AMERICAN CREOSOTE WORKS, INC. (PENSACOLA PLANT)
Site Information:
Site Name:
Address:
AMERICAN CREOSOTE WORKS, INC. (PENSACOLA PLANT)
PENSACOLA, FL
EPA ID:
EPA Region:
FLD008161994
04
Site Alias Name(s):
AMERICAN CREOSOTE WORKS INC
AMERICAN CREOSOTE WORKS (PENSACOLA PLT)
Record of Decision (ROD):
ROD Date:
Operable Unit:
ROD ID:
09/30/1985
01
EPA/ROD/R04-85/006
Media:
Groundwater, Sediments, Sludge, Soil
Contaminant:
BENZENE, ETHYLBENZENE, PAHS, TOLUENE, XYLENE
Abstract:
THE AMERICAN CREOSOTE WORKS, INC. (ACW) SITE
OCCUPIES APPROXIMATELY 12 ACRES IN A MODERATELY
DENSE, COMMERCIAL AND RESIDENTIAL DISTRICT OF
PENSACOLA, FLORIDA. WOOD-PRESERVING OPERATIONS
WERE CARRIED OUT AT THE ACW SITE FROM 1902 UNTIL
DECEMBER, 1981. PRIOR TO 1950, CREOSOTE WAS
EXCLUSIVELY USED TO TREAT POLES. USE OF
PENTACHLOROPHENOL (PCP) STARTED IN 1950 AND
STEADILY INCREASED IN THE LATER YEARS OF THE ACW
OPERATIONS. DURING ITS OPERATIONS, LIQUID PROCESS
WASTES WERE DISCHARGED INTO THE TWO UNLINED,
ONSITE SURFACE IMPOUNDMENTS. PRIOR TO 1970, WASTE
WATERS IN THESE PONDS WERE ALLOWED TO
OVERFLOW THROUGH A SPILLWAY AND FOLLOW A
DRAINAGE COURSE INTO BAYOU CHICO AND PENSACOLA
BAY. IN SUBSEQUENT YEARS, WASTE WATERS WERE
PERIODICALLY DRAWN OFF THE PONDS AND
DISCHARGED INTO DESIGNATED "SPILLAGE AREAS" ON
SITE. ADDITIONAL DISCHARGES OCCURRED DURING
PERIODS OF HEAVY RAINFALL AND FLOODING, WHEN
THE PONDS OVERFLOWED THE CONTAINMENT DIKES.
DATA GATHERED DURING THE RI INDICATE THAT MAJOR
CONTAMINANTS IN THE GROUND WATER ARE AROMATIC
HYDROCARBONS COMMON TO CREOSOTE, SUCH AS,
POLYCYCLIC AROMATIC HYDROCARBONS (PAHS) AND
BENZENE, ETHYLBENZENE, TOLUENE AND XYLENE. IN
ADDITION, ONSITE SOIL SAMPLES SHOW THAT THE
AREAS WHERE WOOD-PRESERVING OPERATIONS WERE
CARRIED OUT ARE CONTAMINATED WITH PAHS.
THE SELECTED REMEDIAL ACTION FOR THIS SITE
INCLUDES EXCAVATION OF ALL CONTAMINATED SOILS
AND SLUDGES, BOTH ON AND OFFSITE, WITH
CONSOLIDATION AND ONSITE DISPOSAL IN A LANDFILL
THAT MEETS RCRA STANDARDS. TOTAL CAPITAL COST
FOR THE SELECTED REMEDIAL ALTERNATIVE IS
ESTIMATED TO BE $5,678,000 WITH ANNUAL O&M COSTS
APPROXIMATELY $50,000 FOR YEARS 1-5 AND $19,000 FOR
YEARS 6-30. AT A LATER DATE THE AGENCY WILL
CONSIDER A SECOND OPERABLE UNIT WHICH WILL
INVOLVE THE SELECTION OF AN ALTERNATIVE FOR THE
MANAGEMENT OF MIGRATION OF CONTAMINANTS IN
THE GROUND WATER AT THE SITE. OPERABLE UNITS I
AND II WILL BE THE BASIS FOR THE SITE'S REMEDIAL
DESIGN.
Remedy:
AFTER A THOROUGH REVIEW OF ALL OPTIONS, I HAVE
DETERMINED THAT ALTERNATIVE NUMBER 2, AS
DETAILED IN THE FEASIBILITY STUDY AND DESCRIBED
BELOW, IS THE APPROPRIATE REMEDY FOR SOURCE
CONTROL MEASURES AT THE SITE. THIS ALTERNATIVE
WILL BE IDENTIFIED AS OPERABLE UNIT I OF THE
REMEDY AND WILL RESULT IN;
- CONTAMINATED SOILS BEING EXCAVATED FROM
AREAS OFF THE SITE TO BE MANAGED WITH
CONTAMINATED SOILS AND SLUDGES FROM AREAS ON
THE SITE.
- THE CONSOLIDATED CONTAMINATED SOILS WILL THEN
BE MANAGED ON THE SITE CONSISTENT WITH RCRA
STANDARDS.
- THE STATE OF FLORIDA WILL EVALUATE WHETHER USE
OF OTHER ALTERNATIVES IS POSSIBLE FOR PORTIONS OF
THE CONTAMINATED MATERIAL PRESENTLY ONSITE.
THESE ALTERNATIVES WOULD BE IMPLEMENTED
THROUGH USE OF THE STATE FUND OR A COMBINATION
OF THE STATE FUND AND CERCLA. THE STATE'S INTENT
IS TO COMPLETE THIS ACTIVITY WITHIN 30 DAYS FROM
THE RECEIPT OF AVAILABLE ENVIRONMENTAL
INFORMATION.
Text:
Full-text ROD document follows on next page.
EPA/ROD/R04-85/006
1985
EPA Superfund
Record of Decision:
AMERICAN CREOSOTE WORKS, INC. (PENSACOLA
PLANT)
EPA ID: FLD008161994
OU 01
PENSACOLA, FL
09/30/1985
AMERICAN CREOSOTE WORKS INC., PENSACOLA, FLORIDA
NPL CERCLA SITE.
#DR
DOCUMENTS REVIEWED
I AM BASING MY DECISION UPON THE FOLLOWING DOCUMENTS DESCRIBING THE ANALYSIS OF
COST-EFFECTIVENESS AND FEASIBILITY OF REMEDIAL ALTERNATIVES FOR THE AMERICAN CREOSOTE WORKS
INC., PENSACOLA, FLORIDA.
-
REMEDIAL ACTION MASTER PLAN
REMEDIAL INVESTIGATION REPORT, VOLUMES I AND II
FEASIBILITY STUDY, VOLUMES I AND II, WITH ADDENDUM
RESPONSIVENESS SUMMARY TO PUBLIC MEETING AND RECOMMENDATIONS
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION.
FUTURE ACTIONS
AT A LATER DATE, OPERABLE UNIT II WILL BE REQUIRED WHICH WILL CONSTITUTE THE AGENCY'S OFFICIAL
SELECTION OF AN ALTERNATIVE FOR THE MANAGEMENT OF MIGRATION OF CONTAMINANTS IN THE GROUNDWATER
AT THIS SITE. OPERABLE UNITS I AND II WILL THEN FORM THE BASIS FOR THE ENTIRE SITE'S REMEDIAL
DESIGN.
#DE
DECLARATIONS
CONSISTENT WITH THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND LIABILITY ACT OF 1980
(CERCLA) AND THE NATIONAL CONTINGENCY PLAN (40 CFR PART 300), I HAVE DETERMINED THAT EXCAVATION
AND CONSOLIDATION OF CONTAMINATED SOILS AND SLUDGES FOR PLACEMENT IN A LANDFILL CONSTRUCTED ON
THE AMERICAN CREOSOTE WORKS SITE IN FLORIDA, IS A COST-EFFECTIVE REMEDY AND PROVIDES ADEQUATE
PROTECTION OF PUBLIC HEALTH, WELFARE, AND THE ENVIRONMENT. BASED ON AVAILABLE INFORMATION, THE
REMEDIAL ACTION DOES NOT ADVERSELY AFFECT ANY FLOODPLAIN OR WETLAND AREAS.
I HAVE FURTHER DETERMINED THAT THE STATE OF FLORIDA HAS AN INDEPENDENT FUND AND MAY CHOOSE TO
HANDLE PORTIONS OF THE CONTAMINATED MATERIAL THROUGH OTHER THAN LAND DISPOSAL ONSITE. THE
REMEDIAL DESIGN WILL INCORPORATE STATE FUNDED AND ADDITIONAL CERCLA ACTIVITIES AS AGREED TO
WITHIN A COOPERATIVE AGREEMENT OR CONTRACT IN ORDER TO PROCEED.
I HAVE DETERMINED THAT THE ACTION BEING TAKEN IS APPROPRIATE WHEN BALANCED AGAINST THE
AVAILABILITY OF TRUST FUND MONIES FOR USE AT OTHER SITES.
SEP 30 1985
DATE
JACK E. RAVAN
REGIONAL ADMINISTRATOR
EPA REGION IV.
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
#SLD
SITE LOCATION AND DESCRIPTION
THE AMERICAN CREOSOTE WORKS, INC., (ACW) SITE OCCUPIES APPROXIMATELY 12 ACRES IN A MODERATELY
DENSE, COMMERCIAL AND RESIDENTIAL DISTRICT OF PENSACOLA FLORIDA. THE SITE IS LOCATED ABOUT ONE
MILE SOUTHWEST OF THE INTERSECTION OF GARDEN AND PALAFOX STREETS IN DOWNTOWN PENSACOLA AND IS
APPROXIMATELY 600 YARDS NORTH OF PENSACOLA BAY AND BAYOU CHICO. IMMEDIATELY NORTH OF THE SITE IS
A LUMBER COMPANY, AN AUTO BODY SHOP, AN APPLIANCE SALES AND REPAIR SHOP AND A WIRE STORAGE AREA.
RESIDENTIAL NEIGHBORHOODS ARE IMMEDIATELY ADJACENT TO THE SITE ON THE EAST AND SOUTH AND A YACHT
SALES SHOP IS SOUTHWEST OF THE SITE. THE RESIDENTIAL POPULATION WITHIN A ONE MILE RADIUS WAS
APPROXIMATELY 5,000 PERSONS IN 1970. THE APPROXIMATE POPULATION IN THE AREA OF THE SITE WAS
1,056 IN 1970. A TOTAL OF 404 DWELLINGS UNITS WERE PRESENT IN THIS SAME AREA IN 1970. FIGURE 1
SHOWS THE GENERAL LOCATION OF THE ACW SITE.
THE MORE PERTINENT FEATURES OF THE SITE ARE SHOWN ON FIGURE 2. THE SITE IS ABOUT 2,100 FEET
LONG, EAST TO WEST, AND AN AVERAGE OF 390 FEET WIDE, NORTH TO SOUTH. PRIMARY ACCESS TO THE
PLANT IS OFF PINE STREET AT ITS INTERSECTION WITH "J" STREET. A RAILROAD SPUR LINE OF THE
BURLINGTON NORTHERN RAILROAD TRAVERSES THE PLANT WEST TO EAST. THE MAJORITY OF SITE BUILDINGS,
PROCESS TANKS, AND EQUIPMENT WAS SITUATED NEAR THE CENTER OF THE SITE IN AN AREA DESIGNATED AS
THE MAIN PLANT AREA. A FEW SMALL WORK SHEDS, MISCELLANEOUS EQUIPMENT AND DEBRIS LIE ABOUT THE
REMAINDER OF THE SITE.
FOUR SURFACE IMPOUNDMENTS WERE LOCATED IN THE WESTERN PORTION OF THE SITE. THE MAIN AND
OVERFLOW PONDS, LOCATED ADJACENT TO "L" STREET, WERE USED FOR DISPOSAL OF PROCESS WASTES AND ARE
1.8 AND 0.9 ACRES IN SIZE, RESPECTIVELY. DURING FORMER PLANT OPERATIONS, LIQUID WASTES
PERIODICALLY OVERFLOWED AND WERE "DRAWN-OFF" FROM THE TWO LARGER IMPOUNDMENTS AND ALLOWED TO
ACCUMULATE IN THE SMALLER RAILROAD IMPOUNDMENT, 0.3 ACRES, AND HOLDING POND, 0.1 ACRE, OR WERE
SPREAD ON THE GROUND IN "SPILLAGE AREAS".
#SH
SITE HISTORY
WOOD-PRESERVING OPERATIONS WERE CARRIED OUT AT THE ACW SITE FROM 1902 UNTIL DECEMBER, 1981.
PRIOR TO 1950, CREOSOTE WAS EXCLUSIVELY USED TO TREAT POLES. USE OF PENTACHLOROPHENOL (PCP)
STARTED IN 1950 AND STEADILY INCREASED IN THE LATER YEARS OF THE ACW OPERATIONS. DURING ITS
YEARS OF OPERATION, LIQUID PROCESS WASTES WERE DISCHARGED INTO THE TWO UNLINED, ONSITE SURFACE
IMPOUNDMENTS. PRIOR TO ABOUT 1970, WASTEWATERS IN THESE PONDS WERE ALLOWED TO OVERFLOW THROUGH
A SPILLWAY AND FOLLOW A DRAINAGE COURSE INTO BAYOU CHICO AND PENSACOLA BAY. IN SUBSEQUENT
YEARS, WASTEWATER WERE PERIODICALLY DRAWN OFF THE PONDS AND DISCHARGED TO DESIGNATED "SPILLAGE
AREAS" ON SITE. ADDITIONAL DISCHARGES OCCURRED DURING PERIODS OF HEAVY RAINFALL AND FLOODING
WHEN THE PONDS OVERFLOWED THE CONTAINMENT DIKES.
IN MARCH, 1980, CONSIDERABLE QUANTITIES OF "OILY/ASPHALTIC/CREOSOTIC AERIAL" WERE FOUND BY THE
CITY OF PENSACOLA IN THE GROUNDWATER NEAR THE INTERSECTION OF "L" AND CYPRESS STREETS. IN JULY
1981, THE U.S. GEOLOGICAL SURVEY INSTALLED NINE GROUNDWATER MONITORING WELLS IN THE VICINITY OF
THE ACW SITE. SAMPLES TAKEN FROM THOSE WELLS REVEALED THAT A CONTAMINANT PLUME WAS MOVING IN A
SOUTHERLY DIRECTION TOWARD PENSACOLA BAY. IN FEBRUARY 1983, THE SITE SCREENING SECTION
CONDUCTED A SUPERFUND INVESTIGATION. THE INVESTIGATION INCLUDED SAMPLING AND ANALYSES OF ONSITE
SOILS, WASTEWATER SLUDGES, SEDIMENT IN THE AREA DRAINAGE DITCHES AND EXISTING ONSITE AND OFFSITE
MONITORING WELLS. CONCURRENT WITH THIS INVESTIGATION, THE USGS INITIATED A SITE AND LABORATORY
RESEARCH STUDY.
BECAUSE OF THE THREAT POSED TO HUMAN HEALTH AND THE ENVIRONMENT BY FREQUENT OVERFLOWS FROM THE
WASTE PONDS, EPA, REGION IV, EMERGENCY RESPONSE AND CONTROL SECTION PERFORMED AN IMMEDIATE
CLEANUP DURING SEPTEMBER TO OCTOBER 1983. THE IMMEDIATE CLEANUP WORK INCLUDED DEWATERING THE
TWO LARGE LAGOONS (MAIN AND OVERFLOW PONDS), WITH THE WATER BEING TREATED VIA COAGULATION,
SEDIMENTATION AND FILTRATION WITH SUBSEQUENT DISCHARGE TO THE CITY OF PENSACOLA SEWER SYSTEM.
THE SLUDGE IN THE LAGOON WAS THEN SOLIDIFIED WITH LIME AND FLY ASH. A TEMPORARY CLAY CAP WAS
PLACED OVER THE SOLIDIFIED MATERIAL. THE FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION (FDER)
ALSO ASSISTED DURING THE CLEANUP. IN JANUARY 1984, A REMEDIAL INVESTIGATION AND FEASIBILITY
STUDY UNDER CERCLA WAS INITIATED BY EPA'S CONTRACTOR.
SITE GEOMORPHOLOGY
THE ACW SITE IS LOCATED IN THE GULF COASTAL LOWLANDS OF WESTERN FLORIDA. THE SITE IS NEARLY
FLAT, WITH ELEVATIONS RANGING BETWEEN 12 TO 14 FEET ABOVE SEA LEVEL. THE LAND SLOPES GENTLY
SOUTHWARD AT ABOUT 25 FEET PER MILE TOWARD THE PENSACOLA BAY.
THE FEDERAL EMERGENCY MANAGEMENT AGENCY (FEMA) FLOOD INSURANCE RATE MAP (FIRM) INDICATES THE
BOUNDARIES AND ELEVATIONS OF THE 100-YEAR FLOODPLAIN. BASED ON THE FIRM, THE 100-YEAR
FLOODPLAIN IS NOT LOCATED WITHIN THE ACW SITE AREA AND WILL NOT BE AFFECTED BY REMOVAL OR SOURCE
CONTROL TYPES OF ACTIONS AT THE SITE.
LOCAL GEOLOGY
THE WATER-BEARING ZONE UNDERLYING THE ACW SITE AREA IS COMPOSED PRIMARILY OF SAND WITH MANY
INTERBEDDED LAYERS AND LENSES OF CLAY AND SANDY CLAY. THESE CLAY LAYERS AND LENSES RANGE FROM
LESS THAN AN INCH TO APPROXIMATELY 38 FEET FEET IN THICKNESS. BASED ON CHARACTERISTICS OF THE
SANDS IN THESE AREAS, THE WATER-BEARING ZONE CAN BE STRATIGRAPHICALLY DIVIDED INTO TWO AREAS.
THE SAND IN THE UPPER 25 FEET OF SEDIMENT VARIES IN GRAIN SIZE FROM FINE TO COARSE AND IN
DENSITY FROM LOOSE TO DENSE. THESE VARIATION IN GRAIN SIZE AND DENSITY ARE IMPORTANT, SINCE
THESE ARE A FACTOR IN THE SEEPAGE RATE OF WATER THROUGH THE SEDIMENT. FIGURE 3 PRESENTS A
GENERALIZED STRATIGRAPHIC COLUMN.
THERE ARE TWO MASSIVE CLAY FORMATIONS IN THE WATER-BEARING ZONE IN THE AREA OF INVESTIGATION.
ONE CLAY LAYER IS DIRECTLY UNDER THE ACW PONDS. THIS CLAY LAYER APPEARS TO BE CONTINUOUS UNDER
THE ACW POND AREA, ALTHOUGH IT DOES PINCH OUT SOUTH OF THE SITE. SOUTH OF THE SITE, A SECOND
MASSIVE CLAY LAYER UNDERLIES THE PENSACOLA YACHT CLUB PROPERTY AND EXTENDS SOUTH TO THE
PENSACOLA BAY. THIS SECOND CLAY PINCHES OUT BEFORE REACHING THE ACW SITE. THE RESULTS OF A
GROUND PENETRATING RADAR SURVEY HAVE SHOWN MANY CHANNEL DEPOSITS IN THE SITE AREA.
SURFACE WATER
THE DOMINANT BODY OF WATER IN THE ACW SITE AREA IS PENSACOLA BAY. DURING RAINFALL EVENTS, MOST
RUNOFF FROM THE SITE PASSES THROUGH THE STREET AND STORM DRAINS TO THE BAY.
THERE IS A SMALL DRAINAGE
ACW SURFACE IMPOUNDMENTS.
STREET AND EXTENDS TO THE
SURFACE DURING RAIN, MOST
DITCH IS BELOW THE TOP OF
DITCH ON THE PENSACOLA YACHT CLUB (PYC) PROPERTY DIRECTLY SOUTH OF THE
THE DRAINAGE DITCH BEGINS APPROXIMATELY 200 FEET SOUTH OF CYPRESS
BAY. THOUGH THE DRAINAGE DITCH IS FED BY SOME RUNOFF FROM THE LAND
RECHARGE OF THE DITCH IS FROM THE GROUNDWATER. THE BOTTOM OF THE
THE GROUNDWATER TABLE.
THE PENSACOLA BAY EXERTS A TIDAL EFFECT ON THE DRAINAGE DITCH. DURING HIGH TIDES, WATER FLOWS
INTO THE DITCH, FLOWING NORTH FROM THE BAY. WHEN THE TIDE RECEDES, WATER FLOWS SOUTH TO THE BAY
FROM THE DITCH, CREATING A 'WASHING' EFFECT, WHERE THE CONTAMINANTS THAT HAVE COLLECTED IN THE
DITCH ARE WASHED TO THE BAY.
HYDROGEOLOGY
IN SOUTHERN ESCAMBIA COUNTY, PRACTICALLY ALL THE FRESH GROUNDWATER IS OBTAINED FROM THE
SAND-AND-GRAVEL AQUIFER. THE AQUIFER IS RECHARGED BY LOCAL RAINFALL. BECAUSE OF THE SANDY
NATURE OF THE AQUIFER AND OVERLYING SOILS, INFILTRATION RATES ARE RELATIVELY HIGH. ANNUAL
RECHARGE IS 0 TO 10 INCHES PER YEAR.
THE DIRECTION OF GROUNDWATER FLOW IS TO THE SOUTH WITH DISCHARGE TO PENSACOLA BAY. THERE ARE NO
PUBLIC WATER SUPPLY WELLS IN THE IMMEDIATE VICINITY OF THE ACW SITE. THE CLOSEST WELL FIELD
BELONGS TO THE CITY OF PENSACOLA, LOCATED APPROXIMATELY A MILE NORTH OF THE SITE. THE CONE OF
INFLUENCE OF THESE WELLS DOES NOT REACH THE ACW SITE, AND ARE NOT EFFECTED BY THE CONTAMINATION
FROM THE ACW SITE.
SURFACE WATER DRAINAGE
DRAINAGE AT THE SITE IS NOT WELL DEVELOPED. MOST DRAINAGE IN THE AREA IS BY OVERLAND SHEET FLOW
THROUGH THE STREETS AND INTO STORM DRAINS SOUTH OF THE SITE TO PENSACOLA BAY AND BY WAY OF THE
DRAINAGE DITCH ON THE PENSACOLA YACHT CLUB PROPERTY.
ECOLOGY
THE ACW SITE IS LOCATED IN THE PENSACOLA URBANIZED AREA. VEGETATION AROUND THE SITE CONSISTS
MOSTLY OF CULTIVATED GRASSES, TREES AND SHRUBS. TREES THE SURROUNDING AREA ARE LARGELY OAKS,
WHILE NO MATURE TREES ARE PRESENT ON THE SITE. VEGETATION ON THE SITE IS MIXTURE OF GRASSES AND
OTHER HERBS. WILDLIFE IN THE AREA IS TYPICALLY URBAN WITH RODENTS, SQUIRRELS, RACCOONS AND
OPOSSUMS OCCASIONALLY ENTERING THE SITE, AS WELL AS URBAN BIRDS SPECIES.
SOME SHORE BIRDS FROM ADJACENT MARINE AND FRESHWATER HABITATS SOMETIMES FREQUENT THE SITE.
PENSACOLA BAY AND BAYOU CHICO REPRESENT CRITICAL ENVIRONMENTAL SYSTEMS DOWNGRADIENT FROM THE ACW
SITE. THE ECOSYSTEM IN THESE WATER BODIES HAS BEEN STRESSED IN THE PAST DUE TO POLLUTION OF
THESE WATER CAUSED BY INDUSTRIAL, MUNICIPAL AND STORM WATER DISCHARGES.
NATURE AND EXTENT OF CONTAMINATION
TABLE 1 SUMMARIZES THE CHEMICAL DATA GATHERED DURING THE RI AND PRESENTS THE CONCENTRATION
RANGES OF THE MOST FREQUENTLY OCCURRING CONTAMINANTS.
WASTE CONDITIONS
LIQUID AND SLUDGES SAMPLES TAKEN FROM THE ONSITE SURFACE IMPOUNDMENTS DURING AN EPA
INVESTIGATION IN FEBRUARY, 1983, REVEALED THE PRESENCE OF 1,1,2,2-TETRACHLOROETHANE,
CHLOROBENZENE, ETHYLBENZENE, XYLENE, STYRENE, PENTACHLOROPHENOL, AND 1,1,1-TRICHLOROPHENOL IN
THE AQUEOUS PHASE AND PAHS ASSOCIATED WITH WOOD PRESERVING CREOSOTE PROCESSES IN THE SLUDGES.
VARIOUS METALS WERE ALSO IDENTIFIED, INCLUDING ALUMINUM, ARSENIC, COPPER, IRON, MANGANESE, AND
ZINC.
A STUDY CONDUCTED BY THE ENVIRONMENTAL RESPONSE TEAM IN JUNE, 1983, DETERMINED THE CREOSOTE
DISTRIBUTION IN THE MAIN AND OVERFLOW PONDS BY OBTAINING SLUDGE CORES AND VISUALLY OBSERVING
SUCH CHARACTERISTICS AS SLUDGE THICKNESS, TOTAL COLUMN HEIGHT AND OTHER PHYSICAL
CHARACTERISTICS. THE VOLUME OF SLUDGE DETERMINED FROM THIS STUDY WAS APPROXIMATED AT 107,300
CUBIC FEET FOR BOTH PONDS.
THE WATER DEPTH NOTED IN THE TWO PONDS DURING THIS INVESTIGATION WAS ABOUT 4 FEET WITH A WATER
SURFACE ABOUT 2 FEET ABOVE THE SURROUNDING GRADE. TESTS INDICATED THAT THE CONTAMINATED SLUDGE
IS IN DIRECT AND CONSTANT CONTACT WITH THE SHALLOW GROUNDWATER TABLE.
THE SLUDGES IN THE PONDS WERE DE-WATERED AND THEN FIXED WITH LIME AND FLY ASH AND A TEMPORARY
CLAY CAP WAS PLACED OVER THE SOLIDIFIED MATERIAL LEFT ON SITE. AS A RESULT OF THE IMMEDIATE
CLEANUP, THE POND AREAS CONTAIN 40,000 CUBIC YARDS OF MATERIAL CONSISTING OF A MIXTURE OF
SLUDGE, FLY ASH AND LIME, AND 24,122 CUBIC YARDS OF CLAY USED FOR CAPPING.
GROUNDWATER CONTAMINATION
DATA GATHERED DURING THE RI INDICATE THAT GROUNDWATER CONTAMINATION EXTENDS AN APPROXIMATE DEPTH
OF 60 FEET BELOW THE GROUND SURFACE AND AT LEVELS 900 FEET SOUTH OF THE SITE. THE DATA SHOW
THAT MAJOR CONTAMINANTS IN THE GROUNDWATER ARE AROMATIC HYDROCARBONS COMMON TO CREOSOTE, SUCH
AS, POLYCYCLIC AROMATIC HYDROCARBONS (PAHS) AND BENZENE, ETHYLBENZENE, TOLUENE, AND XYLENE
(BTX). OTHER CONTAMINANTS THAT HAVE BEEN IDENTIFIED INCLUDE METHYLPHENOL CARBAZOLES, PYRIDENES,
QUINOLENES, STYRENE, ACETONE, NAPHTHALENE, AND A FEW PESTICIDES.
THE DATA INDICATE THE GROUNDWATER CONTAMINATION IS GREATEST SOUTH OF AND IMMEDIATELY ADJACENT TO
THE FORMER SURFACE IMPOUNDMENTS. THE DATA ALSO INDICATE THE CONTAMINATION GENERALLY DECREASES
WITH DEPTH AT EACH MONITORING WELL CLUSTER AND THAT CONTAMINATION GENERALLY DECREASES
DOWNGRADIENT OF THE SITE. AT A DEPTH OF 20 FEET CONTAMINATION DECREASES AS THE GROUNDWATER
MOVES SOUTH OF THE SITE TOWARD THE BAY, THIS IS FURTHER VERIFIED AT THE 60 FOOT DEPTH.
CONTAMINANT REDUCTION IS MOST PROBABLY A COMBINATION OF ADSORPTION ON SOIL AND SEDIMENTS AND
REMOVAL BY MIXING WITH SURFACE WATER. THE DRAINAGE DITCH AREA SOUTH OF THE SITE RECEIVES MOST
OF ITS RECHARGE FROM THE GROUND WATER. HENCE, CONTAMINATED GROUNDWATER MAY BE MOVING RAPIDLY
TOWARD THE BAY AS SURFACE RUNOFF. THE EFFECT OF SURFACE WATER RUNOFF IS ENHANCED BY TIDAL
BACKWASH, WHICH 'WASHES' THE DITCH AREA.
SOIL CONTAMINATION
ONSITE SOIL SAMPLES SHOW THAT THE AREAS WHERE WOOD-PRESERVING OPERATIONS WERE CARRIED OUT ARE
CONTAMINATED WITH PAHS. THE DATA SHOW THAT THE PRIMARY SOILS CONTAMINANTS ARE THE HIGHER
MOLECULAR WEIGHT PAH SPECIES, ANTHRACENE, BENZO(A)ANTHRACENE, CHRYSENE, FLUORANTHENE,
BENZO(A)FLUORANTHENE, FLUORENE, PHENATHRENE, PYRENE, AND BENZO(A)PYRENE. LOWER AQUEOUS
SOLUBILITY AND HIGHER AFFINITY FOR ADSORPTION ON SOIL IS TO BE EXPECTED FOR THESE COMPOUNDS.
THE ANALYTICAL DATA ALSO SHOW TWO DIFFERENT PATTERNS OF SOIL CONTAMINATION IN THE ACW SOIL
SAMPLES. SAMPLES TAKEN IN AREAS 1,2,3,8 AND 9 SHOW A GENERALLY DECREASING DEGREE OF
CONTAMINATION WITH DEPTH AND A TOTAL BASE/NEUTRAL FRACTION CONTENT OF LESS THAN 500 MG/KG IN ALL
SAMPLES, WHILE SAMPLES TAKEN FROM AREAS 4,5,6 AND 7 SHOW A LESS DISTINCT VARIATION OF
CONTAMINANT CONCENTRATION WITH DEPTH AND A MUCH HIGHER TOTAL CONCENTRATION OF ORGANICS. FIGURE
4 ILLUSTRATES THE LOCATIONS OF THESE AREAS.
OFFSITE SOIL SAMPLES SHOW THAT VARIOUS PAHS, SIMILAR TO THOSE FOUND IN THE ONSITE SOIL SAMPLES
WERE IDENTIFIED IN THE AREA REPRESENTING THE NORTHEAST CORNER OF THE PYC. BASED ON THE
AVAILABLE DATA, IT APPEARS THAT SOIL CONTAMINATION OF THE PYC PROPERTY IS LIMITED. BASED ON
ADDITIONAL OFFSITE SOIL SAMPLES, COLLECTED IN JANUARY 1985, IT APPEARS THAT THERE IS SOIL
CONTAMINATION ON CITY BLOCKS 179 THROUGH 184 AND BLOCK 162, IMMEDIATELY SOUTH AND WEST OF THE
ACW SITE.
SURFACE WATER AND SEDIMENT CONTAMINATION
THE DATA SHOW VERY LITTLE CONTAMINATION IN THE SURFACE WATER OF THE DRAINAGE DITCH.
A POSSIBLE
EXPLANATION FOR THIS COULD BE THE EFFECT OF DILUTION FROM OTHER SURFACE WATER CONTRIBUTIONS AND
THE TIDAL WASHING EFFECT. THE LOW LEVELS OF CONTAMINANTS IN THE DRAINAGE DITCH WOULD NOT POSE A
THREAT TO HUMAN HEALTH AND THE ENVIRONMENT. THE HIGH CHLORIDE CONTENT IN CERTAIN SAMPLES TAKEN
IN THE DRAINAGE DITCH INDICATED THE PRESENCE OF SEAWATER.
SEDIMENT DATA FROM THE DRAINAGE DITCH AREA SHOW THE PRESENCE OF THE PAHS AND VOLATILE COMPONENTS
PREVIOUSLY IDENTIFIED IN THE MONITORING WELL SAMPLES. THE HIGH OIL AND GREASE CONTENT OF
SAMPLES COLLECTED ALSO SHOWS THE ATTRACTION OF CREOSOTE OIL TO THE SEDIMENT MATRIX. NO
CONTAMINATION WAS FOUND IN THE SEDIMENT SAMPLES TAKEN AT THE PENSACOLA BAY.
PUBLIC HEALTH AND ENVIRONMENTAL RISK EVALUATION
ENVIRONMENTAL DATA SHOW THAT MOST CONTAMINATED MATERIALS ARE SURFACE SOILS, SUBSURFACE SOILS AND
THE SLUDGE PRESENT IN THE BOTTOM OF THE MAIN AND OVERFLOW PONDS. THE MAJOR PATHWAY FOR THE
MIGRATION OF CONTAMINANTS IS VIA LEACHING BY INFILTRATING, PRECIPITATION OR GROUNDWATER INFLOW,
FOLLOWED BY TRANSPORT WITH GROUNDWATER.
CONTAMINATED SEDIMENT TRANSPORT IS ALSO POSSIBLE VIA SURFACE WATER RUNOFF. THIS WOULD BE
CONFINED TO THE DRAINAGE DITCH RUNNING TO PENSACOLA BAY. TRANSPORT OF THE TYPES OF CONTAMINANTS
FOUND IN THE GROUNDWATER UNDER THE ACW SITE MAY PRESENT THE POTENTIAL FOR SHORT-TERM
BIOACCUMULATION IN THE MARINE BIOTA. BECAUSE ENVIRONMENTAL POLLUTANTS RESULTING FROM OTHER
SOURCES COULD JUST AS EASILY BE THE CONTAMINANT SOURCE, IT COULD BE DIFFICULT TO DIFFERENTIATE
AMONG THE POTENTIAL SOURCES OF PAHS IN MARINE, FISH AND INVERTEBRATES IN THE BAY.
IN SUMMARY, ON THE BASIS OF PRESENT CONTAINMENT DISTRIBUTION, THE MOST SIGNIFICANT TRANSPORT IS
THROUGH THE MOVEMENT OF CONTAMINANTS FROM THE FORMER SLUDGE LAGOONS THROUGH AND WITH GROUNDWATER
TO PENSACOLA BAY. A MINOR TRANSPORT MECHANISM IS THE PHYSICAL TRANSPORT OF CONTAMINATED
SEDIMENTS IN STORM RUNOFF, ALSO MOVING TOWARD THE BAY VIA THE DRAINAGE DITCH. ALTHOUGH AIR
TRANSPORT IS NOT LIKELY, ANOTHER MINOR TRANSPORT MECHANISM COULD BE THROUGH SOILS DUST MOBILIZED
DURING REMEDIAL IMPLEMENTATION.
A PROCESS WAS DEVELOPED TO SELECT THE COMPOUNDS THAT MOST REPRESENT THE OVERALL SITE HAZARD.
THE CRITERIA INCLUDED, SIGNIFICANT HEALTH CONSEQUENCES, THE FREQUENCY OF OCCURRENCE AND
MAGNITUDE OF THE CONTAMINANTS, DATA VALIDATION, THE AVAILABILITY OF STANDARDS AND KNOWN TOXIC
AND/OR CARCINOGENIC PROPERTIES, AND THE RELATIONSHIP OF THE COMPOUND TO THE SITE. TABLE 2
PRESENTS THE CRITICAL CONTAMINANTS USED FOR THE RISK ASSESSMENT.
POTENTIAL HUMAN RECEPTORS INCLUDE CONSUMERS OF MARINE FISH AND SHELLFISH, IN WHICH SOME OF THE
CONTAMINANTS MAY ACCUMULATE ON A SHORT-TERM BASIS. POTENTIALLY, THE SITE COULD BE A CONTRIBUTOR
OF THESE CONTAMINANTS, BUT NOT NECESSARILY THE SOLE SOURCE OR MOST SIGNIFICANT CONTRIBUTOR.
REMEDIAL CLEANUP PERSONNEL MAY BE EXPOSED, IF THEY HAVE DIRECT CONTACT WITH CONTAMINATED
SLUDGES, OR CONTAMINATED DUSTS. LOCAL RESIDENTS WHO MAY COME INTO REPEATED CONTACT WITH
CONTAMINATED SOILS AND SEDIMENT MAY BE EXPOSED. OTHER POTENTIAL RECEPTORS MAY BE CHILDREN
INGESTING CONTAMINATED GROUNDWATER THROUGH LAWN-WATERING AND OTHER CASUAL USE OF THE RESIDENTIAL
WELLS.
POTENTIAL ENVIRONMENTAL RECEPTOR INCLUDE THE GROUNDWATER, AS RELATED TO QUALITY AND LIMITATION
ON ITS USE FOR ALL PURPOSES. AMBIENT AIR MAY BE A RECEPTOR IN THE CONTEXT OF AESTHETIC FACTORS.
ANOTHER POTENTIAL RECEPTOR INCLUDES THE MARINE FLORA AND FAUNA AS WELL AS THE PENSACOLA BAY
WHERE LIMITATIONS ON ITS RECREATIONAL USE MAY BE IMPOSED. TERRESTRIAL FLORA AND FAUNA MAY BE A
RECEPTOR.
#ENF
ENFORCEMENT SUMMARY
THE EARLIEST DOCUMENTED INCIDENT OF A RELEASE OF ANY TYPE FROM THE ACW PLANT OCCURRED IN THE
SUMMER OF 1978, WHEN A SPILL OF LIQUIDS FLOWED ONTO A NEARBY STREET AND THEN ONTO THE PROPERTY
OF A YACHT SALES COMPANY. A FLOOD IN MARCH, 1979, RESULTED IN A SIMILAR SPILL. THIS INCIDENT
RESULTED IN INCREASED REGULATORY ATTENTION TO ACW BY THE FLORIDA DEPARTMENT OF ENVIRONMENTAL
REGULATION (FDER).
ACW FILED AN INCOMPLETE APPLICATION WITH THE FDER IN MAY 1980, FOR THE CONSTRUCTION OF AN
INDUSTRIAL WASTEWATER TREATMENT SYSTEM. THE FDER ISSUED A NOTICE OF VIOLATION (NOV) AND ORDERS
FOR CORRECTIVE ACTION TO ACW IN JANUARY, 1981. THIS ENFORCEMENT ACTION INCLUDED AN ORDER TO
CEASE OPERATIONS UNTIL A PERMIT WAS ISSUED. IN ADDITION, ACW WAS TO SUBMIT A RESTORATION PLAN,
INSTALL A GROUNDWATER WELL MONITORING SYSTEM, AND REMOVE CONTAMINATED SOILS. IN JANUARY 1981,
THE FDER COMPLETED A RESPONSIBLE PARTY SEARCH, A TITLE SEARCH, AND A FINANCIAL ASSESSMENT FOR
THE SITE. THE FDER ISSUED A CONSENT ORDER IN MARCH 24, 1981, INCORPORATING THE NOV REQUIREMENTS
AND ALLOWING ACW TO CONTINUE OPERATIONS. THE ORDER INCLUDED SCHEDULES FOR COMPLETING
CONSTRUCTION OF THE WASTE WATER TREATMENT SYSTEM AND FOR MEETING THE OTHER NOV REQUIREMENTS.
THROUGHOUT 1981 AND 1982, THE FDER ENCOUNTERED DIFFICULTY WITH ACW'S COMPLIANCE EFFORTS. IN
MARCH, 1982 ACW ANNOUNCED THAT IT WAS GOING OUT OF BUSINESS. IN APRIL 1982, THE FDER FILED A
PETITION FOR ENFORCEMENT AND AGENCY ACTION AND COMPLAINT FOR PERMANENT INJUNCTION AND CIVIL
PENALTIES AS A RESULT OF ACW'S FAILURE TO MAKE PROGRESS TOWARD COMPLIANCE. ONE MONTH LATER IN
MAY 1982, ACW, INC., OF FLORIDA, FILED FOR REORGANIZATIONAL BANKRUPTCY COURT. THE FDER PREPARED
MOTIONS OPPOSING THE REMOVAL AND THE STAY OF ITS CASE AGAINST AMERICAN CREOSOTE AS WELL AS PROOF
OF CLAIM AND A MOTION FOR DEFAULT.
IN THE SUMMER OF 1981, THE INFORMATION REQUIRED FOR THE HAZARD RANK SCORING (MITRE RANKING) OF
THE SITE WAS COLLECTED BY ECOLOGY AND ENVIRONMENT, INC., AN EPA CONTRACTOR. THE SITE WAS RANKED
ON SEPTEMBER 24, 1981, AND WAS PROPOSED FOR THE NATIONAL PRIORITIES LIST (NPL) IN OCTOBER, 1981.
IT SCORED 58.41 POINTS OUT OF 100 POSSIBLE POINTS AND NOW RANKS 50TH AMONGST 538 TOTAL NPL SITES
NATIONWIDE. IN SEPTEMBER 1983, THE MAIN AND OVERFLOW PONDS WERE FOUND TO BE WITHIN 1 TO 2
INCHES OF OVERFLOWING. EPA INITIATED AN IMMEDIATE REMOVAL ACTION. EPA'S COST FOR THE IMMEDIATE
REMOVAL TO STABILIZE THE SITE WAS APPROXIMATELY $730,000.
IN 1984 THE BANKRUPTCY COURT PRESENTED A FINAL COURT STIPULATION FOR THE APPROVAL OF THE
LITIGANTS. THE ACW SITE WOULD BE SOLD AFTER CLEANUP AND THE PROCEEDS WOULD BE DIVIDED AMONGST
THE FDER, THE EPA, AND THE FINANCIAL ORGANIZATION HOLDING THE CORPORATION'S ASSETS, I.E., SAVING
LIFE INSURANCE COMPANY (AS OF JULY 1985, THE COURT STIPULATION HAD NOT BEEN SIGNED BY THE
LITIGANTS IN THE BANKRUPTCY PROCEEDING).
IN MARCH 1985, THE BURLINGTON NORTHERN RAILROAD WAS SENT A NOTICE LETTER REQUESTING THAT THEY
PERFORM CERTAIN TASKS ON-SITE. SPECIFICALLY, THEY WERE TO REMOVE, UTILIZING AN EPA-APPROVED WORK
PLAN, RAILROAD SPUR LINES WHICH EXIST OVER AN AREA OF KNOWN CONTAMINATION. COMMUNICATIONS WITH
BURLINGTON NORTHERN REPRESENTATIVES SINCE THEN INDICATE THAT THE RAILROAD IS AMENABLE TO
COMPLETING THE ASSIGNED TASKS WITHIN THE TIME FRAME SPECIFIED.
#AE
ALTERNATIVE EVALUATION
A LIST OF ALL ALTERNATIVES CONSIDERED ARE GIVEN IN TABLE 3. ONSITE ALTERNATIVES THAT COMPLY
WITH OTHER ENVIRONMENTAL LAWS ARE LISTED IN TABLE 4. EACH OF THE REMEDIAL ALTERNATIVES HAS
PASSED TECHNOLOGY SCREENING ON THE BASIS OF PUBLIC HEALTH AND ENVIRONMENTAL CONCERNS. EACH
ALTERNATIVE WAS EVALUATED IN TERMS OF THE EXTENT TO WHICH THE ALTERNATIVE REMEDIATES OR
MINIMIZES THE POTENTIAL HEALTH HAZARDS AND ENVIRONMENTAL IMPACTS AS IDENTIFIED IN THE RI REPORT,
SECTION 7, AND THE POTENTIAL PUBLIC HEALTH IMPACTS AS A RESULT OF IMPLEMENTATION OF THE
ALTERNATIVE.
THE REMEDIAL ALTERNATIVES DEVELOPED WERE PLACED INTO ONE OF THE FOLLOWING CATEGORIES:
1) ALTERNATIVES SPECIFYING OFFSITE STORAGE, DESTRUCTION TREATMENT OR SECURE DISPOSAL OF
HAZARDOUS SUBSTANCE AT A FACILITY APPROVED UNDER RCRA. SUCH A FACILITY MUST ALSO BE IN
COMPLIANCE WITH ALL OTHER APPLICABLE EPA STANDARDS (E.G., CLEAN WATER ACT, CLEAN AIR ACT, TOXIC
SUBSTANCE CONTROL ACT).
2) ALTERNATIVES THAT ATTAIN ALL APPLICABLE OR RELEVANT FEDERAL PUBLIC HEALTH OR ENVIRONMENTAL
STANDARDS, GUIDANCE OR ADVISORIES.
3) ALTERNATIVES THAT EXCEED ALL APPLICABLE OR RELEVANT FEDERAL PUBLIC HEALTH OR ENVIRONMENTAL
STANDARDS, GUIDANCE AND ADVISORIES.
4) ALTERNATIVES THAT MEET THE CERCLA GOALS OF PREVENTING OR MINIMIZING PRESENT OR FUTURE
MIGRATION OF HAZARDOUS SUBSTANCES, BUT DO NOT ATTAIN THE APPLICABLE RELEVANT STANDARDS. THIS
CATEGORY MAY INCLUDE AN ALTERNATIVE THAT CLOSELY APPROACHES THE LEVEL OF PROTECTION PROVIDED BY
THE APPLICABLE OR RELEVANT STANDARDS.
5) NO ACTION.
ALL THE ALTERNATIVES LISTED IN TABLE 5 ARE ASSUMED TO INCLUDE LONG-TERM SITE MONITORING AND
INSPECTION TO VERIFY CLEANUP LEVELS AND MAINTAIN THE REMEDIAL ACTION RELIABILITY.
SOME OF THE ALTERNATIVES, NOTABLY THOSE INVOLVING GROUNDWATER TREATMENT, COULD FIT INTO MULTIPLE
CATEGORIES BY MODIFYING THE TREATMENT PROCESS.
A TWO-PHASE PROCESS HAS BEEN USED TO SELECT THE MOST APPROPRIATE REMEDIAL ALTERNATIVES. FIRST,
AN INITIAL SCREENING OF FEASIBLE TECHNOLOGIES WAS USED TO ELIMINATE INFEASIBLE, INAPPROPRIATE OR
ENVIRONMENTALLY UNACCEPTABLE TECHNOLOGIES. THIS SCREENING INCLUDES TECHNICAL CONCERNS,
INSTITUTIONAL PERFORMANCE AND COST CRITERIA. SECOND, TECHNOLOGIES THAT PASS THE SCREENING ARE
EVALUATED INDIVIDUALLY OR COMBINED TO FORM DEFINITIVE REMEDIAL ALTERNATIVES.
SITE DATA AND WASTE CHARACTERISTICS WERE REVIEWED WITH RESPECT TO EACH TECHNOLOGY TO IDENTIFY
THE TECHNICAL CRITERIA. TABLE 6-A SHOWS LIMITATIONS OF CERTAIN TECHNOLOGIES BECAUSE OF THE
PHYSICAL LIMITATION OF THE SITE CHARACTERISTICS. TABLE 6-B WILL LIMIT CERTAIN TECHNOLOGIES
BECAUSE OF THE LIMITATION OF THE WASTE CHARACTERISTICS. OTHER TECHNICAL CRITERIA CONSIDERED WAS
THE RELIABILITY AND PERFORMANCE OF THE TECHNOLOGY AND THE IMPLEMENTABILITY OR HOW EASILY THE
TECHNOLOGY COULD BE CONSTRUCTED, OPERATED AND MAINTAINED.
REMEDIAL TECHNOLOGIES MUST COMPLY WITH INSTITUTIONAL CRITERIA FROM FEDERAL, STATE AND LOCAL
STANDARDS WHEREVER APPLICABLE TO THE DESIGN, CONSTRUCTION AND OPERATION OF EACH TECHNOLOGY.
SOME CONSIDERATIONS INCLUDE BUT ARE NOT LIMITED TO THE FOLLOWING; A) RESOURCE CONSERVATION AND
RECOVERY ACT (RCRA), B) NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES), C) STATE AND
FEDERAL DEPARTMENT OF TRANSPORTATION REGULATIONS ON THE HANDLING/SHIPPING AND MANIFESTING OF
HAZARDOUS WASTE, D) LOCAL ZONING AND CONSTRUCTION PERMITS AND E) LOCAL PERMITS ISSUED BY
PUBLICLY OWNED TREATMENT WORKS (POTW). TECHNOLOGIES THAT ARE AN ORDER OF MAGNITUDE OR GREATER
IN COST THAN OTHER ALTERNATIVES ARE SCREENED OUT IF THE INCREASED COST OFFERS NO GREATER
RELIABILITY OR IF THE INCREASED COST PROVIDES NO GREATER ENVIRONMENTAL OR PUBLIC HEALTH BENEFIT.
THIS COST SCREENING IS INTENDED TO REDUCE THE NUMBER OF TECHNOLOGIES THAT ARE EXCESSIVELY COSTLY
BUT DOES NOT REPLACE THE DETAILED COST ANALYSIS FOR THE ALTERNATIVES REMAINING AFTER THE INITIAL
SCREENING. A LIST OF REMEDIAL ALTERNATIVES REMAINING FOLLOWING THE SCREENING PROCEDURES ARE
GIVEN IN TABLE 7 AND TABLE 8 LIST THE REMEDIAL ALTERNATIVES. A TOTAL DESCRIPTION OF EACH
REMEDIAL ALTERNATIVE IS GIVEN IN THE FEASIBILITY STUDY REPORT.
#CR
COMMUNITY RELATIONS
THREE FACT SHEETS HAVE BEEN ISSUED TO KEEP THE PUBLIC INFORMED ABOUT THE PROGRESS OF THE
REMEDIAL INVESTIGATION AND THE DEVELOPMENT OF THE FEASIBILITY STUDY. THE LOCAL PRESS HAS BEEN
INVOLVED WITH THE PROGRESS OF THE AMERICAN CREOSOTE WORKS OPERATIONS BEGINNING BEFORE THE SITE
BECAME AN INTEREST OF EPA OR THE NATIONAL PRIORITY LIST. A MEETING WAS HELD AT THE PENSACOLA
YACHT CLUB TO INFORM THE MEMBERSHIP OF THE FINDINGS OF THE REMEDIAL INVESTIGATION. THE YACHT
CLUB IS VERY INTERESTED IN THE DEVELOPMENT OF THEIR PROPERTY IN THE FORM OF CONDOMINIUM OR
YACHTING SLIPS. THE PORTION OF THE CLUB'S PROPERTY THAT WOULD LEND ITSELF TO SUCH DEVELOPMENT
HAS BEEN ESTABLISHED AS CONTAMINATED FROM THE REMEDIAL INVESTIGATION. A PUBLIC HEARING WAS HELD
TO INFORM THE PUBLIC AND PRESENT THE DRAFT FEASIBILITY STUDY OF ALTERNATIVES AND ALLOW FOR
PUBLIC COMMENT. A RESPONSIVENESS SUMMARY OUTLINING THE RESULTS OF THE PUBLIC COMMENT IS
ATTACHED. INFORMATION REPOSITORIES ARE ESTABLISHED AT THE WEST FLORIDA REGIONAL LIBRARY, THE
PENSACOLA JUNIOR COLLEGE AND THE WEST FLORIDA UNIVERSITY. WHEN APPROVED, THE RECORD OF DECISION
WILL BE MAILED TO THESE REPOSITORIES.
#RA
RECOMMEND ALTERNATIVE
SECTION 300.68(J) OF THE NATIONAL CONTINGENCY PLAN (NCP)(47 FR 31180; JULY 16, 1983) STATES THAT
THE APPROPRIATE EXTENT OF REMEDY SHALL BE DETERMINED BY THE LEAD AGENCY'S SELECTION OF A
REMEDIAL ALTERNATIVE WHICH THE AGENCY DETERMINES IS COST EFFECTIVE (I.E., THE LOWEST COST
ALTERNATIVE THAT IS TECHNICALLY FEASIBLE AND RELIABLE) AND WHICH EFFECTIVELY MITIGATES AND
MINIMIZES DAMAGE TO AND PROVIDES ADEQUATE PROTECTION OF PUBLIC HEALTH, WELFARE AND THE
ENVIRONMENT. IN SELECTING A REMEDIAL ALTERNATIVE EPA CONSIDERS ALL ENVIRONMENTAL LAWS THAT ARE
APPLICABLE AND RELEVANT. BASED ON THE EVALUATION OF THE COST EFFECTIVENESS OF EACH OF THE
PROPOSED ALTERNATIVES, THE COMMENTS RECEIVED FROM THE PUBLIC, WE RECOMMEND ALTERNATIVE NUMBER 2
TO BE IMPLEMENTED AT THE AMERICAN CREOSOTE WORKS SUPERFUND SITE. THIS SELECTED ALTERNATIVE WILL
ADDRESS ALL ONSITE SURFACE AND SUBSURFACE CONTAMINATION PROBLEMS IDENTIFIED IN THE REMEDIAL
INVESTIGATION REPORT.
THE NO-ACTION ALTERNATIVE IS A NONACCEPTABLE SOLUTION TO THE PROBLEM AT THE ACW SITE. EVEN IF
THE 317 DRUMS OF DRILLING WASTE ARE REMOVED, THE CONTAMINATED SOURCE REMAINS IN THE ENVIRONMENT
WITHOUT MITIGATION. UNDER THE NO-ACTION ALTERNATIVE, CONTAMINATES WOULD CONTINUE TO MIGRATE
OFFSITE AND AFFECT THE QUALITY OF THE GROUNDWATER. THE NO-ACTION ALTERNATIVE WOULD NOT BE
ACCEPTABLE IN MEETING THE OBJECTIVES OF MITIGATING OR MINIMIZING THE THREAT TO PUBLIC HEALTH,
WELFARE AND THE ENVIRONMENT.
THOSE REMEDIAL ALTERNATIVES THAT SUGGEST OFFSITE DISPOSAL OF BOTH THE HIGHLY AND LESSER
CONTAMINATED SOIL DO NOT MEET THE CRITERIA FOR COST-EFFECTIVENESS. GENERALLY, THE COST RELATED
FOR TRANSPORTING ALL OR PART OF THE HAZARDOUS MATERIALS TO AN APPROVED HAZARDOUS WASTE
MANAGEMENT FACILITY IS COST-PROHIBITIVE. THIS ELIMINATES REMEDIAL ALTERNATIVE NUMBERS 1,3,5 AND
7 FROM FURTHER CONSIDERATION BECAUSE OF THE EXCESSIVE COST WITHOUT ANY GREATER PROTECTION TO
HUMAN HEALTH OR THE ENVIRONMENT.
REMEDIAL ALTERNATIVES 6 AND 8 ARE ELIMINATED FROM FURTHER CONSIDERATION BECAUSE THESE REMEDIAL
ALTERNATIVES ADDRESS GROUNDWATER AND THE GROUNDWATER ISSUE HAS BEEN DEFERRED UNTIL MORE
GROUNDWATER DATA CAN BE GATHERED. THE REMAINING REMEDIAL ALTERNATIVES (2 AND 4) SUGGEST EITHER
EXCAVATION OF BOTH THE HIGHLY AND LESSER CONTAMINATED SOILS OR EXCAVATION OF ONLY THE HIGHLY
CONTAMINATED SOILS FOR DISPOSAL ON THE ACW PROPERTY. BASED ON THE QUANTITATIVE RISK ASSESSMENT
PRESENTED IN THE FEASIBILITY STUDY REPORT, EITHER EXCAVATION REMEDIAL ALTERNATIVE WILL MEET THE
CRITERIA FOR PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT. TABLE 10 PRESENTS THE LIFE-TIME
MAXIMUM RISK ESTIMATIONS FOR THE CONTAMINATION IDENTIFIED ON THE SITE. THE ESTIMATIONS ARE
BASED ON A VARIETY OF "WORST POSSIBLE CASE" ASSUMPTIONS, ALL OCCURRING AT THE SAME TIME. EACH
OF THE ASSUMPTIONS USED IN THE RISK CALCULATIONS ARE ALSO PRESENTED IN TABLE 10. IN REALITY,
THE TRUE CARCINOGENIC RISK WILL BE ESSENTIALLY ZERO BECAUSE A FOOT OF CLEAN SOIL WILL BE
BACKFILLED AFTER THE EXCAVATION OF THE CONTAMINATED SOILS, THEREBY ELIMINATING ALL LIKELY
EXPOSURE. A HEALTH AND SAFETY PLAN SHOULD BE DEVELOPED FOR ANY CONSTRUCTION ACTIVITIES IN THE
AREA TO INSURE PROPER MAINTENANCE OF THE ONE FOOT OF CLEAN FILL.
IT IS EPA'S POSITION THAT ALL CONTAMINATED SOILS BE EXCAVATED AND DISPOSED ON THE ACW PROPERTY
AS A SOURCE CONTROL MEASURE IN A LANDFILL THAT MEETS RCRA STANDARDS. TO ACHIEVE THIS WILL
REQUIRE IMPLEMENTATION OF REMEDIAL ALTERNATIVE NUMBER 2. REMEDIAL ALTERNATIVE NUMBER 2 MEETS
THE CRITERIA FOR PROTECTION OF HUMAN HEALTH, PROTECTION OF THE ENVIRONMENT AND
COST-EFFECTIVENESS. TABLE 11 LISTS THE AREA TO BE EXCAVATED AND THE VOLUMES FOR DISPOSAL AND
FIGURE 5 ILLUSTRATES THE LOCATIONS TO BE ADDRESSED DURING THE IMPLEMENTATION OF ALTERNATIVE
NUMBER 2.
THE DESIGN WILL INCLUDE EXCAVATION OF THE:
1)
HIGHLY CONTAMINATED SOILS ONSITE,
- EXISTING POND AREAS
- OLD PROCESS AREAS
2)
HIGHLY CONTAMINATED SOILS OFFSITE,
- DRAINAGE DITCH AREA ON THE YACHT CLUB
- A SECTION OF CITY BLOCK NUMBER 184
3)
LESSER CONTAMINATED SOILS ONSITE,
- OLD POLE STORAGE AREAS
- CLEANING AND GRUBBING OF THE SITE
- CONTENTS OF THE 317 DRUMS OF DRILLING WASTE
4)
LESSER CONTAMINATED SOILS OFFSITE
- CITY BLOCK NUMBER 179 THROUGH 183 AND BLOCK NUMBER 162
- YACHT CLUB PROPERTY AT THE CORNER OF CYPRESS AND 'K' STREET.
FIGURE 6 ILLUSTRATES CROSS-SECTION OF THE LANDFILL, WHILE FIGURE 7 DEPICTS AN AERIAL VIEW OF THE
LANDFILL.
#OEL
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
ALTERNATIVE 2 WILL RESULT IN A DISPOSAL SITE BEING CONSTRUCTED ON THE ACW PROPERTY TO RCRA
DESIGN STANDARDS. WHILE SOME CONTAMINATED SOILS WILL REMAIN, THE POTENTIAL FOR ANY HEALTH RISK
ARE WELL BELOW THE ESTABLISHED ACUTE TOXICITY OR THE PROBABILITY OF INJURY FROM SHORT-TERM
EXPOSURE DUE TO THE RELATIVELY LOW OBSERVED CONCENTRATION FOR THE CRITICAL CONTAMINANTS. THE
SELECTED ALTERNATIVE WILL NOT EFFECT ANY FLOODPLAINS AND THE WETLANDS AREA. WE DO NOT
ANTICIPATE ANY CONFLICT WITH OTHER ENVIRONMENTAL LAWS. TABLE 8 SUMMARIZES THE EVALUATION OF
ALTERNATIVES WITH RESPECT TO OTHER ENVIRONMENTAL CONCERNS. REMEDIATION FOR THE GROUNDWATER IS
BEING DEFERRED UNTIL MORE INFORMATION IS GATHERED.
#OM
OPERATION AND MAINTENANCE (O&M)
A POST-CLOSURE AND MONITORING PLAN IS REQUIRED UNDER RCRA. THE PLAN PROVIDES FOR THE
PROCEDURES, FREQUENCIES AND TECHNICAL CONSIDERATIONS OF SUCH ACTIVITIES NECESSARY TO PRESERVE
THE INTEGRITY OF A CAPPED DISPOSAL FACILITY. THE ESTIMATED ANNUAL COST ASSOCIATED WITH
OPERATION AND MAINTENANCE ARE PRESENTED IN TABLE 12, ALTERNATIVE NUMBER 2. OPERATION AND
MAINTENANCE COST ARE AVAILABLE FOR FUND MONIES FOR A PERIOD OF ONE YEAR AND THE O&M COST
FOLLOWING ONE YEAR ARE A RESPONSIBILITY OF THE STATE.
#SCH
SCHEDULE
THE CORPS OF ENGINEERS WILL ADVERTISE FOR FIRMS TO CONDUCT THE REMEDIAL DESIGN. REVIEW AND
SELECTION OF A CONTRACTOR IS SCHEDULED FOR MARCH 1986 WITH REMEDIAL DESIGN COMPLETED BY JUNE
1987. CONSTRUCTION SHOULD PROCEED IMMEDIATELY THEREAFTER AND SHOULD BE COMPLETED BY JULY 1988.
#FA
FUTURE ACTIONS
AT A LATER DATE OPERABLE UNIT II WILL BE REQUIRED WHICH WILL CONSTITUTE THE AGENCY'S OFFICIAL
SELECTION OF AN ALTERNATIVE FOR THE MANAGEMENT OF MIGRATION OF CONTAMINANTS IN THE GROUNDWATER
AT THIS SITE. OPERABLE UNITS 1 AND 2 WILL THEN FORM THE BASIS FOR THE ENTIRE SITE'S REMEDIAL
DESIGN.
#TMA
TABLES, MEMORANDA, ATTACHMENTS
#RS
RESPONSIVENESS SUMMARY FOR THE
AMERICAN CREOSOTE WORKS, INC. NPL SITE
PENSACOLA, FLORIDA
BASED ON COMMENTS FROM THE
PUBLIC MEETING OF
AUGUST 15, 1985
TOPIC:
HEALTH CONSIDERATIONS
ISSUE:
WHO IS THE CHEMIST HERE? WHAT IS YOUR DEFINITION OF AN AROMATIC HYDROCARBON?
THAT A CREOSOTE OR A PHENOL?
DISCUSSION:
THAT IS ESSENTIALLY ASSOCIATED WITH CREOSOTE.
ISSUE:
PEOPLE HAVE LIVED NEAR THE SITE, WORKED THERE, AND PLAYED NEAR THERE. NO CASE
STUDIES (HEALTH PROBLEMS) HAVE BEEN FOUND AND NOW YOU'RE TELLING ME THAT THE
CONTAMINANTS ARE GOING TO KILL ME. I'M ASKING YOU, IS IT THE PHENOL OR THE
CREOSOTE?
DISCUSSION:
ARE YOU ASKING WHICH ONE IS MORE TOXIC?
ISSUE:
PENTACHLOROPHENOL IS THE MORE DANGEROUS OF THE TWO SUBSTANCES, ISN'T IT?
DISCUSSION:
I BELIEVE SO, YES.
ISSUE:
WHAT IS AN AROMATIC HYDROCARBON?
DISCUSSION:
THE POLYNUCLEAR AROMATIC HYDROCARBONS WE ARE TALKING ABOUT ARE THE MAJOR COMPONENTS
OF CREOSOTE. THE CHEMICAL CONTAMINANTS ASSOCIATED WITH CREOSOTE ARE POLYNUCLEAR
AROMATIC HYDROCARBONS. SOME EXAMPLES OF POLYNUCLEAR AROMATIC HYDROCARBONS
INCLUDE NAPHTHALENE, ANTHRACENE, AND FLUORANTHENE, JUST TO NAME A FEW.
ISSUE:
THESE ARE COMPONENTS OF CREOSOTE?
DISCUSSION:
YES, THESE ARE COMPONENTS OF CREOSOTE. THE PENTACHLOROPHENOL IS AN ACID-FRACTION
AND IS NOT PART OF CREOSOTE. AS I UNDERSTAND THE HISTORY OF THE SITE, MOST OF THE
PROCESSES INVOLVED CREOSOTE AT THIS PLANT. AFTER 1951, THEY ALSO STARTED USING
PENTACHLOROPHENOL AS A WOOD-TREATING CHEMICAL.
