1983. The Southland Corporation has since sold Citgo to a subsidiary of Petroleo de Venezuela S.A. (PDVSA), the state-owned oil company of Venezuela. Citgo's Lake Charles Manufacturing Complex currently contains three manufacturing operations: a refinery, lubricating oil plant (Lube Plant), and propylene fractionation unit (PFU). The petroleum refinery is wholly-owned and operated by Citgo. The Lube Plant is owned by Cit-Con, a joint venture between Citgo (65 percent) and Conoco (35 percent), and operated by Citgo. The PFU is located in OxyChem's petrochemical plant, but is operated by Citgo. Citgo also operated a butyl rubber and butadiene plant; however, the butyl rubber operation was discontinued in 1983 and the unit was demolished. Citgo's Lake Charles Manufacturing Complex currently covers 1,600 acres along the west bank of the Calcasieu River south of Bayou d'Inde. Citgo's refinery facility is located in the southern part of the complex, and Indian Marais flows west to east through the refinery property before entering the Calcasieu River. The Cit-Con Lube Plant is located northwest of the refinery, and OxyChem, which contains Citgo's PFU, is located northeast of the refinery. Products and Production Processes Refinery Citgo's Lake Charles petroleum refinery is the eighth largest in the nation, with a rated capacity of 320,000 barrels per day. The refinery produces a variety of products through a series of inter-related processes. Exhibit 7-15 lists the refinery's production units as of 1992. These processes separate crude oil into various hydrocarbon groups which are then combined, broken up, or supplemented to make several end-products. Products manufactured at the refinery include refined petroleum products (fuel oils, naphtha, petroleum coke, transportation fuels, and gasoline of varying octanes), benzene, methyl-tertiary butyl ether, sulfuric acid, and ethane.

7-26

Exhibit 7-15

PRODUCTION AREAS OF THE CITGO REFINERY

Crude Distillation Units Cat Crackers

Recovery Unit Hydrocracker Vacuum Units Coking Units

Catalytic Reforming Units Isomerization Unit Benzene Extraction

Treating Units Alkylation Unit

Methyl Tertiary Butyl Ether Unit

Source RCRA Facility Assessment Report: Citgo Petroleum Corporation. PRC Environmental Management, Inc. and ICF Incorporated, May 5, 1992.

Lube Plant The Cit-Con lubricating oil plant is the sixth largest in the nation. The Lube Plant produces lubricating oils and refined wax. The plant uses crude oil received from the Citgo and Conoco refineries after naphtha, kerosene, and other light oils have been removed. The plant's four production areas are the vacuum units, furfural units, duo-sol units, and methyl ethyl ketone units. These processes convert the crude oil into lubricating base oils and recover natural waxes. The base oils are shipped to Citgo's and Conoco's blending and packaging plants where the oils are combined with additives to form finished lubricating oils. The wax is sold as a finished product in either liquid or solid form. The Lube Plant has a production capacity of 9,000 barrels of lube oils and 1,000 barrels of FDA-certified wax per day. Propylene Fractionation Unit (PFU) The PFU purifies propylene from the Citgo refinery by removing LPG and mixed C-4's from the propylene. All materials, products, and wastes managed at this unit are received from or sent to the refinery. The refined propylene is shipped by the refinery to customers as a finished product.

7-27

Butyl Rubber Plant This plant manufactured butyl rubber from isobutylene and isoprene. As of 1982, the plant manufactured 266,700 pounds of butyl rubber per day. The butyl rubber plant operation was discontinued in 1983 and the unit was demolished. NPDES Summary Citgo holds NPDES permit LA0005941, which authorizes the facility to discharge process waste water and storm water runoff to Bayou d'Inde and the Calcasieu River. The 1991 permit specified discharge limits for a total of nine outfalls: Outfalls 001, 002, 003, 004, 006, 008, 009, 010, and 106. Since 1991, Citgo has added Outfalls 011, 012, and 013. Outfall 001 Citgo is authorized to discharge treated process waste water to Bayou d'Inde via Outfall 001. This outfall serves as the primary effluent point for treated waste water from the Lube Plant, discharging 2,250 gallons per minute to the bayou. Discharge from Outfall 001 is monitored for phenolic compounds, hexavalent chromium, sulfide, total chromium, total zinc, ammonia, pH, BOD, TOC, TSS, and oil and grease. Biomonitoring is also required. Outfall 002 Citgo is authorized to discharge storm water runoff from the PFU to Bayou d'Inde via Outfall 002. The discharge from Outfall 002 is monitored for pH, TOC, total zinc, and oil and grease. Outfall 003 Outfall 003 is the primary exit point for all treated water from the refinery. Discharge includes process waste water, ballast water, and storm water runoff. Outfall 003 originally discharged to Indian Marais, which flows into the Calcasieu River, but the outfall was relocated in 1992 to discharge directly to the Calcasieu River. Effluent from Outfall 003 is monitored or phenolic compounds, hexavalent chromium, sulfide, total chromium, total zinc, ammonia, pH, BOD, TOC, TSS, and oil and grease. Biomonitoring is also required.

7-28

Outfall 004 Outfall 004 discharges noncontact cooling water from the power plant, regeneration waste water, and rinse water to the Calcasieu River. As of 1991, effluent flow through Outfall 004 was approximately 64 million gallons per day, most of which was once-through cooling water. The outfall is monitored for pH, TOC and TRC. Outfalls 006 and 106 Outfall 006 discharges storm water from the northeast side of the refinery and treated sanitary waste water from the old Butyl Rubber Plant. The treated sanitary waste water enters Outfall 006 via Outfall 106. Outfall 006 discharges to the Calcasieu River and is monitored for pH, TOC, and oil and grease. Outfall 008 Outfall 008 discharges uncontaminated storm water runoff from the refinery's Spent Catalyst Disposal Area. The outfall has intermittent flow and discharges to Indian Marais, which flows into the Calcasieu River. Effluent from Outfall 008 is monitored for pH, TOC, total cadmium, total zinc, and oil and grease. Outfall 009 Outfall 009 discharges uncontaminated storm water runoff from the Lube Plant Tank Farm and pump stations at Citgo's dock facility on the Calcasieu River. The outfall discharges to the Calcasieu River and flow through the outfall is intermittent. Effluent is monitored for pH, TOC, and oil and grease. Outfall 010 Outfall 010 discharges uncontaminated storm water runoff from the West Tank Farm of the refinery, which covers 304 acres. Citgo also proposed to reroute certain effluent from Outfall 003 to Outfall 010. Effluent to be added to Outfall 010 included nonprocess area storm water from the west side of the South Tank Farm and the Land Farm. Information indicating whether this additional effluent has been rerouted was not available. Effluent from Outfall 010 is monitored for pH, TOC, and oil and grease.

7-29

Outfall 011 As of October 1994, Citgo proposed to establish Outfall 011 to discharge storm water runoff from the South Tank Farm. Further information was not available for Outfall 011. Outfall 012 Outfall 012 discharges nonprocess area storm water from the Lube Plant. Further information was not available for Outfall 012. Outfall 013 Outfall 013 discharges treated sanitary waste water to Indian Marais from Citgo's Contractor's Compound. Further information was not available for Outfall 013. Effluent Monitoring Exhibit 7-16 lists compounds detected in samples from Citgo effluent. Results for effluent monitoring were available from two sources. The authors of the Toxics Study of the Lower Calcasieu River (RTI 1990) collected and analyzed effluent from the Lube Plant's Outfall 001 and the refinery's Outfall 003 in 1988. Additional effluent data were reported by Citgo; however, dates for most of the Citgo analyses were not available.

Exhibit 7-16

RESULTS OF CITGO EFFLUENT TESTS

Date

Outfall

Parameter

Concentration (ppm)

1975 001 Cresol 0.05

003 Cresol 0.22

003B (1) Cresol 0.22

6/88 001 Aluminum Aluminum (D) Chromium Iron Iron (D) Manganese Manganese (D) Zinc Zinc (D)

0.167 0.100 0.021 0.146

0.05 0.194 0.073 0.025 0.023

7-30

Exhibit 7-16

RESULTS OF CITGO EFFLUENT TESTS

Date

Outfall

Parameter Concentration

(ppm)

003 Aluminum Arsenic Cadmium Chromium Chromium (D) Iron Iron (D) Manganese Manganese (D) 3-Methyl Nonane Phenol Zinc Zinc (D)

0.125 0.0095

0.018 0.063 0.025 0.307 0.088 0.300 0.285 0.011 0.023 0.101 0.058

U 001 Chlorine Chromium Hydrogen Sulfide Phenol Phosphoric Acid

0.20 0.27 0.16

0.016 1.0-3.0

003A Chromium Hydrogen Sulfide Phenol Phosphoric Acid

0.51 0.13 0.20

1.0-3.0

U 003B (1) Benzene Ethylbenzene Toluene Ethylene Dichloride Chromium Hydrogen Sulfide Naphthalene Phenol

486 219

1080 12.2 0.24 0.34 131 6.8

004 Phosphoric Acid 0.11

Notes 1 Outfall not in current NPDES permit U Unknown D Dissolved Sources Citgo Petroleum Corporation Facility Profile Sheet, Draft Report. DPRA,

October 31, 1995. Toxics Study of the Lower Calcasieu River. RTI, March 1990.

7-31

NPDES Compliance History Over the last 20 twenty years, Citgo has had multiple violations of the facility's NPDES permit. The majority of Citgo's violations have involved ammonia, BOD, pH, TSS, oil, grease, and phenol. In addition, releases of a variety of oil products to the Calcasieu River at Citgo's docks and system bypasses have also been documented. Exhibit 7-17 summarizes Citgo's NPDES compliance history for oil, grease, metals, and organics through September 1995. Miscellaneous spills and accidents are also included when contaminants may have been released to surface waters. Whole effluent toxicity tests and permit exceedances for ammonia, BOD, fecal coliform, pH, sulfides, TOC, TSS, and TRC are not included in the exhibit. Citgo has renamed, consolidated, or replaced numerous outfalls at the Lake Charles Manufacturing Complex. When possible, Exhibit 7-17 reports past violations for these outfalls using the present outfall identifier.

Exhibit 7-17

CITGO NPDES COMPLIANCE HISTORY

Date

Location

Parameter

Description, Total Quantity or Deviation from Permit Limit

3/76 002 Oil & Grease Visible in outflow and Bayou d'Inde

003 Oil & Grease Visible in outflow and Calcasieu River

002B (1) Oil & Grease Visible in outflow

Spill or dumping in ditch along Highway 108

Oil U

7/76 002B (1) Polyethylene Fibers Visible in outflow

003 Oil Visible at outfall

9/76 Treatment system bypass to 002 Untreated Water Polyethylene Fibers Oil & Grease

U Visible in outflow

+160 lbs./day

002B (1) Oil & Grease Phenol

U U

003 Oil Visible in Calcasieu River at outfall

12/76 003 Oil Visible at outfall

7-32

Exhibit 7-17


Date

Location

Parameter Description, Total Quantity or Deviation from Permit Limit

4/77 002 Oil Oil & Grease

Visible in Bayou d'Inde at outfall +19.1-27.5 lbs./day

002B (1) Polyethylene Fibers Oil & Grease Chromium

Visible at outfall +3.0-34 lbs./day

U

003 Oil Visible in Calcasieu River at outfall

5/78 004 Oil Visible on water

006 Oil Visible on water

10//78 5 bypasses from Petrochemical Plant

U U

5/79 12 treatment system bypasses to 001, 002, 002B (1), 004

U U

10/79 002 Chromium U

10/79 002B (1) Chromium U

3/80 003 Phenol U

7/80 001 Phenol U

11/80 003 Phenol U

3/81 "contaminated discharge to ditch leading to Bayou d'Inde from the flare pad area of the Petrochemical Plant"

U U

6/81 Treatment system bypass to 002 Polyethylene Fibers and Pellets

Visible on Bayou d'Inde

8/81 3 treatment system bypasses to 002 and 002B

U U

003 Oil & Grease Phenol

4 daily maximum violations 8 daily maximum violations

9/81 Treatment system bypass to 002 and 002B (1)

U U


1 daily maximum violation 8 daily maximum violations

10/81 003 Oil & Grease Phenol


7-33

Exhibit 7-17


Date

Location

Parameter


11/81 003 Phenol 6 daily maximum violations

12/81 002 and 002B (1) Zinc 1 daily maximum violation




U U




U U

003 Oil & Grease 10 daily maximum violations

2/82 Spill from clay pits to ditch which flows to Sabine Diversion Canal and Bayou d'Inde

Phenol U

2/83 003 Oil & Grease +174 lbs./day

4/83 001 Phenol +45.9 lbs./day +123.7 lbs./day

5/84 Spill through storm water sewers in the Outfall 001 area

Phenol U

6/85-8/85 001, 003, and 004 Oil & Grease Discharge limit exceedances

10/85 Spill to Calcasieu River Lubricating Oil 10 barrels

11/85-1/86 001 Phenol Daily maximum violations

12/85 006 Chromium 300-400 gallons of rainwater with 3 ppm chromium

1/86 001 Oil & Grease Daily maximum violations

4/86 Spill to Calcasieu River Regular Gasoline 2.5 barrels

7-34

Exhibit 7-17


Date

Location

Parameter


5/86 Leak into sewer and then Calcasieu River

Chromium 0.0076 lbs.

Spill to ground and ditch which flowed to Indian Marais and then Calcasieu River

Untreated Water from Dissolved-Air Flotation Tank

16,400 gallons

Overflow at Petrochemical Plant U U

Refinery Surge Pond overflow to 003B (1)

U U

6/86 003 Phenol +140 lbs./day

003B (1) Oil & Grease Phenol

+959 lbs./day +178 lbs./day

Spill to Calcasieu River Unleaded Gasoline 0.5 barrels

11/86 003B (1) Oil & Grease Phenol

+5853 lbs./day +212.4 lbs./day

12/86 003B (1) Oil & Grease +888 lbs./day

4/87 Spill to Calcasieu River #2 Fuel Oil 4-5 barrels

8/87 Spill to Calcasieu River Fuel Oil 20 barrels

2/88 U Oil & Grease +5 lbs./day

8/88 U Oil & Grease +444 lbs./day

11/88 006B (1) Oil & Grease +8 mg/L

4/89 003 Oil & Grease +1760 lbs./day

Spill to Calcasieu River 340 Neutral Oil Lubricating Oil

84 gallons 2 barrels

5/89 Spill to Calcasieu River Oil 10 gallons

Refinery Surge Pond overflow to 003B (1)

Oil & Grease Phenol

U U

6/89 Spill to Calcasieu River Crude Oil 3-4 gallons



+23.7 lbs./day +31.9 lbs./day

7/89 003 Phenol +68.9 lbs./day

7-35

Exhibit 7-17


Date

Location

Parameter Description, Total Quantity or Deviation from Permit Limit

11/89 001 Phenol o-Cresol Methyl Ethyl Ketone

+4113.4 lbs./day +2509.4 lbs./day +2860.4 lbs./day +2458.4 lbs./day

U U

12/89 Spill to Calcasieu River #2 Fuel Oil Visible on water

4/90 Spill to Calcasieu River Benzene 4-5 gallons

Spill to ditch that flowed to the Calcasieu River

Heavy Gas Oil 3 gallons

5/90 008 Oil & Grease +1.7 ppm

8/90 Spill to Calcasieu River Coker Fuel 2 barrels

9/90 Spill to Calcasieu River Crude Oil 5 gallons

2/91 008 Oil & Grease +4.2 lbs./day

003 Oil & Grease +833 lbs./day

6/91 006B Oil & Grease +9.4 ppm

1/92-6/92 001, 002, 004, 006 Oil & Grease Daily maximum violations

1/92 002 Oil & Grease +8 ppm




2/93 Spill to Calcasieu River Crude Oil 20 gallons

3/93 003 Oil & Grease +3200 lbs./day +601 lbs./day

5/94-7/94 001, 010, 004, 003C Oil & Grease Daily maximum violations

5/94 010 Oil & Grease +30.18 ppm

7/94 003 Oil & Grease 109.4 ppm

010 Oil & Grease +61.7 ppm

10/94 Spill to Indian Marais Heavy Oil U

12/94 010 Oil & Grease +16.8 mg/L

2/95 012 Oil & Grease +8.5 mg/L

7-36

Exhibit 7-17


Date

Location

Parameter


3/95 003 Zinc +4.4 lbs./day

9/95 Spill to Indian Marais Oily Water U

Notes U Unknown 1 Outfall not in current NPDES permit Source Citgo Petroleum Corporation Facility Profile Sheet, Draft Report. DPRA, October 31, 1995.

RCRA Summary The Citgo Refinery, Lube Plant, and PFU produce a variety of RCRA-regulated wastes, including listed wastes F037 and K048 through K052 and EPA characteristic wastes such as spent caustic and sour water (waste water that contains hydrogen sulfide). These wastes are stored, treated, and managed on and off-site. In 1992, the Citgo and Cit-Con facilities contained a total of 107 potential solid waste management units (SWMUs), 12 of which are regulated under RCRA. There is widespread ground water contamination under the facility, and as of 1992, it had not been determined if contamination had spread beyond the facility boundaries.7 The remainder of this section discusses the RCRA-regulated SWMUs for each plant. Refinery There are 71 SWMUs within the refinery, most of which are associated with process waste waters and storm water runoff. Seven of these units are regulated under RCRA and include the West Impoundment, the Surge Pond, Landfarm Areas 4 and 5, the South Impoundment, the Acid Plant Hydromation and Sand Filters, and the Equalization and Aeration Basins. West Impoundment (SWMU 57) The West Impoundment is an unlined surface impoundment with a capacity of 670,000 gallons. The unit was active from the late 1960s until 1980 and was undergoing closure in 1994. Wastes managed in this unit included oily wastes (K051), tank bottom sludges (K052), and slop oil residues (K049). These wastes were potentially contaminated with phenolics and metals.


7-37

Contaminated soils beneath the West Impoundment were found at depths approaching the ground water table, and contaminated ground water was detected near this unit.8 Surge Pond (SWMU 58) The Surge Pond is an unlined surface impoundment, contained within an earthen embankment in the original Indian Marais channel. The Surge Pond has a capacity of 60 million gallons. The unit was active from the early 1940s until 1994 and managed F037 primary sludges, runoff from land treatment units, process water, ship ballast, acids, caustics, storm water containing refinery hydrocarbons, and sanitary wastes. Prior to 1970 the unit discharged directly to the Calcasieu River. Since 1970, the unit has discharged to the Equalization Basin, and overflow waters discharge to the Aeration Basin or to Outfall 003B at the Calcasieu River.9 Contaminated ground water has been detected near the northwest and southeast corners of the Surge Pond. Naphthalene (0.012-0.0201 ppm) and 2-methylnaphthalene (0.0206 ppm) have been detected in ground water samples near the northwest corner of the Surge Pond. Citgo's Sulphur Recovery Unit (SRU) and Tail Gas #2 (TG2) are upgradient of the Surge Pond and are suspected as sources of the contamination. Naphthalene and 2-methylnaphthalene have been reported in the TG2 area at 0.044 ppm and 0.024 ppm, respectively. Naphthalene (0.208 ppm) has also been detected in the SRU area. As of 1994, the horizontal and vertical extent of the contamination were not known.10 Nine VOCs and free-phase oil have also been detected near the southeast corner of the Surge Pond. The VOCs include benzene, 1,2-dichloroethane, 1,1-dichloroethene, trans-1,2-dichloroethene, 1,1,2,2-tetrachloroethane, tetrachloroethene, 1,1,2-trichloroethane, trichloroethene, and vinyl chloride. Two potential sources for the contamination are the Surge Pond and a group of abandoned Oily Waste Burn Pits located in the Laydown Yard.11 The Burn Pits are unlined holes used in the 1950s and 1960s to dispose of waste oils and other combustible solids. Solvents used to clean refinery equipment and laboratory wastes may also have been placed into the pits.




11 See Appendix A Comment 3(f).

7-38

Landfarm Areas 4 and 5 (SWMU 62) Landfarm Areas 4 and 5 are inactive 5-acre plots with compacted clay liners and berms. These plots received hazardous wastes from 1984 through 1989 and were awaiting closure as of 1992. These plots managed nonhazardous biosludge from the waste water treatment facility, API Separator sludge (K051), slop oil emulsion solids (K049), Dissolved-Air Flotation float (K048), and heat exchanger cleaning bundle sludges (K050). South Impoundment (SWMU 63) The South Impoundment was an unlined surface impoundment with a capacity of 7.5 million gallons. The unit operated from the late 1960s through 1980 and had undergone closure by 1992. The unit received a variety of wastes from throughout the refinery including API Separator sludge (K051), heat exchanger cleaning bundles (K50), leaded tank bottoms (K052), and primary sludge (F037). Acid Hydromation and Sand Filters (SWMU 86) This unit consists of seven carbon steel tanks with capacities ranging from 960 gallons to 1,060 gallons. Each tank contains either black walnut shell media or sand. This unit manages solids contained in refinery sour water. These solids contain sulfides, phenols, and ammonia and may also contain soluble hydrocarbons and amines. The tanks were active as of 1992, but Citgo intended to submit a closure plan for the unit.12 Equalization and Aeration Basins (SWMUs 91 and 97) The Equalization and Aeration Basins are part of the Secondary Waste Water Treatment Plant (SWWTP), which was constructed in the early 1970s. These units are unlined surface impoundments with natural clay bottoms and cement-lined berms. The basins are located in the southeast corner of the facility and have capacities of 8 million and 13.2 million gallons. Both units were active from 1971 until 1994, and Citgo submitted closure plans for each. When active, the basins managed process water, ship ballast, acids, caustics, storm water containing hydrocarbons (including benzene), and sanitary wastes. Ground water contamination has been detected in shallow aquifers near each of these units. Chemical constituents have been detected in ground water samples collected from three monitoring wells (MW-36, MW-58, and MW-60) near the southern end of the Aeration Basin in the southeastern corner of the SWWTP. Exhibit 7-18 presents concentration ranges for organic compounds detected in ground water samples from these wells. Toluene has also been reported in groundwater from MW-60, but toluene concentrations were not available. In addition to these

12 See Appendix A Comment 3(g).

7-39

organic compounds, several metals were detected; however, barium (0.7-1.8 ppm) was the only inorganic measured above background levels.

Exhibit 7-18

CONCENTRATION RANGES FOR ORGANIC COMPOUNDS DETECTED IN GROUNDWATER NEAR THE AERATION BASIN

Well Number Compound Concentration Range (ppm) MW-36 Naphthalene 0.0151-0.0384 MW-58 Naphthalene 0.0116-0.0363 MW-60 Benzene 0.0614-0.0626 Ethylbenzene 0.00666-0.00747 Xylene 0.0172-0.0252 Notes Aldrin, endrin aldehyde, and di-n-octyl phthalate were detected at MW-60

but LDEQ concluded these compounds were not in the groundwater. According to LDEQ these compounds were either mis-identified or were laboratory contaminants in all samples.

Source Evaluation of Hydrogeologic and Groundwater Data: Secondary

Wastewater Treatment Plant. Geraghty & Miller, Inc., June 1994. Erosion in the bottom of the aeration basin was discovered and repaired in 1987, and the largest erosion holes were in the southern part of the basin. The Aeration Basin may be the source of naphthalene, barium, ethylbenzene, and xylene ground water contamination. As of 1994, the vertical extent of ground water contamination was not known.13 Ground water impacts have also been reported at several wells located to the north of the SWWTP, near the Neutralization Unit and the Equalization Basin. Exhibit 7-19 lists organic constituents detected in ground water samples from this area. In addition, several inorganics were detected at concentrations greater than background levels. These include arsenic, beryllium, chromium, cobalt, copper, cyanide, nickel, silver, thallium, vanadium, and zinc. The source of contamination is believed to be a leak from a caustic wastewater sewer line at the Neutralization Unit, near MW-65. Ground water contamination was limited to the uppermost aquifer, but discharges may have occurred to Indian Marais, which flows into the Calcasieu River. Indian Marais is located immediately north of the SWWTP, and ground water contamination was detected in all wells located between the SWWTP and Indian Marais.14

13 See Appendix A Comment 3(h).

14 See Appendix A Comment 3(i).

7-40

Exhibit 7-19

CONCENTRATION RANGES FOR ORGANIC COMPOUNDS DETECTED IN GROUNDWATER NEAR THE EQUALIZATION BASIN

Well Number Compound Concentration Range (ppm)

MW-51 Benzene 1.20-1.27

2,4-Dimethylphenol 0.0394

Ethylbenzene 0.0104

2-Methylnaphthalene 0.0119

Naphthalene 0.018-0.0561

Xylene 0.00816-00682

MW-62 Benzene 0.904-1.78

Cresol (total) 0.0225

2,4-Dimethylphenol 00.0227-0.0704

MW-62 (cont'd) Ethylbenzene 0.0384-0.0692



Xylene 0.0466-0.204

MW-63 Benzene 0.0215-0.149

Cresol (total) 0.0408

MW-64 Benzene 0.111-0.201

MW-65 Acetone 0.138

Benzene 0.0145-0.888

2-Chlorophenol 0.0598

Cresol (total) 0.830-13.9

2,4-Dimethylphenol 1.0-3.06

Ethylbenzene 0.00574-0.178



4-Nitrophenol 0.616-4.0

Phenol 1.0-3.46

Toluene 0.018-1.320

Xylenes 0.0331-1.51

Notes Several additional VOCs, SVOCs, and pesticides were detected in monitoring wells near the Equalization Basin and Neutralization Unit. However, LDEQ concluded that those compounds were not in the groundwater, but were either laboratory contaminants or were mis-identified.

Source Evaluation of Hydrogeologic and Groundwater Data: Secondary Wastewater Treatment Plant. Geraghty & Miller, Inc., June 1994.

7-41

Cit-Con Lube Plant There are 34 SWMUs within the Cit-Con Lube Plant, most of which are associated with process waste waters and storm water runoff. Five of these units are regulated under RCRA. These units include Holding Basins 1 and 2, the Interconnecting Channel, and the Neutralization and Retention Basins. Interconnecting Channel (SWMU 15) and Holding Basins 1 and 2 (SWMUs 13 and 16) Holding Basin 1, the Interconnecting Channel, and Holding Basin 2 are unlined surface units with capacities ranging from 4 million gallons to 13 million gallons. Wastes managed in the holding basins and channel include F037 primary sludges, tank farm runoff, steam condensate, and storm water runoff that may contain wax and other refinery hydrocarbons. These units discharge to Bayou d'Inde via Outfall 001. Holding Basin 1 and the Interconnecting Channel have been active since 1949 and Holding Basin 2 since 1971. By 1994 Holding Basin 1 was almost entirely inactive, and Citgo was dredging the channel and Holding Basin 2 with the intention of closing those units.15 Neutralization and Retention Basins (SWMUs 24 and 25) The Neutralization Basin and Retention Basin were active from 1972 to 1988 and had capacities of 50,000 gallons and 2 million gallons, respectively. When active, the Neutralization Basin received waste water from the Lube Plant's Process Water Runoff Sewer System and discharged to the Retention Basin. These units managed F037 primary sludges and process runoff water containing selecto, furfural, and methyl ethyl ketone. Cracks have been observed in the cement of the Neutralization Basin that may have allowed releases to ground water. Ground water contamination has been discovered near both units, but the source of contamination had not been determined as of 1992. Both units were undergoing closure as of 1992.16 Propylene Fractionation Unit (PFU) As of 1992, the PFU did not contain any SWMUs regulated under RCRA.

15 See Appendix A Comment 3(j).

16 See Appendix A Comment 3(k).

7-42

Citgo Wastes Citgo generates, treats, and stores a variety of hazardous and nonhazardous wastes. Exhibit 7-20 lists wastes associated with the manufacturing processes at the Lake Charles Manufacturing Complex. The exhibit includes wastes associated with the petrochemical plant prior to the facility's sale to OxyChem.

Exhibit 7-20

WASTES IDENTIFIED AT CITGO'S LAKE CHARLES FACILITY

Acid and caustic regenerant water Ammonia Ammonium sulfate Ammonium chloride Anthracene API Separator sludge (K051) Asbestos Benzene Biosludge Boiler house lime slurry Carbon tetrachloride Cation resin Cation and anion backwash water Caustics Chloride salts Chlorine Chromic acid Chromium Cleaning solvents Coke fines Contaminated wax Contaminated soil Copper Cresol Cutting and lubricating oils Dexron 1,2-Dichloroethane Dissolved air flotation sludge (K048) Ethylbenzene Ethylene diaminetetracetic acid

Ethylene dichloride Fluid-cracking catalyst (FCC) feed oil Floor sweep Furfural Gasoline Heat exchanger bundle sludge (K050) Hydrochloric acid Hydrogen sulfide Iron and brass metal cuttings Lacquer thinner Lead Leaded tank bottoms (K052) Lube oil filter clay Methyl ethyl ketone (MEK) Methyl mercaptan Mineral spirits Naphthalene Nickel N-propyl alcohol Non-contact cooling tower blowdown water Oil and grease Oily trash Paint residues and rust Peabody Stripper acid Petroleum refinery primary oil/water/solids separation sludge (F037) Phenol Phosphoric acid

Polychlorinated biphenyls (Aroclors 1221, 1242, 1242, 1253, 1248, 1260) Potassium permanganate Process wastewater Reformer catalyst Refractor acid Residual hydrocarbons Residuals from petroleum-based product samples Sanitary wastes Selecto solvent Ship ballast Slop oil emulsion solids (K049) Soda ash Sodium bichromate Sodium hydroxide Spent aluminum catalysts Steam condensate Spent reagents Storm water runoff Sulphur Sulfuric acid Tars Tetrachloroethene Toluene 1,1,1-Trichloroethane Trichloroethene Unleaded tank bottoms Waste paint solids and thinners Xylene Zeolite rinse water Zinc

Source Citgo Petroleum Corporation Facility Profile Sheet, Draft Report. DPRA, October 31, 1995. RCRA Facility Assessment Report: Citgo Petroleum Corporation. PRC Environmental Management,

Inc. and ICF Incorporated, May 5, 1992.

