United Slates
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-88/019
September 1988
Superfund
Record of Decision
Coleman Evans, FL
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TECHNICAL REPORT DATA
/Pleat read Instrucnont on the rtvmt before completing/
I. MPOHT MO.
EPA/ROD/ROih-86/019
3. RECIPIENT'S ACCESSION NO.
4. TITLE ANOSUSTITLC
SUPERFUND RECORD OP DECISION
Coleman Evans, PL
5. R6PO«T DATi
September 25, 1986
«. PERFORMING ORGANIZATION CODE
7. AUTHORS)
8. PERFORMING ORGANIZATION REPORT
t. PERFORMING ORGANIZATION NAMf AND ADDRESS
10. PROGRAM ELEMENT NO.
II CONTRACT/GRANT NO
12. SPONSORING AGENCY NAME ANO AOORESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
i 13. TYP6 OF REPORT ANO PERIOD CO*. £
; Final ROD Report
14, SPONSORING AQ6NCV CODE
800/00
19. SUPPUEMiNTARY NOTES
16. ABSTRACT
The Coleman Evans Wood Preserving Company site is an active 11-acre wood preserving
facility located in the town of whitehouse, Duval County, Florida. The. site consists o
two distinct areas: the western portion, which comprises the wood treating facility;
and the eastern portion, which consists of a landfill area which has been used for t*e
disposal of wood chip and other wastes. Land use around the site is primarily
residential and light commercial/industrial. Since 1954, Coleman Evans has produced
wood products impregnated with PC?. Wastes from the process were discharged into an
onsite drainage ditch, and two unlined sludge disposal pits. In 1980, ground water
underneath the site was found to be contaminated. As a result, Coleman Evans
constructed a closed-loop treatment system. In 1985, an immediate removal action was
taken to remove the contents of the two unlined pits. Subsequent site investigations
confirm soil and ground water contamination, with PCP the primary contaminant of cor.ce:
The selected remedial action for this site includes: all soils and sediments wiiu.
PCP concentrations greater than LO mg/kg will be excavated, approximately 9,000 cur: r
yards; excavated soils will be incinerated in a temporary onsite incineration unit.
Decontamianted soils will be backfilled onsite; ground water recovery will be conduc •.<»••:
for dewatering to facilitate excavation and to treat ground water with PCP
concentrations greater than 1.01 mg/1. Recovered ground water will be stored and
(See Attached Sheet)
<£Y WORDS ANO DOCUMENT ANAfS'S
DESCRIPTORS
SNOEO
C3SAT;
Record of Decision
Coleman Evans, FL
Contaminated Media: gw,
Key contaminants: PCP
soil, sediments
H. DISTRIBUTION STATEMENT
'9 SEC<-R|TV CLASS . Tins Rtpom
None
31
20. SECURITY CLASS
None
i paqti
22 'RICE
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EPA/ROD/RO4-86/019
Coleman Evans, PL
16. ABSTRACT (continued)
analyzed. If the level of PCP exceeds 1 ug/1, the ground water will be
treated by an onsite carbon adsorption unit to a level below 1 ug/1 PCP in
accordance with Chapter 17-3.061.3(m) of the Florida Administrative Code
before discharge to the surface water environment via the onsite drainage
ditch. Other incidental Hazardous Substance List compounds identified in
ground water during the implementation of this remedy will be cleaned up to
levels which comply with Drinking Water Standards. Clean up compounds for
which no standards exist will be to non-detection levels. The estimated
capital cost for the remedy is $3,000,000 - $3,800,000 with no O&M costs.
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RECORD OF DECISION
REMEDIAL ACTION SELECTION
SITE
Coleman Evans Wood Preserving Co.
Jacksonville, Duval County, Florida
DOCUMENTS REVIEWED
I am basing my decision primarily on the following docunents which describe
site specific conditions and the analysis of effectiveness and cost of
the remedial alternatives for the Coleman Evans Site:
- Coleman Evans Wood Preserving Co. Site Remedial Investigation Report,
- Coleman Evans Wood Preserving Co. Site Feasibility Study,
- Coleman Evans Wood Preserving Co. Surmary of Remedial Alternative
Selection,
- Public Health Evaluation,
- Agency for Toxic Substances and Disease Registry - Health
Assessment,
- Department of the Interior - Release from Claims for Damages
to the Natural Resources Under DOI Trusteeship.
DESCRIPTION OF THE SELECTED REMEDY
- All soils and sediments with pentachlorophenol (PCP) concentrations
greater than 10 mg/kg will be excavated; approximately 9000 cubic
yards.
- Excavated soils will be incinerated in a temporary onsite incineration
unit. The soils will be decontaminated in a primary chamber where PCP
and fuel oil will be driven off in a gaseous phase. The PCP will be
thermally destroyed in a secondary chamber. Incineration will be
undertaken in accordance with federal, state, and local laws. A
detailed Quality Assurance/Quality Control plan will be developed
during the Remedial Design.
- Decontaminated soils will be backfilled onsite.
- Ground water recovery will be conducted for dewatering to facilitate
... excavation and to treat ground water with PCP concentrations greater
than 1.01 mg/1. Recovered ground water will be stored and analyzed.
If the level of PCP exceeds 1 ug/1, the ground water will be treated by
an onsite carbon adsorption unit to a level below 1 ug/1 PCP in accordance
with Chapter 17-3.061.3(m) of the Florida Administrative Code before
discharge to the surface water environment via the onsite drainage
ditch. If EPA promulgates further regulations in the future which are
more stringent than those outlined in this ROD, the future regulations
will be observed.
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- Other incidental Hazardous Substance List compounds identified in ground
water during the implementation of this remedy will be cleaned up to
levels which comply with Drinking Water Standards. If the Drinking
Water Standards do not address these compounds, clean up will be consistent
with the human health criteria identified in the 1980 Water Quality
Criteria. Clean up of compounds for which no standards exist will be
to non-detection levels. In cases where standards promulgated by the
State of Florida are more stringent, the State standards will have
precedence.
- Due to the complete destruction of site specific contaminants by
incineration, no post-remedial monitoring or operations and maintenance
activity is required.
DECLARATIONS
Consistent with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA), and the National Contingency Plan (40
CFR, Part 300), I have determined that the above Description of Selected .
Remedy for the Coleman Evans Wood Preserving Co. Site is an effective
remedy and provides adequate protection of public health, welfare, and
the environment. The State of Florida has been consulted and agrees with
the approved remedy. These activities will be considered part of the
approved action and eligible for Trust Fund monies until remedial action
is complete. The basic assumption is that EPA will undertake
implementation if the responsible parties fail to undertake the design
and implementation of the selected remedy.
I have also determined that the action being taken is appropriate when
balanced against the availability of Trust Fund monies for use at other
sites. In addition, the selected remedy is more permanent than other
remedial actions, and is necessary to protect public health, welfare or
the environment.
If additional remedial actions are determined to be necessary, a Record
of Decision will be prepared for approval of the future remedial action.
Date Jack E. Ravan/
Regional Administrator
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SECTION I
SITE LOCATION AND DESCRIPTION
The Colenan Evans Wood Preserving Conpany (Coleman Evans) is located on
Celery Avenue in Whitehouse, Duval County, Florida (Figure 1). The
site is an active 11-acre wood preserving facility which uses pentachloro-
phenol (PCP) as a wood preservative.
The Colenan Evans site is composed of two distinct areas. The first area
comprises the wood treating facility and is located on the western portion
of the property. The eastern portion is a landfill area which has been
used for disposal of wood chips and other facility wastes.
Site surface features include two unlined disposal pits, which were partially
removed in July 1985 under an EPA emergency response, and the active wood
treatment facilities. The treatment system is composed of a large pressure
chamber, several tanks for storage of the preservative fluids, a sand
filter system, and several storage sheds.
The Colenan Evans site is relatively flat, with less than 10 feet of relief
over the entire site. The site drains into a ditch which eventually enters
into a swampy area to the south, and then into McGirts Creek.
Within a 1-mile radius of the site, land use is primarily residential and
light commercial/industrial. Outside the 1-mile radius, the area is
primarily undeveloped rural land.
Locally, there is no central water supply, thus approximately 1000
residents rely on ground water resources for their drinking water source.
Surface waters in Duval County are used exclusively for sport fishing and
recreation. Agriculture near the site is limited to small gardens. The
only natural resources are the surficial aquifer system and Floridan
aquifer.
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^ ,3
Colenan Evans
Wood Preserving
Co.
; DDD Q
L L
a
1
SCALE IN f
APPROXIUA'
CtNC««l AVCHUC
a
a
<=3
i 00
?1
a a
a i
TO UcCiHTS CREEK
Figure 1. Colenan Evans Wood Preserving Coipany Site Ixacation Map.
(2)
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.SECTION II
SITE HISTORY
OPERATIONAL HISTORY :
Since 1954, Coleman Evans has produced preserved wood products which are
impregnated with PCP. The treatment process includes steaming, drying,
and pressure soaking the wood, all within a single chamber. The wood
products are impregnated with PCP dissolved in #2 diesel fuel.
Prior to 1970, the process effluent was precipitated with caustic soda
and aluminum sulfate, passed through a sand filter, and discharged into
the onsite drainage ditch. The recovered sludge was deposited into two
unlined pits onsite. The pits, located along the southern boundary, were
approximately 100 feet by 50 feet and extended to unknown depths. In
1970, Coleman Evans began storing the sludge in storage tanks located
adjacent to the pits. At this time, the company engaged an engineering
firm to design a waste water treatment system. Treatment of the effluent
with chlorination and lime precipitation was adopted to produce a clear
waste water.
In September 1980, the City of Jacksonville Bio-Environmental Services
Division (BES) confirmed the presence of ground water contamination on site.
As a result, Coleman Evans incorporated an activated carbon filter system
into the treatment process in late 1980. In 1981, the company completed the
construction of a closed-loop treatment system.
PEBMIT AND REGULATORY HISTORY
In June 1972, Coleman Evans received an Industrial Operation Permit from
the State of Florida Department of Air and Water Pollution Control. The
permit was for design and operation of a 2500 gpd industrial waste
treatment system and for discharge of effluent to McGirts Creek via the
onsite drainage ditch. A renewal permit was issued in September 1977 and
expired in August 1980.