ISSUE:
HOW MANY PEOPLE HAVE DIED FROM THESE HAZARDOUS WASTES? HOW MANY CASE STUDIES
(HEALTH PROBLEMS) HAVE BEEN DOCUMENTED? THERE'S NO EVIDENCE OF CANCER, AND IF THERE
IS, I WANT TO KNOW ABOUT IT BECAUSE I GREW UP THERE. I PLAYED ON THAT PROPERTY.
YOU SPENT $15,000 FOR A CLAY CAP -- ONE THAT IS POORLY PACKED -- AND THERE ISN'T A
PROBLEM. I DON'T THINK THAT'S SAVING MONEY; THAT'S A WASTE.
DISCUSSION:
JUST BECAUSE NO PEOPLE HAVE DIED DOES NOT MEAN THAT THERE IS NOT A PROBLEM. WE
ADOPT A "CHICKEN LITTLE" SYNDROME AT THESE SITES; THAT IS, WE TREAT THEM AS IF
THERE IS A PROBLEM AND REMEDIATE THEM BEFORE A BIGGER PROBLEM OCCURS.
IS
THAT'S THE POSITION WE'VE TAKEN SO FAR.
ISSUE:
ARE HEALTH DEPARTMENT REPRESENTATIVES HERE TONIGHT?
DISCUSSION:
THEY ARE NOT HERE.
TOPIC:
REMEDIAL TECHNOLOGIES
ISSUE:
THERE ARE BASIC CHEMICAL PROCESSES THAT WERE USED AT THE PLANT. CREOSOTE IS BEING
DESTROYED BY BACTERIA IN THE GROUND AND HAS BEEN FOR OVER THE LAST 80 YEARS. IS THE
BACTERIA IN THE SOIL DESTROYING THE PENTACHLOROPHENOL? I UNDERSTAND THERE IS ONE
KIND THAT IS DESTROYING THE CREOSOTE.
DISCUSSION:
WE DON'T KNOW OF ONE. IF THERE IS ANY PROCESS WITH BACTERIA THAT IS BIODEGRADING
THE CREOSOTE, IT IS NOT EVIDENT FROM THE DATA WE HAVE COLLECTED.
ISSUE:
I READ THIS IN THE (PENSACOLA) NEWS JOURNAL.
DISCUSSION:
I'M NOT AWARE OF THAT. I THINK YOU'RE TALKING ABOUT THE PROCESS OF BIODEGRADATION
OF THIS PARTICULAR COMPOUND. THERE IS SOME INDICATION THAT AEROBIC BACTERIA, THAT
IS, BACTERIA WHICH NEED AIR IN ORDER TO LIVE AND WORK ON THE CONTAMINANTS -- WILL
BIODEGRADE CERTAIN COAL-TAR DERIVATIVES, SUCH AS POLYNUCLEAR AROMATIC HYDROCARBONS.
HOWEVER, WHEN YOU GET AWAY FROM AIR AND START GOING DOWN INTO THE GROUND, YOU GET
INTO ANAEROBIC CONDITIONS. THERE HAVE BEEN NO DEMONSTRATIONS THAT I KNOW OF THAT
ANAEROBIC BACTERIA WILL WORK ON THESE PARTICULAR CONTAMINANTS UNDER THE GROUND.
ISSUE:
THERE IS A NEWS RELEASE SAYING THAT THERE'S A NEW TECHNIQUE OF PUMPING OXYGEN INTO
THE GROUND FOR THESE BACTERIA.
DISCUSSION:
WE ARE AWARE THAT THERE ARE SOME NEW TECHNOLOGIES ON THE LEADING EDGE THAT COULD
POSSIBLY BE USED. HOWEVER, NONE HAVE BEEN PROVEN TO DATE.
ISSUE:
IF THIS AEROBIC BACTERIA DESTROYS THIS MATERIAL, WHY NOT TILL UP THE GROUND AND
BRING IT TO THE SURFACE AND LET THE BACTERIA DESTROY IT? OR, WHY DON'T YOU
INTRODUCE MORE BACTERIA THAT WOULD WORK ON THE POLYNUCLEAR AROMATIC HYDROCARBONS?
DISCUSSION:
WE HAVE LOOKED AT THIS TECHNOLOGY. THE REASON WE SCREENED OUT THIS TECHNOLOGY IS
AGAIN THE SAME REASON WE SCREENED OUT INCINERATION, I.E., WE HAVE POCKETS OF
CONTAMINATION MIXED IN WITH EARTH AND SOIL AND FLY ASH AND LIME. AND EVEN IF YOU
BRING IT UP TO THE SURFACE AND MIX THIS STUFF, YOU ARE GOING TO HAVE PARTIAL
TREATMENT OF THESE CONTAMINANTS. IF YOU HAD HOMOGENEOUS WASTES AND IF IT WERE
LOCALIZED, BIODEGRADATION COULD VERY WELL WORK. BUT WE WOULD HAVE TO REALLY
ISOLATE THE WASTES FROM THE SOIL ITSELF IN ORDER FOR US TO AEROBICALLY TREAT THIS
STUFF. WE FELT THAT THE TECHNOLOGIES CURRENTLY ON THE MARKET ARE NOT PROVEN FOR
THIS PARTICULAR SITE IN ITS PRESENT CONDITION. THERE HAVE BEEN SOME ATTEMPTS IN
OTHER AREAS TO USE BIODEGRADATION ON SITES OF THIS NATURE THAT ARE CONTAMINATED
WITH CREOSOTE. PART OF THE PROBLEM WITH BIODEGRADATION IS THAT YOU HAVE MANY
FACTORS TO MANAGE THAT COULD INFLUENCE THE WAY THE BUGS ARE GOING TO ATTACK THE
MATERIAL. THE WEATHER, THE AMOUNT OF RAINFALL, TEMPERATURE -- THESE ALL HAVE TO BE
CONTROLLED VERY CAREFULLY IN ORDER FOR THIS TO WORK. BIODEGRADATION IS NOT WHAT WE
CONSIDER TO BE A PROVEN TECHNOLOGY.
ISSUE:
HAVE YOU THOUGHT OF DEEP WELL DISPOSAL, PUMPING THE STUFF UNDERGROUND?
DISCUSSION:
THAT COMPOUNDS THE PROBLEM SOMEWHAT, BECAUSE, AS YOU CAN WELL UNDERSTAND, IT IS
VERY DIFFICULT TO FATHOM OR DELINEATE WHAT HAPPENS TO A WASTE STREAM WHEN YOU PUMP
HOWEVER, THEY WERE INVITED.
IT UNDERGROUND UNDER PRESSURE. WE HAVE MANY HORROR SHOWS IN THE REGIONS WHERE
PERMITTED INJECTION WELLS HAVE CONTAMINATED LOCAL WATER SUPPLIES BECAUSE OF
IMPROPER INSTALLATION OF THE WELL OR BECAUSE OF THE INABILITY TO DETERMINE WHAT THE
SUBSTANCE IS LIKE, WHICH MIGHT HAVE PREVENTED IT FROM GETTING INTO THE WATER
SUPPLY. I THINK WE WOULD BE COMPOUNDING OUR PROBLEM.
ISSUE:
I WANT TO KNOW WHY YOU DISMISSED INCINERATION AS AN ALTERNATIVE WHEN YOUR OTHER
REGIONS ARE PROMOTING IT AS A METHOD OF DESTROYING DIOXIN.
DISCUSSION:
WE ARE BASICALLY LOOKING AT MATERIALS THAT ARE INERT. WE'RE LOOKING AT MATERIALS
THAT HAVE A LOW BTU CONTENT. WHEN THE IMMEDIATE REMOVAL OCCURRED IN THE POND AREA,
THEY MIXED THE SLUDGE WITH FLY ASH AND LIME, WHICH ARE ESSENTIALLY INERT MATERIALS.
THE COSTS FOR BOTH ONSITE AND OFFSITE INCINERATION ARE THEREFORE CONSIDERABLY
HIGHER THAN SOME OF THE OTHER ALTERNATIVES WE ARE LOOKING AT. OFFSITE INCINERATION
COSTS WOULD BE MORE THAN THE TOTAL COST OF THE OFFSITE DISPOSAL ALTERNATIVE THAT WE
ARE DISCUSSING. ALSO, WE EVALUATED CAPACITIES OF EXISTING PERMITTED INCINERATORS.
IT WILL TAKE 7 TO 10 YEARS TO BURN THIS MATERIAL, AND IF YOU USE AN OFFSITE
FACILITY, YOU MUST STORE THIS MATERIAL SOMEPLACE IN ANY CASE. WITH ONSITE
FACILITIES THERE WOULD BE AN INCINERATOR IN THE MIDDLE OF DOWNTOWN PENSACOLA,
SURROUNDED BY A RESIDENTIAL AREA. IT WOULD HAVE TO MEET AIR POLLUTION STANDARDS.
THERE WOULD ALSO BE RESIDUES LEFT OVER AFTER INCINERATION SINCE WE WOULD BE BURNING
A LOT OF INERT MATERIAL. WE WOULD HAVE TO DISPOSE OF THE ASH AFTER WE BURN THE
WASTES. SINCE THERE IS A LOT OF INERT MATERIAL, THE HIGH COSTS INVOLVED, WHICH ARE
5 TO 10 TIMES GREATER THAN SOME OF THE OTHER ALTERNATIVES PROPOSED, WERE THE MAIN
REASONS WHY WE SCREENED OUT INCINERATION AS A VIABLE ALTERNATIVE.
ISSUE:
WERE YOU COMPARING THIS TO THE DIOXIN INCINERATION IN MISSOURI, AT THE VERONA SITE?
DISCUSSION:
I DON'T KNOW WHAT QUANTITIES WERE INVOLVED AT THAT SITE. I'M NOT FAMILIAR WITH THAT
SITE.
ISSUE:
WHAT ABOUT PUTTING THE CONTAMINATED MATERIAL UNDER CONCRETE OR ASPHALT WITH A
SHOPPING CENTER OVER IT?
DISCUSSION:
THERE ARE MANY MATERIALS THAT ARE EVALUATED AS MATERIALS FOR LINERS, WHICH ARE
DESIGNED TO CONTAIN WASTES OF ONE KIND OR ANOTHER. WE HAVE FOUND THAT WHEN IT
COMES TO CONTAINING ORGANIC WASTES, ORGANIC MATERIALS CANNOT CONTACT THE LINER.
FOR EXAMPLE, ASPHALT WOULD BE OUT BECAUSE CREOSOTE WOULD GO RIGHT THROUGH IT.
TOPIC:
ADMINISTRATIVE ISSUES
ISSUE:
WHAT IS THE PURPOSE OF THIS MEETING?
WHERE DO YOU SEE THIS GOING?
DISCUSSION:
THE PURPOSE OF THIS MEETING IS TO INFORM THE PUBLIC OF THE FINDINGS OF THE
FEASIBILITY STUDY AND TO OBTAIN INPUT FROM YOU, THE CITIZENS, CONCERNING THE
RECOMMENDED ALTERNATIVES. THE PUBLIC COMMENT PERIOD CLOSES IN 3 WEEKS, AND YOU MAY
SEND YOUR LETTERS TO ME OR TO BEVERLY MOSELY. OUR ADDRESSES ARE LISTED IN THE FACT
SHEET. WE WILL USE YOUR COMMENTS IN GUIDING US IN OUR DECISION. ONCE AN
ALTERNATIVE HAS BEEN CHOSEN, A RECORD OF DECISION WILL BE WRITTEN. THE NEXT STEP
IS DESIGN AND CONSTRUCTION OF THE ALTERNATIVE.
ISSUE:
WHICH ALTERNATIVE HAVE YOU DECIDED ON?
WE'VE IDENTIFIED THE PROBLEM.
WHAT IS NEXT?
DISCUSSION:
NO SELECTION HAS YET BEEN MADE. WE WILL SELECT THE ALTERNATIVE AFTER THE PUBLIC
COMMENT PERIOD AND AFTER WE CONSULT WITH THE DER. THE ALTERNATIVE WE SELECT WILL
BE COST-EFFECTIVE AND TECHNICALLY SOUND.
ISSUE:
YOU DO NOT HAVE A RECOMMENDATION AT THIS PARTICULAR STAGE THAT YOU THINK IS THE
BEST ONE?
DISCUSSION:
AT THIS TIME, WE ARE LEANING TOWARDS PARTIAL EXCAVATION WITH ONSITE DISPOSAL AND
GROUNDWATER MONITORING.
ISSUE:
ARE YOU ASKING WHAT WE THINK SHOULD BE DONE? AS A HOMEOWNER, I WOULD LIKE TO SEE
ALTERNATIVE NO. 9 IMPLEMENTED (NO ACTION WITH GROUNDWATER PLUME MONITORING
AND ASSESSMENT).
DISCUSSION:
THANK YOU.
ISSUE:
THE FACT SHEET INDICATES THAT THESE REPORTS ARE AVAILABLE AT THE LIBRARIES LISTED.
ARE ALL REPORTS AVAILABLE FOR PUBLIC REVIEW AT THESE LIBRARIES?
DISCUSSION:
YES. THE REMEDIAL ACTION MASTER PLAN (RAMP), THE DRAFT REMEDIAL INVESTIGATION
REPORT (RI), AND THE DRAFT FEASIBILITY STUDY REPORT (FS) ARE AT THE REPOSITORIES.
THE COMMUNITY RELATIONS PLAN IS ALSO AVAILABLE AT THOSE LOCATIONS.
ISSUE:
WHAT IS YOUR PROPOSAL CONCERNING THE RAILROAD?
PROPERTY ADJACENT TO MY PROPERTY.
DISCUSSION:
WE ARE PROPOSING, ONLY FOR THOSE ALTERNATIVES CONTAINING TOTAL EXCAVATION, TO
REMOVE THE FOLLOWING: 360 FEET OF THE MAIN LINE IN ORDER TO EXCAVATE CONTAMINATED
SOILS (THE LINE WILL THEN BE REPLACED); ABOUT 6500 LINEAR FEET OF TRACKS ON THE ACW
PROPERTY AND ANY OTHER SITE ACTIVITIES; AND 2500 FEET OF TRACK ON PINE STREET SOUTH
OF THE SITE FOR INSTALLATION OF THE STORM WATER COLLECTION SYSTEM.
ISSUE:
BASED ON COMMENTS I'VE HEARD SO FAR, AND AS A TAXPAYER AND AN ENVIRONMENTALIST, I
WOULD LIKE YOU TO GO FOR THE ENTIRE WORKS. I THINK ONSITE DISPOSAL IS NOT GOING TO
REMEDY THE SITUATION, BECAUSE YOU WILL STILL HAVE A BLOCK OF LAND WITH CONTAMINATED
SEDIMENTS. THE YACHT CLUB HAS PLANS FOR THE REDEVELOPMENT OF THE AREA AND WE COULD
PARTIALLY RECOVER AND USE THE LAND. REDEVELOPMENT OF THAT LAND AFTER IT HAS BEEN
TOTALLY CLEANED IS MUCH BETTER. SUPERFUND IS A TAX, RIGHT? DOESN'T IT (THE MONEY)
COME FROM A TAX ON THE CHEMICAL COMPANIES?
DISCUSSION:
THE FUTURE USE OF THE LAND AT AND SURROUNDING THE AMERICAN CREOSOTE SITE WILL HAVE
TO BE COMPATIBLE WITH THE REMEDY SELECTED AS WELL AS ALL OTHER LOCAL AND STATE
INSTITUTIONAL RESTRICTIONS. SUPERFUND CLEANUPS ARE FINANCED BY A TRUST FUND WHICH
WILL GROW TO $1.6 BILLION OVER A FIVE-YEAR PERIOD. THE FUND CAN BE USED TO PROVIDE
BOTH EMERGENCY AND LONG-TERM CLEANUP OF RELEASES OF HAZARDOUS SUBSTANCES AND
INACTIVE WASTE SITES. IT IS COLLECTED THROUGH TAXES PAID BY MANUFACTURERS,
PRODUCERS AND EXPORTERS AND IMPORTERS OF OIL AND 42 CHEMICAL SUBSTANCES.
ISSUE:
IN THE TOTAL EXCAVATION ALTERNATIVE, WHAT PROVISIONS ARE MADE FOR THE HOMEOWNERS?
DO YOU PUT US UP IN OTHER HOUSES OR WHAT?
DISCUSSION:
IT IS NOT EPA'S POLICY TO RELOCATE PEOPLE.
ISSUE:
ARE THE PEOPLE COMPENSATED OR DO THE PEOPLE JUST GET A NEW YARD IN RETURN?
I BOUGHT ALL OF THE RAILROAD
DISCUSSION:
THERE ARE NO PROVISIONS FOR COMPENSATION; HOWEVER, THE PROPERTY WOULD BE RESTORED
TO ITS ORIGINAL CONDITION AFTER EXCAVATION WORK IS COMPLETED.
ISSUE:
DID YOU CHECK OUT ASHLEY FOR ITS PENTACHLOROPHENOL? THEY WERE TREATING WOOD WITH
PENTACHLOROPHENOL BEFORE AMERICAN CREOSOTE KNEW WHAT PENTACHLOROPHENOL WAS.
DISCUSSION:
I'M NOT FAMILIAR WITH THAT SITE.
ISSUE:
BACK IN 1981, WHEN YOU FIRST DISCOVERED THIS PROBLEM, WHY WEREN'T THE ADJACENT
PROPERTY OWNERS NOTIFIED OF THIS PROBLEM? WOULDN'T IT HAVE BEEN PROPER TO NOTIFY
THE PEOPLE OF THE PROBLEM?
DISCUSSION:
THAT WAS THE FIRST TIME THE SITE WAS DISCOVERED. THERE WAS NOT ENOUGH DATA TO
ASSESS THE NATURE AND EXTENT OF THE CONTAMINATION AND ITS POTENTIAL IMPACT ON HUMAN
HEALTH OR THE ENVIRONMENT.
ISSUE:
I HAVE A GROUND WELL THAT IS CONTAMINATED.
DISCUSSION:
AT THIS POINT, WE DO NOT HAVE PLANS FOR THAT.
ISSUE:
HOW SOON DO YOU ANTICIPATE THE MOST RAPID ACTION?
SITE?
DISCUSSION:
I WOULD SAY NEXT SUMMER WOULD BE THE EARLIEST. BUT THAT HINGES ON THE FACT THAT
MONEY IS AVAILABLE. CONGRESS HAS NOT YET REAUTHORIZED THE SUPERFUND BILL.
ISSUE:
AS FAR AS YOU HAULING THE STUFF AWAY IN TRUCKS -- TO ANOTHER LANDFILL OR WHATEVER
-- WHO IS GOING TO KEEP TRACK OF THE TRUCKS AND ASSUME RESPONSIBILITY FOR THEM?
THE STATE? EPA? WHO IS GOING TO CLEAN UP THIS HAZARDOUS WASTE IF THESE TRUCKS
JACKKNIFE OR BREAK DOWN?
DISCUSSION:
YOU'RE SAYING THAT YOU DON'T WANT IT TRUCKED AWAY?
ISSUE:
I'M SAYING, "KEEP THAT SNAKE IN THE BOX". I DON'T WANT IT ON THE HIGHWAYS. WHY
MOVE IT 300 MILES TO ALABAMA? FLORIDA OUGHT TO TAKE CARE OF ITS OWN PROBLEMS.
DISCUSSION:
THE PROBLEM HERE IN FLORIDA IS THAT THE GROUNDWATER TABLE IS VERY CLOSE TO THE
SURFACE. IT'S ONLY ABOUT 3 FEET UNDERGROUND. THEREFORE, LAND BURIAL OF HAZARDOUS
WASTE IN FLORIDA IS NOT FEASIBLE, AS IT WOULD BE BURIED RIGHT NEXT TO OUR
GROUNDWATER. THERE ARE MANY DEMONSTRATION PROJECTS GOING ON FOR NEW ALTERNATIVE
WAYS OF TREATING WASTES. WE'RE HOPEFUL THAT SOME OF THEM WILL PAN OUT AND WILL BE
APPLICABLE. THE POTENTIAL IN THIS PROGRAM IS THAT DOWN THE ROAD, IF THERE IS A
REALLY UNIQUE ALTERNATIVE THAT COMES TO LIGHT THAT MAY BE USEFUL IN TREATING A
PARTICULAR WASTE, THEN WE COULD USE IT. UNTIL SUCH A TREATMENT COMES ALONG WE HAVE
TO ACT ON WHAT WE HAVE RIGHT NOW IN THE WAY OF ACCEPTABLE, PROVEN TECHNOLOGIES.
ISSUE:
WHAT ABOUT STORING IT OVER ON SOME OF EGLIN'S PROPERTY? THAT'S FEDERAL GOVERNMENT
PROPERTY, AND IT WOULD SEEM THAT THEY COULD SPARE A FEW INCHES OVER THERE ON THAT
BOMB RANGE.
DISCUSSION:
I THINK EGLIN MIGHT HAVE THEIR OWN HAZARDOUS WASTE PROBLEMS. THE DEPARTMENT OF
DEFENSE HAS SOME SITES ON OUR LIST, AND I'M NOT SURE THAT THEY WOULD BE RECEPTIVE
TO THAT IDEA.
WILL I BE REIMBURSED FOR IT?
HOW SOON CAN YOU CLEAN UP THE
ISSUE:
DID YOU COST OUT INCINERATION AND BIODEGRADATION IN YOUR REPORT?
DISCUSSION:
WE DID NOT COST EVERY TECHNOLOGY UNDER THE BOOK. IF WE DID THAT, THIS REPORT WOULD
COST A LOT MORE THAN IT DID. BUT WE LOOKED AT EVERY SINGLE TECHNOLOGY BEFORE WE
BEGAN THE SCREENING PROCESS AND EXPLAINED WHY WE SCREENED THOSE TECHNOLOGIES OUT,
WHETHER IT WAS BECAUSE OF SITE CHARACTERISTICS, WASTE CHARACTERISTICS, OR EXCESSIVE
COSTS AS COMPARED TO OTHER ACCEPTABLE, PROVEN TECHNOLOGIES. IN THIS PARTICULAR
AREA OF HAZARDOUS WASTE CLEANUP, WE ARE LOOKING AT PROVEN TRACK RECORDS ON
TECHNOLOGIES. THERE ARE A LOT OF CLEANUP METHODS CURRENTLY ON THE MARKET. IF YOU
USE ONE OF THEM, AND IT DOESN'T WORK, THEN YOU HAVE TO GO BACK AND REINVENT THE
WHEEL, SO TO SPEAK.
ISSUE:
IS THERE GOING TO BE MONEY LEFT OVER FROM SUPERFUND TO CLEAN UP THIS SITE?
DISCUSSION:
I THINK SUPERFUND WILL BE HERE FOR A WHILE. JUDGING BY THE NUMBER OF SITES WE TURN
UP ANNUALLY, IT (THE PROBLEM) IS GROWING AND THERE WILL BE A NEED FOR THE SUPERFUND
TO BE AROUND.
ISSUE:
THE WAY IT WAS EXPLAINED TO ME WAS THAT WHEN CONGRESS REVISED RCRA AND MADE THESE
REGULATIONS ON HAZARDOUS WASTE, THEY INTENDED IT TO BE OVERSIGHT. THE INTENT OF
CONGRESS IS NOT TO EVEN HAVE THESE WASTES AND TO FIND ALTERNATIVES SUCH AS
INCINERATION. IF YOU HAVE LIABILITIES AND TAKE THE MATERIAL TO EMILLE, AND IF THEY
TAKE IT FROM YOU, THAN AS A PRIVATE COMPANY THEY ARE LIABLE IF THE STUFF LEAKS OUT
OF THEIR LANDFILL. WOULD YOU HAVE TO CLEAN UP EMILLE IF YOU DISPOSE OF THE
MATERIAL THERE?
DISCUSSION:
EMILLE HAS ABOUT A 600-FOOT CLAY LAYER AND IT WILL TAKE 5800 YEARS OR SO FOR THE
MATERIAL TO MIGRATE, IF IT DOES. THEY ARE BUILDING THE CELLS A LOT SMALLER AND ARE
ALSO BEING EXTRA CAREFUL, UTILIZING SAMPLING TO A LARGE EXTENT IN ORDER TO VERIFY
WHAT IS GOING INTO THE LANDFILL. THE OVERALL GOAL OF THE HAZARDOUS WASTE
MANAGEMENT PROGRAM IS TO GET OUT OF THE LANDFILL BUSINESS EVENTUALLY AND GET MORE
INTO REDUCING THE AMOUNT OF HAZARDOUS WASTE WE PRODUCE AND ALSO MOVE INTO THE
RECYCLING AND RESOURCE RECOVERY ASPECTS OF HAZARDOUS WASTE.
ISSUE:
WHERE DOES THE LOCAL GOVERNMENT FIT IN WHEN WE GET FURTHER INTO THE PROCESS WITH
THESE ALTERNATIVES? I'M WITH THE CITY OF PENSACOLA. YOU WERE TALKING ABOUT LOCAL
PERMITTING AT ONE POINT.
DISCUSSION:
THAT'S CORRECT. BEFORE WE DO ANYTHING, WE WOULD FIRST HAVE TO TAKE INTO
CONSIDERATION ALL OF THE REQUIREMENTS, WHETHER THEY ARE LOCAL, STATE, OR FEDERAL,
INCLUDING ENVIRONMENTAL OR ENGINEERING PERMITS. THE CITY HAS BEEN CONTACTED DURING
THE TIME OF THIS STUDY. THE CITY ENGINEER'S OFFICE WAS CONTACTED IN ORDER TO
DETERMINE THINGS SUCH AS WHETHER EXISTING SEWER LINES WOULD BE ADEQUATE TO CONVEY
THE TREATED GROUNDWATER TO THE SEWAGE TREATMENT PLANT OR WHETHER EXISTING STORM
SEWERS ARE ADEQUATE. THE CITY AND THE COUNTY HAVE BEEN INVOLVED ONE WAY OR
ANOTHER. WE ALSO INVOLVED THE ESCAMBIA COUNTY UTILITIES AUTHORITY BECAUSE WE
WERE TALKING ABOUT DISCHARGING GROUNDWATER INTO THEIR SYSTEM. ANY AFFECTED PARTIES
HAVE BEEN KEPT ABREAST OF OUR ACTIVITIES.
TOPIC:
LAND REDEVELOPMENT
ISSUE:
UNDER ANY OF THE ALTERNATIVES CONSIDERED, WHAT POTENTIAL IS THERE FOR FUTURE
DEVELOPMENT IN THE AREA? THE YACHT CLUB IS CONSIDERING BUILDING BOAT SLIPS. WOULD
ANY OF THE ALTERNATIVES PERMIT FUTURE DEVELOPMENT OR WOULD THEY PRECLUDE THIS?
DISCUSSION:
FUTURE DEVELOPMENT WOULD DEPEND ON THE ALTERNATIVE SELECTED AND ALSO UPON LOCAL
PERMITTING REQUIREMENTS, INCLUDING COMPLIANCE WITH LOCAL ORDINANCES.
ISSUE:
WOULD TOTAL EXCAVATION WITH OFFSITE DISPOSAL PERMIT MORE DEVELOPMENT IN THE AREA?
DISCUSSION:
YES.
ISSUE:
IS IT CORRECT THAT THE LAND SURROUNDING THE DISPOSAL AREA COULD NOT BE DEVELOPED AS
SUCH AS IT COULD IF THERE WERE NOT ONSITE DISPOSAL?
DISCUSSION:
THAT IS ALSO TRUE. THE ONSITE LANDFILL WOULD ESSENTIALLY ISOLATE THAT PARTICULAR
AREA FROM ANY DEVELOPMENT. THE AREA AROUND THE SITE PROPERTY COULD BE DEVELOPED
REGARDLESS OF ONSITE OR OFFSITE DISPOSAL.
ISSUE:
IF THE ONSITE DISPOSAL ALTERNATIVE IS SELECTED AND THE LAND IS RECOVERED AND
REVEGETATED, WOULD YOU BE ABLE TO USE THE AREA AS A PARK OR RECREATIONAL AREA?
DISCUSSION:
AS LONG AS THE USE IS CONSISTENT WITH THE ALTERNATIVE SELECTED IN THE REMEDIAL
ACTION THAT'S TAKEN, THERE IS PROBABLY NO REASON WHY IT COULDN'T BE USED FOR
WHATEVER THE LOCAL PERMITS WOULD ALLOW FOR THE AREA.
TOPIC:
TECHNOLOGICAL CONCERNS
ISSUE:
WHEN YOU TALK ABOUT TOTAL EXCAVATION, DOES THAT MEAN THE TOTAL REMOVAL OF THE
HOUSES?
DISCUSSION:
NO, JUST THE SOIL WOULD BE REMOVED.
ISSUE:
SO HOW ARE YOU GOING TO REMOVE THE SOIL FROM UNDER THE HOUSES?
DISCUSSION:
WE WILL NOT REMOVE SOIL FROM UNDERNEATH THE HOUSES. WE WILL WORK AROUND PERMANENT
STRUCTURES SUCH AS DRIVEWAYS, HOUSES, TREES, AND SHRUBS. AND A LOT OF IT WILL HAVE
TO BE DONE MANUALLY AS OPPOSED TO USING HEAVY EQUIPMENT SO AS TO DISTURB ONLY THOSE
SOILS THAT ARE CONTAMINATED.
ISSUE:
COULD YOU REPORT THE DEPTHS OF THE EXCAVATIONS?
DISCUSSION:
FOR THOSE AREAS WHERE THE CONTAMINANT CONCENTRATIONS DECREASED WITH DEPTH, WE WILL
EXCAVATE DOWN TO THE WATER TABLE, WHICH IS APPROXIMATELY 4 1/2 TO 5 FEET. IN ALL
OTHER AREAS WE WILL REMOVE THE TOP FOOT OF CONTAMINATED SOILS.
ISSUE:
CAN YOU SHOW ME WHERE THE UNDERGROUND PLUME IS NOW, WHERE IT IS GOING, AND HOW FAST
IT IS MOVING SOUTH?
DISCUSSION:
BASED ON THE GROUNDWATER MONITORING DATA, CONTAMINANTS HAVE BEEN DETECTED IN THE
SOUTHERNMOST WELL TO A DEPTH OF 60 FEET. THIS WELL IS APPROXIMATELY 900 FEET SOUTH
OF THE SITE. BASED ON THE CONCENTRATION OF THE CONTAMINANTS FOUND AT THIS WELL, IT
CAN BE SURMISED THAT THE CONTAMINANTS HAVE MIGRATED FURTHER SOUTH, CLOSE TO THE
BAY.
ISSUE:
IS THERE A WALL OF CLAY PREVENTING THE GROUNDWATER FROM GOING INTO THE BAY?
DISCUSSION:
THERE ARE VARIOUS THICKNESSES OF CLAY UNDERNEATH THE POND AREA, BUT THE MOST
EXTENSIVE CLAY IS ON THE YACHT CLUB PROPERTY. IT STARTS AT A DEPTH OF 20 FEET, AND
IT IS ABOUT 20 TO 30 FEET THICK. AS THE PLUME MOVES SOUTH OF THE SITE, THIS CLAY
AREA DIVIDES THE PLUME. PART OF THE PLUME GOES ABOVE THE CLAY AREA; PART OF IT
GOES BELOW IT. THE ONE THAT GOES ABOVE THE CLAY AREA EVENTUALLY RECHARGES THE
DITCH AND FLOWS INTO THE BAY THROUGH THE DITCH ITSELF, AS SURFACE WATER. THERE IS
WATER IN THE DITCH AND ESPECIALLY DURING DRY TIMES, WHAT YOU'RE LOOKING AT IS NOT
RAINWATER -- IT'S GROUNDWATER, RECHARGED FROM THAT AREA.
ISSUE:
SO THERE'S NO WALL BETWEEN THE DITCH AND THE BAY?
DISCUSSION:
NO, THERE IS NO WALL.
ISSUE:
IS IT ALREADY FLOWING INTO THE BAY?
DISCUSSION:
WE DO NOT HAVE MONITORING WELLS DOWN TO THE BAY LEVEL, BUT WE HAVE DETECTED
CONTAMINATION IN THE SOUTHERNMOST WELLS.
ISSUE:
WHERE IS THE 100-YEAR FLOOD PLAIN IN RELATION TO THE SITE?
DISCUSSION:
WE ARE REQUIRED TO STUDY THAT ISSUE UNDER SUPERFUND STATUTES. THE 100-YEAR FLOOD
PLAIN BEGINS RIGHT WHERE THE SITE ENDS. THE 100-YEAR FLOOD PLAIN IS AT AN
ELEVATION OF 10 FEET, AND THE AVERAGE ELEVATION OF THE SITE IS 12 TO 13 FEET. WHEN
WE REFER TO THE DITCH, WE ARE IN THE 100-YEAR FLOOD PLAIN BECAUSE THE ELEVATION IS
UNDER 10 FEET. HOWEVER, THE SITE ITSELF IS NOT IN THE 100-YEAR FLOOD PLAIN
ELEVATION.
ISSUE:
ARE THE CONTAMINATION LEVELS MEASURED IN PARTS PER MILLION OR PARTS PER BILLION?
DISCUSSION:
IN THE SOILS, WE MEASURED IN PARTS PER MILLION, OR WHAT WE CALL MILLIGRAMS PER
KILOGRAMS. IN THE GROUNDWATER, WE MEASURED CONTAMINANTS SUCH AS NAPHTHALENE AND
FLUORANTHENE IN PARTS PER MILLION. THE REST OF THE CONTAMINANTS IN THE
GROUNDWATER WERE MEASURED IN PARTS PER BILLION. ESSENTIALLY, THE ONE CONTAMINANT
THAT WE FOUND IN DIFFERENT MEDIA AND AT HIGH LEVELS WAS NAPHTHALENE. IN THE SOILS,
WE DETECTED NAPHTHALENE AT LEVELS VARYING FROM 74 TO 1100 PARTS PER MILLION. AS
FAR AS GROUNDWATER IS CONCERNED, WE DID FIND VERY HIGH LEVELS OF NAPHTHALENE
RANGING BETWEEN 35 AND 580,000 PARTS PER BILLION. SO TO ANSWER YOUR QUESTION,
WE HAVE RANGES OF PARTS-PER-MILLION LEVEL IN THE SOIL AND PARTS-PER-BILLION LEVEL
IN THE WATER.
ISSUE:
YOU DETECTED 580,000 PARTS PER BILLION?
DISCUSSION:
YES. HOWEVER, THIS MIGHT NOT HAVE BEEN A REPRESENTATIVE SAMPLE. IT IS A
QUESTIONABLE RESULT BECAUSE THIS ONE SAMPLE WAS AN ORDER OF MAGNITUDE HIGHER,
COMPARED TO DATA FOR THE SAME CONTAMINANT IN OTHER WELLS. WHAT THIS TELLS US IS
THAT THE DATA MIGHT BE QUESTIONABLE FOR THAT PARTICULAR SAMPLE, BUT WE HAD TO
INCLUDE IT -- WITH A QUALIFIER THAT SAID THAT THE NUMBER MAY NOT BE REPRESENTATIVE.
ISSUE:
HOW HIGH ABOVE THE GROUND WOULD THE ONSITE LANDFILL BE?
DISCUSSION:
ABOUT 15 TO 19 FEET, DEPENDING ON WHETHER YOU GO WITH TOTAL OR PARTIAL EXCAVATION.
ISSUE:
WITH REGARD TO THE AMOUNT OF MATERIAL YOU HAVE TO REMOVE, HOW DOES IT COMPARE TO
OTHER PROJECTS? DO YOU HAVE TO REMOVE A LOT OF MATERIAL?
DISCUSSION:
THE ONLY OTHER PROJECT THAT I CAN THINK OF WHERE WE MOVED ANYWHERE NEAR THE AMOUNT
OF DIRT THAT WE HAVE TO REMOVE AT THIS SITE CONSISTED OF HALF THAT AMOUNT, OR ABOUT
40,000 CUBIC YARDS, WHICH WE MOVED TO A SPECIALLY CONSTRUCTED LANDFILL IN THE STATE
OF NORTH CAROLINA. SO WE ARE TALKING TWICE THAT AMOUNT OF MATERIAL FOR THIS SITE.
ISSUE:
WOULD INCINERATION COMPLETELY CLEAN UP THIS AREA AS WELL AS TOTAL OFFSITE REMOVAL?
DISCUSSION:
YES, IT WOULD. YOU WOULD HAVE TO DO SOMETHING WITH THE RESIDUAL ASH THAT WOULD
CONTAIN HEAVY METALS, AND YOU MIGHT HAVE TO TRANSPORT THAT MATERIAL OFFSITE IF YOU
DECIDED NOT TO HAVE AN ONSITE LANDFILL.
ISSUE:
IF YOU HAD TO PICK A PLACE TO PUT HAZARDOUS WASTE, THIS WOULD BE ONE OF THE WORST
PLACES BECAUSE THE GROUNDWATER IS SO CLOSE TO THE SURFACE, RIGHT?
DISCUSSION:
THAT IS CORRECT. THE REMEDIES THAT WE HAVE BASICALLY PROPOSED FOR LEAVING THE
WASTE ON THE SITE ARE TO CONTAIN IT AND ABATE FURTHER MIGRATION OF THE WASTE FROM
THE SITE -- IN OTHER WORDS, TO TRY TO PREVENT IT FROM SPREADING ANY FURTHER AND TO
HOLD IT IN PLACE.
ISSUE:
BUT ISN'T THERE ALREADY CONTAMINATION IN THE WATER TABLE BENEATH THE SITE?
DISCUSSION:
YES, BUT THAT COULD BE TAKEN CARE OF IF YOU PICK AN ALTERNATIVE IN WHICH YOU ARE
ALSO TREATING THE GROUNDWATER. IF YOU CONSOLIDATED ALL THE EXCAVATED MATERIAL AND
STORED IT IN AN ONSITE LANDFILL, AND AT THE SAME TIME PUT IN WELLS AND PUMPED OUT
THE CONTAMINATED GROUNDWATER AND TREATED IT, YOU WOULD HAVE ESSENTIALLY TAKEN CARE
OF THE PROBLEM.
ISSUE:
WHAT'S THE TIME PERIOD INVOLVED?
DISCUSSION:
YEARS.
BASED ON THE DATA THAT WE HAVE EVALUATED, WE ARE LOOKING AT A SPAN OF ABOUT 5
ISSUE:
WHY DON'T YOU LEAVE THINGS AS THEY ARE AND JUST MONITOR THE PUBLIC HEALTH UNTIL A
NEW TECHNOLOGY IS DISCOVERED TO COMPLETELY CLEAN UP THE SITE?
DISCUSSION:
THE NO-ACTION ALTERNATIVE WITH MONITORING IS AN ALTERNATIVE WE ARE EVALUATING.
IN ADDITION TO THE ORAL COMMENTS RECEIVED AT THE PUBLIC MEETING ON AUGUST 15, 1985, THE EPA ALSO
RECEIVED ONE WRITTEN COMMENT FROM THE AUDUBON SOCIETY.
ISSUE:
TOLERANCE LEVELS AND SPECIFIC EFFECTS ON HUMANS, PLANTS, AND ANIMALS WERE NOT
GIVEN. IN THE REPORT, THERE WAS NOT ADEQUATE INFORMATION ON BIOACCUMULATION OR THE
POTENTIAL EFFECTS ON HUMANS WHO FREQUENT SANDERS BEACH, WHERE THE UNDERGROUND PLUME
EMERGES. ALSO, THE POSSIBILITY OF CHEMICALS AT THE SITE INTERACTING WITH EACH
OTHER WAS NOT DISCUSSED IN THE STUDY.
WE FEEL THAT PARTICULAR ATTENTION SHOULD BE GIVEN TO THE ONSITE TREATMENT OF
GROUNDWATER. DISCHARGE OF THE GROUNDWATER INTO THE MAIN STREET PLANT SHOULD OCCUR
ONLY IF THERE IS ASSURANCE THAT THIS FACILITY IS CAPABLE OF PROPERLY HANDLING THIS
TREATMENT IN A MANNER SAFE TO THE PLANT AND THE BAY WHERE IT DISCHARGES. WE DO NOT
RECOMMEND ONSITE DISPOSAL.
DISCUSSION:
SINCE EPA HAS BEEN INVOLVED WITH THE AMERICAN CREOSOTE SITE, EPA HAS MADE AN EFFORT
TO INFORM THE RESIDENTS, THE LOCAL GOVERNMENT AND THE STATE ABOUT THE ACTIVITIES AT
THE SITE.
BOTH CHRONIC AND ACUTE TOXIC EFFECTS THAT MAY AFFECT HUMAN HEALTH AS WELL AS THE
ENVIRONMENT AS A RESULT OF THE CONTAMINATION FROM THE ACW SITE HAVE BEEN PRESENTED
IN THE REMEDIAL INVESTIGATION REPORT AND THE DRAFT FEASIBILITY STUDY.
TOTAL EXCAVATION PLUS GROUNDWATER RECOVERY IS A PROPOSED ALTERNATIVE THAT IS UNDER
CONSIDERATION FOR FINAL REMEDIAL ACTION. THE GROUNDWATER DISCHARGE TO THE ESCAMBIA
COUNTY UTILITY AUTHORITY WASTE WATER TREATMENT PLANT (WWTP) IS AN ITEM OF CONCERN,
SINCE THE WWTP HAS NOT ALWAYS BEEN IN COMPLIANCE WITH THEIR NPDES PERMIT. AN
ONSITE DISPOSAL ALTERNATIVE WHICH WILL RESULT IN THE SITE BEING SOMEWHAT HIGHER IN
ELEVATION IS POSSIBLE. HOWEVER, WITH REVEGETATION AND PROPER DESIGN THE DISPOSAL
AREA COULD BLEND IN WITH THE SURROUNDING AREA. OUR INFORMATION INDICATES THAT THE
ACW PROPERTY IS NOT WITHIN A 100 YEAR FLOOD PLAIN, AND THAT AN ONSITE DISPOSAL
ALTERNATIVE WOULD NOT OF ITSELF CREATE AN ENVIRONMENTAL OR HEALTH HAZARD.
TABLE 1
RANGE AND FREQUENCY OF CHEMICAL CONTAMINANTS
IN VARIOUS MEDIA
AMERICAN CREOSOTE WORKS, INC., SITE
ALL CONCENTRATIONS IN MG/KG (SOILS) AND UG/L (WATER)
SOILS
CONTAMINANT
GROUNDWATER
CONCENTRATION
RANGE & NO. OF
OBSERVATIONS
CONCENTRATION
RANGE & NO. OF
OBSERVATIONS
SEDIMENT
CONCENTRATION
RANGE & NO. OF
OBSERVATIONS
POLYCYCLIC AROMATIC HYDROCARBONS (PAHS)
BENZO(A)ANTHRACENE
BENZO(A)PYRENE
BENZO(B)FLUORANTHENE
BENZO(K)FLUORANTHENE
CHRYSENE
ANTHRACENE
BENZO(GHI)PERYLENE
FLUORENE
PHENANTHRENE
DIBENZO(A,H)ANTHRACENE
INBENO(1,2,3-CD)PYRENE
PYRENE
8.8-870 (16)
6.7-140 (10)
9.2-480 (17)
7.9-8.7 (2)
5.6-750 (19)
7.2-1,600 (17)
5.4-20 (5)
7.1-1,800 (13)
5.7-29,00 (21)
7.8-91 (2)
6.1-210 (5)
7.9-9,000 (29)
7,300 (1)
8,300 (1)
6,400-430,000 *(2)
50-140,000 *(13) 5,700 (1)
30-1,300 (10)
20,000 (1)
2,200 (1)
15,000 (1)
OTHER ACID AND BASE/NEUTRAL ORGANICS
ACENAPHTHENE
FLUORANTHENE
NAPHTHALENE
DIBENZOFURAN
2-METHYLNAPHTHALENE
PENTACHLOROPHENOL
7.3-6,900 (12)
8.1-10,000 (30)
74-1,100 (7)
58-880 (8)
39-540 (7)
7.2-2500 (10)
40-140,000 *(12)
60-2,700 (3)
18,000 (1)
35-580,000 *(17)
45-660 (6)
35-3,680 (8)
0.04-0.13
0.03-0.26
0.01-0.22
0.08 (1)
0.01-0.35
6-150 (15)
15-110 (15)
5-150 (15)
400-2,700 (8)
5-240 (16)
VOLATILE ORGANICS
BENZENE
ETHYLBENZENE
TOLUENE
ACETONE
O-XYLENE
(3)
(5)
(7)
(10)
PESTICIDES
BETA-BHC
ENDOSULFAN
+
++
*
()
+0.66-0.9 (5)
++0.47 (2)
ONE REPORTED CONCENTRATION @ 230*
SAME SAMPLE AS ABOVE 12UG/L
MAY BE IN ERROR DUE TO NONREPRESENTIVE DATA
FREQUENCY OF CHEMICAL FOUND.
TABLE 2
CRITICAL CONTAMINANTS
FOR ASSESSMENT OF RISK
* PAHS
- BENZO(A)ANTHRACENE
- BENZO(A)PYRENE
- ANTHRACENE
- FLUORENE
- PHENANTHRENE
- PYRENE
SOILS, SEDIMENT AND GROUNDWATER
IN SOILS, AND SEDIMENTS
IN SOILS AND GROUNDWATER
MOST FREQUENTLY DETECTED IN GROUNDWATER
IN SOILS AND GROUNDWATER
MOST FREQUENTLY FOUND IN SOILS AND
GROUNDWATER
* OTHER ACID/BASE/NEUTRAL FRACTION ORGANIC CONTAMINANTS
- ACENAPHTHENE
IN GROUNDWATER
- FLUORANTHENE
IN SOILS
- NAPHTHALENE
IN WATER
- DIBENZOFURAN
IN GROUNDWATER
- 2-METHYLNAPHTHALENE
IN GROUNDWATER
- PENTACHLOROPHENOL
IN SOILS
* VOLATILE ORGANICS
- BENZENE
- ETHYLBENZENE
- TOLUENE
- O-XYLENE
IN
IN
IN
IN
GROUNDWATER
GROUNDWATER
SOIL AND GROUNDWATER
GROUNDWATER.
TABLE 3
GENERAL RESPONSE ACTIONS & ASSOCIATED
REMEDIAL TECHNOLOGIES
AMERICAN CREOSOTE WORKS, INC., SITE
GENERAL RESPONSE
ACTION
TECHNOLOGIES
NO ACTION
SITE MONITORING (SURFACE DISTURBANCE, MONITORING
WELLS, SURFACE DISCHARGES)
PUMPING
GROUNDWATER PUMPING; DREDGING (SEDIMENTS IN DRAINAGE DITCH)
CONTAINMENT
CAPPING; GROUNDWATER CONTAINMENT BARRIER WALLS
DIVERSION
GRADING; CONSTRUCTION OF SURFACE WATER DRAINAGE DITCHES AND BERMS
REMOVAL
EXCAVATION AND HANDLING OF SLUDGES, SOILS AND
SEDIMENTS; AND REMOVAL OF RAILROAD TRACKS, STORED
DRUMS, AND DEBRIS
ONSITE TREATMENT
INCINERATION; BIOLOGICAL, PHYSICAL, AND CHEMICAL TREATMENT
OFFSITE TREATMENT
INCINERATION; BIOLOGICAL, CHEMICAL, AND PHYSICAL TREATMENT
ONSITE STORAGE
TEMPORARY STORAGE STRUCTURES
ONSITE DISPOSAL
LANDFILLS; SURFACE IMPOUNDMENTS; LAND APPLICATION
OFFSITE DISPOSAL
LANDFILLS; SURFACE IMPOUNDMENTS; LAND APPLICATION.
TABLE 5
TECHNOLOGY SCREENING
REMEDIAL ALTERNATIVES SUMMARY
AMERICAN CREOSOTE WORKS, INC., SITE
SOURCE CONTROL
1. CAPPING OF SELECT AREAS
2. EXCAVATION OF CONTAMINATED ONSITE SOILS AND SLUDGE AND EXCAVATION OF
CONTAMINATED OFFSITE SOILS AND SEDIMENTS
3. SURFACE WATER RUN-ON/RUNOFF CONTROLS AT THE SITE
4. CLEARING AND GRUBBING OF THE SITE:
- REMOVE RAILROAD TRACKS COMPLETE, INCLUDING TIES, EXCEPT THE MAIN-LINE WITHIN THE
RAILROAD RIGHT-OF-WAY, WHICH MAY BE TEMPORARILY REMOVED AT SELECT LOCATIONS AND
RESTORED TO FACILITATE EXCAVATION OF CONTAMINATED SOIL
- REMOVE TRASH AND DEBRIS, INCLUDING ABANDONED EQUIPMENT AND FOUNDATIONS
- REMOVE STORED ONSITE DRUMS
- REMOVE FUEL TANKS AND SERVICE UTILITY LINES
OPTIONS TO 2, 3, AND 4, ABOVE:
A) DISPOSE OF EXCAVATED MATERIAL AT OFFSITE RCRA LANDFILL
B) DISPOSE OF EXCAVATED MATERIAL AT ONSITE RCRA LANDFILL
MANAGEMENT OF MIGRATION
5. RECOVER CONTAMINATED GROUNDWATER -- COLLECT DRILL SOILS AND MUD
6. CLEAN AND FLUSH EXISTING STORM SEWERS
OPTIONS FOR 5 AND 6, ABOVE:
A) TREAT GROUNDWATER ON SITE AND DISCHARGE TREATED WATER TO THE BAY
B) PRETREAT GROUNDWATER ON SITE AND DISCHARGE TO A PUBLIC OWNED TREATMENT WORKS (POTW)
D) SAME OPTIONS AS LISTED FOR 2,3, AND 4 FOR SOURCE CONTROL
E) COLLECTION AND DISPOSAL OF SEDIMENTS AND WATERS FROM STORM SEWERS ON SITE OR OFF
SITE
NO ACTION
7. NO ACTION
8. NO ACTION WITH MONITORING (INCLUDING DRUM REMOVAL).
TABLE 6-A
SITE LIMITING CHARACTERISTICS
TECHNOLOGIES ELIMINATED
FROM CONSIDERATION
EXISTING LAND USE (ZONED
RESIDENTIAL/LIGHT COMMERCIAL)
INCINERATION; LAND APPLICATION
DEPTH OF CONTAMINATED GROUND-PLUME
WATER (APPROX 60-80 FT)
SUBSURFACE COLLECTION DRAINS
SITE CONFIGURATION
LAND APPLICATION
DEPTH OF BEDROCK
GROUNDWATER BARRIERS
SITE AREA
LAND APPLICATION.
TABLE 6-B
WASTE LIMITING CHARACTERISTICS
TECHNOLOGIES ELIMINATED
FROM CONSIDERATION
CHEMICAL COMPOSITION (PAHS,
METALS)
PUMPING AND DISCHARGING TO
SURFACE WATER OR WWTP WITHOUT
TREATMENT
TREATABILITY
CHEMICAL TREATMENT WITH THE
EXCEPTION OF OXIDATION
CURRENT CONDITION OF SLUDGE
IN-SITU TREATMENT
LOW BTU CONTENT
INCINERATION
BIODEGRADABILITY
BIOLOGICAL TREATMENT BY ITSELF
VOLATILITY
AIR OR STEAM STRIPPING.
TABLE 7
REMEDIAL ALTERNATIVES FOR EVALUATION
AMERICAN CREOSOTE WORKS, INC., SITE
1. TOTAL EXCAVATION WITH OFFSITE DISPOSAL
TOTAL EXCAVATION, TRANSPORTATION, AND DISPOSAL OF ALL CONTAMINATED
MATERIALS, AND THE BACKFILL OF EXCAVATIONS (SEE TABLE 3-2A). DISPOSE
OF APPROXIMATELY 83,000 CUBIC YARDS OF EXCAVATED MATERIALS OFF SITE
IN A RCRA LANDFILL
SUPPORTIVE ITEMS INCLUDE CLEARING AND GRUBBING, REMOVAL OF RAILROAD
TRACKS, ONSITE DRUMS, DEBRIS, GRUBBED MATERIAL, BURIED FUEL TANKS,
BLOCK SHOWER BUILDING, OFFICE-LABORATORY BUILDING, AND OTHER
ABANDONED UTILITIES. MATERIALS CLASSIFIED AS HAZARDOUS WILL BE
TRANSPORTED AND DISPOSED OFF SITE IN A RCRA LANDFILL; NON-HAZARDOUS
MATERIALS WILL BE DISPOSED OF LOCALLY IN AN APPROVED LANDFILL. OTHER
ITEMS INCLUDE GRADING, REVEGETATION, AND STORM WATER MANAGEMENT
2. TOTAL EXCAVATION WITH ONSITE DISPOSAL
TOTAL EXCAVATION AND DISPOSAL OF ALL CONTAMINATED MATERIALS IN AN
ONSITE LANDFILL. THE QUANTITIES TO BE EXCAVATED AND THE QUANTITIES
OF VARIOUS MATERIALS TO BE USED FOR CONSTRUCTION OF AN ONSITE
LANDFILL ARE SHOWN IN TABLE 3-2B
SUPPORTIVE ITEMS WILL BE THE SAME AS DESCRIBED IN ALTERNATIVE NO. 1
ABOVE; HOWEVER, ALL MATERIALS EXCEPT THE ONSITE DRUMS AND RAILROAD
TRACKS WILL BE DISPOSED ON SITE IN THE NEWLY-CONSTRUCTED LANDFILL.
ONSITE DRUMS WILL BE TRANSPORTED AND DISPOSED OFF SITE IN A RCRA
LANDFILL, WHILE THE RAILROAD TRACKS (RAILS ONLY) WILL BE SOLD AS SALVAGE
OTHER TABLES MENTIONED ARE PRESENTED IN THE DRAFT FS REPORT
TABLE 7
REMEDIAL ALTERNATIVES FOR EVALUATION
AMERICAN CREOSOTE WORKS, INC. SITE
PAGE TWO
3. PARTIAL EXCAVATION WITH OFFSITE DISPOSAL
SELECTIVE EXCAVATION, TRANSPORTATION AND DISPOSAL OF GROSSLY
CONTAMINATED SLUDGES, ONSITE SOILS, AND OFFSITE SEDIMENTS, IN AN
OFFSITE RCRA LANDFILL. EXCAVATION AND BACKFILL QUANTITIES ARE AS
SHOWN IN TABLE 3-2C
SUPPORTIVE ITEMS WILL INCLUDE FENCING AROUND SITE, STORM WATER
MANAGEMENT, AND BACKFILLING CONTAMINATED CITY BLOCKS WITH TOPSOIL,
RESEEDING AND REVEGETATION
4. PARTIAL EXCAVATION WITH ONSITE DISPOSAL
SELECTIVE EXCAVATION AND DISPOSAL OF GROSSLY-CONTAMINATED SLUDGES,
ONSITE SOILS, AND OFFSITE SEDIMENTS IN AN ONSITE LANDFILL. THE
QUANTITIES TO BE EXCAVATED AND THE QUANTITIES OF VARIOUS MATERIALS
TO BE USED FOR CONSTRUCTION OF AN ON SITE LANDFILL ARE SHOWN IN
TABLE 3-2D
SUPPORTIVE ITEMS WILL BE THE SAME AS THOSE DESCRIBED FOR ALTERNATIVE
NO. 3, ABOVE
5. ALTERNATIVE NO. 1 (AS LISTED PREVIOUSLY), PLUS GROUNDWATER RECOVERY
SUPPORTIVE ITEMS WOULD INCLUDE THE FOLLOWING TREATMENT OPTIONS:
A. PRETREAT GROUNDWATER ON SITE AND DISCHARGE OFF SITE TO POTW
B. TREAT GROUNDWATER ON SITE AND DISCHARGE OFF SITE INTO SURFACE
WATER BODY
OTHER TABLES MENTIONED ARE PRESENTED IN THE DRAFT FS REPORT
TABLE 7
REMEDIAL ALTERNATIVES FOR EVALUATION
AMERICAN CREOSOTE WORKS, INC. SITE
PAGE THREE
6. ALTERNATIVE NO. 2 (AS LISTED PREVIOUSLY), PLUS GROUNDWATER RECOVERY
SUPPORTIVE ITEMS WOULD INCLUDE THE SAME TREATMENT OPTIONS AS LISTED
UNDER ALTERNATIVE 5.A AND 5.B
7. ALTERNATIVE NO. 3 (AS LISTED PREVIOUSLY), PLUS GROUNDWATER RECOVERY
SUPPORTIVE ITEMS WOULD INCLUDE THE SAME TREATMENT OPTIONS AS LISTED
UNDER 5.A AND 5.B
8. ALTERNATIVE NO. 4 (AS LISTED PREVIOUSLY), PLUS GROUNDWATER RECOVERY
SUPPORTIVE ITEMS WOULD INCLUDE THE SAME TREATMENT OPTIONS AS LISTED
UNDER 5.A AND 5.B
9. NO ACTION WITH GROUNDWATER PLUME MONITORING AND ASSESSMENT.
TABLE 9
MAXIMUM RISK
POLYNUCLEAR AROMATIC HYDROCARBONS & BENZENE
AMERICAN CREOSOTE WORKS INC., SITE
MAXIMUM CONCENTRATION
(MG/KG)
ALTERNATIVE
NO-ACTION
PARTIAL EXCAVATION
TOTAL EXCAVATION
TOTAL PAHS (1)
800
138
12.0
CARCINOGENIC RISK
BENZENE
DERMAL (2)
EXPOSURE
0.13
0.13
0.13
5.6 X 10-1
9.7 X 10-2
8.4 X 10-2
ACCIDENTAL (3)
INGESTION
2.3 X 10-1
4.1 X 10-2
3.5 X 10-2
NOTE:(1) THE CONCENTRATIONS TABULATED ARE THE SUMMATION OF THE MAXIMUM
CONCENTRATION OF THE COMPOUNDS FOUND
(2) DERMAL EXPOSURE RISKS WERE BASED ON TABLE C-3 IN THE DRAFT FS
(3) ACCIDENTAL EXPOSURE RISKS WERE BASED ON TABLE C-4 IN THE DRAFT FS
ASSUMPTIONS USED IN THE ESTIMATION OF THE EXCESS CANCER RISK ASSOCIATED
WITH DERMAL CONTACT ARE AS FOLLOWS:
(A) ALL CARCINOGENIC PAH'S USED IN THE ESTIMATION OF CANCER RISK HAVE
THE SAME CARCINOGENIC POTENCY AS BENZO(A)PYRENE
(B) A RECEPTOR WILL BE EXPOSED TO THE MAXIMUM CONCENTRATION OF
CARCINOGENIC PAH'S OVER A LIFETIME (70 YEARS)
(C) LIFETIME DERMAL SOIL ACCUMULATION IS 110,000 GRAMS (SCHAUM, 1984)
(D) 100% OF THE PAH'S ARE ABSORBED THROUGH THE SKIN
(E) PAH'S DO NOT DEGRADE IN SOIL OVER TIME
ADDITIONAL ASSUMPTIONS USED IN THE ESTIMATION OF THE EXCESS CANCER RISK
ASSOCIATED WITH ACCIDENTAL INGESTION AS FOLLOWS:
(A) BODY WEIGHT OF A CHILD IS 14 KILOGRAMS
(B) EXPOSURE DURATION IS 365 DAYS PER YEAR FROM AGES 2-6, FOR A TOTAL
OF 1,830 DAYS (SCHAUM, 1984)
(C) A RECEPTOR INGEST 5 GRAMS OF SOIL PER DAY.
TABLE 10
TABULATION OF EXCAVATION AND BACKFILL
(TOTAL EXCAVATION-ONSITE DISPOSAL)
AMERICAN CREOSOTE WORKS, INC., SITE
QUANTITY
FOR DISPOSAL
DESCRIPTION
1. EXCAVATION FROM EXISTING PONDS
TOTAL - CAP, SLUDGE, KILN, DUST,
AND LIME
CLAY CAP (SALVAGE)
50,500 CU YD
13,100 CU YD
NET QUANTITY FOR DISPOSAL
37,400 CU YD
2. EXCAVATION OF CONTAMINATED SOILS AT SELECT LOCATIONS
ONSITE
A) AT 4.5 FT DEPTH (SAMPLING
AREAS 4, 5, 6, AND 7)
10,600 CU YD
B) AT 2.0 FT DEPTH (SAMPLING
AREA 9)
1,100 CU YD
C) AT 1.0 FT DEPTH (SAMPLING
AREAS 1, 2, 3, AND 8)
2,350 CU YD
D) EXCAVATION FOR LANDFILL
4,400 CU YD
OFFSITE
E) AT 1.0 FT DEPTH AT YACHT
CLUB PROPERTY
3,500 CU YD
F) CONTAMINATED SEDIMENTS FROM
"L" STREET DRAINAGE OUTFALL
DITCH FROM YACHT CLUB PROPERTY
800 CU YD
G) AT 1.0 FT DEPTH (OFFSITE
SAMPLING AREAS 0-1, 0-2, 0-3
AND 0-4 WITHIN CITY BLOCKS 179
THROUGH 184 AND BLOCK 162)
20,000 CU YD
3. CLEARING AND GRUBBING 9.0 ACRES AT
0.5 FT DEPTH
TOTAL EXCAVATION, GENERAL
7,250 CY YD
17,500 CU YD
TOTAL EXCAVATION OF CONTAMINATED
MATERIALS FOR DISPOSAL
83,000 CU YD.
AMERICAN CREOSOTE WORKS, INC. (PENSACOLA PLANT)
Site Information:
Site Name:
Address:
AMERICAN CREOSOTE WORKS, INC. (PENSACOLA PLANT)
PENSACOLA, FL
EPA ID:
EPA Region:
FLD008161994
04
Site Alias Name(s):
AMERICAN CREOSOTE WORKS INC
AMERICAN CREOSOTE WORKS (PENSACOLA PLT)
Record of Decision (ROD):
ROD Date:
Operable Unit:
ROD ID:
09/28/1989
01
EPA/ROD/R04-89/055
Media:
Soil
Contaminant:
ORGANICS, DIOXINS, PAHS, PCP
Abstract:
THE 18-ACRE AMERICAN CREOSOTE WORKS (PENSACOLA
PLANT) SITE, IS IN A DENSE MODERATELY COMMERCIAL
AND RESIDENTIAL AREA OF PENSACOLA, FLORIDA,
APPROXIMATELY 600 YARDS FROM PENSACOLA BAY AND
BAYOU CHICO. AMERICAN CREOSOTE WORKS, INC.
OPERATED A WOOD PRESERVING FACILITY ONSITE FROM
1902 TO 1981. DURING THIS TIME, PROCESS WASTEWATER
CONTAINING PENTACHLOROPHENOL (PCP) WAS
DISCHARGED INTO TWO 0.9-AND 1.8-ACRE UNLINED,
ONSITE SURFACE IMPOUNDMENTS. PRIOR TO 1970,
WASTEWATER IN THESE PONDS WAS ALLOWED TO
OVERFLOW THROUGH A SPILLWAY INTO THE
NEIGHBORING BAYOU CHICO AND PENSACOLA BAY.