7-43

CONDEA VISTA COMPANY Site Description and History CONEDA Vista Company (Vista) owns and operates the Lake Charles Chemical Complex (LCCC) near Westlake, Louisiana. The LCCC was constructed in 1961 by Conoco Chemicals, an operating division of Conoco, Inc. In 1981, E.I. DuPont Nemours & Company, Inc. purchased Conoco Inc., but maintained the Conoco Chemicals name at the LCCC. In 1984, Vista was created, and subsequently purchased most of the assets of Conoco Chemicals, including the LCCC. A German holding company, RWE-DEA, purchased Vista in 1991. The Vista facility currently occupies 470 acres between Westlake and Mossville, Louisiana. The site is bordered by Houston River Road on the northwest and Old Spanish Trail Road on the south. Residential areas boarder the facility on the northeast and west. Bayou Verdine lies to the south of the facility and provides the conduit for the plant's waste water and storm water discharge. Portions of the facility are subject to variable flooding, with much of the plant falling within the 100-year flood plain. Vista is currently divided into three operating areas: the Vinyl Chloride Monomer Plant (VCM), the Linear Alkylbenzene Plant (LAB), and the Lake Charles Chemical Plant (LCCP). Past manufacturing operations included a methyl chloride unit (1961-1991), a chlorohexane unit (1965-1968), and a poly-alpha olefins unit (1979-1986). Products and Production Processes Vista manufactures vinyl chloride monomer, linear alkyl-benzene, normal paraffins, low polynuclear aromatic solvent, linear alcohols, alumina, ethoxylates, and ethylene. Wastes associated with these products include heavy ends from VCM/1,2-dichloroethane manufacture and treatment system discharges. Vista's products, raw materials, and by-products are detailed in Exhibit 7-21. By-products and wastes are described in more detail in the RCRA Summary. NPDES Summary Vista holds NPDES permit LA0003336, which authorizes the facility to discharge process waste water and plant runoff to Bayou Verdine via the Vista West Ditch. The plant's main discharge point is Outfall 001, which routes process water and treated waste water from the VCM, LAB, and LCCP operations. Prior to 1987, Vista held separate NPDES permits for the VCM and the LAB/LCCP plants. Outfall 001B is the emergency outfall for these units. Storm water runoff flows to Bayou Verdine via several outfalls and holding ponds.17


7-44

Exhibit 7-21

VISTA'S PRODUCTS, FEEDSTOCKS, AND BY-PRODUCTS

Product Feedstocks By-Products

Ethylene Ethane Hydrocarbons Aromatics Benzene Propane Propolyene Butene Butadiene Methane Hydrogen

Vinyl Chloride Monomer (VCM) Note: includes 1,2-dichloroethane (EDC) production

Ethylene Chlorine Anhydrous HCL Oxygen

Tars: chlorinated C3-C4 hydrocarbons and chlorinated aromatics Muriatic Acid

Linear Alkyl-Benzene (LAB) Normal paraffins Benzene

C6-C8 paraffins Light hydrocarbons Aromatics Dialkyl benzene

Normal Paraffins Kerosene Hydrogen

Hydrocarbons

Low Polynuclear-Aromatic Solvent (LPA)

Hydrogen Branched hydrocarbons

Light hydrocarbons

Linear Alcohols (C2-C30) Ethylene Aluminum Hydrogen

LPA Solvent Olefins Light hydrocarbons

Alumina Alkoxide Water

None

Alcohol Ethoxylates Alcohol Ethylene oxide

Ethoxylates

Source RCRA Facility Investigation, Description of Current Conditions Report. Vista Chemical Company, Lake Charles Chemical Complex, Westlake, Louisiana. Vista Chemical Company and C-K Associates, November 1993.

Outfall 001 receives waste water from Vista's three main production units (VCM, LAB, LCCP), which also include wastes from the alcohol, ethoxylate, paraffins, and ethylene units. Outfall 001 also receives wastes from the sanitary sewer, steam plant, boiler, and cooling tower. Typical wastes include process losses, once through cooling water, blowdown, sanitary wastes, washdown, caustic, acid wash, and contaminated storm water. Total combined flow is approximately 1,650 gallons per minute. As of 1987, Outfall 001 was monitored for TSS, BOD, pH, TOC, ammonia, benzene, toluene, 1,2-dichloroethane, chloroform, methylene chloride,

7-45

sodium hydroxide, total chromium, total zinc, and temperature. Effluent toxicity testing is also required. Vista did not have a waste water treatment system prior to 1971. Vista also has internal and storm water runoff outfalls. According to the RCRA Facility Investigation conducted in 1993, several storm water/plant runoff outfalls are numbered 033-042 and 051-055. Outfalls 033-037 generally drain the plant's production areas. The remaining outfalls drain roadways, rail lines, maintenance, and shop areas. Effluent Monitoring The authors of the Toxics Study of the Lower Calcasieu River (RTI 1990) collected and analyzed effluent from Vista outfall 001 in 1988. Heavy metals and organic compounds were detected in plant effluent during these tests. Vista also has reported constituents identified in storm water from a 1992 sampling program. Exhibit 7-22 shows all of the compounds detected during the 1988 and 1992 sampling. Results of the 1988 testing at Outfall 001 indicate the presence of heavy metals, including chromium, copper, lead, nickel, iron, zinc, aluminum, manganese, and barium. Organics included di-n-butylphthalate and phenol. Constituents identified in storm water include copper, zinc, 1,1,2,2-tetrachloroethane, and xylene. 1,2-Dichloroethane, which is found in Vista's ground water, was not detected in either sampling program (detection limits were not provided). NPDES Compliance History Exhibit 7-23 summarizes Vista's NPDES compliance history for 1,2-dichloroethane, oil, grease, and heavy metals through May of 1995. Miscellaneous spills and accidents are also included when contaminants may have been released to surface waters. Permit exceedances for TSS, BOD, pH, TOC, ammonia, and temperature are not included in this review.

7-46

Exhibit 7-22

RESULTS OF VISTA EFFLUENT TESTS

Date

Outfall

Parameter

Concentration (ppm)

6/88 001 Chromium (total) Copper Lead Nickel Zinc Iron Aluminum Manganese Barium Di-N-Butylphthalate Phenol

0.012 0.025 0.044 0.053 0.765 0.844 2.465 0.231 0.188 0.005 0.005

12/92 033 Copper Zinc 1,1,2,2-Tetrachloroethane

0.040 0.620 9.480

039 Copper Zinc

0.020 0.250

040 Copper Zinc

0.020 0.360

052 Copper Zinc Xylene

0.030 0.240 6.780

053 Copper Zinc

0.030 0.580

Source Toxics Study of the Lower Calcasieu River. RTI, March 1990. RCRA Facility Investigation, Description of Current Conditions Report.

Vista Chemical Company, Lake Charles Chemical Complex, Westlake, Louisiana: Appendix N. Vista Chemical Company and C-K Associates, November 1993.

7-47

Exhibit 7-23

VISTA NPDES COMPLIANCE HISTORY

Date Location/Outfall Parameter Deviation

1/67 Spill to Calcasieu River Heavy oil 1,400 lbs.

1970-1988 Spills to loading area EDC U

1/81 U Oil & Grease Sodium hydroxide

U U

3/81 U Oil & Grease U


3/82 - 1/84 U Oil & Grease U

5/84 001 (assumed) EDC +68.06 lbs./day

5/84-12/84 U Oil & Grease U





11/86 U Benzene U


4/87 Spill Methyl chloride 66.83 lbs.

2/88 Spill to Calcasieu River Kerosene 1,000 barrels

7/88 023 Oil & Grease 10 mg/L

8/88 004 001

Oil & Grease EDC

40 mg/L +13.06 lbs./day

10/88 001 EDC EDC


12/88 Spill to Bayou Verdine Sodium hydroxide 2,430 lbs.

1/89 001 EDC +3.88 lbs./day

2/89 001 Benzene Toluene


3/89 001 EDC Oil & Grease

+4.59 lbs./day 48 mg/L

5/89 Spill to Outfall 002 Oily waste water 25 gal.

5/89 001 EDC +4.06 lbs./day

6/89 001 (assumed) Spill to Storm Drain

EDC Caustic

U 50-70 gal.

7/89 Spill to Outfall 018 Kerosene 1 gal.

7-48

Exhibit 7-23



12/89 Spill to Process Sewer Spill

Sulfuric acid Sodium hydroxide

100 gal. 2,430 gal.

4/90 Spill to Calcasieu River Kerosene 120 gal.

6/90 U Toluene Benzene

U U

7/90 001 EDC +7.05 lbs./day


1/91 001 (assumed) EDC U

3/91 Spill to Outfall 004 Acidic water containing Oil & Grease

30 gal.


6/91 001 (assumed) EDC Benzene Oil & Grease

4.78 lbs./day U U

7/91 Spill to 001 (assumed) EDC 266 lbs.

9/91 Spill to Bayou Verdine Partially treated water 4,000 gal.

12/91 001 Chromium Zinc Chloroform Toluene Benzene Methyl chloride

U U U U U U

1/92 001 (assumed) Phenol U

9/92 001 EDC +7.46 lbs./day

10/92 Spill Benzene waste water 20 gal.

3/93 001 (assumed) EDC U

11/93 001 Spill to 053

EDC EDC Chloroform Vinyl Chloride

+5.59 lbs./day 0.16 lbs.

0.009 lbs. 0.001 lbs.

12/93 001 EDC 2.064 lbs./day

1/94 Spill 024

F024 waste water Oil & Grease

834 lbs. +5 mg/L


7/94 018 Storm water runoff containing EDC and VCM

100,000 gal.

7-49

Exhibit 7-23



9/94 001 EDC +10.13 lbs./day

10/94 054 Storm water runoff containing EDC and VCM

242,227 gal.

11/14 Spill to 054 EDC 0.0075 lbs.

12/94 054 Contaminated storm water

12,700 gal.

Notes U Unknown Source Vista Chemical Corporation Facility Profile Sheet. DPRA, October 31, 1995.

RCRA Summary Vista holds RCRA permit LAD086478047. Throughout the operational lifetime of the plant, heavy ends contaminated with chlorinated hydrocarbons have been released to the ground and stored or managed in holding tanks, ponds, and landfills.18 These releases have resulted in soil and ground water contamination throughout the Vista facility. Primary sources of these releases include the waste management facilities in the VCM plant-north, the waste water treatment basin and lagoons in the VCM plant-south, and loading/unloading and storage facilities at the VCM tank farm. Ground Water Contamination As of 1992, fourteen compounds had been identified in Vista's soil and ground water. These include carbon tetrachloride, chlorobenzene, chloroethane, chloroform, dichlorobenzene, 1,1-dichloroethane, 1,2-dichloroethane, 1,1-dichloroethene, 1,1,2,2-tetrachloroethane, tetrachloroethene, 1,1,2-trichloroethane, vinyl chloride, and trans-1,2-dichloroethene.


7-50

1,2-Dichloroethane (EDC), has been extensively studied at Vista. EDC contamination varies significantly across the soils and ground water of the facility, with the highest levels of contamination existing near the VCM plant. Soil contaminated with EDC has been found to depths of 70 feet at concentrations as high as 950 parts per million. Ground water concentrations have been measured as high as 13,300 parts per million, and several wells frequently range from 100 to 1,000 parts per million. Unspecified volumes of EDC may have migrated to surface waters via ground water flow in the past. Four shallow saturated zones are present in the upper 100 feet of the Vista property. These zones, or "sands," occur at approximate depths of 10, 25, 50, and 80 feet. The 10 and 25 foot sands are in hydrologic contact with local surface waters on a seasonal basis. Ground water in the two upper sands flows in a southerly direction at rates ranging from 10 to 40 feet per year. This flow provides a possible mechanism for contaminant transport. Currently, however, much of the EDC contamination is not found in the upper sands. Exhibit 7-24 indicates that EDC contamination is sinking below the surface water contact range, with maximum concentrations existing in the 50 foot sand. According to the Vista RCRA Facility Investigation, this draw-down is accelerating due to recent ground water remediation and heavy industrial withdrawals.

Exhibit 7-24

VISTA EDC CONTAMINATION IN GROUND WATER, 1995

Depth

Maximum Concentration (ppm)

10 Foot Sand 0.266

25 Foot Sand 447

50 Foot Sand 1,848

70/80 Foot Sand 302

>80 Foot Sand 123

Source Louisiana Department of Environmental Quality, Ground Water Division.

Summary of Solid Waste Management Units (SWMUs) As of 1993, Vista had identified 31 SWMUs at the LCCC. Many of these are sources of past releases to the soil and ground water. Exhibits 7-25, 7-26, and 7-27 summarize the existing SWMUs for the VCM, LCCP, and LAB plants, respectively. These exhibits describe each SWMU's general location, dates of operation, capacity, use, and typical wastes.

7-51

Exhibit 7-25

SUMMARY OF VISTA'S CURRENT SWMUs VCM PLANT AREA

SWMU

Dates of Operation

Capacity

Use

Wastes Associated With These Units

Heavy Ends Storage Tanks (T-405)

1967-present 62,000 gal. EDC and VCM heavy ends

Acids, allyl chloride, benzene, butanol, carbon tetrachloride, caustic, chlorobenzene, chloroform, chloroprene, chromium, dichlorobenzene, dichloroethylene, dichloroporpane, dichloropropene, 1,2-dichloroethane, 1,1-dichloroethane, ethanol, hexachlorobenzene, hexachlorobutadiene, hexachlorocyclopentadiene, hexachloroethane, methanol, methyl chloride, methyl chloroform, methylene chloride, naphthalene, nickel, octane, octene, pentachlorobenzene, pentachloroethane, styrene, sulfides, tetrachlorobenzene, 1,1,1,2-tetrachloroethane, 1,1,2,2-tetrachloroethane, tetrachloroethylene, vinyl chloride, xylene, bis(2-chloroethyl)ether phenanthrene, fluorene, hexachlorohexane, bis(2-ethylhexyl)phthalate.

Waste Water Neutralization Basin (T-500)

1968-present 37,000 gal. Process waste water containing liquid EDC.

Vent Gas Scrubber Pit (T-1) 1969-present 28,780 gal. Vent gas scrubber bottoms; oil and hydrocarbon recovery.

Settling Basin (T-2) 1969-present 28,780 gal. Process area drainage; oil and hydrocarbon recovery.

Copper Precipitation Basin 1979-1990 144,000 gal. Received copper catalyst and EDC contaminated waste water.

ASU Clarification Unit 1972-1993 132,000 gal. Waste water from VCM Plant ASU basin.

Wasted Sludge Pond 1972-1984 341,000 gal. VCM Plant ASU biological solids (wasted sludge).

Turtle Pond-East 1963-1980 7 acres General disposal; unknown material; tarry wastes.

Turtle Pond-West 1957-1989 8 acres General disposal; unknown waste.

Clamshell/Limestone Stockpile Area

1968-1984 2.2 acres Used clamshell and limestone from neutralization of waste water.


7-52

Exhibit 7-26

SUMMARY OF VISTA'S CURRENT SWMUs LCCP PLANT AREA

SWMU

Dates of Operation

Capacity

Use

Representative Wastes

Biological Treatment Unit (North and South Lagoons)

1971-? 18,000,000 gal. (combined)

Neutralized hydrochloric acid, spent caustic, blowdown, holding pond effluent.


Digester Pond 1978-1991 1,500,000 gal. Biological solids.

Polishing Pond 1971-1984 2,500,000 Settling pond to clarify waste water discharge from LCCP. Surge basin.

Closed Settling Ponds North of Faubacher Ditch

1969-1978 2.67 acres Separator sludge, waste oil emulsions, alumina, aluminum hydroxide, methyl chloride, alcohols, contaminated dirt.

Coke Disposal Site 1957 Not determined Coke disposal. Chromium, lead.

7-53

Exhibit 7-26

SUMMARY OF VISTA'S CURRENT SWMUs

LCCP PLANT AREA

SWMU Dates of

Operation

Capacity

Use

Representative Wastes CA-1 Waste Pile 1962-1968 4 acres Construction and maintenance

debris. Acids, benzene, butanol, caustic, chloroform, chromium, ethanol, ethyl benzene, hexane, hexene, methanol, methyl chloride, naphthalene, nickel, octane, octene, pentane, pentene, styrene, sulfides, toluene, xylene.

CA-2 Waste Pile 1962-1968 1 acre Construction and maintenance debris. Aluminum hydroxide.

Holding Pond 1961-present 4,100,000 gal. Process waste water from the ethylene and alcohol oily sewers. Surface ditch drainage. Paraffin waste water, LAB waste water.

Small Pits North of Alum Pits 1970-1983 1 acre Off-spec alcohols, alum. Butanol, chromium, ethanol, hexanol, nickel, sulfides.

Closed Alum Pits 1963-1976 2 acres alum

Waste Pile Under High Line 1968-1983 3.5 acres Filter aid, aluminum hydroxide. Acids, benzene, butanol, caustic, chloroform, chromium, ethanol, ethyl benzene, hexane, hexene, methanol, methyl chloride, naphthalene, nickel, octane, octene, pentane, pentene, styrene, sulfide, toluene, xylene.

API Separator 1962-1983 110 square feet Holding pond waste water, oily water sewers from alcohol and ethylene plants, nonchlorinated hydrocarbons.

North Yard Disposal Area 1968-1982 12 acres Equipment laydown, filter aid, aluminum hydroxide, molecular sieves, construction and demolition debris.

Old Methyl Chloride Acid Neutralization Pit

1969-1972 Not determined Acidic waste water from methyl chloride unit.

Acids, caustic, chloroform, chromium, methanol, methyl chloride, nickel, sulfide.

Disposal Area NE of Alcohol Unit 1963-1970 1.5 acres Filter aid, aluminum hydroxide. Butanol, chromium, ethanol, hexane, hexene, hexanol, nickel, octane, octene, pentane, pentene, sulfide.

Buried Heat Exchanger 1968 10x3 feet Buried heat exchanger Aluminum triethyl


7-54

Exhibit 7-27

SUMMARY OF VISTA'S CURRENT SWMUs LAB PLANT AND MISCELLANEOUS AREAS

SWMU

Dates of Operation

Capacity

Use

Representative Wastes

Surface Impoundments Near the Sand Filter Area

1961-1970 2 acres Separator sludge, holding pond sludge, waste oil emulsions, alumina, methyl chloride, aluminum hydroxide, alcohols.


Pits Located North of Ethylene/VCM Plants

1979-1983 750 square feet Unknown

Road in North Yard 1962-1977 1 acre Built with clam shell used to neutralize methyl chloride waste water.

Chloroform, chromium, methanol, methyl chloride, nickel, sulfides.

Old Laydown Area 1968-1980 3.5 acres Construction laydown, scrap yard, aluminum hydroxide.

Acids, benzene, butanol, caustic, chloroform, chromium, ethanol, ethyl benzene, hexane, hexene, methanol, methyl chloride, naphthalene, nickel, octane, octene, pentane, pentene, styrene, sulfide, toluene, xylene.

Waste Pile in LAB Plant 1968-1981 6 acres Aluminum hydroxide, filter aid, lime basin solids., construction debris.


7-55

Vista Wastes Vista generates, handles, treats, and disposes of large volumes of RCRA hazardous wastes, many of which have migrated into the plant's soils and ground water. Exhibit 7-28 summarizes Vista's RCRA waste generation activities.

Exhibit 7-28

VISTA'S AVERAGE ANNUAL WASTE GENERATION

Waste Description

RCRA Waste Codes

Estimated Annual Generation (tons)

Benzene Contaminated Waste Water D018 500,000

VCM Plant Waste Water D019, D021, D022, D027, D028, D029, D034, D039, D040, D043

350,000

Corrosive Wastes and Waste Water D002 150,000

Benzene Contaminated Corrosive Wastes D002, D018 10,000

Heavy Ends from EDC/VCM Production K019, K020, D001, D028, D039 6,000

Benzene Contaminated Solids and Sludge D018 100

EDC Contaminated Wastes D028 50

Equipment Cleaning Wastes from VCM Plant

F024, D009, D028, D043 40

Benzene Contaminated Solids U019, D018 25

Ignitable Wastes D001 25

Spent Activated Carbon D001, D028 20

EDC Contaminated Materials U077, D018, D019, D022, D027, D028, D040, D043

10

Materials Contaminated with Light Ends from EDC/VCM Production

F025, D028 10

Waste Paint Related Materials F003, F005, D001, D005, D007, D008, D018, D035

10

Solids Contaminated with Heavy Ends K019, K020, D028, D039 5

Solvent Contaminated Wastes F003, F005 5

Waste Petroleum Naphtha D001, D018, D039 5


7-56

OLIN CHEMICALS19 Site Description and History Olin Chemicals began producing soda ash at the Lake Charles facility in 1934. The first of many plant expansions took place two years later with the addition of a caustic soda plant. In the early 1940s, Olin responded to wartime demands for nitrate explosives, and began producing synthetic ammonia. After World War II, Olin re-tooled and entered the nitric acid and sodium nitrate markets. Since then, Olin has continued to expand the production capabilities of the Lake Charles facility, producing rocket fuel for the Titan II missile, synthetic anhydrous ammonia, urea, nitric acid, issocyanates, and a cyanurate based swimming pool chemical. During the 1980s, Olin eliminated several product lines including soda ash, caustic, sodium nitrate, urea, and ammonia. The Olin facility currently occupies 1,200 acres approximately one mile west of the city of Lake Charles and immediately southwest of Westlake, Louisiana. The site is bordered by Conoco and U.S. Interstate 10 on the north and the Clooney Island Loop of the Calcasieu River on the south. Bayou Verdine boarders the facility on the west while marsh land lies immediately to the east. Products and Production Processes Olin currently operates several production units. These include the TDA/TDI and Hyco Facilities, ADI Manufacturing Unit, Nitric Acid Plant, Trichloroisocyanuric Acid Plant (TCCA), Hydrazine Manufacture, Ultrapure Hydrazine Plant, and HDI Adducts Semi-Commercial Unit. Exhibit 7-29 identifies Olin's primary products, feedstocks, and by-products. NPDES Summary Olin holds NPDES permit LA0005347, which authorizes the facility to discharge process waste water and storm water runoff to Bayou Verdine, the Calcasieu River, and Kelso Bayou. In total, the current permit specifies discharge limitations for 18 different outfalls. Outfalls 001, 010, and 028 are Olin's primary discharge points; each of these empties to the Clooney Island Loop of the Calcasieu River. The remaining outfalls (008, 011, 016, 017, 019-020, 022, 025-027, 029-030, 032-034) discharge noncontact cooling water, boiler blowdown, and plant runoff. These outfalls are discussed briefly below.


7-57

Exhibit 7-29

OLIN'S PRODUCTS, FEEDSTOCKS, AND BY-PRODUCTS

Production Unit / Products Feedstocks By-Products

TDA/TDA Hyco Facility Toluene Diamine TDA Toluene Diisocyanate TDI

Hydrogen; DNT; carbon monoxide; methanol; chlorine; MCB solvent

Hydrochloric acid; MCB solvent; DNT phosgene; mercury

ADI Manufacturing Unit (Luxate) Isophorone Diisocyanate Hexamethylene Diisocyanate Methylene Dicyclohexyl Diisocyanate Octadecyl Issocyanate

Amines; phosgene; MCB solvent

Hydrogen chloride

Nitric Acid Plant 65% Nitric Acid

Ammonia; catalyst Not specified

TCCA Plant Trichloroisocyanuric Acid (TCCA)

Cyanuric acid; sodium hypochlorite; chlorine; sodium hydroxide; hydrochloric acid

Liquid waste water

Hydrazine Manufacture (Raschig Process) Hydrazine

Chlorine; sodium hydroxide; ammonia

Not specified

Hydrazine Manufacture (Ketazine Process) Hydrazine Hydrate

Acetone; ammonia; sodium hypochlorite

Hydrazine; pyrazoline; isopropanol

Ultrapure Hydrazine Plant Purified Hydrazine

Hydrazine Waste water

HDI Adducts Semi-Commercial Unit Hexamethylene Diisocyanate Trimer Hexamethylene Diisocyanate Biuret

Hexamethylene diisocyanate monomer

Not Specified

Source Olin Chemical Facility Profile Sheet, Draft Report. DPRA, October 31, 1995.

Outfall 001 Outfall 001 discharges nonprocess waste water and storm water runoff from several of Olin's major production areas. These include the ammonia, urea, and nitric acid plants. Outfall 001 is monitored for TSS, temperature, oil, grease, chlorides, vanadium, nitrogen, chromium, zinc, and chlorine. Toxicity testing is conducted quarterly. Outfall 010 Outfall 010 is Olin's main discharge point for process waste water, non process waste water, sanitary wastes, recovered ground water, landfill leachate, and storm water runoff. Prior to 1990, wastes were routed through the North and South Ponds prior to discharge to Outfall 010. After 1991, Olin treated all wastes at a new waste water treatment plant prior to release

7-58

through Outfall 010. Olin's NPDES permit requires weekly monitoring for 1,2-dichloroethane, 1,1,1-trichloroethane, chloroform, 2,4-dimethylphenol, 1,2-dichloropropane, 2,4-dinitrotoluene, methyl chloride, vinyl chloride, and nickel. Monitoring every three weeks is required for TSS, BOD, oil, grease, phosphorus, total chlorinated hydrocarbons, vanadium, zinc, chlorine, nitrogen, and chromium. Annual monitoring for a wide range of additional volatile and semi-volatile organics is also required. Toxicity testing is conducted on a quarterly basis. Internal Outfall 410 also discharges to 010. Internal Outfall 410 is monitored weekly for dinitrotoluene, 2,4-toluenediamine, 2,5-toluenediamine, aniline, chlorobenzene, and TOC. Outfall 028 Outfall 028 discharges treated toluenediamine still bottom waste water to the Calcasieu River. Monitoring for volatile and semi-volatile organics is conducted on an annual basis. Outfalls 008, 011, 016, 017, 019-020, 022, 025-027, 029-030, 032-034 The majority of these outfalls discharge to the Calcasieu River. Outfalls 025 and 026, however, discharge to Bayou Verdine, while Outfall 011 discharges to Kelso Bayou. Discharges are predominantly storm water runoff, although Outfalls 008, 011, and 029 also discharge noncontact cooling water, floor runoff, and boiler blowdown. Monitoring requirements include, TSS, TOC, oil, grease, BOD, zinc, copper, and nitrogen. Effluent Monitoring The authors of the Toxics Study of the Lower Calcasieu River (RTI 1990) collected and analyzed effluent from Olin outfalls 001, 010, and 028 in 1988. Heavy metals were detected at every outfall, while organics were only prevalent in the discharges at Outfall 010. Exhibit 7-30 shows the results of the RTI sampling program. NPDES Compliance History Over the last twenty-five years, Olin has violated the facility's NPDES permit limits multiple times. For the period January 1982 to October 1985, for example, the Louisiana Department of Environmental Quality cited Olin for 238 unpermitted surface water discharges. A review of Olin's compliance history through March of 1995 indicates that the majority of Olin's NPDES violations have involved TSS, TOC, oil and grease, pH, ammonia nitrogen, organic nitrogen, and total chlorine. Permit violations for zinc, nickel, chloroform, and

7-59

monochlorobenzene were noted on a very infrequent basis. Because most of Olin's reported violations involve conventional parameters, a separate compliance history exhibit is not provided in this section.

Exhibit 7-30

RESULTS OF OLIN EFFLUENT TESTS, 1988

Outfall

Parameter

Concentration (ppm)

001 Zinc Zinc (D) Iron Iron (D) Manganese Manganese (D) Barium Barium (D)

1.658 0.953 2.321 0.802 0.593 0.482 0.483 0.385

010 Nickel Nickel (D) Zinc Zinc (D) Iron Aluminum Aluminum (D) Manganese Manganese (D) Barium Barium (D) 1,2-Dichloroethane 2,2,6,6-Tetramethyl 1-4-Piperidinone 2-Chloro-Phosphate-Ethanol Bis (2-Methoxyethyl) Phthalate

0.099 0.087 0.019 0.009 0.341 0.868 0.335 0.025 0.020 0.047 0.039 0.009 0.012 0.014 0.029

028 Arsenic Zinc Zinc (D) Iron Iron (D) Aluminum Manganese Manganese (D)

0.006 0.472 0.033 0.094 0.084 0.168 0.062 0.058

Notes D Dissolved concentration Source Toxics Study of the Lower Calcasieu River. RTI, March 1990.

7-60

A review of the available ambient water and sediment data (see Chapter 5) indicates the presence of several volatile and semi-volatile organic compounds in Clooney Island Loop near the Olin facility. These include: bromoform, chloroform, 1,2-dichloroethane, 1,1,2,2-tetrachloroethane, tetrachloroethene, trichloroethene, diethyl phthalate, phenol, and isophorone. Most of these compounds, however, also are found either upstream or downstream of the Clooney Island Loop. In addition, compounds identified in Clooney Island Loop may have migrated to surface waters and sediments from Olin's surface impoundments rather than through end-of-pipe discharges. RCRA Summary Olin holds RCRA permit LAD008080681. Historically, Olin's process wastes and debris were disposed of in landfills, discharged to holding ponds, incinerated on-site, or transferred off-site. Waste holding areas include the Old Hazardous Waste Landfill, Interim Status Landfill, East End SWMU, North Pond, and South Pond. Olin also has identified the plant's internal process sewers as sources of soil and ground water contamination. The primary waste storage areas and the process sewers are described below. Old Hazardous Waste Landfill The Old Landfill is located between Olin's North and West Ponds, adjacent to the Waste Water Treatment Basins. Between 1974 and 1979, Olin disposed of approximately 10 million cubic yards of TDI residues, dirt, metals, filters, and debris in this landfill. Wastes identified in the landfill include: acetone fluorotrichloromethane alkyl alcohol formaldehyde asbestos hydrazine aniline mercury benzyl chloride methanol carbon tetrachloride methyl hydrazine chlorobenzene phosgene chloroform pyridine creosols tetrachlorobutylane alcohol dichlorodifluoromethane tetrachlorobutylane oxide dimethylamine toluenediamine (TDA) dimethylhydrazine toluene diisocyanate (TDI) dinitrotoluene (DNT) trichloromono fluoromethane ethylene oxide 1,2-dichloroethane 1,1,1-trichloroethane

7-61

In the mid-1980s, ground water contamination in the vicinity of the Old Landfill and adjacent drum storage area was discovered. Analytical data for the Old Landfill area from the Olin RCRA Facility Investigation - Phase I Interim Report identified monochlorobenzene (4.2 ppm), dinitrotoluene (7,300 ppm), and toluenediamine (380 ppm) in subsurface soil borings from the site. Release rates from the landfill have been estimated at 0.1 pounds per year. Interim Status Landfill The Interim Status Landfill was designed to replace the Old Hazardous Waste Landfill. Located west of the North Pond, the Interim Status Landfill is clay-lined and contains a leachate collection system. From 1979 to 1985, approximately 5,183 tons of wastes were disposed of in the landfill. Wastes included: TDI residue, DNT, TDA column packing, and contaminated metal. Leachate contaminated with monochlorobenzene (0.76 ppm) and dinitrotoluene (2,912 ppm) was identified in 1983. Olin was cited for leachate discharges and seeps to surface and ground water from the landfill between 1983 and 1986. East End Solid Waste Management Unit The East End SWMU is located at the extreme eastern end of the Olin facility. This old disposal site and tank area is bordered on the west by the Olin plant, on the east by marsh, on the north by I-10, and on the south by the Calcasieu River. The East End SWMU was first used in the early 1940s for fill disposal. Over time, solid wastes, copper liquor, asbestos, waste oils, and process wastes were disposed of at the site. Several above ground storage tanks were also housed in the area. The ground water beneath the East End SWMU is contaminated with a number of volatile and semi-volatile organic compounds. According to Olin's RCRA Facility Investigation, Preliminary Report, East End SWMU (March 1995), contaminated ground water is not migrating off-site. Exhibit 7-31 summarizes maximum contaminant concentrations found in ground water beneath the East End SWMU. North Pond and South Pond The North Pond is an unlined surface impoundment located south of the Olin manufacturing complex between the Clooney and Coon Island Loops of the Calcasieu River. The North Pond was built in 1934 and covers approximately 170 acres; the pond's bottom is below river level. Prior to closure in the late-1980s, the North Pond received waste water, industrial solid waste, calcium carbonate, and construction and demolition debris. Wastes included ammonia, sodium nitrate, sodium hydroxide, chlorine, soda ash, hydrazine, chlorine, acetone, cyanuric acid, and chlorides. Analytical data indicate the presence of cadmium (5.5 ppm) and chloride (9,640 ppm) in North Pond Soils. Aniline (9.8 ppm) and chloroform (7 ppm) have been detected in North Pond surface waters.