A National Pollution Discharge Elimination System (NPDES) Permit was
issued to Coleman Evans in August 1975. Upon institution of a closed-loop
system, the company allowed this permit to expire in August 1980. EPA
formally inactivated the NPDES permit in June 1982.
In November 1980, Coleman Evans filed a Part A EPA Hazardous Waste Permit
Application as required under Section 3005 of RCRA. In its application,
the company stated that with the closed-loop system there was a capacity
for storing 2000 gallons of waste. The estimated annual quantity of
hazardous waste generated was 5000 gallons.
After BES confirmed the presence of ground water contamination, Coleman
Evans was served a Notice to'Comply for violation of ground water standards.
It was under this notice that Coleman Evans submitted plans for the existing
closed-loop system. In an effort to remedy violations, the company
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submitted a plan and schedule for construction of the closed-loop system
in April 1981. The Florida Department of Environmental Regulation (FDER)
issued a construction permit in June 1981.
Also in 1981, an FDER Inspection found that Coleman Evans was in violation
of RCRA hazardous waste reporting, planning, and safety requirements.
FDER issued a Consent Order in November 1982 which required Coleman Evans
to implement a plan for sampling, analysis, monitoring, and reporting.
The company hired a contractor to assist in meeting the terms of the
Consent Order. Final reports were issued by August 1983.
A further Site Inspection was conducted by FDER in April 1983. FDER
found that Coleman Evans was a generator and storer of hazardous wastes,
and was in violation of RCRA requirements. As a result, FDER required
Colenan Evans to submit an application for a Temporary Operation Permit
by April 19, 1983. No application was submitted. In September 1984,
FDER filed a lawsuit against the company, seeking relief which would
require the company to conduct remedial activities at the site. The suit
is still pending.
In October 1981, the Coleman Evans site was proposed for inclusion on
the National Priorities List (NPL) based on an Hazard Ranking Score
of 59.14. The site was finalized on the NPL in March 1983.
In September 1984, EPA obligated funds for an RI/FS. By October 1984,
EPA had tasked Camp Dresser and McKee, the REM II contractor, to execute
the RI/FS. The field investigation was delayed by Coleman Evans1 refusal
to allow EPA onsite to conduct the removal and remedial activities. As a
result, EPA and DOJ filed a motion in Federal Court to obtain an order
granting site access. By June 1985, EPA and its agents were granted site
access and field operations were initiated.
In an Immediate Removal Action, EPA excavated the contents of the two
unlined pits, and the pit material was shipped to Ernelie, Alabama. This
action was conducted in June and July 1985. The pits were backfilled
with clean material and french drains were installed.
The Remedial Investigation Report was completed in April 1986 and the draft
Feasibility Study was ready for release to the public on July 21, 1986.
A public meeting to present the FS was held on August 7, 1986. The public
meeting was the initiation of the public comment period which closed on
August 28, 1986.
Due to the fact that Coleman Evans is an active facility which periodically
continues to have releases of hazardous substances, EPA requested that
Region IV RCRA personnel perform a site inspection. The EPA inspector
found several RCRA infractions; however, the infractions identified are
being addressed in the State of Florida's lawsuit. EPA will continue to
monitor the RCRA aspects of this site.
(4)
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PREVIOUS STUDIES
Several site investigations were conducted between 1980 and 1983. Studies
of air, soil, ground water, surface water and sediments were conducted by
federal and state agencies, as well as two consultants to Coleman Evans.
During the period from August to December 1980, BBS, FDER, Ecology and
Environment, Inc. (E&E), and NUS Corp. conducted separate soil and
ground water studies. In December 1980, Law Engineering & Testing Company
(LETCO) installed and sampled monitor wells, soil test borings, and
shallow soil auger holes. In June 1982, EPA conducted an air investigation,
using a photo-ionization meter (PI) and an infrared spectrophotometer,
and in March 1983, Groundwater Technology, Inc. (GTI) conducted a well
installation and sampling program at the site. In 1985, EPA subcontracted
with Haztech, Inc. to remove the contents of the onsite sludge pit. The
results are summarized below.
0 Air Studies - Air investigations were conducted by EPA in 1982. None
of the measurements recorded WC levels above background. The GTI
investigation indicated that ambient air quality was within acceptable •
levels (<5.0 ug/1) except in a single borehole which had VDC levels of
14.0 ppm and in the area of the sludge pits where VDC levels were
recorded to be 5.0 ug/1.
0 Soil Studies - In 1980 LETCO collected three soil borings on site,
however, analysis was conducted on only two of the samples. These two
samples indicated PCP concentrations of 320 and 430 mg/kg. In 1983, GTI
analyzed soil samples from eight locations. PCP concentrations ranged
from 11 mg/kg along the southern edge of the disposal pits to 1,490
mg/kg along the northern edge of the disposal pits (refer to Figure 2
and Table 1). In addition to PCP, chromium and copper were found in 5
locations in concentrations ranging from less than 1 to 15 mgAg
x (Table 2).
0 Ground Water Studies - PCP contamination in the ground water of the
upper surficial aquifer was confirmed by the 1980 LETCO study, the 1980
E&E study, and the 1983 GTI study (Figure 3 and Table 3). Several
other organic compounds were identified during the E&E and GTI
investigations (Table 4). Metals contamination was also identified
during these investigations; however, only the E&E study found lead and
chromium above the 1980 Water Quality Criteria. Lead was found at a
concentration of 105 ug/1 in monitoring well M-l and chromium was found
at 300 ug/1 and 1960 ug/1 in wells M-l and M-2 respectively.
In the E&E study for EPA and in the 1983 LETCO study, shallow auger holes
were also sampled for ground water contamination. These wells, which
range in depth frcm 2 to 5 feet below the surface, revealed PCP concentrations
in the ground water ranging frcm 12 ug/1 to 4,900 ug/1 (Table 5).
Private wells were sampled in 1980 by E&E and by the Florida Department
of Health and Rehabilitative Services (DHRS). No contamination of private
wells was found. This is primarily due to the presence of a competent
confining unit within the surficial aquifer, below which private wells
receive water, and to the low solubility level of PCP.
(5)
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IT
LEGEND
N
I
IPH
B-2
M-6
LJ
M-5® »>M U.A ' ;$
\rn PkM.,^v:^*s-5 '•
t-^i.
S3 M 8~S 4
!• i'i
i.i L
/
GINERAl AVINIIt
• B-1 HAND AUGER SAMPLE LOCATIONS (1980)
® M-5 MONITOR WELL LOCATIONS (1983)
• S'1 HAND AUGER SAMPLE LOCATIONS (1983)
P-1
Figure 2. Soil Sanple Locations Used in Previous Investiq.il ions ol the Colimin I^vans Wood
Preserviiic) Conpany Site.
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Table 1. Results of Previous Soil Investigations for PGP Contamination
Location
B-l
B-2
-• P-l
P-2
P-3
Depth
(ft)
3.5-5.0
3.5-5.0
0.0-3.0
0.0-3.0
0.0-3.0
Sartple By
LETCO
LETCO
GTI
GTI
GTI
Date
12/2-4/80
12/2-4/80
3/4-14/83
3/4-14/83
3/4-14/83
PCP
Concentrations
(mgAg)
320
430
<12.5
1,170
2,090
M-5 0.0-3.0 GTI 3/4-14/83 1,490
M-5 6.0-8.0 GTI 3/4-14/83 990
M-6 3.0-6.0 GTI 3/4-14/83 616 •
M-6 7.5-9.0 GTI 3/4-14/83 346
M-7 0.0-3.0 GTI 3/4-14/83 11.0
M-7 3.0-6.0 GTI 3/4-14/83 53.6
M-8 0.0-3.0 GTI 3/4-14/83 787
M-8 3.0-6.0 GTI 3/4-14/83 504
(7)
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Table 2. Results of Previous Soil Investigations for Metals Contamination
Location
S-l
S-2
S-3
S-4
S-5
Date
3/83
3/83
3/83
3/83
3/83
C o n c e
Chromium (mg/kg)
4.94
3.97
4.69
15.46
4.55
ntrations
Copper (mgAg)
4.01
1.42
1.56
12.55
<1.0
Source: LETCO, 1981
(8)
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vo
i;-r-
LEGEN
9fSSi
3>M-1
• P-1
* A-1
'i
UJ
U
Z
Ul
5
>-
a
Ul
_j
UJ
o
D
i
^^S***£^^ j.
tt^""11^ ..,- • -4Vib~"~~ ";•"
. . < T , 1
f^=— --wi^cj mn ^ ' J
I AM~3 /
SC^L [ — i^"2 7 ^M-2
^ooooOP rnM^' / i
J fe "• LI J * __- '« J
TP ' u * *""5^ ^l — 1 A-4'lf /' --
1 •• c^—j v -• ( pl< **** 1 H' ^!A /t\
//v A- 2* _ ll D l""l Bp~3
I/* ^^ ~D 7 H 11 II
<\ is I — 1 F )• K5! n tCI!"! | ] r^j
U y P-6 / ^
GENERAL AVENUE ~
Ii 1 *
" rzi ^
i
EXISTING MONITOR WELLS
PRIVATE DRINKING WELLS
HAND AUGER SAMPLE LOCATIONS
c: 3. Pontachlorophenol Grcuuid Water Sanqilinq Locations Used in Previous Invest iqat ions
ot tlie Colenvin LV.ins Wcxxl I'reservinc] Coni}>any Site.
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Table 3. Results of Previous Ground Water Investigations for PGP
Contamination.
Location
M-l
M-2
M-3
M-4
M-5
M-6
M-7
M-8
M-9
M-10
M-ll
M-l 2
M-l 3
Depth
(ft)
13
13
15
15
15
15
15
15
15
15
15
14.5
14.5
Sanple By
E&E
E&E
GTI
GTI
GTI
GTI
GTI
GTI
GTI
GTI
GTI
LETCO
LETCO
Date
12/16/80
12/16/80
3/4-14/83
3/4-14/83
3/4-14/83
3/4-14/83
3/4-14/83
3/4-14/83
3/4-14/83
3/4-14/83
3/4-14/83
12/2-4/80
12/2-4/80
PCP
Concentrations
(ug/1)
4,000
12,000
ND
1,480
332
1,370
525
714
560 '
ND
ND
2,000
3,200
ND - none detected
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Table 4. Results of Previous Ground Water Investigations for Contamination
by Chemicals Other than PCP.