AFTER 1970, WASTEWATER WAS PERIODICALLY DRAWN
FROM THE PONDS AND DISCHARGED TO DESIGNATED
ONSITE SPILLAGE AREAS. ADDITIONAL DISCHARGES
OCCURRED DURING PERIODS OF HEAVY RAINFALL WHEN
THE PONDS OVERFLOWED. IN MARCH 1980, THE CITY
FOUND CONSIDERABLE QUANTITIES OF OILY,
ASPHALTIC, CREOSOTIC MATERIAL IN THE GROUND
WATER NEAR THE SITE. BECAUSE OF THE THREAT POSED
TO HUMAN HEALTH AND THE ENVIRONMENT DUE TO
FREQUENT OVERFLOWS FROM THE WASTE PONDS, EPA
AND THE STATE PERFORMED AN EMERGENCY CLEANUP
IN 1983, WHICH INCLUDED DEWATERING THE TWO
PONDS, TREATING THE WATER VIA COAGULATION AND
FILTRATION, AND DISCHARGING TREATED WATER TO
THE CITY SEWER SYSTEM. THE SLUDGE IN THE PONDS
WAS THEN SOLIDIFIED AND CAPPED. EPA SIGNED A
RECORD OF DECISION (ROD) IN 1985 REQUIRING ALL
ONSITE AND OFFSITE CONTAMINATED SOLIDS, SLUDGE,
AND SEDIMENT TO BE PLACED IN AN ONSITE
RCRA-PERMITTED LANDFILL. BECAUSE THE STATE DID
CONCUR WITH THE SELECTED REMEDY, NO REMEDIAL
ACTION WAS TAKEN. CONSEQUENTLY, A POST REMEDIAL
INVESTIGATION WAS CONDUCTED IN 1988 TO
CHARACTERIZE THE EXTENT OF CONTAMINATION
FOLLOWED BY A POST FEASIBILITY STUDY IN 1989 TO
IDENTIFY, DEVELOP, AND EVALUATE ALTERNATIVES.
THIS ROD IS THE FIRST OF TWO PLANNED OPERABLE
UNITS AND ADDRESSES REMEDIATION OF
CONTAMINATED SURFACE SOIL. A SUBSEQUENT
OPERABLE UNIT WILL ADDRESS TREATMENT OF
CONTAMINATED SUBSURFACE SOIL, SLUDGE, AND
GROUND WATER. THE PRIMARY CONTAMINANTS OF
CONCERN AFFECTING THE SURFACE SOIL ARE ORGANICS
INCLUDING DIOXINS, CARCINOGENIC PAHS, AND PCP.
THE SELECTED REMEDIAL ACTION FOR THIS SITE
INCLUDES EXCAVATING AND TREATING 23,000 CUBIC
YARDS OF PAH-CONTAMINATED SOIL USING
SOLID-PHASE BIOREMEDIATION IN AN ONSITE LAND
TREATMENT AREA FOLLOWED BY ONSITE DISPOSAL OF
TREATED SOIL IN THE EXCAVATED AREAS OR
SPREADING THE SOIL OVER THE ENTIRE SITE;
IMPLEMENTING TEMPORARY EROSION CONTROL
MEASURES TO PRESERVE SURFACE WATER QUALITY;
COLLECTING LEACHATE AND DRAIN WATER FOR
SPRAYING OVER THE TREATMENT AREA TO MOISTEN
SOIL; MONITORING DISSOLVED OXYGEN, PH, NUTRIENTS,
AND SOIL MOISTURE CONTENT; REMOVING DEBRIS,
REPAIRING FENCES, SAMPLING THE CAP AND DISPOSING
OF DRUMS CONTAINING DRILLING MUD; AND
IMPLEMENTING LAND AND GROUND WATER USE
RESTRICTIONS. THE ESTIMATED PRESENT WORTH COST
IS $2,275,000 WHICH INCLUDES AN O&M COST OF $319,000.
Remedy:
THE REMEDY SELECTED BY EPA WILL BE CONDUCTED IN
TWO SEPARATE OPERABLE UNITS. THIS OPERABLE UNIT
IS THE FIRST OF TWO OPERABLE UNITS FOR THE SITE.
THIS INITIAL OPERABLE UNIT ADDRESSES TREATMENT
OF THE CONTAMINATED SURFACE SOIL AND IS FULLY
CONSISTENT WITH ALL PLANNED FUTURE SITE
ACTIVITIES. FUTURE SITE ACTIVITIES INCLUDE
TREATMENT OF THE CONTAMINATED GROUND WATER
AND PREVIOUSLY SOLIDIFIED SLUDGES AND
UNDERLYING SUBSURFACE SOIL.
THE MAJOR COMPONENTS OF THE SELECTED REMEDY
FOR THIS FIRST OPERABLE UNIT ARE AS FOLLOWS:
* EXCAVATING, SCREENING, AND STOCKPILING THE
CONTAMINATED SURFACE SOIL
* TREATMENT OF THIS CONTAMINATED SOIL BY
BIOREMEDIATION
* ON-SITE DISPOSAL OF THE TREATED SOIL IN THE
EXCAVATED AREAS
* CONTAINING DRILLING MUDS AND PROPERLY DISPOSE
OF CONTENTS, AND REPAIR EXISTING CLAY CAP.
Text:
Full-text ROD document follows on next page.
EPA/ROD/R04-89/055
1989
EPA Superfund
Record of Decision:
AMERICAN CREOSOTE WORKS, INC. (PENSACOLA
PLANT)
EPA ID: FLD008161994
OU 01
PENSACOLA, FL
09/28/1989
1.
2.
3.
4.
5.
6.
CARCINOGENIC PAHS
NON-CARCINOGENIC PAHS
PHTHALATES
PHENOLS
PENTACHLOROPHENOL
CHLORINATED DIOXINS-DIBENZOFURANS
OTHER CLASSES OF COMPOUNDS WERE FOUND, BUT ONLY SPORADICALLY, AT LOW CONCENTRATIONS.
6.2 EXPOSURE ASSESSMENT SUMMARY
THE RISK ASSESSMENT FOR THIS SITE WAS DEVELOPED USING A MATHEMATICAL MODELING PROGRAM DESIGNED
TO PERFORM PROBABILISTIC RISK ANALYSIS USING A MONTE CARLO TECHNIQUE.
IN THIS PROGRAM, RISK-RELATED PARAMETERS (SUCH AS BODY WEIGHTS, ABSORPTION FACTORS AND EXPOSURE
FREQUENCY) ARE INPUT AS RANGES WITH PROBABILITY DISTRIBUTIONS, AND PROBABILITY DISTRIBUTION OF
RISK IS THE OUTPUT.
THE PATHWAYS CONSIDERED FOR DEVELOPMENT OF THE CLEANUP GOALS FOR THE CONTAMINATED SURFACE SOIL
WERE:
1.
ORAL AND DERMAL EXPOSURE TO SURFACE SOIL IN THE FOLLOWING LOCATIONS:
A.
B.
C.
D.
AMERICAN CREOSOTE WORKS SITE
RESIDENTIAL AREAS
DRAINAGE DITCH AREA
CONDOMINIUM BLOCK
2.
INHALATION EXPOSURE TO AIRBORNE PARTICULATES FROM ACW SITE SURFACE SOIL WHICH MAY BE
EXPERIENCED BY INDIVIDUALS RESIDING IN NEARBY RESIDENTIAL AREAS.
3.
INGESTION OF HOME GROWN CROPS IN CONTAMINATED SOIL IN RESIDENTIAL AREAS.
6.3 SUMMARY OF THE TOXICITY ASSESSMENT OF THE CONTAMINANTS OF CONCERN
CANCER POTENCY FACTORS (CPFS) HAVE BEEN DEVELOPED BY EPA'S CARCINOGENIC ASSESSMENT GROUP FOR
ESTIMATING EXCESS LIFETIME CANCER RISKS ASSOCIATED WITH EXPOSURE TO POTENTIALLY CARCINOGENIC
CHEMICALS. CPFS, WHICH ARE EXPRESSED IN UNITS OF (MG/KG-DAY)(-1), ARE MULTIPLIED BY THE
ESTIMATED INTAKE OF A POTENTIAL CARCINOGEN, IN MG/KG-DAY, TO PROVIDE AN UPPER-BOUND ESTIMATE OF
THE EXCESS LIFETIME CANCER RISK ASSOCIATED WITH EXPOSURE AT THAT INTAKE LEVEL. THE TERM "UPPER
BOUND" REFLECTS THE CONSERVATIVE ESTIMATE OF THE RISK CALCULATED FROM THE CPF. USE OF THIS
APPROACH MAKES UNDERESTIMATION OF THE ACTUAL CANCER RISK HIGHLY UNLIKELY. CANCER POTENCY
FACTORS ARE DERIVED FROM THE RESULTS OF HUMAN EPIDEMIOLOGICAL STUDIES OR CHRONIC ANIMAL
BIOASSAYS TO WHICH ANIMAL-TO-HUMAN EXTRAPOLATION AND UNCERTAINTY FACTORS HAVE BEEN APPLIED.
REFERENCE DOSES (RFDS) HAVE BEEN DEVELOPED BY EPA FOR INDICATING THE POTENTIAL FOR ADVERSE
HEALTH EFFECTS FROM EXPOSURE TO CHEMICALS EXHIBITING NONCARCINOGENIC EFFECTS. RFDS, WHICH ARE
EXPRESSED IN UNITS OF MG/KG-DAY, ARE ESTIMATES OF LIFETIME DAILY EXPOSURE LEVELS FOR HUMANS,
INCLUDING SENSITIVE INDIVIDUALS. ESTIMATED INTAKES OF CHEMICALS FROM ENVIRONMENTAL MEDIA (E.G.,
THE AMOUNT OF A CHEMICAL INGESTED FROM CONTAMINATED DRINKING WATER) CAN BE COMPARED TO THE RFD.
RFDS ARE DERIVED FROM HUMAN EPIDEMIOLOGICAL STUDIES OR ANIMAL STUDIES TO WHICH UNCERTAINTY
FACTORS HAVE BEEN APPLIED (E.G., TO ACCOUNT FOR THE USE OF ANIMAL DATA TO PREDICT EFFECTS ON
HUMANS.) THESE UNCERTAINTY FACTORS HELP ENSURE THAT THE RFDS WILL NOT UNDERESTIMATE THE
POTENTIAL FOR ADVERSE NONCARCINOGENIC EFFECTS TO OCCUR.
TO CHARACTERIZE THE TOXICOLOGIC PROPERTIES OF DIOXINS-DIBENZOFURANS, THE TOXICOLOGICAL
EQUIVALENT FACTOR (TEF) APPROACH, AS DEVELOPED BY EPA, WAS USED TO RELATE ALL DIOXIN/FURAN
CONGENERS TO THE MORE TOXIC 2,3,7,8-TCDD. CARCINOGENIC PAHS WERE ALL ASSIGNED THE CARCINOGENIC
POTENCY FACTOR (CPF) DEVELOPED WITH BENZO(A)PYRENE DATA BY EPA. PHTHALATES WERE REPRESENTED
TOXICOLOGICALLY USING CRITICAL TOXICITY VALUES FOR BIS-(2-ETHYLHEXYL)-PHTHALATE AND PHENOLIC
COMPOUNDS BY TOXICOLOGIC PARAMETERS DERIVED FOR 2,4-DIMETHYLPHENOL. COMPOUND-SPECIFIC
TOXICOLOGIC DATA WERE USED FOR PENTACHLOROPHENOL. RISKS FOR EXPOSURE TO NON-CARCINOGENIC PAHS
WERE CHARACTERIZED USING TOXICOLOGIC PARAMETERS FOR NAPHTHALENE.
6.4 RISK CHARACTERIZATION SUMMARY
THE RECEPTOR POPULATION WAS SEPARATED INTO FOUR AGE GROUPS. THEY ARE 1 TO 6, 7 TO 11, 12 TO 18,
AND OVER 18 YEARS OLD. SEPARATE SKIN SURFACE RANGES, BODY WEIGHT RANGES, EXPOSURE FREQUENCIES,
AND SOIL INGESTION RATES WERE USED FOR EACH GROUP. NON-CARCINOGENIC RISKS WERE CALCULATED FOR
EACH AGE GROUP. LIFETIME CANCER RISKS WERE CALCULATED BY SUMMING THE RISKS FOR EACH AGE GROUP.
EXCESS LIFETIME CANCER RISKS ARE DETERMINED BY MULTIPLYING THE INTAKE LEVEL WITH THE CANCER
POTENCY FACTOR. THESE RISKS ARE PROBABILITIES THAT ARE GENERALLY EXPRESSED IN SCIENTIFIC
NOTATION (E.G., 1X10(-6)). AN EXCESS LIFETIME CANCER RISK OF 1X10(-6) INDICATES THAT, AS A
PLAUSIBLE UPPER BOUND, AN INDIVIDUAL HAS A ONE IN ONE MILLION CHANCE OF DEVELOPING CANCER AS A
RESULT OF SITE-RELATED EXPOSURE TO A CARCINOGEN OVER A 70-YEAR LIFETIME UNDER THE SPECIFIC
EXPOSURE CONDITIONS AT A SITE.
POTENTIAL CONCERN FOR NONCARCINOGENIC EFFECTS OF A SINGLE CONTAMINANT IN A SINGLE MEDIUM IS
EXPRESSED AS THE HAZARD QUOTIENT (HQ). THE HQ IS THE RATIO OF THE ESTIMATED INTAKE DERIVED FROM
THE CONTAMINANT CONCENTRATION IN A GIVEN MEDIUM TO THE CONTAMINANT'S REFERENCE DOSE. BY ADDING
THE HQS FOR ALL CONTAMINANTS WITHIN A MEDIUM OR ACROSS ALL MEDIA TO WHICH A GIVEN POPULATION MAY
REASONABLY BE EXPOSED, THE HAZARD INDEX (HI) CAN BE GENERATED. THE HI PROVIDES A USEFUL
REFERENCE POINT FOR GAUGING THE POTENTIAL SIGNIFICANCE OF MULTIPLE CONTAMINANT EXPOSURES WITHIN
A SINGLE MEDIUM OR ACROSS MEDIA.
THE TOTAL UPPERBOUND LIFETIME CARCINOGENIC RISKS FROM DERMAL-INGESTION EXPOSURE OF BOTH
CARCINOGENIC PAHS AND DIOXINS IN THE VARIOUS STUDY AREAS ARE:
AREA
MEDIAN
ON-SITE
RESIDENTIAL
DITCH
CONDOMINIUM BLOCK
2.6
1.6
2.7
7.4
X
X
X
X
10(-4)
10(-6)
10(-6)
10(-5)
90TH PERCENTILE ESTIMATES
1.2
6.6
1.2
1.9
X
X
X
X
10(-3)
10(-6)
10(-4)
10(-4)
THE RISK RESULTS ALSO INDICATE THE POTENTIAL FOR NON-CARCINOGENIC HEALTH RISKS (IN ALL CASES DUE
TO EXPOSURE TO DIOXINS-DIBENZOFURANS) IN AREAS I AND IV. NON-CARCINOGENIC RISKS ARE NOT
PREDICTED TO BE A HAZARD FOR EXPOSURE TO CONTAMINATED SOIL IN AREAS II AND III. THE MEDIAN
UPPERBOUND CANCER RISK ESTIMATE FOR EXPOSURE TO AIRBORNE PARTICULATES DERIVED FROM SITE SOIL WAS
6.1X10(-7). THE 90TH PERCENTILE RISK ESTIMATE WAS 4.1X10(-6).
THE VEGETABLE PATHWAY DOES NOT APPEAR TO BE A PATHWAY OF CONCERN BASED ON ANALYTICAL DATA
COLLECTED DURING THE VEGETABLE GARDEN STUDY OF 1985. HOWEVER, TO ASSESS PRESENT CONDITIONS AND
TO PROVIDE ASSURANCE OF THE PROTECTION OF PUBLIC HEALTH AND THE ENVIRONMENT, LIMITED SAMPLING
WILL BE CONDUCTED DURING THE REMEDIAL DESIGN.
6.5 REMEDIATION GOALS
OF THE SIX SUBSTANCES SELECTED AS INDICATOR COMPOUNDS, ONLY THE TOTAL CARCINOGENIC PAHS,
DIOXINS, AND PCP WERE PRESENT IN CONCENTRATIONS REQUIRING REMEDIATION CONSIDERATIONS. SURFACE
SOIL REMEDIATION GOALS FOR THE TOTAL CARCINOGENIC PAHS WERE DEVELOPED BASED ON THE RISK
ASSESSMENT AND THE FOLLOWING FACTORS:
A.
THE CANCER POTENCY FACTOR (CPF) FOR BENZO(A)PYRENE IS VERY CONSERVATIVE AND A
REDUCTION OF THIS VALUE IS BEING CONSIDERED BY EPA;
B.
THE SUM CARCINOGENIC PAHS OF THE CONCENTRATIONS DETECTED IN SITE SAMPLES WERE
COMPRISED OF ONLY 5 TO 10% BENZO(A)PYRENE WITH INDIVIDUAL PAHS HAVING A MUCH LOWER
CARCINOGENIC POTENCY COMPRISING THE MAJOR PERCENTAGE;
C.
NATURAL DEGRADATION OF PAH COMPOUNDS OCCURS IN SOIL, AND USING A STANDARD 1.25 YEARS
OF HALF-LIFE ASSUMPTION, THE CALCULATED DECAY RATE INDICATES THAT SOIL CONCENTRATION
WOULD DECREASE NATURALLY BY AN ORDER OF MAGNITUDE ABOUT EVERY FIVE YEARS.
BASED ON THIS EVALUATION, THE SURFACE SOIL REMEDIATION GOAL FOR THE CARCINOGENIC PAHS AT THE
SITE WAS ESTABLISHED TO BE 50 PARTS PER MILLION (PPM).
SURFACE SOIL REMEDIATION GOALS FOR DIOXINS WERE ALSO DETERMINED. APPLYING THE MEDIAN EXPOSURE
ESTIMATES, A SOIL LEVEL OF 0.3 PARTS PER BILLION (PPB) 2,3,7,8-TCDD TOXICITY EQUIVALENCY
CONCENTRATION WOULD YIELD AN UPPER RISK OF 1X10(-5). THE USE OF THE MEDIAN ESTIMATE AND THE
1X10(-5) IS CONSIDERED TO BE APPROPRIATE FOR PROTECTION OF HUMAN HEALTH. HOWEVER, THE CPF FOR
2,3,7,8-TCDD IS VERY CONSERVATIVE AND UNDER CONSIDERATION BY THE AGENCY FOR A TENFOLD (PLUS)
DECREASE IN ITS NUMERICAL VALUE.
ALSO, ATSDR/CDC HAS INDICATED THAT 1 PPB 2,3,7,8-TCDD IS A REASONABLE SOIL LEVEL TO BEGIN
CONSIDERATION OF REMEDIAL ACTION. THEREFORE, THE SOIL CLEANUP LEVEL WAS ESTABLISHED AT 2.5 PPB
FOR 2,3,7,8-TCDD TOXICITY EQUIVALENCY FOR THIS SITE.
EPA'S INTEROFFICE WORK GROUP, CARCINOGEN RISK ASSESSMENT VERIFICATION ENDEAVOR (CRAVE), AND THE
OFFICE OF RESEARCH AND DEVELOPMENT HAVE RECENTLY RECLASSIFIED PCP FROM A "D" TO A "B2"
(PROBABLE) HUMAN CARCINOGEN. A CANCER POTENCY FACTOR HAS YET TO BE DETERMINED BUT ORD HAS
INDICATED THAT THE UPPER LIMIT OF THE RANGE OF VALUES BEING CONSIDERED IS 1.0. APPLYING THIS
POTENCY VALUE OF 1.0, MEDIAN EXPOSURE VALUES, AND THE 1 X 10(-5) UPPER BOUND RISK LEVEL
DETERMINED FOR CPAHS AND DIOXIN, THE SOIL CLEANUP LEVEL FOR PCP IS 30 PPM.
THE ANALYTICAL DATA WAS EXAMINED BASED ON THE CLEANUP LEVELS FOR THE CARCINOGENIC PAHS, PCP, AND
THE DIOXIN/FURAN. ALL SAMPLE RESULTS WERE BELOW THE 2,3,7,8-TCDD EQUIVALENTS (1987 TEQS)
CLEANUP LEVEL OF 2.5 PPB. FIGURE 6.1 DEPICTS THE REMEDIATION AREAS BASED ON PCP AND THE
CARCINOGENIC PAHS.
ACTUAL OR THREATENED RELEASES OF HAZARDOUS SUBSTANCES FROM THIS SITE, IF NOT ADDRESSED BY
IMPLEMENTING THE RESPONSE ACTION SELECTED IN THIS ROD, MAY PRESENT AN UNACCEPTABLE RISK TO
PUBLIC HEALTH, WELFARE, OR THE ENVIRONMENT.
#DA
7.0 DESCRIPTION OF ALTERNATIVES
THE FOLLOWING ALTERNATIVES FOR REMEDIATION WERE EVALUATED IN THE POST FEASIBILITY STUDY REPORT:
1)
2)
3)
NO ACTION
CAPPING/LANDFILLING
FRENCH DRAIN SYSTEM
4)
5)
6)
7)
8)
9)
10)
GROUND WATER PUMP AND TREAT
SOLIDIFICATION/FIXATION
ON-SITE INCINERATION
BIOREMEDIATION: SLURRY PHASE
BIOREMEDIATION: SOLID PHASE
BIOREMEDIATION: IN SITU
LOW TEMPERATURE THERMAL AERATION
ALTERNATIVES 1, 3, 4, 7, 8, AND 9 WERE DEVELOPED TO ADDRESS THE CONTAMINATED GROUND WATER AND
SOLIDIFIED SOIL AT THE SITE. ALTERNATIVES 1, 2, 5, 6, 7, 8, 9, AND 10 WERE DEVELOPED TO ADDRESS
THE SURFACE SOIL CONTAMINATION. BASED ON THE CLEANUP LEVELS DEVELOPED FOR THE AMERICAN CREOSOTE
WORKS SITE, THE ESTIMATED VOLUME (WORST CASE ESTIMATE) TO BE REMEDIATED IS 23,000 CUBIC YARDS.
ADDITIONAL SAMPLING WILL BE CONDUCTED DURING THE REMEDIAL DESIGN PHASE TO FURTHER DEFINE THE
VOLUME TO BE REMEDIATED.
7.1 ALTERNATIVE 1:
NO ACTION
THE SUPERFUND PROGRAM REQUIRES THAT THE NO ACTION ALTERNATIVE BE CONSIDERED AT EVERY SITE.
UNDER THE NO ACTION ALTERNATIVE, EPA WOULD TAKE NO FURTHER ACTION AT THE SITE TO CONTROL THE
SOURCE OF CONTAMINATION. THE NO ACTION ALTERNATIVE SERVES AS A BASELINE WITH WHICH OTHER
ALTERNATIVES CAN BE COMPARED.
POTENTIAL HEALTH RISKS ASSOCIATED WITH CURRENT EXPOSURE PATHS WOULD REMAIN ON SITE. THIS
ALTERNATIVE EXCEEDS THE TARGET RISK RANGE AND DOES NOT ATTAIN APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS (ARARS). THE NO ACTION ALTERNATIVE PROPOSES LEAVING THE SITE IN ITS
PRESENT CONDITION WITHOUT DISTURBING THE CONTAMINATED SURFACE SOIL. ASSOCIATED WITH THE NO
ACTION ALTERNATIVE WOULD BE CONTINUED LONG-TERM MONITORING OF GROUND AND SURFACE WATER,
CONSTRUCTION OF A PERIMETER FENCE, POSTING OF WARNING SIGNS ON THIS FENCE, AND GROUND WATER AND
LAND USE RESTRICTIONS. A PUBLIC HEALTH ASSESSMENT WOULD BE PERFORMED EVERY FIVE (5) YEARS TO
EVALUATE POTENTIAL CHANGES IN RISK ASSOCIATED WITH NO ACTION.
THE ESTIMATED PRESENT WORTH COST OF THIS ALTERNATIVE IS $408,000 WHICH INCLUDES $330,000 FOR
OPERATION AND MAINTENANCE.
7.2 ALTERNATIVE 2:
CAPPING/LANDFILLING
THE CAPPING/LANDFILLING ALTERNATIVE WOULD CONSIST OF PLACING THE CONTAMINATED SOIL INTO A
DOUBLE-LINED LAND VAULT WITH A PERMANENT CAP OVER THE FACILITY IN ACCORDANCE WITH THE RESOURCE
CONSERVATION AND RECOVERY ACT (RCRA) REGULATIONS. THE LANDFILL WOULD OCCUPY ABOUT FIVE (5)
ACRES OF THE SITE AND WOULD RISE TO ABOUT FIVE (5) FEET ABOVE THE EXISTING GROUND LEVEL,
ASSUMING THE TOTAL VOLUME OF WASTE MATERIAL DISPOSED IS 23,000 CUBIC YARDS. THE LANDFILL WOULD
BE VEGETATED AND WOULD HAVE A PERIMETER DRAINAGE DITCH AND A PERIMETER ROAD. A NEW SURFACE
DRAINAGE SYSTEM WILL BE NEEDED TO CONTROL RUNON AND RUNOFF. A 24-INCH THICK CLAY CAPSULE WILL
BE REQUIRED. OTHER LARGE VOLUMES OF CLEAN FILL AND DRAINAGE MATERIAL WILL HAVE TO BE BROUGHT ON
TO THE SITE. ALSO, AN ADDITIONAL FENCE WOULD BE BUILT IMMEDIATELY, SURROUNDING THE VAULT'S
PERIMETER ROAD TO PRESERVE THE LANDFILL'S INTEGRITY.
A SEMI-ANNUAL MONITORING PROGRAM TO ANALYZE FOR THOSE GROUND WATER CONSTITUENTS OF CONCERN WOULD
BE IMPLEMENTED FOR A PERIOD OF FIVE (5) YEARS. A PUBLIC HEALTH ASSESSMENT WOULD BE CONDUCTED BY
EPA EVERY FIVE (5) YEARS FOLLOWING REMEDIAL ACTION COMPLETION. FOLLOWING THE FIRST ASSESSMENT,
MONITORING WOULD CONTINUE ANNUALLY FOR AN ADDITIONAL TWENTY-FIVE (25) YEARS PROVIDED THE PUBLIC
HEALTH ASSESSMENT DOES NOT IDENTIFY A NEED FOR FURTHER REMEDIAL ACTION OR MONITORING.
THIS ALTERNATIVE WOULD SERVE AS AN EFFECTIVE MEASURE TOWARD PREVENTING EXPOSURE BY INGESTION OF
CONTAMINATED SOIL. THE VAULT MUST BE MAINTAINED IN PERPETUITY AND WILL BE AN EYESORE NEAR PRIME
FLORIDA WATER FRONT PROPERTIES. THIS ALTERNATIVE DOES NOT MEET CERCLA/SARA'S PREFERENCE FOR
TREATMENT OF CONTAMINANTS BUT WOULD SIGNIFICANTLY REDUCE THEIR MOBILITY.
THE TOTAL PRESENT VALUE COST FOR THIS ALTERNATIVE IS ESTIMATED AT $2,250,000 WHICH INCLUDES
$330,000 FOR OPERATION AND MAINTENANCE.
7.3 ALTERNATIVE 3:
FRENCH DRAIN SYSTEM
BECAUSE THIS OPERABLE UNIT IS ONLY ADDRESSING REMEDIATION ALTERNATIVES FOR THE CONTAMINATED
SURFACE SOIL, THE FRENCH DRAIN ALTERNATIVE WILL NOT BE DISCUSSED IN THIS ROD SINCE IT ADDRESSES
THE EXISTING GROUND WATER CONTAMINATION.
7.4 ALTERNATIVE 4:
GROUND WATER PUMP AND TREAT
BECAUSE THIS OPERABLE UNIT IS ONLY ADDRESSING REMEDIATION ALTERNATIVES FOR THE CONTAMINATED
SURFACE SOIL, THE GROUND WATER PUMP AND TREAT ALTERNATIVE WILL NOT BE DISCUSSED IN THIS ROD
SINCE IT ADDRESSES THE EXISTING GROUND WATER CONTAMINATION.
7.5 ALTERNATIVE 5:
SOLIDIFICATION/FIXATION
A PORTLAND CEMENT BASED POZZOLAN SOLIDIFICATION/FIXATION OF CONTAMINATED SURFACE SOIL WOULD BE
ACCOMPLISHED BY EXCAVATING THE CONTAMINATED AREAS TO DEPTHS DETERMINED BY THE LATEST (1988)
SAMPLING EFFORT. THE TOTAL ESTIMATED VOLUME OF CONTAMINATED SOIL TO BE SOLIDIFIED IS 23,000
CUBIC YARDS. THE SOLIDIFIED MATERIAL WOULD THEN BE DISPOSED OF BY BACKFILLING INTO PREVIOUSLY
EXCAVATED AREAS OF THE SITE. STANDARD CONSTRUCTION EQUIPMENT WOULD BE UTILIZED. WHEN
SOLIDIFICATION IS COMPLETE, A 12-INCH THICK VEGETATED COVER WOULD BE PLACED OVER THE SOLIDIFIED
MASS.
TREATABILITY OR BENCH-SCALE STUDIES WOULD BE REQUIRED TO DETERMINE THE PROPER WASTE POZZOLAN
RATING AND THE PARTICULAR POZZOLAN CONSTITUENTS.
IN THE FIRST FIVE (5) YEARS FOLLOWING COMPLETION OF THIS ALTERNATIVE, SEMI-ANNUAL GROUND WATER
MONITORING WOULD OCCUR. AT FIVE (5) YEARS, A PUBLIC HEALTH ASSESSMENT WOULD BE CONDUCTED BY
EPA. FOLLOWING THIS ASSESSMENT, MONITORING ACTIVITIES WOULD BE TERMINATED, PROVIDED THAT THE
PUBLIC HEALTH ASSESSMENT DOES NOT IDENTIFY A NEED FOR FURTHER REMEDIAL ACTION OR MONITORING.
GROUND WATER USE RESTRICTIONS WOULD BE IMPOSED WITHIN A REASONABLE DISTANCE FROM THE SITE. LAND
USE RESTRICTIONS WOULD BE IMPOSED ON THE SITE TO PREVENT DISTURBANCE OF THE SOLIDIFIED MATERIAL.
SUPPORT ACTIVITIES INCLUDE REMOVING DEBRIS, REPAIRING THE FENCE, CLEARING AND GRUBBING THE
VEGETATION, AND GRADING THE SITE.
THIS ALTERNATIVE SHOULD EFFECTIVELY BREAK THE INGESTION EXPOSURE PATHWAY.
SOLIDIFICATION/FIXATION, AN ESTABLISHED TECHNOLOGY WITH IMPROVING TECHNIQUES WOULD IMMOBILIZE
CONTAMINANTS, MINIMIZE POTENTIAL LEACHING, AND IMPROVE THE HANDLING CHARACTERISTICS OF THE
CONTAMINATED MEDIA; HOWEVER, IT WOULD INCREASE THE VOLUME. THE ORGANIC COMPOUNDS WOULD NOT
INTERFERE WITH THE SETTING, CURING, AND PERFORMANCE OF THE SOLIDIFIED MATERIAL.
SOLIDIFICATION/FIXATION PROCESSES ARE SUCCESSFUL WITH SOIL CONTAINING UP TO 10,000 PPM PAHS; THE
BONDING OF CONTAMINANTS TO THE STABILIZING AGENT SHOULD NOT BE IMPACTED BY LONG-TERM
SITE-SPECIFIC CHARACTERISTICS.
THE TOTAL PRESENT VALUE COST FOR THIS ALTERNATIVE IS ESTIMATED TO BE $3,249,600 WHICH INCLUDES
$339,600 FOR OPERATION AND MAINTENANCE.
7.6 ALTERNATIVE 6:
ON-SITE INCINERATION
PRIOR TO INCINERATION, ALL OF THE WASTE WOULD BE EXCAVATED AND SCREENED. SIZE REDUCTION
EQUIPMENT SUCH AS SHREDDERS WOULD BE USED TO REDUCE SOLID PARTICLE SIZE. DURING EXCAVATION,
TEMPORARY EROSION CONTROL DEVICES WOULD BE REQUIRED TO PREVENT DETRIMENTAL EFFECTS TO THE
SURFACE WATER QUALITY SOUTH AND SOUTHEAST OF THE SITE. SPECIFIC INCINERATOR UNIT AVAILABILITY
IS UNCERTAIN; HOWEVER, IT IS PROBABLE THAT DEMAND FOR UNITS WOULD DICTATE SUPPLY. A NUMBER OF
PORTABLE ROTARY KILN INCINERATORS ARE AVAILABLE WITH CAPACITIES UP TO 500 TONS PER DAY. IF THIS
ALTERNATIVE IS USED, IT WOULD BE NECESSARY TO CONDUCT TEST BURNS. POLLUTION CONTROL EQUIPMENT,
SUCH AS CYCLONES AND SCRUBBERS, WOULD BE NECESSARY TO COLLECT AND TREAT EXHAUST GASES AND
SUSPENDED PARTICULATES. THE LACK OF FINE PARTICLES (EXCEPT FOR PORTIONS OF THE CONTAMINATED
CLAY CAP ALREADY IN PLACE) IN SOIL FEEDS WILL NOT RESULT IN HIGH PARTICULATE LOADING IN FLUE
GASES. THIS EXCESSIVE LOADING WOULD OCCUR WITH FINE PARTICLES DUE TO THE TURBULENCE IN THE
ROTARY KILN (IF A ROTARY KILN INCINERATOR IS UTILIZED). THEREFORE, POLLUTION CONTROL ACTIVITIES
CAN BE EXPECTED TO BE OF AVERAGE INTENSITY AT THE SITE.
A SEMI-ANNUAL GROUND WATER MONITORING PROGRAM TO ANALYZE FOR THOSE GROUND WATER CONSTITUENTS OF
CONCERN WOULD BE IMPLEMENTED FOR A PERIOD OF FIVE (5) YEARS AFTER THE COMPLETION OF THE
INCINERATION. AT THAT TIME A PUBLIC HEALTH ASSESSMENT WOULD BE CONDUCTED BY EPA.
FOLLOWING THIS ASSESSMENT, MONITORING WOULD BE TERMINATED, PROVIDED THE PUBLIC HEALTH ASSESSMENT
DOES NOT IDENTIFY A NEED FOR FURTHER REMEDIAL ACTION OR MONITORING. GROUND WATER USE
RESTRICTIONS WOULD BE IMPOSED WITHIN A REASONABLE DISTANCE OF THE SITE IN KEEPING WITH THE
ESTABLISHMENT OF GROUND WATER QUALITY STANDARDS.
THIS ALTERNATIVE WOULD PERMANENTLY AND EFFECTIVELY DESTROY THE CONTAMINATION PRESENT IN THE
SURFACE SOIL THAT EXCEED CLEANUP GOALS. ALL RISK OF EXPOSURE BY INGESTION OF CONTAMINATED SOIL
WOULD BE ELIMINATED. INCINERATION IS A PROVEN TECHNOLOGY AT HAZARDOUS WASTE SITES AND REDUCES
TOXICITY, MOBILITY, AND VOLUME OF HAZARDOUS MATERIALS. THIS ALTERNATIVE MEETS ALL ARARS.
THE TOTAL PRESENT VALUE COST FOR THIS ALTERNATIVE IS ESTIMATED TO BE $9,990,000 WHICH INCLUDES
$330,000 FOR OPERATION AND MAINTENANCE.
7.7 ALTERNATIVE 7:
BIOREMEDIATION - SLURRY PHASE
THIS TECHNOLOGY INVOLVES THE TREATMENT OF CONTAMINATED SURFACE SOIL IN A LARGE (MOBILE)
BIOREACTOR. THIS SYSTEM MAINTAINS INTIMATE MIXING AND CONTACT OF MICROORGANISMS WITH THE
HAZARDOUS COMPOUNDS AND CREATES THE APPROPRIATE ENVIRONMENTAL CONDITIONS FOR OPTIMIZING
MICROBIAL BIODEGRADATION OF TARGET CONTAMINANTS. THERE MAY BE AIR EMISSIONS FROM THE BIOREACTOR
WHICH MAY CAUSE COMPLAINTS FROM THE COMMUNITY. THE BIOREACTOR WOULD HAVE TO BE ENCLOSED AND AIR
POLLUTION CONTROL EQUIPMENT UTILIZED TO MITIGATE THE AIR EMISSIONS FROM THE BIOREACTOR.
THE TOTAL VOLUME OF CONTAMINATED SURFACE SOIL IS ESTIMATED AT 23,000 CUBIC YARDS. THE SOIL
WOULD HAVE TO BE EXCAVATED AND SCREENED. EXCAVATION OF THE CONTAMINATED SOIL WOULD REQUIRE
EROSION CONTROL MEASURES TO PREVENT IMPACT TO THE SURFACE WATER QUALITY SOUTH AND SOUTHEAST OF
THE SITE. THE SOIL IS THEN MIXED WITH WATER TO OBTAIN THE APPROPRIATE SLURRY DENSITY. THE
WATER SOURCE WOULD LIKELY BE CONTAMINATED GROUND WATER. THE TYPICAL SOIL SLURRY CONTAINS ABOUT
FIFTY (50) PERCENT SOLIDS BY WEIGHT. THE SLURRY IS MECHANICALLY AGITATED IN THE REACTOR VESSEL
TO KEEP THE SOLIDS SUSPENDED. NUTRIENTS, OXYGEN, AND PH CONTROL CHEMICALS MAY BE ADDED TO
MAINTAIN OPTIMUM CONDITIONS. MICROORGANISMS MAY BE ADDED TO MAINTAIN THE CORRECT CONCENTRATION
OF BIOMASS. THE VOLUME OF THE BIOREACTION AND THE RESIDENCE TIME FOR EACH BATCH WILL DETERMINE
THE AMOUNT OF TIME NECESSARY TO BIOTREAT THE CONTAMINATED MATERIAL. ONCE BIODEGRADATION OF THE
CONTAMINANTS IS COMPLETED, THE TREATED SLURRY IS DEWATERED. THE RESIDUAL WATER MAY REQUIRE
FURTHER TREATMENT PRIOR TO DISPOSAL. FUGITIVE AIR EMISSIONS OF VOCS CAN BE CONTROLLED BY
ENCLOSING THE BIOREACTOR. THREE OR MORE COMPANIES HAVE WORKING SLURRY-PHASE BIOREACTORS
IMMEDIATELY AVAILABLE FOR SCHEDULING.
A PREREQUISITE FOR THE USE OF THE SLURRY-PHASE BIOREACTOR MAY BE THE DESIGN AND CONSTRUCTION OF
A GROUND WATER EXTRACTION SYSTEM SO THAT GROUND WATER MAY BE USED FOR SLURRY WATER. ALSO,
FURTHER WATER TREATMENT MAY BE NECESSARY BEFORE GROUND WATER MAY BE SENT TO A PUBLICLY OWNED
TREATMENT WORKS (POTW) OR DISPOSED OF IN ANOTHER FASHION.
THIS ALTERNATIVE WOULD PERMANENTLY AND EFFECTIVELY DESTROY THE CONTAMINATION IN THE SURFACE
SOIL. ALL RISK OF EXPOSURE BY INGESTION OF CONTAMINATED SOIL WOULD BE ELIMINATED. SLURRY-PHASE
BIODEGRADATION IS A PROVEN TECHNOLOGY AT HAZARDOUS WASTE SITES AND REDUCES THE TOXICITY,
MOBILITY, AND VOLUME OF HAZARDOUS CONTAMINANTS IN SOIL AND GROUND WATER.
THE DECANTED GROUND WATER RESULTING FROM THE SETTLING OF THE BIOREACTOR SLUDGE MAY BE REUSED IN
THE BIOREACTOR OR BE TESTED AND DISPOSED BY SIMPLY BEING SENT TO THE LOCAL POTW.
A SEMI-ANNUAL MONITORING PROGRAM TO ANALYZE FOR THOSE CONSTITUENTS OF CONCERN WOULD BE
IMPLEMENTED FOR A PERIOD OF FIVE (5) YEARS UPON COMPLETION OF THE REMEDY. A PUBLIC HEALTH
ASSESSMENT WOULD BE CONDUCTED BY EPA AT THE END OF THE FIVE (5) YEARS. FOLLOWING THIS
ASSESSMENT, MONITORING ACTIVITIES WOULD BE TERMINATED, PROVIDED THAT THE PUBLIC HEALTH
ASSESSMENT DOES NOT IDENTIFY A NEED FOR FURTHER REMEDIAL ACTION OR MONITORING. THIS ALTERNATIVE
MEETS ALL ARARS.
THE TOTAL PRESENT VALUE COST FOR THIS ALTERNATIVE IS ESTIMATED TO BE $3,258,000 WHICH INCLUDES
$330,000 FOR OPERATION AND MAINTENANCE.
7.8 ALTERNATIVE 8:
BIOREMEDIATION - SOLID PHASE
WITH THIS TECHNOLOGY, THE CONTAMINATED SURFACE SOIL (23,000 CUBIC YARDS) WOULD BE EXCAVATED,
DISAGGREGATED, AND SCREENED AS IN THE DESCRIPTION OF THE SLURRY-PHASE BIOREMEDIATION AND
STOCKPILED IN A LINED CONTAMINANT AREA ON-SITE. EXCAVATION OF SOIL WOULD REQUIRE TEMPORARY
EROSION CONTROL MEASURES TO PRESERVE SURFACE WATER QUALITY SOUTH AND SOUTHWEST OF THE SITE.
THE ON-SITE EXCAVATED AREAS TO BE USED FOR A LAND TREATMENT AREA WOULD BE FILLED AND LEVELED
WITH CLEAN FILL. THE TREATMENT AREA WOULD HAVE BEEN GRADED TO FLOW WATER AND LEACHATE TO ONE
CORNER OF THE AREA. THE LAND TREATMENT AREA WOULD BE LINED WITH A HIGH DENSITY POLYETHYLENE
(HDPE) GEOMEMBRANE LINER WITH WELDED SEAMS. OVER THE LINER, FLAT PERFORATED PLASTIC PIPE
COVERED WITH FILTER FABRIC WOULD FORM A DRAINAGE SYSTEM TO CONDUCT WATER AND LEACHATE TO A
RETENTION POND. THE LINER AND DRAINAGE SYSTEM WOULD BE COVERED WITH AT LEAST SIX (6) INCHES OF
CLEAN SAND TO PROMOTE DRAINAGE. CONTAMINATED SOIL, HAVING BEEN DISAGGREGATED, WOULD BE LAID ON
THE SAND IN SIX (6) INCH LIFTS.
LOCAL NATURALLY-OCCURRING BACTERIA WOULD BE USED TO SEED THE SPREAD SOIL AND NUTRIENTS, AND
MOISTURE WOULD BE ADDED TO PROMOTE THE GROWTH OF BIOMASS. LEACHATE AND DRAIN WATER WOULD BE
COLLECTED AND SPRAYED OVER THE TREATMENT AREA WHEN THE SOIL MOISTURE CONTENT FELL TOO LOW. THE
SOIL WOULD BE TILLED PERIODICALLY TO FACILITATE SOIL PARTICLE/BACTERIA CONTACT. SOME PAHS WOULD
BE ELIMINATED BY PHOTOLYSIS AND BY VOLATILIZATION DUE TO THE DIRECT SUNLIGHT AND HOT WEATHER.
AIR EMISSIONS MAY BE A PROBLEM AT CERTAIN TIMES AND MAY CAUSE COMPLAINTS FROM NEARBY RESIDENCES.
THE LAND TREATMENT AREA AND THE
ALREADY EXISTS AROUND THE SITE,
CUBIC YARDS OF PAH-CONTAMINATED
COULD BE LEFT WHERE THEY LAY OR
STOCKPILE AREA WOULD OCCUPY ALL OF THE SITE AREA. A FENCE
BUT MAY HAVE TO BE RE-SET OR ADDED TO. TREATMENT OF 23,000
SOIL WOULD PROBABLY TAKE AT LEAST TWO (2) YEARS. TREATED SOIL
SPREAD OVER THE ENTIRE SITE.
CONTINUOUS MONITORING OF THE DISSOLVED OXYGEN, PH, NUTRIENTS, SOIL MOISTURE CONTENT, ETC., WOULD
BE REQUIRED. A TEMPERATURE RANGE OF 50-100 DEGREES F WOULD BE REQUIRED. AIR EMISSIONS FROM THE
TREATMENT AREA DUE TO VOLATILIZATION WOULD BE SIGNIFICANT JUST AFTER THE INITIAL SPREADING OF
THE SOIL WHEN LEVELS OF SOIL CONTAMINATION ARE STILL HIGH.
CONTAMINATED SOIL WOULD BE EFFECTIVELY TREATED AND THE INGESTION EXPOSURE PATHWAY BROKEN.
TIME, SOLID-PHASE BIOREMEDIATION WOULD SATISFY MOST ARARS AT THE SITE.
GIVEN
A SEMI-ANNUAL MONITORING PROGRAM TO ANALYZE FOR THOSE CONSTITUENTS OF CONCERN WOULD BE
IMPLEMENTED FOR A PERIOD OF FIVE (5) YEARS. A PUBLIC HEALTH ASSESSMENT WOULD BE CONDUCTED AT
THAT TIME. FOLLOWING THIS ASSESSMENT, MONITORING ACTIVITIES WOULD BE TERMINATED, PROVIDED THAT
THE PUBLIC HEALTH ASSESSMENT DOES NOT IDENTIFY A NEED FOR FURTHER REMEDIAL ACTION OR MONITORING.
GROUND WATER USE RESTRICTIONS WOULD BE IMPOSED WITHIN A REASONABLE DISTANCE FROM THE SITE. LAND
USE RESTRICTIONS WOULD BE IMPOSED TO PREVENT USE OF THE SITE FOR RESIDENTIAL PURPOSES.
IMPLEMENTATION TIME FOR THIS ALTERNATIVE IS EXPECTED TO BE SEVERAL YEARS. HOWEVER, THE
PROJECTED UNIT COSTS MAKE THIS ALTERNATIVE COMPETITIVE WITH OTHER TECHNOLOGIES. THIS
ALTERNATIVE WOULD BE AS EFFECTIVE TOWARDS THE PROTECTION OF PUBLIC HEALTH AND THE ENVIRONMENT AS
OTHER TREATMENT TECHNOLOGIES. IN ADDITION, CLIMATIC CONDITIONS OF THE SITE ARE FAVORABLE FOR
THIS TYPE OF TREATMENT.
THE TOTAL PRESENT VALUE COST FOR THIS ALTERNATIVE IS ESTIMATED TO BE $2,275,000 WHICH INCLUDES
$319,000 FOR OPERATION AND MAINTENANCE.
7.9 ALTERNATIVE 9:
BIOREMEDIATION - IN SITU
IN SITU BIOREMEDIATION WOULD REQUIRE THE DESIGN OF A GROUND WATER PUMPING AND REINJECTION SYSTEM
BOTH ON-SITE AND OFF-SITE. SOIL WOULD NOT REQUIRE EXCAVATION. THE NATURAL BIODEGRADATION
PROCESS WOULD BE ENHANCED BY INJECTING NUTRIENTS (I.E., PHOSPHORUS, NITROGEN, ETC.), OXYGEN
(E.G., HYDROGEN PEROXIDE), AND EVEN CULTURED BACTERIAL STRAINS. ADJUSTMENTS TO PH MAY ALSO BE
MADE. THE GROUND WATER PUMPING AND REINJECTION WOULD CIRCULATE NUTRIENTS AND OXYGEN THROUGH A
CONTAMINATED AQUIFER AND THE ASSOCIATED SOIL. AEROBIC BIODEGRADATION GENERALLY PROCEEDS MORE
RAPIDLY THAN ANAEROBIC BIODEGRADATION.
IN SITU BIOREMEDIATION WOULD DIRECTLY ATTACK BOTH SOIL AND GROUND WATER CONTAMINATION. GROUND
WATER USE RESTRICTIONS WOULD BE IMPOSED WITHIN A REASONABLE DISTANCE FROM THE SITE. LAND USE
RESTRICTIONS WOULD NOT NEED TO BE IMPOSED IF BOTH OIL AND GROUND WATER CONTAMINATION WERE
REDUCED TO INSIGNIFICANT LEVELS.
CONTINUOUS MONITORING OF THE DISSOLVED OXYGEN, PH, NUTRIENTS, ETC. WOULD BE REQUIRED.
TEMPERATURES IN THE SUBSURFACE SOIL AND IN GROUND WATER AT VARIOUS DEPTHS WOULD HAVE TO BE
MONITORED. ODORS MAY BE FORTHCOMING FROM THE EXTRACTION/REINJECTION SYSTEM AND MAY CAUSE
COMPLAINTS FROM THE PUBLIC. ODOR MAY BE EMITTED FROM THE PROCESS AREA. GROUND WATER WOULD NOT
BE ABLE TO BE USED FOR DRINKING OR IRRIGATION BY ANYONE IN THE SITE AREA BECAUSE OF THE HIGH
BACTERIAL COUNT AND THE INTERMEDIATE BREAKDOWN PRODUCTS OF THE BIODEGRADATION. HIGH BACTERIAL
COUNT IN THE GROUND WATER DURING PROCESSING WOULD PROHIBIT THE USE OF GROUND WATER EVEN FOR
IRRIGATION.
ROD CLEANUP LEVELS AND ADDITIONAL ALTERNATE CONCENTRATION LEVELS (ACLS) MAY NOT BE ABLE TO BE
COMPLETELY MET BY THIS ALTERNATIVE IN A SHORT PERIOD OF TIME. THE ORIGINAL TIME FOR
IMPLEMENTATION MAY HAVE TO BE EXTENDED.
A SEMI-ANNUAL MONITORING PROGRAM TO ANALYZE FOR THOSE CONSTITUENTS OF CONCERN WOULD BE
IMPLEMENTED FOR A PERIOD OF FIVE (5) YEARS AFTER THE COMPLETION OF THE REMEDIAL ACTION.
A
PUBLIC HEALTH ASSESSMENT WOULD BE CONDUCTED AT THAT TIME. FOLLOWING THIS ASSESSMENT, MONITORING
ACTIVITIES WOULD BE TERMINATED, PROVIDED THAT THE PUBLIC HEALTH ASSESSMENT DOES NOT IDENTIFY A
NEED FOR FURTHER REMEDIAL ACTION OR MONITORING.
THIS ALTERNATIVE SHOULD BE ABLE TO SATISFY MOST ARARS OVER A PERIOD OF TIME.
THE TOTAL PRESENT VALUE COST FOR THIS ALTERNATIVE IS ESTIMATED TO BE $2,299,000 WHICH INCLUDES
$319,000 FOR OPERATION AND MAINTENANCE.
7.10 ALTERNATIVE 10:
LOW TEMPERATURE THERMAL AERATION
TWENTY-THREE THOUSAND (23,000) CUBIC YARDS OF SURFACE OIL WOULD BE EXCAVATED, DISAGGREGATED,
SCREENED, AND STOCKPILED. THE PREPARED SOIL WOULD THEN BE INTRODUCED TO THE LOW TEMPERATURE
THERMAL AERATION (LTTA) EQUIPMENT (PROCESSING EQUIPMENT WHICH WOULD OPERATE AT ITS MAXIMUM
TEMPERATURE OF 800 DEGREES F.) PROCESS RESIDUALS WOULD BE PROCESSED SOIL, ASH FROM THE
AFTERBURNER OR SPENT CARBON, AND STACK GASES. A BENCH-SCALE OR SMALL PILOT-SCALE TEST BURN
WOULD BE NEEDED TO EVALUATE THE TECHNICAL EFFECTIVENESS AND COST-EFFECTIVENESS OF THE PROCESS AT
THIS SITE.
PRESENTLY, WESTON SERVICES, INC. HAS A SYSTEM AVAILABLE WHICH CAN PROCESS UP TO 7.5 TONS/HOUR.
THE PROCESS SHOULD PRODUCE REMOVAL EFFICIENCIES GREATER THAN 90 PERCENT FOR 1, 2, AND 3-RING
PAHS. PAHS WITH FOUR OR MORE RINGS WOULD NEED HIGHER TEMPERATURES FOR VOLATILIZATION. IF
NECESSARY, OTHER TECHNOLOGIES COULD BE USED FOR THESE REMAINING PAHS. STACK GASES WOULD HAVE TO
BE CONTINUOUSLY MONITORED TO ENSURE THAT AIR POLLUTION WAS NOT OCCURRING.
A SEMI-ANNUAL MONITORING PROGRAM TO ANALYZE FOR THOSE CONSTITUENTS OF CONCERN WOULD BE
IMPLEMENTED FOR A PERIOD OF FIVE (5) YEAR AFTER THE COMPLETION OF THE REMEDIAL ACTION. A PUBLIC
HEALTH ASSESSMENT WOULD BE CONDUCTED AT THAT TIME. FOLLOWING THIS ASSESSMENT, MONITORING
ACTIVITIES WOULD BE TERMINATED, PROVIDED THAT THE PUBLIC HEALTH ASSESSMENT DOES NOT IDENTIFY A
NEED FOR FURTHER REMEDIAL ACTION OR MONITORING.
THIS ALTERNATIVE WOULD PROBABLY PERMANENTLY AND EFFECTIVELY STRIP CONTAMINATED SOIL THAT EXCEED
CLEANUP GOALS. ALL RISK OF EXPOSURE BY INGESTION OF CONTAMINATED SOIL WOULD BE ELIMINATED. LOW
TEMPERATURE THERMAL AERATION SHOULD REDUCE THE TOXICITY, MOBILITY, AND VOLUME OF HAZARDOUS
CONSTITUENTS IN THE SOIL. THIS ALTERNATIVE SHOULD SATISFY MOST ARARS.
THE TOTAL PRESENT VALUE COST FOR THIS ALTERNATIVE IS ESTIMATED TO BE $3,048,000 WHICH INCLUDES
$330,000 FOR OPERATION AND MAINTENANCE.
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
THIS SECTION PROVIDES THE BASIS FOR DETERMINING WHICH ALTERNATIVE PROVIDES THE BEST BALANCE OF
TRADE-OFFS WITH RESPECT TO THE EVALUATION CRITERIA. THE MAJOR OBJECTIVE OF THE POST FEASIBILITY
STUDY (FS) WAS TO DEVELOP, SCREEN, AND EVALUATE ALTERNATIVES FOR REMEDIATING THE AMERICAN
CREOSOTE WORKS SITE. THIS DECISION DOCUMENT DEALS WITH THE CONTAMINATED SURFACE SOIL. SEVERAL
REMEDIAL TECHNOLOGIES WERE IDENTIFIED FOR THE SURFACE SOIL CLEANUP. THESE TECHNOLOGIES WERE
SCREENED BASED ON THEIR FEASIBILITY GIVEN THE CONTAMINANTS PRESENT AND THE SITE CHARACTERISTICS.
THOSE WHICH REMAINED AFTER THE INITIAL SCREENING WERE EVALUATED IN DETAIL BASED ON THE NINE
CRITERIA REQUIRED BY SARA. COST WAS USED TO COMPARE ALTERNATIVES ONLY WHEN THEY PROVIDED
SIMILAR DEGREES OF PROTECTION AND TREATMENT. A SUMMARY OF THE RELATIVE PERFORMANCE OF THE
ALTERNATIVES WITH RESPECT TO EACH OF THE NINE CRITERIA IS PROVIDED IN THIS SECTION. A GLOSSARY
OF THE VALUATION CRITERIA IS OFFERED IN TABLE 8.1.
TABLE 8.1
GLOSSARY OF EVALUATION CRITERIA
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT - ADDRESSES WHETHER OR NOT A REMEDY
PROVIDES ADEQUATE PROTECTION AND DESCRIBES HOW RISKS POSED THROUGH EACH PATHWAY ARE ELIMINATED,
REDUCED, OR CONTROLLED THROUGH TREATMENT, ENGINEERING CONTROLS, OR INSTITUTIONAL CONTROLS.
COMPLIANCE WITH ARARS - ADDRESSES WHETHER OR NOT A REMEDY WILL MEET ALL OF THE APPLICABLE OR
RELEVANT AND APPROPRIATE REQUIREMENTS OF OTHER FEDERAL AND STATE ENVIRONMENTAL STATUTES AND/OR
PROVIDES GROUNDS FOR INVOKING A WAIVER.
LONG-TERM EFFECTIVENESS AND PERMANENCE - REFERS TO THE MAGNITUDE OF RESIDUAL RISK AND THE
ABILITY OF A REMEDY TO MAINTAIN RELIABLE PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT OVER
TIME ONCE CLEANUP GOALS HAVE BEEN MET.
REDUCTION OF TOXICITY, MOBILITY, OR VOLUME - IS THE ANTICIPATED PERFORMANCE OF THE TREATMENT
TECHNOLOGIES THAT MAY BE EMPLOYED IN A REMEDY.
SHORT-TERM EFFECTIVENESS - REFERS TO THE SPEED WITH WHICH THE REMEDY ACHIEVES PROTECTION, AS
WELL AS THE REMEDY'S POTENTIAL TO CREATE ADVERSE IMPACTS ON HUMAN HEALTH AND THE ENVIRONMENT
THAT MAY RESULT DURING THE CONSTRUCTION AND IMPLEMENTATION PERIOD.
IMPLEMENTABILITY - IS THE TECHNICAL AND ADMINISTRATIVE FEASIBILITY OF A REMEDY, INCLUDING THE
AVAILABILITY OF MATERIALS AND SERVICES NEEDED TO IMPLEMENT THE CHOSEN SOLUTION.
COST - INCLUDES CAPITAL AND OPERATION AND MAINTENANCE COSTS.
STATE ACCEPTANCE - INDICATES WHETHER THE STATE CONCURS WITH, OPPOSES, OR HAS NO COMMENT ON THE
PREFERRED ALTERNATIVE.
COMMUNITY ACCEPTANCE - WILL BE ASSESSED IN THE RESPONSIVENESS SUMMARY IN THE APPENDIX OF THE
RECORD OF DECISION AFTER REVIEWING THE PUBLIC COMMENTS RECEIVED ON THE POST FEASIBILITY STUDY
AND THE PROPOSED PLAN.
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
ALL OF THE ALTERNATIVES WITH THE EXCEPTION OF THE NO ACTION ALTERNATIVE WOULD PROVIDE ADEQUATE
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT BY ELIMINATING, REDUCING, OR CONTROLLING RISK
THROUGH TREATMENT, ENGINEERING CONTROLS, OR INSTITUTIONAL CONTROLS.
BECAUSE THE NO ACTION ALTERNATIVE WOULD NOT BE PROTECTIVE OF HUMAN HEALTH AND THE ENVIRONMENT,
IT IS NOT CONSIDERED FURTHER IN THIS ANALYSIS AS AN OPTION FOR THE SITE.
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
ALL ALTERNATIVES WOULD MEET THEIR RESPECTIVE APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
OF FEDERAL AND STATE ENVIRONMENTAL LAWS; HOWEVER, ALTERNATIVE 2 - RCRA LANDFILLING, DOES NOT
MEET SARA'S (SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT) PREFERENCE FOR TREATMENT.
LONG-TERM EFFECTIVENESS AND PERMANENCE
LONG-TERM EFFECTIVENESS AND PERMANENCE WOULD BE PROVIDED BY ALL ALTERNATIVES THROUGH ELIMINATION
OF RISK POSED BY CONTAMINANTS AT THE ACW SITE.
REDUCTION OF TOXICITY, MOBILITY, OR VOLUME
ALTERNATIVE 2 DOES NOT PROVIDE FOR A REDUCTION OF TOXICITY OR VOLUME OF THE CONTAMINANTS BUT
WOULD REDUCE THEIR MOBILITY. ALTERNATIVE 5 WOULD REDUCE TOXICITY AND MOBILITY BUT NOT VOLUME OF
THE CONTAMINANTS.
ALTERNATIVES 6, 7, 8, 9, AND 10 WOULD REDUCE TOXICITY, MOBILITY, AND/OR VOLUME.
SHORT-TERM EFFECTIVENESS
THE ALTERNATIVES WILL REQUIRE VARYING AMOUNTS OF TIME TO ACHIEVE CLEANUP OF THE SITE. ALL
ALTERNATIVES WOULD HAVE A DEGREE OF SHORT-TERM EFFECTIVENESS. COMPARED TO THE OTHER
ALTERNATIVES, THE IN SITU BIOREMEDIATION ALTERNATIVE WOULD NOT HAVE AS GREAT A DEGREE OF
SHORT-TERM EFFECTIVENESS DUE TO THE TIME REQUIRED FOR BACTERIAL CULTURE GROWTH. ANY SHORT-TERM
RISK TO WORKERS INVOLVED IN CONSTRUCTION OF THE REMEDY WOULD BE REDUCED THROUGH IMPLEMENTATION
OF A HEALTH AND SAFETY PLAN.
IMPLEMENTABILITY
ALL ALTERNATIVES ARE IMPLEMENTABLE, HOWEVER, IT IS IMPORTANT TO NOTE THAT ALL ALTERNATIVES WOULD
REQUIRE VARIOUS STEPS TO REACH FULL-SCALE IMPLEMENTATION. THESE INITIAL ACTIVITIES WOULD
INCLUDE ITEMS SUCH AS TREATABILITY STUDIES, BENCH-SCALE OR PILOT-SCALE STUDIES, TEST BURNS, AND
CULTURING OF BACTERIAL STRAINS.
COST
THE PRESENT ESTIMATED COST OF EPA'S SELECTED REMEDY RANGES FROM 2.3 MILLION TO 3.3 MILLION
DOLLARS. THE SELECTED REMEDY PROVIDES OVERALL EFFECTIVENESS PROPORTIONAL TO ITS COSTS SUCH THAT
THE REMEDY REPRESENTS A REASONABLE VALUE FOR THE MONEY. WHEN THE RELATIONSHIP BETWEEN COST AND
OVERALL EFFECTIVENESS OF THE SELECTED REMEDY IS VIEWED IN LIGHT OF THE RELATIONSHIP BETWEEN COST
AND OVERALL EFFECTIVENESS PROVIDED BY OTHER ALTERNATIVES, THE SELECTED REMEDY APPEARS TO BE
COST-EFFECTIVE.
STATE ACCEPTANCE
THE STATE OF FLORIDA AS REPRESENTED BY THE FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION IS IN
FAVOR OF THE SELECTED REMEDY FOR REMEDIATING THE SURFACE SOIL AT THE ACW SITE.
COMMUNITY ACCEPTANCE
BASED ON COMMENTS MADE BY CITIZENS AT THE PUBLIC MEETING HELD ON SEPTEMBER 6, 1989, AND THOSE
RECEIVED DURING THE PUBLIC COMMENT PERIOD, THE COMMUNITY BELIEVES THE SELECTED REMEDY WILL
EFFECTIVELY PROTECT HUMAN HEALTH AND THE ENVIRONMENT.
#SR
9.0 SELECTED REMEDY
EPA SELECTS BIOLOGICAL TREATMENT (BIOREMEDIATION) AS THE MOST APPROPRIATE ALTERNATIVE TECHNOLOGY
TO REMEDIATE THE ACW SITE. BASED ON AVAILABLE DATA AND ANALYSIS TO DATE, SOLID PHASE
BIOREMEDIATION (ALTERNATIVE 8) IS EXPECTED TO BE THE MOST APPROPRIATE SOLUTION FOR MEETING THE
GOALS OF THE INITIAL SURFACE SOIL OPERABLE UNIT AT THE AMERICAN CREOSOTE WORKS SITE. HOWEVER,
TREATABILITY STUDIES WOULD BE CONDUCTED DURING THE PRE-DESIGN PHASE TO DETERMINE THE MOST
EFFECTIVE TYPE OF BIOLOGICAL TREATMENT (I.E. SLURRY PHASE, SOLID PHASE, OR IN SITU PHASE).
SOLID PHASE BIOREMEDIATION INCLUDES EXCAVATION AND TREATMENT OF SOIL IN AN ON-SITE LAND
TREATMENT AREA. AT THE PRESENT, EPA IS SUCCESSFULLY APPLYING THIS TECHNOLOGY AT ANOTHER
SUPERFUND SITE IN FLORIDA.
