United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA.-ROD/R04-85/006
September 1985
vvEPA
Superfund
Record of Decision:
American Creosote, FL
-------
TECHNICAL REPORT DATA
(Please read Instructions on the rel'erst before completintl
'. REPORT NO. 12. 3, RECIPIENT'S ACCESSION NO.
pPA/ROD/R04-85/006
fiTLE AND SUBTITLE 5. REPORT DATE
~UPERFUND RECORD OF DECISION September 30, 1985
American Creosote, FL 6. PERFORMING ORGANIZATION CODE
7. AUTHORIS) 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
1 t. CONTRA~T/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Report
401 M Street, S.W. 1.. SPONSORING AGENCY CODE
Washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
.
18. ABSTRACT. Inc. (ACW) site occupies approximately 12
The Amerlcan Creosote Works.
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 8ay. 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 (PARs) 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 PARs.
17. KEY WORDS AND DOCUMENT ANALYSIS
.. DESCRII'TORS b.IDENTIFIERS/OPEN ENDED TERMS C. CDSATI Field/Group
Record of Decision
k~erican Creosote, FL
Contaminated Media: gw, sediments, sludge,
soil
Key contaminants: PAHs, benzeRei ~
ethylbenzene, toluene, xylene
IISTRIBUTION STATEMENT 19. SECURITY CLASS (Tllis R,portl 21. NO. OF PAGES
.
None 52
20. SECURITY CLASS (Tllis page} 22. PRICE
I None
E'. ,- 2220-1 (R....4-77)
PlutVIOUS I:OITION" 08.01.1:TI:
-------
INSTRUCTIONS
1,
REPORT NUMBE R
Inser! rhe l PA report number is It appealS on the caver of the publl.:allon,
2.
3.
LEAVE BLANK
RECIPIENTS ACCESSION NUMBER
Reserved for use by ~J.'h r~pon re:.:apient.
4.
TITLE AND SUBTITLE
Title should IMdlCile dCJrly and bueny the sub)e:.'1 ,'oYer;!~e \II the report, Jnd be ,!I'l'lay,'J I'r U 11\111"11 1 I) . S,'t 'Ubi Ilk, II u','d, 111 '1110111.-1
type or otherwise subordInate It to maIM title. When a repon.s I'repar~d 1M mon° than "II,' v,llume, rq,,".Illh"l'ramary tllk. .Idl! v,.lalll"
number and include subtitle for the specific tllie.
5.
REPORT DATE
Each report shaU carry a dale Indicalinl at lusl month and year. Ind,,'ale 1111" b,"I' UI1 "1\1.11 II \\,1' ,,''''\'I,.J (0'.,,:, Jult "1 II.\/Ic', Jafc' "1
app,ollal. diltt of prt{JQrGflon, tIC.).
a.
PERFORMING ORGANIZATION CODE
Leave blank.
7.
AUTHORISI
Give name(s) 1M ,',mvenIlOn;!! order (John R. Doc. J Ro/x'" Do('. ('fl.). lIsl aUlhur's alrihallull If 11 ,hIla' Irlll1\ II", II\.'rlurl1l1nj: ,"j:;!III'
ulion.
'.
PERFORMING ORGANIZATION REPORT NUMBER
Insert if performlMl organazallon wIshes to assl,n th" number,
8.
PERFORMING OAGANIZATION NAME AND ADDRESS
Give name, street, clly, state. and ZIP code:. Lisl no more: than two !(ve!s 01 an urj:JI1I1Jllul1allureardIY.
10. PROGRAM ELEMENT NUMBER
Use the prolRm element number under which the report WilS prepared, SuborJII1i1te numlxr' ma)' II\: 111.1 II d...1111 l'all'l1lh,'"",
11. CONTRACT/GRANT NUMBER
Insert conUact or pant number under which report Win prepared,
12. SPONSORING AGENCY NAME AND ADDRESS
Include ZIP code.
13. TYPE OF REPORT AND PERIOD COVERED
Indicate IMtenm filW, etc" and If applicable, dates covered,
14. SPONSORING AGkNCY CODE
Insert appropriate code.
15. SUf't'LEMENTARY NOTES
Enter information not Included e:lsewhere but useful. such as.
To be published in, Supersedes, Supplements. (tc,
Prepared 111 ,'oo~'allun Wllh, I '.II1,lalllll1lll, 1'''''''''I1I,'d JI ,,,"1.'0"",, ,.1.
1'. ABSTRACT
Include a brief (200 wordr 0' lerr) faclual summary of the mo.,r 'l"n.I/,...nl IM/urmil,,,,n ,unlalM.,,, '" ,I,,' ''''''''1. II Ih,. "'1'''' I ,""1.'"" a
sisnificant bibliolfaphy or llteralure survey, menuon It hell:,
17. KEY WORDS AND DOCUMENT ANALYSIS
(a) DESCRIPTORS - Select from Ihe Thc...,uru~ of ~nllncellr.1I Jnd So;l"UIIIi, lerm, thc pru~r ilulh,,'II,'\J 1,"111' Ihat l\Jenll'Y Ih,' RlJ)'"
concepl of Ihe research and are sufficiently spc!:lf;c ..nd preo.:l": 10 be used 'IS ,nun enlrll:~ lur ,..IOIII,/o=,n/=.
(b) IDENTlrJERS AND OP[N.ENDED TERMS. Use Identirltn for prole!:t naRl.., ,ude n..m"" "\ju'pm"l1t J",,/=nalurs, ,'I.. tJ....., ",,,,,,.
ended terms will/en In dcscnptor form for those subjects for which no de\l:lIptur "'lstS.
(c) COSio TlIILLD GROUP. Held and poup ilSsi.nmenu.ue to be tilken from the 1 'I6S ('OS,,'II Suh,..." (JI,')!ory I.lsl. Slno.:,' the nla.
jority of documents are multidisciplinary In nature, the Primary Held/Group ;!\\llInmelltf '. w,lI Ix 'I"'" II" JI\\ 11'1,"", arc;! 01 hU"IJn
endeavor. or type of physical object. The applicatlonls) will be cross-rCiereneed with \C,unua,y Iiddil ,'''UI' a"'I="""'1I1\ IhJ' "1111011..,,
the primary postangu).
18. DISTAIBUTION STATEMENT
Denote releasabllllY to the publi!: or limitation for rea,ons other th..n s.:':UJlt)' fur eJtilmp!e "N.cI"J'" t ,Ji"" 11,'d," ( ,t,' allY a..III.Jillhl} I..
the public. with address ilnd pme.
11..20. SECURITY CLASSIFICATION
DO NOT submil cl4lsslfied reports 10 the Nilllon... Te!:hnlcJllnformatiun \Crv!.:e.
21. NUMBER OF PAGES
Insert the total number of pages. including Ihls one and unnumbered p3gcs, hur e"dud!: dl,trlbutlOn "", ,/ ,/nY.
22. PRICE
Insert the price sc=t by the National rechmcal'nformation S.:rv!.:e ur the GoYernment Pllntlng Olfi.:e, " knuwn
IEP. ,..... 2220-1 (Rn. ~-77) (Ru....)
I .
-------
SUPERFUND RECORD OF DECISION
American Creosote, FL
ABSTRACT Continued
The selected remedial action for this site includes excavation of all
contaminated soils and sludqes. 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 Aqency will consider a second operable unit which
will involve the selection of an alternative for the Management of Miqration
of contaminants in the ground water at the site. Operable units I and II
will be the basis for the site's remedial design.
-------
REXDRD OF DD:ISICN
Remedial Alternative Selectioo
Operable unit I
SITE: American Creosote Works Inc:., Pensaoola, Florida
NPL CEIaA Site
~ Reviewed
I am basing nri decl.sim upc:n the folloring documents describing the analysis
of ooet-effectiveness and feasibility of remedial alternatives for the
American Creosote W:rks Inc., Pen8aa)la, Florida.
- Remedial Actim Master Plan
- Remedial Investigatim Report, Volumes I and II
- Feasibility Study, Vol\.m!S I and II, with addendum
- R8spcm8i veness Surm8ry to Public: Meeting and Rau....111~ticms
- Surm8ry of Remedial Alternative Selectim
D88criptiem of Selected Alternative
After a tharcugh review of all optia18, I have determined that. alt.ernative
p--yo 2, .as detailed in the Feasibility Study and described below, is the
awrq,riate rei,~ far Source Centrol Measures at. the site. 'Ibis alt.ernative
will be identified as ~le unit I of the lau.,dy and will result in:
- Ocm:andnated soils being excavat.ed fran areas off the sit.e
to be managed with cxmtaminated soils and 8ludges £ran areas
em the site.
- '!be a:nsol1dat.ed contaminated soils will then be mmaged em the
site CXln8istent. with ReM standards.
- '!be State of Flarida wiU evaluate Whether use of other alternatives
18 poesible far particms of the cxmtaminat.ed material presently awit.e.
~. alternatives WtWd be 1nplement.ed threugb use of the State
Fund or a ari:d.natim of the State Fund and CERaA. '!be Stat.e' s
intent is to carplete this activity within 30 days £ran the receipt
of available envira1ment.al infarmatim.
P\Jt:ure Actia1s
At a later date, Operable unit II will be required Which wiU constitute
the ~'8 offic:ial selec:t1m of an alternative for the Management. Of
Migratia1 of ccntami.nants in the groundBter at. this sit.e. Operable units I
and II will then farm the basis for the entire site's Remedial Design.
[I .
-------
Declarations
O::I'1Sistant with the Oatprehensive Enviravnental Respc::nse, Catpensatioo,
and Liability Act of 1980 (CERaA) and the National ContiD:Jency Plan (40
CFR Part 300), I have determined that excavatioo. and oonsolidatioo of
ca1taminated soils and sludges for placement in a landfill constructed 00
the American Creosote Works Site in Florida, is a (X)8t~ffect.ive rerredy and
provides adequate prot.ectioo of p.1blic health, welfare, and the envira1ment. .
Based en available infarmatioo, the renedial act!oo does not adversely
affect. 8rr:I floodplain or wetland areas.
I have further cSetennined that. the State of Florida has an independent
Fund and may cboose to handle porticns of the cont.ami.nated material through
other than land disposal cnsite. '!he Remedial Design will inoorporate State
. Funded and additiaml a:rctA act! vities as agreed to within a Cooperative
Agreement or Contract in order to proceed.
I have also determined that the actien being taken is appropriate ~en balanced
against the availability of Trust Fund ncnies for use at other sites.
SEP 3 0 1985
am:
~Zi.&
JaCk E. van
Regiooal Administrator
EPA Regien IV
I .
-------
EIMWt{ CF R!MEDIAL ALTEaU\TIVE SELECI'IOO
. SITE u:rATICN AND DESCRIPl'ICN
'1he Arrerican Creosote Works, Inc., (AOJ) Site occupies 8J:ProxiJlately 12 acres
in a IIDderate1y dense, cxmrerciAl and residential district. of Pensacola,
Florida. '!he site is located about me mile' 8CJUt1west of the intersectioo of
Garden and Palafox Streets in dcM1t.cM1 Pensacola and is approxinate1y 600
yards north of Pen8aoola Bay and Baycu QUoo. Imnediately north of the Site
is a 1unbr CCI!pU1y, an auto boc!y 8hcp, an appliance eales and repair shop
and a wire 8t.arage area. Resident.i.a1 neighboIboods are imaediatelyadjacent.
to the Site 00 the eut and IIalth and a yac!1t eales 8hop is 8aJt1M!st of the
Site. '1he residential Y'P,1At.ia\ within a me mile radius we approxiJrete1y
5,000 pe1'IICm8 in 1970. '!be approxinate Y'P'J"tim in the area of the site
-.s 1,056 in 1970. A tot.al of 404 dwellings units were present in this INIIte
area in 1970. Figure 1 8hcMI the. generallocaum of the N:W Site.
'1b! IIDre pertinent features of the aite are 810m m Figure 2. '111e site is
8baJt 2,100 feet ],a,g, east to west, and an awrage of 390 feet wide, north
to 8OUth. Prinary access to the plant is off Pine Street at ita interaectial
with "J" Street. A railroad spur line of the Bur1ingt:.a\ !brthern Railroad.
U8ver888 the plant west to east. 'l'he -jority of .ite buildings, process
t.an1t8, end 8JUipIent .. situated near the center of the site in an area
designated as the ai.n plant area. A fw III'Bll worlc sheds, miscellaneous
8JUipIent and debris Ue about the nma1nder of the site.
Pa1r llUrface ~ were lacated in the westem p:rtia1 of the site.
'111e Main and Overflow Pcnda, located adjacent to "L" Street, were used for
d18p088l of prooe88 wutes and are 1.8 and 0.9 acres in .ize, respectively.
bu:i.ng fo:mer plant cprat.!aw, liquid wutea periodically overflcwed and were
"4rawn-off" fraD the two larger ~ts end allowed to acc:uIL1late in the
8IIaller Rail%'C8d ~, 0.3 acres, and !bIding Pend, 0.1 acre, or were
apread al the gramd in "spillage areas."