Concentrations iti ug/1
M-l M-2 M-3 M-4 M-5 M-6 M-7 M-8 M-9 M-10 M-ll
Naphthalene 15 16
Bis(2-ethylhexyl)phthalate 16 75 — — — 58.3 15.7 — —
Di-n-octylphthalate — — — — — — 55.3 —
Anthracene — 23 — — — — — — —
i
Phenanthrene — 23
Phenol 170 680 — -- — 41.5 12.9 —
Toluene 86 300 ~ — — — — 14.3
Di-n-butyl phthalate — — — — — 10.6 — 10.6
tluorene — — — — — 19.7 —
Isophorone — . — — — — — 10.3 —
— - none detected
Source:
Ecology and Environment, Inc., 1980 (MW-1 and MW-2)
Groundwater Technology, Inc., 1983 (Wells Other Than MW-1 and MW-2)
(11)
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Table 5. Results of Previous Auger Hole Ground Vfeter Investigations for
PGP Contamination.
Location
Depth
(ft)
Sanpled By
Date
PCP
Concentration s
(ug/1)
A-l
A-2
A-3
A-4
A-5
A-6
A-7
5.0
3.0
2.0
3.0
7.0
5.0
5.5
BES
BES
BES
BES
BES
LETCO
LETCO
9/9/80
9/9/80
9/9/80
9/9/80
9/9/80
12/2-4/80
12/2-4/80
537
4,800
12
1,070
12
4,900
20
(12)
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•f.
0 Surface Water Studies - The 1983 GTI investigation documents the
existance of contaminated surface water runoff. During a rainstorm on
March 7, 1983, GTI collected two samples from the onsite drainage ditch
(Figure 4). The upgradient sample (SW-2) contained less than 10 ug/1 of
PCP in background runoff. The downgradient sample (SW-1) yielded 1,760
ug/1 of PCP.
(13)
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j
ni
II J
CJ
r ....... ..,
\r-TT f "' *"* \
i KIM NO ruu
7
* I'l
SW - 2
a
''
7
GENERAL AVENUE
/
a
N
I
LEGEND
SW-1 SURFACE WATER SAMPLING LOCATION
Figure 4. Surface Water Sampling Locations Used in the T)83 C.roundwat er Technologies, Inc
Surface Water Investigation at the Colenvin LVans Vvotx.1 Preserving Company Site.
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SECTION III
CURRENT SITE STATUS
Soils ' :
Soil samples were collected from seven well defined areas as shown in
Figure 5. The collection areas were based on operation sites. Samples
were analyzed by an onsite laboratory, a local laboratory, and a Contract
Laboratory Program facility in a three-tiered quality control program.
The areal extent of PCP contamination at a one foot depth, as shown in
.. Figure 6, includes the landfill area in the eastern portion of the
site, a broad area east of the treatment cylinder, a broad east^west
trending area comprising the waste pits and storage tanks, and the north-
south drainage ditch which is south of the Coleman Evans property.
Although the pattern of PCP occurrences is similar for both of the depth
intervals sampled, the 3-foot interval (Figure 7) was found to contain
the highest concentration. This is reasonable, because the PCP-laden oil-
was observed to float on the water table, which typically fluctuates from
two to five feet below the surface.
The vertical extent of contamination was identified from soil samples
collected at 5-foot intervals from 12 boreholes (Figure 8). Cnly
trace levels of PCP were found in boreholes located along the northern
portions of the site; however, boreholes 38, 40, 41, 44, and 49 encountered
PCP concentrations above background levels (Table 6). Generally, PCP
contamination was limited to the upper 10 feet of the soils, except in
two boreholes which showed PCP contamination to a depth of approximately
35 feet; however, contamination found at depth did not exceed action
levels.
Several metals such as arsenic, cyanide, mercury, thallium, and vanadium,
were also identified in onsite soil samples; however, the Public Health
Evaluation (Appendix A, FS) states that the metals occur at levels below
or within the normal ranges found in typical soils of the southeastern
United States, Therefore, metals are not of concern at this site.
CLP data confirmed the presence of onsite PCP contamination. The only
other chlorinated phenol detected in onsite soil was at sample location
D-50, which contained tetrachlorophenol at an estimated concentration of
4,000 ug/kg. Additional organic contaminants detected include, but are
not limited to, a variety of napthalenes, alkanes, and xylenes, which
are thought to be associated with the fuel oil. Also found was Aroclor
1254, a polychlorinated biphenyl (PCB), which was found at sample F-29 at
a concentration of 30,000 ug/1.
Several samples contained compounds that have been identified as possible
laboratory contaminants. These include acetone, methyl ethyl ketone,
methylene chloride, and bis (2-ethylhexyl) phthalate.
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AREA 0
GENERAL AVENUE
L-J
LEGEND
AREA A - TREATED WOOD STORAGE
AREA B - TREATED WOOD STORAGE
AREA C - LANDFILL AREA
AREA D - CHEMICAL TREATMENT AREA
Fiquir '). Ons.it r So.i 1 Soii^l IIKJ Arras (A
Fit>M St inly .
AREA E - WASTE DISPOSAL PIT AREA
AREA F - DRAINAGE AREA
AREA Q - REMAINDER OF SITE
r>
5
LTD
G) llstnl Dm in<) thr I'.I'A K.'in •(! 1.11 Invi-.l i'|.il \«\\
-------
Figure 6. Pentachloroph^nol Concentrations in Soils at a Depfth of. One Foot. Iwxjrads Outline
Areas with Pentachlorophenol Concentrations Greater tlv«n 1 mq/k().
-------
1 1
BH4O
i »MOI it i »m
SOUTH PHOPtHIV IINE
'CP.«P«.8P.HM,ll,0«
" f001 OII>IN>
.- ...«
00 *ttO« OdiCIION tlltll
•"! - rcP COMClMm*lKM LOMIOUM
A I€M»OH»»l> •OMHOK
O «fO««Cl lAIWf
00
b. «l 1 IN I t 1 I
GENERAL AVENUE
n r
Figure 7. Pentachlorophenol Concentrations in Soil at a I)c|>th ot Tin ex.- lv<-t.
Outline Areas with Pentachlorophenol Concentrations C,i (\itci th.ni I
-------
GENERAL AVtMUE
a
a
izn
LEGEND
AREA A - TREATED WOOD STORAGE
AREA B - TREATED WOOD STORAGE
AREA C - LANDFILL AREA
AREA D - CHEMICAL TREATMENT AREA
AREA E - WASTE DISPOSAL PIT AREA
AREA F - DRAINAGE AREA
AREA Q - REMAINDER OF SITE
Fiyure 8. Location Map of Boreholes Used for Soil Samples During the EPA Remedial Investiqation.
-------
Table 6. Results cf PCP Analyses of Soil Samples Collected from
Boreholes Durino the IPA Remedial Investigation.
Sanple
Code
CES-
BH-35-1
BH-35-2
BH-35-3
Btt-35-4
BH-35-5
B»-35-6
BH-36-1
BH-36-2
BH-36-3
BH-36-4
Btt-36-5
BH-36-6
BH-37-1
BH-37-2
BH-37-3
BH-37-4
BH-37-5
BH-38-1
BH-3S-2
BH-3&-3
BH-38-4
BH-38-5
BH-38-6
BH-38-7
BH-3S-8
BH-36-9
BH-38-10
BH-40-1
BH-4G-2
BH-40-3
OMO-4
BH-40-5
BH-40-6
Depth
(ft bis)
5
10
15
20
25
30
5
10
15
20
25
30
5
10
15
20
25
5
10
15
20
25
30
35
40
45
50
5
10
15
20
25
30
PCP in Soil (mqAg)
Cnsite Dup. Onsite Local Dup. Local
Lab Lab Lab Lab
M)
ft)
M)
tt>
M)
M)
[*>
tr
MD 0.04
to
tr 0.06
ID
MD
ND
ND
ro
M) ND
1,025 585
37
205
2.3
0.09
tr
tr 0.3
M)
tr
tr
10
.45
tr
tr
tr
tr
CL?
M)
It)
ND
rc
ND
ND
ND
ND
ND
ND
(20)
-------
• z.
Table 6 (cont.).
Results of PCP Analyses of Soil Samples Collected from
Boreholes During the EPA Remedial Investigation.
Sample
Code
CES-
BH-41-1
BH-41-2
BH-41-3
BH-41-4
BH-41-5
BH-41-6
BH-42-1
BH-42-2
Bft-42-3
BH-42-4
BH-42-5
BH-43-1
BH-43-2
BH-43-3
BH-43-4
BH-43-5
BH-43-6
BH-44-1
BB-44-2
BH-44-3
mAA— A
BH-44-5
BH-44-6
Btt-44-7
BH-46-1
BH-46-2
BH-46-3
HH dfi 4
BH-46-5
BH-46-6
BH-49-1
BH-49-2
BH-49-3
RH dl A
BH-4^-5
Depth
(ft bis)
5
10
15
20
25
30
5
10
15
20
25
5
10
15
20
25
30
5
10
15
20
£w
25
30
35
5
10
15
20
«u
25
30
5
10
15
5f)
£w
25
PCP in Soil (mqAq)
Qnsite Dup. Cnsite Local Oup. Local
Lab Lab Lab Lab
0.6
tr
tr
M)
tr
K>
M)
M>
BH
MD
M> {O
tr
(0
to
tt>
(C
ft} MD
2.1
15.1
0.9 <1.6
jsT)
im^
7.0
1.25
M}
M>
M>
MD
MQ
V^J
ND
M> M)
tr 0.1
1.1
0.45 <1.6
^
tr 0.3
CLP
MD
M>
M)
M)
ND
ND
1.6
2.7
ND
ND
0.54
ND
(21)
-------
Table 6 (cont.) .