7-62

Exhibit 7-31

MAXIMUM CONTAMINANT CONCENTRATIONS IN GROUNDWATER EAST END SWMU

Volatile Organic Compounds Semi-Volatile Organic Compounds

Parameter


(ppm)

Parameter


(ppm) Benzene 0.109 Acenaphthene 0.790

Bromodichloromethane 0.005 Anthracene 0.410

Chlorobenzene 0.034 Benzo(a)anthracene 0.320

1,2-Dichlorobenzene 0.021 Benzo(b)fluoranthene 0.290

1,3-Dichlorobenzene 0.201 Bis (2-ethylhexyl) phthalate 0.071

1,4-Dichlorobenzene 0.038 Chrysene 0.330

1,2-Dichloroethane 0.005 2,4-Dimethylphenol 1.200

Ethylbenzene 0.024 Di-n-octylphthalate 0.200

Methylene chloride 0.013 Fluoranthene 0.880

Toluene 0.023 Fluorene 0.720

Naphthalene 5.600

Phenanthrene 0.440

Phenol 0.630

Pyrene 0.760

1,2,4-Trichlorobenzene 1.530

Source RCRA Facility Investigation, Preliminary Report, East End SWMU, Olin Chemicals, Lake Charles Plant. Woodward-Clyde Consultants, March 1995.

The North Pond flowed to the South Pond, which provided final clarification prior to discharge through Outfall 010. The South Pond is completely surrounded by the Calcasieu River. Analytical data indicate the presence of chlorobenzene (0.212 ppm), cadmium (7.7 ppm), and chloride (38,600 ppm) in South Pond Soils. Process Sewers Olin maintained waste water sewer systems for each of the major plant areas. Wastes entering these systems frequently leaked prior to reaching the plant's waste water treatment facilities, ultimately entering the plant's soils and ground water.

7-63

Analysis of ground water beneath the process sewer identified the following compounds and maximum concentrations: chromium (0.396 ppm), copper (3.300 ppm), nickel (0.439 ppm), vanadium (0.248 ppm), 1,2-dichloroethane (4,000 ppm), 1,2-dichloropropane (250 ppm), 2,4-toluenediamine (0.660 ppm), and chlorobenzene (1.700 ppm).

7-64

OXYCHEM PETROCHEMICALS Site Description and History Occidental Petroleum Corporation purchased the Bayou d'Inde manufacturing facility from Cities Service Company in 1985. The facility is located in a highly industrialized complex south of Bayou d'Inde and west of the Calcasieu River. The facility is roughly bounded by Bayou d'Inde on the north, Westlake Polymers on the east, Firestone on the south, and Citgo on the west. At the time of purchase, the facility encompassed about 300 acres and consisted of two polyethylene units and two ethylene/propylene units. In 1987, Occidental sold the two polyethylene production units to Westlake Polymers Corporation. Occidental also leased one of the ethylene/propylene units to Citgo/Cit-Con, who subsequently modified the facility into a Propylene Fraction Unit (PFU). Occidental currently operates the remaining ethylene/propylene unit through OxyChem Petrochemicals (OxyChem). The production unit is known as Olefins Plant #1, and along with the Citgo/Cit-Con PFU, sits on approximately 150 acres. OxyChem describes the history of the site and facility as follows:

The Lake Charles Refinery Complex originally consisted of the basic Refinery (opened in 1944) which was owned and operated by Cities Service Refining Corporation ("CSRC", a subsidiary of Cities Service Company ("Cities")) and the Cit-Con Lube Oil Plant (opened in 1949) owned and operated by Cit-Con Oil corporation ("Cit-Con", a joint venture between Cities and Continental Oil Company). The U.S. Government's Reconstruction Finance Corporation owned a nearby butadiene plant which commenced operations in 1944. The butadiene plant was purchased from the government in 1955 by Petroleum Chemicals Inc. (PCI) - a Cities-Continental Oil Co. joint venture). By 1956, PCI had expanded the butadiene plant into a larger petrochemical complex. In 1963, Cities acquired the outstanding stock of PCI and consolidated the refinery and petrochemical operations into Cities Service Oil Company. In 1964, the Columbian Chemicals Division of Cities also opened a butyl rubber plant near (but separate from) the petrochemical plant. In the spring of 1982 Cities closed the petrochemical plant. During 1982, Cities was acquired by Occidental Petroleum Corporation ("Oxy"). Shortly after the acquisition, the refining, marketing and transportation assets of Cities were transferred to a newly created subsidiary of Cities known as CITGO Petroleum Corporation ("CITGO"). The assets transferred to CITGO included the Lake Charles Refinery, Cities 65% interest in Cit-Con, and the propylene fractionation unit located within the petrochemical plant. The stock of CITGO was subsequently sold by OXY to Southland Corporation in August of 1983. In 1986, Southland sold half of the stock of CITGO to Petroleos De Venezuela (PDVSA). The remainder of the CITGO stock was purchased from Southland by PDVSA in 1990.

7-65

In 1985, Occidental Chemical Corporation ("OxyChem") purchased the petrochemical plant from OXY/Cities for the production of ethylene and propylene. In 1987, the portion of the petrochemical plant known as PE-II (used for the manufacture and reprocessing of low density polyethylene) was sold by OxyChem to Westlake Polymers, Inc. OxyChem now operates the remaining portion of the petrochemical plant primarily for the production ethylene (sic) and propylene.

Products and Production Processes OxyChem manufactures ethylene and propylene via thermal cracking of ethane and propane feedstocks. The plant has the capacity to produce 500 million pounds of ethylene and 125 million pounds of propylene annually. Finished product is stored on-site or in a near-by salt dome prior to shipping by rail, truck, pipeline, or barge. NPDES Summary OxyChem holds NPDES permit LA0069850, which authorizes the facility to discharge process waste water and plant runoff to Bayou d'Inde through outfalls 001, 002, and 003. OxyChem also has an internal outfall (102) that is subject to permit conditions. OxyChem also discharged to Outfall 002B until 1987, when the discharge route was transferred to Westlake Polymers as part of the polyethylene facility sale. Outfall 001 is OxyChem's main outfall, discharging process waste, nonprocess waste water, and storm water runoff. Prior to discharge, process wastes are treated by the on-site treatment facility. Discharges include boiler and saturator blowdown, maintenance washdown, spent caustic, and decoking sump water. The primary waste source is OxyChem's Olefins Plant #1. Prior to 1991, Outfall 001 was known as Outfall 002E. Outfall 001 is currently monitored bi-monthly for benzene, ethylbenzene, and toluene. Toxicity testing and monitoring for a wide range of volatile organic and semi-volatile organics is conducted on an annual basis. Outfall 001 is also monitored for BOD, TSS, and pH. Heavy metals are not analyzed, but OxyChem has noted that nickel, zinc, and arsenic are used or produced at the facility. Outfall 002 discharges storm water runoff from the south portion of the facility and sanitary waste from internal outfall 102. Outfall 002 is monitored for pH, TOC, and oil and grease. Outfall 102 is monitored for BOD, TSS, and fecal coliform. The pre-1991 designation for Outfall 002 was 002A; Outfall 102 was formerly designated 002C.

7-66

Outfall 003 (prior name 002F), discharges storm water runoff from the northwest portion of the facility. The outfall's discharge is intermittent. Effluent Monitoring Effluent monitoring has been conducted for Outfall 001 since at least 1987. Compounds detected during effluent tests are shown in Exhibit 7-32. With the exception of the 1988 results, all tests were conducted for OxyChem by West Paine Laboratories. The 1988 samples were collected as part of the RTI study. RTI did not detect organic constituents in OxyChem's effluent.

Exhibit 7-32

RESULTS OF OXYCHEM EFFLUENT TESTS OUTFALL 001

Date

Parameter

Concentration (mg/L)

Detection Limit (mg/L)

6/22/88 Cadmium Selenium Zinc Iron Manganese Barium

0.005 0.005 0.019 1.413 0.248 0.222

U U U U U U

12/7/88 Methylene chloride 0.1040 0.010



6/11/89 Naphthalene 0.0229 0.020

8/15/89 bis(2-Ethylhexyl)phthalate 0.0408 0.010

2/6/90 1,1-Dichloroethene Methylene chloride

0.2600 0.0130

0.010 0.010




Notes U Unknown Source OxyChem Petrochemical Facility Profile Sheet, Draft Report. DPRA, August 25, 1995. Toxics Study of the Lower Calcasieu River. RTI, March 1990.


7-67

NPDES Compliance History Exhibit 7-33 summarizes OxyChem's NPDES compliance history for oil, grease, and organics through October of 1994. Miscellaneous spills and accidents are also included when contaminants may have been released to surface waters. Permit exceedances for TSS, BOD, pH, TOC, and fecal coliform are not included in this review. Several outfalls identified in the facility profile sheet have been renamed or replaced. Exhibit 7-33 reports past violations for these outfalls using the present outfall identifier. RCRA Summary OxyChem holds RCRA permit LAD981052367. Primary RCRA activities at the facility involve OxyChem's East and West Surface Impoundments. Constructed in 1973, each impoundment covered approximately 4.5 acres. The East Impoundment primarily served as a holding basin for process waste water and potentially contaminated storm water. Initially, however, the East Impoundment also received contaminated sludge. The West Impoundment stored sewer sump solids and sludge and sediments from the plant's waste water treatment system. In 1990, shallow groundwater contamination was discovered in the vicinity of the East and West Impoundments. The specific contaminants were not identified in the facility profile sheet. In 1992, all wastes were removed and the impoundments were taken out of service. Constituents identified in the wastes included benzene, toluene, xylenes, and PCBs. During the closure, OxyChem discharged approximately 10 million gallons of water from the impoundments to Bayou d'Inde. This water was treated prior to release, and no permit excursions were reported. OxyChem Wastes Manufacturing by-products and their annual production are shown in Exhibit 7-34. By-products are recirculated or sold. Remaining wastes are sent to OxyChem's on-site treatment plant prior to discharge to Bayou d'Inde.

7-68

Exhibit 7-33

OXYCHEM NPDES COMPLIANCE HISTORY

Date Location/Outfall Parameter Deviation 5/86 001 Oil & Grease +40 lbs./day6/86 001

001 Oil & Grease Oil & Grease


7/86 001 001 001 001

Oil & Grease Oil & Grease Oil & Grease Oil & Grease

+1 lbs./day +52 lbs./day +48 lbs./day +67 lbs./day

8/86 001 001

Oil & Grease Oil & Grease


9/86 001 001 001

Oil & Grease Oil & Grease Oil & Grease


+25 lbs./day10/86 002


+3.5 mg/L +53 lbs./day

12/86 002 002 002 001

Oil & Grease Oil & Grease Oil & Grease Oil & Grease

+0.7 mg/L +5.4 mg/L +0.1 mg/L +4 lbs./day

2/87 001 Oil & Grease +113 lbs./day5/87 001 Oil & Grease +4 lbs./day9/87 001



10/87 001 Oil & Grease +10 lbs./day12/87 001



1/88 001 Oil & Grease +37.7 lbs./day10/27/89 Spill to storm ditch Sulfuric acid 660 gal.7/3/90 Spill to Bayou d'Inde Oil 270 gal.11/90 001


+28 lbs./day21 +8.7 mg/L

8/91 002 Oil & Grease +2.5 mg/L1/24/92 Spill Sulfuric acid 3,400 gal.3/15/92 Spill Sulfuric acid 170 gal.10/94 002 Oil & Grease

Oil & Grease 36.1 mg/L

11 mg/L10/18/94 Spill Oil/benzene waste water 10,240 gal.Source OxyChem Petrochemical Facility Profile Sheet, Draft Report. DPRA, August 25, 1995.


7-69

Exhibit 7-34

OXYCHEM BY-PRODUCT PRODUCTION

By-Product Annual Production (tons)

Butadiene mix 18,000

Pyrolysis gasoline 25,000

Fuel oil 3,000

Fuel gas 94,000

Source OxyChem Petrochemical Facility Profile Sheet, Draft Report. DPRA, August 25, 1995.

7-70

WESTLAKE POLYMERS CORPORATION Site Description and History Westlake Polymers Corporation, a member of the Westlake Group, owns and operates a polyethylene manufacturing facility located in Sulphur, Louisiana. The facility, composed of two polyethylene production plants (Poly I and Poly II), was originally part of the Petrochemical Division of Cities Service Company (Citgo). Occidental Petroleum Corporation acquired the facility in 1985 and subsequently sold the two production units to Westlake in 1987. The Westlake facility is located on Highway 108, 1.5 miles south of Intestate 10, in Sulphur Louisiana. The facility is in a highly industrialized complex south of Bayou d'Inde and west of the Calcasieu River. The site is bordered by Occidental Petrochemicals (OxyChem) to the south and west and by Bayou d'Inde to the north. Products and Production Processes The Westlake facility is a high pressure, low density polyethylene production plant. The facility manufactures polyethylene in a continuous reaction by compressing ethylene with propylene through an autoclave or tubular reactor with peroxide catalyst. The total flow is depressurized to a separator where the polyethylene is separated from the unconverted gases and routed through an extruder system where it is solidified and pellitized. In addition, Westlake manufactures an ethylene vinyl acetate copolymer product by injecting vinyl acetate with ethylene through a reaction system. As of 1990, the Poly I and Poly II units had the capacity to produce 700 million pounds or polyethylene annually. NPDES Summary Westlake holds NPDES permit LA0071382 which authorizes the facility to discharge process waste water and storm water runoff to Bayou d'Inde. The current permit specifies discharge limitations for five different outfalls. Westlake's main discharge point is Outfall 010, which routes treated process water, utility water, and potentially contaminated storm water from the Poly I and Poly II plants to Bayou d'Inde via the East Ditch. The remaining outfalls (004, 005, 006, and 011) discharge uncontaminated storm water to Bayou d'Inde via the East and West Ditches. Westlake's original permit, which expired in April 1992, authorized discharges from several outfalls that were later consolidated into Outfalls 010 and 011. Outfall 010 In the early 1990s, Westlake eliminated Outfalls 007 and 001, combining the effluent into Outfall 010. Outfall 010 discharges process waste water, utility waste water, and potentially contaminated storm water from the Poly I and Poly II processes. Process and utility waste waters include cooling tower blowdown, fly knife water, silo wash water, hopper car wash water,

7-71

and process pad wash water. Prior to discharge, treatment is provided in a solids removal unit. Outfall 010 has an estimated flow of 0.899 million gallons per day and discharges to Bayou d'Inde via the East Ditch. Outfall 010 is currently monitored on an annual basis for numerous volatile and semivolatile organic compounds. Whole effluent toxicity monitoring is conducted monthly. Outfall 010 is also monitored for flow, temperature, pH, BOD, TSS, zinc, and oil and grease. Outfalls 004, 005, 006, and 011 In the early 1990s, Westlake consolidated Outfalls 002, 003, and 008, and renamed the consolidated outfalls 011. Outfalls 004, 005, 006, and the consolidated outfall 011 discharge uncontaminated storm water runoff from the East Railroad Track area, the Poly I and Poly II production units, and the administration, QC, and CTS buildings. No treatment is provided for runoff.22 Outfalls 004, 005, and 006 discharge to Bayou d'Inde via the East Ditch, and Outfall 011 discharges to the bayou via the West Ditch. Each of these outfalls is currently monitored bi-monthly for flow, TOC, pH, and oil and grease. Effluent Monitoring Effluent monitoring was conducted in 1987 and 1988. In 1987, EPA Region 6 analyzed effluent from an unspecified location for volatile and semivolatile organic compounds. EPA detected bromoform and chloroform in the sample. The authors of the Toxics Study of the Lower Calcasieu River (RTI 1990) collected and analyzed Westlake effluent from Outfalls 001 and 007 in 1988. These outfalls were later consolidated to Outfall 010. Metals and organic compounds were identified in plant effluent from these tests. Exhibit 7-35 lists compounds detected during the 1987 and 1988 sampling programs. NPDES Compliance History Exhibit 7-36 summarizes Westlake's NPDES compliance history for oil, grease, metals, and organics through May of 1995. Miscellaneous spills and accidents also are included when contaminants may have been released to surface waters. Whole effluent toxicity results and permit exceedances for TSS, BOD, and pH are not included in the exhibit. Several outfalls identified in the profile sheet have been renamed or replaced (see above). Exhibit 7-36 reports past violations for these outfalls using the present outfall identifier.


7-72

RCRA Summary Westlake holds RCRA permit LAD981522048. Westlake generates spent halogenated solvents (F001) and spent nonhalogenated solvents (F003 and F005).23 Records provided by Westlake also indicate that the following wastes have been generated between 1991 and 1995: D001, D006, D007, D008, D018, D035, D039, and U211. A review of the files at EPA Region 6 and the Louisiana Department of Environmental Quality did not provide any other information regarding the wastes stored or generated at Westlake.

Exhibit 7-35

RESULTS OF WESTLAKE EFFLUENT TESTS

Date Outfall Parameter Concentration (ppm)

9/87 unspecified Bromoform Chloroform

0.0029 0.0058

6/88 001 Iron Iron (D) Manganese Manganese (D) Zinc Zinc (D)

1.059 0.098 0.184 0.147 0.025 0.016

007 Acetone Aluminum Chromium Copper Di-N-Butylphthalate Iron Iron (D) Manganese Manganese (D) 2-Methyl-2-Proponal Zinc Zinc (D)

6.350 0.112 0.012 0.094 0.002 3.413 1.126 0.385 0.294 0.023 0.106 0.033

Notes D Dissolved Outfalls 001 and 007 were consolidated in the early 1990s and renamed

Outfall 010. Sources Westlake Polymers Corporation Facility Profile Sheet, Draft Report.

DPRA, September 11, 1995. Toxics Study of the Lower Calcasieu River. RTI, March 1990.


7-73

Exhibit 7-36

WESTLAKE NPDES COMPLIANCE HISTORY


3/87 011 Oil & Grease +138.9 mg/L

4/87 011 Oil & Grease +18.3 mg/L

6/88 U U

bis(2-ethylhexy)phthalate Oil & Grease


7/88 Spill to OxyChem holding ponds 011

Oil Oil & Grease

U

U

8/88 011 U

Oil & Grease Oil

U U

9/88 U 011

Oil Oil & Grease

U U

1/89 010 011 U

Oil & Grease Oil & Grease Oil

U U U

3/89 010 Oil & Grease +10.7 mg/L

11/91 010 Oil & Grease +2.9 lbs./day

1/92 010 bis(2-ethylhexyl)phthalate +1.19 lbs./day

1/93 010 Zinc +0.902 lbs./day

4/93 011 Oil & Grease + 20 mg/L

7/93 006 011

Oil & Grease Oil & Grease

+12.6 mg/L +75.5 mg/L

8/93 011 Oil & Grease +15.7 mg/L

1/94 010 Zinc +0.618 lbs./day

3/94 010 Zinc +1.401 lbs./day

4/94 010 011

Zinc Oil & Grease

+0.54 lbs./day +13.03 mg/L

6/94 010 Zinc +2.51 lbs./day

Notes U Unknown Source Westlake Polymers Corporation Facility Profile Sheet, Draft Report. DPRA, September 11,

1995.

7-74

FIRESTONE SYNTHETIC RUBBER AND LATEX COMPANY Site Description and History Firestone Synthetic Rubber and Latex Company (Firestone), a division of Firestone Tire and Rubber Company, owns and operates a rubber and latex manufacturing facility near Sulphur, Louisiana. The Firestone facility began operations in 1943 and occupies approximately 80 acres in a highly industrialized complex south of Bayou d'Inde. Firestone formerly operated an emulsion synthetic rubber production unit, which was shut down in 1981. The facility is bordered to the south and east by Citgo, to the north by OxyChem, and to the west by Cit-Con. Products and Production Processes Firestone produces synthetic rubber and latex, which are used in the production of tires and other rubber-based products. The plant manufactures approximately 165,000 tons of synthetic rubber and latex annually. Firestone produces about 20 different grades of rubber by the solution polymerization process. In this process, butadiene and styrene are polymerized in a solution of hexane. After being separated from the hexane, the resulting "solution crumb rubber" is shipped off-site to be used in the manufacturing of tires and other rubber-based products. The hexane solvent is recycled and purified. As of 1994, the Firestone plant produced approximately 1,000,000 pounds of solution crumb rubber per day. The Firestone facility manufactures latex rubber using an emulsification process. In this process butadiene, styrene, and vinyl pyridine are polymerized to produce latex emulsions. As of 1994, Firestone produced approximately 7,700 pounds of latex rubber per day. NPDES Summary Firestone holds NPDES permit LA0003824, which authorizes the facility to discharge process waste water and storm water runoff to Bayou d'Inde via Outfalls 001, 003, and 004. Firestone's main discharge point is Outfall 001, which routes process waste water, sanitary waste water, cooling tower blowdown, and process area storm water from the waste water treatment plant to Bayou d'Inde. Flow through Outfall 001 to Bayou d'Inde is approximately one million gallons per day. Outfall 001 is currently monitored three times per week for BOD, COD, TSS, oil, grease, ammonium nitride (NH3N), and chromium. Biomonitoring is conducted quarterly, and flow and pH are also monitored.24 Outfalls 003 and 004 discharge nonprocess storm water runoff via earthen ditches along the east and west plant boundaries. Flow through these outfalls is intermittent. Outfalls 003 and


7-75

004 are monitored twice per week for TOC, oil, and grease. The outfalls are also monitored for pH. Effluent Monitoring The authors of the Toxics Study of the Lower Calcasieu River (RTI 1990) collected and analyzed an effluent sample from Firestone Outfall 001 in 1988. Heavy metals and a single organic compound were detected in Firestone's effluent. These results are presented in Exhibit 7-37.

Exhibit 7-37

RESULTS OF FIRESTONE EFFLUENT TESTS OUTFALL 001, 1988

Parameter Concentration (ppm)

Aluminum Di-N-Butylphthalate Iron Iron (D) Manganese Manganese (D) Zinc (D)

0.1 0.003 0.902 0.212 0.202 0.152 0.017

Notes D Dissolved Sources Toxics Study of the Lower Calcasieu River. RTI,

March 1990.

NPDES Compliance History Exhibit 7-38 summarizes Firestone's NPDES compliance history for oil and grease through April 1995. Miscellaneous spills and accidents also are included when contaminants may have been released to surface waters. Permit exceedances for pH, BOD, COD, TOC, TSS, ammonia, and ammonium nitride are not included in this review. Several outfalls with exceedances (001A, 003A, and 004A) appear to be internal outfalls flowing into Outfalls 001, 003, and 004.25


7-76

Exhibit 7-38

FIRESTONE NPDES COMPLIANCE HISTORY

Date Location/Outfall Parameter Deviation 10/90 004

004A Oil & Grease Oil & Grease

+5.9 percent26 +74 percent

10/91 003A Oil & Grease +74 mg/L27 3/94 Spill from styrene

storage tank Styrene ~6,000 gallons not

recovered in cleanup28

8/94 001 Oil & Grease +26 lbs./day +33 lbs./day

11/94 001 Oil & Grease +318 lbs./day29 12/94 001 Oil & Grease +214 lbs./day30

+66 lbs./day +81 lbs/day

+67 lbs./day 1/95 001 Oil & Grease +87 lbs./day


+7 lbs./day 004A Oil & Grease U31 2/95 001 Oil & Grease +149 lbs./day

+120 lbs./day 3/95 001 Oil & Grease +19 lbs./day


4/95 001 Oil & Grease +7 mg/L 5/95 001 Oil & Grease +228 lbs./day


Notes U Unknown Sources Firestone Synthetic Rubber and Latex Company Facility Profile

Sheet, Draft Report. DPRA, August 31, 1995.



28 See Appendix A Comment 8(e).

29 See Appendix A Comment 8(f).

30 See Appendix A Comment 8(g).

31 See Appendix A Comment 8(h).

7-77

RCRA Summary Firestone holds RCRA permit LAD008073439. In the past, Firestone has generated a variety of characteristic and listed wastes. Exhibit 7-39 lists available information on characteristic and listed wastes generated by the Firestone facility in two different years, 1981 and 1990. The production of synthetic rubber generates distillation bottoms contaminated with hexane and styrene (D001), paint-related waste (D001, F005), and lab waste solvents (F003, F005). Prior to 1991, Firestone burned the distillation bottoms waste in on-site boilers as supplemental fuel. Since 1991, Firestone has stored all wastes in dedicated on-site tanks prior to shipping all wastes off-site for disposal.

Exhibit 7-39

FIRESTONE'S 1981 AND 1990 WASTE GENERATION32

Year

Waste Description

Waste Code

Amount Generated (tons)

1981 API Separator Sludge K051 13.2

Recovery Sump Wastes U 59.4

Asbestos U013 25.5

Polymer Peroxides D003 0.6

DNCB Empty Drums U 0.6

Cement Rubber Waste D001 62.9

Waste Degreasing Solvents F001 0.6

One PCB Transformer U 35

1990 Not Specified D001 521.1

Not Specified D008 13.75

Not Specified F003/F005 3

Not Specified F005 18.89

Notes U Unspecified Sources Firestone Synthetic Rubber and Latex Company Facility Profile Sheet,

Draft Report. DPRA, August 31, 1995. Generator's Annual Hazardous Waste Report -- 1990. Firestone

Synthetic Rubber & Latex Company, February 28, 1991.

32 See Appendix A Comment 8(i).

7-78

Groundwater Contamination Firestone maintains four monitoring wells around the perimeter of a surface impoundment and aeration lagoon on the north side of the property. The impoundment, which is to the north of the lagoon, was closed in 1986. The impoundment had been used to store non-hazardous sludge from the plant's waste water treatment system. In August 1991, chlorobenzene, 1,2 dichlorobenzene, 1,3-dichlorobenzene, 1,4-dichlorobenzene, and 1,2,4-trichlorobenzene were discovered in the monitoring well (MW-4) on the southern side of the lagoon. Since the discovery of the contamination, Firestone has collected samples from the well on 18 different occasions. Exhibit 7-40 shows the maximum concentrations measured in the well for each of the contaminants by year since 1991. The results show that concentrations of the compounds generally have been decreasing since 1991, and none of the contaminants were detected in 1995 samples. These compounds are confined to the first water-bearing zone in the area of the affected well (MW-4) and have not been detected in the other three monitoring wells, including two wells (MW-1 and MW-2) which are located along the northern property line, downgradient of the impacted area. The compounds are not associated with Firestone's production processes, and the source of the contaminants is still unknown.

Exhibit 7-40

MAXIMUM CONTAMINANT CONCENTRATIONS MEASURED IN SAMPLES FROM MONITORING WELL MW-4

Concentration (ppm)

Compound Name 1991 1992 1993 1994 1995

Chlorobenzene 0.089 0.050 0.00131 ND (0.005) ND (0.005)

1,2-Dichlorobenzene 0.047 0.050 0.0038 ND (0.005) ND (0.010)



1,2,4-Trichlorobenzene 0.118 0.097 NA 0.0231 ND (0.010)

Notes NA Not Analyzed ND Not Detected. The minimum detection limit for samples from that year is indicated in

parentheses. Source Semiannual Groundwater Monitoring: Firestone Synthetic Rubber and Latex Company. Philip

Environmental Services Corporation, October 3, 1995.

7-79

W.R GRACE Site Description and History W.R. Grace has owned and operated a manufacturing facility in Carlyss, Louisiana since at least 1953. The facility covers 121 acres and extends approximately 3,000 feet west of the Calcasieu River, south of Citgo Petroleum Corporation. Very little information was available for W.R. Grace. Several resources, such as a Facility Profile Sheet or RCRA Facility Investigation, could not be located. This review relies on the following sources:

• Current and former discharge permits; • NPDES fact sheet; • Groundwater and soil studies; and • Phase IA site inspection prioritization report.

Products and Production Processes W.R. Grace has manufactured silica-alumina petroleum cracking catalysts since 1953. Manufacturing processes at the facility do not use any organic chemicals. NPDES Summary W.R. Grace holds NPDES permit LA0001333, which authorizes discharges from Outfalls 001 and 002 to the Calcasieu River via Young's Bayou. The permit also authorizes discharges from an internal Outfall 101 to Outfall 001. Outfall 001 Outfall 001 discharges treated process waste water and process area storm water to Young's Bayou, which flows to the Calcasieu River. According to W.R. Grace's 1995 water discharge permit, the outfall has continuous flow estimated at 2.5 mgd, not including storm water runoff which is estimated at an additional 0.1757 mgd.33 Outfall 001 effluent is monitored three times per week for TSS and ammonia nitrogen and annually for whole effluent toxicity. Flow and pH are also monitored.


7-80

Outfall 002 Outfall 002 discharges uncontaminated nonprocess area storm water to Young's Bayou via a roadside ditch. Flow through this outfall is intermittent, and effluent is monitored monthly for pH and oil and grease. Outfall 101 Outfall 101 discharges treated sanitary waste water to Outfall 001 at a rate of approximately 0.0144 mgd. Outfall 101 is monitored monthly for flow and once every three months for fecal coliform and BOD. Effluent Monitoring The authors of the Toxics Study of the Lower Calcasieu River (RTI 1990) collected and analyzed effluent from W.R. Grace Outfall 001 in 1988. Exhibit 7-41 lists compounds detected in the plant effluent. Organic compounds were included in the test parameters, but were not detected.

Exhibit 7-41

RESULTS OF W.R. GRACE EFFLUENT TESTS, OUTFALL 001, 1988

Parameter Concentration (ppm)

Aluminum Aluminum (D) Cadmium Iron Iron (D) Manganese Manganese (D) Nickel Zinc Zinc (D)

0.432 0.194 0.017 0.067 0.032 0.254 0.252 0.021 0.171 0.395

Notes D Dissolved Source Toxics Study of the Lower Calcasieu River. RTI,

March 1990.

7-81

NPDES Compliance History The information sources used for this review did not contain data for W.R. Grace's NPDES compliance history. RCRA Summary W.R. Grace has tested soil and ground water, but no contamination has been identified. There are two solid waste management units at the W.R. Grace facility. One is an inactive 5-acre landfill containing plastic, scrap iron, trash, and refractory bricks. According to the 1994 Phase 1A Site Inspection Prioritization Report and PA Score Package, the bricks contain 20 to 30 percent hexavalent chromium and aluminum and are listed as RCRA hazardous waste; these metals are fixed and insoluble. The landfill is capped; however, exposed bricks were reported in the Site Inspection Prioritization Report.34 The other solid waste management unit includes a series of lagoons used to settle particulates from the plant effluent. The particulates are recycled back to the plant for reuse.


PART III

PRELIMINARY INJURY EVALUATION AND CONTAMINANT REVIEW

8-1

INJURY EVALUATION AND CONTAMINANT REVIEW INTRODUCTION AND SUMMARY CHAPTER 8 Part III (Chapters 8-11) of this report evaluates contaminants found in Calcasieu Estuary resources with respect to their potential to injure natural resources and services. Chapter 8 provides an introduction to and summary of the resource review and injury evaluation. Chapters 9 through 11 provide our detailed review of surface water, sediment, and fish and shellfish resources, respectively. OVERVIEW OF METHODS Parts I and II of this report review the physical condition of the Calcasieu Estuary, focusing on chemical contaminant concentrations and releases. Part I quantifies chemical concentrations in the estuary's sediments, surface water, fish, and shellfish. Part I also evaluates spatial variations in the contaminant data and identifies reporting variations among data sets. Part II, the Facility Review, provides information about the major production facilities discharging to estuary waters and the relationship between plant locations and estuary contamination. Studies conducted in the Calcasieu Estuary between 1987 and 1996 identify more than 100 chemical compounds in estuary sediments, surface waters, fish, and shellfish. In Part III we evaluate the estuary conditions summarized in Parts I and II to identify existing natural resource injuries, and to select contaminants with significant potential to injure resources. We accomplish this in two steps. (1) We evaluate existing injury by identifying contaminants that satisfy the

definitions of injury provided in the natural resource damage assessment regulations promulgated by the Department of the Interior (DOI). The DOI regulations provide definitions of various resource injuries, and establish acceptance criteria required to determine (prove) these injuries. For some resources, the DOI regulations also identify specific injuries that automatically satisfy the acceptance criteria. We compare Calcasieu Estuary contamination levels to all relevant injury definitions, and find that surface water and biological injuries exist based on contaminant exceedances of promulgated water quality criteria and based on state-imposed limits on fish and shellfish consumption.