SITE HISTO~
~eeerving ~rat.ian8 W8re carri815 aut at the 101 Site fraD 1902 \mt.i1
~.ler, 1981. Prior to 1950, c:reoeote was ucluaively used to treat poles.
Use of pentac!llor:qtlenol (PCP) 8tarted in 1950 and steadily increased in the
later years of the ItDI1 ~atiaw. lUring its years of cperatial, liquid
prooe8s wute8 wre discharged into the two unlined, a181te 8Urface 1npcund-
1II!nt8. Prior to abc:ut. 1970, watewatera in these ponds were allowed to over-
flow th%tIucl\ a spillway and follow a drainage course into Bayou ou.co end .
Pensacola Bay. In 8Ub8equent years, wstewater were periodically drawn off
the pcn&s end cti.8d\arged to designated "8plllage areas" al aite. Mditiaml
diad1arges occurred during periods of heavy rainfall and f100c!ing, When the
p:mds overfla.led the ccnt.aiment dikes.
-1-
-------
1
N
,
: " '",iI,~ J . ~ 'itt;n~jm~-i!. I,tr,'''",.t.'t,,',J.)i (,,'r;r:r",. ":\'\:"h.t.~~;,1:"~.,, .---:7~
' , :MI~.. I 'I' ,. '''-' .' . ~J~'fl L t' '. ~ \., ,~, "f F~. '1 h.J /
'5 ~A" r~"NC;I~~~\,:p ,",;~~::::~- '. ~ L'Ut - . . ~-~I t.lrJ:~f1, '".J.~lf,. \1.. ~ ~\." l~~,IT' ~' N
... .~..:. .:."'~'~>'I' 139 ,'~:~,~ .~~,:~' . ~t-J,~ iij"tL".f.I:;r'I-"'~!,f" 1~~"'J",' ,~\' :.~'\~' f'~~~,!. \,'." r
" . ., .....,', """: ,"',. ',..,~ ,. _1 ~ {'''I'' I ..' ''''('6 . \'
. ' , '" ":,~.,,,- . '., : l I " ~""43 ,.h 'of.,.~ r "
" .' ,. . '. 'r -- 'I~ .., I 4 ~ \ J'-'r..",.
. "" ~ ,,"'" . ; - . ..-." II ! ~ Jiit \ , .' I S,;~
:. I .. , ~.L" l~' . I~~ .~..:~. c::», 101.: ,J ,: ~ . \ ,,'~' ,IJ'- ~\\ \ . .' \,. ','
.... .,t""'- t ,\ Joe .,...." .' ' ,..: ~ '! .~':!r: ~~~: q';'" ~ - . ." ,J"" 'o', r. L. '~'l ~ \. " \ t.!' " .,',
'. JR : t \ "(t~N$AC61..A . .",'; .'lii!!.~ <:'1, fa, ,. Ft' ..d.:.I- ~.. ~_I.. II' , . ''t'~l'''~ . .t~""HJ' .\ '..'.\ ,;~,.~ So
;',' ~~",~,~~O ~ . '\: : 'i - '''0'' .( ~: J"'''' ,,! d , i -, f--! :;: -., 'ft:.f. ..\. ,~~4t " ,~~ ~'" "\i;j...i~.ti ~ ~"~~"', .
"r':': ~ c '.,' ;.~ '1,/" ' .. C '.'" r 1'1 ~. ' , AMERICAN CREOSOTE WORkS,lNC, \:'~~,. ,: ., r; ~r~:
. ~, \.". ;~~=r\..,"~~ ~:"..:.I..IM' . I-J .".''.!-l;,IJI'~..I', -~~~:.~~. if-, k,'5. ~>.. .
, ~ "~I ' ,. ...r, J ,. -... , ;;h,:.J. . .. . ., . f -...... '. .
."..~ ,." ;"~;""" S I' " 40 .. i,:' ..,f ->,'~" '. ~ ': '.. _It.t l ~Jtf;:~ ~, ',,,' ; . \ :~tJ ~= ~,J.,;:!~' '.:: r_........ '
"""" ""-... 4C 5, ',;. ef' - . '. . '. - ~f ( '" 8,. ~ i\ '. ....; ". : ,'''.' ""II.....
\'0'" ,,~r""''''\'n \. '~~- ,......!.t:~:rt 1)" " 11.',.. ,~~). i~$ 8 ., \):-,', N .:."-. ",,;.. "",'
.,,-.....,.,....... ,--~,- . ~ O",~ .t' " ..; r r:a II J. I ~", "...:::::::.-- ',,',J, \:_....:~
....:', ~ .Y i ,".f-~A. , ~" , ;,' ,,', .. ,..--
'.. 'fi\ 1". 1.. .." J
'.',.." . ~I .. 'b. ':i ',,, -"';4;;',., tr;i"{.,1- '.!-~~~ .t ..."r" .,."",,,,
, .. 'h '. . 49 ~ G. z' . .'¥' ,-"-" ... ". l
't ~ . . III'" . II'.' '.) e..ch c:"""
.t .' I: Q. . ...,' 'l , 1 .
t" , 'II""'.'.....W 47 . .~ " . , '.
IIW(;OI'I ~ " :I. ,.. :t.' ,
. . ~., . "'. . ~. ' : "..:>r'~ ,,/' \
, t ,. , ~ 4 1m) -- ,/ \
'" " ;.::.. ..-; ,~} l ~'F \
. . I ~ ,:,...' ,. ". , ,
~ ' "we ~ . .' 11--~ '.
...- ~. . ,.' 'fjo ,
....... ... ,
J."" , ...' ,
. >/ \
,
-. . "
(.0 . , 0 1000 2000
.. . ......... ~,., . , . I I
,p"'" ' \ SCALE IN FEET
. ,
BASE MAP" A PORTION OF THE U.S.G.S, PENSACOlA. FL QUADRANGlE 11.5 MINU1'£ SERIES, 1970, CONTOUR INTERVAL 5') AND A PORT1ON OF THE W~ST PEt:
SACOLA, fL -AL QUADRANGLE It5 MINUTE SERIES, 1910, CONTOUR INTERVAL 5'J, . FIGURE 1
PENSACOLA
BAY
PO
.
...
,
-
,
,I ""1
t
PO
.,.
..
. .
n
1
.
~
~
...
r
--
~~
n
1
.
&
I
PO
r
LOCATION ..MAP
AMERICAN CR.EOSOTE WORKS' )SITE. PENSACOLA. FL
SCALE: ," = 20Utt
L-1J-I~L ..3
11 ":J()RATIO
t!\ " I'....... ,I'rrnn~nrnn~~
-------
II
II
II
II
1\
~".
~
Dde
j
~
,...: ~
,III' 'to-
,~ :; \
GIMBLE STREET
-- I
. MAIN~ND ~RO AREA..... ....ot
,/' i;;;:;;:OfMP(XJM)M£Nr_- .~
.,.-
.., PINE. . , STREET
'. .~'''. . .'... . ~ . . . .
':"~~"'~';':,..' "',.:'.",,, :,'. ,...; ; ~,
':."'~"'\.~"::. <;,':~.j.< ~:' :':~': .'. ~I
~.:~),::. : : /,; : ~~':~". ,::':. ';;' "~~Ri~s. .. STREET
to-
W
W
~, ex:
~"" to-
U')
"-
I
, .
ti
&&J
a:
to-
U')
.,
to-
W
&&J
a:
to-
U')
. .'.
..~,
J.
!to ~
i I':~
YACHT CUJ8 ~" ~
"'''OPE''7 I' .~
~ "
! ;
.l..
SONIA
STREET
~
'7 14 914'(
ftNS14CO\..
8.4 "'ou CHICO
LEGEND
o OFFSITE REMEDcAL AREA
FIGURE
1:'
GENERAL ARRANGEMENT
AMERICAN CREOS01E WORKS, I NC.,S ITE, PENSACOLA,FL
NnT Tn ~rA' I:'
-3-
:B=JNUC=
I H ...
I , I ~~TIOf'\
. Com
- . ~ A Halliburton pan)
I ' .
-------
In Mard1, 1900, cxnsiderab1e quantities of "oi1y/asphaltic/creosotic JTBteria1"
were found by the City of Pensacola in the gramdwater near the intersection
of "L" am Cypress Streets. In July 1981, the u.S. Geological SUrvey instal-
led nine groundwater m::nitoring ~lls in the vicinity of the NJIl Site.
Sanples taken fran tOOse wells revealed that a CXI'1taminant p1\ne ~ lIOVing
in a lIOOtherly directioo ~d Pensacola Bay. In February 1983, the Site
Screening Sect.ioo oa1duct.ed a SUperfund investigatioo. '!he investigaticn
included sanpli.n;J aOO analyses of oosite soils, wastewater .ludges, eediJrent
in the area drainage ditches aOO existing ausite aOO offsite ncnitoring ~lls.
Qmcurrent with this investigatioo, the USGS initiated a site and latoratory
research study. ..
Because of the threat p»ed to h\mm health am the envirammt by frequent
owrfl0W8 £ran the ~ pc:nds, EPA, Regicm IV, &rergency Re8pcmae and Cbntro1
Sectim perfoDlBd an iJmediate cleanup during Sept:8Iber to 0C'tcber 1983. 'lhe
ilmediate c1earop '-'On included dewatering the t1«> large la9XX18 (Main and
Overflow 1Q}ds), with the wter being treated via ooagulatim, 88dimentatim
and fi1t.ratioo with 8Ubsequent. di8c:harge to the City of Pensacola IIeWer
1IY8t8n. '1he .1~ in the la9OQ'1 was then 80lidified with tiDe am fly ash.
A tstporary clay cap ~ placed OYer the 80lidified D8.terial. '1he Florida
Department of Envi~Al8:l1tal Regulatim (FDER) also Hsated during the clean-
up. In Jamuy 1984, a remedial inveatigaticm and feuibility 8tudy under
CEIaA wu initiaUld by EPA's contractor.
SITE ~
'1he 101 8i te i8 located in the Gulf Q:8stal Lowlands of western norida. 'lhe
Site 18 nearly flat, with e1evatlma ranging between 12 to 14 feet above sea
level. '!be land .1opes gently 8OUth.rard at about. 25 feet per mile t:oerd the
Pen8aCDla Bay.
'Dw Federal Dtergency Manag8lent 1qercy (F!I9.) Flood In8uranoe Rate Map
(FI~) indicates the tomdariea and elevaticma of the 1()().-year floodplain.
SUed em the FIRM, the l()()...year floodplain i8 not located within the 101 Site
arM am will not be affected by rencval or aource centrol types of act.iCX18
at the .ite.
local Geology
'Dw vat.er-bearing ~ \D3erlying the NJIl Site area 18 o...,~ed pr:iJrerlly of
And with aany i.nt.erbedded layers and lenses of clay and aan::!y clay. '!hese
clay layer8 and lenses ran:Je £ran 188s than an 1nd1 to approx:i.nBtely 38 feet
in thickne8.. Based Q1 characteristica of the aand8 in these areas, the
wter-bearing zcme can be atratigrapucally divided into two areas.
'!be Mnc! in the \JR)er 25 feet of 8edinent varies in grain .1M &an fine to
coane and in density £ran loo8e to dense. 'lhe8e variaticm in grain .ize and
density are irrportant, 8ince these are a factor in the seepage rate of water
thra.1gh the aediment. Figure 3 presents a generalized 8tratigraphiC colurm.
-4-
-------
- 20
- .0.
.- 10
.
J
.
.
.
I .80
!
i
z
- -100
~
~
<
>
W
-'
W -120
.'''0
o
-'80
-180
iT ,.1 .~;... Of'
1If.~li~it;!
':~':.:.:::'::':~.:.:::.~::':~:'
......,.....:"...::
~
.
'- ,. .. ~..,...";\'., .
SAND (SP-SM) - white to
dark brown, loose to verv
dense, moist to saturated,
with trace to some silt
CLAYEYSAND~C)-duk
gray to light brown (some red
and purple), loose, dry to
saturated, some silty sand
CLAY (CH) - white to blue-
&ray (same red, brown and
purple), medium stiff to hard,
dry to moist
Figure
3
GENERALIZED
STRA TIGRAPHIC
COLUMN
American Creosote Works
Pensacola, Florida
-5-
-------
'!here are two nassive clay formaua1S in the water-bearing za1e in the area
of investigauoo. 01e clay layer is directly under the ADIl pa1ds. '!his clay
layer ~a.rs to be CD'lt.inuous under the 1CN p:n:'1 area, altho.Jclt it does
pind1 art. 8CUth of the 8ite. South of the 8ite, a eeccnd nB88ive clay layer
underlies the Pensaoola Yad1t Club prcp!rty and exteros south to the Pensa-
cola Bay. 'nUs aeccnd clay pinches art. before read1ing the NJIl Site. 'n1e
results of a gramd pentrating radar IIUIVeY have 8hown mmy d1annel depoei ts
in the ai te area.
Surface Water
'1b! c5cminant body of ..ter in the 101 8ite area i8 Pensacola Bay. DJring
rainfall eV8nt8, IIC8t runoff £ran the .ite passes through the 8t.reet and
8t.onn drains to the bay.