Results of PCP Analyses of Soil Samples Collected frorr.
Boreholes During the EPA Remedial Investigation.
Sample
Code
Depth
(ft bis)
PCP in Soil (aq/k
Cnsite
Lab
Dup.
Cnsite
Lab
Lab
Dup. Local
Lab
CLP
CES-
BH-50-1
BH-50-2
BH-50-3
BH-50-4
BH-50-5
BH-50-6
BH-50-7
5
10
15
20
25
30
35
tr
M)
NO
M>
M)
ND
tr
M> Not Detected Above Detection Limit
tr trace «0.45 mg/kg)
(22)
-------
Surface Water and Sediments
Surface water and sediment samples were collected at the locations shown
in Figure 9. The background sediment sample, SD-15, taken upgradient
along McGirts Creek, was found to contain a suite of metals, which included
antimony (69 mg/1), lead (11 mg/kg)» mercury (0.13 mg/kg), and nickel (31
nxj/kg). The surface water sample (SW-15) collected at this location, was
estimated to contain 9 ug/1 chromium. Neither sample contained organic
compounds above the laboratory detection limits (Table 7).
Analyses of stream and stream sediment samples revealed the presence of
PCP in the water and sediments of the drainageway leading from the site
to McGirts Creek. Surface water concentrations near the site exceed the
surface water criteria established in Chapter 17-3061.3 (M) FAC, but
attenuate to below these criteria prior to reaching General Avenue. The
mechanism for this attenuation is probably a combination of dilution in
water and adsorption to soils. Sediment samples were found to contain
low levels of PCP south of General Avenue, and no indication of PCP at
McGirts Creek.
HYDROGEOLOGY
Groundwater Characteristics
At the Coleman Evans site groundwater contaminants were identified in the
upper portion of the water table zone of the Surficial Aquifer System.
The Surficial Aquifer System is comprised of three units: the water table
zone, the semi-confining unit, and the limestone unit. In the site area
private groundwater supplies are obtained from the limestone unit which
is locally well-protected by the semi-confining unit. Groundwater flows
to the south and south west of the site.
Groundwater Contaminants
Groundwater samples were collected from 12 new monitoring wells (Figure
10) and 13 private wells (Figure 11). The well samples were analyzed
under, the CLP program, and no contaminants except for methylene chloride
were found, but it was identified as a laboratory contaminant.
New monitoring well sample results are presented in table 8. The only
metals identified with concentrations above existing standards were
beryllium and magnesium, but based on the soils data, this occurrance is
believed to be natural. Several compounds were identified in background
wells and in blank water samples and cannot be attributed to the site.
These compounds are bis (2-ethylhexyl) phthalate, hexahydroxepinone,
acetone, and toluene.
Several compounds were identified downgradient from the site, but not
onsite, carbon disulfide, 1,1,1-dichloroethane, and 3,3-dichlorobenzene.
Finally, PCP was identified in four onsite boreholes, but only BH-40
contained levels above the 1980 Water Quality Criteria of 1.01 mg/1.
(23)
-------
COLEMAN EVANS
WOOD PRESERVING
^—-v-
'io«i«» L \
BASE MAP IS A PORTION OF THE
U.S.G.S. MARIETTA. FLORIDA
QUADRANGLE 7.5 MINUTE SERIES
(PHOTO REVISED 1970)
Figure 9a. Locations at which Surface Water and Sediment Sanples were
Collected During the EPA Remedial Investigation.
-------
to
m
GENERAL AVENUE
"\SW-20
SD-20
LEGEND
SW-17 • WATER SAMPLE
SD-17 SEDIMENT SAMPLE
Piquio <>\>. Locations at which Surface Water and Sedi/nent Sairples were CoJ looted Durinq the
i:i'A Ktmxlial Investiqation.
-------
Table 7. Analytical Results of Surface Water Sarrples Collected during the
Remedial Investigation. Concentration Presented in Micrograms
per Liter (ug/1).
Pentachloro-
Phenol
C-ll Alkene
Total Xylenes
Sanple Location Nuirber
SW-15
SW-16
SW-17
r SW-18
4700x
7.1x
SW-19
77x
30x*
SW-20
360x
SW-21
SW-D1
3100x
7.7x
Aluminum
Antimony
Arsenic
870x
790x
6.5
640x
240x
570x
61x
600x
41 Ox
58x
200x
55x
Cadmium
Chromium
Cobalt
9x
9x
Iron
Lead
Magnesium
880x
1400x
760x
1600x
960x
5800x
360x
2800x
7x
llx
lOOOx
5700x
•~
HOOx
2.8x
6000x
1200x
2.2x
4900x
43Dx
2800>
Manganese
Potassium
Silver
29x
27x
21x
48x
1200x
7x
28x
33x
25x
1200x
62x
l20Cb
6x
Sodium
Tin
Zinc
6900x
26x
4800x
20,000x
15x
7000x
31x
22,000x
18x
21,000x
21x
23,000x
42x
44x
83(X)>
x = estimated value
* = tennatively identified carpound
(26)
-------
MW-610 BMW-52
MW-60
•""•'WSP
/
Q
GENERAL AVLNUC
MW-59
a
«... ««
n
1~J
MW-61
LEGEND
LOCATION OF SHALLOW MONITOR WELL
LOCATION OF DEEP MONITOR WELL
LOCATION OF INTERMEDIATE
MONITOR WELL
- N
T
MW-57
czi
CLUSTER WELL
Figure 10. Location Map of New Monitoring Wells Installed cind Sampled Durincj the EPA
Remedial Investigation.
-------
•PW-1
• PW-2
T
I
4i -
[•
(
'
V
AREA
PW-3
n\GJ__uuus-
n
Li
1™f • Ml HfH
II
3—i
-PW-6
OCHCRAL AVO4UC
•PW-14
/
/
y
/
Q
^
pw-12
a
00
(N
LEGEND
PW-1» PRIVATE WELL SAMPLE LOCATIONS
1'i'juif II. I/ K-.it KM> Kip of I'rivato Wt;lls Son|)lo(l Durinq tln> Kl'A
Invest iqat ion.
-------
Table 8. Analytical Results of Ground Water Samples Collected from
New Monitoring Wells Installed During the Remedial
Investigation. Concentration Presented in Micrograms per
Liter (ug/1). :
3,3-Dichloro-
benzidine
Carbon
Disulfide
1 , 1-Dichloro-
ethane
Well Identification Number
MW-51
MW-52
MW-53
MW-54
MW-55
11
MW-56
Aluminum
Beryllium
Cadmium
3100
410
880
380
1800
6.0
380
Calcium
Chromium
Copper
18
60,000
24
8900
71,000
30
11,000
110,000
Iron
Lead
Magnesium
790
7.2x
470
21x
2300
2500
7.8x
2300
270
3200
2000
470
5.9x
3400
Manganese
Potassium
Selenium
20
4600x
5.5x
22
53,000x
58
6000x
21
24,000x
37
2800x
41
17,000x
Sodium
Zinc
22,000
26,000
85x
89,000
23x
18,000
40,000
19,000
30x
x = estimated value
(29)
-------
liable 8 (cont.
Analytical Results of Ground Water Samples Collected
from New Monitoring Wells Installed During the
Remedial Investigation. Concentration Presented in
Micrograms per Liter (ug/1).
3 , 3-DJ chloro-
benzidine
Carbon
Disulfide
1,1-Dichloro-
ethane
Well Identification Number
MW-57
8.1x
MW-58
4.3x
4.3x
MW-59
r MW-60
200
6.2x
MW-61
MW-62
8.6x
Aluminum
Beryllium
Cadmium
810
440
7. Ox
550
860
1200
1400
Calcium
Chromium
Copper
3800
11
3400
1 3600
11
3100
13
46
Iron
Lead
Magnesium
4200
3600
6. Ox
2700
2500
2800
6.7x
4200
5.7x
2800
1300
9.4x
Manganese
Potassium
Selenium
61
3100x
69
4800x
28
2800x
20
4200x
33
2700x
6000x
7.4x
Sodium
Zinc
14, 000
39x
33,000
21x
24,000
41x
22,000
102x
24,000
89x
36,000
26x
x = estimated value
(30)
-------
SECTION IV
ENFORCEMENT ANALYSIS
As noted in Section II of this document, the Coleman Evans Wood Preserving
Company has been involved in litigation with both the State of Florida
and U.S EPA. In Septeniber 1984, Florida filed suit against Coleman Evans
seeking relief which would require the company to perform both short-term
and long-term remedial actions at the site. That suit is ongoing and
has recently been amended to include charges of violation of RCRA
requirements. In October 1984, EPA issued an administrative order pursuant
.to Section 106 of CERCLA, requiring Coleman Evans to conduct sampling
and perform immediate removal activities. Coleman Evans refused to comply
with the order, and denied EPA access to the site to perform the response
activities. Therefore, in March 1985, EPA filed a motion in Federal
Court, seeking an order which would permit EPA to enter the site and
conduct response activities. That motion was granted and EPA conducted
an immediate removal action in June 1985.
During the public comment period which followed the release of the RI/FS,
Coleman Evans submitted a proposal for remedial action at the site. That
proposal suggested treatment of the contamination by biodegradation. As
noted in Section V, that alternative has been rejected due to concern
over the extensive time period required and the possibility of incomplete
digestion of PCP leaving a dioxin residue.
Upon finalization of the Record of Decision, the Agency intends to formally
notify the company of the remedy which has been selected, and initiate
negotiations with them for the conduct of the remedy. If the company
does not formally commit to perform the remedy, and provide assurances
that adequate funding is available to complete the remedy in a timely
manner, EPA will proceed with a Fund-financed Remedial Design/Remedial
Action.
It is important to note that implementation of the remedy recommended in
this jSunmary of Remedial Alternative Selection may temporarily disrupt
operations at the Coleman Evans Wood Preserving Company during the
implementation of the Remedial Action. The extent of the disruption,
if any, will be determined during design of the selected remedy.