8-2

(2) To identify additional contaminants of concern, we develop resource-specific

chemical thresholds from the available literature, and compare Calcasieu Estuary contaminant levels to these thresholds. The thresholds indicate contaminant concentrations at which adverse effects are likely, for example Effects Range-Median (ER-M) thresholds used to evaluate sediment toxicity. Where Calcasieu Estuary contaminant levels exceed thresholds, adverse effects are likely, but further work is needed to determine injury. Where contaminant levels are below thresholds, injury is less probable. Where thresholds cannot be developed for a contaminant, we recommend that the contaminant continue to be included as a contaminant of concern.

Our analyses in Part III rely on the same data sources used in Part I. These data sets are summarized in Chapter 2. Note that while we use the same data sources for all parts of the report, the data compilation methods and measurement bases change in Part III depending on the requirements of the analysis. The most significant changes include the use of dry weight data for the sediment analysis and dissolved metals concentrations in the water analysis. Any divergence from the original data compilation methods outlined in Chapter 2 are noted in the appropriate chapter. We also continue to compile and analyze data according to the geographic conventions outlined in Part I. These conventions divide the estuary into three major geographic areas: Bayou d'Inde, Bayou Verdine, and the Calcasieu River and Ship Channel. Each of these areas is further sub-divided into segments. Bayou d'Inde contains four segments (segments 1-4), Bayou Verdine contains seven segments (segments 5-11), and the Calcasieu River and Ship Channel contains six segments (segments 12-17). Data are conveyed from the original studies to the segment-level. We then aggregate the segment data to the area-level to provide overall summaries for the entire estuary. Consult Chapter 2 for an overview of the segments and the data coverage of each study. Consult Chapters 3 through 5 for specific information about segment boundaries, dimensions, and characteristics. SUMMARY OF RESULTS: INJURY DETERMINATION Surface Water Natural resource injury to surface water is determined based on five criteria set forth in the DOI regulations. Our analysis focuses on one of these criteria -- water contaminant concentrations exceeding promulgated ambient water quality criteria. We compare Calcasieu Estuary surface water contaminant concentrations to the applicable water quality criteria promulgated by the state of Louisiana. We also analyze the spatial and temporal characteristics of the exceedance data for adherence to DOI's measurement standards. Based on this review, we identify 13 compounds that satisfy the regulatory criteria for surface water injury. These contaminants are listed in Exhibit 8-1, and are described further in Chapter 9.

8-3

This surface water injury analysis uses data collected between 1987 and 1996. During this period, estuary studies generally have shown a declining trend in water column contamination over time. Therefore, current water conditions, if analyzed independently, would not demonstrate the same degree of surface water injury as the complete data set. We rely on the longer time frame because all data are relatively recent, and therefore, relevant. In addition, the approach provides a larger analytical sample and ensures the greatest level of protection for the surface water resource. We also review the four other criteria for surface water injury set forth by DOI: (1) Water contaminant concentrations causing sediments to exhibit hazardous waste

characteristics; (2) Water contaminant concentrations sufficient to cause injury to other natural

resources; (3) Water contaminant concentrations in excess of drinking water standards

established by sections 1411-1416 of the Safe Drinking Water Act; and (4) Water contaminant concentrations in excess of water quality criteria established

by section 1401(1)(D) of the Safe Drinking Water Act. As noted in Chapter 9, additional testing would be necessary to evaluate injury with respect to (1) and (2). Injury associated with drinking water standards or the Safe Drinking Water Act are not applicable because the Calcasieu Estuary is not designated as a drinking water supply.

Exhibit 8-1

CONTAMINANTS CAUSING INJURY

Contaminants Exceeding Water Quality Criteria

Limits on Fish and Shellfish Consumption

Dibromochloromethane 1,2-Dichloroethane 1,1-Dichloroethene 1,1,2,2-Tetrachloroethane Tetrachloroethene 1,1,2-Trichloroethane Hexachlorobutadiene PCBs Copper Lead Mercury Nickel Zinc

Hexachlorobenzene Hexachlorobutadiene PCBs

8-4

Sediment Sediments are considered part of surface water resources in the DOI regulations. Injury to sediments is determined by proving biological injury to sediment-dwelling organisms via the DOI acceptance criteria. Since we did not identify or review any in-situ or laboratory toxicity studies specifically considering Calcasieu Estuary sediments, contaminants, and biota this report does not determine sediment injury in the Calcasieu Estuary. We did not search for published or unpublished studies addressing the toxicity of Calcasieu Estuary sediments. Instead, we reviewed the literature to find general sediment effects thresholds developed by others for use in contaminant screening. Exceedance of these thresholds strongly suggests that injury is occurring to sediment-dwelling organisms; however, further work would be necessary to determine the severity and extent of injury as required by the DOI regulations. We provide detailed results of the threshold analysis in Chapter 10. Fish and Shellfish We review three injury criteria for fish and shellfish: (1) adverse changes in viability such as death, disease, or genetic mutations; (2) exceedances of Food and Drug Administration action levels or tolerances; and (3) existence of state-imposed consumption limits or bans. Injury to fish and shellfish can be determined by proving adverse changes to the organisms based on the DOI acceptance criteria for biological injury. Fish and shellfish injuries that meet the acceptance criteria include fish kills, fin erosion, neoplasms, and reduced fish reproduction. Specific toxicological studies using species and contaminants found in the Calcasieu Estuary are necessary to determine biological injury. We did not search for published or unpublished studies addressing these types of effects in Calcasieu Estuary fish and shellfish. We do review whether any contaminants found in Calcasieu Estuary fish and shellfish exceed action levels or tolerances set by the Food and Drug Administration (FDA). The only tolerance established by FDA for Calcasieu Estuary contaminants is for PCBs (2 parts per million). None of the fish or shellfish tissue measurements from the Calcasieu Estuary exceed this tolerance. The State of Louisiana maintains fish consumption advisories for the entire Calcasieu Estuary. The existence of these advisories meets the DOI requirement for determining injury to fish and shellfish. Within Bayou d'Inde, the advisory prescribes specific limits on fish and shellfish consumption due to hexachlorobenzene, hexachlorobutadiene, and PCB contamination. The estuary-wide advisory (outside of Bayou d'Inde) is informational, advising the public about trace chemical contamination in the estuary's fish and shellfish so that they may make informed decisions about the quantity of Calcasieu Estuary fish they consume. Contaminants of concern listed in the estuary-wide advisory include hexachlorobenzene, hexachlorobutadiene, and PCBs (see Exhibit 8-1).

8-5

SUMMARY OF RESULTS: CONTAMINANTS OF CONCERN Studies of the Calcasieu Estuary compiled for this report have detected 116 different compounds in estuary sediments, 60 compounds in surface water, and 13 compounds in fish and shellfish. Based on a review of the relevant literature, we were able to locate or calculate endpoint-based contaminant thresholds for approximately 45 percent of these compounds. Exhibit 8-2 presents summary statistics for the threshold analysis. These results are based on comparisons of median contaminant concentrations with the threshold values. In Chapters 9 and 10 we also conduct threshold analysis using maximum contaminant concentrations.

Exhibit 8-2

SUMMARY OF THRESHOLD EXCEEDANCES

Sediment Surface Water Fish and Shellfish

Number of Compounds Detected 116 60 13

Number of Thresholds Available 44 38 NA

Number of Contaminants Exceeding Thresholds

36 16 NA

Percent of Thresholds Exceeded 82 % 42 % NA

Calcasieu Estuary sediments exhibit the greatest proportion of threshold exceedances. We were able to develop thresholds for 44 of the 116 contaminants detected in sediments. These thresholds include effects range-medians (ER-Ms), apparent effects thresholds (AETs), sediment quality criteria, and sediment quality standards issued by the State of Washington. In 82 percent of the compounds with thresholds (36 out of 44), contaminant concentrations exceed the applicable threshold in at least one estuary segment. Surface water exhibits a lower proportion of threshold exceedances. Water thresholds are based on Louisiana-promulgated ambient water quality criteria and are available for 38 out of the 60 detected compounds. Of these, 16 compounds exceed the criteria. As discussed above, injury is determined for 13 of these compounds based on the DOI injury criteria. Contaminants of concern identified through threshold exceedances are listed in Exhibit 8-3. Median concentrations of 45 contaminants exceed applicable thresholds for either sediments or surface water in at least one estuary segment. Many of these compounds are pervasive throughout the estuary. Ten contaminants, for example, exceed applicable thresholds in more than one-third of the 17 estuary segments: 1,2-dichloroethane, benzo(a)anthracene, bis(2-ethylhexyl)phthalate, chrysene, fluorene, 2-methylnaphthalene, phenanthrene, manganese, mercury, and nickel. Twelve additional compounds exceed applicable thresholds in 20 to 30 percent of the segments (tetrachloroethene, acenaphthene, anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, dibenzo(a,h)anthracene, fluoranthene, indeno(1,2,3-cd)pyrene, naphthalene, pyrene, and PCBs).

8-6

Some contaminants exceed thresholds in limited geographic areas, but exhibit proximity to specific dischargers. Median concentrations of five of these compounds (hexachlorobenzene, hexachlorobutadiene, dichlorobenzene, trichlorobenzene, and dibromochloromethane) only exceed thresholds in the PPG Canal and Lower Bayou d'Inde. Xylene exceedances correlate with the Industrial Area of Bayou d'Inde (segment 2), and the portion of Bayou Verdine (segment 11) and the Calcasieu River (segment 14) immediately downstream from the Conoco outfall and the PPG facility. Other compounds exceeding thresholds in the lower portions of Bayou Verdine (segments 9, 10, and 11) and Coon Island Loop (segment 14) include anthracene, fluoranthene, pyrene, and dibenzofuran. On an estuary-wide basis, trends in the relative contaminant burdens across segments also appear. Five segments in particular, exhibit more threshold exceedances than the other twelve. Within Bayou d'Inde, 36 percent of the contaminants exceed applicable thresholds in the PPG Canal; 57 percent exceed thresholds in Lower Bayou d'Inde. In Bayou Verdine, the I-10 reach and Lower Bayou Verdine have 53 percent and 38 percent exceedance rates, respectively. Coon Island Loop within the Calcasieu River also exhibits a 54 percent exceedance rate. Exhibits 8-4 through 8-9 provide further detail on chemical contamination in surface water and sediment. Each exhibit contains information on the number of contaminants detected and the number of exceedances by estuary area and segment. Within each estuary area, we also identify the most heavily impacted segments, both in terms of the number of compounds that exceed thresholds and in the magnitude of threshold exceedances. This analysis identifies significant contamination in nine estuary segments. Three of these segments fall within Bayou d'Inde and include the Industrial area, PPG Canal, and Lower Bayou d'Inde (segments 2, 3, and 4). Multiple contaminants within each of these three segments have been measured at concentrations of more than 100 times greater than applicable thresholds. Bayou Verdine exhibits significant contamination in four segments: Faubacher Ditch, KCSRR Ditch, I-10 reach, and Lower Bayou Verdine (segments 8 through 11). Numerous contaminants within these segments are 10 to 100 times greater than applicable thresholds. Within the Calcasieu River and Ship Channel two segments, Coon Island Loop and Prien Lake, exhibit significant sediment contamination. Both segments have one or more contaminants that are more than 10 times greater than applicable thresholds, and one contaminant that is more than 100 times greater than the thresholds. In addition to the contaminants identified above, we also recommend that the contaminants of concern include all compounds that do not have associated thresholds. Each of these compounds should be included in further injury investigations until specific evidence demonstrates that they do not impair the estuary's natural resources. We present media-specific listings of these compounds in Chapters 9 and 10.

8-7

Exhibit 8-3

THRESHOLD EXCEEDANCES BY SEGMENT Bayou d'Inde Bayou Verdine Calcasieu River & Ship Channel

Compound 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 TOTAL VOCS Carbon Tetrachloride 1 Dibromochloromethane 2 Dichloroethane, 1,2- 7 Dichloroethene, 1,1- 1 Ethylbenzene 1 Tetrachloroethane, 1,1,2,2- 2 Tetrachloroethene 5 Trichloroethane, 1,1,2- 2 Xylene (total) 3 SVOCs Acenaphthene 4 Anthracene 4 Benzo(a)Anthracene 6 Benzo(a)Pyrene 4 Benzo(b)Fluoranthene 5 Benzo(g,h,i)Perylene 4 bis(2-Ethylhexyl)phthalate 6 Butyl Benzyl Phthalate 1 Chrysene 6 Dibenzo(a,h)Anthracene 4 Dibenzofuran 2 Dichlorobenzene, 1,2- 2 Dichlorobenzene, 1,4- 2 Diethyl Phthalate 1 Di-n-Butylphthalate 2 Fluoranthene 4 Fluorene 6 Hexachlorobenzene 3 Hexachlorobutadiene 2 Indeno(1,2,3-cd)Pyrene 4 Methylnaphthalene, 2- 6 Naphthalene 5 Nitrosodiophenylamine, N- 2 Phenanthrene 9 Phenol 1 Pyrene 5 Trichlorobenzene, 1,2,4- 2 PCBs and Pesticides Total PCBs 4 DDE, 4,4'- 1 Endrin 2 Inorganic Elements Copper 3 Lead 1 Manganese 8 Mercury 6 Nickel 6 Zinc 2 TOTAL 3 10 16 26 1 5 5 5 10 24 17 1 2 25 5 2 2 159 Segment Identification Bayou d'Inde Bayou Verdine Calcasieu River and Ship Channel 1 Upstream 5 Upstream 12 Lake Charles 2 Industrial Area 6 Vista West Ditch 13 Clooney Island Loop 3 PPG Canal 7 Trousdale Reach 14 Coon Island Loop 4 Lower Bayou d'Inde 8 Faubacher Ditch 15 Prien Lake 9 KCSRR Ditch 16 Moss Lake 10 Interstate 10 Reach 17 Calcasieu Lake 11 Lower Bayou Verdine

9-1

SURFACE WATER INJURY EVALUATION AND CONTAMINANT REVIEW CHAPTER 9 This chapter reviews the contaminants affecting the surface water resources of the Calcasieu Estuary. The first part of the chapter evaluates the regulatory requirements for determining natural resource injury to surface water and identifies contaminants meeting these criteria. The remainder of the chapter presents a detailed surface water analysis for the entire Calcasieu Estuary. SURFACE WATER INJURY ASSESSMENT The Department of the Interior (DOI) has promulgated natural resource damage assessment regulations at 43 CFR 11.62(b) that establish five general categories of surface water resource injury. These are: (1) Water contaminant concentrations exceeding water quality criteria; (2) Water contaminant concentrations causing sediments to exhibit hazardous waste

characteristics; (3) Water contaminant concentrations sufficient to cause injury to ground water, air,

geologic, or biological resources; (4) Water contaminant concentrations in excess of drinking water standards

established by sections 1411-1416 of the Safe Drinking Water Act; and (5) Water contaminant concentrations in excess of water quality criteria established

by section 1401(1)(D) of the Safe Drinking Water Act. The majority of our analysis considers the first of these criteria -- assessing potential injury based on exceedances of water quality criteria. Following this assessment, we briefly review the regulations for water injury defined by sediment-based hazardous waste characteristics and injury associated with related resources. We do not review injuries

9-2

associated with the Safe Drinking Water Act because the Calcasieu Estuary is not a designated drinking water supply. Water Contaminant Concentrations Exceeding Water Quality Criteria Exceedances of Clean Water Act or state-imposed ambient water quality criteria provide a direct method for determining injury to surface water resources. Below, we outline the regulatory definition of surface water injury with respect to criteria exceedances and identify contaminants satisfying this injury definition. We present detailed analysis of the surface water data, including segment-level contaminant evaluations and a review of the data aggregation methodology in the second part of Chapter 9. Definition of Injury DOI's natural resource damage assessment regulations state: "An injury to a surface water resource has resulted from the discharge of oil or

release of a hazardous substance if....concentrations and duration of the substances in excess of applicable water quality criteria established by section 304(1)(a) of the CWA, or by other Federal or State laws or regulations that establish such criteria, in surface water that before the discharge or release met the criteria and is a committed use...as a habitat for aquatic life, water supply, or recreation. The most stringent criterion shall apply when surface water is used for more than one of these purposes" (43 CFR 11.62(b)(1)(iii)).1

The standard for determining injury to surface water resources also includes the following measurement standards at 43 CFR 11.62(b)(2)(i): "The acceptance criterion for injury to the surface water resource is the

measurement of concentrations of oil or a hazardous substance in two samples from the resource. The samples must be one of the following types:

(A) Two water samples from different locations, separated by a straight-line

distance of not less than 100 feet; or (B) Two bed, bank, or shoreline sediment samples from different locations

separated by a straight-line distance of not less than 100 feet; or

1 Note that injury is determined only if the water body would have met the applicable criteria before the release or discharge.

9-3

(C) One water sample and one bed, bank, or shoreline sediment sample; or (D) Two water samples from the same location collected at different times." Surface Water Injury Determination Using median contaminant concentrations, a total of 13 compounds meet the requirements for surface water injury within the Calcasieu Estuary. Exhibit 9-1 lists these 13 compounds. Exhibit 9-1 also identifies which of these contaminants satisfy the regulatory requirements within each estuary area. Within Bayou d'Inde, eight contaminants satisfy the injury criteria: dibromochloromethane, 1,2-dichloroethane, 1,1,2,2-tetrachloroethane, tetrachloroethene, hexachlorobutadiene, PCBs, mercury, and nickel. Four of these compounds (dibromochloromethane, tetrachloroethene, hexachlorobutadiene, and PCBs) do not meet the injury criteria in any other estuary area. Within Bayou Verdine, four compounds (1,2-dichloroethane, 1,1,2-trichloroethane, nickel, and zinc) satisfy the injury criteria. Of these compounds, only zinc is unique to Bayou Verdine. Eight compounds identified in the Calcasieu River and Ship Channel satisfy the injury criteria. These include 1,2-dichloroethane, 1,1-dichloroethene, 1,1,2,2-tetrachloroethane, 1,1,2-trichloroethane, copper, lead, mercury, and nickel. Three of these compounds (1,1-dichloroethene, copper, and lead) do not meet the injury criteria in any other estuary area. As part of this evaluation, we reviewed the Louisiana Administrative Code to determine compliance with DOI's designated use criteria, which require that all water bodies being considered for surface water injury have a committed use as a habitat for aquatic life, water supply, or recreation. All areas of the Calcasieu Estuary satisfy this criteria. Bayou d'Inde, Bayou Verdine, and the Calcasieu River and Ship Channel hold recreation and aquatic life habitat designations (e.g., primary and secondary contact recreation; fish and wildlife propagation). Moss Lake and Calcasieu Lake also are designated for oyster propagation. We also evaluated the surface water data for compliance with DOI's measurement standards. Two compounds -- carbon tetrachloride in the Calcasieu River and copper in Bayou Verdine -- exceed water quality criteria but do not satisfy the regulatory measurement standards. As a result, we do not list carbon tetrachloride in Exhibit 9-1 and copper is not listed within Bayou Verdine. All other compounds exceeding applicable water quality criteria within an estuary area exhibit more than one criteria exceedance within that area. Further, at least two of the exceedances for each compound listed within an estuary area were sampled at distances greater than 100 feet or were sampled at different times. This surface water injury analysis uses data collected between 1987 and 1996. During this period, estuary studies generally have shown a declining trend in water column

9-4

contamination over time. Therefore, current water conditions, if analyzed independently, would not demonstrate the same degree of surface water injury as the complete data set. We rely on the longer time frame because all data are relatively recent, and therefore, relevant. In addition, the approach provides a larger analytical sample and ensures the greatest level of protection for the surface water resource. Future surface water injury determination studies should continue to evaluate the applicability of the earlier data.

Exhibit 9-1

SURFACE WATER INJURY DETERMINATION BY ESTUARY AREA

Bayou d'Inde Bayou Verdine Calcasieu River and Ship Channel

Dibromochloromethane U

1,2-Dichloroethane U U U

1,1-Dichloroethene U

1,1,2,2-Tetrachloroethane U U

Tetrachloroethene U

1,1,2-Trichloroethane U U

Hexachlorobutadiene U

PCBs U

Copper U

Lead U

Mercury U U

Nickel U U U

Zinc U

Notes If we use maximum concentrations, bromodichloromethane (Bayou d'Inde), bromoform (Bayou d'Inde, Calcasieu River), and carbon tetrachloride (Calcasieu River) also would be included in this list.

Carbon tetrachloride and copper exceed Louisiana-promulgated water quality criteria

in the Calcasieu River and Bayou Verdine, respectively; however, neither compound satisfies the regulatory measurement standards in those areas.

Exhibit 9-1 does not include compounds that exceed criteria listed in EPA's Quality

Criteria for Water since these are not Louisiana-promulgated standards. These compounds are listed as "additional contaminants of concern" later in this chapter.

9-5

Water Contaminant Concentrations Causing Sediments to Exhibit Hazardous Waste Characteristics DOI's natural resource damage assessment regulations provide for surface water resource injury when water body sediments exhibit hazardous waste characteristics. "An injury to a surface water resource has resulted from the discharge of oil or

release of a hazardous substance if....concentrations of substances on bed, bank, or shoreline sediments sufficient to cause the sediment to exhibit characteristics identified under or listed pursuant to section 3001 of the Solid Waste Disposal Act, 42 USC 6921" (43 CFR 11.62(b)(1)(iv)).

The specified characteristics include ignitability, corrosivity, reactivity, and toxicity. Sediment samples exhibiting these characteristics and satisfying the measurement standards at 43 CFR 11.62(b)(2) (discussed above) would meet the requirements for surface water resource injury. Of the studies reviewed during this effort, only EPA (1996) included any analysis of hazardous waste characteristics. The other studies were not conducted for the purpose of identifying hazardous waste characteristics in bed, bank, and shoreline samples, and are not applicable to evaluation against these regulatory criteria. EPA (1996) conducted preliminary Toxicity Characteristic Leachate Procedure (TCLP) analysis on a limited number of sediment samples from Bayou d'Inde (segment 4). EPA (1996) concluded that the Bayou d'Inde sediment samples analyzed do not exhibit hazardous waste characteristics as specified in 40 CFR 261(c). Additional research would be necessary to fully evaluate this category of surface water injury within the Calcasieu Estuary. Water Contaminant Concentrations Sufficient to Cause Injury to Ground Water, Air, Geologic, or Biological Resources DOI's natural resource damage assessment regulations provide for surface water resource injury when surface water contaminant concentrations are sufficient to cause injury to other specified resources. "An injury to a surface water resource has resulted from the discharge of oil or

release of a hazardous substance if....concentrations and duration of substances sufficient to have caused injury as defined in paragraphs (c), (d), (e), or (f) of this section to ground water, air, geologic, or biological resources, when exposed to surface water, suspended sediments, or bed, bank, or shoreline sediments" (43 CFR 11.62(1)(b)(v)).

Because of the interaction of the Calcasieu Estuary surface waters with surrounding resources, injury via this definition is plausible. Chapters 10 and 11 evaluate the relationship between surface water contamination and biological resources.

9-6

SURFACE WATER CONTAMINANT REVIEW The remainder of Chapter 9 presents the detailed review of surface water contaminant concentrations compared to applicable water quality standards. This section of Chapter 9 begins with a summary of results followed by a discussion of the methodology used to aggregate contaminant data and compile the state's water quality criteria. We then evaluate each contaminant for exceedances of the water quality criteria within the estuary's major geographic areas. We then present the results of the contaminant review on a segment-by-segment basis. Summary Exhibit 9-2 summarizes the results of the surface water contaminant review. The first column of Exhibit 9-2 lists all compounds that satisfy the DOI natural resource damage assessment regulations based on median contaminant concentrations. The second column lists additional contaminants of concern. These additional contaminants of concern are based on one of three factors: (1) Median concentrations of the compound do not exceed the Louisiana-

promulgated water quality criteria, but maximum concentrations of the compound do exceed the standards;

(2) The associated criteria is from the Quality Criteria for Water and median

concentrations of the compound exceed the applicable standard; or (3) The compounds do not have any associated criteria. The last column of Exhibit 9-2 lists contaminants that have been detected in the Calcasieu Estuary's surface waters, but that are not present in sufficient concentrations to warrant future analysis. Methodology The contaminant review consists of two components: (1) Collection of surface water quality criteria; (2) Compilation of surface water concentration data, and comparison to water quality

criteria. Each of these steps is discussed below.

9-7

Exhibit 9-2

SURFACE WATER CONTAMINANT REVIEW

Contaminants of Concern

Contaminants that Meet DOI's Definition of Injury

Additional Contaminants of Concern

Contaminants that Do Not Exceed Water Quality

Criteria

Dibromochloromethane 1,2-Dichloroethane 1,1-Dichloroethene 1,1,2,2-Tetrachloroethane Tetrachloroethene 1,1,2-Trichloroethane Hexachlorobutadiene PCBs Copper Lead Mercury Nickel Zinc

Acetone Bromodichloromethane Bromoform Bromomethane 2-Butanone Carbon Disulfide Carbon Tetrachloride 1,1-Dichloroethane Dichloropropene N-Nitrosodiphenylamine Styrene Xylene Acenaphthylene Bis(2-ethylhexyl)phthalate Di-n-Butyl phthalate N-Nitroso Di-N-Propylamine Pyrene Iron Manganese Magnesium

Benzene Chloroform Chloromethane 1,2-Dichloropropane Ethylbenzene Methylene Chloride Toluene 1,1,1-Trichloroethane Trichloroethene Vinyl Chloride Diethyl Phthalate Naphthalene Nitrobenzene Phenol Arsenic Cadmium Chromium Selenium Thallium

Collection of Ambient Water Quality Criteria Water quality standards exist for 38 of the 52 contaminants detected in our analysis of surface water resources. The primary source of these standards is the Louisiana Administrative Code (LAC), Title 33, Part IX, Chapter 11. When the LAC does not list a compound, we refer to standards listed in the Environmental Protection Agency's Quality Criteria for Water, 1986. We briefly describe each of these sources below. Louisiana Administrative Code Thirty of the 38 water quality criteria in this report are from the Louisiana Administrative Code. These criteria, which are listed at 33 LAC IX.1113(c)(6), are designed to protect public health, the state's natural resources, and the designated uses of public waters. State-defined criteria include acute and chronic aquatic life standards and human health standards for drinking water and non-drinking water supplies. The state applies these standards according to the designated use assigned to each water body, with the most stringent standards governing water quality.

9-8

Within our study area, the state designates four use classifications: primary contact recreation, secondary contact recreation, fish and wildlife propagation, and oyster propagation. The estuary is a non-drinking water resource. In addition, the state includes the entire Calcasieu Estuary under Louisiana's saltwater criteria and expresses all metals standards in dissolved concentrations. Exhibit 9-3 lists the designated uses and the criteria typically associated with each use category. Exhibit 9-4 lists the designated uses assigned to each of the segments defined in this study.

Exhibit 9-3

DESIGNATED USES AND ASSOCIATED WATER QUALITY CRITERIA Designated Use Associated Criteria Notes

Primary Contact Recreation Non-Drinking Water Human Health Protects for primary and secondary contact recreation and prevents contamination of fish and aquatic

Secondary Contact Recreation life consumed by humans. Criteria for proven carcinogens are based on a cancer risk of 1x10-6.

Fish and Wildlife Propagation Acute/Chronic Aquatic Life Based on EPA water quality criteria documents or derived from lowest

Oyster Propagation LC50 for Louisiana species. Source Louisiana Administrative Code

Exhibit 9-4

DESIGNATED USES OF STUDY-DEFINED SEGMENTS

Estuary Area Segments Designated Uses

Bayou d'Inde All Segments (segments 1-4) A, B, C

Bayou Verdine All Segments (segments 5-11) A, B, C

Calcasieu River and Ship Channel

Lake Charles, Clooney Island, Coon Island, Prien Lake (segments 12-15)

A, B, C

Moss Lake, Calcasieu Lake (segments 16-17)

A, B, C, E

Notes A Primary Contact Recreation B Secondary Contact Recreation C Fish and Wildlife Propagation E Oyster Propagation Source Louisiana Administrative Code

9-9

Quality Criteria for Water, 1986 Eight of the 38 water quality criteria we use in this report are from the Environmental Protection Agency's Quality Criteria for Water, 1986 (the "Gold Book"). The eight criteria include: 1,2-dichloropropane, diethyl phthalate, naphthalene, nitrobenzene, N-nitrosodiphenylamine, manganese, selenium, and thallium. Note that these are not Louisiana-promulgated criteria. The Quality Criteria for Water, however, does provide the foundation for most state-promulgated water quality criteria, including those issued in Louisiana. We use the standards presented in Quality Criteria for Water for screening purposes only. Since these standards are not Louisiana-promulgated, exceedances do not constitute injury under the DOI natural resource damage assessment regulations. We include contaminants that exceed these standards in the list of additional contaminants of concern (Exhibit 9-2). Note also that 4 of the 8 criteria are LOELS (lowest observed effect levels). These four compounds include 1,2-dichloropropane, naphthalene, nitrobenzene, and thallium. Although not designated as criteria, these values are presented in Quality Criteria for Water because they represent acute effect levels in marine aquatic life. Compilation of Ambient Water Concentration Data The Resource Characterization presented in Part I summarizes and reviews surface water data from seven studies of the Calcasieu Estuary.2 Based on these studies, we compile median and maximum water concentrations for each of the 38 contaminants having water quality criteria. We compile contaminant data on a segment-by-segment basis for each major area of the estuary (i.e., Bayou d'Inde, Bayou Verdine, and the Calcasieu River). We also aggregate the segment-level data into summary exhibits containing median and maximum concentrations for Bayou d'Inde, Bayou Verdine, and the Calcasieu River. Note that we aggregate organic and inorganic data using different methods. This different treatment is dictated by Louisiana's water quality criteria for metals, which are expressed in dissolved concentrations. The applicable data aggregation methods are discussed briefly below. Organics Organic concentrations for each segment are taken directly from data exhibits in Part I of this report. These data are derived from seven studies containing ambient water concentrations for the Calcasieu Estuary. Exhibit 9-5 lists the status of each of these reports with respect to the

2 An eighth study, Report to Characterize Sediments in the Upper PPG Effluent Canal. ITC, 1994, also was included in the sediment sections of the Resource Characterization; however, it does not contain ambient water measurements.

9-10

availability of organic and inorganic data; detailed descriptions of each study are provided in Chapter 2. Inorganics The metals data included in Part I of this report are tabulated as total concentrations. We selected this reporting convention to maximize the number of studies available to characterize ambient conditions. Louisiana's metals criteria, however, are expressed in dissolved concentrations. Consequently, the data presented in Part I are not directly comparable to the water quality standards. Three of the seven original studies presented both total and dissolved inorganic water data. These included ChemRisk 1994, ChemRisk 1995, and RTI. For the contaminant review, we re-compiled data from these three studies using dissolved metals concentrations. Data from the four remaining studies could not be used. Of these, LDEQ and PRC 1994 did not sample for inorganic constituents. The two remaining studies, PRC 1993 and EPA 1996, only reported total inorganic concentrations.3 Exhibit 9-5 lists the status of each of these reports with respect to the availability of organic and inorganic data; detailed descriptions of each study are provided in Chapter 2.