~ i8 a 8Itall drainage ditd\ em the Pen8aoola Yacht Club (PYC) property
directly south of the 101 .urface hp::JUn&tehta. '1be drainage ditch begins
approxiJ1ate1y 200 feet 800th of Cypress Street and extends to the bay. Al-
thcu~ the drainage ditch 18 fed by 8CIft! runoff £ran the land .urface during
rain, JlC8t rec:harge of the ditch 18 fran the groundwater. '!he botton of the
ditch 1.8 below the t.q) of the ~ter table.
'1he Penaaoola Bay uert.a a tidal effect em the drainage ditch. Iming high
tide., ..ter flc:M8 into the ditch, flCMing north £ran the bay. th!n the tide
recedes, w.ter flCWII 80Uth to the bay £ran the ditch, creating a 'washing'
effect, Where the CDttaminant.8 that have collected in the ditd\ are washed to
the bay.
Hydrogeology
In 80Uthern E8canbia County, practically all the fresh groundwater 18 obtained
fran the And-end-gravel aquifer. '1he aquifer 18 recharged by local rainfall.
BecaUH of the 8alX!y nature of the aquifer and cwerlying 8Oi18, infiltratioo
rates are relatively high. Anrual recharge 18 0 to 10 :1nches per year.
'1he direct:.iem of groundwater f1.cw 18 to the 8C11th with di8d1arge to Pen8acx)la
Bay. '1here are no pJblic water 8Upply wells in the imnediate vicinity of the
IDl aite. '!he c1o-est well field beloogB to the City of Pen8acola, located
approxinately a mile north of the .ite. '1be cone of influence of tnese well
does not read1 the NJIl Site, and are not effected by the contaminatioo £ran
the N:J1l Site.
Surface Water Drainage
Drainage at the Site 18 not well develcped. tblt drainage in the area 18 by
overland 8heet flow throu~ the .treeta and into atonn drains aarth of the
site to Pensacola Bay and by ..y of the drainage ditc::h Q'1 the Pen8aa:)la Yacht
.Club prcperty.
~
-------
Ecology
'!he /tOl Site is located in the Pensacola urbanized area. ~tatlon around
the site consists mostly of cultivated grasses, trees am shrubs. 'n:ees in
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, raCCX)ns and
()p)SS'-IDB occasionally entering the site, as well as urban birds species.
Sane shore birds fran adjacent marine and freshwater habitats sanetimes freq-
uent the site. Pensacola Bay and Bayou Chico represent critical envirorrnent-
al systems downgradient fran the /tOl Site. '!he ecosystem in these water
bodies has been stressed in the past due to pollution of these water caused
by industrial, 1IIJnicipal and stonn water discharges. .
K\Tt.E AND EXTENI' (R CXIm\MI~TIOO
. .
Table 1 s\ll"lNU"izes the chemical data gathered duri~ the RI and presents the
ccncentration r~s of the IIDSt frequently occurring conbminants.
Waste Cbnditions
Li~id and slwges umples taken frcl'\ the ensi te surface ~ts durirg
an EPA investigation in February, 1983, revealed the presence of 1,1,2,2-
tetrachloroethane, chlorcbenzene, ethylbenzene, xvlene, styrene, pentachloro-
phenol, and l,l,l-trichlorcphenol in the aqueous phase and PARs associated
with '«XX! preserving creosote PLocesseS in the sludges. Various metal were
also identified, inchding al\l1dm.m, arsenic, copper, iron, manganese, and
zinc.
A stJ.dy conducted by the Qwirormental Response '!\t81'l in June, 1983, determined
the ~wsote distribution in the main and overflow pxx!s by cbtaining sl\D.;Je
cores and visually observiDiJ auch characteristics as slWge thickness, total
col\lll\ height and other physical characteristics. "lhe volune of sl\D.;Je deter-
mined £ran this study was ar:Proxhnated at 107,300 cubic feet for both ponds.
the ..ter depth noted in the t'lO px1ds during this investigation -s about 4
feet with a ..ter surface about 2 feet aboYe the 8\.IrrCU1ding grade. '!\tsts
inUcated that the cont81'linated 8l\dge is in direct and constant contaCt with
the shallow groundwater table.
'!be slldges in the ~nds were de-watered am then Iftixed with lime and fly ash
and a tEll'lJP)rary clay cap was 'placed ewer the solidified material left on site.
As a result of the imnediate cleanup, the pond areas contain 40,000 cubic.
yards of material consisti~ of a mixture of sludge, fly ash and lime, and
24,122 cubic yards of clay used for ~irg.
-7-
-------
TABLE 1
RANGE AND FREQUENCY OF CHEMICAL CONTAMINANTS
IN VARIOUS MEDIA
AMERICAN CREOSOTE WORKS, INC.. SITE
ALL C~NCENTRATIONS IN mg/kg (SOILS) AND }lglI (WATER)
SOliS Groundwater Sediment
Concentrltion Concentration Concentration
R.nge .nd No. R.ngt .nd No. R.ngt .nd No.
COht.ml"."t Of Observ,tlons of Observ.tlons 01 Observ.tiol"lS
POlvcvclic Aromatic Hvdroc.rbons (PAHs)
b.nzo(.).nthr,cl"' 1.8-870 (16) 7.300 (1)
b.nzo(.)pyr.n. 1.7-1.0 (10)
b.nZO(b)fluor.nth'"t 8.2-.80 (17) 1,300 (1)
benZO(k)1Iuro."thent 7.9-8.7 (2)
chrySt"e 5.6-750 (19)
anthracene 7.2-1,600 (17) 8,.00-.30,000.(2)
b.nzo(ghi)ptryllnl 5....20 (5)
fluorenl 7.1-1,800 (13) 50-1.0,000. (13) 5.700 (1)
ph,n.nth"n, 5.7-29,000 (21) 30-1.300 (10) 20,000 (')
dlbtnzo(.,h).nthr.ct ne 7.8-91 (2)
Inctt nor 1,2.3-Cd)pyrtne 8.1-210 (5)
pyr,ne 7.2-9.000 (29) 2.200 (1) 15,000 (1'
Other Acid and BlSe/Neutr.1 OrQ.nics
.c.n.phth.". 7 .3-6.900 (12) .0-140,000. (12)
fluor.nth.n. 1.1-10.000 (30) 60-2.700 (3) 18,000 (1)
naphth"ln. 7.-1.100 (7) 35-580,000. (17)
dlb.nzofur.n 58-880 (8) .5-660 (6)
2-m.thylnaphth.lenl 39-5.0 (7) 35-3.&80 (8)
Plf\tlChloroph.nol 7.2-2,500 (10)
VoI.tll, Oraanlcs
b.nlln. 0.0.-0.13 (3) 6-150 (15)
Ithylblnllne 0.03-0.26 (5) 15-110 (15)
tolu.ne 0.01-0.22 (7) 5-150 (15)
.Cltonl 0.08 (1) .00-2,700 (8)
a-xv'.n. 0.01-0.35 (10) 5-2.0 (16)
P.stlcides
b.ta-BHC +0.66-0.9 (5)
Indosulfan ..0..7 (2)
. On. r.pon.d conc.ntrltion @ 230.
.. S.m. IImpl. IS .bOYI 12 \,1;/1
. M.y b. in Irror due to nonreprlSentive d.t.
e) Frequency of chemical found.
-8-
-------
Groundwater Contamination
Data gathered duri~ the RI indicate that qroundwater contanination extends to
an approximate depth of 60 feet below the grouoo surface and at least 900
feet south of the site. 'ltae data show that major contaninants in the ground-
water are aranatic hydrocarbons CCJmY:)n to creosote, such as, polycyclic aro-
matic hydrocarbons (PARs) and benzene, ethylbenzene, toluene, and xylene
(BTX). Other contllT\inants that have been identified lnclooe methylphenol,
carbazoles, pyridenes, quinolenes, styrene, acetone, naphthalene, and a few
oesticides. .
1he data indicate the groundwater contanination is greatest south of and
imnediately adjacent to the fonner surface impourdnents. ']he data also
indicate the contamination generally decreases with depth at each monitoril'YJ
_11 cluster am that contamination generally decreases downgraU ent of the
site. At a depth of 20 feet contauination decreases as the groundwater mcNes
south of the site toward the bay, this is further verified at the 60 foot
depth. Q)ntaminant reduction is most probably a CXIIIbination of adsorption on
8:>il and sediments and renewal by mixing with surface wter. 1he drainage
ditch area south of the site receives most of its recharge fran the ground
wter. Bence, contaminated groundwater may be mcNing rapidly toward the bay
as surface runoff. '!he effect of surface water EU'X)ff is enhanced by tidal
backwash, which 'washes' the ditch area.
Soil Cbntanination
Onsite soil sanples show that the areas where ~preserving operations were
carried out are contaminated with PARs. ')he data show that the primary soil
contaminants are the higher molecular weight PAR species, anthracene, benzo-
(a)anthracene, chrysene, fluoranthene, benzo(a)fluoranthene, fluorene, phen-
athrene, pyrene, am benzo(a)pyrene. IDler aQU8OU8 solubility and higher
affini ty for adsorption on 80il 1s to be expected for these canpounds.
'!he analytical data also 8how t"O different patterns of soil contamination in
the AOIl soil sanp1.es. Sanples taken in areas 1,2,3,8 and 9 show a generally
decreasi~ deqree of contauination with depth and a total base/neutral frac-
tion content of less than 500 Jrg~ in all MftPles, while umples taken fran.
areas 4,5,6 and 7 show a less distinct variation of containant concentration
with depth and a much higher total concentration of organics. Figure 4 ill-
ustrates the locations of these areas.
Offsite sol1 samples sheM that various PABs, similar to those found in the
onaite 8011 aaaples were identified in the area representing the northeast
comer of the PYC. Based on the available data, it appears that soil contam-
ination on the PYC property is limited. Based on additional offsite soil
IUmples, collected in January 1985, it appears that there Is soil contanina-
tion on city blocks 179 throught 184 and block 162, i1rmediately south and
west of the 1DJ 8i te.
-9-
-------
if
iU
II
I
!
,'7~
10. '-IC-r. I
DI STREET 1
, I
II
II
II
J
SiREET
f1
~
~
I
I
.
14
STREET
~
LAJ
WJ
:t:
~
V)
&.
12.
CYPRESS STREET
~ ~
LAJ ~
~ ~
:t:
~ ~
V) V)
-:»
SONIA STREET
, I . .
. . . .
\ 'I.
I ..
f.
..
,.
v
:;;---
. . C.O\..~ CjtL'<
~E.NS~
-1
lJ"'YOU'C&J
" ICO
LEGEND
rlZZ2J ON- SITE SOIL SAM~NG AREA,19"4 - .
. OFF-SIT! SOIL SAMPLING A"EA,I'''4
. OFF-SITE SOIL SAMPLING AREA,IU'
--u- AMERICAN CREOSOTE WORKS,INC,
51TE 80UNDARY
All other aampling location. are diacu88ed in the RI Report.
FIGURE 4
APPROXIMATE LOCATION OF SOIL SAMPLING AREAS ~NL' E
AMERICAN CREOSOTE WORKS, INC., SITE, PENSACOLA, FL --=--
NOT TO SC~:':: . COF;PO ~nor
-10- 0 A Ha'hbunon Compa"
-------
9Jrface Water and Sediment Contanination
'!he data show very little contanination in the surface water of the drain~e
ditch. A possible explanation for this could be the effect of dilution fran
other surface water contributions am the tidal washi~ effect. ')he low
levels of contaninants in the drainage ditch would not pose a threat to h\.lnan
health am the environnent. '!he high chloride content in certain sanples
taken in the drainage ditch indicated the presence of seawater.
Sediment data fran the drainage ditch area show the presence of the PARs and
volatile canponents previously identified in the monitoril'VJ well samples.
1he high oil and grease Content of samples collected also sheM; the attraction
of creosote oil to the sediment matrix. it) contamination was founCl in the
sediment sanples take at the Pensacola Bay.
PtSUC RFALTH AND D1VIRafotENrAL RISK BVAIll'TIOO
E'n1irorrnental data show that ftl)8t contsninated materials are surface soils,
8Ubsurface soils and the sl\dge present in the batten of the main and over-
flow ponds. '!he major pathway for the migration of contllftinants is via
leachil'VJ by infiltratil'VJ, precipitation or grcurdwater inflow, follOllled by
transport with groundwater.
Contaminated sediment transport is also possible via an-face wat.er runoff.
'Ibis ~uld be confined to the drainage ditch running to Pensacola Bay. Trans-
port of the types of contaninants found in the groundwater under the AOJ 8i te
1118Y present the potential for ahort-tem bioaCC\lllUlation in the marine biota.
Because environnental pollutants resulting fran other eources could just as
easily be the oontsninant source, it 1IIOUld be difficult to differentiate
8DOng the )X)tential sources of PARs in marine, fish and invertebrates in the
bay.