-------
SECTION V
ALTERNATIVES EVALUATION
PUBLIC HEALTH AND ENVIRONMENTAL OBJECTIVES
Public Health. The public health threat posed by the Coleman Evans Site,
as identified in Public Health Evaluation (Appendix A, FS), is minimal.
Several exposure pathways are complete including physical contact with
the contaminated soils, sawdust, and surface waters, inhalation of airborne
particulates, and the potential for ingestion of contaminated ground
water. The Public Health Evaluation found that the site currently appears
to pose significant health threat based on the levels of contamination
which were identified in the Remedial Investigation, but potential exposures
are a risk.
Environmental Concerns. The surface water levels of PCP identified in
the remedial investigation indicated that the site poses a threat to
aquatic species. Unless the PCP runoff into the drainage ditch and
ultimately into McGirts Creek is prevented, there is significant
potential for adverse environmental impact.
Alternatives Considered
Several alternatives were considered for remediating the Coleman Evans
site. The alternatives were presented in groups targeted at remediating
a single aspect of the site. Table 9 shows the technologies identified
for remediation of the ground water contamination (Group A alternatives),
and technologies considered for remediation of soil contamination (Group
B alternatives).
Several confcinations of group A and group B alternatives will provide
remedial actions which ccnply with applicable environmental laws. One
example is a combination of ground water recovery and treatment (Group
A), and containment/encapsulation (Group B). Ground water recovery and
treatment will respond to issues raised under the Clean Water Act (CWA),
the Toxic Substances Control Act (TSCA), and the Resource Conservation
and Recovery Act (RCRA). These same laws are also addressed by containment
encapsulation of the landfill material.
Screening of Technologies
Potential remedial alternatives identified for the Coleman Evans site
were initially screened on the basis of technical feasibility and level of
protection provided to public health. For example, biological degradation
of PCP was eliminated during the initial screening phase because of the
protracted time frame necessary to accomplish cleanup and because incomplete
degradation can lead to a residue of dioxin in the soils. Similarly,
thermal treatment was eliminated because this technology does not provide
any additional effectiveness compared to incineration of soils and it is
not cost effective compared to incineration.
-------
Table 9. Technologies Considered for Remediation of the Coleman Evans Site.
A. Ground Water Technologies (Group A Alternatives)
1. Treatment Technologies
a. Flocculation, Sedimentation, and Filtration
b. Activated Carbon Adsorption
2. Recovery and Disposal Technologies
a. Recovery
b. Surface Water Discharge
c. Ground Water Recharge *
B. Soils Technologies (Group B Alternatives)
1. Treatment Technologies
a. Off Site Disposal
b. Solidification and Stabilization
c. Incineration
d. Solvent Extraction
e. Thermal Treatment * ' .
f. Land Treatment *
g. Insitu Bicdegradation *
h. Containment and Encapsulation
j. Surface Capping
2. Recovery Transport
a. Excavation
b. Transportation
(*) = Denotes technologies vrtiich were eliminated during the
preliminary screening phase.
(33)
-------
The next phase of alternatives screening was based on a detailed review
of each remedial alternative based on site specific criteria. The second
phase review considered technical feasibility, the level of public health
and environmental protection provided, and on a relative cost-estimate
basis. The alternatives eliminated during this phase are listed in
Table 10.
The alternatives Which were retained after screening were then described
in detail with regard to engineering considerations, equipment needs,
operation and maintenance needs, monitoring requirements, health and
safety, permitting requirements, scheduling projections, and cost estimates.
Technologies Eliminated
Several alternatives were eliminated in the preliminary screening phase
and in the detailed screening. The following is a list of remedial
options which were eliminated during the screening phases and the reasons
for elimination.
Ground Water Technologies.
Ground Water Recharge. Dae to the locally high water table, ground water
recharge of recovered ground water would likely flood the surface
environment. This alternative was eliminated in favor of discharge to
surface waters.
Flocculation, Sedimentation, and Filtration. This technology is feasible
and the risks to worker safety and the environment are short-term.
However, carbon adsorption was found to be equally feasible and had none
of the short-term risks. Therefore, this remedy was screened out in
favor of carbon adsorption.
Soil Technologies.
Thermal Treatment. Thermal treatment was eliminated because the effective-
ness of this technology is equivalent to incineration, but incineration
is significantly more cost effective.
Land Treatment. This technology requires a large land area, extensive
material transport and handling, and extensive monitoring. Other
technologies identified have fewer implementation constraints and are
equally effective.
In Situ Biological Destruction. Incomplete digestion of PCP could leave
dioxin by-products.Biological treatment requires extensive pilot testing
and the time involved in execution of this technology is protracted.
(34)
-------
Table 10. Technologies Eliminated During the Coleman Evans Wood Preserving
Ccnpany Feasibility Study Screening Process,
TECHNOLOGIES ELIMINATED
REASON
Ground Water Technologies
Flocculation, Sedimentation,
and Filtration
Ground Water Pecharge
Carbon adsorption is equally
effective and less expensive
Recharge rates are too slow
for effective implementation
Soils Technologies
Thermal Treatment
Land Treatment
In Situ Biodegradation
Incineration is equally
effective and less expensive
Requires large areas of
land and long term (30
years) monitoring
Requires extensive testing,
long implementation period,
and may leave dioxin
residuals
(35)
-------
ALTERNATIVES RETAINED
Several technologies were retained for final consideration as alternatives
for remediating the site. Those alternatives retained are listed in
Table 11. With the exception of the No Action Alternative and surface
capping, all technologies inherently include ground water recovery and
treatment due to the fact that these technologies require dewatering for
excavation.
Each of the remaining alternatives was evaluated based on technical
feasibility, environmental impact, and public health concerns (Table 12).
The present worth and operations and maintenance costs are presented in
Table 13. Technologies which were found to be feasible for the Coleman
Evans site are described below.
Ground Water Technologies
Alternative 1. Well Point Ground Water Recovery, Carbon Adsorption, and
Surface Water Discharge. This technology involves a mobile well point
configuration for recovery of contaminated ground water and for dewatering
of excavation areas. Recovered ground water would be analyzed, and treated
if contamination is found. Treatment will involve passing contaminated
ground water through a carbon adsorption unit. This technology is well
proven and can have removal efficincies up to 99%. Discharge would
be to the surface water environmemt. The contaminant concentration in
effluent must be less than 1 ug/1 in order to comply with State surface
water standards for PCP.
All excavation technologies inherently will require use of this recovery/
treatment/disposal option. Therefore, this technology has been included in
all excavation options, and carbon adsorption has not been cost evaluated
as a single item.
Soil Technologies
Alternative 1 - Surface Capping. This option involves leaving contaminated
soils in place and constructing a RCRA-approved cap over identified areas
of PCP soil contamination. A cap will prevent runoff of PCP into the
surface water environment, reduce air emissions, and prevent further
migration of PCP into the soils.
Alternative 2 - Containment and Encapsulation. This technology consists of
constructing an impermeable barrier,excavating the contaminated soils and
placing the soils within the impermeable barrier, and capping the soils
to provide full encapsulation onsite. Ultimately, the contaminated soils
would be removed from contact with the environment.
Alternative 3 - Solidification and Stabilization. This technology would
require excavation of contaminated soils and solidification by using a
mixture of soils with either a cement - based process or other pozziline
process, and on-site storage to solidify the contaminated soils. Although
pilot testing would be required, this technology will reduce the solubility
or mobility of the wastes or may detoxify the contaminants.
(36)
-------
TABLE 11. Remedial Technologies Retained for Detailed Evaluation.
1. Surface Capping
2. Containment/Encapsulation*
3. Solidification and Stabilization*
4. Off Site Disposal*
a. Etnelle, Alabama
b. Pinewood, South Carolina
5. Incineration *
6. Solvent Extraction *
7. No Action
(*) = Denotes technologies that inherently require groundwater
recovery operations to facilitate excavation activities.
(37)
-------
Table 12. Surrmary of Evaluation of Remedial Alternatives.
Alienist I ve
I . Surface
Capping
Cost Conf Hence
OnTI Co a I ~flange*
17.85 to 4VM
Technical feasibility
Conventional equivalent
t> procedure* are uaed
(or capp 1 ng .
Kuv 11 01 t-.ent a 1 l*»t>ac I
Hr it urea air eat as 1 ona, nur-
face runoff f I den* a I con-
Inrt . (.round water re-tain*
cont ami itnt ed .
Public Health Concern*
Potential risks of people
drinking contaminated water
or Ingesting vegetable*
having accumulated PCPa.
InatItutlonal Requlremenla
Requirement* for 4OCKK I'nrta
760 through 264 for closure
plana applicable to aurface
capping. I)KR permit.
U)
CD
2. Sol Idl ( leal Ion Conventlonal equipment
& procedurea uaed for aoll
excavation & aol Idl f Icat Ion .
Cleanup effeel Ivenea* must
Coal Conf Idence
Unit Cost Range*
87.81 to 99. /I
be verified with leach
teat a .
SolIdlIIcatIon of contami-
nated aolla will minimize
possible adverae environ-
mental Impact a.
Rlak exposure of workera
during excavation la high.
After colIdlfIcatIon. rtak
of exposure to contaminated
aolla la low. The rlaka of
ground water contamination
wl11 be algnlfleant ly
reduced.
Local permits may be required
for alte activities. Slate I>KR
permit RCRA permit required for
discharging treated water to
NcClrta Creek. Requirement of
of 40CPR Parts 760 through 264.
170 » 124 are applicable for
solldlflcallon/alahlllzallon.
1. Containment &
KncapaulatIon
Cost ConfIdence
Unit CoHt Range*
^8. IS to 76.71
Conventions! equipment
and procedures used lor
aol I exi aval I mi &
Conl a I iiMent . Vi a I tied
pelHOlliiel ncf-tt*d tor liner
n.ltt «ellioo«alble fiivl ruiiMcnl a I 1«^
|.A< t n . '.i» Ht *•( envl i uii«rn-
lal rlak than Allcruntlve.1
I i '2. .Lie l.i |>oa»lbLe tm\\
ti i c »f ( he I I lie r .