Exhibit 9-5

STUDIES INCLUDED IN THE WATER RESOURCES CONTAMINANT REVIEW

Organic Data Inorganic Data (Dissolved)

RTI, 1990 YES YES

PRC, 1993 YES NO

PRC, 1994 YES NA

ChemRisk, 1994 YES YES

ChemRisk, 1995 YES YES

EPA, 1996 YES NO

LDEQ, 1987-1995 YES NA

Notes NA = Not applicable (study did not collect inorganic data).

3 The PRC 1993 and EPA 1996 results could be converted to dissolved concentrations based on a partitioning analysis.

9-11

Results and Discussion This section presents summary results for the overall estuary. We also present individual analyses for Bayou d'Inde, Bayou Verdine, and the Calcasieu River and Ship Channel based on the segment-level data. We also provide a separate discussion for the LDEQ water data. Unless noted otherwise, all analyses are conducted using median surface water concentrations. Summary of Results Exhibit 9-6 compares median surface water concentrations for Bayou d'Inde, Bayou Verdine, and the Calcasieu River and Ship Channel to the water quality criteria. Concentrations for 16 of the 38 compounds with water quality criteria exceed applicable standards. Specific compounds exceeding the criteria, however, varied across each area of the estuary. Only three compounds (1,2-dichloroethane, manganese, and nickel) exceed the criteria in all three areas of the estuary, while four others (1,1,2,2-tetrachloroethane, 1,1,2-trichloroethane, copper, and mercury) exceed the criteria in two areas. Median concentrations of the remaining nine compounds exceed the criteria in only one of the three major estuary areas. Exhibit 9-7 compares maximum surface water concentrations for Bayou d'Inde, Bayou Verdine, and the Calcasieu River and Ship Channel to the water quality criteria. In addition to the 16 compounds identified in the analysis of median concentrations, three additional compounds (bromodichloromethane, bromoform, and dichloropropene) exceed the criteria using maximum contaminant concentrations. In addition to the increase in the number of compounds, a greater proportion exceed thresholds in multiple areas of the estuary. Maximum concentrations of bromoform, carbon tetrachloride, 1,2-dichloroethane, 1,1-dichloroethene, 1,1,2,2-tetrachloroethane, 1,1,2-trichloroethane, copper, manganese, mercury, and nickel exceed the criteria in more than one area of the estuary. Bayou d'Inde is the most impaired area of the estuary in terms of the number of compounds that exceed the criteria. Using median concentrations, 10 compounds exceed the criteria in Bayou d'Inde. The Calcasieu River also has 10 compounds that exceed the criteria, while Bayou Verdine has six. The divergence among areas increases, however, when maximum water concentrations are compared to the criteria. Maximum concentrations of 16 compounds exceed the criteria in Bayou d'Inde. In the Calcasieu River, the number of compounds exceeding the criteria increases to 11, while the number of compounds exceeding the criteria in Bayou Verdine remains unchanged.

Exhibit 9-6WATER SUMMARY TABLE

MEDIAN WATER CONTAMINANT CONCENTRATIONS (1)mg/l (ppm)

Chemical Threshold Criteria (2)Group Compound Name Bayou Bayou Calcasieu Non-Drinking Water Marine AWQC (3)

d'Inde Verdine River Human Health (4) Chronic AcuteVOCs Benzene 0.0002 ND ND 0.0125 1.35 2.7

Bromodichloromethane 0.0031 ND ND 0.0033Bromoform 0.028 0.008 0.012 0.0347 0.895 1.79Carbon Tetrachloride (5) 0.00056 NI 0.0053 0.0012 7.5 15Chloroform 0.0075 0.001 0.001 0.07 4.075 8.15Chloromethane 0.00021 NI 0.00038 13.5 27Dibromochloromethane 0.018 0.002 0.0018 0.00508Dichloroethane, 1,2- 0.0255 0.132 0.0195 0.0068 5.65 11.3Dichloroethene, 1,1- (5) 0.00016 NI 0.00385 0.00058 11.2 22.4Dichloropropane, 1,2- (5) 0.0003 NI 0.0006 3.04 *+ 10.3 *+Dichloropropene (5) 0.0031 NI 0.00016 0.163 0.0395 0.079Ethylbenzene (5) 0.00215 NI 0.00095 8.1 4.38 8.76Methylene Chloride 0.0055 ND ND 0.087 12.8 25.6Tetrachloroethane, 1,1,2,2- 0.0022 ND 0.005 0.0018 0.451 0.902Tetrachloroethene 0.0092 ND 0.0014 0.0025 0.51 1.02Toluene 0.0004 ND 0.001 46.2 0.475 0.95Trichloroethane, 1,1,1- 0.0021 ND ND 1.56 3.12Trichloroethane, 1,1,2- 0.0032 0.0085 0.009 0.0069Trichloroethene 0.0027 ND 0.00045 0.021 0.1 0.2Vinyl Chloride 0.0007 0.003 ND 0.0358

SVOCs Diethyl Phthalate 0.014 0.44 0.46 1800 *Hexachlorobutadiene 0.009 ND ND 0.00011 0.00032 0.0016Naphthalene 0.013 ND 0.0135 2.35 *+Nitrobenzene 0.011 ND ND 6.68 *+Nitrosodiphenylamine, N- 0.019 ND ND 0.0161 *Phenol NI 0.016 0.005 0.05 0.29 0.58

PCBs & Total PCBs 0.0023 ND ND 0.00000001 0.00003 0.01PesticidesInorganic Arsenic NI 0.0044 0.0021 0.036 0.069Elements (6) Cadmium T 0.0009 0.0014 0.01 0.04562(dissolved) Chromium 0.001 0.0073 0.005 0.103 0.515

Copper T 0.0138 0.0119 0.00437 0.00437Lead 0.006 ND 0.012 0.0085 0.22Manganese 0.47 0.231 0.172 0.1 *Mercury 0.009 ND 0.0002 0.000025 0.0021Nickel 0.023 0.0196 0.0134 0.0083 0.075Selenium ND ND 0.033 0.054 * 0.41 *Thallium 0.04 ND ND 0.048 * 2.13 *+Zinc 0.026 0.093 0.029 0.086 0.095

Notes:

Concentration exceeds water quality criteria.NI Not investigated.T Compound investigated, but no dissolved concentrations were available.ND Not detected.(1) Concentrations presented are the highest median measurements from Bayou d'Inde, Bayou Verdine, and the Calcasieu River.(2) Standards are from Louisiana Administrative code unles otherwise specified.

Louisiana applies the most stringent of the available state promulgated criteria (LAC IX 1113(c)(6)(e)).(3) Numeric toxic criteria based on EPA Blue, Red, and Gold Books; consideration for natural background conditions;

and known or suspected occurance in Louisiana waters and potential threat to attainment of desigated uses (LAC IX 1113 (c)(6)(a)).(4) Based on a cancer risk of 1x10-6. Criteria for water bodies not designated as drinking water supplies are developed

to protect for primary and secondary contact recreation and to prevent contamination of fish and aquaticlife consumed by humans (LAC IX 1113 (c)(6)(c)).

(5) From LDEQ data.(6) Inorganics criteria are dissolved concentrations (LAC IX 1113 (c)(6)(d)).* No Louisiana criteria available. Criteria are from EPA Gold Book (Quality Criteria for Water, 1986).+ Insufficient data to develop formal criteria. EPA Gold Book value is the LOEL.

Exhibit 9-7WATER SUMMARY TABLE

MAXIMUM WATER CONTAMINANT CONCENTRATIONSmg/l (ppm)

Chemical Threshold Criteria (1)Group Compound Name Bayou Bayou Calcasieu Non-Drinking Water Marine AWQC (2)

d'Inde Verdine River Human Health (3) Chronic AcuteVOCs Benzene 0.0002 ND ND 0.0125 1.35 2.7

Bromodichloromethane 0.0084 ND ND 0.0033Bromoform 0.189 0.033 0.041 0.0347 0.895 1.79Carbon Tetrachloride (4) 0.0017 NI 0.0053 0.0012 7.5 15Chloroform 0.033 0.001 0.0012 0.07 4.075 8.15Chloromethane 0.00062 NI 0.003 13.5 27Dibromochloromethane 0.0236 0.002 0.0018 0.00508Dichloroethane, 1,2- 0.0489 0.14 0.14 0.0068 5.65 11.3Dichloroethene, 1,1- (4) 0.019 NI 0.0046 0.00058 11.2 22.4Dichloropropane, 1,2- (4) 0.0003 NI 0.0033 3.04 *+ 10.3 *+Dichloropropene (4) 0.1367 NI 0.0029 0.163 0.0395 0.079Ethylbenzene (4) 0.0026 NI 0.0021 8.1 4.38 8.76Methylene Chloride 0.006 ND ND 0.087 12.8 25.6Tetrachloroethane, 1,1,2,2- 0.0109 ND 0.005 0.0018 0.451 0.902Tetrachloroethene 0.0184 ND 0.0022 0.0025 0.51 1.02Toluene 0.0004 ND 0.001 46.2 0.475 0.95Trichloroethane, 1,1,1- 0.014 ND ND 1.56 3.12Trichloroethane, 1,1,2- 0.0077 0.012 0.009 0.0069Trichloroethene 0.0106 ND 0.0005 0.021 0.1 0.2Vinyl Chloride 0.0007 0.003 ND 0.0358

SVOCs Diethyl Phthalate 0.014 0.44 0.7 1800 *Hexachlorobutadiene 0.009 ND ND 0.00011 0.00032 0.0016Naphthalene 0.016 ND 0.14 2.35 *+Nitrobenzene 0.011 ND ND 6.68 *+Nitrosodiphenylamine, N- 0.019 ND ND 0.0161 *Phenol NI 0.016 0.008 0.05 0.29 0.58

PCBs & Total PCBs 0.0023 ND ND 0.00000001 0.00003 0.01PesticidesInorganic Arsenic NI 0.0049 0.0021 0.036 0.069Elements (5) Cadmium T 0.0009 0.0014 0.01 0.04562(dissolved) Chromium 0.001 0.0073 0.0053 0.103 0.515

Copper T 0.0138 0.0168 0.00437 0.00437Lead 0.006 ND 0.017 0.0085 0.22Manganese 0.559 0.294 0.996 0.1 *Mercury 0.009 ND 0.0002 0.000025 0.0021Nickel 0.025 0.022 0.0178 0.0083 0.075Selenium ND 0.022 0.033 0.054 * 0.41 *Thallium 0.04 ND ND 0.048 * 2.13 *+Zinc 0.0327 0.209 0.046 0.086 0.095

Notes:

Concentration exceeds water quality criteria.NI Not investigated.T Compound investigated, but no dissolved concentrations were available.ND Not detected.(1) Standards are from Louisiana Administrative code unles otherwise specified.



to protect for primary and secondary contact recreation and to prevent contamination of fish and aquaticlife consumed by humans (LAC IX 1113 (c)(6)(c)).

(4) From LDEQ data.(5) Inorganics criteria are dissolved concentrations (LAC IX 1113 (c)(6)(d)).* No Louisiana criteria available. Criteria are from EPA Gold Book (Quality Criteria for Water, 1986).+ Insufficient data to develop formal criteria. EPA Gold Book value is the LOEL.

9-14

Bayou d'Inde This section presents the contaminant review for Bayou d'Inde. Our analysis is organized by major chemical group and bayou segment. The Bayou d'Inde segments include the Upstream Reach, Industrial Area, PPG Canal, and Lower Bayou d'Inde. We define these segments to facilitate the attribution of incremental pollution inputs to specific facilities or groups of facilities. As a result, segment boundaries are based on characteristics such as point source discharge locations, potential for drainage of untreated flood and storm water, and visual inspection of area and facility maps. Refer to Chapter 3 for a complete description of Bayou d'Inde and the study-defined segments. The results of the Bayou d'Inde contaminant review are presented in Exhibits 9-8 and 9-9. The majority of the discussion relies on the analysis of median chemical concentrations. At the conclusion of each major chemical group, however, we summarize relevant maximum concentration results. VOCs Fourteen of the 22 VOCs detected in Bayou d'Inde have water quality criteria. Four of these VOCs (dibromochloromethane, 1,2-dichloroethane, 1,1,2,2-tetrachloroethane, and tetrachloroethene) exceed their applicable criteria in one or more bayou segments. Each of the VOC exceedances is 1 to 4 times greater than the applicable criteria. All VOC exceedances occur for the non-drinking water human health criteria. Upstream Reach and Industrial Area Tetrachloroethene is the only VOC that exceeds the water quality criteria in the Upstream Reach and Industrial Area. PPG Canal Dibromochloromethane is the only VOC that exceeds the water quality criteria in the PPG Canal.

Exhibit 9-8BAYOU D'INDE

MEDIAN WATER CONTAMINANT CONCENTRATIONS BY SEGMENT (1)mg/l (ppm)

Chemical Threshold Criteria (2)Group Compound Name Upstream Industrial PPG Lower Bayou Non-Drinking Water Marine AWQC (3)

Reach Area Canal d'Inde Human Health (4) Chronic AcuteVOCs Benzene ND 0.0002 ND ND 0.0125 1.35 2.7

Bromodichloromethane ND 0.0005 ND 0.0031 0.0033Bromoform ND 0.012 0.007 0.028 0.0347 0.895 1.79Chloroform 0.0031 0.0051 0.0075 0.0065 0.07 4.075 8.15Dibromochloromethane ND 0.0025 0.018 0.0055 0.00508Dichloroethane, 1,2- 0.0031 0.0026 ND 0.0255 0.0068 5.65 11.3Methylene Chloride ND 0.0055 ND ND 0.087 12.8 25.6Tetrachloroethane, 1,1,2,2- 0.0008 0.0009 ND 0.0022 0.0018 0.451 0.902Tetrachloroethene 0.0045 0.0044 ND 0.0092 0.0025 0.51 1.02Toluene ND 0.0004 ND ND 46.2 0.475 0.95Trichloroethane, 1,1,1- 0.0004 0.0005 ND 0.0021 1.56 3.12Trichloroethane, 1,1,2- ND 0.001 ND 0.0032 0.0069Trichloroethene 0.0019 0.0016 ND 0.0027 0.021 0.1 0.2Vinyl Chloride ND ND ND 0.0007 0.0358

SVOCs Diethyl Phthalate ND ND 0.014 ND 1800 *Hexachlorobutadiene ND ND 0.009 0.0055 0.00011 0.00032 0.0016Naphthalene 0.005 0.013 0.005 0.005 2.35 *+Nitrobenzene ND 0.011 ND ND 6.68 *+Nitrosodiphenylamine, N- ND 0.019 ND ND 0.0161 *Phenol NI NI NI NI 0.05 0.29 0.58

PCBs & Total PCBs ND 0.0008 0.0023 ND 0.00000001 0.00003 0.01PesticidesInorganic Arsenic NI NI NI NI 0.036 0.069Elements (5) Cadmium T ND ND T 0.01 0.04562(dissolved) Chromium 0.001 0.001 T 0.001 0.103 0.515

Copper T T ND T 0.00437 0.00437Lead T T ND 0.006 0.0085 0.22Manganese 0.47 0.135 0.14 0.09 0.1 *Mercury ND ND 0.009 0.009 0.000025 0.0021Nickel ND ND ND 0.023 0.0083 0.075Selenium ND ND ND ND 0.054 * 0.41 *Thallium ND 0.031 ND 0.04 0.048 * 2.13 *+Zinc T 0.0252 0.026 0.0206 0.086 0.095

Notes:

Concentration exceeds water quality criteria.NI Not investigated.T Compound investigated, but no dissolved concentrations were available.ND Not detected.(1) Concentrations presented are the highest of the study-specific medians available for that segment.(2) Standards are from Louisiana Administrative code unles otherwise specified.


and known or suspected occurance in Louisiana waters and potential threat to attainment of desigated uses (LAC IX 1113 (c)(6)(a)).(4) Based on a cancer risk of 1x10 -6. Criteria for water bodies not designated as drinking water supplies are developed

to protect for primary and secondary contact recreation and to prevent contamination of fish and aquatic life consumed by humans (LAC IX 1113 (c)(6)(c)).(5) Inorganics criteria are dissolved concentrations (LAC IX 1113 (c)(6)(d)).* No Louisiana criteria available. Criteria are from EPA Gold Book (Quality Criteria for Water, 1986).+ Insufficient data to develop formal criteria. EPA Gold Book value is the LOEL.

Exhibit 9-9BAYOU D'INDE

MAXIMUM WATER CONTAMINANT CONCENTRATIONS BY SEGMENTmg/l (ppm)

Chemical Threshold Criteria (1)Group Compound Name Upstream Industrial PPG Lower Bayou Non-Drinking Water Marine AWQC (2)

Reach Area Canal d'Inde Human Health (3) Chronic AcuteVOCs Benzene ND 0.0002 ND ND 0.0125 1.35 2.7

Bromodichloromethane ND 0.001 ND 0.0084 0.0033Bromoform ND 0.073 0.062 0.189 0.0347 0.895 1.79Chloroform 0.0031 0.011 0.009 0.033 0.07 4.075 8.15Dibromochloromethane ND 0.007 0.018 0.0236 0.00508Dichloroethane, 1,2- 0.0031 0.0034 ND 0.0489 0.0068 5.65 11.3Methylene Chloride ND 0.006 ND ND 0.087 12.8 25.6Tetrachloroethane, 1,1,2,2- 0.0008 0.0011 ND 0.0109 0.0018 0.451 0.902Tetrachloroethene 0.0045 0.0062 ND 0.0184 0.0025 0.51 1.02Toluene ND 0.0004 ND ND 46.2 0.475 0.95Trichloroethane, 1,1,1- 0.0004 0.0006 ND 0.014 1.56 3.12Trichloroethane, 1,1,2- ND 0.0011 ND 0.0077 0.0069Trichloroethene 0.0019 0.0019 ND 0.0106 0.021 0.1 0.2Vinyl Chloride ND ND ND 0.0007 0.0358

SVOCs Diethyl Phthalate ND ND 0.014 ND 1800 *Hexachlorobutadiene ND ND 0.009 0.008 0.00011 0.00032 0.0016Naphthalene 0.005 0.016 0.005 0.005 2.35 *+Nitrobenzene ND 0.011 ND ND 6.68 *+Nitrosodiphenylamine, N- ND 0.019 ND ND 0.0161 *Phenol NI NI NI NI 0.05 0.29 0.58

PCBs & Total PCBs ND 0.0008 0.0023 ND 0.00000001 0.00003 0.01PesticidesInorganic Arsenic NI NI NI NI 0.036 0.069Elements (4) Cadmium T ND ND T 0.01 0.04562(dissolved) Chromium 0.001 0.001 T 0.001 0.103 0.515

Copper T T ND T 0.00437 0.00437Lead T T ND 0.006 0.0085 0.22Manganese 0.559 0.55 0.194 0.198 0.1 *Mercury ND ND 0.009 0.009 0.000025 0.0021Nickel ND ND ND 0.025 0.0083 0.075Selenium ND ND ND ND 0.054 * 0.41 *Thallium ND 0.031 ND 0.04 0.048 * 2.13 *+Zinc T 0.0276 0.0327 0.0288 0.086 0.095

Notes:





9-17

Lower Bayou d'Inde Four VOCs (dibromochloromethane, 1,2-dichloroethane, 1,1,2,2-tetrachloroethane, and tetrachloroethene) exceed water quality criteria in Lower Bayou d'Inde. One of these compounds, tetrachloroethene, also exceeds the criteria in the Upstream and Industrial reaches, but does not exceed the criteria in the PPG Canal. Dibromochloromethane exceeds the criteria in Lower Bayou d'Inde and the PPG Canal, but not in the Upstream or Industrial reaches. Median concentrations of 1,2-dichloroethane and 1,1,2,2-tetrachloroethane do not exceed the criteria in other areas of the bayou. Maximum Contaminant Concentrations If maximum VOC concentrations are analyzed, three additional compounds exceed water quality criteria. These compounds are bromodichloromethane (Lower Bayou d'Inde), bromoform (Industrial Area, PPG Canal, Lower Bayou d'Inde), and 1,1,2-trichloroethane (Lower Bayou d'Inde). SVOCs Five of the six SVOCs detected in Bayou d'Inde have water quality criteria. Two of these SVOCs (hexachlorobutadiene and N-nitrosodiphenylamine) exceed their applicable criteria in one or more bayou segments. Upstream Reach None of the six SVOCs with water quality criteria exceed the standards in the Upstream Reach. Industrial Area Median concentrations of N-nitrosodiphenylamine exceed the non-drinking water human health criteria in the Industrial Area. N-nitrosodiphenylamine does not exceed water quality standards in any other bayou segment. PPG Canal and Lower Bayou d'Inde Hexachlorobutadiene is the only SVOC that exceeds the criteria in the PPG Canal and Lower Bayou d'Inde. Exceedances are approximately 50 to 80 times greater than the criteria. Hexachlorobutadiene exceeds all applicable criteria, including the acute ambient water quality criteria. Hexachlorobutadiene does not exceed the criteria in the Upstream or Industrial segments.

9-18

Maximum Contaminant Concentrations Analysis of maximum SVOC concentrations yields results identical to those of median concentrations. PCBs and Pesticides PCBs (Aroclor 1242 and 1254) exceed the non-drinking water human health and ambient marine chronic criteria in the Industrial Area and PPG Canal. Note that the water quality criteria for PCBs is extremely low, and will result in PCB exceedances in nearly all cases where Aroclors are detected. Since only one sample from each segment detected Aroclor, the median and maximum results are identical. No pesticides were detected in Bayou d'Inde's ambient water. Inorganic Elements Eleven of the 12 inorganics detected in Bayou d'Inde have water quality criteria. Three of these inorganics (manganese, mercury, and nickel) exceed their applicable criteria in one or more bayou segments. The mercury concentrations are 300 times greater than the criteria. Upstream Reach and Industrial Area Manganese concentrations exceed the non-drinking water human health criteria in the Upstream and Industrial segments. No other inorganic compounds exceed the criteria in these segments. PPG Canal Concentrations of manganese and mercury exceed applicable water quality criteria in the PPG Canal. Manganese exceeds the non-drinking water human health criteria; mercury exceeds acute and chronic ambient water quality standards.

9-19

Lower Bayou d'Inde Mercury and nickel concentrations exceed the water quality criteria in Lower Bayou d'Inde. Mercury also exceeds the standard in the PPG Canal. Mercury exceeds acute and chronic ambient water quality standards; nickel exceeds the acute water quality criteria. Maximum Contaminant Concentrations Analysis of maximum inorganic concentrations yields results identical to those of median concentrations. Bayou Verdine The Bayou Verdine segments include the Upstream Reach, Vista West Ditch, Trousdale Reach, Faubacher Ditch, KCSRR Ditch, Interstate 10 Reach, and Lower Bayou Verdine.4 Refer to Chapter 4 for a complete description of Bayou Verdine and the study-defined segments. The results of the Bayou Verdine surface water contaminant review are presented in Exhibits 9-10 and 9-11. The majority of the discussion relies on the analysis of median chemical concentrations. At the conclusion of each major chemical group, however, we summarize relevant maximum concentration results. VOCs Two of the eight VOCs detected in Bayou Verdine (1,2-dichloroethane and 1,1,2-trichloroethane) exceed the water quality criteria. Concentrations of 1,2-dichloroethane exceed the non-drinking water human health criteria in five of the six segments. These include the Upstream, Vista West Ditch, Trousdale Reach, I-10 Reach, and Lower Bayou Verdine. The highest 1,2-dichloroethane concentrations are in the Upstream Reach. 1,2-Dichloroethane exceedances range from approximately 2 to 20 times the criteria. Concentrations of 1,1,2-trichloroethane exceed the non-drinking water human health criteria in the Trousdale Reach; no other reaches have concentrations exceeding the 1,1,2-trichloroethane criteria. Analysis of maximum concentrations yields identical results. SVOCs None of the six SVOCs detected in Bayou Verdine exceed the applicable standards.

4 No water data were collected from the KCSRR Ditch.

Exhibit 9-10BAYOU VERDINE


Chemical Threshold Criteria (2)Group Compound Name Upstream Vista West Trousdale Faubacher Interstate 10 Lower Bayou Non-Drinking Water Marine AWQC (3)

Reach Ditch Reach Ditch Reach Verdine Human Health (4) Chronic AcuteVOCs Benzene ND NI ND NI ND ND 0.0125 1.35 2.7

Bromodichloromethane ND NI ND NI ND ND 0.0033Bromoform ND ND ND ND 0.005 0.008 0.0347 0.895 1.79Chloroform ND ND 0.001 ND 0.001 ND 0.07 4.075 8.15Dibromochloromethane ND NI ND NI ND 0.002 0.00508Dichloroethane, 1,2- 0.132 0.0425 0.058 ND 0.023 0.014 0.0068 5.65 11.3Methylene Chloride ND ND ND ND ND ND 0.087 12.8 25.6Tetrachloroethane, 1,1,2,2- ND ND ND ND ND ND 0.0018 0.451 0.902Tetrachloroethene ND ND ND ND ND ND 0.0025 0.51 1.02Toluene ND NI ND NI ND ND 46.2 0.475 0.95Trichloroethane, 1,1,1- ND NI ND NI ND ND 1.56 3.12Trichloroethane, 1,1,2- 0.001 ND 0.0085 ND 0.0022 0.001 0.0069Trichloroethene ND NI ND NI ND ND 0.021 0.1 0.2Vinyl Chloride 0.003 ND ND ND ND ND 0.0358

SVOCs Diethyl Phthalate 0.4 NI ND NI ND 0.44 1800 *Hexachlorobutadiene ND NI ND NI ND ND 0.00011 0.00032 0.0016Naphthalene ND NI ND NI ND ND 2.35 *+Nitrobenzene ND NI ND NI ND ND 6.68 *+Nitrosodiphenylamine, N- ND NI ND NI ND ND 0.0161 *Phenol 0.007 NI 0.016 NI 0.011 0.003 0.05 0.29 0.58

PCBs & Total PCBs ND NI ND NI ND ND 0.00000001 0.00003 0.01PesticidesInorganic Arsenic T NI T NI 0.00435 0.0023 0.036 0.069Elements (5) Cadmium T NI ND NI 0.0007 0.0009 0.01 0.04562(dissolved) Chromium T NI T NI 0.003 0.0073 0.103 0.515

Copper T NI T NI 0.0023 0.0138 0.00437 0.00437Lead ND NI ND NI ND ND 0.0085 0.22Manganese T NI T NI 0.231 0.221 0.1 *Mercury ND NI ND NI ND ND 0.000025 0.0021Nickel T NI T NI 0.0134 0.0196 0.0083 0.075Selenium NI NI NI NI ND ND 0.054 * 0.41 *Thallium NI NI NI NI ND ND 0.048 * 2.13 *+Zinc T NI T NI 0.093 0.0682 0.086 0.095

Notes:





Exhibit 9-11BAYOU VERDINE


Chemical Threshold Criteria (1)Group Compound Name Upstream Vista West Trousdale Faubacher Interstate 10 Lower Bayou Non-Drinking Water Marine AWQC (2)

Reach Ditch Reach Ditch Reach Verdine Human Health (3) Chronic AcuteVOCs Benzene ND NI ND NI ND ND 0.0125 1.35 2.7

Bromodichloromethane ND NI ND NI ND ND 0.0033Bromoform ND ND ND ND 0.008 0.033 0.0347 0.895 1.79Chloroform ND ND 0.001 ND 0.001 ND 0.07 4.075 8.15Dibromochloromethane ND NI ND NI ND 0.002 0.00508Dichloroethane, 1,2- 0.14 0.044 0.063 ND 0.053 0.042 0.0068 5.65 11.3Methylene Chloride ND ND ND ND ND ND 0.087 12.8 25.6Tetrachloroethane, 1,1,2,2- ND ND ND ND ND ND 0.0018 0.451 0.902Tetrachloroethene ND ND ND ND ND ND 0.0025 0.51 1.02Toluene ND NI ND NI ND ND 46.2 0.475 0.95Trichloroethane, 1,1,1- ND NI ND NI ND ND 1.56 3.12Trichloroethane, 1,1,2- 0.001 ND 0.012 ND 0.0022 0.001 0.0069Trichloroethene ND NI ND NI ND ND 0.021 0.1 0.2Vinyl Chloride 0.003 ND ND ND ND ND 0.0358

SVOCs Diethyl Phthalate 0.4 NI ND NI ND 0.44 1800 *Hexachlorobutadiene ND NI ND NI ND ND 0.00011 0.00032 0.0016Naphthalene ND NI ND NI ND ND 2.35 *+Nitrobenzene ND NI ND NI ND ND 6.68 *+Nitrosodiphenylamine, N- ND NI ND NI ND ND 0.0161 *Phenol 0.007 NI 0.016 NI 0.013 0.003 0.05 0.29 0.58

PCBs & Total PCBs ND NI ND NI ND ND 0.00000001 0.00003 0.01PesticidesInorganic Arsenic T NI T NI 0.0049 0.0009 0.036 0.069Elements (4) Cadmium T NI ND NI 0.0007 0.0009 0.01 0.04562(dissolved) Chromium T NI T NI 0.0032 0.0073 0.103 0.515

Copper T NI T NI 0.0026 0.0138 0.00437 0.00437Lead ND NI ND NI ND ND 0.0085 0.22Manganese T NI T NI 0.294 0.293 0.1 *Mercury ND NI ND NI ND ND 0.000025 0.0021Nickel T NI T NI 0.022 0.0196 0.0083 0.075Selenium NI NI NI NI ND ND 0.054 * 0.41 *Thallium NI NI NI NI ND ND 0.048 * 2.13 *+Zinc T NI T NI 0.209 0.129 0.086 0.095

Notes:





9-22

PCBs and Pesticides No PCBs or pesticides were detected in water samples from Bayou Verdine. Inorganic Elements Seven of the eight inorganic elements detected in Bayou Verdine have water quality criteria. Four of these exceed their applicable standards in one or more segments. These compounds include copper, manganese, nickel, and zinc. Only two studies, RTI and ChemRisk 1994, report dissolved-fraction inorganic data in Bayou Verdine. Exceedances range from approximately 1 to 3 times the criteria. Upstream, Vista West Ditch, Trousdale, and Faubacher Ditch Reaches Inorganic concentration data for the Upstream, Vista West Ditch, Trousdale Reach, and Faubacher Ditch are generally expressed as total inorganics or are not detected. None of the detected inorganics expressed as dissolved-fraction exceed the water quality criteria. Interstate 10 Reach Three inorganics (manganese, nickel, and zinc) exceed applicable water quality criteria in the I-10 Reach. Manganese exceeds the non-drinking water human health criteria while nickel and zinc exceed the chronic ambient water quality standard. None of these compounds exceed the criteria upstream of the I-10 Reach. Manganese and nickel also exceed the criteria downstream in Lower Bayou Verdine; zinc exceeds the criteria only in the I-10 Reach. Lower Bayou Verdine Three inorganics (copper, manganese, and nickel) exceed applicable water quality criteria in Lower Bayou Verdine. Copper exceeds the acute/chronic standard; manganese exceeds the non-drinking water human health standard; nickel exceeds the chronic ambient water quality criteria. Manganese and nickel also exceed the criteria in the I-10 Reach. Copper exceeds the criteria only in Lower Bayou Verdine. Maximum Contaminant Concentrations Analysis of maximum inorganic concentrations yields results identical to those of median concentrations.