BASED ON CURRENT INFORMATION, THE SELECTED PROVIDES THE BEST BALANCE AMONG THE NINE CRITERIA
THAT EPA USES TO EVALUATE ALTERNATIVES. THE RATIONALE FOR CHOOSING THIS ALTERNATIVE INCLUDES
THE FOLLOWING REASONS:
•
PROVIDES IMMEDIATE PROTECTION TO HUMAN HEALTH FROM THE POTENTIAL THREATS ASSOCIATED WITH
DIRECT CONTACT WITH THE CONTAMINATED SURFACE SOIL;
•
CONTRIBUTES TO THE IMPLEMENTATION OF A MORE PERMANENT REMEDY AT THE SITE;
•
IS CONSISTENT WITH ADDITIONAL SITE ACTIONS AND WILL BE COMPATIBLE WITH THE FINAL SITE
REMEDY.
#SD
10.0 STATUTORY DETERMINATIONS
THE US EPA AND FDER HAVE DETERMINED THAT THIS REMEDY WILL SATISFY THE STATUTORY REQUIREMENTS OF
SECTION 121 OF CERCLA BY PROVIDING PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT, ATTAINING
ARARS, PROVIDING COST-EFFECTIVENESS, AND UTILIZING PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES OR RESOURCE RECOVERY TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE. SECTIONS 10.1
AND 10.5 BELOW ARE THE STATUTORY REQUIREMENTS FOR THIS SITE.
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
THE SELECTED REMEDY OF SOLID PHASE BIOREMEDIATION PROVIDES PROTECTION OF HUMAN HEALTH AND THE
ENVIRONMENT BY ELIMINATING THE DIRECT THREAT THROUGH DERMAL CONTACT WITH CONTAMINATED SURFACE
SOIL. THE SOURCE OF CONTAMINATION, THE SURFACE SOIL, WILL BE EXCAVATED AND TREATED. FOR A
SHORT PERIOD FOLLOWING EXCAVATION, CONCENTRATIONS OF CONTAMINANTS MIGHT EXCEED ARARS BUT THIS
CONCENTRATION WILL DECREASE AFTER TIME WITH TREATMENT.
10.2 ATTAINMENT OF THE APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS)
REMEDIAL ACTIONS PERFORMED UNDER CERCLA, AS AMENDED BY SARA, MUST COMPLY WITH ALL APPLICABLE OR
RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS). ALL ALTERNATIVES CONSIDERED FOR THE ACW SITE WERE
EVALUATED ON THE BASIS OF THE DEGREE TO WHICH THEY COMPLIED WITH THESE REQUIREMENTS. THE
RECOMMENDED ALTERNATIVE WAS FOUND TO MEET OR EXCEED THE ARARS.
WHEN ARARS ARE NOT AVAILABLE FOR SPECIFIC COMPOUNDS OR EXPOSURE MEDIA (SUCH AS SOIL), THE
CLEANUP GOALS ARE BASED ON AGENCY REFERENCE DOSES (RFD) FOR NONCARCINOGENS AND 10(-5) RISK
LEVELS FOR CARCINOGENS DERIVED BY USE OF AGENCY POTENCY FACTORS AND SITE SPECIFIC EXPOSURE
ASSUMPTIONS.
NO FEDERAL OR STATE CONTAMINANT-SPECIFIC ARAR HAS BEEN IDENTIFIED FOR PAH, PCP, OR
DIOXIN-CONTAMINATED SOIL.
POTENTIAL FEDERAL LOCATION-SPECIFIC ARARS FOR THE ACW SITE INCLUDE THE FOLLOWING:
•
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) LOCATION REQUIREMENTS - MANDATES THAT
HAZARDOUS WASTE TREATMENT, STORAGE, OR DISPOSAL FACILITIES LOCATED WITHIN A 100-YEAR
FLOODPLAIN MUST BE DESIGNED, CONSTRUCTED, OPERATED, AND MAINTAINED TO AVOID WASHOUT.
•
FISH AND WILDLIFE COORDINATION ACT - REQUIRES ADEQUATE PROTECTION OF FISH AND
WILDLIFE IF ANY STREAM OR OTHER BODY OF WATER IS MODIFIED.
•
ENDANGERED SPECIES ACT - REQUIRES ACTION TO CONSERVE ENDANGERED OR THREATENED
SPECIES FOR ACTIVITIES IN CRITICAL HABITATS UPON WHICH THESE SPECIES DEPEND.
•
NATIONAL HISTORICAL PRESERVATION ACT - REQUIRES THAT ACTION BE TAKEN TO PRESERVE OR
RECOVER HISTORICAL OR ARCHAEOLOGICAL DATA WHICH MIGHT BE DESTROYED AS A RESULT OF
SITE ACTIVITIES.
FEDERAL REGULATIONS THAT CONTAIN POTENTIAL ACTION-SPECIFIC ARARS FOR THE SITE ARE LISTED BELOW:
•
40 CFR SECTION 264.99 COMPLIANCE MONITORING PROGRAM - ESTABLISHES CRITERIA FOR
MONITORING GROUND WATER QUALITY WHEN CONTAMINANTS HAVE BEEN DETECTED. THIS INVOLVES
DEVELOPMENT OF A GROUND WATER QUALITY DATA BASE SUFFICIENT ENOUGH TO CHARACTERIZE
SEASONAL FLUCTUATIONS IN GROUND WATER QUALITY AT THE SITE.
•
CLEAN WATER ACT (CWA) - PROVIDES CRITERIA FOR GROUND WATER REMEDIATION AND DISCHARGE
INTO SURFACE WATERS.
•
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) - THE PROVISIONS OF RCRA PERTINENT TO
THE ACW SITE HAVE BEEN PROMULGATED UNDER 40 CFR PARTS 257, 260, 261, 262, 263, 264,
269, AND 280. EPA HAS DETERMINED THAT THE ABOVE REGULATIONS ARE APPLICABLE TO RCRA
CHARACTERIZED OR LISTED HAZARDOUS WASTES (40 CFR PART 260) WHICH WERE EITHER: 1)
WERE DISPOSED AT A SITE AFTER NOVEMBER 19, 1980; OR 2) THE CERCLA REMEDIAL ACTION
CONSISTS OF TREATMENT, STORAGE, OR DISPOSAL AS DEFINED BY RCRA (40 CFR PART 264).
IN ADDITION, THE REGULATIONS ARE RELEVANT AND APPROPRIATE TO RCRA HAZARDOUS WASTES
DISPOSED AT A SITE PRIOR TO NOVEMBER 19, 1980. EXAMPLES OF RCRA REQUIREMENTS
INCLUDE MINIMUM TECHNOLOGY STANDARDS, MONITORING REQUIREMENTS, AND STORAGE AND
DISPOSAL PROHIBITIONS.
•
CLEAN AIR ACT (CAA) - THE CAA REQUIREMENTS MAY BE APPLICABLE IN CASES WHERE ON-SITE
THERMAL DESTRUCTION IS CONSIDERED.
•
LAND DISPOSAL RESTRICTIONS - THE LDRS ARE APPLICABLE TO THE WASTE ON-SITE IF THE
SOIL IS EXCAVATED AND REMOVED OR EXCAVATED AND TREATED. IN ALTERNATIVES WHERE THE
LDRS ARE APPLICABLE, THE SOIL MUST BE TREATED TO THE INTERIM TREATMENT LEVELS PRIOR
TO LAND DISPOSAL.
•
SECTION 121(D) OF THE SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT (SARA) - SARA
REQUIRES THAT THE SELECTED REMEDIAL ACTION ESTABLISH A LEVEL OR STANDARD OF CONTROL
WHICH COMPLIES WITH ALL ARARS. AT THE ACW SITE, GROUND WATER DISCHARGES INTO
PENSACOLA BAY AND, THEREFORE, BEYOND THE BOUNDARIES OF THE SITE. APPLICABLE
STATUTORY LANGUAGE CONCERNING CLEANUP STANDARDS UNDER CERCLA IS FOUND IN SECTION
121(D)(2)(B)(II) OF SARA. SARA DOES NOT ALLOW ANY INCREASE IN CONTAMINANTS IN
OFF-SITE SURFACE WATER. TO RELATE HEALTH-BASED STANDARDS FOR CONTAMINANT
CONCENTRATIONS TO POTENTIAL RECEPTORS, A CURRENT-USE SCENARIO WAS EMPLOYED. UNDER
AN EVALUATION OF THE CURRENT-USE SCENARIO, THERE ARE NO DIRECT RECEPTORS OF GROUND
WATER AT OR DOWNGRADIENT OF THE SITE. RATHER, THE CLOSEST POTENTIAL RECEPTORS ARE
ASSOCIATED WITH SURFACE WATER USE WHERE AFFECTED GROUND WATER DISCHARGES TO
PENSACOLA BAY.
10.3 COST-EFFECTIVENESS
THE PRESENT ESTIMATED COST OF EPA'S SELECTED REMEDY RANGES FROM $2.3 MILLION TO 3.3 MILLION
DOLLARS. THE SELECTED REMEDY AFFORDS OVERALL EFFECTIVENESS PROPORTIONAL TO ITS COSTS SUCH THAT
THE REMEDY REPRESENTS A REASONABLE VALUE FOR THE MONEY. WHEN THE RELATIONSHIP BETWEEN COST AND
OVERALL EFFECTIVENESS OF THE SELECTED REMEDY IS VIEWED IN LIGHT OF THE RELATIONSHIP BETWEEN COST
AND OVERALL EFFECTIVENESS AFFORDED BY OTHER ALTERNATIVES, THE SELECTED REMEDY APPEARS TO BE COST
EFFECTIVE.
10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT TECHNOLOGIES TO THE MAXIMUM
EXTENT PRACTICABLE
THE US EPA BELIEVES THIS REMEDY IS THE MOST APPROPRIATE CLEANUP SOLUTION FOR INITIATING THE
FIRST OPERABLE UNIT AT THE ACW SITE AND PROVIDES THE BEST BALANCE AMONG THE EVALUATION CRITERIA
FOR THE REMEDIAL ALTERNATIVES CONSIDERED. THIS REMEDY PROVIDES EFFECTIVE PROTECTION IN BOTH THE
SHORT- AND LONG-TERM TO POTENTIAL HUMAN AND ENVIRONMENTAL RECEPTORS, IS READILY IMPLEMENTED, IS
COST-EFFECTIVE, AND IS CONSISTENT WITH FUTURE RESPONSE ACTIONS TO BE UNDERTAKEN AT THE SITE.
BIOREMEDIATION OF THE CONTAMINATED SURFACE SOIL REPRESENTS A PERMANENT SOLUTION (THROUGH
TREATMENT) WHICH WILL EFFECTIVELY REDUCE AND/OR ELIMINATE MOBILITY OF HAZARDOUS WASTES AND
HAZARDOUS SUBSTANCES INTO THE ENVIRONMENT.
10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
THE STATUTORY PREFERENCE FOR TREATMENT WILL BE PARTIALLY MET BECAUSE THE SELECTED REMEDY
DESCRIBED HEREIN ONLY TREATS THE CONTAMINATED SURFACE SOIL. FUTURE REMEDIAL ACTIONS TO BE
PERFORMED AT THE SITE WILL TREAT THE PRINCIPAL THREAT POSED BY THE CONTAMINATED GROUND WATER AND
THE SOLIDIFIED SLUDGES AND UNDERLYING SUBSURFACE SOIL.
#TA
TABLES AND ATTACHMENTS
TABLE 5.1
CARCINOGENICITY OF PAHS
CHEMICALS FOR WHICH THERE IS SUFFICIENT EVIDENCE THAT THEY ARE
CARCINOGENIC IN ANIMALS:
BENZO(A)ANTHRACENE
BENZO(B)FLUORANTHENE
BENZO(J)FLUORANTHENE
BENZO(K)FLUORANTHENE
BENZO(A)PYRENE
DIBENZO(A,H)ACRIDINE
DIBENZO(A,J)ACRIDINE
DIBENZO(A,H)ANTHRACENE
7H-DIBENZO(C,G)CARBAZOLE
DIBENZO(A,E)PYRENE
DIBENZO(A,H)PYRENE
DIBENZO(A,I)PYRENE
DIBENZO(A,L)PYRENE
IDENO(1,2,3-C,D)PYRENE
5-METHYLCRYSENE
CHEMICALS FOR WHICH THERE IS LIMITED EVIDENCE THAT THEY ARE CARCINOGENIC
IN ANIMALS:
ANTHANTHRENE
BENZO(C)ACRIDINE
CARBAZOLE
CHRYSENE
CYCLOPENTA(C,D)PYRENE
DIBENZO(A,C)ANTHRACENE
DIBENZO(A,J)ANTHRACENE
DIBENZO(A,E)FLUORANTHENE
2-, 3-, 4-, AND 6-METHYLCHRYSENE
2- AND 3-METHYLFLUORANTHENE
CHEMICALS FOR WHICH THE EVIDENCE IS INADEQUATE TO ASSESS THEIR CARCINOGENEITY:
BENZO(A)ACRIDINE
BENZO(G,H,I)FLUORANTHENE
BENZO(A)FLUORENE
BENZO(B)FLUORENE
BENZO(C)FLUORENE
BENZO(G,H,I)PERYLENE
BENZO(C)PHENANTHRENE
BENZO(E)PYRENE
CORONENE
1,4-DIMETHYLPHENANTHRENE
FLUORENE
1-METHYLCHRYSENE
1-METHYLPHENANTHRENE
PERYLENE
PHENANTHRENE
TRIPHENYLENE
CHEMICALS FOR WHICH THE AVAILABLE DATA PROVIDE NO EVIDENCE THAT THEY ARE CARCINOGENIC:
ANTHRACENE
FLUORANTHENE
SOURCE:
IARC 1983, 1984
PYRENE
APPENDIX A
SITE DATA
TOTAL SELECT PAH CONCENTRATION ON-SITE
AMERICAN CREOSOTE WORKS
PENSACOLA, FLORIDA
TOTAL SELECT PAH CONCENTRATION (MG/KG)
DEPTH BLS (INCHES)
SAMPLE
LOCATION
1 (BACKGROUND)
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
60
4-12
18-24
---57.00
7.34
41.40
40.20
11.89
24.10
42.40
---1.16
3.41
102.6
31.40
13.49
51.80
498.0
7.17
35.80
3.01
6.97
---1078.0
---2.25
---1.91
---12.18
10.15
------39.00
---1.83
1.84
70.2
9.22
55.80
-------
VADOSE ZONE
------1.18
0.16
---------0.40
0.91
------1.79
------0.08
0.48
0.30
29.41
-------
DIOXIN/DIBENZOFURAN CONCENTRATIONS ON-SITE
AMERICAN CREOSOTE WORKS
PENSACOLA, FLORIDA
TOTAL DIOXIN/DIBENZOFURAN CONTRATION IN TEQS (1)
(UG/KG)
DEPTH BLS (INCHES)
SAMPLE
LOCATION
4-12
TEQ
18-24
TEQ
1 (BACKGROUND)
36
38
40
46
48
---1.03
0.66
1.31
0.07
1.39
------0.75
1.86
.003
.01
VADOSE ZONE
TEQ
------.01
.01
-------
---- MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
4-2
INCHES BLS REPRESENTS A SAMPLING DEPTH
18-24 INCHES BLS REPRESENTS B SAMPLING DEPTH
VADOSE ZONE
REPRESENTS C SAMPLING DEPTH
(1) NOTE:
SPECIFIC DIOXINS/DIBENZOFURANS ARE CONVERTED TO
2,3,7,8-TCDD TOXICITY EQUIVALENTS (1987 TEQS) USING THE
TOXICITY FACTORS FROM TABLE 3-3 IN THE RISK ASSESSMENT
(JUNE 1988), I.E.:
2,3,7,8
2,3,7,8
2,3,7,8
2,3,7,8
2,3,7,8
-
HEXA
HEPTA
PENTA
HEXA
HEPTA
CDDS
CDDS
CDFS
CDFS
CDFS
----------------
.04
.001
.1
.01
.001
PENTACHLOROPHENOL CONCENTRATION ON-SITE
AMERICAN CREOSOTE WORKS
PENSACOLA, FLORIDA
SAMPLE
LOCATION
1 (BACKGROUND)
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
60
PENTACHLOROPHENOL CONCENTRATION (MG/KG)
DEPTH BLS (INCHES)
4-12
--11.0
8.6
5.6
3.4
9.4
16.0
--1.5
15.0
5.2
-110.0
-2.9
5.0
-0.34
18-24
-----5.2
-17.0
5.5
-0.2
2.4
---0.74
5.5
--0.34
VADOSE ZONE
---------------------
-- MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
4-12 INCHES BLS REPRESENTS A SAMPLING DEPTH
18-24 INCHES BLS REPRESENTS B SAMPLING DEPTH
VADOSE ZONE
REPRESENTS C SAMPLING DEPTH
RANGE AND FREQUENCY OF CHEMICAL CONTAMINANTS
IN VARIOUS MEDIA
AMERICAN CREOSOTE WORKS, INC., SITE
ALL CONCENTRATIONS IN MG/KG (SOILS) AND UG/L (WATER)
CONTAMINANT
SOILS
CONCENTRATION
RANGE AND NO.
OF OBSERVATIONS
GROUNDWATER
CONCENTRATION
RANGE AND NO.
OF OBSERVATIONS
SEDIMENT
CONCENTRATION
RANGE AND NO.
OF OBSERVATIONS
POLYCYCLIC AROMATIC HYDROCARBONS (PAHS)
BENZO(A)ANTHRACENE
BENZO(A)PYRENE
BENZO(B)FLUORANTHENE
BENZO(K)FLUORANTHENE
CHRYSENE
ANTHRACENE
BENZO(GHI)PERYLENE
FLUORENE
8.8-870 (16)
6.7-140 (10)
9.2-480 (17)
7.9-8.7 (2)
5.6-750 (19)
7.2-1,600 (17)
5.4-20 (5)
7.1-1,800 (13)
PHENANTHRENE
DIBENZO(A,H)ANTHRACENE
INDENO(1,2,3-CD)PYRENE
PYRENE
5.7-29,000 (21)
7.8-91 (2)
6.1-210 (5)
7.2-9,000 (29)
7,300 (1)
8,300
6,400-430,000 (*) (2)
50-140,000 (*) (13)
5,700 (1)
30-1,300 (10)
20,000 (1)
2,200 (1)
15,000 (1)
OTHER ACID AND BASE/NEUTRAL ORGANICS
ACENAPHTHENE
FLUORANTHENE
NAPHTHALENE
DIBENZOFURAN
2-METHYLNAPHTHALENE
PENTACHLOROPHENOL
7.3-6,900 (12)
8.1-10,000 (30)
74-1,100 (7)
58-880 (8)
39-540 (7)
7.2-2,500 (10)
40-140,000 (*) (12)
60-2,700 (3)
18,000 (1)
35-580,000 (*) (17)
45-660 (6)
3503,680 (8)
0.04-0.13
0.03-0.26
0.01-0.22
0.08 (1)
0.01-0.35
6-150 (15)
15-110 (15)
5-150 (15)
400-2,700 (8)
5-240 (16)
VOLATILE ORGANICS
BENZENE
ETHYLBENZENE
TOLUENE
ACETONE
O-XYLENE
(3)
(5)
(7)
(10)
PESTICIDES
BETA-BHC
ENDOSULFAN
0.66-0.9 (5) (+)
0.47 (2) (++)
(+) ONE REPORTED CONCENTRATION @ 230 (*)
(++) SAME SAMPLE AS ABOVE, 12 UG/L
(*) MAY BE IN ERROR OWING TO NONREPRESENTATIVE DATA
RESPONSIVENESS SUMMARY
THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY (EPA) AND THE FLORIDA DEPARTMENT OF
ENVIRONMENTAL REGULATION (FDER) ESTABLISHED A PUBLIC COMMENT PERIOD FROM SEPTEMBER 6, 1989
THROUGH SEPTEMBER 27, 1989 FOR INTERESTED PARTIES TO COMMENT ON EPA'S AND FDER,A PROPOSED
REMEDIAL ACTION PLAN (PRAP) FOR THE FIRST OPERABLE UNIT AT THE AMERICAN CREOSOTE WORKS, INC.
(ACW) SITE. THE COMMENT PERIOD FOLLOWED A PUBLIC MEETING CONDUCTED BY EPA HELD AT THE EACAMBIA
COUNTY HEALTH DEPARTMENT BUILDING IN PENSACOLA, FLORIDA. THE MEETING PRESENTED THE STUDIES
UNDERTAKEN AND THE PREFERRED REMEDIAL ALTERNATIVE FOR THE SITE.
A RESPONSIVENESS SUMMARY IS REQUIRED BY SUPERFUND POLICY TO PROVIDE A SUMMARY OF CITIZEN
COMMENTS AND CONCERNS ABOUT THE SITE, AS RAISED DURING THE PUBLIC COMMENT PERIOD, AND THE
RESPONSE TO THOSE CONCERNS. ALL COMMENTS SUMMARIZED IN THIS DOCUMENT HAVE BEEN FACTORED INTO THE
FINAL DECISION OF THE PREFERRED ALTERNATIVE FOR CLEANUP OF THE ACW SITE.
THIS RESPONSIVENESS SUMMARY FOR THE ACW SITE IS DIVIDED INTO THE FOLLOWING SECTIONS:
I.
OVERVIEW:
THIS SECTION DISCUSSES THE RECOMMENDED ALTERNATIVE
FOR REMEDIAL ACTION AND THE PUBLIC REACTION TO THIS ALTERNATIVE.
II.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS: THIS SECTION
PROVIDES A BRIEF HISTORY OF COMMUNITY INTEREST AND CONCERNS
REGARDING THE ACW SITE.
III.
SUMMARY OF MAJOR QUESTIONS RECEIVED DURING THE PUBLIC COMMENTS
PERIOD AND EPA'S OR FDER'S RESPONSE:
THIS SECTION
PRESENTS BOTH ORAL AND WRITTEN COMMENTS SUBMITTED DURING THE
PUBLIC COMMENT PERIOD, AND PROVIDES RESPONSE TO THESE COMMENTS.
IV.
REMAINING CONCERNS: THIS SECTION DISCUSSES COMMUNITY CONCERNS
THAT EPA SHOULD BE AWARE OF IN DESIGN AND IMPLEMENTATION OF THE
FIRST OPERABLE UNIT AND IN PLANNING FOR THE SECOND OPERABLE UNIT.
I.
OVERVIEW:
THE PREFERRED REMEDIAL ALTERNATIVE WAS PRESENTED TO THE PUBLIC IN A PUBLIC MEETING HELD ON
SEPTEMBER 6, 1989. THE RECOMMENDED ALTERNATIVE IS AN OPERABLE UNIT RECORD OF DECISION (ROD)
WHICH ADDRESSES THE SURFACE, SOIL CONTAMINATION. THE MAJOR COMPONENTS OF THE RECOMMENDED
ALTERNATIVE FOR THE SURFACE SOIL INCLUDE:
•
EXCAVATION, SCREENING, AND STOCKPILING OF CONTAMINATED SURFACE SOIL
•
TREATMENT OF THE STOCKPILED SOIL BY BIOREMEDIATION
•
ON-SITE DISPOSAL OF REMEDIATED SOIL.
THE COMMUNITY, IN GENERAL, FAVORS THE SELECTION OF THE RECOMMENDED ALTERNATIVE.
II.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERN:
THE PENSACOLA COMMUNITY HAS BEEN AWARE OF THE CONTAMINATION PROBLEM AT ACW SITE FOR SEVERAL
YEARS. A PUBLIC MEETING WAS HELD AT THE PENSACOLA YACHT CLUB TO INFORM THE MEMBERSHIP OF THE
FINDINGS OF THE REMEDIAL INVESTIGATION. A SECOND PUBLIC MEETING WAS HELD ON AUGUST 15, 1985 TO
PRESENT THE DRAFT FEASIBILITY STUDY AND ALLOW FOR PUBLIC COMMENT.
EPA AND FDER CONDUCTED THE THIRD PUBLIC MEETING ON SEPTEMBER 6, 1989. THE PURPOSE OF THIS
MEETING WAS TO EXPLAIN THE RESULTS OF THE SITE STUDIES, TO PRESENT THE RECOMMENDATIONS OF EPA
AND FDER FOR THE SITE CLEANUP, AND TO ACCEPT QUESTIONS AND COMMENTS FROM THE PUBLIC ON THE SITE
OR ITS CLEANUP. AT THIS MEETING, THE KEY ISSUES AND CONCERNS IDENTIFIED WERE:
TIME:
THE PUBLIC WAS CONCERNED WITH THE AMOUNT OF TIME THAT IT WILL TAKE TO CLEANUP THE SITE.
THE PUBLIC WANTED TO BE BETTER INFORMED OF SITE ACTIVITIES.
III.
SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND
EPA'S OR FDER'S RESPONSES:
1.) ONE COMMENTER INQUIRED HOW WOULD THE PUBLIC BE NOTIFIED.
EPA RESPONSE: EPA DEVELOPED A COMMUNITY RELATIONS PLAN THAT OUTLINED EPA,S ROLE IN
COMMUNICATING WITH THE PUBLIC. AS A PART OF THE COMMUNITY RELATIONS PLAN, A MAILING LIST WAS
DEVELOPED WHICH INCLUDED RESIDENTS, THE MEDIA, LOCAL, STATE, AND FEDERAL OFFICIALS. WHEN EPA
CONDUCTED THE FIRST PUBLIC MEETING, A SIGN-IN SHEET FOR INTERESTED INDIVIDUALS WHO WANTED TO BE
ADDED TO THE MAILING LIST WAS MADE AVAILABLE. THE PROPOSED PLAN FACT SHEET WAS MAILED TO ALL
THE PEOPLE WHO WERE ON THE MAILING LIT. IN ADDITION TO THE PROPOSED PLAN, PUBLIC NOTICE WAS
PUBLISHED IN THE LEGAL SECTION OF THE NEWSPAPER.
2.) ONE COMMENTER INQUIRED ABOUT BIOREMEDIATION STUDIES AND THEIR EFFECTIVENESS WITH THE TYPE OF
CONTAMINANTS ON SITE.
EPA RESPONSE: THERE ARE A NUMBER OF BIOREMEDIATION STUDIES THAT APPLY TO TREATMENT OF SITES
CONTAMINATED WITH CREOSOTE. THE STUDIES HAVE INDICATED THAT BIOREMEDIATION IS EFFECTIVE AS A
CLEANUP METHOD FOR CREOSOTE.
3.) ONE COMMENTER INQUIRED IF THE CONTAMINATED SOILS WERE BEING SPREAD BY THE CITY OR COUNTY
WHEN THEY GRADED THE SOILS.
EPA RESPONSE: AT THIS TIME THERE IS NO IMMEDIATE CONCERN, BUT WE WILL BE DOING ADDITIONAL
STUDIES AND WILL KEEP THIS IN MIND.
4.)
ONE COMMENTER INQUIRED IF ALL OF THE BIOREMEDIATION WOULD BE DONE ON THE SITE.
EPA RESPONSE:
5.)
YES.
ONE COMMENTER EXPRESSED CONCERNS ABOUT THE BAY.
EPA RESPONSE: EPA WILL BE WORKING WITH EXPERTS TO ENSURE THAT THE BAY IS NOT ADVERSELY
AFFECTED. WE HAVE DONE SOME SAMPLING OF THE BAY, AND PLAN TO CONDUCT MORE SAMPLING DURING THE
REMEDIAL DESIGN PHASE. WITH THE CURRENTLY AVAILABLE DATA, EPA HAS NO INDICATION THAT THE BAY
HAS BEEN ADVERSELY AFFECTED.
6.) ONE COMMENTER INQUIRED IF THE CAPPED AREAS ON SITE WOULD REMAIN IN THEIR CURRENT STATE OR
IF THEY WOULD BE TREATED.
THE CAPPED AREAS WILL BE ADDRESSED IN A SECOND PHASE FOR THIS SITE. ADDITIONAL STUDIES ARE
REQUIRED BEFORE AN APPROPRIATE DECISION CAN BE MADE FOR THE SOLIDIFIED MATERIALS, GROUND WATER,
AND THE BAY.
7.)
ONE COMMENTER INQUIRED IF THE CONTAMINATED SOILS WERE GOING TO BE EXCAVATED AND TREATED ON
THE SITE.
EPA RESPONSE: YES, THE SOILS WILL BE EXCAVATED AND TREATED ON-SITE.
8.)
ONE COMMENTER INQUIRED IF A LOT OF EQUIPMENT WOULD BE BROUGHT TO THE SITE.
EPA RESPONSE: YES, THERE WILL BE SOME EQUIPMENT. EPA WANTS TO HAVE ANOTHER PUBLIC MEETING TO
PROVIDE THE CITIZENS WITH INFORMATION ABOUT THE TYPE OF EQUIPMENT AND HOW LONG THE REMEDY IS
GOING TO TAKE.
9.)
ONE COMMENTER INQUIRED IF ALL OF THE SOILS WOULD BE EXCAVATED AT THE SOME TIME.
EPA RESPONSE: NO, ALL OF THE SOIL WILL NOT BE TREATED AT THE SAME TIME. THE SOILS WILL BE
TREATED IN LAYERS; ONCE A LAYER HAD REACHED THE CLEANUP GOAL, ANOTHER LAYER OF CONTAMINATED SOIL
WOULD BE EXCAVATED AND TREATED.
10.) ONE COMMENTER INQUIRED HOW LONG WOULD IT TAKE TO CLEAN UP THE SITE.
EPA RESPONSE: EPA WILL START REMEDIAL ACTION ON THE SITE IN SEPTEMBER 1990. EPA HAS ESTIMATED
THAT IT WILL TAKE TWO YEARS TO REMEDIATE THE SITE. ONCE THE REMEDIAL DESIGN HAS BEEN COMPLETED,
EPA WILL BE ABLE TO DEFINE THE ACTUAL AMOUNT OF TIME NECESSARY TO CLEAN UP THE SITE.
11.) ONE COMMENTER INQUIRED IF EPA FELT RELATIVELY COMFORTABLE THAT THE SITE WAS CONTAINED
RIGHT NOW.
EPA RESPONSE:
YES, EPA HAS ALLEVIATED THE IMMEDIATE THREAT AT THE SITE.
12.) TWO COMMENTERS EXPRESSED THE NEED FOR MORE PUBLIC NOTICE, AND STATED THAT SOME RESIDENTS
DID NOT RECEIVE THEIR PROPOSED PLAN FACT SHEETS.
EPA RESPONSE: EPA DID MAIL A LARGE NUMBER OF RESIDENTS THE PROPOSED PLAN FACT SHEET. IN
ADDITION, EPA RELEASED A PUBLIC NOTICE IN THE NEWSPAPER TO INFORM THE CITIZENS OF THE PUBLIC
MEETING.
IV.
REMAINING CONCERNS
THE COMMUNITY'S CONCERNS SURROUNDING THE ACW SITE WILL BE ADDRESSED IN THE FOLLOWING AREAS:
COMMUNITY RELATIONS FOR THE SECOND OPERABLE UNIT, INCORPORATION OF COMMENTS/SUGGESTIONS IN THE
REMEDIAL DESIGN, AND COMMUNITY RELATIONS SUPPORT THROUGHOUT THE REMEDIAL DESIGN AND THE REMEDIAL
ACTION.
COMMUNITY RELATIONS SHOULD CONSIST OF MAKING AVAILABLE FINAL DOCUMENTS (I.E., REMEDIAL DESIGN
WORK PLAN, REMEDIAL DESIGN REPORTS, ETC.), IN A TIMELY MANNER, TO THE LOCAL REPOSITORY, AND
ISSUANCE OF FACT SHEETS TO THOSE ON THE MAILING LIST TO PROVIDE THE COMMUNITY WITH PROJECT
PROGRESS AND A SCHEDULE OF EVENTS. THE COMMUNITY WILL BE MADE AWARE OF ANY PRINCIPAL DESIGN
CHANGES MADE DURING PROJECT DESIGN. AT ANY TIME DURING REMEDIAL DESIGN OR REMEDIAL ACTION, IF
NEW INFORMATION IS REVEALED THAT COULD AFFECT THE IMPLEMENTATION OF THE REMEDY, OR, IF THE
REMEDY FAILS TO ACHIEVE THE NECESSARY DESIGN CRITERIA, THE RECORD OF DECISION MAY BE REVISED TO
INCORPORATE NEW TECHNOLOGY THAT WILL ATTAIN THE NECESSARY PERFORMANCE CRITERIA.
COMMUNITY RELATIONS ACTIVITIES WILL REMAIN AN ACTIVE ASPECT OF THE REMEDIAL DESIGN AND THE
REMEDIAL ACTION PHASES OF THIS PROJECT.
AMERICAN CREOSOTE WORKS, INC. (PENSACOLA PLANT)
Site Information:
Site Name:
Address:
AMERICAN CREOSOTE WORKS, INC. (PENSACOLA PLANT)
PENSACOLA, FL
EPA ID:
EPA Region:
FLD008161994
04
Site Alias Name(s):
AMERICAN CREOSOTE WORKS INC
AMERICAN CREOSOTE WORKS (PENSACOLA PLT)
Record of Decision (ROD):
ROD Date:
Operable Unit:
ROD ID:
02/03/1994
02
EPA/ROD/R04-94/208
Media:
Groundwater, Soil
Contaminant:
PAHs, phenols, VOCs
Abstract:
Please note that the text in this document summarizes the Record of
Decision for the purposes of facilitating searching and retrieving key
text on the ROD. It is not the officially approved abstract drafted by
the EPA Regional offices. Once EPA Headquarters receives the
official abstract, this text will be replaced.
The 18-acre American Creosote Works, Inc. site is a moderately
dense commercial and residential district in Pensacola, Florida. The
site is aproximately 600 yards north of Pensacola Bay and Bayou
Chico. Residential neighborhoods are immediately adjacent to the
site on the east and south. The site was used between 1902 until
December 1981 as a wood-preserving operation. The site is currently
abandoned.
The site has been conducting wood-preserving operations from 1902
until 1981. Prior to 1950, creosote was used exclusively to treat
poles. Use of pentachlorophenol started in 1950 and increased in the
later years. Four former surface impoundments are located on the
west side of the site: the Main Pond, the Overflow Pond, Railroad
Impoundment, and Holding Pond. Overflow from these areas drained
off-site or to the Spillage Area on-site.
In 1981, monitoring wells were installed by the U.S. Geologic
Survey (USGS) and results indicated a contaminant plume. The site
was proposed for the NPL in 1981 and listed in 1983. In 1983, EPA
investigations detected PAHs in the soil and groundwater. In late
1983, EPA conducted an immediate cleanup. In 1985, EPA
conducted an RI/FS that detected PAHs, phenols, and VOCs in soil
and groundwater. A 1985 ROD selected a remedy addressing all
on-site and off-site soils, sludge, and sediments. However, no action
was taken because the State did not concur. After further study, a
1989 ROD selected a remedy for contaminated soil. An amended
ROD is anticipated to address soil and sludge.
This ROD addresses OU-2 which addresses ground-water
contaminated with DNAPLs in Phase 1 and dissolved contaminants
in Phase 2.
Remedy:
The selected remedy for OU-2 consists of two phases. The first phase
includes: enhanced DNAPL recovery using a combination of water,
alkaline, surfactant, and polymer flooding; DNAPL/water separation
and ground-water treatment to be determined; off-site transport and
recycling of recovered DNAPL and reinjection of treated
groundwater; periodic ground-water monitoring to evaluate DNAPL
recovery efficiency; sampling, plugging, and abandoning private
wells; implementation of State-imposed well permit restrictions. The
second phase includes: groundwater removal via extraction wells;
on-site treatment of contaminated groundwater using dissolved air
flotation (DAF), continuous flow bioreactor, clarifier, filter, and a
granular activated carbon column; nutrient and hydrogen peroxide
addition to treated water; reinjection of treated groundwater into the
contaminated portion of the aquifer to stimulate in-situ biological
treatment activity; dewatering of waste sludge from the treatment
process and disposal at an off-site RCRA landfill; periodic
ground-water and surface-water monitoring to evaluate treatment
system performance.
Text:
Full-text ROD document follows on next page.
EPA/ROD/R04-94/208
1994
EPA Superfund
Record of Decision:
AMERICAN CREOSOTE WORKS, INC. (PENSACOLA
PLANT)
EPA ID: FLD008161994
OU 02
PENSACOLA, FL
02/03/1994
RECORD OF DECISION
OPERABLE UNIT 2
GROUNDWATER REMEDIATION
AMERICAN CREOSOTE WORKS, INC.
Pensacola, Escambia County, Florida
Prepared By
Environmental Protection Agency
Region IV
Atlanta, Georgia
RECORD OF DECISION
OPERABLE UNIT 2
AMERICAN CREOSOTE WORKS, INC. SITE
I.
DECLARATION
SITE NAME AND LOCATION
American Creosote Works, Inc.
Pensacola, Escambia County, Florida
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for Operable Unit 2 at the American
Creosote Works, Inc. (ACW) site in Pensacola, Florida, which was chosen in accordance with the
Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), as mended
by the Superfund Amendments and Reauthorization Act of 1986 (SARA), and, to the extent
practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This
decision is based on the Administrative Record for the site.
The Florida Department of Environmental Protection (FDEP) has provided input as the support
agency throughout the remedy selection process. Based on FDEP's comments to date, EPA expects
that concurrence on this remedy will be forthcoming, although a formal concurrence letter has
not yet been received.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
The remedy selected by EPA for the American Creosote Works site will be conducted in two
operable units. Operable Unit 1 addresses contaminated soils and sludges which represent the
source of contamination at the site. Operable Unit 2, presented in this ROD, will address
groundwater contamination at the site.
The selected remedy for Operable Unit 2 consists of two phases. The first phase, involving
recovery and disposal of dense non-aqueous phase liquids (DNAPLs), includes the following
components:
•
Enhanced DNAPL recovery using a combination of water, alkaline, surfactant, and
polymer flooding
•
DNAPL/water separation and groundwater treatment
•
Off-site transport and recycling of recovered DNAPL and reinjection of treated
groundwater
•
Periodic groundwater monitoring to evaluate DNAPL recovery efficiency
•
Sampling, plugging, and abandoning private wells for which owner consent is granted
•
Implementation of State-imposed well permit restrictions
Based on the results of periodic monitoring data compiled during the five year review, EPA will
determine whether to continue enhanced recovery of DNAPLs or to implement the second phase of
the Operable Unit 2 remedy to address residual groundwater contamination in the aquifer. The
components of this second phase of the remedy are listed below:
•
Groundwater removal via extraction wells
•
On-site treatment of contaminated groundwater
•
Nutrient and hydrogen peroxide addition to treated water
•
Reinjection of treated groundwater (including nutrients) into the contaminated
portion of the aquifer to stimulate in-situ biological treatment activity
•
Dewatering of waste sludge from the treatment process and disposal at an off-site
RCRA landfill
•
Periodic groundwater and surface water monitoring to evaluate treatment system
performance
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with Federal and
State requirements that are legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable and satisfies the statutory preference
for remedies that employ treatment that reduces toxicity, mobility, or volume as a principal
element.
Because this remedy may result in hazardous substances remaining in the groundwater above
health-based levels, a review will be conducted every five years after commencement of remedial
action to evaluate system performance and ensure that the remedy continues to provide adequate
protection of human health and the environment.
--------------------------Date
-----------------------------John H. Hankinson
Regional Administrator
U.S. EPA Region IV
TABLE OF CONTENTS
DECLARATION . . . . . . . . . . . . . . . . . . . . . . . . .
i
Table of Contents . . . . . . . . . . . . . . . . . . . . . . iii
II.
List of Figures . . . . . . . . . . . . . . . . . . . . . . .
v
List of Tables
vi
. . . . . . . . . . . . . . . . . . . . . . .
DECISION SUMMARY
. . . . . . . . . . . . . . . . . . . . . .
1
1.O
SITE NAME, LOCATION, AND DESCRIPTION
. . . . . . . . .
1
2.0
SITE HISTORY AND ENFORCEMENT ACTIVITIES . . . . . . . .
1
3.0
HIGHLIGHTS OF COMMUNITY PARTICIPATION . . . . . . . . .
5
4.0
SCOPE AND ROLE OF OPERABLE UNIT . . . . . . . . . . . .
6
5.0
SUMMARY OF SITE CHARACTERISTICS . . . . . . . . . . . .
7
5.1
5.2
6.0
7.0
General Site Characteristics . . . . . . . . . .
Results of Groundwater Investigations . . . . .
SUMMARY OF SITE RISKS . . . . . . . . . . . .
6.1 Human Health Risks . . . . . . . . . . . .
6.1.1 Contaminants of Concern . . . . . .
6.1.2 Exposure Assessment . . . . . . . .
6.1.3 Toxicity Assessment . . . . . . . .
6.1.4 Risk Characterization . . . . . . .
6.1.5 Uncertainties in the Risk Assessment
6.2 Environmental Risks . . . . . . . . . . .
.
.
.
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.
.
.
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.
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.
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.
.
.
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.
DESCRIPTION OF ALTERNATIVES . . . . . . . . . . . . .
7.1 Alternative DN1 - No Action . . . . . . . . . .
7.2 Alternative DN2 - DNAPL Extraction; On-site
Thermal Treatment. . . . . . . . . . . . . . . .
7.3 Alternative DN3A - DNAPL Extraction; Off-site
Treatment . . . . . . . . . . . . . . . . . . . .
7.4 Alternative DN3B - DNAPL Extraction; Recycling. .
7.5 Alternative GW1 - No Action . . . . . . . . . . .
7.6 Alternative GW2 - Groundwater Use Restrictions and
Monitoring . . . . . . . . . . . . . . . . . . .
7.7 Alternative GW3A - Extraction and Treatment;
Surface Water Discharge . . . , . . . . . , . . .
7.8 Alternative GW3B - Extraction and Treatment;
Reinjection . . . . . . . . . . . . . . . . . . .
7.9 Alternative GW4 - In-Situ/Ex-Situ Bioremediation.
7
9
11
11
11
14
17
22
26
27
28
29
29
30
30
31
33
33
35
35
8.0
COMPARATIVE ANALYSIS OF GROUNDWATER AND DNAPL
ALTERNATIVES . . . . . . . . . . . . . . . . . . . . .
8.1 Overall Protection of Human Health and the
Environment . . . . . . . . . . . . . . . . . . .
8.2 Compliance with ARARs . . . . . . . . . . . . .
8.3 Long-Term Effectiveness and Permanance . . . . .
8.4 Reduction of Toxity, Mobility, or Volume through
Treatment . . . . . . . . . . . . . . . . . . .
8.5 Short-Term Effectiveness . . . . . . . . . . . .
8.6 Implementability . . . . . . . . ... . . . . . .
8.7 Cost . . . . . . . . . . . . . . . . . . . . . .
8.8 State Acceptance . . . . . . . . . . . . . . . .
8.9 Community Acceptance . . . . . . . . . . . . . .
37
38
39
39
40
40
41
41
42
42
9.0
SELECTED REMEDY . . . . . . . . . . . . . . . . . . .
9.1 Remedial Action Objectives. . . . . . . . . . . .
9.2 Performance Standards . . . . . . . . . . . . . .
10.O
STATUTORY DETERMINATIONS. . . . . . . . . . . . . . .
52
10.1 Protection of Human Health and the Environment..
52
10.2 Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs) . . . . . . . . . 53
10.3 Cost Effectiveness . . . . . . . . . . . . . . . . 54
10.4 Utilization of Permanent Solutions to the Maximum
Extent Practicable . . . . . . . . . . . . . . . . 54
10.5 Preference for Treatment as a Princinal Element . . 54
11.O
DOCUMENTATION OF SIGNIFICANT CHANGES. . . . . . . . . .
Appendix A - Dioxin Toxicity Equivalence Factors
III. RESPONSIVENESS SUMMARY.
42
49
50
55
LIST OF FIGURES
Page
Figure 1 General Site Location Map . . . . . . . . . . . . . 2
Figure 2 Shallow Zone Contamination Above Remedial Goals . . 10
Figure 3 Intermediate Zone Contamination Above Remedial
Goals . . . . . . . . . . . . . . . . . . . . . . . 12
Figure 4 Deep Zone Contamination Above Remedial Goals
. . . 13
Figure 5 Groundwater Treatment System Schematic. . . . . . . 44
Figure 6 Conceptual Groundwater Extraction and Reinjection
Scenario. . . . . . . . . . . . . . . . . . . . . . 48
LIST OF TABLES
Page
Table 1 Contaminants Concern and Exposure Point
Concentrations . . . . . . . . . . . . . . . . . . . . . 15
Table 2 Exposure Assumptions for Future On-site and Off-site
Residents Exposed to Contaminated Groundwater . . . . . 18
Table 3 Daily Intake Formulas. . . . . . . . . . . . . . . . . . 19
Table 4 Toxicity Values for Contaminants of Concern
. . . . . . 20
Table 5 Individual Risks Associated with Contaminants of
Concern . . . . . . . . . . . . . . . . . . . . . . . . 23
Table 6 Summary of Future Cancer Risks . . . . . . . . . . . . . 25
Table 7 Summary of Future Hazard Quotients . . . . . . . . . . . 25
Table 8 Groundwater Remedial Goals
. . .. . . . . . . . . . . . 32
Table 9 Surface Water Quality Standards and MCLs for
Contaminants of Concern . . . . . . . . . . . . . . . . 45
II. DECISION SUMMARY
1.0 SITE NAME, LOCATION, AND DESCRIPTION
The American Creosote Works, Inc. (ACW) site occupies 18 acres in a moderately dense commercial
and residential district in Pensacola, Florida. The site is located about one mile southwest
of the intersection of Garden and Palafox Streets in downtown Pensacola and is approximately 600
yards north of Pensacola Bay and Bayou Chico. Immediately north of the site is a lumber
company, an auto body shop, an appliance sales and repair shop, and a wire storage area. The
Pensacola Yacht Club is southwest of the site. Residential neighborhoods are immediately
adjacent to the site on the east and south, with the nearest residence located approximately 50
feet from the site boundary. A general site location map is provided as Figure 1.
The ACW site is nearly flat, with elevations ranging between 12 and 14 feet above sea level.
The land slopes gently southward at about 25 feet per mile toward Pensacola Bay. The site is
about 2,100 feet long, east to west, and an average of 390 feet wide, north to south. Primary
access to the plant is from Barrancas Avenue. Originally, a railroad spur line of Burlington
Northern Railroad traversed the plant from west to east. The majority of site buildings,
process tanks, and equipment were situated near the center of the site in an area designated as
the main plant area. A few small work sheds, miscellaneous equipment, and debris were situated
around the remainder of the site. The railroad spur and all of the process equipment and
buildings have been removed. At present, only the main building foundation and approximately
200 drums containing investigation-derived wastes remain on-site.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
Wood-preserving operations were carried out at the ACW site from 1902 until December 1981. Prior
to 1950, creosote was used exclusively to treat poles. Use of pentachlorophenol (PCP) started
in 1950 and increased in the later years of the ACW operations.
Four former surface impoundments were located in the western portion of the ACW site. The Main
and Overflow ponds, located adjacent to "L" Street, were used for disposal of process wastes.
During its years of operation, ACW discharged liquid process wastes into the two unlined surface
impoundments. Prior to about 1970, wastewaters in these ponds were allowed to overflow through
a spillway and follow a drainage course into Bayou Chico and Pensacola Bay. In subsequent
years, liquid wastes were periodically drawn off the larger impoundments and allowed to
accumulate in the smaller Railroad Impoundment and Holding Pond, or were spread out on the
designated "Spillage Area" on-site. Additional discharges occurred during periods of heavy
rainfall and flooding when the ponds overflowed the containment dikes.
<IMG SRC 0494208>
In March 1980, the City of Pensacola found considerable quantities of an oily creosote-like
material in the groundwater near the intersection of "L" and Cypress Streets. In July 1981, the
U.S. Geological Survey (USGS) installed nine groundwater monitor wells in the vicinity of the
ACW site. Samples taken from those wells revealed that a contaminant plume was moving in a
southerly direction toward Pensacola Bay. In October 1981, EPA proposed the site for inclusion
on the National Priority List (NPL), a list of abandoned or unregulated hazardous waste sites
eligible for attention under the CERCA long-term cleanup program. The site's listing was
finalized on September 8, 1983.
In February 1983, EPA conducted an investigation which included sampling and analysis of on-site
soils, wastewater sludges, sediment in area drainage ditches, and existing groundwater from
on-site and off-site monitoring wells. Analytical results indicated that the major contaminants
in the groundwater and on site soils were polynuclear aromatic hydrocarbons (PAHs), which are
common to creosote. Among the various surface water and sediment locations that were sampled,
only the drainage ditch on the Pensacola Yacht Club (PYC) property-showed contaminants
associated with the ACW site. Analytical results indicated that inorganic contaminants were not
present in significant concentrations.
Because of the threat posed to human health and the environment by frequent overflows from the
waste ponds, the EPA Region IV Emergency Response and Control Section performed an immediate
cleanup during September to October 1983. The immediate cleanup work included dewatering the
two large lagoons (main and overflow ponds), treatment of the wastewater, and discharge to the
City of Pensacola sewer system. The sludge in the lagoon was then stabilized with lime and fly
ash, and a temporary clay cap was placed over the stabilized material. The Florida Department
of Environmental Regulation (FDER), the predecessor agency to FDEP, also assisted during the
cleanup.
In 1985, EPA completed a remedial investigation and feasibility study (RI/FS) under CERCLA.
Samples were collected from local surface water, sediment, existing USGS monitor wells,
residential wells, newly installed monitor wells, and on-site and off-site surface soils.
Analytical results indicated that on-site and off site surface soils, the drainage ditch on the
Pensacola Yacht Club property, and groundwater were contaminated with PAHs, phenols, and
volatile organic compounds.
Based on this study, EPA signed a ROD in September 1985 which selected a remedy for all on-site
and off-site contaminated surface soils, sludges, and sediments to be placed in an on-site
hazardous waste landfill. Groundwater remediation was not included. However, the State of
Florida did not agree with this decision, citing the need for additional information.
Consequently, EPA initiated another study in 1988 (known as the Post-RI) to provide further
information on the extent of contamination in surface soils. Over 125 organic compounds were
detected on and around the ACW site during this investigation. Indicator groups of contaminants
were selected to simplify the data discussion. These included carcinogenic PAHs,
noncarcinogenic PAHs, phenols, pentachlorophenol, dioxins/dibenzofurans, and phthalates.
Following the Post-RI, EPA prepared a revised risk assessment and a supplemental alternatives
evaluation (the Post-FS) and selected a new cleanup remedy in September 1989 which called for
bioremediation of surface soils. The ROD specified that treatability studies would be conducted
during the design phase to determine the most effective type of biological treatment. These
studies demonstrated that bioremediation would not be effective for addressing all contaminants
in site soils, so EPA anticipates selecting another remedy in a ROD amendment in 1994.
In March 1990, EPA compleeed Phase II of the Post-RI which addressed contamination in
groundwater, solidified sludge, and subsurface soils. A total of 63 samples were collected
including 23 groundwater samples, 17 sediment samples, 15 subsurface soil samples, and 8 surface
soil samples. The groundwater, sediment, subsurface soil, and one surface soil sample were
analyzed for purgeable and extractable organic compounds. Seven on-site surface soil samples
were analyzed for total dioxins. Results of the analyses indicated the presence of elevated
concentrations of numerous organic campounds and dioxins in one or more environmental media
(soil, surface water, groundwater, or sediments).
EPA completed Phase III of the Post-RI in January 1991 to further characterize and verify the
extent of organic contamination in the groundwater and dioxin contamination in the on-site and
off-site soil (down to a depth of 18 inches). During this investigation, a total of 16 samples
were collected including 4 groundwater samples, 8 on-site soil samples, and 4 off-site surface
soil samples. A variety of organic compounds and dioxins were detected.
Finally, EPA conducted a focused groundwater investigation (Phase IV) in May 1993 to evaluate
the presence of dioxin in groundwater. Samples were collected from 10 wells screened in the
shallow, intermediate, and deep zones of the aquifer along the axis of the known contaminant
plume. Dioxins were detected at very low levels (0.0092 ng/l TEQ) in only one well completed in
the deep zone directly beneath the site.
EPA completed a Baseline Risk Assessment in August 1993 to evaluate potential risks associated
with groundwater, solidified sludge, and subsurface soils. A summary of the risks associated
with contaminated groundwater at the site is presented in Section 6.0.
Enforcement Summary
The earliest documented incident of a release of any type from the ACW plant occurred in the
summer of 1978, when a spill of liquids flowed onto a nearby street and then onto the property
of a yacht sales company. A flood in March 1979 resulted in a similar spill. These incidents
resulted in increased regulatory attention to ACW by FDER.
In 1980, ACW filed an incomplete application with FDER for construction of an industrial
wastewater treatment system. FDER issued a Notice of Violation (NOV) for corrective action in
1981, alleging contamination of soils and groundwater. This enforcement action called for ACW
to cease operations until a permit was issued, submit a restoration plan, install a groundwater
monitoring system, and remove contaminated oils. In January 1981, FDER completed a responsible
party search, a title search, and a financial assessment for the site, and in March 1981, FDER
and ACW entered into an administrative consent order which incorporated the previous NOV
requirements and allowed ACW to continue operations. The Order included schedules for completing
construction of the wastewater treatment system and meeting the other NOV requirements.
Throughout 1981 and 1982, FDER encountered difficulty with ACW's compliance efforts, and in
March 1982, ACW announced that environmental regulations were forcing the company to go out of
business. As a result, FDER filed a Petition for Enforcement and Agency Action and a Complaint
for Permanent Injunction and Civil Penalties in April 1982 because of ACW's failure to make
progress toward compliance. One month later, in May 1982, ACW, Inc. of Florida filed for
reorganization in bankruptcy court. In 1984, the court presented a final court stipulation for
the approval of the litigants. The stipulation provided that half of the proceeds of any sale
or lease of the AW property would go to EPA and FDER. The remaining 50 percent would go to
Savings Life Insurance Company which holds a mortgage on the property in the principal sum of
$675,000. The stipulation was finalized and entered by the court in 1988.
In 1985, EPA sent a notice letter to Burlington Northern Railroad requesting removal of a
railroad spur line along their right of way on the site. The railroad company completed this
work in 1986.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
In accordance with Sections 113 and 117 of CERCLA, as amended, EPA has conducted community
relations activities at the ACW site to solicit community input and ensure that the public
remains informed about site activities. EPA has relied on a number of methods for keeping-the
public informed, including press releases, fact sheets, public meetings, establishment of an
information repository, and public comment periods.
EPA's earliest community outreach effort was a press release related to the emergency removal
activities in 1983. Periodic fact sheets were issued during 1984 and 1985 to update the
community concerning studies being conducted at the state. In September 1985, EPA issued fact
sheets and press releases announcing a public meeting and comment period related to the proposed
plan for addressing source contamination at the site. Similarly, in 1989, EPA issued a fact
sheet and held a public meeting to discuss the revised source control remedy. In 1990, EPA
prepared an Explanation of Significant Differences (ESD) notifying the public of additional
taske that would be necessary to implement the 1989 ROD. Later, in March 1991, a fact sheet was
published to advise the public of the initiation of these site preparation activities which
included cap repair, drum characterization, fence repairs, well closure, and building
demolition.
More recently, EPA conducted a door-to-door survey in September 1993 in the neighborhood
surrounding the site to update its mailing list. EPA's Proposed Plan for Operable Unit 2 was
sent to the public in November 1993, and the administrative record for the site was made
available in the public repository at the West Florida Regional Library. A notice was published
in the Pensacola News Journal on November 28 and 30, 1993 advising the public of the
availability of the administrative record and the date of the upcoming public meeting. On
December 2, 1993, EPA held a public meeting to answer questions and receive comments on EPA's
preferred alternative for addressing groundwater contamination at the site. A public comment
period was held from November 12, 1993 to January 11, 1994, and a response to any significant
oral or written comments received during this period is included in the Responsiveness Summary
in Section III of this ROD.
This decision document presents the selected remedial action for contaminated groundwater at the
ACW site in Pensacola, Florida, chosen in accordance with CERCLA, as amended by SARA, and to the
extent practicable, the NCP. This decision is based on the Administrative Record for the site.
4.0 SCOPE AND ROLE OF OPERABLE UNIT
As with many Superfund sites, the problems at the ACW site are complex. As a result, EPA has
organized the remedial work into two smaller units, referred to as operable units. Operable
Unit 1 addresses contaminated soils and sludges which represent the source of contamination at
the site. Operable Unit 2, presented in this ROD, will address groundwater contamination at the
site. The selected remedy for Operable Unit 2 will be conducted in two phases. The first phase
will involve recovery and disposal of DNAPLs, and the second phase will involve remediation of
dissolved contamination in the groundwater. The selected remedy is consistent with plans for
future work to be conducted at the site.
In 1989, EPA selected bioremediation for cleaning up on-site surface soil contamination.
However, following further testing of this technology, EPA determined this remedy might not be
fully effective for all contamination in site surface soils. Therefore, EPA plans to issue an
amended ROD for Operable Unit 1 in 1994 which selects a more suitable remediation strategy.
This amended ROD will also address subsurface soil contamination and solidified sludges.
5.0 SUMMARY OF SITE CHARACTERISTICS
5.1 General Site Characteristics
Pensacola lies within the Coastal Lowlands, or subdivision of a major physiographic division of
the United States known as the Coastal Plain Province. The Coastal Lowlands are relatively
undissected, nearly level, and lie about 100 feet or less above sea level. The only distinctive
topographic features of the Lowlands are the step-like Pleistocene marine terraces, which
descend from the north, southward to the coastline. The area is situated on a somewhat hilly,
sandy slop which borders Bayou Chico and Pensacola Bay. The bay is separated from the Gulf of
Mexico by a long narrow island that forms a natural breakwater for the harbor. Most surface
water drainage in the area is by overland sheet flow through the streets and storm drains south
of the site to Pensacola Bay, and by way of the drainage ditch on the Yacht Club property.
The Gulf of Mexico, situated about 6 miles south of Pensacola Bay, moderates the climate of
Pensacola by tempering the cold northern winds of winter and causing cool sea breezes during the
daytime in summer. The average temperature for the summer months is around 80 degrees with an
average daily range of 12.5 degrees. Temperatures of 90 degrees or higher occur on an average
of 39 times yearly. A temperature of 100 degrees or higher occurs occasionally. The average
winter temperature is in the low to mid 50s with an average daily range of 15.7 degrees. Severe
cold waves are infrequent.
Rainfall is usually well distributed through the year with the greatest frequency normally being
in July and August. The greatest average monthly rainfall occurs in July, and the lowest occurs
in October. Seriously destructive hurricanes are occasionally experienced in the vicinity.
Hurricanes historically occur from early July to mid-October.
The groundwater in the vicinity of the ACW site contains three major aquifers: a shallow
aquifer which is both confined and unconfined the (Sand-and-Gravel Aquifer), and two deep
confined aquifers (the upper and lower limestones of the Floridan Aquifer). The Sand-and-Gravel
Aquifer and upper limestone of the Floridan Aquifer are separated by a thick section of
relatively impermeable clay called the Pensacola Clay.
The Sand-and-Gravel Aquifer is the only freshwater aquifer in central and southern Escambia
County and is the source of public water supply for the area, including the City of Pensacola.
The aquifer is exposed at the surface throughout Escambia County and deepens to as much as 1,100
feet thick. It exceeds north and west from Pensacola into Alabama and is recognized as far
eastward as the Chactawhatchee River (about 78 miles).
The water bearing zone underlying the ACW site area is composed primarily of sand with many
interbedded layers and lenses of clay and sandy clay. These clay layers and lenses range from
less than an inch to approximately 38 feet in thickness. Based on characteristics of the sands
in these areas, the water-bearing zone can be divided into two distinct strata. The sand in the
upper 25 feet below land surface (b.l.s.) of sediment varies in grain size from fine to coarse
and in density from loose to dense. These variations in grain size and density are important,
since these are a factor in the seepage rate of water through the sediment.
The sand at depths greater than 25 feet b.l.s. to a depth of about 200 feet is predominantly a
very dense sand, usually fine to medium grained, with variable amounts of silt. Discontinuous
clay and sandy clay nodules and lenses occur throughout the deep sand. No stratigraphic
correlations can be determined between the clay lenses found in the various borings.
Two massive clay formations exist in the water-bearing zone in the site area. One clay layer is
directly under the ACW ponds at a depth of about 100 feet b.l.s. This clay appears to be
continuous under the ACW pond area, although it does pinch out south of the site. South of the
site, a second massive clay layer approximately 38 feet thick underlies the Pensacola Yacht Club
property at a depth of about 20 feet b.l.s., and extends south to the Pensacola Bay. This
second clay pinches out before reaching the ACW site.
There are three recognizable geologic subunits within the Sand-and-Gravel aquifer in the site
area. The uppermost subunit includes the terrace sands, with shallow wells to approximately 25
feet b.l.s., which provide relatively small yields of less than 50 gallons per minute (gpm).
The middle subunit includes the Citronelle Formation, where water supply wells extend 50 to 150
feet b.l.s. in depth, and have yields ranging from 50 to several hundred gpm. The lowest
subunit includes the Miocene Coarse Clastics and the lower portion of the Citronelle Formation,
where wells are over 200 feet b.l.s. in depth and have yields ranging from 1,000 to 2,000 gpm.
Water-level measurements from wells installed north of the 20-foot deep clay layer to depths of
less than 100 feet indicate that the groundwater within the upper 100 feet is unconfined.
Water-levels from 20-foot deep and 60-foot deep wells indicate similar groundwater elevations.
South of the site where the 20-foot deep clay layer is present, water levels below the clay
layer show groundwater elevations 0.5 to 3 feet higher than groundwater elevations in the sand
overlying this clay layer. This difference in hydraulic head indicates that groundwater below
the 20-foot clay layer is confined. This water-level difference also suggests that an upward
gradient exists. The ultimate fate of groundwater below the 20-foot clay is upward migration to
the overlying sand and discharge to Pensacola Bay and Bayou Chico. The groundwater below the
100-foot clay is also under water-table conditions, with little difference between wells above
and below this clay layer. This deeper clay contains profuse layers and lenses of clayey sand
which allow hydrologic communication between the two sand units.
The direction of groundwater flow is to the south with discharge to Pensacola Bay. Portions of
the shallow groundwater appear to discharge to a drainage ditch on the Pensacola Yacht Club
property, which subsequently drains into Pensacola Bay at the mouth of Bayou Chico. The aquifer
is recharged by local rainfall, with relatively high infiltration rates because of the sandy
nature of the aquifer and overlying soils. Annual recharge is 0 to 10 inches per year.
There are no public water supply wells in the immediate vicinity of the ACW site, making this
portion of the Sand-and-Gravel aquifer a Class G-II groundwater under Florida Administrative
Code (FAC) 17-520.410. The nearest well field belongs to the City of Pensacola, located
approximately a mile north of the site. The cones of influence of these wells do not reach the
ACW site, and these wells are not affected by site contamination. The People's Crystal Ice
Company, located upgradient of the site at 1511 W. Government Street, does operate a well for
ice production. Samples were collected from a nest of wells near the ice company well, and
results indicated the presence of very low levels of phenol to a depth of 100 ft. However, the
well is 190 ft. deep, and it is sampled annually to comply with permit requirements.
5.2 Results of Groundwater Investigations
In order to facilitate discussions of groundwater contamination at the ACW site, EPA refers to
three zones within the Sand-and-Gravel aquifer known as the shallow zone, intermediate zone, and
deep zone. The shallow zone represents groundwater at depths of up to 30 feet b.l.s.
The-intermediate zone extends from 30 feet to 70 feet b.l.s., and the deep zone includes
groundwater at depths greater than 70 feet. These zone descriptions have no geologic
significance, but they provide a convenient way of referencing data from specific depths within
the aquifer.