In IRIIIMIY, on the basis ()f present. contaminant distribution, the D)St sig-
nignificant transport is through the movement of contlll\1.nants £ran the foaner
8ludge lagoons through and with grcurdwater to Pensacola Bay. A minor trans-
port mechaniln is the physical transport of cont.lII\1.nanted sediments in storm
EUnOff, also lIDVing toward the bay via the drainage ditch. Although air
transport is not likely, another minor transport mechanian could be through
8011s dust mcbilbad duriI'VJ E8D8dial imp].eentation.
A pmcess was developed to select the ~~s that most represent the over-
all 8ite hazard. '!he criteria incl\.,ed, significant health conseauences, the
frequency of occurrence and magnitme of the contaninants, data validation,
the availability of standards and known toxic and/or carcinogenic properties,
~ the relationship of the ~ to the site. Table 2 presents the
critical contaninants used for the risk asse8Sll'ent.
-11-
-------
TABLE 2
CRITICAL ~
FOR ASSESSl-INr OF RISK
.PARs
- benzo(a)anthr"acene - aoils, 88d1ment. anC! ~ter
- be1zo(a)pyrene in aoi18, anC! aediJTents
- anthracene in 8Oi18 anC! ~ter
- fluorene IIIJ8t frequently cSetected in ~ter
- phenanthrene in aoi18 anC! ~ter
- pyrene IftJ8t frequently found in aoi1. anC! groundwater
eOther kid/Bue/Neut.ral Fract.icr1 Organic: Cartaminants
- ~thene in gran:Mter
- flucranthene in 8Oi18
- DB;hthalene in water
- ~ in gran:Mter
- 2-tret:hy1nap\thalene - in ~ter
- pent:.adU.arcphenol - in 8Oi18
~latil. Ck'ganiC8
- benzene
- ethylb8nz8ne
- t.olume
- ~zylaw
in ~ter
in gran:Mter
in 80il an! groun&Iater
in gran:Mter
-12-
-------
Potential hurtBll I~pl.Ors include ocnsumers of ne.rine fish and shellfish, in
'-'dch &ale of the contaminates rray accurulate 00 a short-t.enn basis. ft)ten-
tially, the site could be a ccnt.rib.1tor of these ccntaminanta, but. rot neces-
aarily the 80le IIOOrce or nest significant contributor. RePer"~ .1 cleanup °
personnel DaY be exposed, if they have direct. ccntact with acntaminated
aludges, or contaminated dusts. Local residents Who rray ocme into repeated
contact with a:I1taminated soils and aed.immt nay be upoeed. Other potential
~pl.Ors may be childem ingesting a:I1taminated groundwater through lawn-
watering and other casual use of the residential wells.
POtential envira1mental recq;,l.Or include the groundwater, as related to qual-
ity and limitatioo 00 its use for all pm:poses. Anbient air may be a recept-
or in the CDttext of aesthetic factors. Another potential ° receplor includes
the marine flora and fauna as well as the Pen8acola Bay Where limitatioos on
its recreatiooal use my be i ~. Terre8t.ia.l flora and fauna my be a
Z'~Lar .
1NroJaMDn' ~
'!be earUest doc:\mmt.ed incident of a release of artf type £ran the IDIl plant
occurred in the 8dmer of 1978, When a apil1 of liquids floI.Ied a1to a nearby
atreet. and then a1to the property of a yacht sales a::IIpmY. A flood in March,
. 1979, resulted in a .imilar apill. '1his incident. resulted. in increased reg-
ulatory attenticn to IDIl by the Florida Departmmt of &1vi%ammtal Regula-
Ucm (mER).
ID1f filed an 1ncarp1ete appUcatial with the mER in May 1980, for the ocnst-
ructicm of an industrial waste'Ater t.reatDent 8}'8t8n. '!be mER i8sued a
Notice of Violatial (NJIJ) and orders for ocrrect.!:ve act.ia1 to 1LW in JanuaIy,
1981. '1bi8 enforcement act1cm 1ncl\ded an arder to cease ~t.iaw until a
pemit was iaaued. In additiat, 1D1f.. to IlUbait a n8taration plan, inatall °
a groundwater well aaUt.oring 8Y8t8D. and naDVe a:I1taminated. 8Oil8. In Janu-
ary 1981, the 1'DER OCIIplet:.ed a l:'66iXXwible party 88at'Ct1, a Utle aea.rd'1, and
a financial _esanent far the .ite. '!he PIER 1a8U8d a ccnsent order in
Marth 24, 1981, 1ncorporat.ing the tDJ nquirllllmt8 and 811Mng IDIl to contin-
ue ~t.icns. '!be Order included 8Cbedules far CCIIplet.ing cxmat.xuctiat of
the wastetater t.reatment ayst8D and far aeeting the other tDJ nqu1rementa..
'1hraJgba.Jt 1981 and°1982, the PIER encoUrt:.ered c!iffiallty with KIf'. carpU-
ance efforta. In Marth, 1982, IDiI anncunoed that it was going cut of busi-
neue In April 1982, the PEER filed a Petiticm for &Uor~.&t and IqD::y
Act.icn and a O::IIplaint for Pemanent. Injuncticn and CiVil. Penalties as a re-
8Ult of KIf'. failure to make progress ta.Iard CXIIp1iance. ~ aatth later,
in May 1982, KIf, Inc., of Florida, filed for rearganizaticna1 bankrupt.cy
court. 'D1e PtER prepared IIDticna cppo8ing the renDVal and the atay of its
C88e against. Anerican Creosote as well as proof of claim and a IIDtia1 for
default.
-13-
-------
In the s\.ltmer of 1981, the information reouired for the Hazard Rank Scorinq
(Mitre ranking) of the site was collected by Ek:ology aoo Enviroment, Inc. ~
an EPA contractor. '!he site was rank~ on September 24, 1981, and was prop:)s-
ed for the Natioanl Priorities List (NPL) in O::tober, 1981. It scored 58.41
points out of 100 possible points and now ranks 50th anongst 538 total NFL
sites nationwide. In Septenber 1983, the main am overfl~ ponds were found
to be within 1 to 2 inches of overflowinq. EPA initiated an iDmediate renov-
al action. EPA's cost for the imnediate rEmOVal to stabilize the site was
aRX'oximate1y $730,000
In 1984 the bankruptcy court presented a final court stipulation for the app-
roval of the litigants. '!he AGJ site would be sold after cleanup aro the
proceeds ~ld be divided amongst the PtER, the EPA, and the financial organi-
zation holding the corporation's assets, i.e., Saving Life Insurance Canpany
(as of ~y 1985, the court stipulation had not been signed by the litigants
1n the bankruptcy ptoc.eeding).
In March 1985, the 8Jrlington ~rthern Railroad was sent a notice letter re-
questirg that they perfoIm certain tasks on-site. Specifically, they were to
r81QYe, utilizing an EPA-approved 'A:>rX plan, railroad spur lines which exist
over an area of known oontSftination. O:ImIJnications with Iklrlirgton N:)rthern
repnsentatives since then iR1icate that the railroad is amenable to can-
pleting the ass1Qned tasks within the time fraDe specified.
ALTERNI\TIVE E.VAI.tP.TICN
A list of all alternatives considered are given in Table 3. Q\site alterna-
tives that canply with other environnental laws are listed in Table 4.. ~ch
of the r8')8dial alternatives has passed technology screening on the basis of
pblic health and envirormental concerns.. Fach alternative _5 waluatert in
texms of the extent to which the alternative ranediates or minimizes the pot-
ential health hazards am environnental iq)acts as identified in the RI
Report, Section 7. and the potential publ ic heal th impacts as a resul t of
implenentation of the alternative
"!'he 1"8'nedial alternatives developed were placed into one of the following
categories:
1) Alternatives specifying offsite storage, destruction treatment or secure
disposal of hazardous 8tbstance at a facility approved under RCRA. &Jch a
facility 81.18t also be in caapliance with all other applicable EPA staR1ards
(e.g., Clean _ter Act, Clean Air Act, '1bxic Slbstance Cbntrol Act).
2) Alternatives that attain all arolicable or relevent Federal J'Ublic
health or .""iromental staR1ards, guidance or advisories.
3) Alternatives that exceed all a~licable or relevent Federal public
health or environnental staR1ards, guidance arwj advieories.
4 ) Alternatives that meet the CERCIA qaals of preventing or minimizing pre-
.nt of future migration of hazardous s\bstances, but do not attain the app-
-14-
-------
General Response
Action
No Action
Pumping
Containment
Diversion
R.moval
Onslt. Tr.atm.nt
Offslte Treatment
Onslt. Storlg&
Onsltl Disposal
Offslt8 Disposal
TABLE 3
GENERAL RESPONSE ACTIONS & ASSOCIATED
REMEDIAL TECHNOLOGIES
AMERICAN CREOSOTE WORKS, INC.. SITE
TechnolOQles
Site Monitoring (surface disturbance, monitoring wells.
surface discharges)
Groundwater pumpIng; dredgIng (sedIments In dra.rnage
ditch)
" Capping: groundwat.r containment barrIer walll
Grading; constructIon
ditches and berms
of lurface
water draln.g.
Excav.tlon Ind handling of Iludg.., lolls, .nd
I.dlments; Ind r.moval of railroad tracks, stored
drums, and debris
Inclnerltlon; biological, physical, Ind ch.mlcal
tr..tment
.
Inclnerltlon; biological, chemical, and physic II
tr.atment
Temporary storlge structures
Landfills; surface Impoundments; land application
Landfills; surflce Impoundments; land application
-15-
-------
'lftE
4
CI\f(CORI£S or MM(ow. M1["""''''' CCN'ON£"'S
D(VUOf'(O ran "I( I\M(mcNI Cm:OSOT( WORK$. INC. SI'E
("A CAUOOntES
R"""" Aft.........
COf'IpCN"""
lTabl' l-lJ
,. on",.
Me....11
2. A""".
S"nd.,d.
1 rllC88tII
S'enderd.
t. M.... CfllClA
GNt. 8", 00.. Not
AU.1n 5,.nd"d.
5. No Aellon
1. be.".',.'" b.c',.
.elecl locellont.
Not Appllcebl'
2. RIPe-., lJfoundw.."
'.c''''". .nd b.e"",.
3. "'CO"., g'oundw"".
.. No Ac'1on. ..." or
wlthou' monl'Ofh..
Oil.... "'JIIO'" 1ft
nCM lend..
S.m. ., AII"",.Iw.
CompOfrInt Ho. 1.
0"'''' "",0'"
IJ '0. roTW.
bJ 10 I"'ac. ."",.
cJ wi'" Of .18l1ou'
tr,..m,nl.
On.". dI,,oII' In ..eM
land'.
On"'.. ., AI'"n."'"
No.2. and ground....,,,
,...,ment.
.t ,.",...,......, '0
"qulr.d ...nd..-
'0' POTW dl.eh"",
.. ,..., '0 Nf"OESIW".
au,"" Standard. 'Of
'''Ich."..
ct '...'m,n' ,. 01".
...,. .,.nd.,d. 'Of
..lnlec'lon.
S.me II A'"mlllw.
Compon,n. No. l lbow'.
Hoe -...c....
'r88fmen8 of .....,-
wll" '0 drtn,,,,, .""
lIandard. .nd'I.ehar"
08' II".
Not Apo8lc:""
Hot AppIte IbI,
~.." ',..'m,",
lev". do not meet .n
wlrlow. ,r'.'m'n'
.'.nlllrd..
S.",. II Att,""I1".
Compon,n' No. l lboYl.
Not AppIIc Ibl.
Not Appllc.bl.
Allflllcibl. '" no Ie 110ft.
b'" do" no. m... C(RCLA
gOll. 'or public hullh
-------
licable or relevent standards. '!his ca~ry nay include an alternative that
closely approaches the level of prot.e<:t.im provided by the applicable or
relevent standards. .
5) No acUm.
All the alternative listed in Table 5 are assuned to include 1.cmg-tenn site
aadtoring and inspectia1 to verify cleamp levels and mintain the remedial
acita'l reliability.
Sane of the alt.ematives, notably thcee involving gramdwater treatment,
could fit into nultiple categories by IIDdifying the treatment process.
A tJ«>..phaBe ~s has been used to _leet the IIDIt ~\..I14iate r8nedia1
alternatives. Fint, an initial 8Creeni.ng of feasible tec:tmologies was used
1:0 .lim1.nate infeasible, ~opriate or 81Vira1nentally unacceptable t.edh-
nologies. '1bi8 8Cr88ning includes tec!mioal ccncema, instituticmal perfor-
~ and ooet criteria. Seoa~, t.echcnologies that pus the 8Creeni.ng are
evaluated indi vi A"a11y or CCIIbined to fo%m definitive r8nedia1 altemati ves.
Site data and waste characteristics were reviwed with respect. to eact\ tech-
nology to identify the tedm1cal criteria. Table 6-A 8baw8 limitatiCIUI of
certain tec:tmologies because of the physical 1.tm1tat.1a1 of the site character-
i8tics. 'I'able 6-B will limit certain tec:tU1ologies because of the limitatiCl1
of the wste ctvaracterietics. Other tedmioal criteria ocnaidered was the
reliability and perfamance of the tectmology, and the iJlplellentability or
hew easily the technology cculd be ~, operated and naintained.