9-23

Calcasieu River and Ship Channel The Calcasieu River and Ship Channel segments include Lake Charles, Clooney Island Loop, Coon Island Loop, Prien Lake, Moss Lake, and Calcasieu Lake. Refer to Chapter 5 for a complete description of the Calcasieu River and Ship Channel and the study-defined segments. The results of the Calcasieu River and Ship Channel surface water contaminant review are presented in Exhibits 9-12 and 9-13. The majority of the discussion relies on the analysis of median chemical concentrations. At the conclusion of each major chemical group, however, we summarize relevant maximum concentration results. VOCs Fourteen of the 18 VOCs detected in the Calcasieu River and Ship Channel have water quality criteria. Three of these VOCs (1,2-dichloroethane, 1,1,2,2-tetrachloroethane, and 1,1,2-trichloroethane) exceed their applicable criteria. All of these exceedances occur in Coon Island Loop; no other river segments have VOC concentrations that exceed applicable criteria. Of the three compounds detected in Coon Island Loop, only 1,2-dichloroethane was detected in the I-10 Reach and Lower Bayou Verdine. Other potential sources to Coon Island Loop include surface and subsurface discharges from the PPG manufacturing facility located on Coon Island Loop's west bank. All exceedances occur for the non-drinking water human health criteria and range from approximately 1 to 2 times greater than the criteria. Maximum Contaminant Concentrations Analysis of maximum VOC concentrations yields one additional criteria exceedance. This exceedance occurs for bromoform in Prien Lake. Bayou d'Inde is one potential source of this contamination, with maximum bromoform concentrations exceeding the criteria in three of the Bayou d'Inde segments. SVOCs None of the six SVOCs detected in the Calcasieu River and Ship Channel exceed applicable water quality criteria. PCBs and Pesticides No PCBs or pesticides were detected in water samples from the Calcasieu River and Ship Channel.

Exhibit 9-12CALCASIEU RIVER AND SHIP CHANNEL


Chemical Threshold Criteria (2)Group Compound Name Lake Clooney Is. Coon Is. Prien Moss Calcasieu Non-Drinking Water Marine AWQC (3)

Charles Loop Loop Lake Lake Lake Human Health (4) Chronic AcuteVOCs Benzene ND ND ND ND ND ND 0.0125 1.35 2.7

Bromodichloromethane ND ND ND ND ND ND 0.0033Bromoform 0.0006 0.004 0.0055 0.012 0.0055 0.001 0.0347 0.895 1.79Chloroform ND ND ND 0.0009 0.001 ND 0.07 4.075 8.15Dibromochloromethane ND ND ND 0.0018 ND ND 0.00508Dichloroethane, 1,2- ND ND 0.0195 0.001 ND ND 0.0068 5.65 11.3Methylene Chloride ND ND ND ND ND ND 0.087 12.8 25.6Tetrachloroethane, 1,1,2,2- ND ND 0.005 0.00035 ND ND 0.0018 0.451 0.902Tetrachloroethene ND 0.001 ND 0.0014 0.001 ND 0.0025 0.51 1.02Toluene ND ND 0.001 ND ND ND 46.2 0.475 0.95Trichloroethane, 1,1,1- ND ND ND ND ND ND 1.56 3.12Trichloroethane, 1,1,2- ND ND 0.009 0.0003 ND ND 0.0069Trichloroethene ND ND ND 0.00045 ND ND 0.021 0.1 0.2Vinyl Chloride ND ND ND ND ND ND 0.0358

SVOCs Diethyl Phthalate 0.45 0.46 0.4 0.011 0.22 0.15 1800 *Hexachlorobutadiene ND ND ND ND ND ND 0.00011 0.00032 0.0016Naphthalene ND ND ND 0.0135 ND ND 2.35 *+Nitrobenzene ND ND ND ND ND ND 6.68 *+Nitrosodiphenylamine, N- ND ND ND ND ND ND 0.0161 *Phenol 0.002 0.0025 0.002 ND 0.005 0.004 0.05 0.29 0.58

PCBs & Total PCBs ND ND ND ND ND ND 0.00000001 0.00003 0.01PesticidesInorganic Arsenic 0.0021 0.0011 0.001 ND ND ND 0.036 0.069Elements (5) Cadmium 0.0014 0.0008 0.0007 0.0008 0.0006 0.0009 0.01 0.04562(dissolved) Chromium 0.005 0.0045 0.0037 0.0024 0.0012 0.0012 0.103 0.515

Copper 0.0019 0.0012 0.0025 0.0063 0.0119 0.0022 0.00437 0.00437Lead ND ND 0.012 ND ND 0.0037 0.0085 0.22Manganese 0.172 0.156 0.056 0.1445 0.077 0.0095 0.1 *Mercury ND ND ND 0.0001 0.0002 ND 0.000025 0.0021Nickel 0.0006 0.01 0.0062 0.0134 0.0017 0.0021 0.0083 0.075Selenium NI NI 0.033 ND NI NI 0.054 * 0.41 *Thallium NI NI ND ND NI NI 0.048 * 2.13 *+Zinc 0.029 0.0026 0.0054 0.0218 0.0032 0.0049 0.086 0.095

Notes:





Exhibit 9-13CALCASIEU RIVER AND SHIP CHANNEL


Chemical Threshold Criteria (1)Group Compound Name Lake Clooney Is. Coon Is. Prien Moss Calcasieu Non-Drinking Water Marine AWQC (2)

Charles Loop Loop Lake Lake Lake Human Health (3) Chronic AcuteVOCs Benzene ND ND ND ND ND ND 0.0125 1.35 2.7

Bromodichloromethane ND ND ND ND ND ND 0.0033Bromoform 0.0006 0.005 0.007 0.041 0.006 0.001 0.0347 0.895 1.79Chloroform ND ND ND 0.0012 0.001 ND 0.07 4.075 8.15Dibromochloromethane ND ND ND 0.0018 ND ND 0.00508Dichloroethane, 1,2- ND ND 0.14 0.005 ND ND 0.0068 5.65 11.3Methylene Chloride ND ND ND ND ND ND 0.087 12.8 25.6Tetrachloroethane, 1,1,2,2- ND ND 0.005 0.0005 ND ND 0.0018 0.451 0.902Tetrachloroethene ND 0.001 ND 0.0022 0.001 ND 0.0025 0.51 1.02Toluene ND ND 0.001 ND ND ND 46.2 0.475 0.95Trichloroethane, 1,1,1- ND ND ND ND ND ND 1.56 3.12Trichloroethane, 1,1,2- ND ND 0.009 0.0003 ND ND 0.0069Trichloroethene ND ND ND 0.0005 ND ND 0.021 0.1 0.2Vinyl Chloride ND ND ND ND ND ND 0.0358

SVOCs Diethyl Phthalate 0.45 0.7 0.6 0.011 0.22 0.22 1800 *Hexachlorobutadiene ND ND ND ND ND ND 0.00011 0.00032 0.0016Naphthalene ND ND ND 0.14 ND ND 2.35 *+Nitrobenzene ND ND ND ND ND ND 6.68 *+Nitrosodiphenylamine, N- ND ND ND ND ND ND 0.0161 *Phenol 0.002 0.003 0.002 ND 0.006 0.008 0.05 0.29 0.58

PCBs & Total PCBs ND ND ND ND ND ND 0.00000001 0.00003 0.01PesticidesInorganic Arsenic 0.0021 0.0011 0.001 ND ND ND 0.036 0.069Elements (4) Cadmium 0.0014 0.0008 0.0008 0.001 0.0006 0.001 0.01 0.04562(dissolved) Chromium 0.0053 0.0048 0.0105 0.0038 0.0014 0.0028 0.103 0.515

Copper 0.0019 0.0016 0.0035 0.0063 0.0168 0.0036 0.00437 0.00437Lead ND ND 0.017 ND ND 0.0046 0.0085 0.22Manganese 0.2 0.285 0.996 0.291 0.095 0.035 0.1 *Mercury ND ND ND 0.0001 0.0002 ND 0.000025 0.0021Nickel 0.0006 0.0108 0.0178 0.0134 0.0019 0.0028 0.0083 0.075Selenium NI NI 0.033 ND NI NI 0.054 * 0.41 *Thallium NI NI ND ND NI NI 0.048 * 2.13 *+Zinc 0.046 0.0042 0.0158 0.0269 0.004 0.0093 0.086 0.095

Notes:





9-26

Inorganic Elements Ten of the 12 inorganic elements detected in the Calcasieu River and Ship Channel have water quality criteria. Five of the inorganic elements with water quality criteria exceed applicable standards. These compounds include copper, lead, manganese, mercury, and nickel. Exceedances range from approximately 1 to 8 times greater than the criteria. Lake Charles and Clooney Island Loop Manganese concentrations exceed the non-drinking water human health criteria in both Lake Charles and Clooney Island Loop. Manganese also exceeds the criteria further downstream in Prien Lake. Nickel exceeds the marine chronic ambient water quality criteria in Clooney Island Loop. Coon Island Loop Lead exceeds the marine chronic ambient water quality criteria in Coon Island Loop. Lead does not exceed the standard in any other portion of the river or Bayou Verdine. No other inorganics exceed the criteria in Coon Island Loop. Prien Lake Four inorganics (copper, manganese, mercury, and nickel) exceed water quality criteria in Prien Lake. Copper, mercury, and nickel exceed the chronic ambient water quality criteria; manganese exceeds the non-drinking water human health standard. Only manganese and nickel have observed criteria exceedances in upstream portions of the river. Copper, however, exceeds the criteria in Lower Bayou Verdine and mercury exceeds the criteria in the PPG Canal and Lower Bayou d'Inde. Maximum Contaminant Concentrations No significant changes in the inorganic results occur when maximum concentrations are compared to the water quality criteria. There are no additional inorganics with exceedances; however, the geographic range of criteria exceedances for manganese and nickel extends to Coon Island Loop under maximum concentrations.

9-27

LDEQ Data The Louisiana Department of Environmental Quality (LDEQ) has measured ambient water conditions in the Calcasieu Estuary on a monthly basis since 1987. LDEQ collects water samples from seventeen discrete sampling locations within the estuary. Stations range from the saltwater barrier near Lake Charles to the southern end of Calcasieu Lake, and include Bayou d'Inde, Prien Lake, and portions of the Calcasieu River and Ship Channel. Over the history of the program, LDEQ has collected more than 2,000 water samples. These samples are analyzed for volatile organic compounds and conventional parameters such as dissolved oxygen and salinity. LDEQ does not analyze the data for semivolatile organics, pesticides, PCBs, or inorganic elements. The LDEQ data are segregated from the results of the other studies because the state water data include more than eight years of monitoring information. Other studies referenced in this report provide data for a single point in time. Similarly, LDEQ limits its analysis to volatile organic compounds, whereas other studies measure a wider range of chemical groups. Results of the LDEQ review are provided in Exhibits 9-14 and 9-15. Water quality criteria are available for 20 of the VOCs measured by LDEQ. Note that because of the large number of compounds and years analyzed, the data exhibit considerable differences in the number of compounds exceeding the criteria when comparing median and maximum concentrations. Median concentrations of only four compounds exceed the criteria. Using maximum concentrations, however, 12 compounds exceed the criteria. Lake Charles, Clooney Island Loop, Coon Island Loop Prien Lake, and Moss Lake None of the VOCs (median concentrations) exceed applicable water quality criteria. Bayou d'Inde Median concentrations of two VOCs (1,1,2,2-tetrachloroethane and tetrachloroethene) exceed the non-drinking water human health criteria in Bayou d'Inde. Other studies of Bayou d'Inde also show that these compounds exceed the criteria. Calcasieu Lake Median concentrations of carbon tetrachloride and 1,1-dichloroethene exceed the non-drinking water human health criteria in Calcasieu Lake.

Exhibit 9-14LDEQ DATA

MEDIAN WATER CONTAMINANT CONCENTRATIONS BY SEGMENTmg/l (ppm)

Chemical Threshold Criteria (1)Group Compound Name Lake Clooney Is. Coon Is. Bayou Prien Moss Calcasieu Non-Drinking Water Marine AWQC (2)

Charles Loop Loop d'Inde Lake Lake Lake Human Health (3) Chronic AcuteVOCs Benzene 0.00025 0.00022 0.0002 0.000335 0.00018 0.0003 0.00021 0.0125 1.35 2.7

Bromodichloromethane ND 0.00005 0.00032 0.0011 ND 0.00012 0.00015 0.0033Bromoform 0.00014 0.00051 0.00169 0.01705 0.00105 0.0026 0.0007 0.0347 0.895 1.79Carbon Tetrachloride 0.0002 ND 0.0001 0.00056 0.0003 0.00035 0.0053 0.0012 7.5 15Chloroform 0.000095 0.0002 0.00033 0.006 0.00048 0.0005 0.0002 0.07 4.075 8.15Chloromethane 0.00033 ND 0.00038 0.00021 ND 0.00011 0.00003 13.5 27Dibromochloromethane 0.00015 0.0001 0.0006 0.0031 0.00025 0.0009 0.00025 0.00508Dichloroethane, 1,2- (EDC) 0.000385 0.0004 0.00121 0.00448 0.0004 0.0007 0.00034 0.0068 5.65 11.3Dichloroethene, 1,1- ND ND ND 0.00016 0.0004 0.0001 0.00385 0.00058 11.2 22.4Dichloropropane, 1,2- ND ND 0.00035 0.0003 ND 0.000615 ND 3.04 *+ 10.3 *+Dichloropropene ND ND ND 0.0031 ND 0.000159 ND 0.163 0.0395 0.079Ethylbenzene 0.0008 ND 0.0002 0.00215 0.00095 0.0008 0.0007 8.1 4.38 8.76Methylene Chloride 0.00015 0.00014 0.0002 0.0003 0.00015 0.00021 0.00015 0.087 12.8 25.6Tetrachloroethane, 1,1,2,2- 0.000085 0.00019 0.00024 0.00305 0.00023 0.00039 0.0002 0.0018 0.451 0.902Tetrachloroethene 0.00017 0.0002 0.00018 0.00302 0.0002 0.0004 0.0002 0.0025 0.51 1.02Toluene 0.00028 0.00021 0.0003 0.000315 0.0007 0.0007 0.0006 46.2 0.475 0.95Trichloroethane, 1,1,1- 0.0001 ND 0.00039 0.0012 0.00017 0.000185 0.0005 1.56 3.12Trichloroethane, 1,1,2- 0.00013 0.0001 0.0003 0.0022 0.000295 0.000315 0.0002 0.0069Trichloroethene 0.00015 0.0001 0.0001 0.0012 0.00008 0.00016 0.0001 0.021 0.1 0.2Vinyl Chloride 0.0048 0.00395 0.0047 0.0004 0.00345 0.00075 0.0012 0.0358

Notes:




to protect for primary and secondary contact recreation and to prevent contamination of fish and aquatic life consumed by humans (LAC IX 1113 (c)(6)(c)).* No Louisiana criteria available. Criteria are from EPA Gold Book (Quality Criteria for Water, 1986).+ Insufficient data to develop formal criteria. EPA Gold Book value is the LOEL.

Exhibit 9-15LDEQ DATA


Chemical Threshold Criteria (1)Group Compound Name Lake Clooney Is. Coon Is. Bayou Prien Moss Calcasieu Non-Drinking Water Marine AWQC (2)

Charles Loop Loop d'Inde Lake Lake Lake Human Health (3) Chronic AcuteVOCs Benzene 0.00214 0.0006 0.00084 0.0083 0.00097 0.0026 0.00294 0.0125 1.35 2.7

Bromodichloromethane ND 0.00005 0.0026 0.0286 ND 0.0058 0.0006 0.0033Bromoform 0.00038 0.0132 0.0186 0.185 0.00831 0.201 0.0784 0.0347 0.895 1.79Carbon Tetrachloride 0.0002 ND 0.0001 0.0017 0.0004 0.0013 0.0053 0.0012 7.5 15Chloroform 0.00069 0.042 0.00499 0.0521 0.0007 0.0087 0.0255 0.07 4.075 8.15Chloromethane 0.00033 ND 0.003 0.00062 ND 0.00035 0.00003 13.5 27Dibromochloromethane 0.0002 0.00112 0.0029 0.04 0.0005 0.00611 0.0022 0.00508Dichloroethane, 1,2- (EDC) 0.034 0.114 0.124 0.0525 0.199 0.0214 0.015 0.0068 5.65 11.3Dichloroethene, 1,1- ND ND ND 0.019 0.0004 0.0004 0.0046 0.00058 11.2 22.4Dichloropropane, 1,2- ND ND 0.0004 0.0003 ND 0.0033 ND 3.04 *+ 10.3 *+Dichloropropene ND ND ND 0.1367 ND 0.0029 ND 0.163 0.0395 0.079Ethylbenzene 0.00115 ND 0.00022 0.0026 0.0017 0.0021 0.0019 8.1 4.38 8.76Methylene Chloride 0.00074 0.00093 0.0017 0.00539 0.00089 0.0019 0.002 0.087 12.8 25.6Tetrachloroethane, 1,1,2,2- 0.00026 0.00033 0.0024 0.045 0.00059 0.0066 0.0025 0.0018 0.451 0.902Tetrachloroethene 0.0003 0.00148 0.0025 0.033 0.0013 0.0036 0.0021 0.0025 0.51 1.02Toluene 0.00534 0.0022 0.0011 0.013 0.003 0.0046 0.0067 46.2 0.475 0.95Trichloroethane, 1,1,1- 0.0004 ND 0.0075 0.00724 0.0026 0.0035 0.0045 1.56 3.12Trichloroethane, 1,1,2- 0.00016 0.0009 0.0073 0.0224 0.00055 0.0123 0.0042 0.0069Trichloroethene 0.0006 0.0005 0.0091 0.0239 0.0003 0.00016 0.0016 0.021 0.1 0.2Vinyl Chloride 0.0048 0.0088 0.0227 0.038 0.0124 0.0078 0.0087 0.0358

Notes:




to protect for primary and secondary contact recreation and to prevent contamination of fish and aquatic life consumed by humans (LAC IX 1113 (c)(6)(c)).* No Louisiana criteria available. Criteria are from EPA Gold Book (Quality Criteria for Water, 1986).+ Insufficient data to develop formal criteria. EPA Gold Book value is the LOEL.

9-30

Maximum Contaminant Concentrations Using maximum contaminant concentrations, 12 VOCs exceed water quality criteria. These include bromodichloromethane, bromoform, carbon tetrachloride, dibromochloromethane, 1,2-dichloroethane, 1,1-dichloroethene, dichloropropene, 1,1,2,2-tetrachloroethane, tetrachloroethene, 1,1,2-trichloroethane, trichloroethene, and vinyl chloride. One compound, 1,2-dichloroethane, exceeds the criteria in every LDEQ segment. With the exception of dichloropropene, all other compounds exceed the criteria in multiple segments. Bayou d'Inde has more contaminant exceedances than any of the river segments; all 12 of the compounds exceeding the criteria did so in Bayou d'Inde. Moss Lake has eight compounds exceeding the criteria, followed by Calcasieu Lake with five.

10-1

SEDIMENT INJURY EVALUATION AND CONTAMINANT REVIEW CHAPTER 10 This chapter reviews the contaminants affecting the biological resources residing in the sediments of the Calcasieu Estuary. The first part of the chapter summarizes the regulatory framework for determining natural resource injury to biological resources and identifies contaminants that are likely to meet these criteria. The remainder of the chapter presents a detailed analysis of sediment contamination levels for the entire Calcasieu Estuary. SEDIMENT-DWELLING ORGANISM INJURY ASSESSMENT The Department of the Interior (DOI) has promulgated natural resource damage assessment regulations governing injury to biological resources at 43 CFR 11.62(f). With respect to sediment-dwelling organisms, the relevant part of the regulation states: "An injury to a biological resource has resulted from the discharge of oil or

release of a hazardous substance if concentration of the substance is sufficient to cause the biological resource or its offspring to have undergone at least one of the following adverse changes in viability: death, disease, behavioral abnormalities, cancer, genetic mutations, physiological malfunctions (including malfunctions in reproduction), or physical deformations" (43 CFR 11.62(f)(1)(i)).1

Studies conducted to test the existence or significance of these effects must show a measurable biological response and satisfy the following requirements (summarized from 43 CFR 11.62(f)(2)): (1) The biological response is the result of exposure to the hazardous substances;

1 Sediment-dwelling organisms fall within the DOI definition of biological resources at 43 CFR 11.14(f).

10-2

(2) Exposure to the hazardous substance is known to cause the specific biological response in free-ranging organisms;

(3) Exposure to the hazardous substance is known to cause the specific biological

response in controlled experiments; (4) The biological response measurement is practical to perform and produces

scientifically valid results. The DOI regulations also state that injury to surface water exists when biological resources are injured as a result of exposure to contaminated sediments and surface water: "An injury to a surface water resource has resulted from the discharge of oil or

release of a hazardous substance if....concentrations and duration of substances sufficient to have caused injury...to ground water, air, geologic, or biological resources, when exposed to surface water, suspended sediments, or bed, bank, or shoreline sediments" (43 CFR 11.62(1)(b)(v)).

Area-specific studies are required to determine injury as defined by the DOI regulations, and we did not conduct a review for existing toxicity studies that evaluate Calcasieu Estuary sediments and biota against these criteria. SEDIMENT CONTAMINANT REVIEW The remainder of Chapter 10 presents the detailed review of sediment contaminant concentrations compared to available sediment thresholds. This section of Chapter 10 begins with a summary of our findings and a discussion of the methodology we use to evaluate sediment thresholds and aggregate the sediment data. We then evaluate each contaminant for exceedances of sediment thresholds within the estuary's major geographic areas. We then present the results of the contaminant review on a segment-by-segment basis. Summary We identify contaminants that are likely to be associated with injury to sediment-dwelling biological resources by comparing median sediment contaminant concentrations from the Calcasieu Estuary with endpoint-based thresholds. These thresholds are derived from the current literature; they are developed specifically to identify sediment contaminant concentrations sufficient to induce biological effects similar to the adverse changes defined by the DOI regulations (e.g., mortality, reproductive effects, and avoidance behavior). Studies of the Calcasieu Estuary have detected 116 different compounds in area sediments. We identified thresholds for 44 of these compounds. In comparing the sediment

10-3

concentrations to contaminant thresholds, a total of 36 compounds exceed thresholds. Exhibit 10-1 lists these 36 compounds by estuary area. Within Bayou d'Inde, a total of 25 compounds exceed sediment effect thresholds. Most of these compounds also exceed thresholds in other estuary areas. Eight compounds, however, exceed the thresholds only in Bayou d'Inde: butyl benzyl phthalate, 1,2-dichlorobenzene, 1,4-dichlorobenzene, hexachlorobutadiene, phenol, 1,2,4-trichlorobenzene, 4,4'-DDE, and endrin. Within Bayou Verdine, 24 of the 44 compounds with thresholds register exceedances. Only three of these 24 compounds (n-nitrosodiophenylamine, nickel, and zinc) are unique to Bayou Verdine. Threshold exceedances are most predominant in the I-10 Reach and Lower Bayou Verdine (segments 10 and 11). Twenty-two compounds exceed thresholds in the Calcasieu River and Ship Channel. Ethylbenzene and diethyl phthalate exceedances are unique to the river. All other compounds register exceedances in multiple areas of the estuary. With the exception of hexachlorobenzene, all threshold exceedances occur within the Coon Island Loop (segment 14). Exhibit 10-2 reviews all of the sediment contaminants. The first column of Exhibit 10-2 lists contaminants that exceed sediment thresholds using median concentrations. The second column lists additional contaminants of concern (i.e., those contaminants without threshold values and contaminants with maximum concentrations that exceed the thresholds). The last column lists contaminants that have been detected in Calcasieu Estuary sediments, but that are not present in sufficient concentrations to warrant further analysis.

10-4

Exhibit 10-1

SEDIMENT-EFFECT THRESHOLD EXCEEDANCES BY ESTUARY AREA

Bayou d'Inde Bayou Verdine

Calcasieu River

Ethylbenzene U Tetrachloroethene U U Xylene (total) U U U Acenaphthene U U U Anthracene U U Benzo(a)Anthracene U U U Benzo(a)Pyrene U U U Benzo(b)Fluoranthene U U Benzo(g,h,i)Perylene U U bis(2-ethylhexyl)phthalate U U U Butyl Benzyl Phthalate U Chrysene U U U Di-n-Butylphthalate U U Dibenzo(a,h)Anthracene U U U Dibenzofuran U U Dichlorobenzene, 1,2- U Dichlorobenzene, 1,4- U Diethyl Phthalate U Fluoranthene U U Fluorene U U U Hexachlorobenzene U U Hexachlorobutadiene U Indeno(1,2,3-cd)Pyrene U U U Methylnaphthalene, 2- U U U Naphthalene U U U Nitrosodiophenylamine, N- U Phenanthrene U U U Phenol U PCBs U U Pyrene U U Trichlorobenzene, 1,2,4- U DDE, 4,4'- U Endrin U Mercury U U Nickel U Zinc U Notes With the exception of hexachlorobenzene, all of the contaminants registering exceedances

within Calcasieu River sediments are from the Coon Island Loop (segment 14). If we use maximum concentrations, the following compounds also exceed thresholds: Bayou d'Inde: Benzo(g,h,i)perylene, dieldrin, chromium, copper, lead, zinc. Bayou Verdine: Cadmium, chromium. Calcasieu River: Chromium, lead, mercury, nickel, zinc.

10-5

Exhibit 10-2

SEDIMENT CONTAMINANT REVIEW

Contaminants of Concern Contaminants that Exceed Sediment

Thresholds

Additional Contaminants of Concern Contaminants that Do Not Exceed

Sediment Thresholds Ethylbenzene Tetrachloroethene Xylene (total) Acenaphthene Anthracene Benzo(a)Anthracene Benzo(a)Pyrene Benzo(b)Fluoranthene Benzo(g,h,i)Perylene bis(2-ethylhexyl)phthalate Butyl Benzyl Phthalate Chrysene Di-n-Butylphthalate Dibenzo(a,h)Anthracene Dibenzofuran Dichlorobenzene, 1,2- Dichlorobenzene, 1,4- Diethyl Phthalate Fluoranthene Fluorene Hexachlorobenzene Hexachlorobutadiene Indeno(1,2,3-cd)Pyrene Methylnaphthalene, 2- Naphthalene Nitrosodiophenylamine, N- Phenanthrene Phenol Pyrene Trichlorobenzene, 1,2,4- PCBs (total) DDE, 4,4'- Endrin Mercury Nickel Zinc

Acetone Benzene Butanone, 2- Carbon Disulfide Chlorobenzene Chloroethane Chloroform Dichloroethane, 1,1- Dichloroethane, 1,2- Dichloroethene, 1,1- Dichloroethene, 1,2- (total) Methylene Chloride Tetrachloroethane, 1,1,2,2- Toluene Trichloroethane, 1,1,1- Trichloroethane, 1,1,2- Trichloroethene Vinyl Chloride Bis(2-Chloroethyl)Ether Carbazole Chlorophenyl-phenylether, 4- Dichlorobenzene, 1,3- Hexachlorocyclopentadiene Hexachloroethane Isophorone TPH-Diesel TPH-Gasoline Bis(2-Methoxyethyl)Phthalate Butyl 2-Methyl Propyl Phthalate Chloroethylvinyl-Ether, 2- Decahydronaphthalene Isomer Dimethyl Naphthalene Ethyl Naphthalene Methyl Parathion Methyl Trithion

Pentyl Cyclohexane Tetrachlorobenzene, 1,2,3,5- Tetramethyl Heptadecane, 2,6,10,15- Tetramethyl Pentadecane, 2,6,10,14- Trimethyl Dodecane Isomer Trithion Aldrin BHC, alpha- BHC, beta- BHC, delta- BHC, gamma- (Lindane) Chlordane, alpha- Chlordane, gamma- Dieldrin DDD, 4,4'- DDT, 4,4'- Endosulfan II Endosulfan Sulfate Endosulfan I Endrin Aldehyde Endrin Ketone Heptachlor Heptachlor Epoxide Methoxychlor Toxaphene Beryllium Cadmium Chromium Copper Iron Lead Magnesium Manganese Selenium Thallium

Benzo(k)Fluoranthene Arsenic Silver

10-6

Methodology The sediment contaminant review compares sediment data from the Calcasieu Estuary with biological effect thresholds. The sediment review consists of two steps: (1) Compilation of sediment thresholds; (2) Aggregation of sediment contamination data, and comparison with the thresholds. Each step is discussed below. Compilation of Sediment Thresholds Using the current literature, we identify four categories of sediment thresholds to use in this analysis. The thresholds in this study include: (1) Effect Range-Medians (ER-Ms); (2) Sediment Quality Criteria (SQC); (3) Washington State Sediment Quality Standards; and (4) Apparent Effects Thresholds (AETs). Using these values, we obtain sediment thresholds for 44 of the 116 contaminants detected in the Calcasieu Estuary. Twenty-three of these values (52 percent) are ER-Ms; two of the values are SQCs (5 percent); 13 are from Washington State (30 percent); and six are NOAA AETs (14 percent). These thresholds identify sediment contaminant concentrations that are likely to reduce the viability of sediment-dwelling organisms. The threshold values are derived using techniques such as spiked sediment bioassays, benthic community studies, and laboratory toxicity testing. These tests are based on a variety of biological endpoints, many of which are similar to the biological responses included in DOI's damage assessment regulations. Example endpoints include: (1) Acute or chronic mortality; (2) Reduced growth; (3) Impaired reproduction; (4) Abnormal development; (5) Increased incidence of tumor or pre-cancerous lesions; (6) Altered organ morphology or size; (7) Avoidance behavior; (8) Altered benthic community structure. Below, we briefly review each of the thresholds used in the sediment analysis.

10-7

Effects Range-Median (ER-M). ER-Ms represent the median of the ranked hazardous substance concentrations observed to be associated with a biological effect. ER-Ms utilize data from a suite of study types, endpoints, and biological organisms. Note that we also consider Effects Range-Low (ER-Ls) within our analysis. Because of the high contamination levels within the Calcasieu Estuary, however, analysis based on ER-Ls does not provide adequate contaminant screening; nearly all compounds exceed the ER-Ls within the estuary. ER-Ms provide a more effective screening threshold to assist in the identification of injury.

Sediment Quality Criteria (SQC). SQCs identify the concentration of hazardous

substance in sediment associated with the EPA Water Quality Criteria (WQC). This value is calculated using an equilibrium partitioning model and is dependent on the amount of organic carbon in the sediment. Since SQCs are based on WQCs they are expected to be predictive of biological effects. Benthic organisms should be "acceptably" protected at concentrations at or below the SQC, "except possibly where a locally important species is very sensitive."2

Washington State Sediment Quality Standards. The State of Washington has

promulgated standards that regulate the highest level of hazardous substance contamination at which no adverse effects to biological resources (acute or chronic) or human health are observed. Endpoints considered in developing these values include amphipod mortality, larval survivorship, and benthic abundance.

Apparent Effects Threshold (AET). AETs are highest levels of hazardous

substance contamination at which no adverse biological effects are observed. The lowest value among four biological tests (amphipod bioassay, benthic community, Microtox bioassay, and oyster larvae bioassay) is selected as an AET.

Threshold Hierarchy When more than one of the above four thresholds is available for a compound, we select the threshold for this analysis according to the following hierarchy: (1) ER-Ms (2) SQCs (3) Washington State Values (4) AETs

2 EPA (U.S. Environmental Protection Agency). 1993. Sediment Quality Criteria for the Protection of Benthic Organisms: Dieldrin and Endrin. United States Environmental Protection Agency, Washington D.C.