Contamination in the shallow zone appears to be limited to the area below and immediately
downgradient of the ACW site. The primary sources of this contamination were the four former
wastewater lagoons on the ACW property. Although EPA drained these lagoons, stabilized the
sludges, and placed a clay cap over the stabilized material in 1983, these concentrated wastes
may continue to serve as a contaminant source for the shallow groundwater. Volatile organic
compounds (VOCs), phenols, and (PAHs) were detected in wells installed in this zone. EPA also
observed a separate DNAPL layer of oil and creosote in this zone. The limits of contamination
in the shallow zone above remedial goals is illustrated in Figure 2.
<IMG SRC 0494208A>
The intermediate zone appears to have the highest level of contamination. The highest
contaminant concentrations were detected on-site immediately downgradient of the former sludge
ponds. VOCs, phenols, and PAHs were detected at levels above standards protective of human
health. VOCs, phenols, and PAHs were also found in significant concentrations off-site in the
direction of groundwater flow. The contaminant plume containing these compounds has extended
past Sonia Street, and it is approaching Pensacola Bay. A DNAPL layer was also observed in this
zone. The extent of contamination above remedial goals in the intermediate zone is illustrated
in Figure 3.
PAHs, VOCs, and phenols have also been detected in significant concentrations in the deep zone.
However, VOC/phenol contamination has migrated further downgradient than PAH contamination. The
majority of the PAH contamination was found on-site and immediately downgradient from the site.
In contrast, VOC and phenol contamination was detected in a well just north of Pensacola Bay
and Bayou Chico. The extent of contamination above remedial goals in the deep zone is
illustrated in Figure 4.
Based on the data available to date, EPA estimates that 152 million gallons of groundwater will
require treatment. While 7.25 million gallons of DNAPL are estimated to be present in the
saturated zone, EPA expects that only 2 million gallons (approximately 30 percent) of this
material can be recovered. However, further investigations will be necessary during the design
to refine these volume estimates.
6.O SUMMARY OF SITE RISKS
6.1 Human Health Risks
In order to evaluate whether existing or future exposure to contaminated groundwater could pose
a risk to people or the environment, EPA completed a Baseline Risk Assessment (BRA) in August
1993. In estimating potential site risks, EPA assumed no further action would be taken to
address contamination at the site. This evaluation then served as a baseline for determining
whether cleanup of each site media was necessary. In the BRA, EPA evaluated site risks for
several environmental media. However, this ROD addresses only the risks attributable to
chemicals in the groundwater at the ACW site. The risk assessment included the following major
components: contaminants of concern, exposure assessment, toxicity assessment; and risk
characterization.
6.1 Contaminants of Concern
Chemicals are included in the Summary of Site Risks section as contaminants of concern if the
results of the risk assessment indicate that the contaminant might pose a significant current or
future risk. Contaminants of concern are those compounds that contribute to a pathway that
exceeds a 1x10-4 risk or a Hazard Index (HI) of 1. Chemicals contributing risk to these
pathways were not included if their individual carcinogenic risk contribution was less than
1x10-6 or their noncarcnogenic Hazard Quotient (HQ) was less than 0.1. In addition, chemicals
were included if they exceeded either State or Federal ARARs. A list of contaminants of concern
for groundwater and their associated exposure point concentrations is shown in Table 1. The
exposure point concentration for each contaminant was derived using the 95 percent upper
confidence limt (UCL) on the arithmetic mean as defined by the following formula:
_
95% UCL = X + F n x 1.96
where: X = arithmetic mean of the data
Fn = standard deviation of the data
If the 95% UCL resulted in a concentration higher than the maximum concentration detected, the
maximum concentration detected was used as the exposure point concentration. In order to
provide an accurate assessment of risk from the site, EPA calculated exposure point
concentrations using sampling results from the Phase II Post-RI, which provided the most current
and complete set of groundwater data available.
<IMG SRC 0494208B>
<IMG SRC 0494208C>
The site is currently abandoned. However, it was assumed for the purposes of the BRA that
future development could result in the site itself becoming residential, since it is currently
surrounded on the south and east by residential properties. The groundwater is not currently
used for drinking water since the area is serviced by the City of Pensacola potable water supply
system. However, EPA assumed in the BRA that the groundwater could be used for drinking water
and other potable uses in the future in the event existing institutional controls designed to
prevent or limit groundwater use were not enforced. Additionally, private wells which have been
documented to exist in the area are currently used for irrigation purposes.
6.1. Exposure Assessment
In the exposure assessment, EPA considered ways in which people could come into contact with
contaminated groundwater under both current and future conditions. EPA determined that there is
no exposure to contaminated groundwater under current conditions. However, under potential
future scenarios, both existing off-site residents and hypothetical on-site residents could be
exposed if groundwater were used as a potable water source. It was assumed that people could
potentially drink and bathe with this water, resulting in exposure through the ingestion, dermal
contact, and inhalation pathways. In addition to evaluating future adult resident exposure, EPA
considered potential exposure for a child resident, since children generally represent a more
sensitive population. Final lifetime risk estimates were then calculated by summing the risks
derived from both adult and child exposures.
Table 1
Contaminants of Concern and
Exposure Point Concentrations
Contaminant of Concern
Exposure Point
Concentration (mg/l)a
Future Offsite
Residents
Carcinogenic PAHs (total)
Benzo(b and/or k)Fluoranthene
Benzo(a)Anthracene
Chrysene
Naphthalene
Acenaphthene
Dibenzofuran
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Bis(2-ethylhexyl)Phthalate
2-Methylphenol
(3-and/or 4-)Methylphenol
Phenol
2,4-Dimethylphenol
Pentachlorophenol
1,2,4-Trichlorobenzene
Carbazole
Quinoline
Benzene
Cis-1,2-Dichloroethene
Methyl Ethyl Ketone
Styrene
Trans-1,2-Dichloroethene
Vinyl Chloride
a
b
--
81
24
30
27
580
320
240
300
830
37
270
170
0.02b
4.3
20
6.4
7.3
1.9
1.0
0.9
7.6
0.09
0.87
0.10
0.03
0.34
0.26
Future Onsite
Residents
330
96
120
110
1,400
760
560
710
2,000
150
1,100
690
.015
7.7b
38b
25
11b
3.9b
- 1.0b
20b
.10b
- .14b
.04b
_ _
_ _
Results rounded to two significant figures
Maximum concentration detected was used as exposure point
concentration
Compound was not detected in on-site groundwater
The exposure assumptions for each pathway are provided in Table 2. The same exposure assumptions
were used for both off-site and on-site adult residents. Similarly, the same assumptions were
used for both off-site and on-site child residents. Based on the exposure point concentrations
derived from site data for the compounds shown in Table 1 and using the exposure assumptions
identified in Table 2, EPA estimated the average daily intake (DI) associated with each exposure
pathway and population combination. The formulas used to calculate the DI for each pathway are
provided in Table 3.
6.1.3 Toxicity Assessment
The toxicity assessment evaluated possible harmful effects of exposure to each contaminant of
concern. A number of compounds found at the site, including benzene, PAHs, pentachlorophenol
(PCP), and dioxins, have the potential to cause cancer (carcinogenic). Slope factors (SFs) have
been developed by EPA,s Carcinogenic Assessment Group for estimating lifetime cancer risks
associated with exposure to potentially carcinogenic compounds. These SFs, which are expressed
in units of (mg/kg-day)-1, are multiplied by the estimated intake of a potential carcinogen to
provide an upper-bound estimate of the excess lifetime cancer risk associated with exposure at
that intake level. The term "upper bound" reflects the conservative estimate of the risks
calculated from the SF. Use of this approach makes underestimation of the actual cancer risk
highly unlikely. Slope factors are derived from results of human epidemiological studies or
chronic animal bioassays to which animal-to-human extrapolation and uncertainty factors have
been applied. The SFs for the carcinogenic contaminants of concern are contained in Table 4.
Other contaminants of concern, such as dibenzofuran, may cause other problems not related to
cancer. Reference doses (RfDs) have been developed by EPA for indicating the potential for
adverse health effects from exposure to contaminants of concern exhibiting noncarcinogenic
effects. RfDs, which are expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals. Estimated intakes of contaminants
of concern from contaminated groundwater can be compared to the RfD. RfDs are derived from
human epidemiological studies or animal studies to which uncertainty factors have been applied
(to account for the use of animal data to predict effects on humans). The RfDs for the
noncarcinogenic contaminants of concern are also provided in Table 4.
As an interim procedure until more definitive Agency guidance is established, Region IV has
adopted a toxicity equivalency factor (TEF) methodology for evaluating chlorinated dioxins and
furans. This methodology relates the relative potency of each dioxin or furan congener to the
potency of 2,3,7,8-tetrachlorodibenzodioxin (2,3,7,8-TCDD), the most toxic dioxin compound. The
TEFs for the doxins/furans are presenced in Appendix A.
Table 2
Exposure Assumptions for
Future On-Site and Off-site Residents
Exposed to Contaminated Groundwater
Parameter
Assumed Value
Adult Residents
Child Residents
Exposure Frequency (EF)
350 days/yra
350 days/yra
Exposure Duration (ED)
chronic: 12 years
lifetime: 24 years
chronic: 6 years
Body Weight (BW)
70 kg
16 kg
Averaging Time (AT)
chronic: 4,380 days
lifetime: 25,550 days
chronic: 2,190 days
lifetime: 25,550 days
2.0 L/day
1.4 L/day
Skin Surface Area (SA)
18,150 cm²
7,195 cm²
Exposure Time (ET)
0.2 hr/day
0.2 hr/day
Conversion Factor for Water (CF)
1L/1000 cm3
1L/1000 cm3
Inhalation Rate
0.6 m3/hr
0.6 m3/hr
Exposure Time
0.2 hr/day
0.2 hr/day
Standard Assumptions
Ingestion Pathway
Ingestion Rate (IR)
Dermal Contact Pathway
Inhalation Pathway
a
Assumes people are not home during 2 weeks of vacations per year
Table 3
Daily Intake (DI) Formulas
Ingestion Pathway
CSxIRxEFxED
DI=------------BWxAT
where:
DI
CS
IR
EF
ED
BW
AT
=
=
=
=
=
=
=
average daily intake (mg/kg/day)
exposure point concentration (mg/L)
ingestion rate (L/day)
exposure frequency (days/yr)
exposure duration (years)
body weight (kg)
averaging time (days)
Dermal Contact Pathway
CSxSAxPCxETxEFxEDxCF
DI=---------------------BWxAT
where:
DI
CS
SA
PC
ET
EF
ED
CF
BW
AT
=
=
=
=
=
=
=
=
=
=
average daily adsorbed dose (mg/kg/day)
exposure point concentration (mg/L)
skin surface area available for contact (cm²)
permeability constant (cm/hr)
exposure time (hours/day)
exposure frequency (days/yr)
exposure duration (years)
volumetric conversion factor for water (1L/1000 cm3)
body weight (kg)
averaging time (days)
Inhalation Pathway
CSxIRxETxEFxED
DI=--------------BWxAT
where:
DI
CS
IR
ET
EF
ED
BW
AT
=
=
=
=
=
=
=
=
average daily intake (mg/kg/day)
exposure point concentration (mg/L)
inhalation rate (m3/hr)
exposure time (hours/day)
exposure frequency (days/yr)
exposure duration (years)
body weight (kg)
averaging time (days)
Table 4
Toxicity Values for
Contaminants of Concern
Weight of
Evidence for
Cancer
D
D
D
D
D
B2
B2
B2
B2
B2
D
B2
B2
ORAL INHALATION
Contaminant of Concern
Cancer SF
Naphthalene
Acenaphthene
Dibenzofuran
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)pyrene1
Benzo(b and/or k)fluoranthene
Benzo(a)anthracene
Chrysene
Bis(2-ethylhexyl)phthalate
2-Methylphenol
(3-and/or 4-)Methylphenol
Phenol
2,4-Dimethylphenol
Pentachlorophenol
1,2,4-Trichlorobenzene
Carbazole
7.3E+00
7.3E+00
7.3E+00
7.3E+00
1.4E-02
1.2E-01
2.0E-02
Chronic RfD
Reference
4.0E-03
6.0E-02
1.0E-02
4.0E-02
HEAST
IRIS
HEAST
IRIS
3.0E-01
4.0E-02
3.0E-02
IRIS
IRIS
IRIS
IRIS
*
*
*
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
HEAST
HEAST
2.0E-02
5.0E-02
5.0E-02
6.0E-01
2.0E-02
3.0E-02
1.3E-03
Cancer SF
Chronic RfD
6.1E+00
Reference
HEAST
9.0E-03
HEAST
Table 4
(Continued)
Weight of
Evidence for
Cancer
C
A
D
B2
A
B
IRIS
HEAST
1
*
Contaminants of Concern
Quinoline
Benzene
Cis-2,3-Dichloroethene
Methyl Ethyl Ketone
Styrene
Trans-1,2-Dichloroethene
Vinyl Chloride
2,3,7,8-TCDD (equivalents)
Cancer SF
ORAL INHALATION
Chronic RfD Reference
1.2E+01
2.9E-02
3.0E-02
1.9E+00
1.5E+05
1.0E-02
5.0E-02
2.0E-01
2.0E-02
Cancer SF
HEAST
IRIS
IRIS
IRIS
IRIS
IRIS
HEAST
IRIS
Chronic RfD
2.9E-02
HEAST
1.0E+00
1.0E+00
3.0E-01
1.5E+05
Integrated Risk Information System
Health Effects Assessment Summary Tables
Although Benzo(a)pyrene (BaP) was not detected in groundwater, EPA customarily relates the potency of other
carcinogenic PAHs to thc toxicity of BaP. For the ACW site, it was assumed that each carcinogenic PAH was
as potent as BaP.
Since no slope factor exists for this compound, the slope factor for BaP was used.
assumption, since the other PAHs are considered less toxic than BaP.
Reference
This is a conservative
IRIS
IRIS
HEAST
IRIS
6.1.4 Risk Characterization
The centerpiece of the BRA is the risk characterization, which combines the other components of
the evaluation to estimate the overall risk from exposure to site contamination. For cancercausing compounds, risk is a probability that is expressed in scientific notation. For example,
an excess lifetime cancer risk of 1x10-6 means that an individual has an additional 1 in
1,000,000 chance of developing cancer as a result of site-related exposure over an estimated 70
year lifetime. EPA has established a target risk range for Superfund cleanups of between 1x10-4
(1-in 10,000) and 1x10-6. The formula used for calculating cancer risks is shown below:
Risk = DI x SF
where:
risk =
DI =
SF =
a unitless probability of an individual developing cancer
chronic daily intake averaged over 70 years (mg/kg-day)
slope-factor, expressed as (mg/kg-day)-1.
Estimated cancer risks associated with potential future potable use of groundwater at the ACW
site are extremely high, approaching 1.0 for the ingestion and dermal contact exposure pathways
for both on-site and off-site residents. These upper bound probability estimates predict that
an individual exposed to the concentrations and exposure rates assumed in the BRA will contract
cancer. These risks are primarily associated with PAHs in the groundwater. Inhalation risks for
both on-site and off-site residents were associated with VOC contamination. A summary of the
cancer risks for each contaminant of concern is presented in Table 5. Total cancer risks for
each population group evaluated are provided in Table 6.
For compounds which cause toxic effects other than cancer, EPA compared the average
concentration of a contaminant found at the site with a reference dose representing the maximum
amount of a chemical a person could be exposed to without experiencing harmful effects. The
ratio of the average daily intake to the reference dose is called a hazard quotient (HQ). The
formula for calculating the HQ is shown below:
Noncancer HQ = DI/RfD
where:
DI = chronic daily intake
RfD = reference dose
DI and RfD are expressed in the same units (mg/kg-day) and represent the same exposure
period (i.e., chronic, subchronic, or short-term).
Table 5
Individual Risks Associated with
Contaminants of Concern1
Hazard Quotients
Contaminants of Concern
On-site Groundwater
Ingest.
(Child)
Naphthalene
30,000
Acenaphthene
1,000
Dibenzofuran
5,000
Fluorene
1,000
Phenanthrene
-Anthracene
40
Fluoranthene
2,000
Pyrene
2,000
Benzo(b and/or k)fluoranthene -Benzo(a)anthracene
-Chrysene
-Bis(2-ethylhexyl)phthalate
0.06
2-Methylphenol
10
(3-and/or 4-)Methylphenol
60
Phenol
4
2,4-Dimethylphenol
50
Pentachlorophenol
10
1,2,4-Trichlorobenzene
0
Dermal
(Child)
4,000
300
1,000
500
-20
2,000
1,000
---0.003
0.04
0.4
0.04
1
10
0
Cancer Risks
Off-site Groundwater
Inhal.
(Child)
Ingest.
(Child)
-----------------0
10,000
400
2,000
600
-10
600
500
---0.08
7
30
0.9
30
5
60
Dermal
(Child)
2,000
100
600
200
-5
400
300
---0.004
0.02
0.2
0.01
0.9
7
10
On-site Groundwater
Inhal.
(Child)
Ingest.
(Adult)
-----------------10
--------1.0E+00
1.0E+00
1.0E+00
2.0E-06
----4.4E-03
--
Off-site Groundwater
Dermal Inhal.
(Adult) (Child)
--------1.0E+00
1.0E+00
1.0E+00
1.7E-07
----1.0E-02
--
-------------------
Ingest.
(Adult)
--------1.0E+00
1.0E+00
1.0E+00
2.6E-06
----2.1E-03
--
Dermal
(Adult)
Inhal.
(Child)
--------1.0E+00
1.0E+00
1.0E+00
2.3E-07
----5.0E-03
--
-------------------
Table 5
(continued)
Hazard Quotients
Contaminants of Concern
On-site Groundwater
Ingest.
(Child)
Carbozole
Quinoline
Benzene
Cis-2,3-Dichloroethene
Methyl Ethyl Ketone
Styrene
Trans-1,2-Dichloroethene
Vinyl Chloride
Total Pathway
---0
0.2
0.02
0
-41,000
Dermal
(Child)
---0
0.0005
0.002
0
-8,800
Inhal.
(Child)
----0.02
0.005
--0.03
Cancer Risks
Off-site Groundwater
On-site Groundwater
Ingest.
(Child)
Dermal
(Child)
Inhal.
(Child)
Ingest.
(Adult)
---7
0.2
0.01
1
--
---0.1
0.0004
0.001
0.03
--
----0.02
0.004
---
1.9E-04
9.0E-01
2.7E-05
--1.1E-05
-0.0E+00
1.0E-06
1.2E-02
2.1E-06
--2.2E-06
-0.0E+00
10
1.0E+00
1.0E+00
14,000
3,600
1
The risk for the sensitive population (adult or child) is shown.
--
No RfD or Slope Factor is available for the compound under this pathway.
Dermal
(Adult)
Off-site Groundwater
Inhal.
(Child)
Ingest.
(Adult)
Dermal
(Adult)
Inhal.
(Child)
--2.9E-05
0.0+00
---0.0E+00
1.7E-04
5.8E-01
2.5E-05
--8.5E-06
-4.6E-03
9.2E-07
4.7E-03
1.9E-06
--1.7E-06
-1.2E-04
--2.6E-05
7.0E-05
---7.8E-04
2.9E-05
1.0E+00
1.0E+00
1.5E-03
Table 6
Summary of Future Cancer Risks
Associated with Groundwater Contamination
Excess Lifetime Cancer Risk
Groundwater
Exposure Pathway
Adult
On-site
Resident
Child
On-site
Resident
Adult
Off-site
Resident
Child
Off-site
Resident
Ingestion
1.0E+00
1.0E+00
1.0E+00
1.0E+00
Dermal Contact
1.00E+00
1.0E+00
1.0E+00
1.0E+00
Inhalation
2.7E-05
2.9E-05
1.4E-03
1.5E-03
Total Cancer Risk1
1.0E+00
1.0E+00
1.0E+00
1.0E+00
1
Cancer risks cannot theoretically exceed 1.0, since
risk is presented as a probability. A risk level
of 1.0 predicts that an individual exposed to the
concentrations and exposure rates assumed in the
BRA will contract cancer.
Table 7
Summary of Future Hazard Quotients
Hazard Quotient
Groundwater
Exposure Pathway
Ingestion
Dermal Contact
Inhalation
Total Hazard Index1
Adult
On-site
Resident
Child
On-site
Resident
13,000
41,000
5,300
14,000
5,100
8,800
2,000
3,600
.006
0.3
3
10
50,000
7,000
20,000
20,000
1
The Hazard index was rounded to one significant figure.
Adult
Off-site
Resident
Child
Off-site
Resident
The hazard index (HI) can be generated by adding the HQs for all contaminants of concern that
affect the same target organ (such as the liver) within a medium or cross all media to which a
given population may reasonably be exposed. In general, EPA considers an HI of 1.0 to be the
maximum acceptable hazard. However, the ACW risk assessment estimated an HI of 50,000 for a
future child on-site resident. For both on-site and off-site residents, non-cancer risks for
ingestion of and dermal contact with site groundwater were primarily associated with PAHs.
Non-cancer risks for the inhalation pathway stemmed from VOC contamination in the groundwater.
A summary of the potential future HQs for each contaminant of concern is presented in Table 5.
Hazard indices (HIs) for each population group are in Table 7.
It should be stressed that current human health risks associated with direct exposure to
contaminated groundwater are minimal since residents near the site are connected to the City of
Pensacola potable water supply. Therefore, no one is currently using the groundwater near the
ACW site for drinking or bathing. However, as indicated in Section 6.1.1, EPA has evidence to
suggest that some private wells located in the vicinity of the site are being used for
residential irrigation purposes. Based on samples collected from two of these wells in June
1988, EPA plugged an irrigation well on the condominium property south of the site in 1991. A
survey of residents near the site will be necessary to locate as many additional wells as
possible.
In summary, the results of the BRA indicate that human-health risks associated with potential
future scenarios at the ACW site exceed EPA's target risk range for protection of human health.
Therefore, actual or threatened releases of hazardous substances in the groundwater in the area
of the ACW site, if not addressed by EPA's preferred alternative or one of the other
alternatives considered, may present a current or potential threat to public health and the
environment.
6.1.5
Uncertainties in the Risk Assessment
The factors that contribute uncertainty to the estimates of exposure concentrations, daily
intakes, and toxicity information also contribute uncertainty to the estimates of risk. These
factors include:
•
•
•
•
•
Chemicals not included in the risk assessment
Exposure pathways not considered
Derivation of exposure point concentrations
Intake uncertainty
Toxicological dose-response and toxicity values
If a compound does. not have an assigned slope factor and it had data qualifiers indicating the
presumptive evidence of its presence, it was eliminated from the quantitative risk assessment.
Compounds identified using presumptive evidence cannot be given the same weight as a compound
which was positively identified. If a compound had data qualifiers indicating that the data
were not useable, it was alo eliminated from the risk assessment. Also, compounds that do not
have an assigned reference dose or slope factor were eliminated from the risk assessment.
Elimination of these compounds will result in an underestimation of risk.
There are uncertainties associated with summing cancer risks or hazard indices for different
chemicals. The cumulative dose ignores possible synergism or antagonism among chemicals and
differences in mechanism of action and metabolism. However, for the ACW site, the risks for
most of the individual contaminants of concern fell outside the acceptable risk range prior to
being summed.
Another uncertainty surrounds the fact that risk calculations for dermal exposure to all
compounds are evaluated using dermal toxicity value. The dermal toxicity values represent an
adjustment to the oral toxicity value to reflect an adsorbed dose rather than an administered
dose. The accuracy of this adjustment depends on the suitability of the absorption rate which
was used to make the adjustment. This and other uncertainties need to be considered when
evaluating the results of the risk assessment and when making risk management decisons for the
site.
6.2 Environmental Risks
To evaluate the potential ecological impacts from the site, EPA initiated a phased approach to
ecological studies. The initial phase of the ecological assessment, known as the Dye Dispersion
and Sediment Sampling Study, was completed by EPA in 1991. The objective of this study was to
determine the presence and concentration of site-related contaminants within the area of
Pensacola Bay influenced by surface water drainage from the PYC drainage ditch. This ditch has
historically received surface runoff from the ACW site, and contaminated groundwater may also be
discharging into the ditch.
Significant conclusions from the study are presented below:
•
Continuous communication between the PYC ditch and the bay was afforded by the
presence of an 18-inch concrete culvert even when the mouth of the ditch was
occluded by a sandbar.
•
The presence of a 15 ft. deep navigation channel entering Bayou Chico suggests a
potential additional source for contamination in the nearshore bay area.
•
No organic compounds were detected within the upper stratum of the bay sediments.
•
Toxic levels of organic compounds, principally anthracene, fluoranthene, and pyrene,
were detected within the drainage ditch and lower stratum of the bay sediments at
the mouth of the ditch.
•
Levels of organics and metals in the surface waters were within normal ranges found
throughout southeastern estuarine systems.
Following evaluation of
Trustees will determine
the collection of water
contaminant levels, and
the results of this investigation, EPA, FDEP, and the Natural Resource
whether a subsequent study is necessary. The second study would involve
and sediment samples for toxicity tests, testing of biota for
bioaccumulation studies.
7.0 DESCRIPTION OF ALTERNATIVES
EPA conducted an FS to identify and evaluate appropriate remedial alternatives for minimizing
current and future risks to people and the environment posed by contaminated groundwater. In
the FS, remedial alternatives were assembled from applicable remedial activities known as
process options. These alternatives were initially evaluated for effectiveness,
implementability, and cost. In order to fully address this contamination, EPA considered four
alternatives for removing and treating the separate DNAPL layer and five alternatives for
treating dissolved groundwater contamination. Included among the remedial alternatives is the no
action alternative, which is required by the NCP to serve as a basis for comparison to the other
alternatives.
Alternatives considered for addressing DNAPL contamination at the ACW site include the
following:
Alternative
Alternative
Alternative
Alternative
DN1
DN2
DN3A
DN3B
-
No Action
DNAPL Extraction and On-site Thermal Treatment
DNAPL Extraction and Off-site Treatment
DNAPL Extraction and Recycling
The alternatives considered for addressing dissolved groundwater contamination include the
following:
Alternative
Alternative
Alternative
Alternative
Alternative
GW1
GW2
GW3A
GW3B
GW4
-
No Action
Groundwater Use Restrictions and Monitoring
Extraction, Treatment, and Surface water Discharge
Extraction, Treatment, and Reinjection
In-Situ/Ex-Situ Bioremediation
7.1 Alternative DN1 - No Action
Under the No Action alternative for DNAPLs, no remedial action would be taken at the ACW site to
address the separate DNAPL layer in the groundwater. No measures would be taken to reduce the
potential for exposure through the use of institutional controls, containment, treatment, or
removal of DNAPLs. As required by the NCP, the no action alternative provides a baseline for
comparison with the other alternatives which offer a greater level of response.
EPA estimated that approximately 7.25 million gallons of DNAPL are present in the aquifer
beneath and immediately down-gradient of the site. Since Alternative DN1 does nothing to remove
or contain any of this material, the risks posed by the site would likely increase as the DNAPL
migrates both horizontally and vertically, contaminating currently uncontaminated portions of
the aquifer and potentially impacting surface water. There are no costs associated with
implementation of Alternative DN1.
7.2 Alternative DN2 - DNAPL Extraction, On-site Thermal Treatment
Alternative DN2 involves extraction of a combination of groundwater and DNAPL contamination,
separation of the aqueous and non-aqueous phases, treatment and reinjection of groundwater, and
on-site incineration of recovered DNAPL.
Enhanced removal technologies would be used to increase the DNAPL removal efficiency. Enhanced
removal can include the use of one or more of the following process options: water flooding,
alkaline water flooding, surfactant water flooding, and polymer water flooding. Water flooding
utilizes the injection of water into wells to hydraulically sweep DNAPL toward production or
recovery wells. Alkaline water flooding relies on the addition of alkaline agents into the
water flood which raise the pH of the water and react with organic acids in the DNAPL to
generate surfactants at the oil-water interface. This reaction leads to improved recovery
due to reduced interfacial tension, emulsification effects, and wettability reversals.
Surfactant water flooding involves the injection of a surfactant solution as a slug in a
flooding sequence to decrease the interfacial tension between DNAPL and water by several orders
of magnitude. This has the effect of improving the displacement efficiency of the flood,
increasing DNAPL recovery, and reducing residual DNAPL saturation. Polymer water flooding uses
polymers in the flood to reduce the mobility ratio (mobility of the displacing fluid divided by
the mobility of the displaced fluid). The result is improved sweep efficiency. A typical
flooding sequence might consist of water, alkaline, surfactant, and polymer-flooding conducted
in series, followed by water flooding to displace the viscous polymer and DNAPL cobination.
Alternative DN, conceptually involves the use of two extraction wells pumping at a combined rate
of up to 100 gpm. The enhancing agents are introduced into the aquifer via two injection wells
located just upgradient of the DNAPL zone. Employing a flooding sequence similar to the one
described above, it is expected that a maximum of 30 percent of the DNAPL can be extracted in 50
pore volumes. This means that based on an estimated 7.25 million gallons of DNAPL present in
the subsurface, only 2 million gallons are recoverable using enhanced recovery methods. It
would take approximately 30 years to remove 50 pore volumes. Further characterization of the
extent of DNAPL contamination, aguifer pumping tests, and detailed computer modeling will be
necessary during design to determine well locations, depths, and pumping rates.
Following extraction, water and DNAPL would be separated using centrifugation or another
appropriate separation technology. The DNAPL would be thermally destroyed on-site in accordance
with RCRA requirements in 40 CFR 264.601 and 265.400, and the recovered water would be treated
to meet Federal and State primary drinking water maximum contaminant levels (MCLs) using the
selected groundwater treatment alternative.
The estimated capital cost for this alternative is $3,441,000, with an annual operation and
maintenance (O&M) cost of $546,000. This results in a net present worth cost of $11,825,000 for
Alternative DN2.
7.3 Alternative DN3A - DNAPL Extraction; Off-site Treatment
This alternative is similar to Alternative DN2, except the recovered DNAPL would be transported
off-site to an approved RCRA facility for treatment. Currently, the only off-site treatment
technology widely available is incineration, so cost estimates are based on ths technology.
RCRA requirements under 40 CFR 263 and 264 would apply to the transportation of the DNAPLs, and
the off-site treatment facility would have to meet requirements in 40 CFR 264.601 and 265.400
and the Superfund Off-site Policy (OSWER Directive 9834.11).
The estimated capital cost for this alternative is $2,506,000, with an annual O&M cost of
$867,000. This results in a net present worth cost of $15,832,000 for Alternative DN3A.
7.4 Alternative DN3B - DNAPL Extraction; Recycling
This alternative is similar to Alternative DN3A, except the recovered DNAPL would be transported
to a recycler for reuse as product. The significant volume of DNAPL which is expected to be
recovered at the ACW site makes recycling a viable alternative.
This alternative would utilize a temporary unit (TU) as defined by RCRA Subtitle C for the
storage of DNAPLs at the site until sufficient quantities accumulate for off-site transport and
recycling. The alternative would comply with all substantive portions of the corrective action
management unit (CAMU) rule pertaining to TUs. This TU would therefore not be subject to the
requirements of the RCA and Disposal Restrictions or Minimum Technology Requirements. Off-site
recycling activities would comply with the provisions of the Superfund Off-site Policy.
The estimated capital cost for this alternative is $2,586,000, with an annual OM cost of
$351,000. This results in a net present worth cost of $7,978,000 for Alternative DN3B.
All alternatives for the extraction of DNAP are expected to leave behind a significant amount of
residual DNAPL in the naturated zone (an estimated 70%). The residual DNAP will be a source of
groundwater contamination by dissolution over time. In order to control the migration of
contaminated groundwater, a containment system consisting of extraction and/or injection wells
may also be necessary.
7.5 Alternative GW1 - No Action
Under the No Action alternative for groundwater, no remedial action would be taken at the ACW
site to address dissolved contamination in the groundwater. No measures would be taken to
reduce the potential for exposure through the use of institutional controls, containment;
treatment, or removal of contaminated water. As required by the NCP, the no action alternative
provides a baseline for comparison with the other alternatives which offer a greater level of
response.
EPA estimates that approximately 152 million gallons of groundwater are contaminated above the
site-specific alternate concentration limits (ACLs) established under CERCLA Section
121(d)(2)(B)(ii) for the site. These ACLs, shown in Table 8, were developed to ensure
compliance with surface water standards at the point where groundwater discharges to surface
water. Since area residents and businesses are on the city water supply, and the groundwater in
the vicinity of the site is presently proposed as a delineated area under Chapter 17-524.420,
F.A.C. to restrict the potable use of the aquifer, EPA believes that adequate institutional
controls exist to support the use of ACLs. Therefore, ACLs are more appropriate than primary
drinking water standards (MCLs) or risk-based levels as remedial goals for groundwater.
Since Alternative GW1 does nothing to remove or contain any of this contamination, the risks
posed by the site would likely increase as groundwater contaminants migrate both horizontally
and vertically, degrading currently uncontaminated portions of the aquifer and potentially
impacting surface water. There are no costs associated with implementation of Alternative GW1.
TABLE 8
Groundwater Remedial Goals
Compound
Volatile Organics
Benzene
Semi-Volatile Organics
Acenaphthene
Fluoranthene
Naphthalene
Total Carcinogenic PAHs
Benzo(a)Anthracene
Benzo(b&k)Fluoranthene
Benzo(a)Pyrene
Chrysene
Anthracenea
Fluorenea
Phenanthrenea
Pyrenea
Dibenzofuran
Pentachlorophenol
a
Remedial Goals
(ug/l)
91
9,000
1,500
21,900
1,100
1,100
44
296,000
These compounds, while not currently considered to be carcinogenic, were
originally incorporated into the ACL calculation for carcinogenic PAHs.
7.6 Alternative GW2 - Groundwater Use Restrictions and Monitoring
Under this alternative, institutional controls would be implemented, restricting the use of the
groundwater from the contaminated plume within the Sand-and-Gravel Aquifer. These State-imposed
restrictions include deed restrictions preventing current and future use of the aquifer for such
purposes as potable and industrial water supplies, irrigation, washing, etc. Permit restrictions
would require the State of Florida to restrict all well drilling permits issued for new wells on
the properties which may impact the contaminated groundwater plume. These restrictions would be
written into the property deeds to inform future property owners of the possibility of
contaminated groundwater beneath their property.
In addition to these restrictions, quarterly groundwater monitoring of all existing monitor
wells would be implemented. Analytical parameters to be evaluated would include at a minimum
PAHs, PCP, VOCs, phenols, and dioxin. Surface water monitoring would also be conducted at the
Pensacola Yacht Club drainage ditch to evaluate the potential impacts of contaminated
groundwater discharges on surface water quality. For cost estimating purposes, it was assumed
that monitoring would continue for a minimum of 30 years.
The primary ARARs which apply to this alternative are the ACLs developed by EPA as remedial
goals for groundwater. Since no extraction or treatment of groundwater would take place under
this alternative, exceedences of these levels would continue to occur, and the risks posed by
contaminated groundwater would continue to increase.
The estimated capital cost for this alternative is $197,000, with an annual operation and
maintenance (OM) cost of $83,000. This results in a net present worth cost of $1,474,000 for
Alternative GW2.
7.7 Alternative GW3A - Extraction and Treatment; Surface Water Discharge
Under this alternative, three extraction wells would pump contaminated groundwater at a combined
rate of 105 gpm to an on-site treatment facility. Primary treatment steps are UV-oxidation,
activated sludge, and granular activated carbon (GAC) adsorption. Auxiliary processes include
dissolved air floatation (pretreatment), sludge dewatering via a filter press, and filtration
prior to GAC adsorption. Treated groundwater would be discharged to Pensacola Bay. The goal of
this alternative would be to treat groundwater to the remedial goals outlined in Table 8.
However, the ability to achieve these goals throughout the plume cannot be determined until the
extraction and treatment system has been implemented and modified as necessary and the plumes
response has been monitored over time.
In general, the extraction well layout is conceptual based on an analytical groundwater model.
It is assumed that the extraction wells will be placed to the depth of the lower most zone of
contamination. Upon completion of aquifer testing to be conducted during design, detailed
groundwater flow modeling would be performed to more precisely estimate locations and depths of
wells along with pumping rates that will be required to extract groundwater from the various
zone within the aquifer. The assumed duration of the extraction and treatment process is 30
years, which will provide for treatment of approximately 11 pore volumes of contaminated
groundwater from the plume.
Inclusion of a dissolved air flotation (DAF) system is required since the selected DNAPL
recovery system is expected to leave a substantial amount of residual DNAPL contamination within
the aquifer. The DAF system includes a circular basin equipped with a skimming arm to handle
floating product, and a scraper arm and sludge trap for sinking product. The DAF system will
also benefit the UV-oxidation system, which is color sensitive, by providing a clearer influent.
The DNAPL will be periodically collected and treated using the selected DNAPL treatment
alternative. Preliminary sizing indicates that a 20 foot diameter basin is appropriate.
The UV-oxidation process involves use of ultraviolet light to catalyze the chemical oxidation of
organic contaminants in water by its combined effect upon the organic contaminant and its
reaction with hydrogen peroxide. The UV-hydrogen peroxide reaction would result in formation of
hydroxyl radicals, second only to fluorine in oxidative power, which then react with organic
contaminants in water. The UV-oxidation process is capable of quickly destroying VOCs such as
trichloroethane, vinyl chloride, tetrachloroethane, 1,1-dichloroethene, and others depending on
oxidation time. The system can also treat phenolic compounds and PAHs, such as naphthalene and
acenaphthalene. UV radiation has been used to generate mutated microorganisms capable of
biodegrading complex chlorinated organics. Pilot testing would be necessary to determine the
applicability of UV-oxidation in treating dioxins and PAHs. The UV-oxidation unit selected
would be a function of the flow rate and the required oxidation time, both of which would be
determined through pilot testing.
The activated sludge treatment process would be based on a system where aeration, clarification,
and sludge recycling would be provided in a single package unit. Several package plant designs
are available. Some systems consist of a single basin structure with an outer tank used for
aeration and an inner tank for clarification. Other package designs feature separate basins
that are operated in series for aeration and clarification. Multi-media tertiary filtration
would be dewatered via a filter press with filtrate recirculated to the activated sludge plant.
Dewatered sludges would be sampled to determine if they exhibit hazardous characteristics. If
the sludge is hazardous, it would be disposed in an off-site RCRA Subtitle C landfill.
Otherwise, the sludge could go to a RCRA Subtitle D sanitary landfill.
The GAC absorption system would consist of two sets of three down-flow carbon beds each
connected in series. For discussion and illustration purposes, each bed would be approximately
5 feet in diameter by 6 feet high. The GAC system is expected to provide polishing treatment to
remove any organics not removed by UV-oxidation or activated sludge treatment. Effluent from
the GAC system would be discharged to a clear well and monitored prior to surface water
discharge.
The treatment system would be designed to treat groundwater to the surface water discharge
standard outlined in the National Pollutant Discharge and Elimination System (NPDES) under the
Clean Water Act (40 CFR 122, Subpart C). Since the treated groundwater would be discharged
off-site, a permit would be required.
The estimated capital cost for this alternative is $3,553,000, with an annual O&M cost of
S349,000. This results in a net present worth cost of $8,910,000 for Alternative GW3A.
7.8 Alternative GW3B - Extraction and Treatment;
Reinjection
Alternative GW3B is similar to Alternative GW3A, except that treated groundwater would be
reinjected into the aquifer instead of being discharged to surface water. Reinjection would
provide a degree of containment of the contaminant plume and minimize salt water intrusion
associated with operation of the extraction system. The goal of this alternative would be to
treat groundwater to the remedial goals outlined in Table 8. However, the ability to achieve
these goals throughout the plume cannot be determined until the extraction and treatment system
has been implemented and modified as necessary and the plume's response has been monitored
over time.
Groundwater would be treated to meet Federal and State primary drinking water maximum
contaminant levels (MCLs) prior to being reinjected into the aquifer. The estimated capital
cost for this alternative is $3,662.000, with an annual O&M cost of S349,000. This results in a
net present worth cost of $9,019,000 for Alternative GW3B.
7.9 Alternative GW4 - In- Situ/Ex-Situ Bioremediation
Alternative GW4 combines in-situ and above-ground biological treatment. The process would
involve pumping contaminated groundwater at a combined rate of 105 gpm to an on-site treatment
facility, consisting of a DAF system, continuous flow bioreactor, clarifier, media filter, and a
GAC column. The treated effluent would then flow to a holding tank where hydrogen peroxide and
nutrients would be added prior to injection into the aquifer. The injection system was
developed solely to illustrate the general concept of oxidant/nutrient injection into the
aquifer. It is anticipated that the total bioremediation operation would require 5 years to
achieve aquifer restoration consistent with the remedial goals shown in Table 8. This scenario
will treat a total of approximately 1.8 pore volumes of contaminated groundwater. However, the
ability to achieve these goals throughout the plume cannot be determined until the extraction
and treatment system has been implemented and modified as necessary and the plume's response
has been monitored over time.
Use of the in-situ bioremediation techniques has potential advantages compared to conventional
"pump and treat" remedial actions for contaminated groundwater plumes. Using pump and treat
techniques, a residual fraction of-organic contaminants will remain adsorbed to organic and
mineral components of the aquifer matrix after effort to remove concentrated forms of the
contaminant, such as creosote oils, have ceased to be productive. This contaminant fraction may
be unrecoverable using standard pumping methods and will continue to slowly solubilize into the
groundwater system. Remediation of the aquifer using a standard pump and treat scheme typically
requires several flushes of the aquifer system within the affected area.
Bioremediation schemes attempt to either stimulate naturally occurring aerobic microorganisms to
degrade contaminants in situ, or introduce microorganism capable of degrading the contaminants.
Indigenous microorganisms would be used if capable of degrading site contaminants. Treatability
testing would be used to determine the need for specialized microbes. Typically, biodegradable
contaminants can be degraded at rates which are orders of magnitude greater than the leaching
rate of the contaminant in a soil/water system, provided environmentally limited nutrients and
oxygen are added as growth enhancing agents. In particular, phenolics, PAH's and ketones are
all readily biodegradable by many indigenous microorganisms.
The in-situ/ex-situ remediation process would first involve pumping of contaminated water from
extraction wells through the DAF system to remove any oil and free product prior to treatment in
the bioreactor, where the bulk of the contaminants would be removed. Oil and free product would
be addressed under one of the DNAPL remedial alternatives. The effluent from the bioreactor
would then flow to a clarifier where suspended solids would be settled out to avoid clogging
problems in the injection wells. Sludge from the clarifier would be dewatered via a filter
press, with filtrate recirculated to the bioreactor. Dewatered sludge would be transported to
an off-site landfill for disposal.
Effluent from the clarifier would then pass through a granular activated carbon column to remove
any remaining contaminants before flowing to a holding tank where it would be amended
with-inorganic nutrients and hydrogen peroxide. The nutrient-enriched water would then be
pumped to reinjection wells. Hydrogen peroxide is used as an oxygen source because it readily
breaks down into oxygen and water. This oxygen- and nutrient-rich water would enter the
aquifer, providing the oxygen and nutrients necessary for in-situ treatment.
This water also acts as a carrier for contaminants that have been released by the soils due to
the natural surfactants produced by the microbial activity. The contaminants would then be
available to in-situ degradation or they would be detroyed in the above-ground bioreactor after
extraction. This combination of in-situ and above-ground treatment would expedite the overall
aquifer restoration. An estimated 20 gpm of treated groundwater would be purged from the system
and discharged to the Escambia County Utilities Authority (ECUA) publicly owned treatment works
(POTW). Effluent monitoring would be performed prior to discharge to assure compliance with the
POW discharge limitation. In addition, periodic monitoring of influent groundwater would be
necessary to assess the effectiveness of the treatment process.
Groundwater would be treated to meet Federal and State MCLs prior to being reinjected into the
aquifer. The estimated capital cost for this alternative is $3,906,000, with an annual O&M cost
of $452,000. This results in a net present worth cost of $5,865,000 for Alternative GW4.
8.0 COMPARATIVE ANALYSIS OF GROUNDWATER AND DNAPL ALTERNATIVE
In this section, the performance of each alternative relative to the other alternatives will be
evaluated for each of the nine criteria identified in the NCP (40 CFR Part 300.430). The
criteria are listed in the NCP and discussed further in EPA,s guidance for conducting Remedial
Investigations and Feasibility Studies. The nine criteria are segregated into three categories.
Threshold Criteria are those which dictate the minimum standards with which a remedial
alternative must comply. Primary Balancing Criteria include those which are used to evaluate
the effectiveness of the remedial alternatives. Finally, Modifying Criteria are those which
may be used in distinguishing between equally protective alternatives. The nine criteria are
shown below:
Threshold Criteria
•
•
Overall Protection of Human Health and the Environment
Compliance with ARARs
Primary Balancing Criteria
•
•
•
•
•
Long-Term Effectiveness and Permanence
Reduction of Toxicity, Mobility, or Volume through Treatment
Short-term Effectiveness
Implementability
Costs
Modifying Criteria
•
•
State Acceptance
Community Acceptance
A comparison of the remedial alternatives with respect to each of these criteria and each other
is presented in the following sections. The discussion has been arranged to provide a
comparison among the DNAPL alternatives followed by a separate evaluation of groundwater
alternatives. Those alternatives which fail to meet the threshold criteria of overall protection
of human health and the environment and compliance with ARARs will be eliminated from further
analysis.
8.1 Overall Protection of Human Health and the Environment
This criterion assesses whether alternatives adequately protect human health and the environment
and to what degree an alternative would eliminate, reduce, or control the risks to human health
and the environment associated with the site through treatment, engineering, or institutional
controls. It is an overall assessment of protection that encompasses other criteria such as
long-term effectiveness and permanence, short-term effectiveness, and compliance with ARARs.
DNAPL:
Alternatives DN2, DN3A, and DN3B each provide equal protection of human health and the
environment. These alternatives reduce contamination in the aquifer through active recovery,
and they result in ultimate destruction or reuse of DNAPLs. However, each alternative will
leave a significant amount of contamination within the aquifer which must be addressed by an
appropriate groundwater alternative. Alternative DN1 is not protective of human health or the
environment, since DNAPL contamination would continue to migrate and further degrade groundwater
and surface water.
Groundwater:
Alternatives GW3A, GW3B, and GW4 would provide equal protection of human health and the
environment and would reduce the concentration of chemical constituents in the groundwater
through a combination of treatment and institutional controls. Alternative GW2 would provide
some protection of public health by preventing the widespread use of the contaminated water.
However, this alternative would do nothing to prevent contaminated groundwater discharges to
area surface water, putting both public health and the environment at risk. Alternative GW1 is
not protective of human health or the environment.
8.2 Compliance with ARARs
This criterion considers whether a remedial alternative meets all Federal and State ARARs.
Unless a waiver is justified, the selected remedy must comply with all chemical-specific,
location-specific, or action-specific ARARs.
DNAPL:
Alternatives DN2, DN3A, and DN3B would be designed to comply with all Federal and State ARARs.
Alternative DN3B is not required to comply with RCRA Land Disposal Restrictions or Minimum
Technology Requirements under 40 CFR Part 268 because this alternative utilizes a TU for storage
of DNAPL. Alternative DN1 would not comply with ARARs, since contamination in the aquifer
currently exceeds ACLs and discharges of DNAPL into local surface water could result in
violations of surface water standards.
Groundwater.
Alternatives GW3A, GW3B, and GW4 would comply with all ARARs. Neither Alternative GW1 nor GW2
would comply with ARARs since groundwater contamination above remedial goals would remain in the
aquifer.
Because Alternatives GW1, GW2, and DN1 do not comply with the two threshold criteria, they will
not be considered further in this analysis.
8.3 Long-Term Effectiveness and Permanence
This criterion assesses whether a remedial alternative would carry a potential, continual risk
to human health and the environment after the remedial action is completed. An evaluation is
made as to the magnitude of the residual risk present after the completion of the remedial
actions as well as the adequacy and reliability of controls that could be implemented to monitor
and manage the residual risk remaining.
DNAPL:
Alternatives DN2, DN3A, and DN3B would all leave behind a significant amount of residual DNAPL
in the saturated zone which will need to be addressed by a groundwater alternative. However,
each of the alternatives provides for maximum DNAPL removal, to the extent practicable and
either treatment or reuse of the recovered creosote.
Groundwater:
In combination with a DNAPL recovery alternative, all three remaining groundwater alternatives
represent permanent solutions to the groundwater contamination at the ACW site. However,
Alternative GW4 provides an additional degree of effectiveness, since treatment occurs both
above ground and within the aquifer, shortening the overall treatment duration. The long-term
effectiveness of Alternatives GW3A and GW3B would depend on the ability of the extraction system
to remove all of the contamination from the aquifer, since treatment only occurs above ground.
8.4 Reduction of Toxicity, Mobility, or Volume through Treatment
This criterion assesses the degree to which a remedial alternative, by utilizing treatment
technologies, would permanently and significantly reduce the toxicity, mobility, or volume of
hazardous substances at the site. The assessment focuses on the degree and irreversibility of
treatment.
DNAPL:
Alternatives DN2, and DN3A provide equal reduction in mobility, toxicity, and volume through
treatment. Alternative DN3B does not require treatment, but provides for recovery and reuse of
the DNAPL as a product or BTU source rather than disposal as a waste. All alternatives have the
potential to mobilize contaminants through the injection of surfactants and other agents.
However, the extraction well network can be designed to capture the mobilized contamination.
Groundwater:
Alternatives GW3A, GW3B, and GW4 all provide a substantial reduction of toxicity, mobility, and
volume of contamination through treatment. Because Alternative GW4 provides for treatment of
contamination both above ground and within the aquifer, EPA expects this alternative to provide
a greater reduction in the contaminant volume.
8.5 Short-Term Effectiveness
This criterion assesses the degree to which human health and the environment would be impacted
during the construction and implementation of the remedial alternative. The protection of
workers, the community, and the surrounding environment as well as the time to achieve the
remedial response objectives are considered in making this assessment.
DNAPL:
The short-term effectiveness of each of the three remaining DNAPL alternatives is equivalent.
Each will involve temporary storage of recovered DNAPL until sufficient volume has been
collected for cost-effective disposal. Normal short-term hazards associated with well
installation and other construction activities will be addressed through a site-specific health
and safety program.
Groundwater:
During the construction phase, all three groundwater alternatives would involve typical
construction hazards and potential contact with contaminated soils and groundwater during well
installation. However, these short-term threats to construction workers would be addressed
through a health and safety program and the use of personal protective clothing and equipment.
Alternative GW4 would provide better short-term effectiveness because of the shorter
remediation time required to implement this alternative (5 years).
8.6
Implementability
This criterion assesses the technical and administrative feasibility of implementing a remedial
alternative and the availability of services and materials required during implementation.
DNAPL:
The recovery technologies for all three DNAPL alternatives are identical. All alternatives are
expected to leave behind a significant amount of residual DNAPL in the saturated zone, which
will be addressed by a groundwater alternative. Alternative DN2 will involve extensive effort,
including a test burn, to meet regulatory requirements for siting an on-site incinerator.
Implementation of Alternatives DN3A and DN3B will depend on the availability of off-site
incineration or recycling facilities, respectively.
Groundwater:
Each of the groundwater alternatives would involve one or more innovative technologies
(UV-oxidation, biological treatment) which would require treatability tests to verify their
ability to meet clean-up levels. Alternative GW3A would require the contractor to obtain an
NPDES permit for discharge to Pensacola Bay. Finally, all three alternatives would involve
extensive negotiations with landowners to obtain access and easements for installation of
extraction wells and distribution system piping.
8.7 Cost
This criterion assesses the capital costs, operation and maintenance costs, and total present
worth analysis associated with implementing a remedial alternative. The capital costs are
divided into direct costs and indirect costs. Direct capital costs include construction costs,
equipment costs, and site development costs. Indirect capital costs include engineering expenses
and contingency allowances. Operation and maintenance (O&M) costs are post construction costs
necessary to ensure the continued effectiveness of a remedial action.
DNAPL:
Alternative DN3B is the most cost effective DNAPL alternative because is provides equal
protection as the other alternatives at a lower cost. Alternative D2 is the next most cost
effective alternative, followed by Alternative DN3A.
Groundwater:
Alternative GW4 is the most cost effective groundwater alternative because it provides a greater
degree of effectiveness and shorter treatment duration at a lower cost than the other
alternatives. Alternatives GW3A and GWnB provide similar protectiveness at similar costs.
8.8 State Acceptance
This criterion assesses the technical and administrative issues and concerns the state may have
regarding each of the remedial alternatives. FDEP and its predecessor, FDER, have been the
support agency during the RI/FS process at the ACW site, providing input into all activities
conducted by EPA. Based on discussions with FDEP staff, EPA anticipates that the State's
concurrence is forthcoming. However, a formal letter of concurrence has not yet been received.
8.9 Community Acceptance
EPA has conducted community relations activities throughout the history of this site to advise
interested persons of EPA's activities and solicit community input. A summary of EPA's
responses to significant oral and written comments received during the public comment period is
provided in the Responsiveness Summary in Section III of this ROD.
9.0 Selected Remedy
Based upon consideration of the requirements of CERCLA, the detailed analysis of alternatives
using the nine criteria, public comments, and the Administrative Record for the site EPA has
determined chat a combination of Alternatives GW4 and DN3B is the most appropriate remedy for
addressing groundwater contamination at the ACW site. EPA anticipates using a phased approach
for implementing the groundwater cleanup. The initial phase would involve recovery of DNAPL
contamination to the maximum extent practicable (Alternative DN3B, to control a significant
source of contamination. The subsequent phase (Alternative GW4) will address the remaining
residual contamination in the aquifer, as necessary, to prevent the migration of contamination
to surface water.
An estimated 2 million gallons of DNAPL will be pumped from extraction wells at a combined rate
of about 100 gpm using enhanced removal methods. The enhancing agents (alkalines, surfactants,
and polymers) will be introduced into the aquifer via injection wells located just upgradient of
the DNAPL zone. Additional aquifer sampling, testing, and modelling will be required during
remedial design to further characterize the extent of DNAPL contamination and to determine the
appropriate location and number of extraction and injection wells.
Recovered DNAPL will be dewatered and stored on-site in a temporary unit (TU) until sufficient
quantities have been collected to cost-effectively transport the material for off-site
recycling. Testing of the recovered DNAPL will be done to characterize the chemical composition
of the material to be recycled to ensure that the recovered DNAPLs will meet the acceptance
criteria of the recycling facility.
The goal of the DNAPL recovery system is to remove the maximum contaminant mass from the aquifer
in the most cost-effective manner. Since additional characterization of the extent of DNAPL
contamination is necessary and significant uncertainty surrounds the ability of any extraction
system in recovering contaminant mass, EPA cannot currently predict the duration of DNAPL
recovery system operation. Instead, EPA will collect system performance data to evaluate
whether enhanced DNAPL recovery should continue at any or all of the following milestones: the
5-year review; upon recovery of 2 million gallons of DNAPL; and/or at such time as EPA
determines that DNAPL recovery is no longer technically feasible or cost-effective.
Following termination of the DNAPL recovery system operation, EPA will initiate the second phase
of the groundwater remediation plan which addresses the residual DNAPL and dissolved groundwater
contamination remaining in the aquifer. Using an estimated porosity of 0.35, one pore volume of
contaminated groundwater is estimated to be 152 million gallons. Alternative GW4 involves
recovery and treatment of about 1.8 pore volumes of groundwater using a combination of in-situ
and above-ground biological treatment.
Groundwater will be pumped from extraction wells at a combined rate of approximately 105 gpm to
an on-site treatment facility consisting of a dissolved air flotation (DAF) system, continuous
flow bioreactor, clarifier media filter, and granular activated carbon (GAC) columns (see Figure
5). Groundwater will be treated to the more stringent of the Federal or State MCLs shown in
Table 9. Experience suggests that not all of the groundwater recovered from the aquifer can be
reinjected, so an estimated 20 gpm of treated groundwater will be discharged to a POTW. The
remaining treated effluent (85 gpm) will then flow to a holding tank where hydrogen peroxide and
nutrients will be added prior to reinjection into the aquifer in order to stimulate in-situ
biological activity. Any sludges generated in the treatment train will be disposed off-site, and
the residual DNAPLs recovered by he system will be sent off-site for recycling.
<IMG SRC 0494208D>
Table 9
MCLs and Surface Water Quality Standards for
Contaminants of Concern
Maximum Contaminants Levels
(ug/l)
Contaminant of Concern
Carcinogenic PAHs (total)
Benzo(b and/or k)Fluoranthene
Benzo(a)Anthracene
Chrysene
Benzo(a)Pyrene
2-Methylnaphthalene
Naphthalene
Acenaphthene
Dibenzofuran
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Bis(2-ethylhexyl)Phthalate
2-Methylphenol
(3-and/or 4-)Methylphenol
Phenol
2,4-Dimethylphenol
Pentachlorophenol
1,2,4-Trichlorobenzene
Carbazole
Quinoline
State Primary
Drinking
Water
Standards
----0.2
---------4.0
----1.0
70
---
Surface Water Quality
Standard (ug/l)
Federal
Primary
Drinking
Water
Standards
----0.2
---------6.0
----1.0
70
---
State Criteria
Class III
Surface
Watera
-0.031
0.031
0 031
0.031
-26c
3c
67c
30c
0.031
0.3c
0.2c
0.3c
---4,600,000
6.5c
7.9
--371c
Federal
Criteriab
-0.0311
0.0311
0.0311
0.0311
--2,700
17
0.031
0.0311
0.0311
16d
0.0311
3.4d
--4,600
-7.9d
----
Maximum Contaminants Levels
(ug/l)
Contaminant of Concern
Benzene
Cis-1,2-Dichloroethene
Methyl Ethyl Ketone
Styrene
Trans-1,2-Dichloroethene
Vinyl Chloride
2,3,7,8-TCDD (Dioxin)
State Primary
Drinking
Water
Standards
1.0
70
-100
100
1.0
0.000000014e
Federal
Primary
Drinking
Water
Standards
5.0
70
-100
100
2.0
0.00000003
Surface Water Quality
Standard (ug/l)
State Criteria
Class III
Surface
Watera
71.3
--1,150c
--0.000000014f
Federal
Criteriab
71
---140,000
525
0.000000014
a
State of Florida surface water quality standards from FAC 17-302.560, January 5,
1993, unless otherwise noted.
b
Unless otherwise noted, the Federal water quality criteria for human health based
on a 10-6 risk level for carcinogens and assuming consumption of organisms (e.g.
fish) only are presented. Sourcc of criteria was OSWER Publication 9234.2O9/FS, June 1990.
c
State of Florida chronic toxicity values developed under Chapter 17-302.530(21)
and 17-302.530(62).
d
Federal water quality criteria for protection of aquatic saltwater species.
e
FDEP identified the dioxin drinking water standard in a letter to EPA dated June
4, 1993.
f
FDEP has adopted the dioxin surface water standard contained in 40 CFR
131.36(d)(6)(ii).
--
No quantitative standard available for this compound
A conceptual extraction and injection well configuration is provided in Figure 6. Additional
aquifer testing and modeling will be conducted during remedial design to further refine the
number and location of extraction and injection wells. EPA anticipates utilizing some or all of
the DNAPL recovery and injection wells as part of the final groundwater remediation system.
Since some of the elements of Alternatives GW4 and DN3B overlap, the combined cost of the
alternatives is less than the sum of their individual costs. The net present worth cost of the
preferred alternative is $10,344,000 based on the assumption that the DNAPL recovery system will
operate for 5 years prior to implementing Alternative GW4. The cost includes $4,498,000 in
capital costs and $789,000 in annual operation and maintenance costs for years 1-5 and $660,000
for years 6-10.
The goal of this remedial action is to manage the migration of contaminated groundwater to
prevent statistically significant increases in contaminants in surface water resulting from
groundwater discharges, and to prevent the use of he groundwater through institutional controls.
Based on information obtained during the remedial investigations and the analysis of all
remedial alternatives, EPA believes that the selected remedy may be able to achieve this goal.
However, groundwater contamination may be especially persistent in the immediate vicinity of the
former wastewater lagoons, where concentrations are relatively high. The ability to achieve
remedial goals (ACEs) at all points throughout the plume cannot be determined until the
extraction system has been implemented, modified as necessary, and plume response monitored
over time. If the selected remedy cannot meet the specified remedial goals at any or all of the
monitoring points during implementation, the contingency measures described below may replace
the selected remedy for these portions of the plume. Such contingency measures will, at a
minimum, prevent further migration of the plume and include a combination of treatment and
containment technologies. These measures are considered to be protective of human health and
the environment and are technically practicable under the corresponding circumstances.
The selected remedy will include groundwater extraction for an estimated period of 10 years,
during which time the system's performance will be carefully monitored on a regular basis and
adjusted as warranted by the performance data collected during operation. Modifications may
include any or all of the following:
•
at individual wells where remedial goals have been attained, pumping may be
discontinued;
•
alternating pumping at wells to eliminate stagnation points;
•
pulse pumping to allow aquifer equilibration and encourage adsorbed contaminants to
partition into groundwater; and
•
installation of additional extraction or injection wells to facilitate or accelerate
cleanup of the contaminant plume.
<IMG SRC 0494208E>
To ensure that remedial goals continue to be maintained, the aquifer will be monitored at least
annually at those wells where pumping has ceased.
If EPA determines on the basis of performance data generated during system operation that
certain portions of the aquifer cannot be restored to meet remedial goals, all of the following
measures involving long-term management may occur, for an indefinite period of time, as a
modification of the existing system:
•
engineering controls such as physical barriers or long-term gradient control provided by
low level pumping as containment measures;
•
chemical-specific ARARs will be waived for the cleanup of those portions of the aquifer
based on the technical impracticability of achieving further contaminant reduction;
•
institutional controls will be provided/maintained to restrict access to those portions of
the aguifer (or affected surface water) which remain above remedial goals;
•
continued monitoring of specified wells; and
•
periodic reevaluation of remedial technologies for groundwater restoration.
The decision to invoke any or all of these measures may be made during a periodic review of the
remedial action, which will occur at five year intervals in accordance with CERCLA Section
121(c).
9.1 Remedial Action Objectives
As part of the FS process, SPA identified remedial action objectives (RAOs) for groundwater at
the site to serve as a basis for determining cleanup levels and appropriate response actions.
The specific RAOs for groundwater are as follows:
•
Prevent ingestion of groundwater that contains concentrations of compounds
representing a total excess cancer risk greater than 10-6, a noncarcinogenic Hazard
Index greater than 1, or concentrations which exceed Federal and State ARARs.
•
Management of migration of the pollutants beyond the existing limits of the known
contaminant plume.
Based on these RAOs, EPA developed remedial goal options for meeting these objectives in
groundwater. Remedial goal options considered included Federal and State MCLs, health-based
cancer risk levels (10-6), health-based noncarcinogenlc risk levels (HI=1), and CERCLA ACLs. The
rationale for selection of the final remedial goals for groundwater and other performance
standards for the selected remedy are provided in Section 9.2.
9.2 Performance Standards
Based on the RAOs discussed in Section 9.1 and the risks identified in the BRA, EPA determined
that remedial action to treat groundwater contamination was warranted. However, EPA further
concluded that since residents and businesses in the area of the ACW site are connected to city
water supplies which draw groundwater from upgradient of the site, remediation to health-based
levels (e.g. MCLs and risk-based remedial goals) was not necessary. For this reason, EPA
developed ACLs under CERCLA Section 121(d)2)(B)(ii) which provide protection of surface water
potentially impacted by discharges of contaminated groundwater.
CERCLA Section 121(d)(2)(B)(ii) sets out the following criteria for the use of ACLs at a
Superfund site:
•
there are known and projected points of entry of the groundwater into surface water;
•
on the basis of measurements or projections, there is or will be no statistically
significant increase of site-related constituents from the groundwater to the
surface water at the point of entry or at any point where there is reason to
believe accumulation of constituents may occur downstream; and
•
the remedial action includes enforceable measures that will preclude human exposure
to the contaminated groundwater at any point between the facility boundary and all
known or projected points of entry of the groundwater into surface water.