ReIIedial t.ectmologies nust CDlply with inatituticmal criteria £ran federal,
8tate and 1ocal1ltancSards 1IIherever 8pplicable to the design, a:In8t:.rUc:tia and
~at.ic:n of _c!\ tectInology. Sc:IIe ccnsiderat.1a1e inclucSe but ate not limit-
ed to the following: a) Reeouroe 0:m8ervat.1a1 and Reoove%y Act (R::RA), b)
I1aticna1 POllutant Diec:harge Elim1natic:n Sy8t8D (NPte), c) State and Federal
D8p8rtm8nt. of 'l'ran8poratiat regulat.icma en the harIdling/ahipping and DBnifest-
ing of hazardauI ..ute, d) Local zca1ng and a:In8t:.rUc:tia permits and e) 10cal
pemits iaeuecS by pJblicly owned ueatD8nt. waEka (POlW).
'1'ecI\nologies that are an order of DBgnitUtSe or greater in ooet than other al-
tarnatiV88 are ecreened cut. "if the 1ncreued C08t offers no greater ntliabil-
ity or if the 1ncreued cost. provide8 no greater envi.rcnII!Inta or p.lblic
health benefit. '!his CXl8t screening is intended to rec!uoe the I'IJI'Iber of ted1-
nologies that are 8XOe88i vely CX8tly but does not replace the detailed cost
analya18 1br the alternatives 1'1!II8.1n1ng after the initial ec:reening. A list
of rernedJA~ alternatives remaining following the ec:reening procedures are
given in Table 7 and Table 8 list the r8nedia1 altematives. A total descrip-
t.ic:n of ead1 nmedial alternative is given in the Feasibility Stut!y Report.
CXMIJNI'N mATICH;
'lbree fact sheets have been issued to keep the public infoI1ned about the pr0-
gress of the remedial inveet1gatiat and the develcprent. of the feasibility
-17-
-------
TABLE 5
TECHNOLOGY SCREENING
REMEDIAL ALTERNATIVES SUMMARY
.AMERICAN CREOSOTE WORKS. INC.. SITE
Source Control
1.
CappIng of select areas.
2.
Excavation of contaminated onsltl aolls and sludge and IXClvltion 01
contaminated offslte solis and sediments.
3.
SurflCI watlr run-on/runoff controls It the alt..
4.
Clearing and grubbing of th. lite: .
. Remove rallrold tracks compllt., Including tie., except the main-line
within the railroad right-of-way, which may be temporarily removld It
.ellct locations and rlltored to facllltit. excavltlon of contlmlnat.d
loll.
. Remove trlSh and debris, Including abandoned equipment and foundations.
. Remove stored on site drums.
. Remove fUll tanks and service utility lines.
Options to 2, 3, and 4, above:
. a) Dispose of excavated ml1erla' It offslte RCRA landfill.
b) Dlapol8 of excavated matlrlal at onslte RCRA landfill.
Manla.m,nt of Mlaratlon
s.
Recover contaminated groundwater--collect drill lolls Ind mud.
6.
Clean and flush exl5tlng storm .ewers.
Options for 5 and 6, above:
a) Tr.at groundwater on alte and discharge trllted water to the bay.
b) Pretrelt groundwlter on .Ite and discharge to I publicly owned treatment
works (POTW).
-18-
-------
TABLE 5
TECHNOLOGY SCREENING
REMEDIAL ALTERNATIVES SUMMARY
AMERICAN CREOSOTE WORKS. INC.. SITE
PAGE TWO
d) Seme options IS listed 10r 2. 3. Ind 4 10r Source Control.
e) Collection end dlsposel 01 sediments end wlters from storm sewers on site
or off ,Ite.
No Action
7.
No letlon.
8.
No Ictlon with monitoring (Including drum remove I).
-19-
-------
Site Limiting O\aracteriatics
Exi8t.in:3 land U8e (zcned.
reeidential/licl1t cxxmerical)
Depth of CXI'1taminat.ed grourx1-
water plune (awrox. 60-80 ft.)
Site a:afiguratia1
D8pt:h to bedrock
Site area
1Iut.8 L1mi t.ing OvI.rac:t.eri8t.ice
a.aical a..~itia1 (PAHs,
88tal8 )
Tr8atability
QJn.~L cc:n1it.icm of 81\dge
IDIt B'lU ccnt.81t
BiocS8gr8&bility
Vblatility
TABLE 6-A
'IUtZ 6-B
-20-
Tedu101ogies Elim:inated
fran CDwidenat.a1
IncineraUa1: land IIpplicatioo
Subsurface ooll8C'tia1 ~ai.ns
tam applioat.ia1
Gr'ourDiater barriers
land applicatia1
'1'8ctmo1ogi- El iJ'Ii rmted
fran cawideratia1
P\8!ping and diac:t\arging to 8urfa~
water CZ' WI'P without treatment
a.1d.cal treatment. witi\ the
ucept.ia1 of orldatiCl1
~itu tr8atnBrt.
Incin8rat.iCl1
Biological treatm8nt by it.8elf
Air ex IIt:eam 81:ripping
-------
TABLE 7
REMEDIAL ALTERNATIVES FOR EVALUATION
AMERICAN CREOSOTE WORKS, INC.. SITE
1. Total Exeavltlon with Offslt. Disposal
Tot.1 .xeavltlon, transport.tlon, .nd disposal of all eontlmlnlted
mat.rlals, and the backfill of .xcavatlonl (I" Tabl. 3-2A). Dispose 01
.pproxlm.telv 83,000 cubic yards of .xeavated materilis off .Ite In a
RCRA landfill.
Supportlv. It.ml Inelud. cltlrlng Ind grubbing, r.moval of rallro.d
tricks, on,lt8 drums, debris, grubb.d mltlrlal, burl.d fUll tlnks, block
Ihower building, offic.-Iaboratory building, Ind oth.r Ibandon.d utilities.
Mltlrilis clallified IS hazirdoul will bl tranlport.d Ind dllposed off lite
In a RCRA landfill; non-hazerdOus materials will be dl.posed of locallv In
In approv.d landfill. Oth.r ft.ms Includ. grading, r.v.getatlon, and
Itorm wat.r mlnag.m.nt.
2. Total excavation with Onllt. Dilposal
'.
Total .xcavatlon Ind dllpolIl of all contaminated mlterlall In an on.lte
Iindflil. Thl qUlntltlls to be Ixclv.ted Ind thl qUlntltle. of various
materlall to b. ulld for con.tructlon of In onllt. Iindfill Ir. Ihown In
Tabl. 3-28.
Supportlv. - Items will be thl .ame I' descrlb.d In Alternative No.1,
IbovI; howlvlr, III matlrl.11 Ixcept the onllte drums Ind railroad tracks
.
will be dlspoltd on lite In the newlv-conltructed Iindfill. Onlltt drum. .
will b. trlnsported and dispoled off lit. In I RCRA landfill, whll. the
railroad tracks (ralll only) will b. lold al .alvagl.
Other Tables mentioned are presented in the Draft FS Report.
-21-
-------
TABLE 7
REMEDIAl AlTERNATIVES FOR EVAlUATION
AMERICAN CREOSOTE WORKS, INC.. SITE
PAGE TWO
3. 'Irtial Excavation with Offslte Disposal
Selective excavltlon', transportation, and disposal at grossly-contaminated
,'udges, onslte lolls, and offslt. ladlments, In In offslte RCRA landfill.
ExClvltion Ind backfill quantltlls arl II Ihown In Table 3-2C.
Supportive Items will Includ. fencing eround .Ite,
m.n.gement, Ind blclcfilling contlmln.ted city bloca
releedlng, Ind reveget.tion.
Itorm water
with topsoil,
~. 'Irtlll Excavltlon with Onslte Disposil
Sel.ctlv. exclvatlon Ind dllpolIl of grollly-contamlnited aludg.l, onslte
.0111, and offatte .edlments In In onllte landfill. The quantltl.s to be
exclvlt.d Ind the quantlt,e. of varioul miterilia to be UI.d for
conltruCtlon of an onllte 'andflll Ire Ihown In Tlble 3-2D.
Supportive Iteml will b. the alme II thole delcrlb.d for Altern.tlve
No.3, Ibove.
5. Altemltlve No.1 (II lilted prevloully), 'Iul Groundwater Recovery
Supportlv. Items would Includ. the following treatment optlonl:
. I. Pretr.at groundwlter on lite and dllch.rg. oft lite to POTW.
b. Treat groundwater on lite Ind dlacharg. oft lite Into lurflC. w.ter
body.
Other Tables mentioned are presented in the Draft FS Report.
-22-
-------
TABLE 7 .
REMEDIAL ALTERNATIVES FOR EVALUATION
AMERICAN CREOSOTE WORKS, tNC., SITE
PAGE THREE
6. Alternative No.2 (a5 listed prevlousIV), Plus Groundwater Recovery
Supportive Items would Include the .Ime treatment options II listed under
Alternative 5.1 Ind S.b.
7. Alternative No.3 (IS listed prevlou.'y), Plu. Oroundwlter Recovery
Supportive Items would Include the .ame treatment options a. lilted under
5.1 Ind S.b.
8. Alt.rnative No. . (IS listed prevloully), Plul Oroundwlter R.cov.ry
Supportlv. It.m. would Include the Sim. tr.atm.nt optlona la list.d under
5.1 Ind S.b.
I. No Action with Oroundwlter Plum. Monitoring Ind Ala.llm.nt .
-23-
-------
n........ Aft"""""
(T."" 3-11
I. Tot" fllC".'''' wIIh Offs".
Dispos" In . ReAA l.nd'.
2. Tot" fllC""1oft with On"'.
Oispos" In I ReM lend'.
3. ....... EIIC."I'1oft with Of's".
OiSpoS8' In I ReM land,,"
4. r... ,... hc."."" with Ons".
Dlspn~" In I RCRA lend''''
t. OftsIIe
"'.s.e.
Off.". ~ 8t
ReM l..,dfII
NA
Offs". 0tItt0t" ..
"CRA lend'.
NA
'MIl 8
SUMMMY OF' ..1Ii1OJW. MTtNMtMS
I\MEmcNI ~DSOf( WONts. INC. Sift
E'A C"""'"
I. "".....
S'and,,"
1 EIICMIII
Siandard.
"A
NA
""
"A
NA
-24-
M
M
M
4. M..,s CtRCtA
lO8Is but ...
!tOt In.
$land,,'S
8y 1toI..... of ..
.1.1. .ources ....
""'11"," of ""'...
.-net.II. cOftlamlne-
110ft. .. r~.
"".. ""'.e fIftpecIs
1o ,"""an and ..,¥Ifon-
M8ftt81 rec.ptor. wit"
lime
s..... IS All.".....,.
No. 1 lboY.
8y ........... of ....,
com""'""" SCMIfCH
and redvc'loft 01 ,,,,,,,-
I'-'CtWI'. COfttamlnl-
1101\ .... r~. 'uturl
eel.... Imp.d. ,.
human Ind ."""Oft-
men'" reuplor. wi'"
lime
s..... .. All_I"'"
No. 3 lboY.
5. "0 Ac'1on
NA
NA
ItA
NA
-------
IN11F. 8
SUMMMn' or ........ M1rNMfMS
AMfmeAN cnl:OSOII WOhItS. INC. SIlt
PI\GE two
tPA C8t......
.. Mee'l C(ACtA
1. 011... 2. All"'" lOe" but dIMI
n......... All......... 1~ not en....
.,..... 3-1. '-e...... 5'8ftd.'d. S.....,.... S'andardl 5. No "(lion
S. To." rllC.".11Oft ..... on,I.. on,-. 0I1fOS" .. Off.h. OIlPOS" OMI8.~IId""" "A "A
DI~pouI Plul Groundw.'.. Recowery ReA" l.ndfIII .. RCRA land"' tre8hMlft IChen18 ..
.IICHCt Feder" Pre-
....."'... 5''''''''' for
.... PO", .W8Iterne''''
.... ... 811CHCt 'OEII
w..., 011"', S'8ftd..
for 'M .... OIKtt8f,e
5."'''""",
8. 'ot" rllCn8tlon """ Ottll.. NA On.h. OI~" .. ...... n .. Menr8tIYe "A HA
Dlspas" Plul Groundw.'e' Recowery RCRA l8ffdlln Mo. S ......
7. r.rtl.. rllCn..1Oft """ Offs", 0II1It. .,...... .. Off.h. Dlspelill .. Sente n .. Att8II1811.. NA ""
Dllpas" Plul Groundwa'.. Recftery ReRA l8ftCIIII RCRA lendl1l Mo. 5 no..