10-8

ER-Ms are considered first because these values are well-documented in the literature. Further, the ER-Ms are highly comparable to the other marine sediment benchmark values, with the average ratio of ER-Ms to the other thresholds being less than three. When ER-Ms are not available for a compound, we utilize SQCs, which are applicable to a wide range of marine sediments. For compounds without ER-Ms or SQCs, we refer to the Washington State values and AETs. Other Available Thresholds Several other potential threshold values also are available. These include: NOAA Threshold Effects and Probable Effects Levels (TELs and PELs), Sediment Quality Benchmark values (SQBs) proposed by the U.S. EPA, and Provincial Sediment Quality Guidelines (PSQGs) developed by the Ontario Ministry of the Environment. We did not use TEL and PEL threshold concentrations in our analysis because they generally are equivalent to ER-Ms and ER-Ls. To ensure that ER-Ms and ER-Ls are appropriate substitutes for TELs and PELs, we conducted a comparability analysis. The results indicate that these thresholds are generally comparable (e.g., ER-Ms and PELs agree within a factor of two for inorganic elements).3 The SQB and PSQG thresholds are based on equilibrium partitioning theory for organic compounds, which assumes specific relationships between biological effects in surface water and sediment. We did not use the SQBs and PSQG because they are immediately applicable to freshwater environments only. Organic Carbon Normalization The thresholds in this study use slightly different procedures with respect to organic carbon normalization. ER-Ms and AETs are presented as dry weight. They are developed using a national database with an average organic carbon content of one to two percent and are not normalized. SQCs are normalized to one percent organic carbon. Washington State values are presented as total organic carbon concentrations, which we normalize to one percent organic carbon. The sediment data that we use for this analysis are presented in dry weight. Comparisons of these data to the ER-Ms and AETs are based on consistent measurement standards. This encompasses 65 percent of our threshold comparisons. Comparisons using the Washington State values and SQCs, however, are slightly inconsistent because our data are not organic carbon

3 In the 1991 workshop concerning sediment quality assessment and development of sediment quality objectives sponsored by the California State Water Resources Control Board (Lorenzato et al. 1991) the participants agreed that a factor of three between studies was generally acceptable as comparable.

10-9

normalized. This encompasses 35 percent of our thresholds. Given the large magnitude of the threshold exceedances and the small percentage of thresholds affected, we do not expect that this slight inconsistency will significantly impact the results. Aggregation of Sediment Contamination Data This chapter relies on data from five of the eight studies identified in Chapter 2. These include: ChemRisk 1994, ChemRisk 1995, PRC 1993, PRC 1994, and EPA 1996.4 We also use the RTI study when other data are not available. We compile these data on a dry weight basis for the threshold comparisons. Note, however, that the sediment data presented in Part I are reported on a wet weight basis.5 Our approach for compiling these data and converting the results to dry weight concentrations is described below. We compare median and maximum sediment concentrations to the contaminant thresholds. To determine the median and maximum values, we rank the available wet weight data and identify the median and maximum observations for each contaminant and segment. Since these values are in wet weight, we use sample identification numbers and refer to the original studies to identify the dry weight counterparts. This process does not involve mathematical data conversions; rather, the ChemRisk, PRC, and EPA studies report equivalent dry weight results. RTI reports data for organics on a wet weight basis; as such these measurements are not directly comparable to the threshold values. When no other data source is available for a given segment, however, we report available wet weight concentrations from the RTI study. Similarly, when the maximum dry weight value from other studies is less than the wet weight concentration reported in RTI, we defer to the larger wet weight result. Using these wet weight concentrations for threshold comparisons is conservative since the equivalent dry weight measurement would be higher. All data from the RTI study are noted with a (w) qualifier. Note that this process converts to dry weight only two of the ranked wet weight values -- the median and maximum. This assumes that the ranked wet weight data exhibit a one-to-one correspondence with the dry weight data. That is, if all of the wet weight data were converted to dry weight, the order of each sample would be unaffected. Since these conversions are based on the moisture content of each sample, it is unlikely that this assumption will hold in some cases.

4 We do not use two of the original studies -- LDEQ and ITC. LDEQ is a water sampling program that does not contain any sediment data. The ITC study was eliminated because sample-specific moisture contents are not available within the report. Further, the ITC data are of less importance since they are applicable only to the isolated portion of the PPG Canal.

5 We use wet weight data in Part I to maximize the number of studies available to characterize the condition of Calcasieu Estuary sediments. Since the thresholds are based on dry weight, however, we converted the wet weight data to dry weight for use in Part III.

10-10

As a result, the calculated dry weight median and maximum may not be the true parameters for all samples. Results and Discussion This section presents summary results for the overall estuary. We also present individual analyses for Bayou d'Inde, Bayou Verdine, and the Calcasieu River and Ship Channel based on the segment-level data. Unless noted otherwise, all analyses are conducted using median sediment concentrations. Summary of Results Exhibit 10-3 compares median sediment contaminant concentrations for Bayou d'Inde, Bayou Verdine, and the Calcasieu River and Ship Channel to the sediment thresholds. Concentrations for 36 of the 44 compounds with thresholds exceed the screening values. Bayou d'Inde exhibits the greatest number of exceedances (25), followed closely by Bayou Verdine (24) and the Calcasieu River and Ship Channel (22). An additional 66 compounds do not have associated thresholds. Note that these summary data reflect only the most contaminated segment within each area. Therefore, it is important to supplement the estuary results with the segment-level data presented below. Twenty-three of the 36 compounds exceed applicable thresholds in multiple areas of the estuary, while thirteen compounds are unique to individual estuary areas. Bayou d'Inde exhibits the largest number of unique compounds (8). These include butyl benzyl phthalate, 1,2-dichlorobenzene, 1,4-dichlorobenzene, hexachlorobutadiene, phenol, 1,2,4-trichlorobenzene, 4,4'-DDE, and endrin. With respect to chemical groups, SVOCs had the greatest number of thresholds (28) and the most exceedances (27) -- an exceedance rate of 96 percent. VOCs, however, had few associated thresholds (3); although, all of the VOC thresholds are exceeded in at least one estuary area. Total PCBs exceed applicable thresholds in Bayou d'Inde and the Calcasieu River and Ship Channel. Pesticides have only three threshold values, and do not appear to be wide-spread throughout the estuary. Three of the nine inorganic elements (33 percent) exceed thresholds in Bayou d'Inde and Bayou Verdine -- well below the exceedance rate for SVOCs. Using maximum concentrations, 41 of the 44 compounds with thresholds exceed the screening values. The three compounds not exceeding thresholds are benzo(k)fluoranthene, arsenic, and silver.

Exhibit 10-3

SEDIMENT SUMMARY TABLE MEDIAN CONTAMINANT CONCENTRATIONS BY ESTUARY AREA

mg/kg (ppm) dry weight(maximum of all individual segment medians by estuary area)

Chemical Group Compound Bayou d'Inde Bayou Verdine

Calcasieu River Threshold

VOCs Ethylbenzene1 ND ND 0.133 0.01Tetrachloroethene1 6504 0.141 0.021 0.057Xylene (total)1 0.23 0.042 0.056 0.04

SVOCs Acenaphthene 1.1 5.8 4.86 0.5Anthracene 0.7 15 2.7 1.1Benzo(a)Anthracene 2.15 33 4.48 1.6Benzo(a)Pyrene 1.65 22 3.55 1.6Benzo(b)Fluoranthene1 1.9 27.5 5.95 3.2Benzo(g,h,i)Perylene2 1.85 18.21 3.43 0.31Benzo(k)Fluoranthene1 1.7(w) 1.775 1.7 3.2bis(2-Ethylhexyl)phthalate2 1.3 33 (w) 57 0.47Butyl Benzyl Phthalate2 0.57(w) ND ND 0.049Chrysene 3.8 62 6.2 2.8Di-n-Butylphthalate2 2.5 8.4(w) ND 2.2Dibenzo(a,h)Anthracene 1.28 6.68 1.6 0.26Dibenzofuran2 ND 2.7 1.31 0.15Dichlorobenzene, 1,2-2 120 ND ND 0.023Dichlorobenzene, 1,4-2 2.3 ND ND 0.031Diethyl Phthalate2 ND ND 5.99(w) 0.61Fluoranthene 2.55 32 7.65 5.1Fluorene 50 19 3.4 0.54Hexachlorobenzene2 37 ND 6(w) 0.0038Hexachlorobutadiene2 20 ND ND 0.039Indeno(1,2,3-cd)Pyrene2 0.8 20.3 1.4 0.34Methylnaphthalene, 2- 1.3 3.6 1.05 0.67Naphthalene 40 6.7 3.15 2.1Nitrosodiophenylamine, N-2 ND 1.4 ND 0.11Phenanthrene 3.2 90 3.4 1.5Phenol1 25 ND ND 0.42Pyrene 1.9 78.5 8.6 2.6Trichlorobenzene, 1,2,4-2 8.1 ND ND 0.0081

Pesticides DDE, 4,4'- 0.097 ND ND 0.027& PCBs Dieldrin3 0.151 ND ND 0.2

Endrin3 0.16(w) ND ND 0.0073PCBs (total) 0.575 0.086 0.565 0.18

Inorganic Arsenic 9.65 5.75 6.32 70Elements Cadmium 1(w) 8.75 ND 9.6

Chromium 119.5 102.7 29(w) 370Copper 93.5 112 27.5(w) 270Lead 170 53.3 55 218Mercury 2 0.97 0.54 0.71Nickel 33.7 60.8 34.01 51.6Silver 2(w) 2(w) 2(w) 3.7Zinc 150 426 72.5(w) 410

Notes:

Concentration exceeds sediment threshold value.ND Not detected(w) Value is taken from the RTI study in wet weightAll reference thresholds are NOAA ER-Ms except where indicated by the following:(1) NOAA Apparent Effects Threshold(2) State of Washington Sediment Quality Standard(3) EPA Sediment Quality Criteria

10-12

Bayou d'Inde This section presents the contaminant review for Bayou d'Inde. Our analysis is organized by major chemical group and bayou segment. The Bayou d'Inde segments include the Upstream Reach, Industrial Area, PPG Canal, and Lower Bayou d'Inde. Refer to Chapter 3 for a complete description of Bayou d'Inde and the study-defined segments. The results of the Bayou d'Inde sediment contaminant review are presented in Exhibits 10-4 and 10-5. The discussion relies on the analysis of median contaminant concentrations. Within Bayou d'Inde, the PPG Canal and Lower Bayou d'Inde are the most contaminated segments. Thirteen of the 44 compounds with thresholds exceed these screening values within the PPG Canal, while 22 compounds exceed thresholds in Lower Bayou d'Inde. Contaminant indices, which measure the magnitude of threshold exceedances, indicate that the PPG Canal is the most severely impacted (score: 130,000) followed by Lower Bayou d'Inde (score: 2,000).6 The Upstream and Industrial areas exhibit one and seven exceedances, respectively. The contaminant index for the Upstream Reach is six, while the Industrial Area measures 37. Volatile Organic Compounds (VOCs) Three of the 19 VOCs detected in Bayou d'Inde sediments have thresholds. Two of these compounds (tetrachloroethene and xylene) exceed the thresholds in one or more segments. Ethylbenzene also has a threshold value but is not exceeded in Bayou d'Inde. Upstream None of the three VOCs were detected in sediment samples collected in the Upstream Reach. Industrial Area Xylene (total) exceeds the threshold in the Industrial Area. Xylene was not detected in any other segment. The exceedance is approximately five times greater than the threshold.

6 Contaminant indices are derived by summing the ratios of threshold exceedances within each segment.

Exhibit 10-4

BAYOU D'INDEMEDIAN SEDIMENT CONTAMINANT CONCENTRATIONS BY SEGMENT

mg/kg (ppm) dry weight

Chemical Industrial Lower BayouGroup Compound Upstream Area PPG Canal d'Inde ThresholdVOCs Ethylbenzene1 ND ND ND ND 0.01

Tetrachloroethene1 ND ND 6504 0.17(w) 0.057Xylene (total)1 ND 0.23 ND 0.0185 0.04

SVOCs Acenaphthene ND ND ND 1.1 0.5Anthracene ND ND ND 0.7 1.1Benzo(a)Anthracene ND ND 0.95 2.15 1.6Benzo(a)Pyrene ND ND 0.95 1.65 1.6Benzo(b)Fluoranthene1 ND ND 1 1.9 3.2Benzo(g,h,i)Perylene2 ND ND ND 1.85 0.31Benzo(k)Fluoranthene1 ND ND ND 1.7(w) 3.2bis(2-Ethylhexyl)phthalate2 1.3 0.8(w) 1.3 0.99 0.47Butyl Benzyl Phthalate2 ND ND 0.57(w) ND 0.049Chrysene ND 1.1 2.3 3.8 2.8Di-n-Butylphthalate2 ND 0.12 ND 2.5 2.2Dibenzo(a,h)Anthracene ND ND ND 1.28 0.26Dibenzofuran2 ND ND ND ND 0.15Dichlorobenzene, 1,2-2 ND ND 120 2.9(w) 0.023Dichlorobenzene, 1,4-2 ND ND 2.3 1.1 0.031Diethyl Phthalate2 ND ND ND ND 0.61Fluoranthene ND ND 2.55 1.9 5.1Fluorene ND ND 50 0.86 0.54Hexachlorobenzene2 ND ND 37 5.6 0.0038Hexachlorobutadiene2 ND ND 20 1.8 0.039Indeno(1,2,3-cd)Pyrene2 ND ND ND 0.8 0.34Methylnaphthalene, 2- ND 1.2 ND 1.3 0.67Naphthalene ND 0.98(w) 40 4.9 2.1Nitrosodiophenylamine, N-2 ND ND ND ND 0.11Phenanthrene ND 1.7 1.4 3.2 1.5Phenol1 ND ND 25 ND 0.42Pyrene ND 1.5 1.25 1.9 2.6Trichlorobenzene, 1,2,4-2 ND ND 8.1 2.3(w) 0.0081

Pesticides DDE, 4,4'- 0.019 ND 0.097 0.013 0.027& PCBs Dieldrin3 0.029 0.081(w) 0.151 0.013 0.2

Endrin3 ND 0.16(w) ND 0.013 0.0073PCBs (total) 0.1775 0.51 ND 0.575 0.18

Inorganic Arsenic 5.15 5.6 9.65 7.1 70Elements Cadmium 0.42 0.72 1(w) ND 9.6

Chromium 12.6 119.5 11 31.95 370Copper 14.3 54.2 93.5 44.7 270Lead 43.8 90 170 47.95 218Mercury 0.52 1.2 2 1.85 0.71Nickel 9.4 11 33.7 14.1 51.6Silver 1.1 ND ND 2(w) 3.7Zinc 42.4 150 120 54.6 410

Notes:

Concentration exceeds sediment threshold value.ND Not detected(w) Median value is taken from the RTI study in wet weightAll reference thresholds are NOAA ER-Ms except where indicated by the following:(1) NOAA Apparent Effects Threshold(2) State of Washington Sediment Quality Standard(3) EPA Sediment Quality Criteria

Exhibit 10-5

BAYOU D'INDEMAXIMUM SEDIMENT CONTAMINANT CONCENTRATIONS BY SEGMENT


Chemical Compound Industrial Lower BayouGroup Upstream Area PPG Canal d'Inde Threshold

VOCs Ethylbenzene1 ND ND ND ND 0.01Tetrachloroethene1 ND ND 430000 0.17(w) 0.057Xylene (total)1 ND 0.31 ND 0.024 0.04

SVOCs Acenaphthene ND ND ND 1.1 0.5Anthracene ND ND ND 0.71 1.1Benzo(a)Anthracene ND ND 0.95 6 1.6Benzo(a)Pyrene ND ND 0.95 4* 1.6Benzo(b)Fluoranthene1 ND ND 1 4* 3.2Benzo(g,h,i)Perylene2 ND ND ND 4.6 0.31Benzo(k)Fluoranthene1 ND ND ND 1.7(w) 3.2bis(2-Ethylhexyl)phthalate2 2.6(w) 0.8(w) 2.8(w) 5.7(w) 0.47Butyl Benzyl Phthalate2 ND ND 0.57(w) ND 0.049Chrysene ND 1.1 1.3* 10* 2.8Di-n-Butylphthalate2 ND 0.12 ND 2.5 2.2Dibenzo(a,h)Anthracene ND ND ND 1.6 0.26Dibenzofuran2 ND ND ND ND 0.15Dichlorobenzene, 1,2-2 ND ND 670 6.4(w) 0.023Dichlorobenzene, 1,4-2 ND ND 2200 4.2* 0.031Diethyl Phthalate2 ND ND ND ND 0.61Fluoranthene ND ND 2.8 2.7 5.1Fluorene ND ND 50 0.86 0.54Hexachlorobenzene2 ND ND 16000 264(w) 0.0038Hexachlorobutadiene2 ND ND 220000 77(w) 0.039Indeno(1,2,3-cd)Pyrene2 ND ND ND 1.2 0.34Methylnaphthalene, 2- ND 28 ND 2.1 0.67Naphthalene ND 0.98(w) 230 4.9 2.1Nitrosodiophenylamine, N-2 ND ND ND ND 0.11Phenanthrene ND 37 68(w) 7.1* 1.5Phenol1 ND ND 49 ND 0.42Pyrene ND 1.9 2.8(w) 11 2.6Trichlorobenzene, 1,2,4-2 ND ND 12000 5.45(w) 0.0081

Pesticides DDE, 4,4'- 0.02 ND 0.097 0.013 0.027& PCBs Dieldrin3 0.029 0.081(w) 8.8 0.013 0.2

Endrin3 ND 0.29(w) ND 0.013 0.0073PCBs (total) 1.71(w) 22.2 ND 1.04 0.18

Inorganic Arsenic 6.3 5.1 9.2 13.9 70Elements Cadmium 0.58 1(w) 1(w) ND 9.6

Chromium 100 2610 91 114 370Copper 57 480 713 376* 270Lead 79 880 900 440 218Mercury 1.1 34 8.2 44 0.71Nickel 24.5 43 68.9 48 51.6Silver 1.1 ND ND 2(w) 3.7Zinc 253 771 242 164 410

Notes:

Concentration exceeds sediment threshold value.ND Not detected(w) Maximum value is taken from the RTI study in wet weight* The wet weight maximum value (which was not used) was found in the RTI studyAll reference thresholds are NOAA ER-Ms except where indicated by the following:(1) NOAA Apparent Effects Threshold(2) State of Washington Sediment Quality Standard(3) EPA Sediment Quality Criteria

10-15

PPG Canal Tetrachloroethane exceeds the threshold in the PPG Canal by five orders of magnitude. This is the largest recorded exceedance using median concentrations in the estuary. Lower Bayou d'Inde Tetrachloroethene exceeds the threshold in Lower Bayou d'Inde. Tetrachloroethene is detected in the PPG Canal at significantly higher concentrations; the compound is not detected in the Industrial or Upstream segments. Semivolatile Organic Compounds (SVOCs) Twenty-eight of the 33 SVOCs detected in Bayou d'Inde have sediment thresholds. Twenty-seven of these exceed applicable thresholds in one or more bayou segments. The majority of these exceed thresholds in the PPG Canal and Lower Bayou d'Inde. Upstream Within the Upstream Reach, only bis(2-ethylhexyl)phthalate exceeds the threshold. Bis(2-ethylhexyl)phthalate also exhibits threshold exceedances in the other Bayou d'Inde segments. Industrial Area Three SVOCs exceed thresholds in the Industrial Area. These include bis(2-ethylhexyl)phthalate, 2-methylnaphthalene, and phenanthrene. Exceedances are generally within an order of magnitude. PPG Canal Of the 21 SVOCs detected in the PPG Canal, 10 exceed the thresholds. 1,2-dichlorobenzene, hexachlorobenzene, hexachlorobutadiene, and 1,2,4-trichlorobenzene are approximately three to four orders of magnitude greater than the thresholds. In addition to these compounds, bis(2-ethylhexyl)phthalate, butyl benzyl phthalate, 1,4-dichlorobenzene, fluorene, naphthalene, and phenol exceed applicable thresholds.

10-16

Lower Bayou d'Inde Of the 26 SVOCs detected in Lower Bayou d'Inde, 18 exceed the thresholds. Hexachlorobenzene and 1,2,4-trichlorobenzene exhibit the largest exceedances (three orders of magnitude). Hexachlorobutadiene, 1,2-dichlorobenzene, and 1,4-dichlorobenzene exceed the thresholds by approximately two orders of magnitude. Each of these compounds is detected in the PPG Canal, but not in the Upstream or Industrial segments. Polychlorinated Biphenyls (PCBs) and Pesticides Total PCBs and three pesticides have associated threshold values. None of these compounds exceed thresholds in the Upstream Reach. Total PCBs and endrin exceed the thresholds in the Industrial Area and Lower Bayou d'Inde. 4,4'-DDE exceeds the threshold in the PPG Canal. Exceedances are generally less than an order of magnitude greater than the threshold. Inorganics Inorganic element concentrations in sediment are generally lower than threshold values in Bayou d'Inde. Using median values, only mercury is observed at concentrations greater than the thresholds. Mercury exceedances occur in the Industrial Area, PPG Canal, and Lower Bayou d'Inde. Exceedances are approximately one order of magnitude above the threshold. Use of maximum concentrations increases the number of inorganic compounds exceeding the thresholds. These additional exceedances include chromium, copper, lead, nickel, and zinc. Bayou Verdine The Bayou Verdine segments include the Upstream Reach, Vista West Ditch, Trousdale Reach, Faubacher Ditch, KCSRR Ditch, Interstate 10 Reach, and Lower Bayou Verdine. Refer to Chapter 4 for a complete description of Bayou Verdine and the study-defined segments. The results of the Bayou Verdine sediment contaminant review are presented in Exhibits 10-6 and 10-7. The discussion relies on the analysis of median contaminant concentrations. Within Bayou Verdine, the I-10 Reach, KCSRR Ditch, and Lower Bayou Verdine are the most contaminated segments. Twenty of the 44 compounds with thresholds exceed these screening values within the I-10 Reach, 10 compounds exceed in the KCSRR Ditch, and 14 compounds exceed thresholds in Lower Bayou Verdine. The Upstream, Vista West Ditch, Trousdale Reach, and Faubacher Ditch exhibit 0, 4, 3, and 5 exceedances, respectively. Contaminant indices, which measure the magnitude of threshold exceedances, indicate that the I-10 Reach is the most severely impacted (score: 240) followed by the KCSRR Ditch (score: 213)

Exhibit 10-6

BAYOU VERDINEMEDIAN SEDIMENT CONTAMINANT CONCENTRATIONS BY SEGMENT


Chemical Vista Trousdale Faubacher KCSRR I-10 Lower BayouGroup Compound Upstream Ditch Reach Ditch Ditch Reach Verdine ThresholdVOCs Ethylbenzene1 ND ND ND ND ND ND ND 0.01

Tetrachloroethene1 ND ND ND ND ND 0.141 0.014 0.057Xylene (total)1 ND ND ND ND ND 0.036 0.042 0.04

SVOCs Acenaphthene ND ND ND ND ND 1.9 5.8 0.5Anthracene ND ND ND ND 15 4.15 13.3 1.1Benzo(a)Anthracene ND 3.1 ND 20 33 6.7 1.02 1.6Benzo(a)Pyrene ND ND 0.17 ND 22 5 0.88 1.6Benzo(b)Fluoranthene1 ND 3.7 ND ND 27.5 4.35 22.29 3.2Benzo(g,h,i)Perylene2 ND ND ND ND ND 5.6 18.205 0.31Benzo(k)Fluoranthene1 ND ND ND ND ND 1.1 1.775 3.2bis(2-Ethylhexyl)phthalate2 ND ND ND ND ND 33 (w) ND 0.47Butyl Benzyl Phthalate2 ND NI ND NI NI ND ND 0.049Chrysene 0.95 9.3 ND 29.6 62 5.6 2.7 2.8Di-n-Butylphthalate2 ND ND ND ND ND 8.4(w) ND 2.2Dibenzo(a,h)Anthracene ND ND ND ND ND 2.3 6.68 0.26Dibenzofuran2 ND ND ND ND ND 2.7 ND 0.15Dichlorobenzene, 1,2-2 ND NI ND NI NI ND ND 0.023Dichlorobenzene, 1,4-2 ND NI ND NI NI ND ND 0.031Diethyl Phthalate2 ND NI ND NI NI ND ND 0.61Fluoranthene ND 2.1 ND 10 32 5.5 2.9 5.1Fluorene ND ND ND ND 19 3.3 17.8 0.54Hexachlorobenzene2 ND NI ND NI NI ND ND 0.0038Hexachlorobutadiene2 ND NI ND NI NI ND ND 0.039Indeno(1,2,3-cd)Pyrene2 ND ND ND ND ND 20.3 11.9 0.34Methylnaphthalene, 2- ND ND 2.98(w) ND ND 3.6 2.5 0.67Naphthalene ND ND ND ND ND 6.7 2.3 2.1Nitrosodiophenylamine, N-2 ND ND ND ND ND 1.4 ND 0.11Phenanthrene ND 4.8 5.15(w) 35 90 14.25 18.5 1.5Phenol1 ND NI ND NI NI ND ND 0.42Pyrene 0.88 ND 0.78 18.05 78.5 5.1 3 2.6Trichlorobenzene, 1,2,4-2 ND NI ND NI NI ND ND 0.0081

Pesticides DDE, 4,4'- ND ND ND ND ND ND ND 0.027& PCBs Dieldrin3 ND NI ND NI NI ND ND 0.2

Endrin3 ND NI ND NI NI ND ND 0.0073PCBs (total) ND ND ND ND ND ND 0.086 0.18

Inorganic Arsenic 5.5 4 5.75 4.95 4.95 5.3 5.42 70Elements Cadmium 1.6 1.7 1.2 ND 1.9 0.96 8.75 9.6

Chromium 12.6 24.3 6.9 22.8 102.7 44.71 36.67 370Copper 53.4 23 112 22.75 50.2 75.97 29.07 270Lead 16.6 21.9 9.6 19.7 53.25 28.05 14.61 218Mercury ND ND 0.25 ND 0.375 0.42 0.97 0.71Nickel 23.95 26.5 60.8 16 26.2 16.4 53.47 51.6Silver ND NI 2 NI NI ND ND 3.7Zinc 49.15 170 22.9 128.25 426 80.15 75.48 410

Notes:

Concentration exceeds sediment threshold value.NI Not investigated.ND Not detected(w) Median value is taken from the RTI study in wet weightAll reference thresholds are NOAA ER-Ms except where indicated by the following:(1) NOAA Apparent Effects Threshold(2) State of Washington Sediment Quality Standard(3) EPA Sediment Quality Criteria

Exhibit 10-7

BAYOU VERDINEMAXIMUM SEDIMENT CONTAMINANT CONCENTRATIONS BY SEGMENT


Chemical Vista Trousdale Faubacher KCSRR I-10 Lower BayouGroup Compound Upstream Ditch Reach Ditch Ditch Reach Verdine ThresholdVOCs Ethylbenzene1 ND ND ND ND ND ND ND 0.01

Tetrachloroethene1 ND ND ND ND ND 0.26 0.021 0.057Xylene (total)1 ND ND ND ND ND 0.22 0.021 0.04

SVOCs Acenaphthene ND ND ND ND ND 3.5 5.8 0.5Anthracene ND ND ND ND 15 28 24.7 1.1Benzo(a)Anthracene ND 3.1 ND 20 47 160 4.5 1.6Benzo(a)Pyrene ND ND 0.17 ND 27 100 42.5 1.6Benzo(b)Fluoranthene1 ND 3.7 ND ND 36 130 43.8 3.2Benzo(g,h,i)Perylene2 ND ND ND ND ND 5.6 35.6 0.31Benzo(k)Fluoranthene1 ND ND ND ND ND 1.1 3.1 3.2bis(2-Ethylhexyl)phthalate2 ND ND ND ND ND 33 (w) ND 0.47Butyl Benzyl Phthalate2 ND NI ND NI NI ND ND 0.049Chrysene 0.95 9.3 ND 52 81 410 164.4 2.8Di-n-Butylphthalate2 ND ND ND ND ND 8.4(w) ND 2.2Dibenzo(a,h)Anthracene ND ND ND ND ND 64 13.2 0.26Dibenzofuran2 ND ND ND ND ND 2.7 ND 0.15Dichlorobenzene, 1,2-2 ND NI ND NI NI ND ND 0.023Dichlorobenzene, 1,4-2 ND NI ND NI NI ND ND 0.031Diethyl Phthalate2 ND NI ND NI NI ND ND 0.61Fluoranthene ND 2.1 ND 10 32 80 45.2 5.1Fluorene ND ND ND ND 19 7.7 17.8 0.54Hexachlorobenzene2 ND NI ND NI NI ND ND 0.0038Hexachlorobutadiene2 ND NI ND NI NI ND ND 0.039Indeno(1,2,3-cd)Pyrene2 ND ND ND ND ND 45.7 11.9 0.34Methylnaphthalene, 2- ND ND 2.98(w) ND ND 64.6 5.6 0.67Naphthalene ND ND ND ND ND 6.7 2.3 2.1Nitrosodiophenylamine, N-2 ND ND ND ND ND 1.4 ND 0.11Phenanthrene ND 4.8 5.15(w) 35 130 250 105.5 1.5Phenol1 ND NI ND NI NI ND ND 0.42Pyrene 0.88 ND 0.78 29 110 300 164.4 2.6Trichlorobenzene, 1,2,4-2 ND NI ND NI NI ND ND 0.0081

Pesticides DDE, 4,4'- ND ND ND ND ND ND ND 0.027& PCBs Dieldrin3 ND NI ND NI NI ND ND 0.2

Endrin3 ND NI ND NI NI ND ND 0.0073PCBs (total) ND ND ND ND ND ND 0.086 0.18

Inorganic Arsenic 5.5 5.6 6 6.4 5.4 6 5.54 70Elements Cadmium 4 1.8 1.2 ND 1.9 0.96 10.8 9.6

Chromium 216 213 217 208 133 458 518 370Copper 53.4 23.9 112 26.5 55.1 89.6 150 270Lead 26.8 22.1 38.4 44.6 60.2 129 217 218Mercury ND ND 0.25 ND 0.59 0.62 0.97 0.71Nickel 37.1 26.5 60.8 20.8 31.4 55.3 68.4 51.6Silver ND NI 2 NI NI ND ND 3.7Zinc 1290 300 2830 1790 598 2314 2592 410

Notes:

Concentration exceeds sediment threshold value.NI Not investigated.ND Not detected(w) Maximum value is taken from the RTI study in wet weight* The wet weight maximum value (which was not used) was found in the RTI studyAll reference thresholds are NOAA ER-Ms except where indicated by the following:(1) NOAA Apparent Effects Threshold(2) State of Washington Sediment Quality Standard(3) EPA Sediment Quality Criteria

10-19

and Lower Bayou Verdine (score: 210). The contaminant index for the Upstream Reach is two, the Vista West Ditch and Trousdale Reach score 10, and the Faubacher Ditch scores 56. Volatile Organic Compounds (VOCs) Three of the 15 VOCs detected in Bayou Verdine sediments have thresholds. Tetrachloroethene exceeds the threshold in the I-10 Reach; xylene exceeds the threshold in Lower Bayou Verdine. These compounds do not exceed thresholds in any other bayou segment. Ethylbenzene also has a threshold value but is not detected in any Bayou Verdine segment. Semivolatile Organic Compounds (SVOCs) Of the 21 SVOCs detected in Bayou Verdine, thresholds exist for 20. SVOCs exceedances exist in all but the Upstream Reach of Bayou Verdine. Upstream No SVOC exceedances exist in the Upstream Reach. Vista Ditch Four SVOCs exceed thresholds in the Vista Ditch. These include benzo(a)anthracene, benzo(b)fluoranthene, chrysene, and phenanthrene. All exceedances range from less than one to two times greater than the thresholds. Trousdale Reach Two compounds (2-methylnaphthalene, and phenanthrene) exceed SVOC thresholds in the Trousdale Reach. Exceedances are two to three times greater than the thresholds. Faubacher Ditch Five SVOCs exceed thresholds in Faubacher Ditch. Compounds include benzo(a)anthracene, chrysene, fluoranthene, phenanthrene, and pyrene. All exceedances range from approximately two to 23 times greater than the thresholds. All of these contaminants also are present at higher levels in the KCSRR Ditch.