EPA believes that these criteria can be met by implementation of the selected remedy. Based on
geological and hydrogeological data collected in the vicinity of the ACW site, EPA has
determined that there is a hydraulic connection between shallow groundwater (above 20 ft.
b.l.s.) and the drainage ditch on the Pensacola Yacht Club property. Regional geological
studies further suggest that deeper groundwater (greater than 30 ft. b.l.s.) discharges into
Pensacola Bay some distance from the shoreline. Therefore, the first statutory criteria for
ACLs is met.
Next, the results of groundwater and sediment sampling near the site suggest that, in the past,
the discharge of contaminated groundwater to the PYC drainage ditch has occurred, and
contaminants have accumulated in the ditch and in Pensacola Bay sediments near the mouth of the
ditch. However, surface water samples collected from the drainage ditch have shown little or no
organic contamination. If left untreated, contaminated groundwater discharges would result in
the continued accumulation of contaminants in the ditch sediments and potential impacts to
surface water quality. For this reason, EPA calculated ACLs (see boundary, would ensure
compliance with surface water standards at the point of groundwater discharge to the drainage
ditch. Application of these ACLs as groundwater remedial goal will prevent statistically
significant increases in surface water contaminant concentrations once the ACLs are achieved at
the point of compliance for the aquifer, which is the southern site boundary. Therefore,
remediation of groundwater to the levels in Table 8 will meet the second statutory criteria for
ACLs.
EPA will conduct monitoring of surface water in the PYC drainage ditch and Pensacola Bay to
confirm that no statistically significant increases of site-related contaminants are occurring.
Additionally, EPA will install shallow monitor wells immediately upgradient of the PYC drainage
ditch and intermediate and deep wells at the Peneacola Bay shoreline to evaluate whether
groundwater exceeds the surface water standards prior to discharge into the surface water body.
The State and Federal surface water criteria which will serve as performance standards in these
monitor wells are shown in Table 9. These standard, while not considered ARARs for groundwater,
were used in the development of groundwater ACLs and will serve as a measure of the performance
of the remedial action.
The final CERCLA criteria for application of ACLs at a site requires that adequately enforceable
institutional controls are in place to prevent human exposure to groundwater contaminants
between the site boundary and the point of discharge to surface water. The area in the vicinity
of the ACW site is presently proposed as a delineated area under Chapter 17-524.420, Florida
Administrative Code (FAC), to restrict the potable use of the aquifer. At this time, requests
for new potable wells are handled by the Northwest Florida Water Management District (NWFWMD) on
a case by case basis. In November 1993, NWFWMD advised EPA and area water well contractors that
pursuant to Sections 40A-3.301 and 40A-3.504 of the FAC "the District intends to seek denial of
any potable or irrigation well permit proposed in [the site] area." EPA believes that this is a
sufficiently restrictive institutional control to ensure that inappropriate potable uses of the
groundwater will not occur. To address the possibility of a proliferation of bootleg wells in
the site area, EPA will conduct a survey during each five year review to determine if any
illegal wells have been installed.
Nine private non-potable wells exist in the immediate vicinity of the site. The majority of
these wells are used for irrigation and other non-potable uses. However, EPA believes that some
or all of these wells may represent a potential source of exposure to current or future
residents if they are allowed to remain in service, since groundwater will not be remediated to
health-based levels. For this reason, EPA will plug and abandon each well for which consent is
granted by the well owner. During remedial design, EPA will conduct a well survey in the area
east of Barrancas Avenue and Pace Boulevard, south of Main Street, and west of South C Street to
determine if wells other than the ones shown below exist:
Location
705 South I St.
1608 W. Cypress St.
1509 W. Cypress St.
708 South G St.
1407 W. Sonia St.
809 South F St.
810 South J St.
1710 W. Cypress St.
916 South I St.
Uses
Heat pump
Not used
Irrigation
Irrigation
Not used
Not used
Irrigation
Irrigation
Irrigation
In addition to the statutory criteria outlined above, it is EPA policy to apply ACLs at a site
only when active restoration of the groundwater to MCLs is deemed not to be practicable. Based
on EPA's experience with groundwater remediation at sites contaminated with DNAPLs, and
considering the pervasiveness of DNAPL contamination at the ACW site, EPA believes that
remediation to MCLs at the ACW site would not be practicable. However, EPA anticipates that the
active remediation measures outlined in this ROD, as modified during implementation based on
performance data, may be able to achieve the ACLs developed for the site.
10.0 Statutory Determination
Under CERCLA Section 121, EPA must select remedies that are protective of human health and the
environment, comply with applicable or relevant and appropriate requirements (unless a
statutory waiver is justified), are cost-effective, and utilize permanent solutions and
alternative treatment technologies or resource recovery technologies to the maximum extent
practicable. In addition, CERCLA includes a preference for remedies that employ treatment that
permanently and significantly reduces the volume, toxicity, or mobility of hazardous substances
as their principal element. The following sections discuss how the selected remedy meets these
statutory requirements.
10.1 Protection of Human Health and the Environment
The selected remedy protects human health and the environment through extraction and recycling
of DNAPLs, extraction and treatment of contaminated groundwater, and implementation of
institutional controls to restrict future groundwater use. This remedy will protect human
health and the environment by restoring groundwater to levels which, when discharged to surface
water, will not result in degradation of surface water quality above surface water standards
protective of both human health and aquatic organisms. Further protection of public health will
be provided through the implementation of State-imposed permit restrictions on construction of
potable wells in the delineated area identified under Chapter 17-524 FAC. Finally, the plugging
and abandonment of existing non-potable private wells in the vicinity down-gradient of the site
will prevent inadvertent exposure through incidental dermal contact and ingestion of groundwater
contaminants.
10.2
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
The selected remedy for groundwater will comply with all ARARs. The major ARARs which apply to
the selected remedy and other non-enforceable guidance and criteria which are to be considered
(TBC) are presented below:
Federal ARARs
Safe Drinking Water Act (SDWA)
•
40 CFR 141. SDWA Maximum Contaminant Levels (MCLS) for contaminants of concern are
relevant and appropriate for treatment of water being reinjected into the aquifer.
•
40 CFR 144. SDWA underground injection control (UIC) regulations are relevant and
appropriate to the construction and operation of injection wells for reinjection of
treated groundwater.
Clean Water Act (CWA)
•
40 CFR 403. CWA pretreatment regulations are applicable to the off-site discharge
of treated groundwater to a publicly owned treatment works (POTW).
•
40 CFR 131. CWA Federal water quality criteria are to be considered for evaluation
of "statistically significant" increases of groundwater constituents in surface
water. These standards, while not considered ARARs for groundwater, were used in the
development of groundwater ACLs and will serve as a measure of the performance of
the remedial action.
Resource Conservation and Recovery Act (RCRA)
•
40 CFR 262 & 263. RCRA generator and transporter requirements are applicable to the
off-site transport and recycling of recovered DNAPL.
•
40 CER 264.553. RCRA requirements for temporary units (TUs) are applicable to any
tank used for DNAPL storage while sufficient volumes accumulate for off-site
recycling.
Other Federal Regulations
•
Alternate Concentration Limits (ACLs), derived pursuant to CERCLA Section
121(d)(2)(B)(ii). ACLs are applicable as remedial goals for groundwater restoration
in place of MCLs.
State ARARs
•
Florida Surface Water Quality Standards, FAC 17-302. State surface water standards
are to be considered for evaluation of "statistically significant" increases of
groundwater constituents in surface water. These standards, while not considered
ARARs for groundwater, were used in the development of groundwater ACLs and will
serve as a measure of the performance of the remedial action.
•
Florida Primary Drinking Water Standards, FAC 17-550.310. Maximum contaminant levels
are relevant and appropriate for treatment of water being reinjected into the
aquifer.
•
Florida Rules on Hazardous Waste Warning Signs, FAC 17-736. Identifies requirements
applicable to signs around perimeter and at entrances of site.
•
Florida UIC Regulations, FAC 17-28. State UIC regulations are relevant and
appropriate to the construction and operation of injection wells for reinjection of
treated groundwater.
10.3 Cost Effectiveness
The combination of alternatives DN3B and GW4 provides the maximum reduction in risks to human
health and the environment at an estimated cost of $10,344,000. The selected remedy combines
the least expensive yet most effective DNAPL and groundwater treatment alternatives which
provide treatment in the shortest period of time.
10.4 Utilization of Permanent Solutions to the Maximum Extent Practicable
The selected remedy relies on the removal and treatment of a significant amount of contamination
in the aquifer to provide for a permanent, long-term solution for groundwater restoration.
While contamination will remain in the aquifer above health-based levels, the institutional
controls called for in this remedy are currently in place and enforced by the Northwest Florida
Water Management District. Additional permanence will be afforded when the proposed delineated
area surrounding the ACW site is finalized by a rule-making by FDEP. Finally, EPA`s closure of
existing privately-owned non-potable wells will prevent future uses of contaminated groundwater.
10.5 Preference for Treatment as a Principle Element
The selected remedy provides for maximum contaminant mass removal from the aquifer by utilizing
enhanced DNAPL recovery to remove the separate creosote phase which is serving as a source for
groundwater contamination. Recycling of the recovered DNAPL uses the recovered material as a
product thereby preventing the need for disposal. Above-ground biological treatment of
groundwater will further reduce contaminant volume. Finally, the in-situ biological treatment
will provide continuing reduction of contamination within the aquifer.
11.0
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for groundwater remediation at the ACW site which was released for public
comment in November 1993 identified a combination of Alternatives DN3B and GW4 as the preferred
alternative for groundwater remediation. While no changes to the overall remediation approach
have been made, EPA has documented a few significant changes below:
Plugging of private wells: Following issuance of the Proposed Plan, EPA determined that
plugging and abandonment of existing private irrigation wells in the ACW site area was
necessary to foreclose any future incidental exposure to contaminated groundwater. EPA
representatives explained this addition to the proposed remedy at the public meeting on
December 2, 1993,
requesting comments on this and other elements of EPA's preferred
alternative. EPA will seek written consent from each individual well owner before
plugging any wells.
Change in dioxin ACL: Based on comments received from FDEP and other reviewers, EPA has
reevaluated the use of the dibenzofuran ACL for 2,3,7,8-tetrachlorodibenzodioxin (TCDD)
because of the notable difference in dibenzofuran and TCDD toxicity characteristics. ACL
calculations demonstrated that chlorinated dioxin compounds would not migrate more than
about 300 feet
downgradient of the site even if dioxin was present at extremely high
concentrations. This is due to the low mobility and solubility of dioxin in water. Since
dioxin concentrations detected in groundwater were very low (0.0092 ng/l TEQ), EPA has
determined that an ACL for dioxin is not needed. However, applicable dioxin surface water
standards will apply as performance standards in the PYC ditch.
Appendix A
DIOXIN TOXICITY EQUIVALENCY FACTORS
Compound
TEFs
Mono-, Di- and TriCCDs
-
2,3,7,8--TCDD
Other TCCDS
1
-
2,3,7,8-PeCDD
Other PeCDDs
0.5
2,3,7,8-HxCDDs
Other HxCDDs
0.1
-
2,3,7,8-HpCDDs
Other HpCDDs
0.01
-
OCDD
0.001
2,3,7,8-TCDFs
Other TCDFs
0.1
-
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
Other PeCDFs
00.5
0.5
-
2,3,7,8-HxCDFs
Other HxCDFs
0.01
-
2,3,7,8-HpCDFs
Other HpCDFs
0.01
-
OCDF
0.001
III.
RESPONSIVENESS SUMMARY
In accordance with Sections 113 and 117 of CERCLA, as amended, EPA has conducted community
relations activities at the American Creosote Works (ACW) site to solicit community input and
ensure that the public remains informed about site activities. EPA has relied on a number of
methods for keeping the public informed, including press releases, fact sheets, public meetings,
establishment of an information repository, and public comment periods.
The U.S. Environmental Protection Agency (EPA) held a public comment period from November 12,
1993 to January 11, 1994 for interested parties to comment on EPA's Proposed Plan for addressing
groundwater contamination (Operable Unit 2) at the American; Creosote Works (ACW) site. During
the comment period, EPA conducted a public meeting at the Sanders Beach Community Center in
Pensacola, Florida on December 2, 1993. During this meeting, representatives of EPA presented
the results of the studies undertaken at the site and EPA's preferred alternative for addressing
groundwater and dense non-aqueous phase liquid (DNAPL) contamination.
A summary of EPA's responses to comments received during the public comment period, known as the
responsiveness summary, is required under Section 117 of CERCLA. The responsiveness summary
also provides a brief background of EPA's community outreach efforts and the concerns of the
community about the site. EPA has considered all of the comments summarized in this
responsiveness summary in determining the final selected remedy presented in the Record of
Decision (ROD) for Operable Unit 2.
A.
Background of Community Involvement and Concerns
EPA's earliest community outreach effort was a press release related to the emergency removal
activities in 1983. Periodic fact sheets were issued during 1984 and 1985 to update the
community concerning studies being conducted at the site. In September 1985, EPA issued fact
sheets and press releases announcing a public meeting and comment period related to the
proposed plan for addressing source contamination at the site. Similarly, in 1989, EPA issued a
fact sheet and held a public meeting to discuss the revised source control remedy. In 1990, EPA
prepared an Explanation of Significant Differences (ESD) notifying the public of additional
tasks thac would be necessary to implement the 1989 ROD. Later, in March 1991, a fact sheet was
published to advise the public of the initiation of these site preparation activities which
included cap repair, drum characterization, fence repairs, well closure, and building
demolition.
More recently, EPA conducted a door-to-door survey in September 1993 in he neighborhood
surrounding the site to update its mailing list. EPA's Proposed Plan for Operable Unit 2 was
sent to the public in November 1993, and the administrative record for the site was made
available in the public repository at the West Florida Regional Library. A notice was published
in the Pensacola News Journal on November 28 and 30, 1993 advising the availability of the
administrative record, announcing the opening of the public comment period, and advertising the
date of the upcoming public meeting. A public comment period was held from November 12, 1993 to
January 11, 1994 to solicit input on EPA's preferred alternative for addressing groundwater
contamination at the site. In addition, EPA held a public meeting at the Sanders Beach
Community Center on December 2, 1993 to discuss EPA findings and answer residents' questions.
Approximately 50 people attended the public meeting during which several residents expressed
concern about their health, citing numerous cases of cancer and other conditions in the
community. At least three people requested that a health study of area residents be conducted.
Residents also registered complaints about the site being overgrown, thereby providing potential
hiding places for criminals. One resident attributed drainage problems and flooding to the
site, furnishing EPA with photographs of flooding along Pine and Gimble Streets. At least two
citizens suggested that EPA was wasting money in cleaning up this site, but many of the
residents expressed support of EPA's Proposed Plan for groundwater remediation.
EPA's responses to these concerns and those provided by mail are summarized in Section B below.
Additionally, a transcript of the public meeting was prepared by a certified notary public, and
this document is a part of the Administrative Record upon which the remedy selected in the
Operable Unit 2 ROD is based.
Following the issuance of the final ROD for Operable Unit 2, EPA will continue to keep the
community informed about progress at the site through fact sheets and informal information
meetings. Additionally, design and construction documents pertaining to the implementation of
Operable Unit 2 will be placed in the information repository at the West Florida Regional
Library.
B.
Summary of Major Comments and EPA`s Responses
Comments on Health and Risk Issues
1. Previous health assessments conducted for the ACW site are inadequate. A new toxicological
and epidemiological study should be performed to include air pollution modeling and a survey of
existing and former residence.
EPA has forwarded this request to the Agency for Toxic Substances and Disease Registry (ATSDR)
and the Florida Department of Health and Rehabilitative Service (HRS).
2. Numerous people in the community have died of cancers and tumors, and birth defects,
thyroid, heart, and other health problems have been identified that may be long term effects of
pollution from the ACW site.
This comment has been relayed to ATSDR and HRS, since the evaluation of health concerns
associated with past exposure would be the responsibility of health agencies. EPA believes that
any immediate health threats have been addressed through the removal actions at the site. The
remaining long-term threats posed by the site will be addressed by the proposed groundwater
remedy and the source control to be proposed later this year.
3. Are the vegetables from residents' gardens safe? Previous vegetable sampling did not
include all the fruits and vegetables consumed from local gardens over the years.
In November 1985, EPA collected samples of pecans, mustard greens, collard greens, and green
peppers from six residents' gardens west and south of ACW site. The results indicated that the
produce was not contaminated in spite of the fact that surrounding garden soils were
contaminated. Although every type of vegetable grown in the area was not sampled, EPA
believes the sampling provided a representative evaluation for the vegetable exposure pathway.
4. Fish having tumors were routinely caught from the local waters. No fish were tented, and
many residents ate mullet and other fish caught from the Sanders Beach pier.
EPA has not sampled fish or other marine animals from the bay to date. However, EPA has
collected numerous surface water and sediment samples from Pensacola Bay. The surface water
was not contaminated, but some bay sediments contained concentrations of contaminants which
could be toxic to aquatic organisms. Studies to evaluate contaminant effects on aquatic
animals in the bay may be conducted in the future.
5.
Is it safe for residents to breathe the air around the site while mowing is done?
Is the
dust from Pine Street safe to walk on, breathe, or dissolve in rainwater?
While workers may need to wear respiratory protection while mowing the site, the quantity of
dust generated as the mower passes each individual house will not be sufficient to result in
health problems. Mowing will be conducted in such a way as to direct clippings into the center
of the site. Very little dust generation is anticipated during implementation of the groundwater
remedy. However, air monitoring and dust suppression would be components of any source control
action which involves movement of significant amounts of contaminated soils. EPA's off-site
soil sampling along Pine Street indicates that, although some contamination exists, the levels
are low enough not to represent a threat from any short-term exposure.
6. The current overgrown condition of the site provides hiding places for criminals. The site
should be secured and mowed.
EPA agrees and has initiated a contract for mowing the site Additionally, new locks will be
placed on the existing gates and new signs will be posted to warn of site contamination. This
work is expected to be done in February 1994.
7. North winds blew air emissions from the ACW plant over the neighborhood for 30 years. The
incidence of lung cancer in the neighborhood should be reevaluated to determine the true risk.
This request has been forwarded to ATSDR and HRS. EPA collected air samples in 1984 to evaluate
the potential for current exposure to air emissions from the site. The results, reported in the
NUS RI report dated January 1985, identified the presence of 12 volatile organic compounds at
very low levels. However, the concentrations detected were 100 to 1,000 times lower than the
Threshold Limit Value for each compound, suggesting that current air emissions from the site
do not represent a threat to human health.
8. What is the main pathway for future exposure to contamination at the ACW site? Is it
children eating soil from the site? Are my children safe, and is it safe to rent my home to
families with young children?
The highest risks documented by EPA for any potential future exposure were associated with the
regular ingestion of contaminated groundwater. EPA's 1989 risk assessment indicated that risks
for both adults and children exposed to off-site soil contamination fell within EPA's acceptable
cancer risk range of 1x10-6 to 1x10-4. However, EPA's most recent off-site soil sampling data
indicates that dioxins are present at levels above 1 ppb, which represents an excuse cancer risk
of greater than 1x10-4 (1 in 10,000). EPA forwarded this soil data to ATSDR for review, and
ATSDR advised that no immediate action was necessary, but that the contamination should be
addressed by EPA's long-term remedial action. Parents should take the following precautions:
prohibit children from trespassing on the the ACW site itself; encourage them not to play in or
eat either on-site or off-site dirt; and wash their hands and face immediately if they do play
in the dirt. However, occasional contact with contaminated soils is not expected to present a
significant risk.
9.
No serious impact on either human or plant life has been documented to date.
The Superfund legislation does not charge EPA with documenting specific health effects in
individual humans or other plant or animal species. Rather, EPA must be determine whether
actual or threatened releases of hazardous substances from the site may present an imminent and
substantial endangerment to public health, welfare, or the environment. EPA's environmental
sampling and risk assessments have demonstrated that, if left unaddressed, contamination from
the site could pose a threat to future residents and the environment.
10. The benzene people breathe each time they fill their gas tanks is more of a human health
hazard than exposure to the ACW site conditions. Likewise for the smoking, drinking, and eating
habits of all of us.
The risks associated with the everyday activities you identified may very well present health
hazards which are greater than the risks related to long-term exposure ACW site. However, these
risks stem from the voluntary activities of individuals whereas the risks from the site result
from actions of others.
11. What data does EPA and/or ATSDR have on the carcinogenic history of former creosote plant
workers anywhere in the U.S.?
EPA's primary mission in the Superfund program is to investigate and respond to release of
hazardous substances into the environment. The Agency for Toxic Substances and Disease Registry
(ATSDR) maintains a registry of persons exposed to hazardous substances and a registry of
serious diseases and illnesses in persons exposed to hazardous substances in thhe environment.
The comment has been forwarded to ATSDR.
12. A commenter cited documentation seating that potential human health and environmental
impacts resulting from possible discharge of contaminated groundwater into Pensacola Bay is of
relatively minor significance.
A later study of the sediments in the Pensacola Yacht Club drainage ditch and Pensacola Bay
(EPA, September 1991) indicated that concentrations of certain PAHs in bay and drainage ditch
sediments pose an ecological risk.
13. What is the potential increase in life expectancy and the expected reduction in the
incidence of all cancers after implementation of the remedy? If you don't have a past record
of the epidemiology in the area, what will be your frame of reference?
EPA remedial action objectives for groundwater at the ACW site are 1) to prevent ingestion of
contaminated groundwater and 2) to manage the migration of pollutants beyond the existing
limits of the known contaminant plume. Success in meeting these objectives will be measured by
the collection and analysis of groundwater and surface water samples and comparison of these
data to established performance standards (i.e. ACLs, surface water standards). Since current
residents are not exposed to contaminated groundwater except through incidental contact from
private wells, EPA anticipates little or no significant reduction in cancer incidence resulting
from the groundwater remedial action. EPA does not use life expectancy as an evaluation
criteria since so many other factors contribute to an individual's life expectancy.
14. What studies have been made on the health status of rodents, snakes or other mammals living
on the ACW site?
EPA has not conducted a health evaluation of on-site animals. Instead, a substantial database of
animal studies which evaluate the effects of the various chemicals found at the ACW site is
available to EPA in conducting risk assessments. Since these studies are conducted under
carefully controlled conditions, any observed health effects can be linked directly to the
chemical being tested. In site specific studies, conditions cannot be controlled as easily, and
too many other factors could confound the study results.
Comments on EPA's Proposed Plan
15. Several commenters stated that the No Action alternative should be selected for the site,
since residents are on city water. Another suggested extracting the DNAPL plume if possible and
allowing nature to take its course.
EPA disagrees. While no one is currently drinking the contaminated water, groundwater
contamination could pose a risk to future residents through incidental ingestion of water from
private wells. In addition to public health, EPA is concerned with protection of the
environment. If not addressed, contaminated groundwater could continue to migrate into surface
water (Pensacola Bay) and potentially impact both humans and aquatic organisms. EPA's selected
remedy does call for initial DNAPL removal. However, experience suggest that even enhanced
recovery technologies have limitations in the percentage of DNAPL that can be removed. Since a
significant fraction of contamination is expected to remain in the aquifer following enhanced
recovery operations, EPA believes that the in-situ/ex-situ groundwater treatment system will be
needed to achieve remedial goals.
16. EPA should evaluate whether the surrounding residents should be relocated during the
cleanup. Were residents at the Escambia Treating Company (ETC) site relocated?
EPA believes that relocation of residents is unnecessary during implementation of the
groundwater remedy. The groundwater treatment system can be designed to capture and treat
fugitive emissions. EPA will also conduct perimeter air monitoring to ensure that airborne
contamination above levels of concern does not leave the site. Two residents were temporarily
relocated during EPA's removal activities at the ETC site, and they are now back in their homes.
EPA will evaluate relocation at ACW more closely in relation to the Operable Unit 1 remedy.
17. Remediation of groundwater pollution practiced by the EPA has proven to be ineffective.
Your studies of 19 sites involving pumping and treating for up to 10 years show that there has
been little success in reducing concentrations to target levels on a permanent basis.
Based on the study referenced, EPA has adjusted its expectations concerning the ability to
completely restore contaminated aquifers and revised its approach to groundwater remediation.
The proposed groundwater remedy for ACW site incorporates this new thinking. Specifically, the
plan proposes a phased approach to groundwater remediation, calling for DNAPL recovery first,
followed by a combination of pump-and-treat and in situ technologies to address residual
contamination. Additionally, the selected remedy will be designed to include careful monitoring
and provisions for modifying the remedy over time to improve its effectiveness. Finally, EPA may
make the determination that modification of remedial action objectives is warranted or that
restoration of the aquifer to remedial goals is technically impractible based on the data
collected during remedial action implementation.
18. Is there data to support that bioremediation works on heavier petroleum products known to
be present at the site?
EPA's preferred alternative for addressing dissolved groundwater contamination calls for the
stimulation of native bacteria by the addition of nutrients and an oxygen source.
Treatability studies performed by EPA determined that bacteria native to site soil were
available and capable of degrading site contaminants. Specifically, the percent degradation of
43 compounds after 30 days of slurry phase soil treatment ranged from 15 percent for heavier
PAHs such as benzo(a)anthracene to 100 percent for lighter fractions such as
2-methylnaphthalene. EPA anticipates achieving higher degradation rates in an aqueous treatment
system. Additionally, research by the USGS indicates that in-situ biodegradation has been
occurring naturally in the aquifer for some time.
19. The option of recycling entails soil removal and transport from the site.
create problems of a magnitude greater than the existing conditions.
This would
EPA is not proposing to transport soils off-site for recycling. Rather, dense non-aqueous phase
liquids (DNAPLs) will be recovered and sent to an off-site recycler. Most recyclers either burn
the DNAPL ± or its BTU value or reuse the material as creosote for treating lumber.
20.
Can benzene be recovered and sold?
EPA's plan basically entails recovering DNAPL, which contains benzene, and allowing it to be
used for fuel or wood treatment. The material cannot be sold, but the costs of recycling are
much lower than the costs of treatment.
21. Alternative DN3B involves the use of surfactants, alkaline agents, and polymers. Are these
proven technologies? What will prevent these chemicals from uncontrolled migration? Will
thermal methods reduce the viscosity of the DNAPL and promote an increase in the pollutant level
of the aquifer?
Enhanced recovery technologies have been used for many years in the oil industry, although their
application in full-scale DNAPL recovery systems is limited. However, the extraction well
network will be designed to prevent uncontrolled migration of mobilized DNAPL. EPA's selected
remedy does not call for the use of thermal recovery methods, which can result in uncontrolled
vertical migration of DNAPLs.
22. The location of reinjection wells associated with alternative GW4 is not specified as it
was for alternative GW3. Will the treated ground water be reinjected at the down gradient
margin of the contaminant plume?
Rejection wells for the in-situ bioremediation system will likely be placed within the
contaminant plume to ensure distribution of nutrients and oxygen to bacteria where the
contamination is located. A conceptual well layout is shown in the ROD. However, EPA will
conduct additional field studies and modeling to determine the exact location of these wells.
23.
Won't the bacteria be pumped back up by the extraction wells?
The extraction system will be designed to minimize the amount of bacteria pumped out of the
aquifer so as to avoid short-circuiting of the in-situ biological treatment.
24. What facilities have been identified to accept recovered DNAPL? What assumptions were used
in calculating the cost of this alternative? What provisions will be established to insure that
adopting this alternative will not result in a repeat of the American Creosote problem at
another location.
EPA has identified at least five facilities which were potentially capable of recycling the ACW
DNAPL. EPA used an average price of $1.15 per gallon for cost estimating purposes based on
telephone bids. To ensure proper management of wastes, any off-site facility receiving
hazardous substances from a Superfund site must be in compliance with its operating permits.
25. The Northwest Florida Water Management District may not be able to enforce ban on the
installation of "bootleg" wells in a restricted area near the site, especially by out-of-state
drillers. In light of this problem, EPA should re-visit the underlying assumptions that went
into the calculation of the ACLS?
EPA believes the Northwest Florida Water Management District is capable of enforcing its
institutional ban. However, to address this concern, EPA will conduct neighborhood surveys
periodically to evaluate whether new "bootleg" wells have been installed. Additionally, EPA
will seek to plug any existing wells.
26.
How soon will the remedy be implemented?
EPA hopes to award a design contract in 1944 and initiate construction activities by late 1995.
Comments on Sampling Data
27. Based on historical drainage patterns in the area, off-site soil sampling has been
insufficient to adequately characterize the extent of contamination. No mention is made of
contaminated soils off-site.
EPA has collected off-site soil samples from over 40 locations throughout the neighborhood south
and west of the ACW site and on the Pensacola Yacht Club (PYC) property. Most samples were
collected to depths of 1 ft., but at least 8 samples from the PYC property were collected to
depths of 2 ft. Results from these investigations have indicated that off-site soils are
contaminated with PAHs, dioxins, and other site-related compounds. However, the contaminant
levels represent a long-term (chronic) threat rather than an immediate (acute) hazard. EPA will
present plans for addressing soil contamination in the Proposed Plan for source control
(Operable Unit 1), at which time the public will have another opportunity to comment on the
adequacy of soil sampling.
28. Groundwater sampling locations reflect current rather than historical drainage patterns.
Deep and intermediate wells should have been sampled east and south of the site as well as
upgradient to the west and north of the site.
During the numerous investigations conducted at the ACW site, EPA, the U.S. Geological Survey,
and EPA's contractors have installed and sampled over 100 wells in the vicinity of the site.
Well locations were selected based on both current and former drainage patterns, historical site
operations, and regional groundwater flow direction. Samples were collected from as far east as
G Street (Ropke well), as far south as Sanders Beach (800 series), as far west as M Street (100
series).
29. What is the degree of contamination in the surface water and sediments in Pensacola Bay?
Are these areas going to be addressed in Operable Unit 2?
EPA has sampled surface water and/or sediments in both Pensacola Bay and the PYC drainage ditch
during investigations in 1984, 1989, 1991, and 1993. Results have consistently indicated little
or no contamination in Pensacola Bay. Data from the upstream reaches of the ditch indicated the
presence of a few contaminants, including bis(2-ethylhexyl)phthalate (200 ug/l), benzene (0.76J
ug/l), and toulene (1.2J ug/l), but a sample collected from near the mouth of the ditch revealed
no organic contamination. Sediments in the PYC drainage ditch are contaminated with a variety of
compounds, including PAHs, phenols, and dioxins. Toxic levels of organic compounds, principally
anthracene, fluoranthene, and pyrene, were detected within the drainage ditch and lower stratum
of the bay sediments at the mouth of the ditch. EPA will address sediment contamination, if
necessary, in either the Operable Unit 2 ROD or a separate Operable Unit 3 ROD.
30. Has the EPA ever analyzed and compared the contaminants in run-off water both north and
south of the site so as to distinguish the amount of pollution from normal run-off versus the
contribution from the ACW site?
EPA collected run-off samples from both north and south of the site in March 1991. The sample
from north of the site indicated no contamination above detection limits. The two samples south
of the site showed no volatile organic contamination. Semivolatile analyses detected a few
compounds below detection limits and Anthracene at a level of 46 ug/l.
31. Both sides of the yacht club drainage ditch is lush with a variety of plant growth. Some
of the largest and healthiest looking oak and magnolia trees in Pensacola borders this ditch.
Is this lush growth consistent with the EPA portrayal of the pollution in the ditch?
EPA frequently relies on the evaluation of stressed vegetation in areal photographs to identify
potential containment source areas. However, this technique provides no quantitative
information, so environmental sampling and laboratory analysis are used to provide data on the
level of contamination in various media.
32. The Proposed Plan lists maximum concentrations detected, but the sampling location is
undisclosed. What was the location? How many samples over what time period were analyzed from
each location? What was the average contaminant level?
The highest concentrations of polynuclear aromatic hydrocarbons (PAHs) were found in well 340,
located on-site just south of the former sludge lagoons. This well was drilled to a depth of
39.8 ft. The highest levels of pentachlorophenol and dioxin were detected in well 380,
located next to well 340 and drilled to a depth of 77.3 ft. The maximum concentration of benzene
was detected in well 480, located just north of the Pensacola Yacht Club and competed at a depth
of 80.4 ft. The Baseline Risk Assessment, located in Volume 5 of the Administrative Record at
the Pensacola library, provides a good summary of the groundwater data for concentrations.
33. Forty-eight percent of the listed contaminants are not carcinogenic.
for the purpose of alarming a lay person?
Is the listing made
Cancer is only one of the many health effects which may result from exposure to chemicals.
Other effects caused by exposure to non-carcinogenic compounds (eg. naphthalene) may include
nausea, headaches, skin rashes, cataracts and other eye disorders, kidney damage, and retarded
cranial ossification (scull hardening) and heart development in the offspring of exposed
individuals. Much of the toxicity information EPA relies upon to assess health effects comes
from animal studies, since data for humans is often not available.
34.
The numbers listed for PCP and dioxins/furan are confusing. Please elaborate?
The concentrations of PCP and dioxin detected in site groundwater exceed drinking water Maximum
Containment Levels (MCLs). However, since no one is currently drinking the water, EPA
calculated alternate concentration limits (ACLs)which, when met in the aquifer, would ensure
compliance with surface water standards where groundwater discharges to the PYC ditch and
Pensacola Bay. The ACLs for PCP and dioxin indicate that existing levels of these compounds in
the aquifer probably do not present a threat to surface water.
35. Was the PCP used at the site in the form of the relatively insoluble pentachlorophenol or
the water soluble sodium- or potassium-pentachlorophenate? It makes a tremendous difference in
the mobility of the compound.
EPA information on actual operations at the ACW site is limited. However, sampling of all media
at the site has revealed the widespread presence of PCP, but none of the pentachlorophenate
compounds have been detected.
36. Have there been any studies completed by EPA to follow up on the 1984 preliminary USGS work
studying contaminant impacts on aquatic life in Pensacola Bay?
EPA completed a Dye Dispersion and Sediment Sampling study in 1991 to evaluate contaminant
dispersion patterns from the mouth of the PYC ditch into Pensacola Bay and to collect additional
sediment samples. Result indicated that lower stratum bay sediments were contaminated with
potentially toxic levels of some organic compounds, so EPA will meet with natural resource
trustees in the near future to discuss the need for further studies.
Comments about Real Estate and Legal Issues
37. Property owners should be held harmless and indemnified against any future health-related
claims if we sell or rent our properties.
EPA has no authority to indemnify property owners for health-related claims made by third
parties. However, based on the results of the risk assessment and feasability study, EPA
believes the groundwater remedy selected in this ROD in conjunction with the source control
(Operable Unit 1) remedy to be selected later this year will fully address any health risks to
the public.
38. Property owners should be compensated for the depressed market value caused by proximity to
the ACW site and planned remedial action activities.
EPA has no authority to compensate owners for losses in property value. Moreover, EPA's
remedial action will likely improve the market value of the property by removing existing
contamination.
39.
Will EPA force people to plug and abandon their private wells.
EPA believes the groundwater in the vicinity of the ACW site cannot be restored to a level that
is safe for drinking water. For this reason, the ROD calls for plugging and abandoning existing
private wells. EPA plans to encourage well owners to voluntarily allow EPA to plug their own
safety and for the safety of future residents. However, EPA may investigate other means to
effect well closure if necessary.
General Comments
40.
I have never been notified of any public meeting regarding the ACW site.
ensure that the mailing list is accurate.
EPA should
The EPA project manager conducted a door-to-door survey in September 1993 to speak to residents
and update the mailing list for the ACW site. All residences south of Main Street, west of C
Street, and east of Barrancas with discernable addresses were added to the mailing list, bring
the current mailing list to over 300 households.
41.
Runoff from the site floods Gimble and Pine Streets.
Can anything be done to prevent this?
EPA's final remedy for Operable Unit 1 will include final grading of the site and installation
of drainage features to prevent this type of runoff problem.
42.
Can the dirt roads and streets be paved?
EPA has no authority to implement public works improvements such as these unless they relate
directly to implementation of the selected remedial action.
43. Why is only part of the ACW site fenced? Site operations (and therefore contamination)
extended to F Street. The perimeter fence needs to be extended.
EPA fenced the most contaminated areas of the site which posed the greatest threat to human
health. While other portions of the facility are contaminated, the risks are associated with
long-term exposure rather than short-term, incidental exposure by trespassers.
Operable Unit 1 remedy is implemented, the whole site probably be fenced.
44.
When the
The neighborhood should be declared a disaster areas, making it eligible for disaster aid.
EPA has no authority to declare "disaster areas." However, EPA believes the best way to rectify
the situation caused by past operations at the ACW site is to conduct remedial actions to
address the short-term risks associated with soil and groundwater contamination.
45. What is the total population and age distribution of all people living within a half-mile
radius of the ACW site?
In 1970, the residential population within a 1 mile radius of the site was approximately 5,000.
EPA does not maintain information on the age distribution of the community.
46. How many private wells exist within this radius? What is the depth of each of these wells?
Has the EPA determined the contaminant level of these wells?
Based on past data and door-to-door surveys, EPA has identified nine private wells in the site
vicinity south of Main St., between Barrancas Ave. and C Street. In addition, a public supply
well is located at the People's Crystal Ice Co. north of the site on Government St. This well
is reportedly sampled annually. Other wells may exist in the area. Most of the private
irrigation wells are fairly shallow (less than 20 ft.), but the ice company well is 190 ft.
deep. EPA sampled four wells, in 1984, including the ice company well. The Results indicated no
organic contamination in three of the wells, but two compounds (toulene and bis(2-ethylhexyl)
phthalate) were detected below detection limits in the Savannah Condo well upgradient of the
site (Mallory St.). Two other wells were sampled in 1988. The Yachtman's Cove condominium well
was contaminated with benzene above MCL, so this well was plugged in 1991.
47.
What is the contaminant level in the air when well water is sprayed during irrigation?
EPA has not determined what this concentration would be.
48.
What percentages of the well owners use their facilities regularly for irrigation?
is the frequency of use via spraying?
What
Based on discussions with known well owners, EPA estimates that 5 of the 9 private wells
identified south of Main St. are used for irrigation. The frequency of use is unknown.
49.
How much money has the EPA spent to date on the ACW site?
An estimated $2.3 million has been spent by the Atlanta office. This figure does not include
expenses incurred by the EPA offices in Athens, GA, Gulf Breeze, FL, and Cincinnati, OH.
50. The last EPA action at the ACW site left many drums, open containers, shallow catch basins
filled with stagnant water, treated poles, and a large open dumpster filled with garbage and
water. Why wasn't the area cleaned up?
During 1991, EPA contractors conducted a number of activities at the site including treatablity
studies, building demolition, drum sampling and segregation, fence and cap repairs, well
plugging, seeding and mowing. The drums containing low-level wastes such as drill cuttings and
purged groundwater were placed in a securely fenced area on the eastern portion of the site.
The "catch basins" are merely the foundations of demolished buildings which have filled with
rainwater. The dumpster remaining at the site contains non-hazardous construction debris.
These areas of concern will be addressed during the Operable Unit 1 remedial action.
51.
The site contains a sizeable open pool of some liquid.
Why hasn't this been covered?
EPA has identified and stabilized the visible source areas and waste impoundments at the site.
Any standing liquids are likely to be ponded rainwater which poses no threat to human health.
AMERICAN CREOSOTE WORKS, INC. (PENSACOLA PLANT)
Site Information:
Site Name:
Address:
AMERICAN CREOSOTE WORKS, INC. (PENSACOLA PLANT)
PENSACOLA, FL
EPA ID:
EPA Region:
FLD008161994
04
Site Alias Name(s):
AMERICAN CREOSOTE WORKS INC
AMERICAN CREOSOTE WORKS (PENSACOLA PLT)
Record of Decision (ROD) - Amendment:
ROD Date:
Operable Unit:
ROD ID:
05/21/1999
01
EPA/AMD/R04-99/500
Abstract:
In 1981, monitoring wells were installed by the U.S. Geologic
Survey (USGS) and results indicated a contaminant plume. The site
was proposed for the National Priorities List in 1981 and listed in
1983. In 1983, EPA investigations detected polycyclic aromatic
hydrocarbons (PAHs) in the soil and groundwater. In late 1983, EPA
conducted an immediate cleanup. In 1985, EPA conducted a
Remedial Investigation/Feasibility Study that detected PAHs,
phenols, and volatile organic compounds in soil and groundwater. A
1985 ROD selected a remedy addressing all on-site and off-site soils,
sludges, and sediments. However, no action was taken because the
State did not concur. After further study, a 1989 ROD selected a
remedy for contaminated soil. Because the RD treatability studies
indicated biological treatment selected in the 1989 ROD would not
work, an amended ROD is anticipated to address soil and sludges.
Remedy:
Consolidation and containment of contaminated sludge, soil, and
sediment beneath an onsite surface cap. The function of the remedy
is to isolate the site as a source of groundwater and surface water
contamination and reduce the risks associated with exposure to the
contaminated materials.
The selected remedy in the ROD Amendment involves the
construction of a Resource Conservation and Recovery Act (RCRA)
cap and surface drainage controls. Future uses of the property would
also be limited by the application of deed restrictions. Since the
Environmental Protection Agency (EPA) retains a 50 percent interest
in the ACW property through a bankruptcy settlement, EPA would
secure an agreement with any prospective purchaser identifying
appropriate land use restrictions and maintenance requirements.
Contaminated surface soil and subsurface soil in residential areas and
the Pensacola Yacht Club (PYC) and contaminated sediment in the
PYC drainage ditch which exceed EPA's remedial goals will be
excavated and consolidated on the ACW property. A low
permeability cap which meets RCRA closure requirements shall be
constructed over the stabilized material in the former surface
impoundments, consolidated materials from other areas within the
Area of Contamination (AOC), and other contaminated areas of the
ACW facility. The cover system shall be designed and constructed to
achieve the following criteria: provide long-term minimization of the
migration of liquids through the contained area; function with
minimum maintenance; promote drainage and minimize erosion or
abrasion of the final cover; and accommodate settling and subsidence
so that the cover's integrity is maintained. A vegetative cover of
native grass would be established to minimize cap erosion.
Because the residential surface soil remedial goal for dioxin is
subject to review and possible revision once EPA's Final Dioxin
Reassessment effort is complete, EPA and the state have agreed to
designate the cleanup of residential areas as an interim action. A final
ROD for residential surface soil will be issued if necessary. Surface
drainage controls including drainage ditches and a stormwater
retention pond will be constructed to manage runoff from the site.
The retention pond will be located on the east end of the ACW
property, and improvements to the City of Pensacola storm sewer
system will likely have to be constructed to provide adequate
capacity to route the water to Pensacola Bay. In addition, process
area foundations and debris will be demolished, decontaminated, and
disposed offsite.
Estimated Capital Cost: $1,341,100
Estimated Annual O&M Costs: $4,800
Estimated Present Worth Costs: 1,400,700
Text:
Full-text ROD document follows on next page.
EPA/AMD/R04-99/500
1999
EPA Superfund
Record of Decision Amendment:
AMERICAN CREOSOTE WORKS, INC. (PENSACOLA
PLANT)
EPA ID: FLD008161994
OU 01
PENSACOLA, FL
05/21/1999
AMENDED
RECORD OF DECISION
OPERABLE UNIT 1
AMERICAN CREOSOTE WORKS SITE
Pensacola, Escambia County, Florida
Prepared by:
U.S. Environmental Protection Agency
Region 4
Atlanta, Georgia
AMENDED
RECORD OF DECISION
OPERABLE UNIT 1
AMERICAN CREOSOTE WORKS
1. DECLARATION
SITE NAME AND LOCATION
American Creosote Works Site
Pensacola, Escambia County, Florida
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for Operable Unit 1 at the American
Creosote Works (ACW) site (“the Site”) in Pensacola, Florida, which was chosen in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as
amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986, 42 U.S.C 9601 et
seq., and to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), 40 CFR Part 300. This decision is based on the Administrative Record for this Site.
The Florida Department of Environmental Protection (FDEP) has provided input as the support agency
for the Site in accordance with 40 CFR 300.430. Based on FDEP’s comments to date, EPA expects that
concurrence on this remedy will be forthcoming, although a formal concurrence letter has not yet been
received.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this Site, if not addressed by implementing the
response action selected in this Amended Record of Decision (AROD), may present an imminent and
substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
The remedy selected by EPA for the ACW Site is being conducted in two operable units. Operable Unit
1, described in this AROD, addresses contaminated sludge, soil, and sediment, which represent the source
of contamination at the Site. Operable Unit 2, which is currently underway, addresses groundwater
contamination. The amended remedy selected in this AROD addresses the source of contamination at the
Site by consolidating and containing contaminated sludge, soil, and sediment beneath an on-site surface
cap. The function of the remedy is to isolate the Site as a source of groundwater and surface water
contamination and reduce the risks associated with exposure to the contaminated materials. The major
components of the selected remedy include the following:
1-1
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Demolish, decontaminate, and dispose process area foundations and debris in an off-site landfill;
Excavate contaminated surface and subsurface soil in residential areas and the Pensacola Yacht
Club (PYC) which exceed EPA’s remedial goals and consolidate these materials on the ACW
property;
Backfill excavated areas with clean fill, regrade, and landscape disturbed areas;
Excavate contaminated sediment in the PYC drainage ditch which exceeds EPA’s remedial goal
(to a maximum depth of 3 ft.) and consolidate this material on the ACW property;
Regrade, revegetate, and restore the disturbed areas of the ditch;
Construct a surface cap over consolidated materials and contaminated areas of the Site which
meets Resource Conservation and Recovery Act (RCRA) closure requirements under 40 CFR
264.228(a)(2);
Install drainage channels, a stormwater retention pond, and other drainage improvements to
manage stormwater runoff from the Site;
Repair or replace existing security fence around the Site as needed;
Provide periodic sampling of sediment in the PYC drainage ditch and regular mowing and
maintenance of the surface cap on the ACW Site, and;
Conduct groundwater monitoring as needed to evaluate the effectiveness of the containment
system.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with Federal and State
requirements that are legally applicable or relevant and appropriate to the remedial action, is cost-effective,
and utilizes permanent solutions and alternative treatment technologies to the maximum extent practicable
for this Site. Because treatment of the principal threats at the Site were accomplished through previous
response actions and the anticipated volume of source materials (over 80,000 cubic yards) render
cost-effective treatment of the source materials impracticable, further treatment was not found to be
practicable. Thus, the remedy in this OU does not satisfy the statutory preference for treatment as a
principal element of the remedy.
Because this remedy will result in hazardous substances remaining onsite above levels that allow for
unlimited use and unrestricted exposure, a review will be conducted within five years after initiation of
remedial action to ensure that the remedy continues to provide adequate protection of human health and
the environment.
1-2
TABLE OF CONTENTS
1. Declaration
SITE NAME AND LOCATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
STATEMENT OF BASIS AND PURPOSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
ASSESSMENT OF THE SITE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
DESCRIPTION OF THE REMEDY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
STATUTORY DETERMINATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2
2. Decision Summary
1.0
Site Name, Location, and Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1
2.0
Site History and Enforcement Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1
2.1
Site History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1
2.2
Enforcement Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4
3.0
Reasons for the ROD Amendment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5
4.0
Highlights of Community Participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6
5.0
Scope and Role of the Response Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6
6.0
Summary of Site Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7
6.1
Surface Soil . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7
6.2
Subsurface Soil . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7
6.3
Stabilized Sludge . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-10
6.4
Drainage Ditch Sediment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-10
6.5
Volume of Contaminated Material . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-10
7.0
Summary of Site Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7.1
Human Health . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7.1.1 Chemicals of Concern . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7.1.2 Exposure Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7.1.3 Toxicity Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7.1.4 Risk Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7.2
Ecological Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7.3
Risk Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
i
2-10
2-11
2-11
2-13
2-14
2-14
2-16
2-17
8.0
Description of Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.1
Alternatives for Addressing Soil and Sludge . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.1.1 Remedy from the 1989 ROD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.1.2 Alternative SS1 - No Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.1.3 Alternative SS2 - Capping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.1.4 Alternative SS3 - Slurry Biotreatment . . . . . . . . . . . . . . . . . . . . . . . . .
8.1.5 Alternative SS4 - In-Situ Vitrification . . . . . . . . . . . . . . . . . . . . . . . . . .
8.1.6 Alternative SS5 - Onsite Incineration . . . . . . . . . . . . . . . . . . . . . . . . . .
8.1.7 Alternative SS6 - Onsite Thermal Desorption . . . . . . . . . . . . . . . . . . . .
8.2
PYC Ditch Sediment Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.2.1 Alternative SD1 - No Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.2.2 Alternative SD2 - Total Sediment Removal . . . . . . . . . . . . . . . . . . . . .
8.2.3 Alternative SD3 - Partial Sediment Removal & Lining of Ditch . . . . . . .
8.2.4 Alternative SD4 - Total Sediment Removal, Extend Culvert, and Backfill
Ditch . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2-17
2-17
2-17
2-18
2-18
2-18
2-19
2-19
2-19
2-19
2-20
2-20
2-20
2-20
9.0
Comparative Analysis of Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-20
9.1
Evaluation of Soil and Sludge Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-21
9.1.1 Overall Protection of Human Health and the Environment . . . . . . . . . . . 2-21
9.1.2 Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-21
9.1.3 Short Term Effectiveness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-21
9.1.4 Long Term Effectiveness and Permanence . . . . . . . . . . . . . . . . . . . . . . 2-21
9.1.5 Reduction of Mobility, Toxicity, or Volume through Treatment . . . . . . . 2-22
9.1.6 Implementability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-22
9.1.7 Cost Effectiveness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-22
9.1.8 State Acceptance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-22
9.1.9 Community Acceptance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-23
9.2
Evaluation of PYC Ditch Sediment Alternatives . . . . . . . . . . . . . . . . . . . . . . . . 2-23
9.2.1 Overall Protection of Human Health and the Environment . . . . . . . . . . . 2-23
9.2.2 Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-23
9.2.3 Short-Term Effectiveness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-23
9.2.4 Long-Term Effectiveness and Permanence . . . . . . . . . . . . . . . . . . . . . . 2-24
9.2.5 Reduction of Toxicity, Mobility or Volume through Treatment . . . . . . . 2-24
9.2.6 Implementability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-24
9.2.7 Cost Effectiveness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-24
9.2.8 State Acceptance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-24
9.2.9 Community Acceptance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-24
10.0
Selected Remedy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-25
10.1 Components of the Selected Remedy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-25
ii
11.0
Statutory Determinations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-33
11.1 Overall Protection of Human Health and the Environment . . . . . . . . . . . . . . . . . 2-33
11.2 Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-33
11.3 Cost Effectiveness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-35
11.4 Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-35
11.5 Preference for Treatment as a Principal Element . . . . . . . . . . . . . . . . . . . . . . . . 2-36
12.0
Documentation of Significant Changes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-36
13.0
Documentation of Five-Year Remedy Review for OU1 . . . . . . . . . . . . . . . . . . . . . . . . 2-37
3. Responsiveness Summary
1.0
Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2
2.0
Background on Community Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2
3.0
Summary of Comments Received and EPA’s Responses . . . . . . . . . . . . . . . . . . . . . . . . 3-3
4.0
Remedial Design/Remedial Action (RD/RA) Concerns . . . . . . . . . . . . . . . . . . . . . . . . . 3-25
iii
2. DECISION SUMMARY
1.0
Site Name, Location, and Description
The American Creosote Works (ACW) site (“the Site”) occupies 18 acres in a moderately dense
commercial and residential district of Pensacola, Florida. The Site is located about one mile southwest of
the intersection of Garden and Palafox Streets about 600 yards north of Pensacola Bay and Bayou Chico
(see Figure 1). Several businesses lie directly north of the Site, including a lumber company, an auto body
shop, and an appliance sales and repair shop. Residential areas are next to the ACW facility on the east
and south, and the Pensacola Yacht Club (PYC) is southwest of the Site.
The Site is generally flat, with elevations ranging between 12 and 14 feet above sea level. The land slopes
gently southward at about 25 feet per mile toward Pensacola Bay. Primary access to the plant is from West
Gimble Street. The Site is fenced, and EPA’s groundwater recovery and treatment system (Operable Unit
2) currently occupies the western portion of the Site. A few building foundations and miscellaneous debris
piles are scattered throughout the remainder of the Site. Current site conditions are depicted in Figure 2.
2.0.
Site History and Enforcement Activities
2.1
Site History
Wood-preserving operations were carried out at the ACW facility from 1902 until December 1981. Prior
to 1950, creosote was used exclusively to treat poles. Use of pentachlorophenol (PCP) started in 1950
and steadily increased in later years of operation. Dioxins at the Site resulted from the use of PCP as a
wood treating chemical, since dioxins are a common impurity in commercial grade PCP.
Four former surface impoundments were located in the western portion of the ACW facility. The Main and
Overflow Ponds, located adjacent to L Street, were used for disposal of process wastes. Prior to about
1970, wastewater in these ponds was allowed to overflow through a spillway, flow through the streets and
storm drains into a ditch on the PYC property, and from there flow into Bayou Chico and Pensacola Bay.
In later years, liquid wastes were drawn off the larger lagoons and collected in the smaller Railroad
Impoundment and Holding Pond or were spread on the ground in designated “Spillage Areas” onsite.
However, the ponds overflowed during periods of heavy rainfall.
In 1980, the City of Pensacola found oily creosote-like material in the groundwater near the intersection
of L Street and Cypress Streets. In 198 1, the U.S. Geological Survey (USGS) installed nine groundwater
monitor wells in the vicinity of the Site. Samples taken from those wells revealed that a contaminant plume
was moving in a southerly direction toward Pensacola Bay. EPA placed the Site on the National Priorities
List (NPL) in 1983.
EPA conducted a Superfund investigation in 1983 to sample onsite soil, wastewater sludge, drainage ditch
sediment, and groundwater. The major contaminants identified were polynuclear aromatic hydrocarbons
(PAHs), which are common constituents of creosote. Later that year, the main and
2-1
Figure 1. Site Location Map
2-2
Figure 2. Site Layout
2-3
overflow ponds were about to overflow due to heavy rains and flooding, so EPA performed an emergency
cleanup to prevent contamination from migrating off-site. The emergency action involved draining the
lagoons, treating the wastewater, solidifying the sludge in the lagoons with lime and fly ash, and constructing
a temporary clay cap over the lagoons.
In 1985, EPA completed a Remedial Investigation and Feasibility Study (RI/FS). Based on this study, EPA
signed a ROD in September 1985 which called for construction of an onsite landfill in which all
contaminated surface soil, sludge, and sediment would be disposed. Groundwater cleanup was not included
in this ROD. However, the Florida Department of Environmental Regulation (predecessor agency to
FDEP) did not concur with this decision, citing the need to evaluate additional treatment technologies.
Consequently, EPA performed an additional study in 1988 (the Post-RI) to provide further information on
the extent of contamination in surface soil. Based on the results of this study, EPA completed a revised risk
assessment and a “Post-FS” and signed a ROD in 1989 which selected bioremediation for treatment of
contaminated surface soil. The 1989 ROD called for treatability studies to be conducted during the design
to determine the most effective type of biological treatment. While these studies indicated that slurry-phase
biotreatment was more effective than solid-phase treatment (landfarming) for addressing many site-related
compounds, neither technology was effective at destroying PCP and some carcinogenic PAHs. For this
reason, EPA is issuing this amended ROD (AROD) to select another cleanup plan for addressing soil,
sludge, and sediment contamination at the Site.
Several additional field studies were conducted following the. 1989 ROD to better characterize the extent
of dioxin, PCP, and PAH contamination in groundwater, solidified sludge, soil, surface water, and sediment.
These studies are summarized in a subsequent section of this AROD.
EPA also completed a supplemental risk assessment and FS in 1993 which addressed groundwater,
solidified sludge, and subsurface soil. Based on the results of these studies, EPA selected a groundwater
cleanup plan in 1994 which called for extraction and recycling of dense non-aqueous phase liquids
(DNAPLs) followed by in-situ/ex-situ biological treatment of contaminated groundwater. Construction of
the DNAPL recovery system was completed in September 1998, and the system is currently being
operated for EPA by the U.S. Army Corps of Engineers, Mobile District.
2.2
Enforcement Summary
The earliest documented incident of a release of any type from the ACW plant occurred in the summer of
1978, when a spill of liquids flowed onto a nearby street and then onto the property of a yacht sales
company. A flood in March 1979 resulted in a similar spill. These incidents resulted in increased regulatory
attention to ACW by FDER.
In 1980, ACW filed an incomplete application with FDER for construction of an industrial wastewater
treatment system. FDER issued a Notice of Violation (NOV) for corrective action in
2-4
1981, alleging contamination of soil and groundwater. This enforcement action called for ACW to cease
operations until a permit was issued, submit a restoration plan, install a groundwater monitoring system, and
remove contaminated soil. In January 1981, FDER completed a responsible party search, a title search,
and a financial assessment for the Site, and in March 1981, FDER and ACW entered into an administrative
consent order which incorporated the previous NOV requirements and allowed ACW to continue
operations. The Order included schedules for completing construction of the wastewater treatment system
and meeting the other NOV requirements.
Throughout 1981 and 1982, FDER encountered difficulty with ACW’s compliance efforts, and in March
1982, ACW announced that environmental regulations were forcing the company to go out of business.
As a result, FDER filed a Petition for Enforcement and Agency Action and a Complaint for Permanent
Injunction and Civil Penalties in April 1982 because of ACW’s failure to make progress toward
compliance. One month later, in May 1982, ACW, Inc. of Florida filed for reorganization in bankruptcy
court. In 1984, the parties presented a stipulation to the court for approval. The stipulation provided that
half of the proceeds of any sale or lease of the ACW property would go to EPA and FDER. The remaining
50 percent would go to Savings Life Insurance Company which holds a mortgage on the property in the
principal sum of $675,000. The stipulation was approved and entered by the court in 1988.
In 1985, EPA sent a notice letter to Burlington Northern Railroad requesting removal of a railroad spur line
along their right of way on the Site. The railroad company completed this work in 1986.
3.0
Reasons for the ROD Amendment
In accordance with the requirements of the 1989 ROD, EPA conducted treatability studies during design
to determine the most effective type of biological treatment. The first of these studies was performed by
Southern Bio Products, Inc., under the supervision of EPA’s Environmental Research Laboratory in Gulf
Breeze, Florida. This bench-scale study evaluated and compared the effectiveness of solid-phase (e.g. land
farming) and slurry-phase bioremediation in reducing levels of PAH and PCP contamination in surface soil
from the Site. The study concluded that solid-phase bioremediation was slow and ineffective, especially
with respect to the carcinogenic PAHs and PCP. Although slurry-phase treatment was much more
effective, persistent contaminants such as cPAHs and PCP were not effectively degraded.
The study also evaluated the effectiveness of both types of bioremediation in addressing stabilized sludge
(called “sediment” in the report) from the Site. Solid-phase treatment was non-effective. However,
slurry-phase treatment with pH adjustment resulted in relatively rapid and extensive biodegradation of
cPAHs and PCP. None of the treatability tests evaluated the effectiveness of biological treatment on dioxin
contamination in soil or sludge from the Site.
EPA later tasked the OU1 design contractor to evaluate the entire treatment train for slurry-phase
biotreatment, which would involve soil washing as a pre-treatment step. This study concluded that the
proposed treatment process was incapable of adequately treating the surface soil most heavily
contaminated with PAHs. In addition, the report concluded that the proposed soil treatment technology
was not appropriate for reduction of dioxin in soil from the Site.
2-5
On the basis of these treatability test findings, EPA determined that the selected remedy for surface soil of
slurry-phase biological treatment would not be effective in addressing surface soil contamination at the Site.
Therefore, this AROD presents the other alternatives EPA considered and identifies EPA’s selected
remedy for addressing all contaminated solid media at the Site.
4.0
Highlights of Community Participation
In accordance with Sections 113 and 117 of CERCLA, as amended, EPA has conducted community
involvement activities at the ACW Site to solicit community input and to ensure that the public remains
informed about site activities. EPA’s Proposed Plan Fact Sheet for this amended remedy was mailed to
the public on April 28, 1998, and a copy of the Administrative Record was made available in the
information repository at the West Florida Regional Library. A public notice was published in the
Pensacola News Journal in Pensacola, Florida, on April 30, 1998, advising the public of the availability
of the administrative record and the date of the upcoming public meeting. EPA held a public meeting on
May 14, 1998, at the Sanders Beach Community Center in Pensacola, Florida, to answer questions and
receive comments on the Agency’s preferred alternative. A public comment period was also held from May
1, 1998 through July 1, 1998. EPA’s responses to comments received during the public meeting and the
public comment period are included in the Responsiveness Summary in Section 3 of this Amended ROD.
5.0
Scope and Role of the Response Action
As with many Superfund sites, the problems at the ACW Site are complex, so the work has been divided
into the following phases referred to as Operable Units (OUs): OU1 is remediation of contaminated soil,
sludge, and sediment, OU2 is remediation of contaminated groundwater.
Prior to 1994, EPA defined the OUs at the Site in a different way. OU1 referred to surface soil
contamination from 0 to 3 ft., and OU2 referred to contaminated groundwater, subsurface soil, and
solidified sludge from the former waste lagoons. Many documents contained in the Administrative Record,
including the OU2 FS, the OU2 Risk Assessment, and the 1989 OU1 ROD reflect this old definition.
However, in 1994, to streamline Site cleanup decisions, EPA grouped all solid media into OU1, including
surface soil, subsurface soil, solidified sludge, and PYC ditch sediment. OU2 was redefined to include only
groundwater, and in February 1994, EPA signed a ROD for OU2 outlining EPA’s cleanup plan for
addressing groundwater contamination.
In 1989, EPA signed a ROD selecting biological treatment to address surface soil contamination at the Site.
However, following further treatability testing of this technology, EPA determined this remedy would not
be fully effective for all contamination. Therefore, this AROD addresses the changes needed to the surface
soil cleanup plan and presents the alternatives EPA considered for addressing subsurface soil, solidified
sludge, and PYC ditch sediment.
2-6
6.0
Summary of Site Characteristics
Since issuance of the 1989 ROD, EPA has conducted the following investigations to further characterize
soil and sediment contamination:
B
B
B
B
B
B
Phase II RI, September 1990
Phase III RI, August 1991
Dye Dispersion and Sediment Sampling Study, September 1991
Supplemental Site Characterization Sampling and Treatability Study, November 1991
Phase IV RI, February 1994
Sanders Beach Community Area Study, December 1997
Samples were taken from the following media: surface soil, subsurface soil, stabilized pond sludge, and
sediment from Pensacola Bay and the PYC ditch. In general, the results of these new investigations confirm
those reported in the Post-RI and the 1989 ROD and provide updated information on dioxin levels. The
maximum concentration of chemicals of concern detected in each medium based on the most recent data
are summarized in Table 1. A summary of contaminant information for each medium is provided below.
In accordance with EPA’s Area of Contamination Policy, EPA has designated the area shown in Figure
3 as an area of contamination (AOC) which requires remediation.
6.1
Surface Soil
On-site surface soil data collection efforts subsequent to 1989 focused primarily on characterizing the extent
of dioxin contamination. Results from the Phase II and Phase III RIs and the Supplemental Site
Characterization indicate surface soil contaminant concentrations exceed EPA’s industrial remedial goals
for the Site of 2.5 parts per billion (ppb) for dioxin and 50 parts per million (ppm) for carcinogenic PAHs
(cPAHs). A discussion of the remedial goals for each medium and the rationale for their selection is
presented in Section 7.1.1 of this AROD.