• laka aaaoclated with process Requirements for 40 CKH Part a
Include worker*' exposure to 760 through 2h4 RCRA specifics
contaminated aoll* i duat tlona for TSO (acllltli-s.
particle* during excavation.
The long-term Incremental re-
duction In rlak Include* elim-
ination of air, surface i
ground water pathway*.
4 . So 1 vent
KxlractIon
C.nn t Con f I dence
Unit Coil Range*
lit).(10-440. I/
Speclsllzed e<|til|*ment ft pe r -
ftoiine I needed f»i solvent
extraction. Common equipment
& |>roce.|uir use I tor
eHt avni I on .
fCP tout ami nat ed soils are
rxliHtled & potential ad-
veine env I i oiiment M I Impact
IK all Igsl ed .
Same concerna regarding ex- Same as All c^rnat I ve I, |>lun Ixil
ravbal Ion a* Alternative I. permits for I r annpor I al I >l
llalng a non-toxic aolvenl o( com ent r ill i-d extisitr.l
will achieve an overall risk fluids containing l'( P« . M'A
ir.liullon from PCP contaml- msnlfenl .loi ument nt I on
nat I on . requ I r eif.
-------
Table 12 (cont.). Sunrnary of Evaluation of Remedial Alternatives.
U)
VO
Alternat tve
Technical Feasibility
•>. lucliierat Ion
Cost Confidence
Unit Cost Range*
I88.U2-2U6.94
Environmental Impact
Public Health Concerns
Institutional Requirements
Common equlpaienl ft proce-
dure* used for sol 1 excava-
tlon. Specialized equipment
ft expert technical personnel
required. Incineration has
•echanlcal component a sub-
ject to breakdown 4 costly
delays.
Sliort-terai potential for
releases of tonic eislaslona
& residues Into environment.
Effective engineering ft man-
aKesient of air pollution con-
trol ft quenching system will
mitigate passible environmental
risk.
High potential for risk
reduction or organic PCP
contaminants.
This option may demand air
quality 'pentta from UK.H .
6. Off site
Disposal
Cost Confidence
Unit Cost Range*
188.36-224.89
Common equipment ft proce-
dures uaed for aoll excava-
tion • offalte trucking.
Possibility of spill during
transportation of soils.
This alternative will have This alternative will have State a Federal IX>T permits
additional (low) envlronmen- Incremental public health required for transportation of
tal rlaks due to possibility rlaka reduction because PCPs contaminated soils. H'A maul-
of spills during transports- are removed 4 tranaported. fest documentation required.
t Ion.
7. No Action No additional equipment or
facilities required.
High possibility of wast*
migration via suit see runoff
ft ground water. Possible
Impact on receiving walera.
Possible rlaks of Ingest Ion,
dermal contact a Inhalation
of PCPs at levels considered
tonic to humans.
None
• Unit costs are expressed In dollars per ton.
-------
Table 13. Cost Estimates of Retained Remedial Technologies
Technologies
Surface Capping
Containment /Encap-
sulation *
Solidification *
Offsite Disposal *
Pinevood, SC
Emelle, AL
Incineration *
Solvent Extraction
Present Worth
Construction
Cost Dollars
447 , 950
992,000
1,4%, 000
3,606,000
5,088,000
3,703,000
5,767,400
Present Worth Total Present
O&M Cost, Dollars Worth Cost
334,000 781,950
334,000 1,326,200
218,000 1,714,900
0 3,606,600
0 5,088,000
0 3,703,000
41,700 5,809,100
(1)
Ratio
1
1.70
2.19
4.61
6-51
4.74
7.43
(1) = Ratio of technology costs over the cost of the technology with the
lowest present worth cost.
* = Costs include ground water recovery and treatment operations.
(40)
-------
' '£..
Alternative 4 - Offsite Disposal. This technology involves excavation of
contaminated soils and transport to an offsite RCRA-approved facility for
treatment, storage, or disposal. Approved facilities exist in Bnelle,
Alabama and Pinewood, South Carolina.
Alternative 5 - Cnsite Incineration. This option would involve the use of
a temporary incineration facility to destroy PCP in contaminated soils
excavated from the site. Contaminated soils would pass through a primary
chamber to "flash" the PCP from the soils and PCP destruction would occur
in a secondary chamber with higher temperatures. The soil residue would be
used to backfill excavation trenches after analysis had demonstrated that
the PCP had been efficently removed.
Alternative 6 - Solvent Extraction. "Soil Washing" would consist of using
some type of solvent such as methanol to remove toxic substances (PCP) from
the soil. Treatability studies conducted during the Remedial Investigation
demonstrated that this technology is feasible for this site on a bench
scale. However, full scale testing will be required.
Alternative 7 - No Action. This option would preclude further EPA involvement
with the Coleman Evans site and no further expenditures of Superfund money.
Institution of the no action alternative may not immediately impact public
health or welfare, but it would allow PCP contaminated site runoff to
continue to enter the surface water regime, thus contributing to the
deterioration of the environment.
(41)
-------
SECTION VI
COMMUNITY RELATIONS ACTIVITIES
Carmunity relations efforts for the Coleman Evans site were initiated in
November 1984 when EPA personnel visited the site along with personnel from
the REM II community relations contractor, ICF, Inc. Attempts were made
to contact area residents; however, neighborhood response ranged from dis-
interest to strongly negative sentiment. Only two area residents agreed to
discuss the site: Mr. H.G. Moore, 10917 General Avenue, and Mrs. Mamie Norman,
10904 General Avenue.
An information repository was established at the Whitehouse Elementary
School near the site, and all finalized documents were placed on file to
provide local public access.
Curing the RI/FS process, EPA was never contacted by concerned citizens with
regard to the Coleman Evans site; although sporadic press interest was
generated.
At the completion of the RI/FS process, EPA published and mailed a fact
sheet to interested parties as identified in the March 1985 Community
Relations Plan. On August 7, 1986, a public meeting was held to discuss the
findings of the RI/FS. Attendance was light and the question and answer
session was not extensive. The public meeting served to initiate a 3 week
public comment period which closed on August 28, 1986. The only written comment
received during this period was a proposal for a remedial action submitted by
Coleman Evans contractors. The responsiveness summary was completed on
September 16, 1986, and placed into the information repository. A copy of
the responsiveness summary is presented in Appendix A.
-------
SECTION VII
z- CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
Environmental Laws which may be applicable or relevant to the remedial
activity are: _._
— Safe Drinking Water Act (SDWA)
— Resource Conservation and Recovery Act (RCRA)
— State of Florida Administrative Code Chapter 17-3.061.3(m)
- Surface Waters: General Criteria
— Federal Water Quality Criteria (WQC)
— Clean Air Act (CAA)
Locally private wells obtain water from the limestone unit of the surficial
aquifer system, which is protected by a high integrity confining unit.
During the RI field study, numerous private wells were sampled and analyzed.
The results indicated that the private wells have not been impacted by the
site. Therefore, the residents currently have a safe drinking water supply,
as specified under the SCWA.
The no-action alternative would not comply with the Hazardous Waste
Regulations identified in Subtitle C of RCRA. However, all other
alternatives being considered are in accordance with RCRA Subtitle C. The
selected alternative, as outlined in Sectin VIII, includes excavation of
contaminated soils. In order to implement soil excavation, the upper
portion of the aquifer will require dewatering. Contaminated ground water
must be treated until the PCP concentration is less than 1 ug/1 in order to
comply with the surface water discharge levels set forth in Chapter 17-3
061.3 (m) FAC. This level was established by the State of Florida to
protect aquatic species. The Federal Water Quality criteria has not
established a standard for PCP to protect aquatic species; however, a
human health criteria of 30 ug/1 was established to prevent organoleptic
effects. A soil cleanup level of 10 mgAg was based on risks identified in
the Public Health Evaluation (FS, Appendix A).
Incineration activites would be conducted in accordance with the applicable
permitting standards and operations protocols established in the Clean Air
Act. A quality assurance program would be developed under the remedial
design phase.
The National Resource Damage Assessment conducted by the Fish & Wildlife
Servive concluded that the Coleman Evans Site has not impacted any federal
trustee resources (Appendix B). There are currently no threatened
wetlands and the site is above the 500-year flood plain (Figure 12).
-------
Figure 12. 500-Year Flood Potential Map for the Area Surrounding
the Coleman EVans Wood Preserving Company. Zones
Designated with the Prefix "A" Indicate Areas of 100-
Year Flood levels (Dark Areas) and 500-Year Flood Zones
are Designated with the Prefix "B". National Flood
Insurance Program Insurance Rate Map #12007-0500-0.
(44)
-------
SECTION VIII
RECOMMENDED ALTERNATIVE
'SELECTED REMEDY
The recommended alternative for the Coleman Evans site consists of excavating
all soils which have PCP contamination in excess of 10 mgAg/ and destruction
of the contaminants through onsite incineration. In order to excavate the
contaminated soils, dewatering will be necessary.
A mobile incinerator will be used onsite to destroy the PCP found in soils.
The process will involve use of primary and secondary incineration chambers.
PCP and diesel fuel will be converted to gaseous phases in the primary
chamber and thermal destruction will occur in the secondary chamber.
Decontaminated soils will retain virtually their initial volume and can be
used to backfill excavation areas. The total volume of soils to be treated
is estimated to be 9,000 cubic yards.
Ground water recovery will involve localized use of well points, which are.
sufficient for the shallow excavation depths (less than 20 feet) necessary
at this site. Areas in which ground water contamination was identified
coincide with areas of soil contamination, thus there is little risk of
allowing contaminated ground water to escape; however, all ground water with
PCP concentrations greater than 1 mg/1 will be recovered. The recovered
ground water will be analyzed and treated by activated carbon adsorption if
PCP concentrations exceed 1 ug/1. Treated effluent will be discharged to
an on site drainage ditch. The spent carbon will be thermally regenerated,
which will destroy the remaining PCP contamination. The volume of ground
water containing PCP in excess of existing standards is conservatively
estimated to be 900,000 gallons.