10-20

KCSRR Ditch Of the nine SVOCs detected in the KCSRR Ditch all exceed the thresholds. Compounds include: anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, chrysene, fluoranthene, fluorene, phenanthrene, and pyrene. Concentrations of these nine compounds were higher in the KCSRR Ditch than any other segment of Bayou Verdine. All exceedances range from approximately six to 60 times greater than the thresholds. Interstate 10 Reach Of the 21 SVOCs detected in the I-10 Reach, 19 exceed applicable thresholds. The most significant exceedances occur for bis(2-ethylhexyl)phthalate, indeno(1,2,3-cd-)pyrene, benzo(g,h,i)perylene, and dibenzofuran. Exceedances for these compounds range from 17 to 70 times the thresholds. Other compounds of interest include acenaphthene, dibenzo(a,h)anthracene, fluorene, 2-methylnaphthalene, n-nitrosodiophenylamine, and phenanthrene. Lower Bayou Verdine Of the 17 SVOCs detected in Lower Bayou Verdine, 11 exceed applicable thresholds. Benzo(g,h,i)perylene, indeno(1,2,3-cd)pyrene, and fluorene exhibit the largest exceedances (59, 35, and 32 times greater than the thresholds, respectively). Other compounds of interest include dibenzo(a,h)anthracene (26 times greater) and acenaphthene, anthracene, and phenanthrene (each of which is 12 times greater than the applicable thresholds). Polychlorinated Biphenyls (PCBs) and Pesticides PCBs were only detected in Lower Bayou Verdine and do not exceed the threshold. Three pesticides have threshold values -- none of these pesticides are detected in Bayou Verdine. Inorganics Three inorganic elements exceed applicable thresholds in one or more segments of Bayou Verdine. Mercury exceeds the threshold only in Lower Bayou Verdine. Nickel concentrations exceed the threshold in the Trousdale Reach and Lower Bayou Verdine. Zinc exceeds the threshold only in the KCSRR Ditch. All exceedances are only slightly above the relevant thresholds. Use of maximum concentrations has little effect on the number of inorganic compounds exceeding the thresholds. Additional exceedances include cadmium and chromium.

10-21

Calcasieu River and Ship Channel The Calcasieu River and Ship Channel segments include Lake Charles, Clooney Island Loop, Coon Island Loop, Prien Lake, Moss Lake, and Calcasieu Lake. Refer to Chapter 5 for a complete description of the Calcasieu River and Ship Channel and the study-defined segments. The results of the Calcasieu River and Ship Channel sediment contaminant review are presented in Exhibits 10-8 and 10-9. The discussion relies on the analysis of median contaminant concentrations. Within the Calcasieu River and Ship Channel, only the Coon Island Loop exhibits significant threshold exceedances. Prien Lake is the only other segment with any threshold exceedances. Volatile Organic Compounds (VOCs) Three VOCs (ethylbenzene, tetrachloroethene, and xylene) have threshold values. Median concentrations from the Coon Island Loop exceed the ethylbenzene threshold by 13 times and only slightly exceed the xylene threshold. These compounds were not detected in any other segment of the Calcasieu River and Ship Channel. Semivolatile Organic Compounds (SVOCs) Nineteen SVOCs exceed thresholds in the Calcasieu River and Ship Channel. Coon Island Loop accounts for 18 of these exceedances. Prien Lake has one exceedance. None of the other river segments exhibit threshold exceedances. Lake Charles, Clooney Island Loop, Moss Lake, Calcasieu Lake None of the SVOCs in the Lake Charles, Clooney Island Loop, Moss Lake, and Calcasieu Lake exceed the thresholds. Coon Island Loop Of the 20 SVOCs detected in Coon Island Loop, 18 exceed applicable thresholds. Bis(2-ethylhexyl)phthalate has a median concentration 120 times greater than the threshold. The median concentration of benzo(g,h,i)perylene is 10 times higher than the threshold. All other exceedances are less than 10 times the threshold.

Exhibit 10-8

CALCASIEU RIVER AND SHIP CHANNELMEDIAN SEDIMENT CONTAMINANT CONCENTRATIONS BY SEGMENT


Chemical Group Compound Lake Charles

Clooney Island Loop

Coon Island Loop Prien Lake Moss Lake

Calcasieu Lake Threshold

VOCs Ethylbenzene1 ND ND 0.133 ND ND ND 0.01Tetrachloroethene1 ND ND 0.021 ND ND ND 0.057Xylene (total)1 ND ND 0.056 ND ND ND 0.04

SVOCs Acenaphthene ND ND 4.86 ND ND ND 0.5Anthracene ND ND 2.7 ND ND ND 1.1Benzo(a)Anthracene ND ND 4.48 ND ND ND 1.6Benzo(a)Pyrene ND ND 3.55 ND ND ND 1.6Benzo(b)Fluoranthene1 ND ND 5.95 ND ND ND 3.2Benzo(g,h,i)Perylene2 ND ND 3.43 ND ND ND 0.31Benzo(k)Fluoranthene1 ND ND 1.7 ND ND ND 3.2bis(2-Ethylhexyl)phthalate2 ND ND 57 ND ND ND 0.47Butyl Benzyl Phthalate2 ND ND ND ND ND ND 0.049Chrysene ND ND 6.2 ND ND ND 2.8Di-n-Butylphthalate2 ND ND ND ND ND ND 2.2Dibenzo(a,h)Anthracene ND ND 1.6 ND ND ND 0.26Dibenzofuran2 ND ND 1.31 ND ND ND 0.15Dichlorobenzene, 1,2-2 ND ND ND ND ND ND 0.023Dichlorobenzene, 1,4-2 ND ND ND ND ND ND 0.031Diethyl Phthalate2 ND ND 5.99(w) ND ND ND 0.61Fluoranthene ND ND 7.65 ND ND ND 5.1Fluorene ND ND 3.4 ND ND ND 0.54Hexachlorobenzene2 ND ND ND 6(w) ND ND 0.0038Hexachlorobutadiene2 ND ND ND ND ND ND 0.039Indeno(1,2,3-cd)Pyrene2 ND ND 1.4 ND ND ND 0.34Methylnaphthalene, 2- ND ND 1.05 ND ND ND 0.67Naphthalene 0.82(w) ND 3.15 0.92(w) ND ND 2.1Nitrosodiophenylamine, N-2 ND ND ND ND ND ND 0.11Phenanthrene ND ND 3.4 ND ND ND 1.5Phenol1 ND ND ND ND ND ND 0.42Pyrene ND ND 8.6 ND ND ND 2.6Trichlorobenzene, 1,2,4-2 ND ND ND ND ND ND 0.0081

Pesticides DDE, 4,4'- ND ND ND ND ND ND 0.027& PCBs Dieldrin3 ND ND ND ND ND ND 0.2

Endrin3 ND ND ND ND ND ND 0.0073PCBs (total) ND ND 0.565 ND ND ND 0.18

Inorganic Arsenic ND 1.4(w) 6.32 5.7 2.4(w) 2.25(w) 70Elements Cadmium ND ND ND ND ND ND 9.6

Chromium 17(w) 25(w) 13.4 10 29(w) 22.5(w) 370Copper 7(w) 23(w) 23.11 26 27.5(w) 12.5(w) 270Lead 30(w) 17(w) 19.4 55 17.5(w) 7(w) 218Mercury 0.125(w) ND 0.4 0.54 ND ND 0.71Nickel 5.5(w) 8(w) 34.0 19 15(w) 14(w) 51.6Silver ND ND 2(w) ND ND 2(w) 3.7Zinc 35.5(w) 55(w) 41.9 28 72.5(w) 57(w) 410

Notes:

Concentration exceeds sediment threshold value.ND Not detected(w) Median value is taken from the RTI study in wet weightAll reference thresholds are NOAA ER-Ms except where indicated by the following:(1) NOAA Apparent Effects Threshold(2) State of Washington Sediment Quality Standard(3) EPA Sediment Quality Criteria

Exhibit 10-9

CALCASIEU RIVER AND SHIP CHANNELMAXIMUM SEDIMENT CONTAMINANT CONCENTRATIONS BY SEGMENT


Chemical Group Compound Lake Charles

Clooney Island Loop

Coon Island Loop Prien Lake Moss Lake

Calcasieu Lake Threshold

VOCs Ethylbenzene1 ND ND 0.133 ND ND ND 0.01Tetrachloroethene1 ND ND 0.05 ND ND ND 0.057Xylene (total)1 ND ND 0.708 ND ND ND 0.04

SVOCs Acenaphthene ND ND 29.5 ND ND ND 0.5Anthracene ND ND 40.4* ND ND ND 1.1Benzo(a)Anthracene ND ND 11.5 ND ND ND 1.6Benzo(a)Pyrene ND ND 75 ND ND ND 1.6Benzo(b)Fluoranthene1 ND ND 73 ND ND ND 3.2Benzo(g,h,i)Perylene2 ND ND 56 ND ND ND 0.31Benzo(k)Fluoranthene1 ND ND 4.5 ND ND ND 3.2bis(2-Ethylhexyl)phthalate2 ND ND 57 ND ND ND 0.47Butyl Benzyl Phthalate2 ND ND ND ND ND ND 0.049Chrysene ND ND 250 ND ND ND 2.8Di-n-Butylphthalate2 ND ND ND ND ND ND 2.2Dibenzo(a,h)Anthracene ND ND 21 ND ND ND 0.26Dibenzofuran2 ND ND 24.8 ND ND ND 0.15Dichlorobenzene, 1,2-2 ND ND ND ND ND ND 0.023Dichlorobenzene, 1,4-2 ND ND ND ND ND ND 0.031Diethyl Phthalate2 ND ND 5.99(w) ND ND ND 0.61Fluoranthene ND ND 75 ND ND ND 5.1Fluorene ND ND 27 ND ND ND 0.54Hexachlorobenzene2 ND ND ND 6(w) ND ND 0.0038Hexachlorobutadiene2 ND ND ND ND ND ND 0.039Indeno(1,2,3-cd)Pyrene2 ND ND 19.2 ND ND ND 0.34Methylnaphthalene, 2- ND ND 13.7 ND ND ND 0.67Naphthalene 0.82(w) ND 4 1.2(w) ND ND 2.1Nitrosodiophenylamine, N-2 ND ND ND ND ND ND 0.11Phenanthrene ND ND 212 ND ND ND 1.5Phenol1 ND ND ND ND ND ND 0.42Pyrene ND ND 231 ND ND ND 2.6Trichlorobenzene, 1,2,4-2 ND ND ND ND ND ND 0.0081

Pesticides DDE, 4,4'- ND ND ND ND ND ND 0.027& PCBs Dieldrin3 ND ND ND ND ND ND 0.2

Endrin3 ND ND ND ND ND ND 0.0073PCBs (total) ND ND 0.78 ND ND ND 0.18

Inorganic Arsenic ND 2.1 13.6 8.4 2.7 4.6 70Elements Cadmium ND ND ND ND ND ND 9.6

Chromium 26 27 714 50 31 31 370Copper 15 28 168 72 32 19 270Lead 30 20 544 53 22 8 218Mercury 0.14 ND 12.8 1.5 ND ND 0.71Nickel 6 11 187 24 17 19 51.6Silver ND ND 2 ND ND 3 3.7Zinc 37 181 678 120 85 88 410

Notes:

Concentration exceeds sediment threshold value.ND Not detected(w) Maximum value is taken from the RTI study in wet weight* The wet weight maximum value (which was not used) was found in the RTI studyAll reference thresholds are NOAA ER-Ms except where indicated by the following:(1) NOAA Apparent Effects Threshold(2) State of Washington Sediment Quality Standard(3) EPA Sediment Quality Criteria

10-24

Prien Lake One SVOC (hexachlorobenzene) exceeds the threshold in Prien Lake. The hexachlorobenzene exceedance is three orders of magnitude greater than the threshold. The hexachlorobenzene threshold also is exceeded in Bayou d'Inde. Polychlorinated Biphenyls (PCBs) and Pesticides Total PCBs in Coon Island Loop are three times greater than the threshold. PCBs do not exceed the threshold in any other portion of the river. None of the pesticides with thresholds are detected in any segment of the Calcasieu River and Ship Channel. Inorganics Using median concentrations, none of the inorganic elements exceed applicable thresholds. Using maximum concentrations, chromium, lead, mercury, nickel, and zinc exceed thresholds in Coon Island Loop. Maximum mercury concentrations also exceed the threshold in Prien Lake.

11-1

FISH AND SHELLFISH INJURY EVALUATION AND CONTAMINANT REVIEW CHAPTER 11 This chapter reviews the contaminants affecting the fish and shellfish resources of the Calcasieu Estuary. The chapter reviews the regulatory requirements for determining injury to fish and shellfish resources and identifies contaminants and resources meeting these criteria. FISH AND SHELLFISH INJURY ASSESSMENT DOI's natural resource damage assessment regulations at 43 CFR 11.62(f) establish three general categories of biological injury relevant to fish and shellfish. These are: (1) Adverse changes in viability such as death, disease, or genetic mutations; (2) Edible tissue contaminant concentrations exceeding FDA action levels or

tolerances; and (3) State-imposed limits or bans on fish or shellfish consumption. Each of these injury categories is discussed below. Adverse Changes in Viability The DOI regulations defining injury to biological resources resulting from adverse changes in viability state: "An injury to a biological resource has resulted from the discharge of oil or

release of a hazardous substance if concentration of the substance is sufficient to cause the biological resource or its offspring to have undergone at least one of the following adverse changes in viability: death, disease, behavioral abnormalities, cancer, genetic mutations, physiological malfunctions (including malfunctions in reproduction), or physical deformations" (43 CFR 11.62(f)(1)(i)).

11-2

Studies conducted to test the existence or significance of these effects must show a measurable biological response and satisfy the following requirements (summarized from 43 CFR 11.62(f)(2)): (1) The biological response is the result of exposure to the hazardous substances; (2) Exposure to the hazardous substance is known to cause the specific biological

response in free-ranging organisms; (3) Exposure to the hazardous substance is known to cause the specific biological

response in controlled experiments; (4) The biological response measurement is practical to perform and produces

scientifically valid results. The biological responses listed in Exhibit 11-1 are identified at 43 CFR 11.62(f)(4) as specific responses that satisfy the requirements for adverse changes in viability for fish. The regulations provide more detailed information on each biological response.

Exhibit 11-1

BIOLOGICAL RESPONSES CLASSIFIED AS ADVERSE CHANGES IN VIABILITY

Adverse Change in Viability

Satisfactory Biological Responses

Death Fish kills; In-situ bioassay; Laboratory toxicity testing.

Disease Fin erosion.

Behavioral Abnormalities Clinical behavioral signs of toxicity; Avoidance.

Cancer Fish neoplasm.

Physiological Malfunctions Reduced fish reproduction.

Physical Deformation Overt external malformations; Skeletal deformities; Internal whole organ and soft tissue malformation; Histopathological lesions.

Source 43 CFR 11.62(f)(4)

In the process of gathering information for this study, we did not find any reports of adverse biological changes (e.g. fish kills, fin erosion) for Calcasieu Estuary fish and shellfish. It would be useful to conduct a review of the fish toxicology literature to learn what kinds of adverse effects have been associated with the contaminants of concern in the Calcasieu Estuary. The literature review should consider contaminants of concern identified in the surface water and sediment reviews as well as contaminants presently measured in fish and shellfish by LDEQ, since surface water and sediment thresholds often are determined based on adverse changes to marine organisms. We did not review the fish toxicology literature as part of this effort.

11-3

FDA Action Levels or Tolerances DOI's natural resource damage assessment regulations state: "An injury to a biological resource has resulted from the discharge of oil or

release of a hazardous substance if concentration of the substance is sufficient to exceed action or tolerance levels established under Section 402 of the Food, Drug and Cosmetic Act, 21 USC 342, in edible portions of organisms" (43 CFR 11.62(f)(1)(ii).

The Food and Drug Administration (FDA), in conjunction with the Environmental Protection Agency, establishes action levels and tolerances to prevent poisonous substances in food. Tolerances generally are established for active registered pesticides. Action levels generally are established for pesticides that have been banned or that are no longer in use. Industrial chemicals, such as those identified in the Calcasieu Estuary, are rarely governed by action levels or tolerances. Further, tolerances frequently apply only to those commodities that receive direct pesticide applications. Since pesticides are rarely applied to fish or water surfaces, few tolerance and action levels exist for fish products. Because of these limitations, FDA action levels and tolerances are of limited use for determining injury to the Calcasieu Estuary's biological resources. Polychlorinated biphenyls (PCBs) are the only industrial chemical group for which FDA has established a formal tolerance in fish tissue. The current PCB tolerance, which was established in the early 1980s, is 2 parts per million in edible fish tissue (21 CFR 109.30(a)(7)). Prior to the early 1980's, the formal tolerance was 5 parts per million. LDEQ's Calcasieu River Estuary Biological Monitoring Program analyzes fish tissues for seven PCBs as Aroclor equivalents; however, Aroclor 1254 is the only mixture detected with consistency. None of the Aroclor measurements reported in Chapter 6 exceed the FDA tolerance. The maximum single-species composite concentration measured over the lifetime of the estuary sampling program is 367 parts per billion -- well below the FDA action level. As a result, PCB injury cannot be determined based on fish and shellfish tissues exceeding FDA action levels and tolerances. The LDEQ program does not measure pesticides in fish tissue. Endrin, dieldrin, and 4,4'-DDE have been detected in Bayou d'Inde sediments at concentrations exceeding sediment thresholds. Although pesticides do not appear to be wide-spread in estuary sediments, the Bayou d'Inde data suggest that limited testing for pesticides in fish tissues may be warranted.

11-4

State-Imposed Consumption Limits State-imposed consumption limits provide a direct method for determining injury to fish and shellfish resources. DOI's natural resource damage assessment regulations state: "An injury to a biological resource has resulted from the discharge of oil or

release of a hazardous substance if concentration of the substance is sufficient to exceed levels for which an appropriate State health agency has issued directives to limit or ban consumption of such organism" (43 CFR 11.62(f)(1)(iii).

The state of Louisiana maintains fish consumption advisories for the entire Calcasieu Estuary. The current advisory for Bayou d'Inde prescribes limited fish consumption. The estuary-wide advisory (outside of Bayou d'Inde) is informational, advising the public about trace chemical contamination in the estuary's fish and shellfish so that they may make informed decisions about the quantity of Calcasieu Estuary fish they consume. Exhibit 11-2 details past and current fish consumption advisories for the Calcasieu Estuary. Most of these consumption advisories were issued due to hexachlorobenzene (HCB) and hexachlorobutadiene (HCBD) contamination. More recently, PCBs have been added to the list of contaminants of concern. Historically, the Louisiana Department of Health and Hospitals (LDHH) based these advisories on an "action level" of 60 parts per billion for HCB and HCBD in edible tissues of fish and shellfish. LDHH currently bases state-issued advisories on site-specific human health risk analysis. LDHH issues and maintains consumption advisories based on guidelines entitled "Protocol for Issuing Health Advisories and Bans Based on Chemical Contamination of Fish/Shellfish in Louisiana" (1996). Historical comparisons show that hexachlorobenzene and hexachlorobutadiene measurements in several areas of the estuary exceed the state's earlier 60 parts per billion action level. Weighted average mean tissue concentrations for hexachlorobenzene measure 212 and 122 parts per billion in the PPG Canal and Lower Bayou d'Inde, respectively.1 Weighted average maximum concentrations for hexachlorobenzene exceed the action level in Bayou d'Inde (150-585 parts per billion) and Prien Lake (60 parts per billion). In Year 6 of the sampling program, mean concentrations for 8 station/species composites, or about 5 percent of all tissue composites analyzed for HCB during the year, exceed the historic hexachlorobenzene action level. The highest concentration ever measured outside of Bayou d'Inde is 329 parts per billion. 1 The weighted average mean concentration was calculated from data in Chapter 6 as follows:

Weighted Average Concentration = (Concentration )(n )

Ni

s ss

n

i

t

=∑

1

where: i = Sampling station s = Species nt = Number of species types collected from station i ns = Sample size for species s at station i Ni = Total sample size at station i

11-5

Hexachlorobutadiene measurements show a similar pattern. Weighted average mean tissue concentrations measure 581 and 308 parts per billion in the PPG Canal and Lower Bayou d'Inde, respectively. Weighted average maximum concentrations exceed the action level in Bayou d'Inde (1,393-895 parts per billion), Prien Lake (84 parts per billion), and the Calcasieu Ship Channel (279 parts per billion). In Year 6 of the sampling program, mean concentrations for 6 station/species composites, or about 3 percent of all tissue composites analyzed for HCBD during the year, exceed the historic hexachlorobutadiene action level. The highest concentration ever measured outside of Bayou d'Inde is 700 parts per billion. The existing advisory for Bayou d'Inde satisfies the regulatory requirements for resource injury under 43 CFR 11.62(f)(1)(iii) since it prescribes limited consumption. The estuary-wide advisory, however, may not satisfy the injury definition because it does not define actual consumption limits. Although the state's intent to advise anglers of potential health effects is clear, the absence of specific consumption recommendations or limits may make it more difficult to establish injury for the estuary outside of Bayou d'Inde. Note also that the existing health advisories are generally less stringent than historic advisories, which recommended against any consumption from the estuary.

Exhibit 11-2

CALCASIEU ESTUARY HEALTH ADVISORIES Location Effective

Dates Advisory Contaminants

of Concern Bayou d'Inde 1/17/87 - 4/6/92 Fish Consumption. Do not eat fish or

shellfish. HCB HCBD

4/7/92 - Present Fish Consumption. Limit consumption to 2 meals per month.

HCB HCBD PCBs

Prien Lake 1/16/87 - 4/6/92 Fish Consumption. Do not eat fish or shellfish.

HCB HCBD

Calcasieu River Above Interstate

210 to Moss Lake Saltwater Barrier to

Gulf of Mexico Saltwater Barrier to

Gulf of Mexico

1/16/87 - 4/6/92

2/24/89 - 4/6/92

4/7/92 - Present

Fish Consumption. Do not eat fish or shellfish. Fish Consumption. Do not eat Speckled Seatrout or Sand Seatrout. Fish Consumption. Informational health advisory for all fish and shellfish.

HCB HCBD HCB HCBD HCB HCBD PCBs

Notes HCB Hexachlorobenzene HCBD Hexachlorobutadiene PCBs Polychlorinated biphenyls Source Louisiana Department of Environmental Quality, Louisiana Department of Health and Hospitals.

FACILITY REVIEW COMMENTS APPENDIX A Appendix A contains comments referenced in the Facility Review (Part II, Chapter 7) of the report. NOAA reviewed and considered all comments, and technical industry comments regarding the Facility Review are included in the report directly or by reference. Facility Review comments that clarify basic information already included in the report or that could be verified using in-house data collections were incorporated directly into the report (and consequently are not included in this appendix). All comments regarding the Facility Review that provided new information, updates, or that could not otherwise be verified are referenced in the report and provided here. The comments provided in this appendix are verbatim except where indicated by brackets [ ].

NOAA provides these comments in the interest of making all relevant information available to interested parties. NOAA does not warrant the accuracy of the information contained in the comments nor endorse the opinions of the commentors. 1. PPG Industries

(a) The Facility Review section of the [Draft] Report (Chapter 7) mischaracterizes the conditions at the PPG facility. In many instances, past conditions are described as if they reflect the current situation at the site, with potential or minor releases catalogued regardless of their significance. More important, the [Draft] Report ignores steps PPG has taken that control any potential release or implies that PPG's documentation of the benefits of those steps is less credible than pre-remediation site descriptions. The work performed by PPG at the facility and the substantial impact of that work in terms of controlling or elimination potential contamination are demonstrable facts and should be recognized in the Report.

(b) Monitoring of BOD and TOC ([Draft] Report p. 7-7) has not been included in the

NPDES permit for the last several years.

A-2

(c) The [Draft] Report's characterization of the discharges from outfalls 002 and 003 is inaccurate; the correct characterization is included in the permit text.

(d) The Riverside Powerhouse has not been identified as a potential source of

chlorinated hydrocarbons and there is no basis for stating contamination from the powerhouse would reach the Coon Island Loop.

(e) PPG has controlled potential flow of groundwater contamination into Bayou

Verdine the (sic) construction and operation of the containment and recovery system.

2. Conoco Incorporated

(a) Based on substantial monitoring and clean up, [Conoco] received clean closure of the LPWMN (sic) from LDEQ.

(b) [The Oily Waste Area] is incorporated in Conoco's RCRA Facility Investigation

(RFI) which recently received final agreement from the agency.

3. Citgo Petroleum Corporation / Cit-Con Oil Corporation

(a) On May 18, 1995, EPA issued the Post-Closure Permit for the South Impoundment. This permit identified 53 SWMUs and, as per permit conditions, Citgo has notified the EPA of four newly identified SWMUs. Of these 57 SWMUs, 11 are regulated under RCRA. In addition, Citgo submitted a work plan to assess the SWMUs in December 1995. Agency approval of the work plan is pending.

(b) The West Impoundment has been closed under RCRA regulations. Closure of the

West Impoundment included the removal of all sludges and excavation of subsoils. In addition, there has been no confirmed release from the impoundment. Citgo is currently pursuing clean closure for the facility.

(c) In 1994, Citgo constructed a wastewater treating plant which included wastewater

storage tanks. The construction of this plant allowed Citgo to discontinue the use of the Surge Pond. The description of the Surge Pond should state that the facility is inactive and a detailed closure plan is being developed by Citgo for submittal to LDEQ and EPA in September 1997.

(d) Groundwater contamination in the area of the Sulfur Recovery Unit (SRU) and

Tail Gas #2 (TG2) was detected during a groundwater assessment prior to the construction of these units. These units are not the source of the groundwater impact and are used only as reference points.

A-3

(e) In October 1995, Citgo submitted to LDEQ a groundwater assessment work plan to delineate the horizontal and vertical extent of contamination. The work plan is pending agency approval.

(f) A comprehensive groundwater assessment was conducted in January 1996 at the

Surge Pond. The results of the assessment indicated that the groundwater in the upper water bearing sands flow into and not out of the Surge Pond.

(g) On May 18, 1995, EPA issued the Post-Closure Permit for the South

Impoundment. The Acid Hydromation and Sand Filters were not identified as SWMUs. The reference of these filters as SWMUs should be deleted.

(h) In 1995 Citgo initiated quarterly groundwater monitoring in the area of

Equalization and Aeration Basins. The monitoring program includes collection of groundwater from the second water bearing sand. Results from these sampling events indicate that the vertical extent of contamination is confined to the uppermost waster (sic) bearing sand.

(i) Citgo has installed a groundwater recovery system in the area between the

SWWTP and the Indian Marias. The text should be revised as follows, "Indian Marias is located immediately north of the SWWTP. Citgo has installed a groundwater recovery system to remove impacted groundwater."

(j) Citgo submitted and received approval of closure plans for these facilities. The

text should state that closure activities are being initiated. (k) Multiple groundwater assessments have been conducted in the area of the

Neutralization and Retention Basins. The findings of these investigations, which includes analytical data and conclusions, were submitted to LDEQ. Closure activities for these units have been completed and closure certification was issued from LDEQ on December 6, 1996.

4. CONDEA Vista Company

(a) Vista feels that after a cursory review a significant portion of the language referencing Vista is misleading and if a detailed study were conducted that more portions would also be misleading, for example,… [Specific comments addressed by edit or footnote]. …. As Environmental Manager for Condea Vista Company, I wish to assure you that Vista has genuine concern for environmental protection of the Estuary; however, Vista believes that much more study needs to be done to determine "injury" to the estuary, and requests that NOAA not issue a final report without further investigation [signed M. G. Hayes].

A-4

(b) In calendar year 1997, Vista will implement a new NPDES discharge permit and Vista's waste water will no longer discharge to West (sic) and thence to Bayou Verdine. It is understanding (sic) that other discharges to Bayou Verdine will be discontinued also. This could facilitate the natural attenuation process to improve conditions in West Ditch and Bayou Verdine.

(c) While there have been occasional releases of heavy ends, and while heavy ends

have been stored in tanks; heavy ends have never been disposed of in tanks, ponds, or landfills. Not only is some of this misleading, it simply is not true.

5. Olin Chemicals

(a) Olin Chemicals did not provide comments on the draft report to NOAA.

6. OxyChem Petrochemicals

(a) In Exhibit 7-33 [Exhibit 7-32 in this report], several sample collection/testing dates are incorrect (i.e., December 7, 1987 should be December 7, 1988; March 8, 1989 should be May 8, 1989).

(b) In Exhibit 7-34 [Exhibit 7-33 in this report], deviations in the NPDES compliance

history incorrectly reports that in November 1990, oil and grease were discharged from Outfall 001 in excess of 28 lbs/day. This discharge was actually 8.04 lbs/day.

7. Westlake Polymers Corporation

(a) In May 1994, Westlake completed a corrective project to prevent any contaminated stormwater from discharging through Outfall 011. During rain events, the contaminated stormwater (the first 20 minute flush) is collected and routed to the process effluent treatment train. Oil & grease results since the project completion have remained well below the permit limit of 15 mg/l for Outfall 011. The project also provided added protection for spills within the plant.

(b) Although Westlake's Hazardous Waste Notification Form indicates that F001,

F003, and F005 solvents are generated, F001 halogenated solvents have never been generated, nor disposed of by Westlake. In addition, the statement that these solvents are discharged to Bayou d'Inde is erroneous. Generation of F003 and F005 solvents are as a result of waste paint from miscellaneous painting activities. All such wastes are properly contained and disposed off-site in accordance with the hazardous waste regulations. Westlake has included in Attachment D, records

A-5

of hazardous waste generation, shipment and disposal activities at Westlake, dating back to 1991.

8. Firestone Synthetic Rubber and Latex Company

(a) Outfall 001 is not monitored for ammonium nitride (NH3N), but is monitored for ammonia (as nitrogen). In addition to monitoring for flow and pH, temperature is also monitored.

(b) While NPDES Discharge Monitoring Reports (DMR's) identify the outfalls as

001A, 003A, and 004A; these identifications are synonymous with 001, 003, and 004, respectively; and are not internal outfalls.

(c) Outfall 003, +13 mg/l. (d) Based on review of [Firestone] data, no exceedances of permit limit. (e) ~6,000 gallons not recovered in on-site cleanup, although some portion of this

was recovered off-site as polystyrene. (f) +161. (g) +57. (h) +3 mg/l. (i) Moreover, while our records do not extend back to 1981, we question the

accuracy of some of the listings in Exhibit 7-40 [Exhibit 7-39 in this report] given our knowledge of the process.

9. W.R. Grace

(a) The outfall has continuous flow, with an actual 30-day maximum of 2.074 mgd. This flow includes storm water runoff which is estimated at 0.1194 mgd.

(b) [W.R. Grace] have attached two letters from the Louisiana Department of

Environmental Quality concerning the inactive industrial waste site. We have placed a three foot recompacted clay cap on this site and there are no exposed bricks.

contamination extent report and preliminary …...contamination extent report and preliminary injury...

Documents