8. ...rt'" (een.'1Oft """ Ofts". 1M On.'" 01",,'11 .. S.... " .. Menra1IYe "A ""
Dlspos.1 Plus G,oundw.,.. R,COYefY RCAA landml Mo. S no..
t. "oActIOn NA "A 1M "A AppIIe...... bu. doel
not "".. C(AClA
goIls 'Of public
heal", .nd !!n..lron-
mentll prOI!!clion
-25-
-------
study. 'n\e local press has been involved with the progress of the American
Creoeoste tIiJrks c:perations beginning before the site becMne an interest of
EPA or the Natiooal Priority List. A neeting was held at the Pensaoola Yacht
Club to inform the ftI!Iti:)ership of the findings of the remedial inYe8tigatioo.
'lbe Yacht Club is very interested in the developtent of their pE'Operty in the
form of cxnXmini\.M\ or yachting slips. 'n\e portioo of the Club'. prc:pert.y
that WOlld lend itself to such developtent has been established as oontaminat-
ed £ran the remedial investigatioo. A public neeting '4IIaS held to inform the
p:blic and present the draft feasiblity study of alternatives and allCM for
public cament. A respcnsiveness 8\mtIU'Y out.1ining the results of the public
cament. is attad1ed. Infomatioo repositories are established at the West
Florida Regional Library, the Pensaoola Junior Q:)llege and the West Florida
UUversity. 1I1en approved, the rec:crd of deci.sioo will be nailed to these
r8p:)8itories. .
REnJ I IN:> AL'1"ERi4ATIVE
Sectia'1 3OO.68(j) of the National Ca1tingency Plan (tCP) [47 FR 311801 July
16, 1983) states that the apprc:priate extent of I.,edy 8hall be determined by
tile lead 8IJ81'1CY'. select.ia'1 of a rsnedial altematiw Wich the eqercy deter-
8Ilnea 18 C08t-effect.ive (i.e., the 10W88t C08t alternative that 18 technically
f_ible and reliable) and Wic:h effectively mitigates and minimizes danage.
to and provides adequate prot.ectioo of public health, welfare and the 8'1Vira1-
ment. In 8elect.ing a r8t8dial alt.ernatiw EPA CD\8ider8 all 8'1Vireaa,ehtAl
laws that are applicable and relevant. SUed a'1 the evaluat.ia1 of the ooet
effectiveneaa of each of the prc:poeed alt.ernativee, the ccrmenta recieved
fran the p:blic, we ~---,.,eud Alternative n.mb!r 2 to be iJlplerrented at the
Anerican Creo8ot.e WorXa SUperfund Site. 'lhi8 selected alten'1ative will
addre.. all cmsita .urface and .ubsurface CD'1tamin&tia1 problems identified
in the R818dial InveBtigatioo Report.
'!'be lb-act.ia1 alten'1ative i. an unacceptable 801utia1 to the prob1sn at the
IDl .ite. EwIn if the 317 d1UI8 of drilling w.ste are rmD\I8d, the oart.am:i-
nated 80Urce naains in the 8'1Virammt wi t.hcut mi tigatia'1. U1der the to-
act.ioo alternative, CD'1tamin&tee would catt.ime to migrate off. ita and affect
the quality of the grc:uncM.ter. 'lhe ~a'1 alternative Wt11ld rot be
8C08ptab1e in JI88ting the objectives of mitigating or mi.ni.mi.zing the threat
to p.1blic b88.lth, welfare and the envi.ra'In8nt.
'1bJ8e nn8dial alternatives that suggest off.ita disposal of both the highly
and leaser CD'1tamin&ted 80il do rot meet the criteria for ooet-effectiveness.
Generally, the C08t related for t.ransporting all or part. of the hazardous
Jlateri.als to an approved Hazardcus Waste Management Facility is 008t~rcbibi-
tive. '1hia eliminates renedial alternative IUlbra 1,3,5 and 7 £ran further
CXI18iderat.ia1 ~I'" of the exoe8Bive coet without any greater protect.ia1 to
b.Jnan health or the enviI\.8I1&S1ll.
Rsnedial alternatives 6 and 8 are e1.iminated fran further oonaicSeratia'1 be-
cause these rened:ial alternatives address groundwater and the groundwater
i.sue has been deferred W1til ncre groundwater data can be gathered.
-26-
-------
1he remaining remedial alternatives (2 and 4) suggest either excavation of
both the highly and lesser contaminated soils or excavation of only the high-
ly contaminated soils for disposal on the ACW property. Based on the quanti-
tative risk assessment presented in the Feasibility Stujy Report, either
excavation r8'nedial alternative will meet the criteria for protection of
hl.lnan health aoo the enviroment. Table 10 presents the life-time Maximl.lTl
Risk estimations for the contanination identified on the site. 1he estima-
tions are based on a variety of .worst possible case8 assll'lPtions, all occurr-
il11 at the ume time. Each of the asslltlptions used in the Risk calculations
are also presented in Table 10. In reality, the true carcinogenic risk will be
essentially merc because a foot of clean soil will be backfilled after the
excavation of the contaminated soils, thereby, el iminatil'rJ all likely exposure.
A health and safety plan should be developed for any construction acti vi ties
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 (bntrol Measure in a landf ill that meets RCRA
standards. 1b achieve this will require implementation of remed ial al tema-
tift nunber 2. RBnedial alternative n\lllber 2 meets the criteria for protec-
tion of tu.man health, protection of the enviroment and cost-effectiveness.
'nIble 11 list the area to be excavated and the whmes for disposal and Fig-
ure 5 illustrates the locations to be -'dressed duril11 the implementation of
alternative n\lllber 2.
'1be design will include excavation of the:
1) highly contsninated soils onsite,
- existing pond areas
- old process areas
2) highly contaninated soils offsi te,
.- drainaqe ditch area on the Yacht Club
- a section of City Block n\lnber 184
3) lesser contmnated soils onsite,
- old pole storage areas
- cleanil'rJ and gnbbin, of the site
- contents of the 317 dNnS of drillil11 wste
4) lesser contmnated soil8 offsite
- City . Block n\.Dber 179 ~h 183 and Block n\ltlber 162
- Yacht Club property at the corner of Cypress and 'K' Street
Figure 6 illustrates cross-section of the landfill, ..mile Figure 7 depicts
an aerial view of the landf ill.
-27-
-------
-----------------
-----
~9
MT\X:IM.Jo1 RISK
Polynuclear Aranatic Hydrocar1:x:l1s & Benzene
AMERICAN CR!rS:)1'£ K>RJCS IN:., SITE
Maxim.1m Q:ncentratioo (m;/kg) Carcinogenic RisK
'Ibta.1 PAHs ( 1 ) Dernal (2) Accidential(3)
Al t.ernati ve Benzene ~1JI'e Ingestion
lb-Act.ioo B)O 0.13 5.6xlO-l 2.3x10-1
Part.ia1 Excavatioo 138 0.13 9. 7xlO-2 4.lxlO-2
Total Excavatioo 12.0 0.13 8.4xlO-2 3.5xlO-2
tJote: (1) '1he CD10entraticns tabulated are tJ1e ~tioo of the naxiJrun an:mIt-
rat.ia1 of the CXIIpCUnds found.
(2) Dernal exposure riaks were based em Table C-3 in the Draft FS.
(3) Accident.ia1 exposure rl8ka were based em Table C-4 in the Draft FS.
A88\.mpticns used in the est.iJretioo of the excess cancer ria'k associated with de~
cc:m:act are as fo1lCM1:
(a) All carcinogenic PAH'. used in the _timatiem of cancer risk have the
8Me carcinogenic potency as benzo(a)pyrene.
(b) A ~t.or will be ex;oeed to the ne.xinun cxnoentratia1 of carcinogenic
PAM '. OYer a lifetime (70 years).
(c) Lifet:.iDe &!mal aoil accmulat.ia1 i. 110,000 gran (Schaum, 1984).
(d) 1001 of the PAH '. are ab80Ibed ~ the akin.
(e) PAR'. do not degrade in .oil OYer t.1me.
Mditiooal ~ used in the eatinBtioo of the excess cancer risk associated
with acciciental inge8t.i.oo are aa follows:
(a) Body weight of a ctd1d i. 14 ki1Oylaire.
(b) !:xp:)8ure duratioo 1. 365
-------
T ABLE.l0
TABULATION OF EXCAVATION AND BACKFill
(TOTAL EXCAVATION-ONSITE DIS'POSAL)
AMERICAN CREOSOTE WORKS. INC.. SITE
OescrlDtion
,. Exclvatlon from Existing Ponds
Total - ClP, sludge. kiln dust. .nd lime. . . . .' 50,500 cu Vd
CI.y Cap (Salvage)
. . .. .
13.100 cu vd
N.t Qu.ntlty 10r Disposal
. . . . . . . .
. . . . . . .
.
2. Excavltlon of Contaminated Solis It Stl.ct Locations
Onslte
a. At 4.5 ft depth (sampling IrllS 4, 5, &, and 7)
b. At 2.0 ft depth (sampling Irea 9)
c. At 1.0 It depth (sampling Ire.. " 2, 3, Ind 8)
d. Exclvltlon 10r Iindfill . . . . . . . . .
...00 cu vd
OHIIte
e. At 1.0 It depth It Ylcht Club property
f. Contaminated .tdlments from "'1,- Street drainage
outfaU ditch on V,cht Club prop.ny
8. At 1.0 It depth (offalte I8mpllng Irl.. 0-1, 0-2,
.0-3, and 0-4 within City Blocks 178 through 184
. and Block 162) .
3. CII.rlng and grubbing 9.0 Icrn at 0.5 It depth
Total Exclvltion, O.n.r.'
17.500 cu Vd
. . . 83 .000 cu Vd
.........
Total Exclvltlon of Contaminated Mat.,lals for Disposal
.'
-29-
Quantity
for OisDosai
37..00 cu yd
10,600 cu Vd-
1,100 cu Vd
2,350 cu yd
3,500 cu Vd
800 cu yd.
20,000 cu yd
.
7.250 cu vd
-------
,
I
,
w
?
- .-.
mUM: 5
snB:1£O UJCATIONS FOR ~11ON OFCIDNT-tm
SOIL.SlUDGE AND SEDIMENT nOTAL £XCAVATION)
AMERICAN CREOSOTE WORKS. INt.. SITE. PENSACOlA. Fl
.
Il1O
.
rn~n~
OA~~
-
~
~ ""rn
-------
.-.-.............
-- -.....,. -,
A
.
.-
J
r
.. .
I
,
..
r'" .~
.
...r-KCncJII At... Mf. ,ntI"
IUU ,.. ad ""1'CI8I'''' . ~
~
w t
~
I -
t-'- .~ ~ -
,
,
I
. - C8ftII--.n ". ....
-...DrTt-"-,
~ [AIIf.. ,,un., PfeII-
_leU
"nn .t.......,.....
DId,,'. ea.- ~ or,.....
"'" 10 ....1
.
.
~
cI II
I w
.. !
.~
-- .. I
.. ~
~
.. .J
W
II
:z II
i .
III
X
.
o
10 40. '" 80 !DO 110
L""'ILL ca'AClfT - 1000 CY.
.
NO
--.10<
,
--~..',...
,-...- ".- co -,
A'
.
----
_._.'_D
...-"....
It"
.
MaL"1m- AT-- ..alnP'
~I " .10' -,...,. . Wt.,~
.....
6
0ftSITE lMDFIU.-TVPICAl SECTION A-A'
MlERlCAN CREOSOTE WORICS INC- SITE. PENSACOLA.FL
seAl.[ AS ,...
E!J~
o A~Company
-------
\
-I
J,
N
I
.P'
~ '1&
o
---
FfGUII£ 7
0NSItt LANDFILL
MlUtICAN CR!OSOT£ WORICS INC. Sm:. PEHSM:OlA. FL
- .
~-
KAt .. 'IU
-
.
E'lj~T~
o A HIIIiburtDn Company
-------
. .::;J
COOSISTEOCY WITH C7mER DNIRCHUNTAL lAWS
Alternative 2 will result in a disposal site bein;d constructed on the Ar:tJ
property to ICRA design standards. N1ile SCIfte contaminated soils will remain,
the potential for any health risk are well below the established acute toxic-
ity or the probability of injury fran short-teen eXJX>sure due to the relative-
ly low observed concentration for the critical contaninants. ')he selected
alternative will not effect any floodplaines and the wetlands area. We do
not anticipate any conflict with other enviromental laws. Table 8 smmarizes
the evaluation of alternatives with respect to other environnental concerns.
R8nediation for the groundwater is bein;d deferred until mre infocnation is
gathered. .'
OPERATI~ AND MAINrmAN:E (O&M)
A Pbst-<:losure and fbnitoring Plan is required under ReM. "lhe Plan provides
for the procedures, frequencies a~ technical considerations of 8uch activi-
ties necessary to pl['eserve the integrity of a capped disposal facility. '!he
estimated Annual Q)st associated with ~ration and Maintenance are presented
in Table 12, Alternative n\J'Rber 2. ~rat1on and Maintenance cost are avail-
able for Fund monies for a period of one year and the a.M cost follMng one
year are a responsibility of the State.
SCHEOOLE
'!be Cbrps of fhgineer will advertise for firms to conduct the renedial
design. awiew and selection of a contractor is scheduled for March 1986
with rEmedial design canpJ.eted by June 1987. Cbnstruction should ptooeed
imnediate1y thereafter am should be canpleted by July 1988.