Residential soil data from the Post-RI indicated elevated levels of PAH contamination in the drainage
pathways south of the ACW facility. Surface soil sampling after 1989 focused on dioxin and PAH
contamination, since PCP was not detected. Data from the Supplemental Site Characterization and the
Sanders Beach Study identified one location just south of the ACW property where dioxin exceeds the
site-specific remedial goal for residential soil of 1.0 ppb. Only one residential lot and three other lots with
potential residential use exceeded the remedial goal for benzo(a)pyrene, the most potent of the cPAHs. An
estimated 24,000 cubic yards (cy) of surface soil on the ACW facility and an estimated 4,000 cy of surface
soil in other areas require remediation.
6.2
Subsurface Soil
For the ACW Site, subsurface soil is defined as soil from 3 ft. below the surface to the top of the water
table. PAHs and low levels of dioxin were detected in this medium, but no PCP was detected. Subsurface
soil exceeding remedial goals is limited to an area south of the former sludge ponds.
2-7
Table I
Chemicals of Concern
Maximum Concentrations Detected (ppm)
Surface Soil
ACW Facilitya
Surface Soil
Residential Areaa
Subsurface Soila
Stabilized Sludge b
PYC Sediment c
.005
ND
ND
.087
ND
1,300
2,400
1,100
1,000
1,600
2,000
4,500
.82
12.0f
.48f
2.3
.78
9.5
6.7
100
230
53
81
120
150
350
410
610
1,100
360
520
440
1,100
43
140
33
30
53
91
170
Carcinogenic PAHs
Benzo(a)Pyrene
Benzo(a)Anthracene
Benzo(b&k)Fluoranthene
Chrysene
Indeno(1,2,3-c,d) Pyrene
Dibenzo(a,h)Anthracene
160
300
240
500
46
12
5.9f
6.6f
14.0f
8.3
9.2
4.7
.27
12
3.7
9.9
.61
ND
49
130
63
100
.0022
ND
20
39
39
31
9.2
ND
Phenols
Pentachlorophenol
110
.54
ND
250
ND
1,100
.01d
.41
.0023f
95
.00019
330
.051
29
.0000046
Compound
Volatile Organics
Benzene
Non-Carcinogenic PAHs
Acenaphthene
Fluoranthene
Naphthalene
Anthracene
Fluorene
Pyrene
Phenanthrene
Dioxins/Furans
Dibenzofuran
2,3,7,8-TCDD (TEQ)
ND - non-detect
a
Source: Post-RI, 1989, unless otherwise
noted.
b
Source: Post-RI, 1989; Phase II RI, 1990.
c
Source: Phase IV RI, 1994.
d
Source: Phase II RI, 1990.
Source: Phase III RI, 1991.
f
Source: Sanders Beach Community Area
Study, 1997.
e
2-8
Figure 3. Area of Contamination
<D>
6.3
Stabilized Sludge
The stabilized sludge located on the western portion of the ACW facility resulted when the former lagoons
were drained and the remaining sludge was stabilized by the addition of lime and fly ash. The estimated
volume of this material above the water table (to a depth of about 6.5 ft. below land surface) along with
the small amount of subsurface soils identified above is 50,700 cubic yards. Results from the Post-RI
indicate that PAH concentrations in this material are as high as 27,200 ppm. PCP concentrations as high
as 250 ppm, were also detected. The pH of this material is also expected to be high because of the addition
of the stabilizing agents. Soil borings drilled during the Phase II RI indicated that significant PAH
contamination (above 50 ppm) extends below the water table to a depth of at least 60 ft. However,
contamination below the water table is being addressed as part of EPA’s groundwater remedial action.
6.4
Drainage Ditch Sediment
In 1991, EPA conducted the Dye Dispersion and Sediment Sampling Study to determine the presence and
concentration of site-related compounds within the area of Pensacola Bay influenced by surface water
drainage from the PYC drainage ditch. Based on the results of a dye tracer study, water stage and elevation
measurements, water current readings, and fathometer transects, EPA selected 18 sediment sampling
locations within the PYC ditch, Bayou Chico, and Pensacola Bay. Samples were analyzed for extractable
and purgeable organic compounds, pesticides and PCBs, and metals. The results of the study indicated that
no organic compounds were detected within the upper stratum of the bay sediments. In addition, levels of
organics and metals in the surface waters were within normal ranges found throughout southeastern
estuarine systems. However, sediment data from two sampling stations in the PYC ditch and its delta
indicated the presence of numerous PAHs which exceeded the National Oceanic and Atmospheric
Administration (NOAA) toxic effects levels for sediment. Samples from the Phase IV RI confirmed cPAH
levels in the PYC ditch sediment as high as 138 ppm. No PCP was detected, and dioxin concentrations
ranged from 0.069 to 5 ng/kg (parts per trillion or ppt) TEQ. After consulting with the Ecological Technical
Advisory Group (ETAG), which includes EPA ecological experts and natural resource trustees, EPA
concluded that the only sediment requiring remediation is the sediment in the PYC drainage ditch. The
estimated volume of contaminated sediment requiring remediation ranges from 833 to 2,500 cubic yards,
depending upon the depth of remediation.
6.5
Volume of Contaminated Material
The total volume of contaminated soil, sediment, and stabilized sludge requiring remediation is estimated
to be 80,500 cy. This volume was used to generate the cost estimate for each alternative.
7.0
Summary of Site Risks
The Baseline Risk Assessment (BRA) includes an evaluation of whether existing or future exposure to Site
contamination could pose a risk to people or the environment. In estimating potential Site
2-10
risks, EPA assumes no further action would be taken to address contamination at the Site. This evaluation
then serves as a baseline for determining whether cleanup of Site media is necessary. EPA has performed
two BRAs for the ACW Site. The first, completed in 1989, evaluated the risks associated with surface soil
at the ACW facility and in residential areas and PYC ditch sediment. Although the toxicologic criteria
values for some Site contaminants have changed slightly in the last 10 years, the risk calculations and
remedial goals presented in the 1989 BRA remain protective. The second BRA, completed in 1993,
evaluated risks associated with subsurface soil, stabilized sludge, and groundwater. This AROD addresses
the risks associated with contaminated soil, stabilized sludge, and PYC ditch sediment. The risks associated
with groundwater contamination were addressed in the 1994 ROD for OU2. The risk assessments include
a human health evaluation which addresses the four components summarized below and an ecological risk
evaluation.
7.1
Human Health
The human health portion of the BRA is designed to evaluate the baseline risk posed by the Site to people
if no action is taken to address Site contamination and to assess if actual or threatened releases of chemical
contamination from the Site pose health risks to exposed individuals under current or potential future
conditions. The ACW property itself is currently fenced and abandoned, and a temporary clay cap has
been placed over the former sludge lagoons. Although groundwater in the unconfined aquifer beneath and
down gradient of the facility is contaminated above drinking water standards, neither private nor public
potable water supplies are drawn from the surficial aquifer.
7.1.1
Chemicals of Concern
EPA identified chemicals of concern for the ACW Site based on past disposal practices, frequency of
detection, and toxicity of contaminants. Over 100 different compounds were identified in the analyses of
soil, sludge, and sediment samples on and around the Site. Of these, 17 were selected as chemicals of
concern (COCs) because of the risk they pose. A list of chemicals of concern for each medium and their
associated remedial goals is shown in Table 2.
The 1989 ROD identified remedial goals for cPAHs, PCP, and 2,3,7,8-TCDD in surface soil on the ACW
facility which correspond to an excess lifetime cancer risk of 1 x 10-5. These remedial goals were
determined to be protective for the anticipated future industrial use of the ACW property.
For residential (and PYC) surface soil, EPA evaluated the data from the Sanders Beach Community Area
Study against FDEP’s residential soil screening levels to determine whether any areas warranted further
attention. Only 4 samples exceeded FDEP screening levels and EPA’s Contract Laboratory Program
(CLP) contract required quantitation limit (CRQL) of 330 ug/kg for benzo(a)pyrene. EPA determined from
this analysis that the remedial goal for benzo(a)pyrene in residential surface soil should be set at the CRQL
of 330 ug/kg. In addition, in all instances where another compound exceeded FDEP’s surface soil guidance
concentration, the benzo(a)pyrene result exceeded the CRQL, indicating that benzo(a)pyrene is an
appropriate indicator compound, and there is no need to set residential surface soil remedial goals for the
other PAHs.
2-11
Table 2
Remedial Goals for Chemicals of Concern (ppm)
Compound
PYC
Sediment a
Subsurface
Soil/Sludge b
Non-Carcinogenic PAHs
Acenaphthene
Anthracene
Fluoranthene
Fluorene
Naphthalene
Phenanthrene
Pyrene
Carcinogenic PAHs (cPAHs)
Total cPAHs (listed below)
Benzo(a)Anthracene
Benzo(a)Pyrene
Benzo(b&k)Fluoranthene
Chrysene
Dibenzo(a,h)Anthracene
Indeno(1,2,3-c,d)Pyrene
Surface Soil
Residential ACW Facilitye
876
145
1,450
78
235
148
1,070
.655
50
740
0.33c
153,065
2,090
Phenols
Pentachlorophenol
138,000
30
Dioxins/Furans
Dibenzofuran
2,3,7,8-TCDD (TEQ)
24
.001d
a
.0025
Sediment Quality Assessment Guideline Toxic Effect Level (TEL) for high molecular weight PAHs, from
the Approach to the Assessment of Sediment Quality in Florida Coastal Waters, Volume 1: Development
and Evaluation of Sediment Quality Assessment Guidelines, November 1994
b
Site-specific groundwater protection standards, OU2 Risk Assessment, 1993
c
Contract required quantitation limit (CRQL) from EPA’s Contract Laboratory Program Statement of
Work. Although the FDEP soil screening level for benzo(a)pyrene is 0.1 mg/kg, the remedial goal was
limited by the CRQL.
d
Approach for Addressing Dioxin in Soil at CERCLA and RCRA Sites (OSWER Directive 9200.4-26)
e
1989 Record of Decision for Operable Unit 1
2-12
With respect to dioxin in residential surface soil, OSWER Directive 9200.4-26, “Approach for Addressing
Dioxin in Soil at CERCLA and RCRA Sites” (4/13/98), was followed in obtaining a preliminary
remediation goal (PRG) of 1 ppb (TEQ) for dioxin in residential surface soil. This level was selected as the
final remedial goal since there were no recognized extenuating circumstances to indicate that the PRG level
was not protective. However, because the 1 ppb residential surface soil remedial goal for dioxin is subject
to review and possible revision once EPA’s Final Dioxin Reassessment effort is complete, EPA and FDEP
have agreed to designate the cleanup of residential areas as an interim action. This approach allows the
Agencies to achieve significant risk reduction immediately rather than deferring action at the Site while EPA
completes the dioxin reassessment. EPA will review the dioxin cleanup level for residential surface soil
following the release and analysis of the reassessment report and issue a final ROD for residential surface
soil if necessary.
EPA will use the remedial goals developed in the OU2 BRA for subsurface soil and solidified sludge. These
remedial goals were developed by EPA’s groundwater technical support section to ensure that contaminant
leaching from subsurface soil and solidified sludge did not result in exceedance of the alternate
concentration limits (ACLs) adopted as remedial goals for groundwater in the OU2 ROD.
For sediment in the PYC drainage ditch, a Site-specific remedial goal for carcinogenic PAHs in ditch
sediment of 1.6 mg/kg was calculated in Appendix B of the Focused Feasibility Study based on the most
likely exposure scenario of an adolescent trespasser (age 7 to 16) playing in the ditch. However, following
issuance of the Proposed Plan and during development of this AROD, FDEP requested that their Sediment
Quality Assessment Guidelines Toxic Effect Levels (TEL) be considered in the development of a remedial
goal for sediment. Based on these guidelines, EPA has established a remedial goal for the PYC ditch
sediment of 0.655 mg/kg for carcinogenic PAHs.
7.1.2
Exposure Assessment
The exposure assessment identified and evaluated the potential routes and pathways through which current
residents, trespassers, or future residents could be exposed to Site contaminants. The BRA identified the
following pathways in which people could come into contact with contaminated solid media under both
current and future conditions:
1.
Ingestion of (eating) or dermal contact with (touching) surface soil by current or future
residents or trespassers in the following locations:
Area I
American Creosote Works facility
Area II
Residential areas
Area III
PYC drainage ditch area
Area IV
Condominium block1
________________________
1
In the 1989 BRA, the “condominium block” (Area IV) is the city block north of Cypress Street
between L and K Streets which includes the Yachtsman Cove Condominiums. The “residential
area” (Area II) includes the remaining residential properties south of the Site.
2-13
2.
3.
7.1.3
Inhalation (breathing) of dust from ACW surface soil by current or future residents.
Consumption of vegetables grown in contaminated soil by current or future residents.
Toxicity Assessment
The toxicity assessment evaluated possible harmful effects of exposure to chemicals of concern. Many
compounds found at the Site, including PAHs, PCP, and dioxins, have the potential to cause cancer
(carcinogenic). These and other chemicals of concern, (e.g. naphthalene), may cause health risks not related
to cancer, such as liver damage or reproductive effects. For carcinogenic compounds, cancer slope factors
(CSFs) have been developed by EPA. These factors are chemical-specific numbers that indicate their
potency as a carcinogen. A chemical’s CSF is multiplied by the estimated intake (dose) of a that chemical
by all routes and pathways of exposure to provide an upper-bound estimate of the excess lifetime cancer
risks associated with exposure at that level. The term “upper bound” reflects the conservative estimate of
the risks calculated from the CSF. Use of this approach makes under-estimation of the actual cancer risk
highly unlikely. Cancer slope factors are derived from the results of human epidemiological studies or
chronic animal bioassays to which animal-to-human extrapolation and uncertainty factors have been
applied.
References doses (RfDs) have been developed by EPA for predicting the potential for adverse health
effects from exposure to chemicals exhibiting noncarcinogenic effects. RfDs, which are expressed in units
of mg/kg-day, are estimates of lifetime daily exposure levels for humans, including sensitive individuals, that
are thought to be without adverse affects. Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking water) can be compared to the RfD. RfDs
are derived from human epidemiological studies or animal studies to which uncertainty factors have been
applied. These uncertainty factors help ensure that the RfDs will not underestimate the potential for adverse
noncarcinogenic effects to occur. The CSFs and RfDs for the chemicals of concern at the Site are listed
in Table 3.
As an interim procedure until more definitive Agency guidance is established, EPA has adopted a Toxicity
Equivalency Factor (TEF) methodology for evaluating the toxicity of chlorinated dioxins and furans. This
methodology relates the relative potency of each dioxin/furan compound to the potency of
2,3,7,8-tetrachlorodibenzodioxin (TCDD), the most toxic dioxin compound. For example, the compound
1,2,3,7,8-pentachlorodibenzodioxin (PeCDD) is considered only 50% as toxic as 2,3,7,8-TCDD, so its
concentration is multiplied by 0.5 to estimate its concentration relative to TCDD. After this is done for each
of the 29 specific dioxin and furan compounds of concern to EPA, the concentrations are added to provide
a single concentration value known as TCDD equivalents (TEQs). All of the dioxin values discussed in this
AROD are presented in TEQs.
7.1.4
Risk Characterization
The risk characterization combines the other components of the risk assessment to estimate the overall risk
from exposure to Site contamination. For carcinogenic compounds, risk is a probability that is expressed
in scientific notation. For example, an excess lifetime cancer risk of 1x10-6 means
2-14
Table 3
Toxicologic Criteria Values for
Chemicals of Concern
(Source: 1989 Baseline Risk Assessment for ACW Site)
Compound
Cancer Slope Factor (CSF)
Oral
Inhalation
Reference Dose (RfD)
Oral
Inhalation
Non- Carcinogenic PAHsa
NA
NA
4.00E-01
NA
Carcinogenic PAHs (cPAHs)b
11.5
6.10
NA
NA
Phenols c
NA
NA
5.00E-02
NA
Pentachlorophenol
NA
NA
3.00E-02
NA
1.56E+05
NA
1.00E-12
NA
2,3,7,8-TCDD
NA - No criteria value available for this chemical under this pathway.
a
The RfD for naphthalene was used to represent noncarcinogenic PAHs.
The CSF for benzo(a)pyrene was used to represent carcinogenic PAHs.
c
The RfD for cresols was used to represent phenols
b
2-15
that an individual has an additional 1 in 1,000,000 chance of developing cancer as a result of Site-related
exposure over an estimated 70 year lifetime. EPA has established a target risk range for Superfund
cleanups of between 10-4 and 10-6. The reasonable maximum (90th percentile) excess lifetime cancer risk
associated with ingestion and dermal exposure to dioxins and cPAHs in surface soil by a trespasser on the
ACW facility (Area I) were estimated to be 1.2x10-3, which exceeds EPA’s acceptable risk range. Excess
cancer risk estimates for the PYC ditch (Area III) and the Condominium Block (Area IV) were at the
upper end of EPA’s risk range.
For compounds which cause toxic effects other than cancer, EPA compares the concentration of a
contaminant found at the Site with a reference dose (RfD) representing the maximum amount of a chemical
a person could be exposed to without experiencing harmful effects. The ratio of the actual concentration
to the RfD for a particular compound is the hazard quotient. The sum of the hazard quotients of all
chemicals of concern within a particular media (e.g. surface soil) is known as the hazard index (HI). EPA
considers an HI of 1.0 to be a threshold for considering remedial action. For the ACW Site, the BRA
indicates the potential for non-carcinogenic health risks on the ACW facility (Area I) and in the
condominium block (Area IV) due to ingestion and dermal exposure to dioxins and dibenzofurans.
Non-carcinogenic risks are not predicted to be a hazard for exposure to surface soil in Areas II and III.
Based on analytical data collected in 1988 during the Post-RI, excess lifetime cancer risks associated with
the vegetable consumption pathway fell within EPA’s acceptable risk range. Non-carcinogenic risks were
not calculated for the vegetable pathway because no non-carcinogenic COCs were known to be present
in the residential areas at elevated concentrations. Risks from dioxins and dibenzofurans were not calculated
for this pathway because the literature suggested that these compounds were not taken up by plants to a
significant extent, and thus did not pose an exposure pathway for these chemicals.
7.2
Ecological Evaluation
Since the ACW facility itself is industrial, and it is surrounded by commercial and residential areas, the
primary areas of ecological concern near the Site are Pensacola Bay and Bayou Chico. To evaluate the
potential for ecological impacts from the Site, EPA conducted the Dye Dispersion and Sediment Sampling
Study in 1991 to determine the presence and concentration of Site-related compounds within the area of
Pensacola Bay influenced by surface water drainage from the PYC drainage ditch. Based on the results
of a dye tracer study, water stage and elevation measurements, water current readings, and fathometer
transects, EPA selected 18 sediment sampling locations within the PYC ditch, Bayou Chico, and Pensacola
Bay. Samples were analyzed for extractable and purgeable organic compounds, pesticides and PCBs, and
metals. The results of the study indicated that no organic compounds were detected within the upper
stratum of the bay sediments. In addition, levels of organics and metals in the surface waters were within
normal ranges found throughout southeastern estuarine systems. However, sediment data from two
sampling stations in the PYC ditch and its delta indicated the presence of numerous PAHs which exceeded
the National Oceanic and Atmospheric Administration (NOAA) toxic effects levels for sediment. Samples
from the Phase IV RI confirmed cPAH levels in the PYC ditch sediment as high as 138 ppm. No PCP was
detected, and dioxin concentrations ranged from 0.069 to 5 ng/kg (parts per trillion or ppt). EPA provided
the
2-16
information from the Dye Dispersion and Sediment Sampling Study and the Phase IV RI to the Ecological
Technical Advisory Group (ETAG), which includes EPA ecological experts and natural resource trustees.
Based on this data, the ETAG concluded that ACW Site-related contamination in the PYC ditch sediment
may represent a potential continuing source of contamination to the bay if left unaddressed, recommending
that remedial action be taken to address contamination in the ditch.
7.3
Risk Summary
A 90th percentile excess lifetime cancer risk of 1.2x10-3 associated with ingestion and dermal exposure to
dioxins and cPAHs in surface soil by a trespasser on the ACW facility (Area I) exceeds EPA’s risk range.
With respect to non-carcinogenic health risks, the hazard indices associated with ingestion and dermal
exposure to dioxins and dibenzofurans on the ACW facility (Area I) and in the condominium block (Area
IV) exceed EPA’s threshold value of 1.0, indicating the need to consider remedial action. In addition,
sediment data suggests that Site-related contamination in the PYC ditch represents a potentially
unacceptable risk to both human and environmental receptors. In summary, actual or threatened releases
of hazardous substances from the ACW Site, if not addressed by EPA’s selected remedy, may present a
current or potential threat to public health and the environment.
8.0
Description of Alternatives
Following issuance of the 1989 ROD, EPA conducted additional feasibility study activities to identify and
evaluate remedial alternatives for addressing contaminated soil, sludge, and PYC ditch sediment. The
Feasibility Study Report for Operable Unit 2, published in November 1993, evaluated six alternatives for
addressing subsurface soil and solidified sludge, The Focused Feasibility Study (FFS) Report for the
Pensacola Yacht Club Drainage Ditch, published in August 1995, developed and evaluated four
alternatives for addressing sediment contamination in the PYC drainage ditch. The FFS assumed that any
sediment removed from the PYC ditch would be treated or disposed in the same manner that soil and
sludge from the ACW facility would be handled. Since the 1993 FS for OU2 only addressed subsurface
soil and solidified sludge and EPA had determined that the 1989 remedy for surface soil would have to be
amended, the FFS also included cost estimates for addressing all solid media (surface and subsurface soil,
solidified sludge, and sediment) under each of the alternatives developed in the 1993 FS. A description of
each alternative and the original remedy selected in the 1989 ROD are presented below.
8.1
Alternatives for Addressing Soil and Sludge
8.1.1
Remedy from the 1989 ROD
The 1989 ROD specifies excavation and treatment of contaminated surface soil (to a depth of 3 feet) using
solid phase, slurry phase, or in situ bioremediation. The most effective form of bioremediation is to be
determined through treatability tests. Treated soil is disposed onsite, and debris and the contents of drums
containing investigation-derived wastes are disposed off-site. The fence and existing cap are to be repaired.
The estimated capital costs of the 1989 remedy range from $1,956,000 to $2,928,000, depending upon
the bioremediation methodology selected. The net
2-17
present worth operation and maintenance costs would range from $319,000 to $330,000, resulting in a
total present worth cost ranging from $2,275,000 to $3,258,000.
8.1.2
Alternative SS1 - No Action
The National Contingency Plan (NCP) requires the development of a no action alternative as a basis for
comparison to other alternatives. Under the no action alternative, the Site is left “as is” and no funds are
expended for monitoring, control, or cleanup of the contaminated soil and sludge. The net present worth
cost of this alternative is $0.
With the exception of the remedy in the 1989 ROD and the No Action alternative, the following activities
are common to all of the remaining soil/sludge alternatives:
•
•
•
•
Demolish, decontaminate, and dispose process area foundations and debris in an appropriate
off-site landfill
Excavate contaminated soil from residential areas and the PYC property and consolidate this
material on the ACW facility
Regrade and revegetate the Site and install stormwater controls
Fence the Site and impose land-use restrictions
Conduct periodic Site mowing and maintenance
8.1.3
Alternative SS2 - Capping
•
Alternative SS2 involves construction of a multi-layer cap over the stabilized surface impoundments and
other contaminated areas of the facility in compliance with minimum technology requirements of the
Resource Conservation and Recovery Act (RCRA) for hazardous waste surface impoundments. Drainage
channels would be installed around the perimeter of the cap to manage stormwater runoff. Groundwater
monitoring in addition to that required as part of the groundwater remedy may be necessary to evaluate
whether contamination remaining in Site soil is leaching into the groundwater. Capital costs associated with
Alternative SS2 are $1,341,100. With an estimated annual O&M cost of $4,800, the net present worth
cost of this alternative over a 30 year period is $1,400,700.
8.1.4
Alternative SS3 - Slurry Biotreatment
Although similar to the remedy selected in the 1989 ROD, this alternative applies slurry phase biotreatment
to all of the contaminated solid media at the Site. After the soil and sludge are excavated, they are put
through grinders and screens to remove large clods. The stabilized sludge is then washed to reduce its
volume by segregating the finer, more contaminated soil particles. Contaminated soil is then mixed into a
slurry with water, nutrients (fertilizer), and oxygen to give the naturally-occurring bacteria in the soil the
things they need to destroy the contaminants. The soil is then dewatered and placed back into the
excavations, and process water is treated and discharged to Pensacola Bay or a publicly owned treatment
works (POTW). The capital costs associated with Alternative SS3 are $12,454,100. Annual O&M costs
are $4,800, for a net present worth cost over a 30 year period of $12,513,700.
2-18
8.1.5
Alternative SS4 - In-Situ Vitrification
This alternative involves the use of electric current passing through electrodes imbedded in the ground to
melt contaminated soil in place. The heat destroys soil contaminants, and, once cooled, the soil is a solid
glass-like monolith. Gases generated during the process are captured in a hood covering the treatment area
and are routed to an air emissions treatment system prior to discharge. The vitrification process results in
a 10 to 20 percent volume reduction, so clean soil may need to be imported to fill the resulting void. Capital
costs for Alternative SS4 are estimated to be $51,377,900. Annual O&M costs are estimated at $4,800,
for a 30 year net present worth cost of $51,437,500.
8.1.6
Alternative SS5 - Onsite Incineration
Alternative SS5 involves the use of incineration to destroy contaminants in the soil. Excavated soil is sorted
and screened to remove debris and then conveyed into the first chamber of the incinerator where
combustion of organic contaminants occurs at temperatures of 1,400 to 1,600EF. Vapors are then
destroyed in a secondary chamber at temperatures of 1,600 to 2,000EF. A proof of performance test is
required prior to full scale treatment to define appropriate operating parameters. Treated soil is then
disposed on the facility property. Capital costs for this alternative are estimated to be $71,818,600. Annual
O&M costs are estimated at $4,800, for a net present worth cost over a 30 year period of $71,878,200.
8.1.7
Alternative SS6 - Onsite Thermal Desorption
Thermal desorption involves heating contaminated soil to temperatures above the boiling points of the
contaminants (800 to 1,200EF) to physically separate them from the soil through volatilization. Desorption
usually takes place in a low-oxygen atmosphere so that little or no combustion of contaminants occurs.
Volatilized contaminants are then cooled to condense them to liquid form. A much smaller volume of liquid
contamination can then be shipped off-site for recycling or incineration, and treated soil is disposed on the
ACW facility. Although this closed system results in very few air emissions, appropriate air treatment
equipment would be in place to address any fugitive emissions. Estimated capital costs for this alternative
are $31,190,400. Annual O&M costs are estimated to be $4,800, for a net present worth cost over 30
years of $31,250,000.
8.2
PYC Ditch Sediment Alternatives
Since previous FS reports did not adequately address contaminated sediment in the PYC drainage ditch,
EPA conducted a Focused FS (FFS) to evaluate alternatives for the ditch. To address comments from the
Pensacola Yacht Club and FDEP, Alternative SD4 was modified from its original form in the FFS to
include excavation of all contaminated sediment exceeding the remedial goal (to a maximum depth of 3 ft.).
With the exception of Alternative SD1, the following activities are common to the remaining sediment
alternatives:
•
•
•
Clear and grub dense vegetation as needed along the ditch
Divert surface water flow during construction and/or dewater the ditch
Regrade and restore landscape to PYC specifications
2-19
8.2.1
Alternative SD1 - No Action
Under the no action alternative, the PYC ditch is left “as is” and no funds are expended for monitoring,
control, or cleanup of the contaminated sediment. The net present worth cost is $0.
8.2.2
Alternative SD2 - Total Sediment Removal
Under this alternative, all contaminated sediment exceeding the remedial goal (to an estimated maximum
depth of 3 ft.) is excavated and transported to the ACW facility for handling with contaminated soil and
sludge. Excavated areas of the ditch are backfilled with clean fill. The costs associated with this alternative
are all capital expenses, with an estimated present worth of $148,700.
8.2.3
Alternative SD3 - Partial Sediment Removal & Lining of Ditch
This alternative involves partial removal of the most contaminated sediment to a depth of about 1 ft.
Excavated sediment is transported to the ACW facility and addressed with contaminated soil and sludge,
and excavated areas of the ditch are backfilled with clean fill. The ditch is then lined with an appropriate
material such as concrete or an impermeable synthetic liner. Periodic maintenance of the liner and drainage
channel is required. Since contamination remains, land use restrictions are imposed to prevent inappropriate
development along the ditch. Capital costs associated with this alternative are $141,600, with annual O&M
costs of $3,600 associated with monthly inspection and maintenance of the ditch. The net present worth
of this alternative over a 30 year period is $186,300.
8.2.4
Alternative SD4 - Total Sediment Removal, Extend Culvert, and Backfill Ditch
Under this alternative, all contaminated sediment exceeding the remedial goal (to a maximum depth of 3
ft.) is excavated and transported to the ACW property for handling with contaminated soil and sludge. The
appropriate subgrade is then placed in the ditch, the City of Pensacola storm sewer culverts are extended
to Pensacola Bay, the necessary backfill and topsoil are placed over the culverts, and the area is
revegetated. Periodic maintenance of the storm sewer is needed to prevent Bay sediment from blocking
the discharge pipe. Capital costs for this alternative are $284,696, with annual O&M costs estimated to
be $1,000. The 30 year net present worth costs are $297,100.
9.0
Comparative Analysis of Alternatives
EPA has established nine criteria for use in assessing the relative advantages and disadvantages of each
alternative. The performance of each alternative (including the 1989 ROD remedy) relative to these criteria
and the other alternatives is discussed below. Soil and sludge alternatives are evaluated in Section 9.1, and
PYC ditch sediment alternatives are evaluated in Section 9.2.
2-20
9.1
Evaluation of Soil and Sludge Alternatives
9.1.1
Overall Protection of Human Health and the Environment
With the exception of Alternative SS1, all of the soil/sludge alternatives are protective of human health and
the environment by eliminating, reducing, or controlling risk through a combination of treatment, engineering
controls, and institutional controls. Though considered protective for surface soil, the 1989 remedy does
not address solidified sludge or subsurface soil, so additional measures developed in the other alternatives
would have to be added to address these media.
9.1.2
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
All alternatives except SS1 can be designed to comply with all Federal and State applicable or relevant and
appropriate requirements (ARARs). Alternative SS1 does nothing to reduce risks to within EPA’s
acceptable risk range or prevent soil and sludge from leaching contamination into the groundwater.
Additional components must be added to the original 1989 remedy to prevent contaminant leaching into
the groundwater.
Because Alternative 1 does not meet the threshold criteria of protection of human health and the
environment and compliance with ARARs, this alternative will be dropped from further consideration. In
addition, since the original 1989 remedy only addresses surface soil, the merits of applying bioremediation
to subsurface soil and sludge at the Site will be addressed under Alternative SS3.
9.1.3
Short Term Effectiveness
Alternatives SS2 and SS4 are expected to have the best short-term effectiveness since very little handling
of contaminated materials is necessary. For Alternative SS2, cap construction could be completed in a
relatively short time-frame. Although large amounts of clean fill materials for cap construction would have
to be brought to the Site in trucks, this traffic could be routed to avoid residential areas. Alternative SS4
would be conducted in-situ, but careful monitoring and management of off-gases would be required during
treatment. Alternatives SS3, SS5, and SS6 are expected to have similar short-term impacts associated with
the excavation and handling of contaminated materials, such as dust and vapor generation and physical
construction hazards.
9.1.4
Long Term Effectiveness and Permanence
Alternatives SS4, SS5, and SS6 are all thermal treatment remedies which result in the destruction of
contaminants, thereby affording the greatest degree of long-term effectiveness. Alternative SS2 serves to
contain the contaminated materials under a cap, thereby eliminating the potential for exposure and reducing
the leaching of contamination into the groundwater. However, perpetual maintenance and repair of the cap
will be necessary to maintain the long-term effectiveness of this remedy. The results of Site-specific
treatability studies have indicated that Alternative SS3 would have limited effectiveness in addressing
principal Site contaminants.
2-21
9.1.5
Reduction of Mobility, Toxicity, or Volume through Treatment
Alternative SS4 not only provides a significant reduction in contaminant volume, but it also results in a 10
to 20 percent reduction in the volume of the contaminated media. Alternatives SS4, SS5, and SS6 provide
the greatest reduction of toxicity and mobility by destroying contaminants through thermal treatment of
contaminated materials. Although bioremediation under Alternative SS3 would destroy some contaminants,
treatability tests have shown that the effectiveness of biotreatment is limited for addressing principal Site
contaminants (cPAHs, PCP, and dioxin). Alternative SS2 is expected to reduce mobility by preventing
rainfall infiltration, thereby reducing the potential for further contaminant leaching into the groundwater. This
alternative would have no effect on toxicity or volume.
9.1.6
Implementability
Alternative SS2 is the most easily implemented alternative because it involves standard, widely available
construction services. Alternatives SS5 and SS6 involve thermal treatment technologies which are
commercially available. As presented, both would require excavation and handling of contaminated
materials, although thermal desorption is now available as an in-situ technology. Both would also require
a proof of performance (POP) test prior to full-scale operation. Alternative SS6 may have limited
effectiveness in addressing the former lagoon sludge because the stabilizing agents may tend to bind
contaminants within the stabilized matrix. Alternative SS4 requires minimal waste handling, but commercial
availability is limited. Bioremediation under Alternative SS3 is commercially available, but extensive
excavation, segregation, and mixing of the waste materials prior to treatment is required, and treatability
test results suggest that additional treatment would be necessary. For all of the alternatives, care will have
to be taken to safeguard the existing DNAPL recovery wells and treatment system on the west end of the
ACW facility.
9.1.7
Cost Effectiveness
Alternative SS2 is the lowest cost alternative that is protective of human health and the environment.
Although Alternative SS3 has the next lowest cost, it is not expected to be effective in reducing contaminant
levels to health-protective levels, Therefore, Alternative SS6 is the next most cost-effective alternative,
providing a greater degree of long-term effectiveness than capping, but at a significantly higher (20-fold)
cost. Alternatives SS5 and SS4 provide a degree of long-term effectiveness similar to SS6 at a much
greater cost.
9.1.8
State Acceptance
As the support agency, FDEP has been actively involved in the development and issuance of the Proposed
Plan and this AROD. Based upon FDEP’s comments to date, EPA expects that concurrence on the
remedy selected in this AROD will be forthcoming, although a formal concurrence letter has not yet been
received. Because the 1 ppb residential surface soil remedial goal for dioxin is subject to review and
possible revision once EPA’s Final Dioxin Reassessment effort is
2-22
complete, EPA and FDEP have agreed to designate the residential cleanup effort as an interim action. This
approach allows the Agencies to achieve significant risk reduction immediately rather than deferring action
at the Site while EPA completes the dioxin reassessment.
9.1.9
Community Acceptance
EPA published a Proposed Plan Fact Sheet in April 1998 outlining the alternatives EPA considered and
identifying EPA’s preferred alternative for addressing soil, sludge, and sediment contamination at the Site.
A public meeting was held on May 14, 1998, to explain the alternatives EPA considered and to receive
oral comments on the Proposed Plan. A copy of the transcript from this meeting is included in the
Administrative Record for the Site, and any significant comments have been addressed in the
Responsiveness Summary section of this AROD. In addition, EPA held a 60-day comment period from
May 1, 1998 through July 1, 1998, during which numerous written comments were received. Community
comments focused primarily on the adequacy of EPA’s residential sampling activities and the proposed
remedy for the PYC ditch.
9.2
Evaluation of PYC Ditch Sediment Alternatives
9.2.1
Overall Protection of Human Health and the Environment
With the exception of Alternative SD1, all of the sediment alternatives are protective of human health and
the environment by eliminating, reducing, or controlling risk through a combination of removal, containment,
engineering controls, and institutional controls.
9.2.2
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
Although there are no promulgated Federal or State cleanup levels for sediment, EPA has developed a
Site-specific risk-based standard for sediment in the PYC ditch. However, all alternatives can be designed
to comply with Federal and State requirements associated with dredging and filling in a wetland. Alternative
SD1 does not trigger wetlands ARARs, and Alternative SD2 results in the least impact to potential
wetlands of the “action” alternatives. The design of the stormwater outfall in Alternative SD4 would comply
with appropriate State regulations and the NPDES requirements under the Clean Water Act.
Because Alternative SD1 does not comply with one or more of the threshold criteria, this alternative will
be dropped from further consideration.
9.2.3
Short-Term Effectiveness
Alternatives SD2, SD3, and SD4 would all require the transport of contaminated sediment through the
community from the Yacht Club to the ACW facility, generating some traffic congestion along Land
Cypress Streets. Construction activities at the Yacht Club could produce nuisance noise levels and impede
access to the little-used eastern portions of the Yacht Club property.
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9.2.4
Long-Term Effectiveness and Permanence
Alternative SD2 and SD4 provide the greatest degree of long-term effectiveness by removal of all
contaminated sediment. Although groundwater may re-contaminate sediment as it discharges into the ditch
under Alternative SD2, EPA’s groundwater remedy is expected to eliminate this problem in the long-term.
The City has identified the need for periodic maintenance to clean out the culverts under Alternative SD4.
Alternative SD3 involves removal of the most heavily contaminated sediment and lining of the ditch. Regular
maintenance of the liner under Alternative SD3 would be critical to ensuring the long-term effectiveness of
this alternative.
9.2.5
Reduction of Toxicity, Mobility or Volume through Treatment
Alternatives SD2 and SD34 provide the greatest reduction of toxicity, mobility, and volume through removal
of all contaminated sediment. Alternative SD3 provides a lesser degree of reduction by removal of the most
contaminated sediment and lining of the ditch to prevent further movement of contaminants between the
groundwater and the ditch.
9.2.6
Implementability
All alternatives utilize standard construction methods which are widely available. Alternative SD2 represents
the least complex alternative. The administrative feasibility of Alternative SD4 is more complex in that it
requires careful coordination with local, State, and Federal authorities to extend the storm sewer to
Pensacola Bay and backfill the ditch.
9.2.7
Cost Effectiveness
Alternative SD32 is the lowest cost alternative that is protective of human health and the environment.
Based on information received during the comment period, maintenance requirements associated with
Alternative SD4 no longer make it a more attractive long-term solution than Alternatives SD2 and SD3 as
stated in the Proposed Plan.
9.2.8
State Acceptance
Based upon discussions with FDEP concerning comments received during the comment period favorable
toward Alternative SD2, FDEP supports Alternative SD2 as the selected remedy for sediment
contamination in the PYC ditch.
9.2.9
Community Acceptance
EPA received a number of comments from the Pensacola Yacht Club, the Bayou Chico Association, the
City of Pensacola, and others identifying specific concerns about the implementation of the various
alternatives for sediment. These comments reflected a preference for Alternative SD2, and they have been
addressed in the Responsiveness Summary, which is included as Part 3 of this AROD.
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10.0
Selected Remedy
Based upon consideration of the requirements of CERCLA, the NCP, the detailed analysis of the
alternatives using the nine criteria, and State and public comments, EPA has determined that a combination
of Alternative SS2 and Alternative SD2 is the most appropriate amended remedy for addressing soil,
sludge, and sediment contamination at the ACW Site in Pensacola, Florida.
10.1
Components of the Selected Remedy
The selected remedy involves the construction of a RCRA cap and surface drainage controls. A conceptual
layout of the RCRA cap and drainage features are shown on Figure 4. Future uses of the property would
also be limited by the application of deed restrictions. Since EPA retains a 50% interest in the ACW
property through a bankruptcy settlement, EPA would secure an agreement with any prospective purchaser
identifying appropriate land use restrictions and maintenance requirements.
A low permeability cap which meets Resource Conservation and Recovery Act (RCRA) closure
requirements under 40 CFR 264.228(a)(2)(iii) shall be constructed over the stabilized material in the former
surface impoundments, consolidated materials from other areas within the AOC, and other contaminated
areas of the ACW facility. The cover system shall be designed and constructed to achieve the following
criteria:
•
•
•
•
Provide long-term minimization of the migration of liquids through the contained area;
Function with minimum maintenance;
Promote drainage and minimize erosion or abrasion of the final cover; and
Accommodate settling and subsidence so that the cover’s integrity is maintained.
In addition to minimizing the infiltration of rainwater into the containment area, the cap also eliminates the
potential for direct contact by humans and fauna with contaminated soil at the ACW facility. In order to
reduce the height of the cap, the U.S. Army Corps of Engineers has developed the low-profile cap design
shown in Figure 5. The cap consists of the following layers: a composite layer consisting of clay and
geosynthetic sandwiched between two 40 mil geomembranes; a 12 inch layer of random fill; a 12 inch layer
of sand for drainage; a geotextile fabric over the drainage layer to prevent clogging; an 18 inch layer of
random fill; and a 6 inch layer of topsoil. The final (topsoil) layer of the cap would be graded to a minimum
slope of 1 percent and a maximum of 5 percent based on the current Site topography. Some grading of the
contaminated soil and solidified sludge may be required to achieve these slopes. A vegetative cover of
native grass would be established to minimize cap erosion. To accommodate potential future uses of the
property, facilitate the addition of extraction wells for the groundwater remedy, and reduce the height of
the cap, alternative cap designs which can provide equivalent functional performance will also be
considered during the Remedial Design. The cap is expected to extend onto privately-owned property
adjacent to the southwest corner of the ACW property which was heavily contaminated by historical
discharges from the former lagoons. In order to effect the construction of the cap, EPA will need to address
appropriately the long-term status of this parcel.
2-25
Figure 4. Conceptual Layout of Surface Cap and Drainage Features
2-26
Figure 5. Typical Cross Section of Low-Profile Surface Cap
2-27
Surface drainage controls including drainage ditches and a stormwater retention pond will be constructed
to manage runoff from the Site. The retention pond will be located on the east end of the ACW property,
and improvements to the City of Pensacola storm sewer system will likely have to be constructed to
provide adequate capacity to route the water to Pensacola Bay.
Because the contaminated soil could potentially act as a source of groundwater contamination as the
groundwater level rises and subsides, Alternative SS2 includes periodic groundwater monitoring for an
assumed period of 30 years. Periodic maintenance of the RCRA cap and surface drainage channels will
also be required during this period.
To address contamination in the PYC drainage ditch, sediment from the ditch which exceeds the remedial
goal for sediment (to a maximum depth of 3 feet) will be excavated and transported to the ACW property
for disposal beneath the surface cap. Confirmation samples will be collected from the excavated area to
determine if the remedial goal has been met. Prior to dredging of the ditch, clearing and grubbing of
vegetation and dewatering of the ditch may be necessary to facilitate the removal of contaminated sediment.
A pump may be needed to temporarily redirect stormwater from the City storm sewer to Chico Bayou.
The ditch excavation will then be backfilled with clean soil, regraded to approximate its original profile, and
revegetated. The banks of the ditch will be stabilized using degradable netting until thick vegetative cover
is established. Permanent rip-rap dams or other features may be placed at intervals in the bottom of the
ditch to reduce flow energy and erosion. The proposed area of remediation is estimated to be a
25-foot-wide area along the 900-foot length of the ditch.
The City of Pensacola has a tree ordinance which regulates the damage or removal of protected tree
species which exceed a certain diameter. EPA will coordinate the clearing of the ACW property and the
PYC ditch area with the City to ensure compliance with this local ordinance to the maximum extent
practicable. Since groundwater which may discharge into the ditch is not expected to reach EPA remedial
goals for several years, periodic sampling of the ditch sediment will be conducted pursuant to a Site-specific
operation and maintenance plan.
Clearing, dredging, and backfilling the PYC drainage ditch are activities which may constitute a discharge
of dredged and fill material into waters of the United States, which is regulated by Section 404 of the Clean
Water Act (CWA), 33 U.S.C. Section 1344. The requirements of CWA Section 404 and the associated
Section 404(b)(1) Guidelines at 40 CFR Part 230 are therefore applicable to the implementation of these
activities. Nationwide Permit 38 applies to cleanup of hazardous and toxic wastes in wetlands, but does
not apply to activities undertaken entirely on a CERCLA site as required by EPA. Accordingly,
Nationwide Permit 38 is not applicable here. However, the General Conditions of this nationwide permit
are relevant and appropriate requirements, and the remedy must meet the substantive requirements of
CWA Section 404 and the Section 404(b)(1) Guidelines. The Guidelines require a hierarchical approach
to mitigation measures which includes impact avoidance, impact minimization, and compensatory mitigation.
Compliance with this three step process with respect to the selected remedy for the ACW Site is evaluated
below:
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Impact Avoidance
The Section 404(b)(1) Guidelines require EPA to avoid any direct or indirect impacts to wetlands if there
is a practicable alternative to the proposed discharge that would have less adverse impact to the aquatic
ecosystem, as long as the alternative does not have other significant adverse environmental consequences.
EPA has determined that the selected remedy may have a direct adverse impact on an estimated 0.5 acre
of wetland area along the length of the PYC drainage ditch. Dredging and restoring the ditch could change
the surface water and groundwater hydrology temporarily.
EPA has determined that contamination from the Site has impacted the wetland area associated with the
PYC ditch. Both routine and storm-related releases of contaminated waste material from the former
lagoons on the ACW facility have resulted in sediment contamination in the PYC ditch. In addition,
contaminated groundwater resulting from the Site is potentially discharging into the ditch. EPA’s Dye
Dispersion and Sediment Sampling Study and the FFS document that taking no action to address
contaminated sediment in the PYC ditch would not be protective of human health and the environment,
potentially allowing continuing contamination of Pensacola Bay and Bayou Chico. Therefore, EPA has
determined that no practicable alternative to the selected remedy exists that would have less impact to the
aquatic ecosystem without significant adverse environmental consequences.
Impact Minimization
If a discharge cannot be avoided, the Guidelines at 40 CFR Part 230.10(d) require that all appropriate and
practicable steps be taken to minimize potential adverse impacts of the discharge on the aquatic ecosystem.
Subpart H of 40 CFR Part 230 sets forth the steps which can be taken to minimize the effects of fill
activities. Section 230.75(d) states that habitat development and restoration techniques may be used to
minimize adverse impacts and to compensate for destroyed habitat. The selected remedy involves removing
contaminated sediment and restoring the ditch as closely as possible to its original condition and function.
This alternative results in the least adverse impact to the ditch among the alternatives considered. Therefore,
EPA believes that adverse impact has been minimized to the extent practicable.
Compensatory Mitigation
Appropriate and practicable compensatory mitigation may be required for unavoidable adverse impacts
which remain after all appropriate and practicable minimization has been attained. The “Memorandum of
Agreement between the U.S. Army Corps of Engineers and the EPA Concerning the Determination of
Mitigation Under the 404(b)(1) Guidelines” (MOA) states that mitigation includes wetland restoration,
enhancement, and/or creation. The evaluation of the appropriate level of mitigation
2-29
requires a case-specific determination and is based solely on the values and functions of the
wetland that is impacted. According to the MOA, mitigation should provide at a minimum one
for one functional replacement with an adequate margin of safety to reflect the expected degree
of success associated with the mitigation plan. Better characterization of the wetlands (including
a functional assessment and delineation) are necessary before specific mitigation actions can
be identified. Therefore, a wetlands delineation and function assessment shall be conducted
during the RD. EPA believes that the removal of contaminated sediment and the restoration of
the ditch represent a one for one functional replacement of any potentially impacted wetland.
Based upon comments received during the public meeting, additional soil sampling was conducted in
specific residential areas prior to issuance of this AROD. First, high PAH levels were detected in a vacant
lot in the 1700 block of West Sonia Street without a plausible route of migration from the ACW facility.
EPA collected surface soil samples from this property and determined that the high PAH levels were not
Site related, but were linked to the use of creosote treated blocks in the construction of a walkway for a
residence that formerly stood on the property. This property has therefore been dropped from EPA’s
remediation plans. Another residential property southeast of the ACW facility exceeded the Site residential
surface soil remedial goals. Although the migration of Site-related contamination to this property along the
railroad right-of-way may have been possible, EPA believes an interview with the site owner and additional
soil sampling is needed before this property is excavated. If additional information collected during design
confirms the theory that the property was contaminated by the ACW Site, then excavation will proceed.
Otherwise, the property will be dropped from the remediation plan. At the request of FDEP, limited surface
soil sampling will be conducted during design in commercial areas north and west of the ACW property
to evaluate compliance with remedial goals.
In addition, during the public meeting, residents requested that the extent of subsurface soil contamination
near the facility be further evaluated in the city block between L and K Streets north of Cypress. To that
end, EPA tasked the U.S. Army Corps of Engineers to collect subsurface samples in this area. The report
on this investigation was not available before issuance of this AROD, but will be considered during design
to further define the AOC requiring remediation.
As part of the Remedial Action activities for Operable Unit 2, EPA’s contractor repaired the existing 6-foot
chain link fence and extended it to encompass the entire perimeter of the ACW property. During
construction of the OU1 remedy, it may be necessary to temporarily remove portions of the fence, but the
fence will be restored, repaired, or replaced as necessary following construction. Warning signs and
placards are currently posted at 100-foot intervals along the perimeter of the fence in accordance with
Florida regulation FAC 62-730.181(3), Warning Signs at Contaminated Sites.
The net present worth cost of the selected remedy is $1,560,500. A detailed breakdown of these
costs is shown in Table 4.
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Table 4
COST ESTIMATE - Alternative SS2 - RCRA CAP
Item
Quantity
Mobilization/Demobilization
Unit
Cost($)
Units
Capital
Cost($)
1
LS
10,000.00
10,000
13
acre
5,150.00
67,000
Annual
Cost($/Yr)
Site Prep
Clearing, grubbing, removal
Fencing
Debris Removal/Disposal
3,600
ft
5.65
20,300
2,525
cy
52.27
132,000
Drum Removal/Disposal
Personal Protective Equipment
10
drums
148.40
1,500
Empty Drums (Nonhazardous)
90.00
drums
44.59
4,000
acre
500.00
6,500
Preliminary Grading
30 mil HDPE Liner (installed)
13
450,600
sf
0.40
180,200
Clay (compacted/installed)
30,000
cy
6.00
180,000
Geotextile & Drainage Net
450,600
sf
0.50
225,300
Top soil (grading)
30,000
cy
4.00
120,000
Hydro seeding
23,400
sy
0.40
9,400
1
LS
2,000.00
2,000
Maintenance Mowing
12
Events/Yr
300.00
3,600
Security
12
Visits/Yr
100.00
1,200
Deed Restriction
Subtotal
958,200
Bid Contingencies (10%)
95,800
Scope Contingencies (10%)
95,800
Construction Total
4,800
1,149,800
Permitting and Legal (3%)
34,500
Construction Services (5%)
57,500
Total Implementation
1,241,800
Engineering Design (8%)
99,300
Total Capital
1,341,100
Total Annual
4,800
Present Worth (30 years of operation)*
1,400,700
*7% APR
All costs rounded to the nearest $100
2-31
Table 4 (continued)
COST ESTIMATE - Alternative SD2
Item
Quant
ity
Mobilization/Demobilization
1
Clear, Grub, and Remove
2
Install Security Fencing
2550
Unit Cost
($)
Capital Cost
($)
LS
$3,500.00
$3,500
Acres
$5,150.00
$10,300
$5.65
$14,408
$18,500.00
$18,500
Units
LF
Annual
Cost ($/Yr)
Dewater Ditch
Flow Rerouting Pump
1
Pump
Flow Rerouting Piping
930
LF
$4.10
$3,815
Wellpoints (dewatering in 100 ft. sections for 1
month)
100
LF
$415.00
$41,500
Dredge ditch to maximum of 3 ft. depth
2490
CY
$2.25
$5,603
Transport sediments to ACW property
2490
CY
$3.25
$8,093
$315.00
$2,835
Remove/Transport Sediments
Confirmation sample analysis (EPA Method 8270)
9
samples
Backfill excavation and regrade to original profile
2490
CY
$6.30
$15,687
Hydro seeding
1000
SY
$0.25
$250
Inspection and Maintenance
2
Subtotal
Visits/yr
$500.00
$1,000
$124,489
Bid Contingencies (5%)
$6,224
Scope Contingencies (5%)
$6,224
Construction Total
$1,000
$136,937
Permitting and Legal (1%)
$1,369
Construction Services (1.%)
$2,054
Total Implementation
$140,360
Engineering Design (5%)
$7,018
Total Capital
$147,378
Total Annual
$1,000
Present Worth (30 years of operation @ 7%
discount)
$159,787
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10.2
Performance Standards
The purpose of this response action is to control risks posed by ingestion, inhalation, and direct contact with
soil, sludge, and sediment contamination through a combination of excavation, treatment, and containment.
All contaminated soil, sludge, and sediment which has been identified as exceeding the respective remedial
goals in Table 2 will be consolidated and isolated beneath the cap on the ACW property, thereby
eliminating the risk associated with direct contact, ingestion, or inhalation. Confirmation sampling will be
conducted following excavation to confirm that the remaining soil or sediment does not exceed the relevant
remedial goal.
The low permeability layer of the surface cap shall achieve a maximum in-place saturated hydraulic
conductivity of 1x10-7 cm/sec. The drainage layer shall achieve a minimum hydraulic conductivity of 1x10-2
cm/sec.
11.0
Statutory Determinations
Pursuant to CERCLA Section 121, EPA must select remedies that are protective of human health and the
environment, comply with applicable or relevant and appropriate requirements, are cost-effective, and
utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the
maximum extent practicable. In addition, CERCLA includes a preference for remedies that employ
treatment that permanently and significantly reduces the volume, toxicity, or mobility of hazardous
substances as their principal element. The following sections discuss how the selected remedy meets these
statutory requirements.
11.1
Overall Protection of Human Health and the Environment
The selected remedy satisfies the statutory requirement to be protective of human health and the
environment. The potential human health and ecological risks associated with direct contact, ingestion, and
inhalation of contaminated soil, sediment, and sludge are reduced eliminated through the consolidation and
isolation of these media within the containment system.
11.2
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
The selected remedy satisfies the statutory requirement to comply with all applicable or relevant and
appropriate Federal and State ARARs. EPA has consulted with FDEP, and no other promulgated State
requirements which are more stringent than the Federal requirements listed below have been identified. The
ARARs which apply to the selected remedy and other non-enforceable guidance and criteria which are “to
be considered” (TBC) are presented below:
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Federal ARARs
Resource Conservation and Recovery Act (RCRA)
•
40 CFR Part 264.228. RCRA requirements for the closure of surface impoundments are relevant
and appropriate to the capping of the former sludge lagoons and other portions of the Site. This
includes by reference the requirements for closure and post-closure care in 40 CFR 264 Subpart
G.
Clean Water Act (CWA)
•
The substantive requirements of Section 404 of the Clean Water Act (CWA), 33 U.S.C. Section
1344, the Section 404(b)(1) Guidelines, 40 CFR Part 230, and Nationwide Permit 38, may be
relevant and appropriate to the dredging and restoration of the PYC drainage ditch.
•
40 CFR Part 403. Requirements under the National Pollutant Discharge Elimination System
(NPDES) program are applicable to the discharge of stormwater from the Site to Pensacola Bay.
State ARARs
•
Regulation of Stormwater Discharge, FAC 62-25.025, 62-25.027, 62-25.040. Substantive
requirements for the design, construction, and operation and maintenance of stormwater discharge
facilities are applicable for stormwater management features at the Site.
•
Surface Water Quality Criteria, FAC 62-302.530. Florida surface water quality criteria are
applicable for the treatment and discharge of groundwater and surface water associated with the
dewatering activities in the PYC drainage ditch.
•
Florida Rules on Hazardous Waste Warning Signs, FAC 62-730.181(3). Requirements for the
design, location, and spacing of warning signs are applicable to the posting of signs around the
perimeter and at entrances of the Site.
To Be Considered
•
Technical Guidance Document: Final Covers on Hazardous Waste Landfills and Surface
Impoundments, EPA/530-SW-89-047. Guidelines for the design of final covers for surface
impoundments shall be considered in the development in the surface cap for the Site.
•
Considering Wetlands at CERCLA Sites, EPA/540/R-94/019.
2-34
11.3
Cost Effectiveness
The selected remedy meets the statutory criteria of being cost effective. Alternative SS2 is the least
expensive alternative which meets the threshold criteria. Although treatment alternatives are available which
would provide a greater degree of long-term permanence and a greater reduction in the toxicity, mobility,
or volume, the selected remedy provides an equivalent level of public health protection at less than 5% of
the cost of the next lowest cost alternative. Alternative SD2 is the most protective and least expensive of
the sediment alternatives. It minimizes the adverse impact to the potential wetlands associated with the
ditch, ultimately resulting in a one for one functional replacement of the impacted wetland. After considering
community comments on the preferred alternative from the Proposed Plan (Alternative SD4), EPA agrees
that Alternative SD2 offers additional treatment of storm water before it enters Pensacola Bay and will
actually minimize maintenance costs by eliminating the need to clean out sediment accumulation at the point
where the culverts would have entered the Bay.
11.4
Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
EPA has determined that the selected remedy represents the maximum extent to which permanent solutions
and treatment technologies can be utilized in a cost-effective manner for the Site. Of those alternatives that
are protective of human health and the environment and comply with ARARs, EPA has determined that
the selected remedy provides the best balance of trade-offs in terms of long-term effectiveness and
permanence, reduction in toxicity, mobility, or volume through treatment, short-term effectiveness,
implementability, and cost.
The selected remedy for soil and sludge ranks the highest against the other alternatives with respect to the
criteria of short-term effectiveness, implementability, and cost. While the thermal treatment technologies
associated with Alternatives SS4, SS5, and SS6 provide the greatest degree of treatment, their
implementation costs range from 20 to 50 times more than the selected remedy for a similar reduction in
risk. Although Alternative SS3 provides a much lower cost for treatment, treatability tests have
demonstrated that this technology would not be effective in addressing the wastes at the Site. The selected
remedy is easily implemented using conventional construction methods, and by limiting the amount of waste
disturbed, it minimizes the short-term impacts to workers and the public during implementation.
Because the ACW Site was listed on the NPL in 1983 and this AROD represents the third attempt in
selecting a remedy for source control at the Site, EPA believes that community sentiment runs against the
selection of an innovative technology or other type of treatment alternative requiring extensive treatability
or performance testing which could slow actual implementation. For this reason, Alternative SS2 offers a
cost effective remedy which can be designed and constructed without the prospect of delay or failure due
to treatability or implementation problems.
2-35
11.5
Preference for Treatment as a Principal Element
EPA has already addressed the principal threat wastes at the Site through previously irnplemented or
ongoing response actions. During the removal actions in 1983 and 1984, EPA addressed the principal
threat wastes of wastewater and bottom sludge in the onsite lagoons by draining and treating the
wastewater and stabilizing the bottom sludge through treatment with lime and fly ash. More recently,
pursuant to the ROD for Operable Unit 2, EPA is actively addressing another principal threat waste by
extracting DNAPL from the subsurface and recycling it off-site.
EPA has determined that the remaining wastes being addressed by the response action in this AROD do
not constitute principal threat wastes. EPA believes that those wastes which are liquids or represent mobile
or highly toxic source material have been appropriately addressed through previous or ongoing response
actions. Therefore, this remedy utilizes a combination of engineering and institutional controls to address
the remaining low level threat wastes at the Site.
Because treatment of the principal threats at the Site have been accomplished through previous response
actions and the recalcitrant nature of contaminants and the anticipated volume of source materials (over
80,000 cubic yards) render cost-effective treatment of these wastes impracticable, further treatment was
not found to be feasible. Thus, although the remedy in this OU does not satisfy the statutory preference for
treatment as a principal element of the remedy, EPA considers that on the whole, treatment technologies
have been utilized in all of the response actions taken at the Site to the maximum extent practicable.
12.0
Documentation of Significant Changes
The Proposed Plan for the ACW Site was released for public comment in April 1998, identifying a
combination of Alternatives SS2 and SD4 as the preferred alternative for the amended remedy. Whereas
Alternative SD4 called for removal of contaminated sediment from the PYC ditch and installation of
culverts to replace the storm water management function of the ditch, Alternative SD2, also presented in
the Proposed Plan, called for excavation of contaminated sediment and restoration of the PYC ditch to its
original condition. Comments received during the public comment period from the City of Pensacola Office
of the Engineer identified long-term maintenance concerns associated with sediment buildup in the culvert
outfall in Pensacola Bay. In addition, the City, PYC, the Bayou Chico Association, and the National
Oceanic and Atmospheric Administration indicated that backfilling the ditch eliminated an important
treatment function of the existing ditch in allowing sediment in storm water to settle out before reaching the
Bay. Therefore, EPA, in consultation with FDEP, decided to select Alternative SD2 for addressing the
PYC ditch.
In addition, based on surface soil sampling results following the Proposed Plan, EPA has eliminated the
residential property located in the 1700 block of West Sonia Street from the AOC requiring remediation.
Discussions with the owner and recent sampling data suggest that the high PAH levels encountered in this
location are not Site-related, but are associated with partially buried creosote-treated blocks used in a
former walkway.
2-36
The Proposed Plan identified a remedial goal for carcinogenic PACs in PYC ditch sediment of 1.6 mg/kg
based on the most likely exposure scenario of an adolescent trespasser (age 7 to 16) playing in the ditch.
However, following issuance of the Proposed Plan and during development of this AROD, FDEP
requested that their Sediment Quality Assessment Guidelines Toxic Effect Levels (TEL) be considered in
the development of a remedial goal for sediment. Based on these guidelines, EPA has established a
remedial goal for the PYC ditch sediment of 0.655 mg/kg for carcinogenic PAHs.
13.0
Documentation of Five-Year Remedy Review for OU1
The 1989 ROD indicates that a review would be conducted within five years after commencement of
remedial action to ensure that the remedy continues to provide adequate protection of human health and
the environment. In August 1990, EPA issued an Explanation of Significant Difference Fact Sheet
identifying several additional cleanup activities not specifically addressed in the 1989 ROD. These tasks
included site preparation, fence repair, drum sampling, analysis, and disposal, demolition of buildings and
removal of debris, well closure, cap repair, and revegetation. The initiation of construction of these
additional site preparation tasks in February 1991 by EPA’s contractor, Roy F. Weston, Inc., technically
triggered the need to conduct a Five-Year Review. The field work was completed in May 1991, and the
remedial action was documented in Weston’s Remedial Action Report dated September 19, 1991. EPA
accepted the work on September 25, 1991.
Since the bulk of the remedy identified in the 1989 ROD was never completed and this ROD Amendment
for OU1 has been planned since 1993, EPA has not conducted a formal Five-Year Review. However,
EPA believes that the analysis in this AROD adequately addresses the scope and conclusions of a
Five-Year Review Report. This analysis concludes that the remedy selected in the 1989 ROD is not
protective, since the selected technology is not capable of achieving the remedial goals for the Site.
Therefore, this AROD identifies and selects an amended remedy which is protective of human health and
the environment.
2-37
American Creosote Works
Pensacola, Escambia County, Florida
3. RESPONSIVENESS SUMMARY
In accordance with Sections 113 and 117 of CERCLA, as amended, EPA has conducted community
involvement activities at the ACW Site to solicit community input and ensure that the public remains
informed about Site activities. EPA’s Proposed Plan Fact Sheet for the Record or Decision (ROD)
amendment was mailed to the public on April 28, 1998, and a copy of the Administrative Record was
made available in the information repository at the West Florida Regional Library in downtown Pensacola.
A public notice was published in the Pensacola News Journal in Pensacola, Florida, on April 30, 1998,
advising the public of the availability of the Administrative Record and the date of the upcoming public
meeting. EPA held a public meeting on May 14, 1998, at the Sanders Beach Community Center to answer
questions and receive comments on the Agency’s preferred alternative for addressing soil, sludge, and
sediment contamination from the Site. Comments received during the public meeting were recorded in an
official transcript of the meeting, a copy of which is included in the Administrative Record. Initially, a public
comment period was scheduled from May 1 through June 1, 1998. However, at the request of the Bayou
Chico Association, the Technical Assistance Grant (TAG) recipient for the Site, EPA granted a 30-day
extension to the comment period through July 1, 1998. EPA published a public notice announcing the
comment period extension in the Pensacola News Journal on June 6, 1998.