Other incidental Hazardous Substance List compounds identified in the ground
water during implementation of this remedy will be cleaned up to levels
which comply with Drinking Water Standards. If the Drinking Water Standards
do not address these compounds, cleanup levels will be consistant with the
human health criteria identified in the 1980 Water Quality Criteria. Clean
up of"compounds for which no standards exist will be to non-detection levels.
In cases where standards promulgated by the State of Florida are more
stringent, the state standards will have precedence. Also, should EPA
promulgate standards which are more stringent than existing standards or
criteria, the newer standard will be implemented.
Since this alternative provides total destruction of the wastes, long term
monitoring is not required, nor will there be any operation and maintenance
costs associated with this remedy. Nor will land use restrictions be
imposed.
COST-EFFECTIVENESS
This remedy selected for the Coleman Evans site is the most effective
alternative, and is considered to be the most permanent remedy of choice
which resolves the threats posed by the site. The environmental benefits
-------
gained outweigh the financial advantages gained by selecting a more
cost-effective solution. A summary of feasible alternatives and rejection
criteria are presented in Table 14.
The selected remedy is estimated to cost between $3.0 and $3.8 mrilion
dollars. The State of Florida has instituted a program for addressing the
problems posed by uncontrolled hazardous waste sites. This program is
designed on the CERCLA model and is operated similarly to Superfund
through the Florida Department of Environmental Regulation. The State of
Florida has agreed to fund 10% of the cost for implementing the selected
remedial action (Appendix C). The City of Jacksonville Bio-Environmental
Services Division has also concurred with the selected remedy (Appendix D).
(46)
-------
Table 14. Sutmary Table of Feasible Alternatives and Cost-Effectiveness
Comparison. Costs Presented in Millions of Dollars^
Remedial Alternative
Reason for Non-Selection
Estimated
Cost Range
1. Surface Capping
Implementation would not deal permanently
with the site contamination although
it provides a high degree of protection
to surface water and air. Groundwater
contamination would remain. Restricts
site use.
0.5 to 0.9
.2. Solidification and
Stabilization
This is a viable alternative, but
contaminants would remain on-site
and long-term monitoring would be
required. Land use limitations
1.4 to 1.9
3. Containment and
Encapsulation
This is a cost-effective option, but
contaminants would remain untreated.
Greater environmental risk arises from
the potential for liner failure. Long
term monitoring and O&M will be required,
0/7 to 1.5
4. Solvent Extraction
This option is fully effective for
migration of all threats, but incineration
is equally effective with a lower cots.
4.5 to 9.6
5. On-Slte Incineration
3.0 to 3.8
6. Off-Site Disposal
Does not remediate wastes, only involves
transport to a RCRA-approved facility.
2.9 to 4.2
7. No Action Alternative
No remediation of site specific conditions
potential health and environmental risks.
0.0
(47)
-------
SECTION IX
OPERATION AND MAINTENANCE
No operation and maintenance will be required for the selected remedy since
all existing contamination will be thermally destroyed.
-------
SECTION X
FUTURE ACTIONS
Successful implementation of the selected remedy will ultimately remove the
Colemari Evans Wood Preserving Conpany site from under the jurisdiction of
the Comprehensive Environmental Response, Compensation and Liability Act
once it has been deleted from the NPL. Future site actions will be limited
to applicable aspects of the Resource Conservation Recovery Act (RCRA), for
the duration of the facility's existance.
-------
SECTION XI
PROJECT SCHEDULE
The schedule for the RD/RI phases of the Coleman Evans Wood Preserving Corrpany
remediation are dependent on the success of enforcement negotiations. If the
PRPs agree to undertake RD/RA, the schedule will be negotiated to acconrnodate
EPA, FDER, and the PRPs.
If, however, negotiations with the PRP are unsuccessful, EPA will follow
the schedule outlined below:
Schedule Landmark
1. Finalization of the ROD
2. Complete Enforcement Negotiations
3. Award Super fund State Contract (and
IAG) for Design
4. Initiate Design
5. Complete Design
6. Award/Amend Superfund State Contract
(and IAG) for Construction
7. Initiate Construction
8,. Complete Construction
Date for
Impl ementaion
9/30/86
12/31/86
2/31/87
4/1/87
10/1/87
10/30/87
12/1/87
12/1/89
-------
APPENDIX A
RESPONSIVENESS SUMMARY
Coleman Evans
Wood Preserving Company
-------
REGION IV
COLEMAN EVANS WOOD PRESERVING CO.
RESPONSIVENESS SUMMARY
September 16, 1986
-------
. RESPONSIVENESS SUMMARY
COLEMAN EVANS WOOD PRESERVING COMPANY SITE
U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
This is the Responsiveness Summary for the Coleman Evans Wood Preserving
Company site in Whitehouse, Duval County, Florida. Since the EPA received
written comments from only one source during the Feasibility Study public
comment period, this document consists of a summary of the community
relations activities conducted at this site, a response to the one written
response received, the Feasibility Study fact sheet, and the transcripts
from the public meeting.
Following the Work Plan phase of the study from September 1984 to April .
1985, the Remedial Investigation/Feasibility Study (RI/FS) for the site was
conducted from June 1985 to June 1986. EPA received no telephone calls or
letters from the public concerning the site during that time. A community
relations plan describing community concerns and recommending community
relations activities was prepared in March 1985. In accordance with the EPA
National Contingency Plan and suggestions made in the Community Relations
Plan, EPA established an information repository at the Whitehouse Elementary
School. The repository contained public documents on the site, including
the RI/FS work plan and the RI/FS report.
Once the draft FS was completed, a fact sheet (Attachment A) was prepared to
describe the remedial technologies that EPA was considering for the site,
the proposed clean-up goals, and the details of the public meeting and the
public comment period. The fact sheet was mailed to individuals on the
Coleman Evans site mailing list and placed in the information repository.
Announcements for the public meeting and the public comment period were
placed in local papers. EPA held the public meeting on August 7, 1986 and
the public comment period covered the period from August 7 to August 28,
1986. Approximately 10 to 15 concerned citizens attended the public meeting.
The~transcripts of the public meeting are presented in Attachment B.
The only written response received was from Ground Water Technology, Inc.
(GTI), a consultant for the Coleman Evans Wood Preserving Company. The GTI
proposal is summarized below, and the full document is presented in
Attachment C.
Cctnnent Summary
GTI submitted a response to the Feasibility Study. The document which was
submitted was a "Response to Feasibility Study" in which GTI outlined a
proposal to undertake photo/biodegradation of the contaminated waters and
soils at the site and to recovery and recycle the free-floating pentachloro-
phenol/diesel fuel mixture from the surficial aquifer. The proposal included
site history, a work plan, a monitoring program, a cost evaluation, and a
photo/biodegradation process summary.
-------
Response
EPA reviewed the potential application of biodegradation for the Coleman
Evans site during the Feasibility Study and has reviewed the proposal
submitted by GTI. This technology was eliminated during the earl%r phases
of the Feasiblity Study because of technical problems associated with
biodegradation. First, the feasibility of this process would have to be
determined during a long term pilot testing program, especially since there
have been limited previous studies which evaluate biodegradation of
pentachlorophenol. Second, the volume of contaminated soils (estimated to
be 9,000 cubic yards) would require a long period of time for complete
digestion of the contaminants, especially at the greater depths of
contamination identified during the Remedial Investigation. Third, the
contaminants which are at depth may exist under anaerobic conditions. In
order to evaluate biodegradation as a feasible option, a very wide range of
conditions would have to be implemented during the testing process. Finally,
there is a potential for the creation of unacceptable by-products during
the biodegradation process; specifically dioxins. Generation of dioxins
vsould further increase the risk to the public health and welfare, and to
the environment than is currently posed by pentachlorophenol, the main
contaminant of concern.
Although the financial aspects of biodegradation are attractive, the
potential for greater health and environmental risk and the long periods of
time required for testing and implementation are unacceptable to EPA. For
these reasons- EPA eliminated biodegradation technologies during the Coleman
Evans Feasibility Study process. EPA has determined that biodegradation is
not sufficiently proven to be an acceptable option for remediation of the
conditions at the Coleman Evans Wood Preserving Company site.
-------
APPENDIX B
Natural Resource
Damage Assessment
Coleman Evans
Wood Preserving Company
-------
United States Department of the Interior
OFFICF OF THE SECRETARY
-liTON, D.C. 20240
JUN 2 I '335
ER84/1518
Mr. Gene Lucero, Director
Office of Waste Programs Enforcement
Environmental Protection Agency
401 M Street, SW (Room S362N) WH 527
Washington, D.C. 20460
Dear Mr. Lucero:
The Department of the Interior has conducted a preliminary natural resources survey of
the Coleman/Evans Wood Preserving Company at Whitehouse, Duval County, Florida, to
determine whether the Secretary of the Interior's trust responsibilities for natural
resources have been affected.
Our survey indicates that there are no lands under the trusteeship of the DOI near the
Coleman/Evans site. However, the Ortega River system nearby can be inhabited by
various trust resources, including anadromous fish, migratory birds, and endangered and
threatened species of wildlife. The manatee, an endangered marine mammal, can be
found in the Ortega River system.
Site visits and review of various reports and studies show that soils and surface waters
have not been seriously contaminated very far off site. There is no documentable
evidence that our trust resources have been affected by materials from this site.
However, we believe the site should be cleaned up quickly so that contaminants do not
move off site.
Accordingly, we would grant a release from claims for damages to natural resources
under our trusteeship from the Coleman/Evans site, provided that timely remedial
action consistent with the NCP is taken to clean up the site.
Sincerely,
Blanchard, -Director
Office of Environmental Project Review
cc:
£_Steve Klein/EPA
-------
APPENDIX C
State of Florida
Letter of Concurrence
for the
Selected Remedy
Coleman Evans
Wood Preserving Company
-------
STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULATION
TWIN TOWERS OFFICE BUILDING
2600 BLAIR STONE ROAD
TALLAHASSEE, FLORI DA 32301-824 1
BOB GRAHAM
?T GOVERNOR
VICTORIA J. TSCHINKEL
SECRETARY
September 24, 1986
Mr. Jack Ravan
Regional Administrator
United States Environmental
Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Jack:
- a p ?/ -L- •
v 1^2 /T, r~: ;•; r->" ' •?' ™ ,~
L';
SEP 25 1985
The Florida Department of Environmental Regulation agrees with
the selection of Alternative #5 as described in the final
feasibility study for the Coleman Evans Wood Preserving Superfund
Site in Whitehouse, Duval County, Florida.