PtmRE ACTICH;
At a later date ~rable t1'\it II will be required which will constitute the
1gency's official selection of an alternative for the Management Of Migration
of conblninants in the groundwater at this site. ~rable O\its I and II will
then fom the basis for the entire site's Remedial D!sign.
-33-
-------
'"'emit'''
""..n.'''' No. .
A"~'n"'" No. 2
I
\io)
~
I
C""'RI""
T.... bc.,,""" ""..
oflllt. "'I,osat
Cl..."" .nd """""-=
d''''''L d,bff.. tr.ck..
0''''' ",Isc.leneou,
r.lItOYII:
I' ICIIn9. ,."......Ioft.
.nd lIor"'w.'" "tin......''''
Tot" .IIC.,,""" whIt
on"', ,. ,po.eI;
Dr"'" I8I.po." "'.118;
,reek. .oId .. ..1.'18:
el'.."" .nd ,",bblng;
..., ".,.,.IIoft .n'
.Ior"'w"" "'Inlg'",",'
1Mll ~
R(M(CMl ACtION IIlttMATMS SUMMMY
AMERICAN CMOS01E WtJRICS. INC. SIll
£!!!!!!.
SI','37
sn,077
S 5.1"
S 5.18'
COlli IS '.0001
Annu.' 0 . M
yr. 1-S yr. 1-30
.5
.5
so
so
.....-
,.......
COft'''''''''''''
(,""","",,n' .1
Conslda'llIon.
..
Surtee. ...,,, runoff
COft"ot ",..,..fI' .nd
proper consI,ucllon
praclkes wll mlnlmlll
"',nll.1 .d.....
,n"l,onman'll Implell
..
....... ...... ......
'.poIW' of ""',...
.nd n,1ftty ,.,,,,,,,"
vi. Inll...lloII "
d,rmll con'lCt wit"
con,.mlnl'" ",..,riels.
008. not ecNr,.. flS"'-8I
I'oundw"" cont,mlnl'lon
Impacl"" toe.. ,acap'or.
''''ougll Inhl..llon. d..rMI
conl'le' 8f enu" "".,lIon
II
S.m, IS AIt..n.II", No. ,
"
S..... II In ....,.......
No. I. In ICNItIon. 1m.
peets on Ioc" 'Keptors
dur"" constructloft 01 'M
onsl" land'" wII b. mini-
m... SIIoft-,- ,.pos",a '0
n,1ftty r.."'IfII. du' 10
.,mpor", .,odpltl",
0' Con..mlnl.ad ",..art...
during .1.. pr,p.,.lIon 'or
conSllveilon of onsll.
I.ndljl
T actlllic"
Consld"8'ion.
tine "'''''1 Y
"girding
and/lol,,' '0'
cleanup
S.ma .. AI"'-
n.liv. No. I
-------
[
I
,"'u 11.
11t:M(IMt "1:"" MUftMTMS $UIIIMM't
AMlItICM CI1tOSOIE ~s.1NC.. Sill
rAGE 1WO
AIIern.I'"
c............
Aftetnlilwe No. 3
~.rtI8t IIIC""- with
011111. eII.poslt
18nelng:
",c"lllint ctIy ModI:
".dln, .nd II_w.l...
man...m.nt
I
\oJ
\II
I
Allernll'" "0. .
~1ft1.1 IIIC..II.. wII..
on.l.. dl.pont
'enclng;
"ac"lIIlng city "ods:
"adl", .nd .tormwll...
manag.m.nl
C"""
.'3.030
120. CM.
. ".171
. ..en
COSIS IS 1.1I0OI
Annual 0 . M
yr, '-5 If. 1-30
.s
.s
so
SO
NIle
. ........
Consld""10181
..
...... .. .. AIIetnll'"
No. '. 1Mtw8Y8r. fll"
10 onslt. end 0"1'"
rec.ptorl lower due 10
..I.c'''' ""WI 10t.1
.ac..a'''' lor AI,.,-
n.'hr. No. t. ....leIu'"
fI.h Is p,,,,,. II
tIIIl altern"'" doel not
8ddr811 .. soarc'l o.
conl...llion. Doe. not
"drell ,,....,..1.,
conla"""a'" .nd III
",enll" Impecll on Ioc..
flCep.orL
..
11
11
ElNllonmenl"
Conslderallon.
S.m. II AI'em..hr. No. .
InwIronmlftt Imp.CIS woutd
d'Plnd on con'arnlnant
,"enuallon .nd .h.
conc.ntra.lon a. 'h. point
01 .apo.ure.
...... .1 for All..""...
No. '. ---. fl...
during Implemen..llon 1.11
due 10 rlduc" lIu."UtI.I. EftWIronmlnl" Imp.ctl
.......... 'Is', P'"" woutd d.pend on con,_lna,,'
"'''' No. . sine. parll.. .II.n'ualion and 'h.
.ac..II" doll nol conc.n.ra.1on .. .h. point
1Iddr.1I .1 .08rC1i 0' .apo.ure .
of con.""""""" Dol.
not "drell "" Imp.CI
ot con.emlna.1d ,round-
w.'".
S.m. II AII.m..h,. No. .
T.chnlca'
Conslde,ations
Sam. .1 A'te,-
naU". No. .
Sarn. II Aller-
n.II". No. ,
-------
fAftlE 11
PI MfOlAl ACIION M1[...AIMS S1JMM1\fty
I\MlnlCAN cnc:uson wonlts. INC. SI.E
rAG( ""'U
Ahe''',''''
Aher".'''' No. 5
I
\,oJ
0-
I
AII.,n.'''', No. .
CostlfStOOGl hMIc
A-v.1 0 . M t....." (,",,_.n,eI Tee"""
C_lI8ln.n" £!!!!!. yr. ,-s 'I'. 1-30 Consld."t"'" Consld."Uons Consldeu1io".
.
Tot" .......... ...... SU, to.' nl 15 'or ...,,8tIon .... off. $"". .. Ahernll'". No.1 $"". " AIt"".th,.
oft.". ","'" "". 3..". .It. lII.po.1l ...... .. III No.1
"ounttw.'er F8COWery. "0. 1; pCMlfMlwlt., "..,.
S.,... lupport"" ...,... SU.18Z1 377 15 ...... wovt' po.. ",,"Irn" No"'. emrlronrMft'" o,er.,.... .n'
., AIt.,,,..... No.1 35,IZZ "''''1 '0 ...,.,.. end Irnpeell on ".. b.., ..- m.lnlln_c. o'
plu. pr."'" pOVftd- toe.. ,..kl8nIl. ,,..t" pee'" bee",.. th. ..- th. ons6t. Ir,.t.
,.11. on.lt. 8MI dllch.".. S23,Z711 ..5 11 ",ell., J' '0 PatW or II"... ,'Av.", conc.". men, peen. c,llIul
'0 POM. or .,.., on,lt. 35,011 'h. It., wit .... ..... ,,.tlon. o. th. c,IUcel wllh '..p.c' 10
,nd disc"'" '0 'h. b.,. any ,d".rs. 1mII8c" . con""""''''1 ar. b.1ow ".. .,"vent qu.llly
12.,0." .20 11 .''''''n' "'881' pret,..,- eevt. .nd chronic w.t.r .nd III polenll.1
35,7" rnent 1,.nd"'1 . wll. qu."t, crlt.,.. 'or th. Irnp.et on Ih. PaTW
......, I'.nd,,'" prOllctlon o' III,-w.'., or Ih. Bay.
.qu.1tc "...
T.'" IIIC"""" wi'" S7 ,US! 731 20 S..... .. All"""" Serne .. A".mll"', No.2 S."'. " AII"n.tlv.
onslt. ellpo." "". 7,.54 No. 2 'or 'h. ..CI"II"" 'or ,Ite .1IC."IIlon No.2'" Ih.
groundw.'" "coV.ry 11,2231 382 20 ,nd on.It. eII'POI" compon.n, ,.c,,,,"on
.0- ...""ar"", It.",. '.232 compon.nt compon.nt
II A".,ne'''' No. 2 S7 ,1201 ISO 2. S"". .1 Ah""..... $..... It Ahem."", No. S S.m..' AII"n.'Iv.
,eu. pr."'" poundw". 7,12' No. 5 'or ,Ite p""'- 'or tlte pound......r No. S .., .h,
onS'" ,nd "'.ch.'" '0 11,3901 05 2. wllar rICovery .nd Flcovery .nd t"lIm,n' ,'GUn",,"II,r
POM or tr.., on,lt. 1.3" ,,,,',,,,n' compon.n, compon.nt recovery .nd
,nd dilch.,,, '0 th. bay. "..Imenl compon.n'
-------
1N1lE .\~
nt-DIAl AC1'" MU"""1MS SUIIIotMY
A..meAN CR[OSOIE WClmtS. INC.. 581(
"AG( rOUR
.
COtl, II ..DOlI PtM&
Anna" 0 . M ........ 1""'0""""''' ' echnlc81
Ntenu"" eon40"''''' C""" 'If. I -S If. 1-30 COft,IeI","'" Conllder.llon, Canlldlf .IIon,
Ah"".I1". No. 7 ....... I_loft """ .,..ml 721 II s... ., ......,... S..... ., AII"n.'''' $"", It "h"-
0tI,,,. DIsfo,8I pIu. I' .1" No. Jr. .... No. 3 lor '", n."", No. 3 for
Orounct.... "ecowery. he...I" C........., '.C"I"on component '", ,.u"lIion
StIlI' .....,.... II..... .".,"' 377 " compon.n'
I' All"""'" No. 3 ZZ.5n ..... I' All.......,. S..... I' All"""...
plu, pr...... graunct- No. S f. .... ground- No.5 f. '118 Ifound- S"", It AIIer-
.... Oftl'" 8ftd ct',- .'..I1Z1 ~, It wll. 'ICOYefy 8M w.'er 'ICO¥'''' .nd n.II". No. 5
ell I,.. '0 P01W or ".., 2'.'" ,,..,"',,,, compon.n' ',..'m.n' compon"" for 'hi ground-
onl"8 lnet IIIlcll8'8' '0 . w.',r "COYIf'
'h, bey .".7W UO It Ind '"."n'n'
22.751 compon.n,
Af'''''''''', No. I, "''''81 IIIC8Y8IIoft ..,.. .'...31 733 ZO ..... 8' Aft........ Seme " """n"'" $"", It AIIer-
On,lI, DI,p0u8 pIu. 1..52 No. . .. '118 "c",'" No. . fOr ,h. ,.un'- n."", No. . 10'
Oroundw.,. Rftow",. compo..,... component 'h. ,.cI"..lon
S.m, .upport... h..... 17.221/ 312 ZO compon'n'
8. AI,,,n."" No.. 7.230 ..... ., AII....1IIre $1'"' It AII,rn,'...
, plu' ,re",.. ground- No. S f. .... If""ct- No.5 for 'h. ,round- $.m. II AI'er-
""
..., .8'., Oftl'" end ctll- SI.I'" 850 2. _I. rICoYIfy end w.'er ,.co",,,, Ind ".,1"1 No. S lor
. eherg. '0 POTW or Ira.' '.In I,..'""n' compon,n, '"lIm,n, compon"" 1111 ground-
Oftlll, .net cII.cherg. w.',r recov,,.,
'0 '", bey. 17 . 3881 .2S 2. Ind 'r,.'m,n'
7.397 compon'n'
-------
''''''' 11 .
'" Mt 'MAl ACflOlt IIurnMAtMS StJMMNt't
AMUtICAIt Cn[OSOIl WOflftS. INC.. SlIE
rAG( nVt
AI1.r".''''
Aller",n". No. .
,
w
00
,
COIftIMfft."t.
No Act"" wit" OroUlld-
w"er "'""' MonIloring
a"d A..e..rnen' wilh
Drum DI'POII' O",lIe
£!!!!!!..
Co,1t II '.-
A-..a' D . II
yr. 1-5 yr. 1-31
..
55
.,
.,
'-"Ie
..."'"
Con.lder,,"'"
II
"
D8nM8 ......,... If
.lIa coni"""", wo....
"ot ".ve IC"" ,1tIIIc
'mpeel..
c.,... .......... If
,~w'I" cCMlld "'"
chronic 'o"kll, .n.ct.
"nee rn,alrnurn ..,.",.,
COltCen'r.I"", III .,ound-
w.t., lor "...........".
.nd IIvor8fttheM win a.-
u" the Acupt.....
D.IIy "".'e, lAor.,
Incldenl'" .11 ....,...
or dermll conteet with
PC".con'ernIn"" ,on.
could h.". chronic
loalcll, Impecl'
(n,,11 Oil"'" "181
Conslde"IIo",
Con,"""" of cont,rn-
"'",. grovndw"" b,
t.",,1I1I .nlm.', m.,
have ,ome 1o"1-II,m con-
..qu,ne..
Cont""'"" IIV'"
'1ipICIe' 10 ruch 'he
"ey wovld no' ImpOII
IImll'Ilon, 0" Its "cru.
lion.' UII
IIolCclIfftUI""" eneelt ef
..AH, on m.""e bioI. .,
01 . ,hort dOl IIlon ,''us
bfom.""flullo" up I".
rood chlln Is "01 e.pul..