In conjunction with the Remedial Action activities for Operable Unit 2, EPA revised the Community
Relations Plan for the Site in July 1998. This effort involved conducting additional community interviews
and updating the Site mailing list.
This Responsiveness Summary provides information about the views of the community and other interested
parties regarding EPA’s proposed action, documents how the Agency has considered public comments
during the decision-making process, and provides answers to major comments received during the
comment period. It consists of the following sections:
1.0
Overview: This section discusses the recommended action for the Site and the public
reaction to this alternative.
2.0
Background on Community Involvement: This section provides a brief history of
community interest in the Site and identifies key public issues.
3.0
Summary of Comments Received and EPA’s Responses: This section provides EPA’s
responses to oral and written comments submitted during the pubic comment period.
4.0
RD/RA Concerns: This section discusses community concerns raised during the comment
period regarding ongoing remedial action activities at the Site.
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1.0
Overview
The Proposed Plan for the ACW Site was released for public comment in April 1998, identifying a
combination of Alternatives SS2 and SD4 as the preferred alternative for the amended remedy. Whereas
Alternative SD4 called for removal of contaminated sediment from the PYC ditch and installation of
culverts to replace the storm water management function of the ditch, Alternative SD2, also presented in
the Proposed Plan, called for excavation of contaminated sediment and restoration of the PYC ditch to its
original condition. Comments received during the public comment period from the City of Pensacola Office
of the Engineer identified long-term maintenance concerns associated with sediment buildup in the culvert
outfall in Pensacola Bay. In addition, the City, PYC, the Bayou Chico Association, and the National
Oceanic and Atmospheric Administration indicated that backfilling the ditch eliminated an important
treatment function of the existing ditch in allowing sediment in storm water to settle out before reaching the
Bay. Therefore, EPA, in consultation with FDEP, decided to select Alternative SD2 for addressing the
PYC ditch.
Numerous comments were received during the comment period and the public meeting. The primary
concerns raised by residents related to the adequacy of the residential soil sampling program and the
preferred alternative for the PYC ditch sediment.
2.0
Background on Community Involvement
EPA’s earliest community outreach effort was a press release related to the emergency removal activities
in 1983. Periodic fact sheets were issued during 1984 and 1985 to update the community concerning
studies being conducted at the site. In September 1985, EPA issued fact sheets and press releases
announcing a public meeting and comment period related to the proposed plan for addressing source
contamination at the site. Similarly, in 1989, EPA issued a fact sheet and held a public meeting to discuss
the revised source control remedy. In 1990, EPA prepared an Explanation of Significant Differences (ESD)
notifying the public of additional tasks that would be necessary to implement the 1989 ROD. Later, in
March 1991, a fact sheet was published to advise the public of the initiation of these site preparation
activities which included cap repair, drum characterization, fence repairs, well closure, and building
demolition.
EPA conducted a door-to-door survey in September 1993 in the neighborhood surrounding the site to
update its mailing list. EPA’s Proposed Plan for Operable Unit 2 was sent to the public in November 1993,
and the administrative record for the site was made available in the public repository at the West Florida
Regional Library. Notices were published in the Pensacola News Journal on November 28 and 30, 1993
advising of the availability of the administrative record, announcing the opening of the public comment
period, and advertising the date of the upcoming public meeting. A comment period was held from
November 12, 1993 to January 11, 1994 to solicit input on EPA’s preferred alternative for addressing
groundwater contamination at the site. In addition, EPA held a public meeting at the Sanders Beach
Community Center on December 2, 1993 to discuss EPA findings and answer residents’ questions.
Approximately 50 people attended the public meeting during which several residents expressed concern
about their health, citing numerous cases of cancer
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and other conditions in the community. At least three people requested that a health study of area residents
be conducted. Residents also registered complaints about the site being overgrown, thereby providing
potential hiding places for criminals. One resident attributed drainage problems, and flooding to the site,
furnishing EPA with photographs of flooding along Pine and Gimble Streets. At least two citizens suggested
that EPA was wasting money in cleaning up this site, but many of the residents expressed support of EPA’s
Proposed Plan for groundwater remediation. EPA issued the final OU2 ROD on February 4, 1994 with
a Responsiveness Summary documenting the Agency’s response to significant comments.
EPA has continued to keep the community informed about progress at the site through fact sheets and
informational meetings. During the design phase for OU2, EPA issued fact sheets in November 1996 and
May 1997. An Open House was held at the Sanders Beach Community Center to discuss EPA’s progress
on the design of the OU2 remedy and outline the alternatives EPA was considering for soil, sludge and
sediment. During the Remedial Action for OU2, EPA published update fact sheets in June 1998 and
January 1999. A public informational poster session was held at the Sanders Beach Center on July 16,
1998 to discuss the upcoming OU2 construction work and answer questions from residents. In addition,
EPA conducted interviews with local officials and community members in March 1998 in preparation for
revising the Community Relations Plan (CRP) for the Site. The revised CRP was published in July 1998.
EPA’s Proposed Plan Fact Sheet for the ROD amendment for OU1 was mailed to the public on April 28,
1998, and a copy of the Administrative Record was made available in the information repository at the
West Florida Regional Library in downtown Pensacola. A public notice was published in the Pensacola
News Journal in Pensacola, Florida, on April 30, 1998, advising the public of the availability of the
Administrative Record and the date of the upcoming public meeting. EPA held a public meeting on May
14, 1998, at the Sanders Beach Community Center to answer questions and receive comments on the
Agency’s preferred alternative for addressing soil, sludge, and sediment contamination from the Site.
Comments received during the public meeting were recorded in an official transcript of the meeting, a copy
of which is included in the Administrative Record. Initially, a public comment period was scheduled from
May 1 through June 1, 1998. However, at the request of the Bayou Chico Association, the Technical
Assistance Grant (TAG) recipient for the Site, EPA granted a 30-day extension to the comment period
through July 1, 1998. EPA published a public notice announcing the comment period extension in the
Pensacola New Journal on June 6, 1998.
EPA awarded a TAG of $50,000 to the Bayou Chico Association in September 1996 for the site. The
Bayou Chico Association hired a local office of Ecology and Environment as their technical expert for
reviewing and interpreting EPA information and documents.
3.0
Summary of Comments Received and EPA’s Responses
Comment: The drainage ditch commonly referred to as the Pensacola Yacht Club (PYC) ditch appears
to fulfill criteria of wetlands. It has artesian springs active near where the culvert from the city storm water
culverts empty into it; it constantly has water in it; it empties into the mouth of
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Bayou Chico; and the vegetation is characteristic of wetlands. We request a formal determination if this is
a wetland. Does EPA have the right to place a culvert in this wetland and fill it? If so, will mitigation be
performed? By whom and in what area?
Response: EPA agrees that available information about the PYC ditch (including the National Wetland
Inventory published by the Department of Interior) suggests that portions of the ditch may be a wetland.
Accordingly, Section 10.1 of this AROD indicates that a formal wetland delineation and functional
assessment will be conducted during the design. Other than the “No Action” alternative (which is not
considered to be protective of human health or the environment), each of the alternatives EPA considered
for addressing sediment contamination in the PYC ditch will result in some degree of impact to the wetlands
associated with the ditch. Clearing, dredging, and backfilling the PYC drainage ditch are activities that may
constitute a discharge of dredged and fill material into waters of the United States, which is regulated by
Section 404 of the Clean Water Act (CWA), 33 U.S.C. Section 1344. The requirements of CWA Section
404 and the associated Section 404(b)(1) Guidelines at 40 CFR Part 230 are therefore applicable to the
implementation of these activities. Nationwide Permit 38 applies to cleanup of hazardous and toxic wastes
in wetlands, but does not apply to activities undertaken entirely on a CERCLA site as required by EPA.
Accordingly, Nationwide Permit 38 is not applicable here. However, the General Conditions of this
nationwide permit are relevant and appropriate requirements, and the remedy must meet the substantive
requirements of CWA Section 404 and the Section 404(b)(1) Guidelines. The Guidelines require a
hierarchical approach to mitigation measures which includes impact avoidance, impact minimization, and
compensatory mitigation. Compliance with this three step process with respect to the selected remedy for
the ACW Site is evaluated in Section 10.1 of the AROD. The Northwest District of FDEP has provided
a letter indicating that neither a wetland resource permit under Chapter 62-312, Florida Administrative
Code nor a stormwater permit under Chapter 62-52, Florida Administrative Code will be required for the
project.
Comment: Numerous comments were received from the Bayou Chico Association, recipient of the
Technical Assistance Grant (TAG) for the Site, relative to the management of storm water from the ACW
Site. Specific concerns or suggestions provided include the following: identify the actions that will be taken
to prevent ACW Site-related contamination from entering Bayou Chico; storm water runoff should be
routed to a sedimentation pond prior to discharge to Pensacola Bay and Bayou Chico; testing and removal
of the accumulated sediment should be done; assurance should be provided that contracts and funding for
long term maintenance will be available.
Response: EPA’s selected remedy involves a number of elements which are expected to improve the
quality of storm water runoff in the vicinity of the ACW Site: contaminated soil from the PYC property and
residential areas will be excavated and consolidated on the ACW property; contaminated sediment from
the PYC ditch will be excavated and placed on the ACW property; and a surface cap will be constructed
over the consolidated material, stabilized sludge, and other contaminated portions of the ACW facility. The
cap will isolate Site contamination, thereby preventing storm water from coming into contact with
contaminated media. Section 10.1 of the AROD indicates that runoff from the Site will be directed to a
retention pond on the east end of the ACW property. Storm water will
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then flow from the retention pond through an improved storm sewer to Pensacola Bay. Any sediment which
collects in the retention pond is not expected to be contaminated, since all contaminated media will be
isolated beneath the cap. EPA will negotiate a State Superfund Contract (SSC) in which FDEP agrees to
fund and perform the long term maintenance of the cap and drainage features.
Comment: Commenters expressed concern about the potential for recontamination of the PYC ditch
should Alternative SD2, Total Removal, be selected. What measures will be taken to evaluate the potential
recontamination of the ditch via the discharge of contaminated groundwater?
Response: Although EPA identified Alternative SD4 as its preferred alternative for addressing PYC ditch
contamination, information and comments received during the comment period have persuaded EPA to
select Alternative SD2 as the selected remedy for the PYC ditch. The rationale for this decision is
documented in Section 12.0 of the AROD. In the long-term, EPA’s groundwater remedy selected in the
OU2 ROD sets cleanup levels for groundwater which are protective of the PYC ditch and Pensacola Bay.
The OU2 ROD already requires that surface water and groundwater monitoring be conducted to evaluate
the performance of the groundwater remedy. EPA shares the commenters’ concern about the potential for
recontamination of the ditch. Therefore, to ensure that an accumulation of contaminants does not occur in
the restored ditch prior to achieving applicable cleanup goals in the groundwater, Section 10.1 of the
AROD requires that periodic sampling of the sediment in the restored ditch be conducted until cleanup
levels in the groundwater have been achieved.
Comment: A number of comments were received with respect to Sediment Alternative SD4 expressing
concern that contaminated groundwater might flow around or into the culverts on the PYC property and
recontaminate the ditch or release contamination into the Bay and Bayou Chico.
Response: As indicated above, EPA’s groundwater remedy is designed to ultimately prevent
contamination from reaching the PYC ditch and Pensacola Bay. Based on comments received during the
comment period, EPA has dropped Alternative SD4 involving the culverts in favor of Alternative SD2
which involves removal of the contaminated sediment and restoration of the PYC ditch.
Comment: Several commenters said that EPA’s sampling program in the residential areas near the ACW
facility was inadequate, suggesting that both the depth (3 inches) and the areal extent of the sampling were
not sufficient. A commenter questioned why samples were not collected at other intervals and analyzed for
PAHs or phenols. In documents previously prepared and in EPA’s 1998 Fact Sheet, surface soils are
defined as soils from 0 to 3 feet below land surface (BLS). It is possible that land surface today may be
slightly different than it was 5, 10, 20 or 50 years ago and that high levels of soil contamination are now
covered with several inches or feet of topsoil. The commenter is especially concerned that high levels of
soil contamination are present below the upper 3 inches in the area of the former drainage ditch and south.
As reported in the Sanders Beach Community Area Study, Sample SA-SB-01 was collected from 2 to
3 feet BLS and had very high levels of PAHs. However, the sample collected nearby (SA-SS-4A) from
the 0 to 3-inch interval had very low levels
3-5
of PAHs. This suggests that what is found at the surface does not necessarily indicate the worst case
scenario.
Response: EPA believes that its residential sampling program for the ACW Site has been thorough and
comprehensive. The Sanders Beach Area Study Report dated December 1997 documents that EPA’s
most recent sampling effort addressed all residential properties from the ACW facility south to Pensacola
Bay, one block east to E Street, and one block west to M Street. The first phase of the study involved the
collection of composite samples from each city block to evaluate whether Site-related contamination had
migrated there. Based on these results, a second round of samples were collected from properties in every
city block between the ACW facility and West Cypress Street and in the city blocks where composite
samples exceeded EPA’s soil remedial goals. The use of a 3 inch surface soil sampling depth offers two
important advantages with respect to chemicals of concern at the ACW Site: first, both dioxins and cPAHs
are easily adsorbed to soil particles, and their deposition in residential areas through storm wafer runoff
would tend to be very shallow; second, because the residential soil cleanup levels for both dioxins and
cPAHs are extremely low, the use of a shallower sampling depth (3" vs. the usual 6") reduced the chance
for “missing” potentially problematic concentrations of these chemicals through dilution in the sample. EPA
recognizes the potential for newer fill material masking the presence of potential contamination, particularly
in the surface drainage area immediately south of the former lagoons. To address this concern, a
supplemental sampling effort was conducted by the Corps of Engineers in March 1999 which included the
collection of samples from the 1 ft., 2 ft., and 3 ft. depths. EPA will use this information to determine
whether additional areas exceed EPA’s remedial goals.
Comment: A commenter requested that all of the surface and subsurface soil sampling data collected both
onsite and off-site be compiled on a single map.
Response: EPA agrees that the soil data upon which this decision is based is located in numerous reports,
which is not very user-friendly. Summary maps showing the sample results for dioxins and cPAHs were
included in the Sanders Beach Community Area Report. During design, the Corps of Engineers will likely
develop a map of the ACW facility indicating contaminated areas which require capping.
Comment: A commenter expressed concern about the health of the youth who live in the ACW area and
use Sanders Beach. There appears to be some significant exposure to toxins for children. What postings
will be placed on the beach, at the PYC ditch, and what instruction will be formally given to home owners?
Response: Based on the results of the Sanders Beach Area Study, the Florida Department of Health
(FDH), under a cooperative agreement with the Agency for Toxic Substances and Disease Registry
(ATSDR), has determined that “the soil in the Sanders Beach Community is not a public health threat.”
Those property owners whose sampling results exceeded EPA’s surface soil remedial goals have been
notified of EPA’s intention to excavate that contamination in connection with the implementation of the
selected remedy documented in this AROD. Other residents whose properties
3-6
were sampled have also been provided with their sampling results with an indication that no action is
necessary to address contamination on their property. The Dye Dispersion and Sediment Sampling Study
(Sept. 1991) documented no Site-related contamination in sediment or surface water samples from
Pensacola Bay in the vicinity of Sanders Beach, so EPA does not believe that posting of warning signs on
the Beach is necessary. EPA and PYC officials discussed the need for warning signs around the drainage
ditch until remediation is undertaken, and EPA has purchased the warning signs, but access issues have not
yet been resolved between EPA and PYC.
Comment: A commenter indicated that residents are concerned about the use of existing and newly drilled
wells for irrigation purposes. These wells are reportedly bringing up “creosote smelling material.” How will
the use of these wells be terminated and future utilization prevented?
Response: The OU2 ROD called for the plugging and abandonment of private irrigation wells for which
consent was given by the owner. Of the 15 irrigation wells identified in the vicinity of the ACW site, 7 wells
were already plugged or destroyed, 7 owners refused to give EPA permission to plug their wells, and 1
well was plugged. In addition, the Northwest Florida Water Management District has placed a ban on the
installation of new wells in the area.
Comment: Pine Street is unpaved. After a rain, it has a creosote/oily residue on its surface. Pine Street
should be paved and adequate storm water utilization facilities be placed. How will EPA arrange for
pavement and what storm water collection facilities will be provided?
Response: A contaminated portion of Pine Street (between J and I Streets) will be removed and
backfilled as part of the remediation. As indicated earlier, storm water runoff from the Site will be diverted
through perimeter drainage channels to a retention pond on the east end of the ACW property. EPA has
no current plans to pave the street unless such improvements are necessary to implement the selected
remedy.
Comment: A commenter asked about the details of cap construction, including specifies about the barrier
cloth, lines, and depth of clay. How will the cap be maintained, and what will be done to prevent roots from
disrupting the cap? The commenter felt that a slurry wall or perimeter barrier must be constructed to
prevent superficial ground water from flowing through highly contaminated areas of the Site.
Response: Cap construction details are presented in Section 10.1 of this AROD, and a cross-section
showing the layers of the cap is provided in Figure 5. As part of the operation and maintenance (O&M)
plan for the Site, the cap and the entire ACW property will be mowed as necessary during the growing
season, which should prevent the growth of deep rooted plants. However, periodic inspections of the cap
will be conducted following construction to evaluate the condition of the cap and drainage features, and a
maintenance program will be implemented to prevent growth of trees or other deep-rooted vegetation from
penetrating the barriers and to fill in any erosion that may occur. Future use of the Site will be limited to uses
that do not require significant ground penetrations. Holes for poles, borings, trenches and other excavations
deeper than 6 inches will not
3-7
be allowed without a corresponding increase in the thickness of the cap cover. EPA is responsible for
O&M for one year following the determination that the remedy is operational and functional. Thereafter,
FDEP will be responsible for O&M pursuant to a Superfund State Contract with EPA. The groundwater
remedy for the Site was selected in the February 3, 1994 ROD for OU2. No slurry wall was determined
to be necessary to address groundwater migration from the Site because the groundwater remedy calls for
extraction and recycling of dense non-aqueous phase liquids (DNAPLs) from the aquifer, followed by
in-situ and ex-situ groundwater treatment. The DNAPL recovery phase of the groundwater cleanup has
been constructed and is in operation. The groundwater treatment phase is expected to begin in 4 to 5 years.
Comment: A citizen has property which appears to be an isolated area of contamination. This citizen has
plans to immediately build on this site. What will EPA do to allow building? What financial compensation
will be given if the site is unbuildable currently or in the future? Are residents who have plans for ground
intrusive or filling activities supposed to wait until soil remediation is complete before conducting these
activities? If not, should they contact EPA prior to conducting these activities? Will sidewalks, driveways,
gardens, etc. be impacted?
Response: The property in question is a vacant lot with high levels of cPAHs in excess of EPA’s remedial
goals for residential surface soil, but there was no immediately plausible migration pathway which linked
this contamination to the ACW facility. The owner explained that a house which formally stood on the site
had a walkway made of creosote-treated blocks. With this information, EPA resampled the property and
isolated the partially buried creosote-treated blocks as the source of the high PAH concentrations.
Therefore, EPA has notified the owner that the property has been dropped from EPA’s remediation plans
for the ACW Site. In the more general case, EPA would appreciate notification by the owner of any
property that is slated for remediation who has plans for improvements to the property. EPA does not
expect existing driveways, sidewalks, or similar improvements to be impacted by the excavation. However,
landscape features, including gardens, would likely be disturbed, but would be restored to their original
condition to the extent practicable.
Comment: There are a number of sections of old pipe which seem to carry storm water along through the
PYC property and Sanders Beach. What is the nature of these pipes? What is the nature of contaminants
in the pipes. How will EPA remove and prevent any further contaminant from flowing through these pipes.
Response: Observations by EPA field personnel collecting samples from the PYC ditch and Pensacola
Bay indicate the pipe appears to carry storm water from the PYC ditch when the mouth of the ditch is
occluded by sand. Sediment and surface water samples in the vicinity of the pipe outfall revealed no
Site-related contamination. EPA has no plans to remove the pipe.
Comment: Each property owner must be contacted by EPA and notified of the amount of contaminant
on his property and the specific health risks, if any, on that property. That has not been done. How will
EPA accomplish this?
3-8
Response: EPA has sent letters to each resident whose property was sampled with a copy of the results
and a discussion of what the results mean. These letters have been placed in the Administrative Record for
the Site.
Comment: The City of Pensacola has not been represented at any of the meetings. EPA is obligated to
include the city and county in plans.
Response: EPA met with representatives of the City Engineering Office, the Pensacola Yacht Club, the
Corps of Engineers, and Bayou Chico Association to discuss the proposed remedy. In addition, the City
Engineering Office provided EPA with comments on the proposed plan. These comments have been
addressed in this Responsiveness Summary and in the AROD.
Comment: Engineering practices appear to make a culvert through the PYC ditch very difficult: a pitch of
1/8 to 1/4 inch per foot would appear to be required, causing the outfall of the culvert into the Bay 3 feet
below high tide level. Because of littoral flow of sand in this area, the culverts would quickly become
occluded. The Bayou Chico Association requests an engineering study of the feasibility of creating a pond
or multiple smaller ponds (if PYC is agreeable) of sufficient size where the culverts enter into the PYC
ditch, including the area of the artesian springs. The exit from this pond would be culverts three feet higher
than the entrance, thus allowing the amount of slope necessary to bring the culverts out above high tide
level. The pond would mitigate the PYC ditch, allowing sampling of the water before it went into the bay
and removal of contaminated sediment.
Response: Based upon this comment and others received from the City Engineering Office and Pensacola
Yacht Club, EPA has changed the selected remedy for the PYC ditch from Alternative SD4 to Alternative
SD2. Alternative SD2 involves excavation of all contaminated sediment exceeding EPA’s remedial goal
for sediment (to an estimated maximum depth of 3 ft.), consolidation of this material on the ACW facility
below the surface cap, and backfilling of the ditch with clean fill. Selection of this alternative will address
the technical concerns associated with Alternative SD4 raised by Bayou Chico Association and others.
EPA believes its Focused Feasibility Study (FFS) represents an adequate development and evaluation of
alternatives for the ditch, and no other engineering or feasibility study will be undertaken by EPA. The
Corps of Engineers will address all technical issues associated with implementation of the selected remedy
during the design.
Comment: There are many instances of cap failure. There are cases where further mobilization of the
contaminant plume migrates and causes more widespread contamination after capping and “sign off” of the
Site. What mechanism will be available for further remediation if the capping does not prove effective in
containing the contamination?
Response: A groundwater monitoring program will be developed and implemented to provide data on
the performance of the remedy. EPA will conduct a review of this data and other information every 5 years
to ensure that the remedy is operating as designed and continues to protect public health and the
environment. Should this review reveal cap failure or other problems, EPA will evaluate alternatives for
addressing the problem and either issue an Explanation of Significant Difference or
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an Amended Record of Decision to document the necessary changes to the remedy. If fundamental changes
to the remedy are needed, EPA will provide an opportunity for public comment on the alternatives being
considered and EPA’s preferred alternative.
Comment: The Bayou Chico Association indicates that the residents are concerned that the land might
revert to the heirs of American Creosote Works, or that some developer may build upon this Site. Who
owns the land currently? Who will own the land when EPA signs off on the project? What deed restrictions
will be in place to prevent any future development of this Site?
Response: County records list American Creosote Works, Inc. as the current property owner. American
Creosote Works, Inc., filed for bankruptcy in 1981. The U.S. District Court for the Northern District of
Florida has entered a Consent Decree between American Creosote Works, Inc., their mortgage company,
and EPA in which EPA was granted access to conduct the cleanup of the facility and half the proceeds
from any sale or lease of the property. Should a developer or other entity desire to purchase or develop
the property, they would have to negotiate a Prospective Purchase Agreement with EPA in which
memorialize the restrictions to future use and the maintenance requirements associated with the cap and
drainage features.
Comment: During the public hearing, EPA’s project manager referred to the PYC ditch as the source of
contamination to the Bay. We request the record be corrected to reflect that while the drainage ditch,
referred to within the documentation as the “PYC ditch,” may have been the conduit of contamination from
the ACW Site to Pensacola, Bay, it is not the source of the pollution.
Response: While EPA agrees that the original source which resulted in contamination of the PYC ditch
is the ACW facility, the contaminated sediment now present in the ditch represents a potential source of
contamination to Pensacola Bay if not addressed by EPA’s selected remedy.
Comment: When dioxin was found, what health warnings were issued by EPA to residents and the general
public? What warnings should be issued to members of PYC, the employees of PYC, and the guests of
PYC? We request that EPA provide PYC with the appropriate wording for such warnings to issue to
members, employees, and guests.
Response: EPA’s sampling data from the Sanders Beach Community Area Study indicates only one small
area along Pine Street between I and J Streets which exceeds EPA dioxin cleanup level for soil in
residential areas. The dioxin level present in this area represents a chronic (long-term) health threat. EPA
notified the community of this and other areas of contamination in its April 1998 Proposed Plan Fact Sheet,
but no warnings were deemed to be necessary. Dioxin levels on the PYC property, in both surface soil and
in the PYC ditch, do not exceed EPA’s residential cleanup criteria, therefore, no health warnings are
necessary. EPA does recommend that PYC members, employees, and guests avoid contact with sediment
from the ditch, which is contaminated with high levels of PAHs.
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Comment: Since there is considerable scientific controversy over appropriate remedial levels against which
contamination is evaluated for removal, we request that Dr. Gilman Veith of EPA (Duluth, Minnesota) or
his staff review all analytical data generated to date on this project for accuracy in the selection of the
remedial level. We request that the cleanup level be confirmed or corrected, that the appropriate protective
health measures be described for the public, the membership, guests, and employees of PYC based on the
most stringent standard and proximity to the Site (PYC ditch), and operational measures to be exercised
by PYC prior to and during operation of the cleanup activity be identified and forwarded to PYC.
Response: EPA’s Proposed Plan and this AROD have undergone an extensive peer review within EPA
by toxicological and risk professionals in both Region 4 and Headquarters. The remedy reflects EPA’s
most current policy and guidance with respect to dioxin cleanup levels. In addition, EPA’s decision
document reflects the review and input of FDEP program and technical review staff, the U.S. Fish &
Wildlife Service, the National Oceanic and Atmospheric Administration, and the Florida Department of
Health. Therefore, no additional level of review within EPA is deemed to be necessary. EPA believes the
Proposed Plan Fact Sheet, EPA’s presentation and question and answer session at the public meeting held
on May 14, 1998, the Administrative Record for the Site, and this AROD and Responsiveness Summary
have adequately described EPA’s basis for the cleanup levels at the Site and the rationale for the selected
remedy. EPA will consult with PYC during the design and construction to coordinate our activities with
PYC activities and events, making every effort to minimize any adverse impact on normal club operations.
Comment: The feasibility study does not include provision to remove the contamination from the northeast
quadrant of PYC property. What are the lateral and vertical limits of this contamination? By what means,
and in what time frame, does EPA plan to remove the contamination? Since the extent of contamination
has not been defined even after seventeen years as an NPL site, we would like to express our
dissatisfaction with the overall assessment of the limits of contamination.
Response: The northeast quadrant of the PYC was identified as an area requiring remediation on the basis
of a composite surface soil sample collected during the Sanders Beach Area Study. The area to be
excavated is depicted in property tax maps and records as Block 190 of the property referenced as
00-OS-00-9080-006-188. The Corps of Engineers will precisely identify the lateral limits of excavation
in engineering drawings developed during the design. The initial depth of excavation will be 1 foot, after
which confirmatory sampling will be conducted to verify that no soil remaining at the 1 foot level exceeds
EPA’s remedial goals. Excavation will likely be done using a backhoe, trackhoe, or similar earth-moving
equipment. Based on the current projections, construction would likely begin in the late Spring or early
Summer of 2000. EPA believes that the Sanders Beach Area Study represents a very thorough and
comprehensive assessment of the extent of contamination in surface soil in areas potentially affected by the
ACW Site. EPA identified the areas requiring remediation in Figure 2 of the April 1998 Proposed Plan
Fact Sheet. A more precise delineation of the Area of Contamination requiring remediation is presented
in Figure 3 of this AROD.
3-11
Comment: The PYC indicated that should a jurisdictional wetland be determined to be present, the
installation of a culvert could not be performed without mitigation by EPA. PYC specifically denies further
use of its property as a mitigation site.
Response: As indicated in EPA’s response to a previous comment, EPA has changed its selected remedy
for the PYC ditch to Alternative SD2, which involves excavation of contaminated sediment and restoration
of the ditch. In this instance, the restoration of the ditch would itself represent a one for one functional
replacement of the wetlands destroyed by EPA’s remedial action. EPA does not anticipate the use of any
additional land area on the PYC to address mitigation requirements other than what is currently occupied
by the ditch.
Comment: Does EPA recommend that PYC suspend rental of the private house located at the entrance
to our property now or during the construction phases which will take place on PYC property?
Response: EPA believes that neither existing contamination on the PYC property nor the proposed
construction activities should adversely impact area residents. As indicated in the response to previous
comments, dust suppression will be utilized to minimize the migration of airborne contaminated, and work
zone delineation and access controls will be used to isolate contaminated areas during invasive activities.
In addition, if necessary, perimeter air monitoring will be conducted to ensure protection of nearby
residents.
Comment: Does EPA require curtailment of any of the functions which currently exist at PYC, such as
use of the swimming pool, tennis courts, boat slips, or grounds?
Response: EPA does not anticipate any significant disruption of PYC use of the swimming pool, tennis
courts, or boat slips. However, during the excavation of the northeast portion of the property and
excavation and restoration of the drainage ditch, these areas will be designated as an “Exclusion Zones,”
and access will be restricted to individuals with proper training and protective clothing. Improvements to
the mouth of the ditch may be necessary to address the significant erosion that has occurred in this area.
Since these improvements have not yet been designed, the potential disruption in the vicinity of the Marina
cannot be determined at this time. However, EPA will coordinate the design and construction of these
improvements with the PYC and attempt to minimize any disruption to PYC activities.
Comment: Please correct Figure 2 of the Fact Sheet to eliminate the dotted line street configuration shown
on the PYC property. Such a configuration stands for road access in civil engineering criteria which could
cause a potential contract bidder to mistakenly think there is an access right-of-way where non exists. What
will be the route of access to, or through, PYC property by contractors or EPA personnel?
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Response: The street configuration shown on PYC property in the Proposed Plan will not be shown on
design documents. Final routes of access cannot be fully determined until the design process is underway,
but it is EPA’s intent to try to limit access to affected areas and the area cast of the ditch.
Comment: Is it potentially possible to clean and regrade the drainage ditch and direct future drainage
flows around PYC property by realigning a culvert on the K Street easement?
Response: Because of the large volume capacity of the storm water culverts that drain into the PYC ditch,
the cost and technical and administrative feasibility of rerouting storm water to the K Street right-of-way
make this option difficult to justify under the Superfund Program.
Comment: What is the legal disposition of the property, specific to PYC, once cleanup of the
contaminated soil is concluded? What public entity will maintain the property? What deed restriction will
be required? How does the City of Pensacola drainage easement affect these requirements?
Response: With the exception of a small parcel immediately adjacent to the former lagoons, the remedial
action will have no effect on property ownership. Based on the remedial goals established for surface soil
and sediment at the PYC property, there will be no restrictions on the use of the property from a human
health standpoint. With the selection of Alternative SD2, any actions which may adversely affect the newly
restored wetlands (if any) would be subject to the regulatory requirements associated with wetlands. No
deed restrictions will be necessary for the PYC property either before or after remedy implementation.
However, EPA requests that PYC exercise due care in the use of contaminated portions of the property
prior to implementation of the remedy. The City of Pensacola will have to be consulted concerning their
drainage easement.
Comment: Has any data, transmittals, or information related to the contamination by ACW been withheld
from the membership of PYC under a “confidential” classification?
Response: No.
Comment: Does EPA intend to issue an order for PYC to cease operation of its facilities, or any part
thereof, during the course of construction?
Response: EPA has no intention of ordering PYC to cease operations during construction.
Comment: PYC requests a formal release to construct around, or above, the culvert should Alternative
SD4 prevail.
Response: As indicated in earlier responses, EPA has changed the selected remedy to Alternative SD2,
which will leave the ditch in place, but allow for its unrestricted use from a human health standpoint.
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Comment: PYC requests that the areas of health hazard concerns be appropriately marked by EPA.
Should Alternatives SD2 or SD4 prevail, the most stringent health standard should be used to designate
contamination and thereby resultant cleanup. Should the standard become even more restrictive in the
future, it would be obligatory to EPA to alleviate the condition to the more stringent standard.
Response: The levels of contamination present on the PYC property generally represent a chronic
(long-term) threat to public health, so their delineation a year before construction begins is not necessary.
The remedial goals for soil on the PYC property are the same as those for residential areas because of
previous indications from PYC that portions of the property might be developed in the future for residential
use. The remedial goal for sediment of 0.655 mg/kg (ppm) for carcinogenic PAHs is based on ecological
concerns. However, EPA risk calculations derived based on the assumption that a child age 7 to 16 (the
most likely target population) would be exposed to the contan-driated sediment in the ditch 100 days per
year (2 days/week, 50 weeks per year) demonstrate that this level is protective for human health. EPA
believes these remedial goals are protective for both current and potential future uses of the PYC property.
EPA will conduct a review every 5 years following initiation of construction to ensure that these levels
remain protective and to evaluate the performance of the selected remedy.
Comment: PYC challenges the differences in the public notice, which is legally binding, and the fact sheet,
which is not legally binding. Specifically, we refer to wording of Alternative SD2 of the legal notice. All
documents in the repository reflect the accuracy of this alternative. The State of Florida and NOAA have
responded with support for this alternative. However, the Fact Sheet has added the caveat of removal to
mean to a 3 foot depth--not total removal as stated in the legal notice. We request the Fact Sheet be
corrected to reflect the Legal Notice.
Response: EPA regrets the discrepancy between the Proposed Plan Fact Sheet and the Public Notice.
The Proposed Plan is correct in placing a limit on the extent of sediment excavation. In general, EPA does
not expect sediment contamination in the ditch to extend as deep as 3 feet. However, because the ditch
intersects the underlying aquifer, EPA is concerned that excavation might continue indefinitely once the
aquifer material is encountered, since the groundwater is known, to be contaminated in this area. EPA notes
that the Focused Feasibility Study (FFS) assumed a 3-foot excavation depth (see Table 5-1 of the FFS)
in the cost estimate for Alternative SD2.
Comment: The issuance of a Technical Assistance Grant (TAG) to Bayou Chico Association as a pubic
information vehicle does not preclude the statutory responsibility of EPA under CERCLA, EPCRA,
RCRA, or OSHA 1910 to PYC as an affected party.
Response: EPA agrees. The purpose of the TAG is to provide funds for affected communities to hire
independent technical experts to help interpret data and reports and provide input to EPA with respect to
a particular Superfund site. The TAG does not affect EPA’s other public participation responsibilities under
CERCLA Section 117.
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Comment: We request that all activity on PYC property be performed expeditiously and with minimal
disruption to the trees which line the drainage area and abound on PYC property. Trees, which include
multiple species of oaks and pecans, are controlled by the City of Pensacola Tree Ordinance found in the
Pensacola Land Development Code. In the engineering design phase it would be appropriate to consider
a series of small cascade ponds, instead of a streamlined ditch, through the affected PYC ditch in order to
preserve as many of the protected trees as possible. This would provide an additional measure of
catchment for rogue contamination.
Response: Because of the invasive nature of the excavation in the ditch, damage or destruction of some
trees is expected. However, EPA will take reasonable measures to minimize the disruption or damage to
trees on the PYC property to the extent practicable. Once access permission is granted by PYC, the Corps
of Engineers plans to conduct a tree survey on the PYC property to identify trees which are protected by
the local ordinance and assess any potential for damage or destruction of these trees. EPA will share this
information with PYC as it becomes available. EPA would be interested in getting more information about
the cascade concept from PYC during the design.
Comment: It would be prudent to consider that a series of cross-check sampling efforts be performed
after initial remediation to monitor performance of the overall effort over time. Please provide us with a
schedule of such a sampling effort affecting PYC.
Response: EPA will conduct confirmatory sampling at the bottom excavated areas to verify that the
applicable remedial goals have been met. In addition, a periodic monitoring program will be implemented
to evaluate the sediment and surface water in the PYC ditch for potential impacts associated with
contaminated groundwater entering the ditch. Although the monitoring schedule cannot be delineated at this
time, EPA will coordinate these sampling events with PYC as the project schedule becomes apparent.
Comment: The City of Pensacola has an existing storm sewer system that discharges into the drainage
ditch and our primary concern is that the hydraulic efficiency is not adversely impacted. There presently are
three 24" corrugated metal pipes that discharge into the ditch. The length of the drainage ditch is
approximately 950 feet before it discharges into Pensacola Bay.
Response: Based on this and other comments, EPA has changed its selected remedy for the ditch to
Alternative SD2, which involves removal of contaminated sediment and restoration of the ditch. This
alternative should result in a very similar hydraulic efficiency as is currently provided by the ditch.
Comment: In evaluating alternatives SD2 and SD3, it appears that alternative SD2 is preferred over SD3
in that considerably more contaminated material is initially removed and SD2 does not require the regular
maintenance associated with the ditch liner proposed for SD3. Furthermore, SD2 would allow the
establishment of vegetation along the ditch slopes thereby improving an existing wetland by allowing the
sediment from storm water runoff to settle and providing some additional treatment.
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Response: EPA agrees and has selected Alternative SD2 as the remedy for the PYC ditch.
Comment: Extending the existing storm sewer as recommended in SD4 would require the construction
of a small retention area where the pipe enters Pensacola Bay. The existing bottom profile is extremely flat
and it will be necessary to construct a rip rap barrier to prevent the pipe from filling in with sediment due
to tidal action. Furthermore, any treatment of storm water would be eliminated with the extension of the
storm sewer. Alternative SD4 could only be justified if it is beneficial to the future land use of this area. It
will have additional maintenance requirements associated with it and does not provide treatment of storm
water runoff as is provided with Alternative SD2. I therefore encourage you to evaluate these facts before
a final decision is made.
Response: EPA is persuaded that the problems related to the construction and on-going maintenance of
the culverts and the benefits of leaving the channel in place make Alternative SD2 a better choice for
addressing sediment contamination in the PYC ditch.
Comment: The extent of subsurface soil contamination has not been defined. This is of particular concern
in the neighborhood south of the ACW Site and the PYC ditch. What does EPA propose to do regarding
the future delineation of subsurface soil contamination?
Response: Under EPA’s direction, the Corps of Engineers collected additional subsurface soil samples
from properties south of the AGW facility in the former drainage pathway. Once the analytical results are
in from this supplemental sampling, EPA will identify the additional properties which need to be excavated
based on EPA’s remedial goals for subsurface soil.
Comment: Several residents have complained that storm water runoff in the neighborhood has an oily
sheen. They believe that the sheen is associated with the ACW Site. Given the contaminant levels in the
area, this is a possibility. E&E recommends that EPA establish baseline contaminant levels for storm water
runoff and compare this data to data from other unimpacted areas. If the levels in the neighborhood are
higher than normal, as the residents suspect, EPA should monitor the storm water runoff contaminant levels
in the neighborhood to see if they decline after the proposed soil remedy is implemented. If the levels do
not decline, some additional soil hot spots, associated with the ACW Site, may exist in the neighborhood
and will need to be remediated.
Response: EPA believes that any significant migration of contamination from the ACW facility into
adjacent residential areas associated with storm water runoff would have likely occurred while the plant
was operating and the wastewater lagoons were extant. Any areas which exceed residential soil cleanup
levels will be addressed by excavation and consolidation of this material beneath the cap on the ACW
facility. Since the results from the Sanders Beach Area Study indicated only a few areas which presented
a long-term threat to residents (primarily along drainage pathways from the Site), EPA believes that storm
water sampling at this time would provide little additional information concerning the proposed remedy.
EPA does plan to collect periodic surface water samples from the retention pond following construction
of the surface cap to monitor the effectiveness of the remedy.
3-16
Comment: Recently (June 1998) during maintenance dredging permitting efforts by the PYC, FDEP
expressed concern about potential dioxin, PAH, and phenol contamination of sediments in Bayou Chico
that may have resulted from activities at the ACW Site. Samples from the Bayou and Pensacola Bay have
been analyzed for PAHs but not dioxins. Is sediment contamination in the Bayou a problem? If not, why
is FDEP concerned?
Response: Sampling results reported in the Dye Dispersion and Sediment Sampling Study did not indicate
a problem in Bayou Chico and Pensacola Bay. Sediment contamination appears to be limited to the PYC
ditch and its delta. Although no sediment samples from the bayou or the bay were analyzed for dioxins, the
Phase IV RI report documents very low dioxin levels in the PYC ditch, ranging from 0.069 to 5.0 ng/kg
(parts per trillion). Since these dioxin levels are below levels of concern for human or ecological receptors,
EPA does not believe that sampling for dioxin in the bay or bayou is warranted. EPA understands the
concern on the part of the FDEP district office about the potential for impacts to Pensacola Bay and Bayou
Chico by the ACW Site because of the well documented surface water migration pathway from the former
Site lagoons to these bodies of water. However, EPA’s available data indicates that no Site-related impacts
to the bay or bayou have occurred, and the remedies selected in this AROD and the OU2 ROD for
groundwater will prevent any potential future impacts.
Comment: Since limited soil data exists deeper than 3 inches BLS, it is very difficult to assess the
risks to residents involved in ground-intrusive activities such as gardening.
Response: The dermal and ingestion exposure pathway evaluated in the 1989 Baseline Risk Assessment
considered the potential for exposure to contaminated soil during outdoor activities such as playing or
gardening. As indicated in Section 7.1.4 of this AROD, the risks associated with residential areas fell within
EPA’s cancer risk range.
Comment: The community has been encouraged to consider beneficial ways to utilize the ACW property
once it is capped. Prior to designing the cap, EPA should discuss beneficial use options with the community
at public hearings.
Response: Future use of the Site will be limited to uses that do not require significant ground penetrations.
Holes for poles, borings, trenches and other excavations deeper than 6 inches will not be allowed without
a corresponding increase in the thickness of the cap cover. Ground penetration at any depth should cease
immediately if the nonwoven geotextile is encountered during excavation. Potential future uses that might
not require significant ground penetration include walking, jogging, and bicycle paths, pavement for parking,
and light-weight slab-on-grade construction. Installation of lighting or other utilities needed for these uses
may not be possible if not designed for and possibly constructed in conjunction with the cap. Precautions
possibly including placement of additional fill would be required during construction. The grades required
for good drainage will make the Site undesirable for ball or soccer fields. Construction of heavily loaded
structures will be impracticable over the cap because of the possibility of settlement and the need for deeper
foundations. A public hearing would be of little benefit unless a concrete proposal for use of the property
was presented and
3-17
underwritten by a sponsoring public or private entity. EPA has received no such proposal for the reuse of
the ACW Site.
Comment: Phase I “Capture & Containment” is fine, but we must also be on line for Phase II “neutralization” - when can we expect Phase II?
Response: Again, this comment appears to relate to the groundwater remedy. EPA estimates that the
DNAPL recovery system will operate for 4 to 5 years, at which time the dissolved-phase recovery and
treatment system (Phase 2) will begin.
Comment: Do not expose the east end of the property to the contamination of the southwest end by
storing toxic materials there; keep the worst materials where they are - on that end.
Response: EPA does not intend to stockpile contaminated material on the east end of the ACW facility
property. Rather, this area will be used for a stormwater retention pond to manage runoff from the new
surface cap.
Comment: How frequently will EPA monitor our individual neighborhood properties after Phase I is
completed?
Response: Other than confirmation samples in properties which are excavated, EPA does not expect to
collect additional soil samples in the neighborhood.
Comment: At a meeting on 6/18/98 I voiced my concern over how soil samples were taken and two
properties, one of which is slightly more than 100 ft. from me is showing a large amount of toxicity. I would
hope maybe some additional test on the affected property might show that property is not as bad as shown
(8507 ppb). Is it possible to get some additional testing? I am glad to hear work is to start to reclaim what
creosote that can be pumped up from the Site.
Response: The property near you with the high PAH levels was in fact resampled to determine whether
the source of the PAHs was really the ACW facility. Based on visual observations and the sampling results,
EPA has determined that this property was not contaminated by the ACW Site, but the high PAH levels
are reflective of the presence of partially buried creosote-treated blocks used in a walkway on the property.
Comment: As residents of the Sanders Beach area, we are very interested in the cleanup efforts of the
EPA. We would like to have as much done as possible, including having the 190 million or so gallons of
creosote that is in the ground now pumped out.
Response: The OU2 ROD for groundwater addresses the treatment of contaminated groundwater at the
ACW Site. The first phase of this groundwater remedy, DNAPL recovery and recycling, is already
underway. Once Phase 2 of the groundwater remedy begins, which involves treatment of
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contaminated groundwater, EPA estimates that closer to 150 million gallons of water will ultimately require
treatment.
Comment: EPA proposes to remediate from midway between G and H Streets back to Barrancas
Avenue. This would involve about 1,200 linear feet of 100-foot wide right-of-way (about 3 acres) owned
by Burlington Northern Santa Fe. This old right-of-way was at the fringe of the contamination and up
gradient and should be safe to develop as non-residential property. We oppose any alternative, such as
capping, that would not allow for some use of our property.
Response: EPA’s data indicates that surface soil contamination exceeding EPA’s industrial remedial goals
for the Site exists in the right-of-way in question. Based on EPA’s evaluation of the alternatives considered
for addressing this and other contaminated areas of the ACW facility, the capping alternative represents
the best balance among the nine NCP selection criteria, including cost effectiveness. Some limited use of
these portions of the property may be possible, as indicated in the response to an earlier comment.
Comment: Having resided at this address for over 60 years; having raised a family of children and
grandchildren to the 4th generation; having had a garden for many, many years and used the produce
thereof as well as fruit from trees, berries and pecans, all without harm, we do not agree that the
contaminants found at the creosote plant are harmful to humans, animals or vegetation. This area should
be left alone. Other residents expressed similar sentiments that they had lived in the area for many years
without any negative impact.
Response: EPA’s risk assessment and recent sampling data confirm that the majority of the residential
areas are safe, and only a few properties in the residential areas present an unacceptable long-term risk to
residents. However, the risk assessment also documents that contamination on the ACW facility itself poses
an unacceptable threat to potential trespassers. Therefore, the Superfund Law requires that EPA take
action to address this unacceptable risk.
Comment: I moved in this area on M Street in December and there are smells like there has been
contamination. I’m not referring to the smell from the sewage plant located down near the Judicial Building.
I am referring to exactly the area located on the map labeled “Figure 1" Site Map, from right near the Yacht
Club down M St., down Barrancas to Main Street all within that area is a horrible stench. I would like you
to comment as soon as possible. I want to protect my family’s health.
Response: EPA believes the stench you refer to is probably not emanating from the ACW Site for two
reasons: First, the type of waste material present at the Site is contaminated soil and debris, which is not
likely to produce a significant odor, since the contaminants are bound to the soil; second, the primary
contaminants at the ACW Site (PAHs, dioxins, PCP) are semi-volatile compounds, which means they are
not likely to evaporate or vaporize from the Site. The source of the stench may be the nearby Reichhold
Chemical plant or other industrial operations along Bayou Chico.
3-19
Comment: Will this action completely clean up the Site?
Response: The selected remedy presented in this AROD represents the second and final response action
EPA plans to take to address contamination related to the ACW Site. The first action, known as Operable
Unit 2, is the groundwater remedy presented in the ROD dated February 3, 1994. The second action
presented in this AROD addresses the remaining contamination at the Site associated with soil, sediment,
and the stabilized sludge from the former lagoons. Once these response actions are completed, the Site will
be “completely cleaned up.”
Comment: What is the ultimate cost?
Response: The total cost of the selected remedy in this AROD is $1,549,400.
Comment: Why the cheaper route?
Response: EPA’s rationale for selection of the capping alternative (Alternative SS2) hinges on more than
just cost effectiveness. Alternative SS2 ranks the highest against the other alternatives with respect to
short-term effectiveness, implementability, and cost. In addition, since the ACW Site was listed on the NPL
in 1983 and this AROD represents the third attempt in selecting a remedy for source control at the Site,
EPA believes that community sentiment runs against the selection of an innovative technology (such as
thermal desorption) or other type of treatment alternative requiring extensive treatability or performance
testing which could slow actual implementation. Finally, EPA believes that the stabilization treatment of the
sludge in the former lagoons during EPA’s earlier response actions has been effective in addressing the
mobility of contaminants associated with these principle threat wastes.
Comment: If incinerated, how much emissions and toxic residue is left.
Response: For incineration actions, EPA sets a goal of reduction of dioxin-contaminated wastes by
99.9999% destruction removal efficiently (DRE) and all other wastes by 99.99% DRE. Emissions are
reduced or eliminated through pollution control equipment on the incinerator stack, With the National
Emissions Standards for Hazardous Air Pollutants (NESHAPS) serving as the applicable performance
standards.
Comment: Why not destroy the toxic waste at this time? It will have to be destroyed someday anyway.
Is there currently technology that will destroy all of the toxic waste? If so, are there any emissions? If there
were technology which would destroy all of the toxic waste without any emissions, would EPA utilize the
technology?
Response: EPA evaluated a number of treatment technologies which are capable of destroying or
removing the contaminants at the ACW Site, including thermal desorption, incineration, and in situ
vitrification. Each of these technologies are likely to produce emissions, but these emissions could be
controlled by currently available air pollution control equipments Based on its evaluation of these
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alternatives and the capping alternative, EPA determined that the capping alternative provided adequate
protection of human health and the environment at a much lower cost. EPA believes that the cap can be
maintained in order to ensure that it remains piotective for a long period of time. EPA will continue to
conduct a review every 5 years to evaluate the protectiveness of the remedy. Should EPA determine that
the remedy is not longer protective, additional measures will be undertaken to restore the remedy to an
adequate level of protection.
Comment: Why start cleanup of the groundwater and leave the overlying surface soil capped?
Response: EPA believes that the earlier stabilization of the sludge in the former lagoons combined with
the capping of this material and contaminated soil at the Site will prevent any significant leaching of
contaminants from the soil into the groundwater. EPA will conduct periodic groundwater monitoring to
evaluate the effectiveness of the remedy.
Comment: EPA should not waste another dime to remediate the ACW Site. Moments after the
appearance of any remediation equipment, be prepared to contend with a number of ill. residents who will
demand that the EPA buy their homes and pay for relocation expenses. Study the Escambia Treating Co.
imbroglio. There was no problem until EPA showed up in space suits and starting digging.
Response: EPA’s risk assessment documents unacceptable risks associated with the ACW Site which
by law require action by EPA. EPA believes the selected remedy in the AROD represents the most
appropriate option for addressing the risk posed by the Site. To date, EPA has not received a mass
demand for relocation of residents near the ACW Site.
Comment: A commenter contended that EPA’s approach to remediating groundwater masks the actual
results because samples were rarely taken during and after remediation. The commenter further contends
that the extraction of groundwater upsets the equilibrium established over a period of 90 years, resulting
in a likely increase of contaminant levels. A number of other issues were raised about the effectiveness of
EPA’s groundwater remedy by citing EPA reports from another Superfund site in the Pensacola area.
Response: Since this comment relates to EPA’s groundwater remedy for the ACW Site, EPA refers the
commenter to the responsiveness summary for the OU2 ROD dated February 3, 1994 for a response to
these comments.
Comment: A commenter indicated that he thought EPA was going to go down and purnp all the material
out and burn that material and dispose of it onsite. In particular, the commenter thought the deep
contamination down to seventy feet would be addressed this way.
Response: The commenter was referring to the DNAPL recovery operation, which is the first phase of
EPA’s groundwater remedy for the Site. The DNAPL recovery system was constructed last
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summer, and extraction wells are currently withdrawing DNAPL from the subsurface. This material is being
sent to a cement kiln in North Carolina for burning as a fuel.
Comment: A resident expressed concern that EPA’s proposed cap would destroy the wooded areas on
the eastern portion of the ACW property.
Response: EPA’s initial response during the public meeting suggested that this area of the ACW property
would not be disturbed by the selected remedy. However, further development of the alternative and
discussions with the Corps of Engineers and the City of Pensacola indicate that this area will be needed for
construction of a retention pond to manage storm water runoff form the surface cap and perimeter drainage
ditches. Construction of the retention pond will necessitate the removal of all trees and brush in this area.
Comment: A commenter recommended using the ACW Site for a container storage terminal.
Response: EPA has been and continues to be open to accommodating possible productive uses of the
ACW facility following cleanup. However, no such proposals have been sponsored and underwritten by
either public or private entities. EPA has no mechanism available to promote or pay for a commercial use
of the property. The conceptualization and funding for such a venture would have to come from business
or public interests within the community.
Comment: A commenter expressed concern that when the sediment was excavated from the PYC ditch,
contaminants would become airborne, causing a problem for local residents.
Response: Since sediment is saturated with water and the contaminants are considered semi-volatile, EPA
does not expect an air emissions problem during this particular activity. However, work zone air monitoring
will be conducted to ensure protection of the workers, and, if determined to be necessary during design,
perimeter air monitoring will be conducted to protect area residents.
Comment: The Site has been here for over 90 years and it seems that some equilibrium has been
established regarding the contaminants. It seems that EPA will exacerbate the situation by taking the
proposed action. What is your benchmark for determining whether you’ve improved the situation or made
the situation worse?
Response: EPA has established cleanup levels for soil and groundwater which serve as benchmarks for
evaluating cleanup level effectiveness. EPA believes that the removal, stabilization, or containment of
contamination at the Site will reduce or eliminate risks associated with these contaminants.
Comment: A commenter raised concern that EPA does not monitor groundwater contamination until five
years after the cleanup. How often is the groundwater monitored? Another commenter was concerned that
if there was a problem, EPA would not know about it for five years.
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Response: EPA has already initiated a groundwater monitoring program in conjunction with the DNAPL
recovery system which is currently operating. This monitoring program will be augmented to include
additional wells once the source control remedy is in place, and additional monitor wells are likely to be
added once full scale pumping and treating of the groundwater begins in 4 to 5 years. Groundwater samples
are currently being collected every 3 months (quarterly). However, the frequency may drop to every 6
months as time goes on. EPA will conduct an ongoing evaluation of groundwater data (not just every 5
years) to ensure that the groundwater and source control remedy remain protective and to make
adjustments in the DNAPL and/or groundwater systems to improve performance.
Comment: A commenter expressed concern that EPA would keep digging in the PYC drainage ditch “to
the parking lot”.
Response: No. EPA expects the lateral limit as set a limit of 3 ft. on the excavation depth (in all directions)
for the PYC ditch.
Comment: A number of residents expressed concern that they had not received data from EPA’s
residential sampling efforts.
Response: Following the public meeting, EPA forwarded the data to individuals whose property had been
sampled.
Comment: Some residents argued that contaminants in the PYC ditch were not a problem, indicating that
EPA has not been able to document any cases of cancer.
Response: EPA’s sediment sampling results and risk assessment indicate that sediment contamination in
the ditch poses a threat both to human health (particularly children age 7 to 16) and the environment.
Comment: A commenter asked if a health study had been done of residents living immediately around the
Site to evaluate if they had cancer.
Response: The Florida Department of Health (FDH) evaluated the soil sampling data from the Sanders
Beach Community Area Study an concluded that the soil in the neighborhood is not a health threat, with
the exception of the areas slated for excavation. FDH also indicated that nationwide, one out of every three
people (33%) will get some kind of cancer, and one out of every four (25%) will die from cancer. Based
on this information, FDH determined that a public health study was not warranted for the ACW Site.
Comment: A commenter expressed concerned that the Site might be developed for residential property
in the future.
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Response: The future use of the ACW property will be restricted by EPA. The bankrupt American
Creosote Works, Inc. remains the owner of record of the ACW property. However, EPA negotiated a
Consent Decree with ACW and their mortgage holder which was entered by the U.S. District Court that
grants EPA 50% of the proceeds of the sale of the ACW property. Should any developer attempt to
acquire the ACW property, he would have to negotiate a prospective purchaser agreement with EPA.
Comment: A commenter asked who owns the building which used to be the office complex for the ACW
company. The commenter expressed frustration that the ACW company or someone associated with it
made (or is still making money) and the residents who are left to deal with the Site.
Response: The property in question is owned in part by a former officer of the ACW facility. However,
it is not EPA’s policy to pursue corporate officers for costs associated with a Superfund cleanup.
Comment: A commenter asked why EPA was relocating residents from as far away as 2 or 3 blocks
because of contamination from the Escambia site on Palafox, but residents living right next to the ACW Site
were determined not to have contamination. EPA says the condominium property is contaminated, and the
PYC ditch is contaminated, but my property, which is in the same line as that ditch, is not contaminated.
Response: The Escambia Treating Company site was selected by EPA as a National Relocation
Evaluation Pilot project. The Pilot was designed to evaluate the use of relocation as a possible solution to
contamination problems at a Superfund site. Although the types of contamination are similar at the ACW
and Escambia sites, the levels of contamination at the Escambia site are generally higher. This is not to say
that every property near the ACW Site is lower than every property that is being addressed under the
Escambia pilot. However, EPA has concluded that, with the exception of the proposed excavation areas,
the risks in residential areas fall within EPA’s range of acceptable risks. With respect to the migration of
contaminants, historical information indicates that a low area existed where the condominiums are now
along which discharges from the ACW lagoons would how, eventually entering the PYC ditch. When the
condominiums were built, clean fill was placed in this area, and recent surface soil samples indicate little or
no surface contamination. However, the subsurface soil in this area appears to be heavily contaminated.
In order to address the commenter’s concern, EPA collected additional subsurface soil samples within the
entire city block know as the “Condominium Block” to determine if the drainage area was wider than
originally thought. The results of this additional sampling will be used during the design to identify additional
properties, if any, which require excavation based on EPA’s subsurface soil remedial goals.
Comment: It seems EPA is doing things backwards. After 17 years, EPA has decided to shut the wells
off that the residents have used all this time. If the water was contaminated, why didn’t you shut the wells
down 17 years ago?
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Response: First, it is important to understand that the wells in question are irrigation wells, and not drinking
water wells. The residents in the area use city water for drinking, cooking, washing, etc. EPA’s ROD for
OU2 called for the plugging of these private irrigation wells not necessarily because they were already
contaminated, but because of the potential for them to become contaminated. In addition, EPA was
concerned that the operation of these wells could potentially interfere with EPA’s groundwater cleanup
plan.
4.0
Remedial Design/Remedial Action (RD/RA) Concerns
Comment: How will the traffic congestion resulting from the work on Barrancas affect EPA’s ability to
implement the remedy?
Response: As of the writing of this Responsiveness Summary, the road work on Barrancas has been
completed, and the resulting traffic congestion along Cypress and L Streets has subsided. Construction at
the Site is not scheduled to begin until the Spring or Summer of 2000. EPA expects the majority of the Site
construction traffic to enter the Site from Main Street, Barrancas, or Gimble to the north. However, trucks
carrying contaminated material from the Yacht Club and residential remediation areas will probably be
routed north on L Street. EPA will conduct an informational meeting prior to initiating construction to
discuss the traffic plans and other aspects of the construction effort.
Comment: A commenter expressed concern about the management of storm water during construction
or other times when soil is disturbed.
Response: As a minimum, a silt fence will be required during construction. Additional measures will be
considered prior to start of construction, such as a temporary earthfill barrier surrounding the perimeter of
the construction site and/or a swale within the barrier to retain all storm water runoff prior to releasing storm
water. A temporary lined retention pond will be part of the design to retain and occasionally test (if needed)
storm water prior to releasing it.
Comment: Several commenters asked what measures would be taken to protect residents from exposure
to dust, airborne contamination, and water (runoff?) during construction. Should pregnant women be
warned to avoid the Site during the construction?
Response: One important advantage of the selected remedy is that minimal disturbance of contaminated
material on the ACW facility is anticipated. However, the construction contractor will be required to use
some sort of dust suppression (most likely water) as necessary to control dust within the Site. The
excavation of contaminated areas in residential areas and the Yacht Club will be undertaken in such a
manner as to minimize the generation of dust. To address storm water runoff, a silt fence will be required
during construction. Additional nwasures will be considered prior to start of construction, such as a
temporary earthfill barrier surrounding the perimeter of the construction site and/or a swale within the
barrier to retain all storm water runoff prior to releasing storm water. A temporary lined retention pond will
be part of the design to retain and occasionally
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test (if needed) storm water prior to releasing it. If determined to be necessary during design, a perimeter
air monitoring program will be instituted during construction. No one, including pregnant women, who is
not properly trained should enter the Site. Only workers with the appropriate OSHA training and medical
monitoring will be allowed to enter contaminated areas of the Site. Contaminated areas will be clearly
delineated as “Exclusion Zones,” and access will be restricted through the use of a “Contamination
Reduction Corridor.” At the PYC and other private properties, similar work zone delineations and access
controls will be used to protect private citizens.
Comment: All dirt used in fill operations must be of the type of soil that is in the immediate area. No red
dirt or sand should be allowed. How will EPA assure that appropriate fill material is used?
Response: The use of a geosynthetic clay liner in place of the usual clay layer (see Section 10.1 of the
AROD) will allow use of fill materials similar to the native soil and minimize the use of clay. Since the use
of red dirt or red sand appears to be primarily an aesthetic concern, EPA will instruct the Corps of
Engineers to incorporate into the spedifications a restriction on the use of such materials to the extent
practicable.
Comment: How long will the operation of PYC be impaired by this project? Is it possible to avoid the
May to August window of PYC activities?
Response: Other than temporarily impacting the use of the northeast quadrant and the areas east of the
ditch, EPA does not expect the construction effort to impair normal operations at the club. Unfortunately,
current schedule projections indicate that EPA construction activities at the PYC may occur during the May
to August 2000 time frame, since the excavation of the soil and sediment must occur prior to construction
of the cap on the ACW facility. It is too early to know exactly how long these activities will take.
Comment: PYC is of the opinion that the contractor for the soil contamination or EPA should be
responsible for providing HAZMAT “awareness lever” training to the onsite personnel of PYC.
Response: EPA would be happy to provide a pre-construction briefing for PYC members a nd staff to
discuss health hazards, contingency plans, project schedule, etc. As the start of construction approaches,
EPA will coordinate such a briefing with PYC. Formal HAZMAT training should not be necessary since
properly trained and attired workers will be the only people allowed in the Exclusion Zone.
Comment: PYC requests to know the hours of construction, seven days aweek, which will be placed in
the notice to bidders, on that portion of the project specific to PYC.
Response: EPA will advise PYC of the construction work hours included in the bid documents. Typically,
EPA restricts working hours to Monday through Saturday from 7 AM to 6 PM.
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Comment: With the revelation of the contanfination of the northeast quadrant, how much of the PYC
property will be fenced by the contractor during the cleanup operation?
Response: Although EPA does not anticipate the need to fence any areas within the PYC property, the
need for fencing will be determined as the design progresses. The “Exclusion Zones” are typically
delineated with caution tape.
Comment: Will there be pump noise, and if so, for how long? Does the pump run at night? Will the water
table be decreased?
Response: This comment appears to relate to EPA’s ongoing groundwater remedy. The pumps associated
with the DNAPL recovery system are low flow pneumatic pumps which operate with little noise. The
modest amount of water being withdrawn from the aquifer during the current phase of the project is not
sufficient to result in a decrease in the water table other than immediately around the well.
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