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Case Study : Services Inc.

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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 for the Tier 2 Remedial Investigation (RI) report, lacking of site specific creel study information, EPA and LDEQ believe the use of default inputs and/or values directed in previous agency comments are appropriate for conducting a risk assessment under the Superfund Program. These values and resulting risk numbers, presented in Appendix N of the Tier 2 RI report, will be used to support remedial decisions by the EPA and the state.

Based on these assumptions, resulting Reasonable Maximum Exposure (RME) Cancer Risks and Non-Cancer Hazards for a Recreational User Exposed to PCBs in Fish and Crawfish over the entire site are reported as 9 x 10-05 and a Hazard Quotient of 6.

For Dioxin like PCBs, reported values are 1 x 10-04 and 4, respectively.

These values exceed the point of departure established in the

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