T ,ch..r
Consld~'''IO"'
Non.
-------
TOPIC:
RESPONSIVENESS SUMMARY FOR THE
AJERICAN CREOSOTE WORKS, INC. NPL SITE
PENSACOLA, FLORIDA
BASED ON CCllENTS FROM THE
PUBLIC MEETING OF
AUGUST 15, 1985
HEALTH CONSIDERATIONS
Who is the chemist here? What is your definition of an aromatic
hydrocarbon? °Is that a creosote or a phenol?
Discussion: That is essentially associated with creosote.
Issue:
People have l1ved 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:
Issue:
Discussion:
Issue:
Discussion:
Issue:
Discussion:
Pentachlorophenol is the more dangerous of the two substances,
1sn't it?
I believe so, yes. That's the position we've taken so far.
What is an aromatic hydrocarbon?
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.
These are components of creosote?
Yes, these are components of creosote. The pentachlorophenol is
In Ic1d-fract1on Ind 1s not part of creosote. As I understand
the h1story of the site, most of the processes involved creosote
It this plant. After 1951, they also started us1ng
pentachlorophenol as I wood-treating chemical.
1
-------
Issue:
Discussion:
Issue:
Discussion:
TOPIC:
Issue:
D1scuss 1 on:
Issue:
Discussion:
Issue:
Discussion:
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.
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 i5 a problem and remediate
them before a bigger problem occurs.
Are health department representatives here tonight?
They are not here. However, they were invited.
REMEDIAL TECHNOLOGIES
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.
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.
I read this in the (Pensacola) News Journal.
I'm not aware of that. I think you're tal king about the process
of biodegradation of this particuhr compound. There 15 some
indication that aerobic bacteria, that is, bacteria which need
a1 r 1 n order to 11 ve and work on the contami nants--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.
There is a news release saying that there's a new technique of
pumping oxygen into the ground for these bacteria.
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.
2
-------
Issue:
Discussion:
Issue:
Discussion:
Issue:
Dfscussion:
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 donlt you introduce more bacteria that would
work on the polynuclear aromatic hydrocarbons?
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. .
Have you thought of deep well disposal, pumping the stuff
underground?
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 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 t~ 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.
I want to know why you dismissed incineration as an alternative
when your other regions are promoting it as a method of
destroying dioxin.
We are basically looking at materfals that are inert. Welre
looking at materials that have a low BTU content. When the
immediate removal occurred on the pond area, they mixed the
sludge with fly ash and lime, which are essentially inert
lIatertals. The costs for both onsite and offsite incineration
are therefore considerably higher than some of the other
alternatives we are looking at. Offsfte incineration costs would
be more than the total cost of the offsfte disposal alternative
that we are discussing. Also, we evaluated capacities of
existfng permftted incfnerators. It will take 7 to 10 years to
burn this material, and if you use an offsite facility, you must
store thi s materi a 1 someplace in any case. Wi th ons f te
facilities there would be an incfnerator in the middle of
3
-------
Issue:
Discuss i on:
Issue:
Discussion:
TOPIC:
Issue:
Discussion:
Issue:
Discussfon:
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.
Were you comparing this to the dioxin fncineration fn Missouri.
at the Verona Site?
I don't know what quantities were involved at that site.
familiar with that site.
11m not
What about putting the contaminated materfal under concrete or
asphalt with a shopping center over ft?
There are many materials that are evaluated as materials for
lfners. which are designed to contain wastes of one kind or
another. We have found that when ft comes to containing organic
wastes. organic materials cannot contact the liner. For example.
asphalt would be out because creosote would go right through it.
ADMIIUSTRATIYE ISSUES
What 15 the purpose of this meeting? We've identified the
problem. What fs next? Where do you see this going?
The purpose of this meeting fs to fnform the public of the
ffndings of the Feasibility Study and to obtain input from you.
the c1tfzens. concerning the recommended alternatives. The
public comment period closes in 3 weeks. and you .ay send your
letters to me or to Beverly Mosely. Our addresses are lfsted in
the Fact Sheet. We will use your comments in guiding us in our
decision. Once an alternative has been chosen. a Record of
Decfsfon will be written. The next step is design and
construction of the alternatfve.
Which alternative have you decided on?
No selectfon has yet been .ade. 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.
You do not have a recommendatfon at thfs particular stage that
you think is the best one?
Dfscussfon: At thfs tfme. we are leanfng towards partial excayat10n wfth
ons1te disposal and groundwater monitoring.
Issue:
4
-------
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:
Issue:
Discussion:
Issue:
Discussion:
Issue: .
The Fact Sheet indicates that these reports are available at the
libraries listed. Are all reports available for public review at
these libraries? .
Yes. The Remedial Action Master Plan (RAMP), the Draft Remedial.
InvestigationReport (RI), and the Draft Feasibility Study Report
(FS) are at the repositories. The Community Relations Plan is
also available at those locations.
What is your. proposal concerning the railroad?
the railroad property adjacent to my property.
.. .
I bought all of
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 so11 s (the line w11l then be
replaced); about 6500 linear feet of tracks on the ACW property
for site preparation, grading, 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.
Based on comments I've heard so far, Ind 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 st111 have a block of land with contaminated
sediments. The Yacht Club has plans for the redevelopment of the
Irea and we could partially recover and use the land.
Redevelopment of that land after it has been totally cleaned i5
much better. Superfund i5 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
IS 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
hlzardous substances and inactive waste sites. It is collected
through taxes paid by manufacturers, producers and exporters and
importers of oil Ind 42 chemical substances.
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:
Issue:
Are the people compensated or do the people just get a new yard
in return?
5
-------
Discussion:
Issue:
Discuss i on:
Issue:
There are no provisions for compensation; however, the property
would be restored to its original condition after excavation work
is completed.
Did you check out Ashley for its pentachlorophenol? They were
treating wood with pentachlorophenol before American Creosote
knew what pentachlorophenol was.
I'm not familiar with that site.
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.
reimbursed for it?
W111 I be
Discussion: At this point, we do not have plans for that.
Issue:
Discusson:
Issue:
How soon do you anticipate the .ost rapid action?
you clean up the site?
I would say next summer would be the earliest. But that hinges
on the fact that .oney is available. Congress has not yet
reauthorized the Superfund 8111.
How soon can
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 responsibl1ity for them? The State? EPA? Who is
going to clean up this hazardous waste if these trucks jackknife
or break down?
D1scuss10n: You're say1ng that you don't want 1t trucked away?
Issue:
Discussion:
I'm saying, 8keep that snake fn the box.8 I don't want it on the
hfghways. Why .ove it 300 miles to Alabama? Florida ought to
take care of its own problems.
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 i5 not
feasible, as it would be burfed right next to our groundwater.
There are .any demonstration projects 90i ng on for new
alternative ways of treating wastes. We're hopeful that sOlie of
them will pan out and wfll be applicable. The potential fn this
program f5 that down the road. 1f there 15 a really unique
alternative that comes to light that lIay be useful fn treating a
particular waste, then we could use it. Until such a treatment
comes along, we have to act on what we have rfght now fn the way
of acceptable, proven technologfes.
6
-------
Issue:
Discussion:
Issue:
Discussion:
What about storing it over on some of £gl1n1s property? That's
Federal Government property, and it would seem that they could
spare a few inches over there on that bomb range.
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.
Did you cost out incineration and biodegradation in your report?
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 sing1e technotogy before we began the screening process and
exptained why we screened those technotogies out, whether it was
because of site characteristics, waste characteristics, or
excessive costs as compared to other acceptable, proven
technot ogi es. In thi s parti cular area of hazardous waste
cleanup, we are lookfng at proven track records on technologies.
There are a lot of cleanup methods currentty 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. .
Is there going to be money teft over from Superfund to ctean up
this site?
Discussion: I think Superfund wilt be here for awhile. Judgfng by the number
of sites we turn up annual1y, it [the problem] is growing and
there will be a need for the Superfund to be around.
Issue:
Issue:
Discussion:
The way it was expTafned to me was that when Congress revised
RCRAand 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 Emitle,.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?
Emil1e has about a 600-foot clay layer and it will take 5800
years or 50 for the material to mfgrate, 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 landfall. The overall goal of the
hazardous waste management program fs 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.
Where does the local government fft fn 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
tocal, State, or Federal, including environmental or engineering
Issue:
7
-------
TOPIC:
permits. The city has been contacted during the time of this
study. The city engineer1s 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 anothe~
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.
LAIID REDEVELOPMENT
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:
Issue:
Discussion:
Issue:
Discussion:
Issue:
Discussion:
TOPIC:
Would total excavation with offsite disposal permit more
development in the area?
Yes.
Is it correct that the land surrounding the disposal area could
not be developed as ~uch as it could if there were not onsite
disposal?
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.
If the ons1te 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?
As long as the use is consistent with the alternative selected in
the remedial action that's taken, there 15 probably no reason why
it couldn't be used for whatever the local permits would allow
for the area.
TECIIIOL06ICAL CONCERNS
When you talk about total excavation, does that ~ean the total
removal of the houses?
Discussion: No, just the soil would be removed.
Issue:
/
8
-------
Issue:
Discussion:
Issue:
Discussion:
Issue:
Discussion:
Issue:
Discussion:
Issue:
So how are you going to remove the soil from under the houses?
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. .
Could you report the depths of the excavations?
For those areas wher~ the contaminant concentrations increased
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. . .
Can you show me where the underground plume is now. where it is
going, and how fast it is moving south?
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.
Is there a wall of clay preventing the groundwater from going
- into the bay?
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.
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.
9
- --
-------
Issue:
Discussion:
Issue:
Discussion:
Issue:
Discussion:
Issue:
Discussion:
Is s ue :
Discussion:
Where is the 100-year flood plain in relation to the site?
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.
Are the contamination levels measured in parts per million or
parts per billion?
In the soils, we measured in parts per million, or what we call
mi1igrams per kilograms. In the groundwater, we measured
contaminants such as napthalene and f1uoranthene 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
napthalene. In the soils. we detected napthalene at levels
varying from 74 to 1100 parts per million. As far as groundwater
is concerned. we did find very high levels of napthalene ranging
between 35 and 580.000 parts per billion. So to answer your
question. we have ranges of parts-per-m111ion level in the soil
and parts-per-b1111on level in the water.
You detected 580.000 parts per billion?
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 well s. What th1 stell s us 1 s that the data 111 ght be
questionable for that particular sample. but we had to include
1t--w1th a qualifier that said that the number may not be
representative.
How high above the ground would the ons1te landfill be?
About 15 to 19 feet, depending on whether you go with total o.r
partial excavation.
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 uter1al?
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 Imount. or Ibout 40.000 cubic Ylrds.
which we moved to I specially constructed landfill in the State
of North Carolina. So we are talking twice that amount of
material for this site.
10
-------
Issue:
Discussion:
Issue:
Dfscussion:
Issue:
Dfscussfon:
Issue:
Would incineration completely clean up this area as well as total
offsite removal? .
Yes. ft 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 ff you decided not to have an
onsite landfill.
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, rfght?
Th.at 15 correct. The remedies that we have basically proposed
for leavfng 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
phce.
..
But fsnlt there already contamination fn the water table beneath
the sfte?
Yes, but that could be taken care of if you pick an alternative
fn whi ch you are al so treati ng the groundwater. If you
consolfdated all the excavated materfal and stored it in an
onsfte 'andff", and at the same tfme put fn wells and pumped out
the contamfnated groundwater and treated it, you would have
essentially taken care of the problem.
Whatls the tfme perfod fnvolved?
D1scussfon: Based on the data that we have evaluated, we are lookfng at a
span of about 5 years.
Why donlt you leave thfngs as they are and just monftor t~e
publfc health untfl a new technology fs dfscovered to completely
clean up the sfte?
Dfscuss1on: The No-Actfon alternative with mon1torfng 15 an alternative we
are evaluatfng.
Issue:
In addition to the oral comments recefved at the public meetfng on August 15,
1985. the EPA also received one written comment from the Audubon Society.
Issue:
Tol.rance levels and specific effects on humans, plants, and
animals were not gfven. In the report, there was not adequate
information on b1oaccumulat1on or the potential effects on humans
who frequent Sanders Beach, where the underground plume emerges.
Also. the possibility of chemicals at the site interacting ~~th
each other was not dfscussed in the study.
11
-------
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 contamfnation from
the ACW Site have been presented in the Remedial Investigation
Report and the Draft Feasibility Study.
Tota 1 excavation pl us groundwater recovery is a proposed
alternative that f5 under consideration for ffnal remedial
action. The groundwater discharge to the Escambia County Utility
Authority Waste Water Treatment Plant (WWPT) is an item of
concern, since the WWPT 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, wfth revegetatfon and proper design the
disposal area could blend in with the surroundfng area. Our
information indicates that the ACW property fs not within a 100-
year flood plain, and that an onsite dfsposal alternative would
not of ftself create an environmental or health hazard.
12
------- |