GHD Services Inc. (GHD) prepared the Draft Feasibility Study (FS) Work Plan on behalf of the potentially responsible party (PRP), Clean Harbors Environmental Services, Inc. (Clean Harbors), at the Devil’s Swamp Lake (DSL) Superfund Site (Site), located in East Baton Rouge Parish, Louisiana. Clean Harbors submitted the document to the U. S. Environmental Protection Agency (EPA) on 1 March 2016.
The work plan provides an adequate description of the FS process. General comments are provided in Section 2, Specific comments are provided in Section 3, and State comments are provided in Section 4.
2.0 GENERAL REVIEW COMMENTS
1. As previously note in EPA’s approval of the Tier 2 Remedial Investigation (RI) report,…show more content… Therefore a remedial action is required and remedial alternatives should be presented for the protection of human receptors that may use the site for recreational purposes.
2. Please note that the use of a Risk Management non-cancer hazard level threshold of 3 is only applicable for Removal Management decision.
3. As previously informed, values presented under Central Tendency Exposure (CTE) scenarios, or presented under Clean Harbors’s fish/crawfish consumption assumptions are considered for information only.
4. Similarly, comparisons to the Food and Drug Administration (FDA) intake concentrations or Maximum Contaminants (MCLs) should not be utilized in conclusions to evaluate risk levels.
3.0 TECHNICAL REVIEW COMMENTS
The following technical review comments are associated with the Draft FS Work Plan.
1. Page 7, Section 184.108.40.206. In the third paragraph under the Tier 2 Remedial Investigation (RI) Sample Results the text states that the bluegill and crappie fish samples were dissected and analyzed as filets (edible tissue). Later in this paragraph it states that the bluegill sample data were used in the Baseline Ecological Risk Assessment (BERA).
How was the difference between filet and whole body tissue samples accounted for in the
2. Pages 8 through 14, Sections 2.2 and