This alternative includes the excavation and on-site incineration
of soils and sediments, and the on-site treatment of contaminated
ground water. This alternative will effectively destroy contam-
inated soils and sediments and treat ground water.
The cost estimate for Alternative #5 ranges from $3.0 - $3.8 mil-
lion for the use of a temporary on-site incineration facility,
and groundwater treatment unit. Due to the complete destruction
of site specific contaminants by incineration, no post-remedial
monitoring or operation and maintenance activity is required.
The state will provide ten percent of the total cost, or about
$300,000 - $380,000 from the State Water Quality Assurance Trust
Fund.
We look forward to participating with the U. S. Environmental
Protection Agency during implementation of remedial activities
at the Coleman Evans .Wood Preserving site.
Sincerely,
Victoria J. Tschinkel
Secretary
VJT/ps
Protecting Florida and Your Quality of Life
-------
APPENDIX D
City of Jacksonville
Letter of Concurrance
for the
Selected Remedy
Coleman Evans
Wood Preserving Company
-------
DEPARTMENT OF HEALTH, WELFARE
& BIO-ENVIRONMENTAL SERVICES
Bio-Environmental Services Division
May 21, 1986
Ms. Kristina Teepen
Remedial Project Manager
U. S. Environmental Protection Agency - Region IV
345 Courtland Street
Atlanta, GA 30365
RE: Coleman Evans Wood Preserving Company ;-
Draft Feasibility Study
Dear Ms. Teepen:
The Bio-Environmental Services Division (BESD) has briefly reviewed EPA's Draft
Feasibility Study of Coleman Evans Wood Preserving Company, dated May 2, 1986.
The BESD would support the option of incineration, over the other options for
remedial actions, as presented. Incineration provides the following benefits
which BESD feels are noteworthy.
I. Destruction of the organics
II. Usability of the site after contamination disposal
III. No requirement for continual monitoring
Incineration, of course, as an option needs to be better defined prior to
implementation. Specifically such items as retention times, in situ monitoring,
etc. must be detailed. Further, in order for incineration to be viable, just from
a permitting standpoint, a great deal of public awareness and education on the
benefits—of the program shall be necessary. Otherwise a permit may be delayed as
a result of public concerns requesting Administrative Hearings.
If BESD can be of further assistance, please advise.
Very truly yours,
obert Steven Pace, P.E.,
Bio-Environmental Engineer
cc: Mr. Ernest E. Frey, P.E.
John K. Flowe, P.E.
Khurshid K. Mehta, P.E.
RSP/ns
DER
AREA CODE / 904 / 633-3318 / 515 WEST 6TH STREET / JACKSONVILLE, FLORIDA 32206-4397
-------
APPENDIX E
PUBLIC HEALTH EVALUATION
Submitted
by
CDC/ATSDR
Coleman Evans
Wood Preserving Company
-------
_. ttiviri, ^
•;*' '"J
(4
•<"..<,£<•
Date
From
Subject
To
DEPARTMENT OF HEALTH & HUMAN SERVICES
June 26, 1986
Public Health Advisor
ATSDR-EPA Liaison
Public Health Service
Agency for Toxic Substances
and Disease Registry
Memorandum"
Coleman-Evans
Duval County,
NPL Site;
Florida
Kris Teepen, RPM
EPA ERRB RAS
A7L..STA,
As requested, I have reviewed the Draft Feasibility Study,
dated May 2, 1986, for the referenced site. Given my long
term involvement with this site, and in the interest of time
for your program management purposes, I have elected not to
refer this document to the ATSDR for a more indepth review
and comment. I trust you will find the following useful.
Historical EPA and ATSDR review and other site documents on
file have sufficiently identified the actual and potential
public health issues of concern for this site, especially the
factors that must be present in order for a public health threat
to exist. The 1984 EPA emergency response action (excavation
of lagoon sludges) appears to have helped reduce the predominant
public health threat posed by the site (i.e. potential for
percolation and migration of contaminants to adjacent private
wells).
The qualitative risk assessment that is described in the FS
assesses on both technically and epidemiologically sound bases,
the potential health concerns existing at the site with current
(p. 1-1) and future use (p. A-32) exposure scenarios. As such,
any, or a combination of the three preferred remedial alternatives
(surface capping w/closure; solidification; incineration) appear
adequate to protect public health and to reduce the potential for
future exposures to occur that may increase the threat of exposure'
to site contaminants at levels that would be of health concern.
However, if a "No Action" alternative is selected, it appears
prudent that a monitoring program of private wells at the
residences adjacent to the site be considered. Contingency plan:
should also be developed if such monitoring identifies that site
contaminants at levels exceeding primary drinking water standard:
are found at those wells in use for potable purposes.
If I can assist further with the remaining remedial phases of th
site, ple_ase let me know.
QL?
Chuck
L
P ietrosewicr
cc: file
ATSDR/Buynoski
-------
REGION IV
COLEMAN EVANS WOOD PRESERVING CO.
RESPONSIVENESS SUMMARY
September 16, 1986
-------
RESPONSIVENESS SUMMARY
COLEMAN EVANS WOOD PRESERVING COMPANY SITE
U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
This is the Responsiveness Summary for the Coleman Evans Wood Preserving
Company site in Whitehousa, Duval County, Florida. Since the EPA received
written comments from only one source during the Feasibility Study public
cement period, this document consists of a summary of the ccrmunity
relations activities conducted at this site, a response to the one written
response received, the Feasibility Study fact sheet, and the transcripts
from the public meeting.
Following the Work Plan phase of the study from September 1984 to April
1985, the Remedial Investigation/Feasibility Study (RI/FS) for the site was
conducted from June 1985 to June 1986. EPA received no telephone calls or
letters from the public concerning the site during that time. A community
relations plan describing ccrmunity concerns and recommending community
relations activities was prepared in March 1985. In accordance with the EPA
National Contingency Plan and suggestions made in the Community Relations
Plan, EPA established an information repository at the Whitehouse Elementary
School. The repository contained public documents on the site, including
the RI/FS work plan anci the RI/FS report.
Once the draft FS was completed, a fact sheet (Attachment A) was prepared to
describe the remedial technologies that EPA was considering for the site,
the proposed clean-up goals, and the details of the public meeting and the
public comment period. The fact sheet was mailed to individuals on the
Coleman Evans site mailing list and placed in the information repository.
Announcements for the public meeting and the public comment period were
placed in local papers. EPA held the public meeting on August 7, 1936 and
the public comment period covered the period from August 7 to August 28,
1986. Approximately 10 to 15 concerned citizens attended the public meeting.
The-'transcripts of the public meeting are presented in Attachment B.
The only written response received was from Ground Water Technology, Inc.
(GTI), a consultant for the Coleman Evans Wood Preserving Company. The GTI
proposal is summarize"! 'rvlow, and the full document is presented in
Attachment C.
Garment Summary
GTI submitted a resper-- -3 the Feasibility Study. The document which was
submitted was a "Res^-.--: to Feasibility Study" in which GTI outlined a
proposal to undertake ph?tO''biodegradation of the contaminated waters and
soils at the site and to recovery ar1 rer/rle the free-floating pentachloro-
phenol/diesel fuel mixture from, the sur':icial aquifer. The proposal includes
site history, a work plan, a monitoring program, a cost evaluation, and a
photo/biodegradation process summary.
-------
Pfesponse
EPA reviewed the potential application of biodegradation for the Coleman
Evans site during the Feasibility Study and has reviewed the proposal
submitted by GTI. This technology was eliminated during the early phases
of the Feasiblity Study because of technical problems associated with
biodegradation. First, the feasibility of this process would have to be
determined during a long term pilot testing program, especially since there
have been limited previous studies which evaluate biodegradation of
pentachlorophenol. Second, the volume of contaminated soils (estimated to
be 9,OOC cubic yards) would require a long period of tijne for complete
digestion of the contaminants, especially at the greater depths of
contamination identified during the Remedial Investigation. Third, the
contaminants which are at depth may exist under anaerobic conditions. In
order to evaluate biodegradation as a feasible option, a very wide range of
conditions would have to be implemented during the testing process. Finally,
there is a potential for the creation of unacceptable by-products during
the biodegradation process; specifically dioxins. Generation of dioxins
would further increase the risk to the public health and welfare, and to
the environment than is currently posed by pentachlorophenol, the main
contaminant of concern.
Although the financial aspects of biodegradation are attractive, the
potential for greater health and environmental risk and the long periods of
time required for testing and implementation are unacceptable to EPA. For
these reasons. EPA eliminated biodegradation technologies during the Colenan
Evans Feasibility Study process. EPA has determined that biodegradation is
not sufficiently proven to be an acceptable option for remediation of the
conditions at the Coleman Evans Wood Preserving Company site.
-------
APPENDIX B
Natural Resource
Damage Assessment
Coleman Evans
Wood Preserving Company
-------
United States Department of the Interior
OFFICF OF THE SECRETARY
\\ASH:--JTON, D.C. 20240
JUN 2 I
ER84/1318
Mr. Gene Lucero, Director
Office of Waste Programs Enforcement
Environmental Protection Agency
401 M Street, SW (Room S362N) WH 527
Washington, D.C. 20460
Dear Mr. Lucero:
The Department of the Interior has conducted a preliminary natural resources survey of
the Coleman/Evans Wood Preserving Company at Whitehouse, Duval County, Florida, to
determine whether the Secretary of the Interior's trust responsibilities for natural
resources have been affected.
Our survey indicates that there are no lands under the trusteeship of the DO1 near the
Coleman/Evans site. However, the Ortega River system nearby can be inhabited by
various trust resources, including anadromous fish, migratory birds, and endangered and
threatened species of wildlife. The manatee, an endangered marine mammal, can be
found in the Ortega River system.
Site visits and review of various reports and studies show that soils and surface waters
have not been seriously contaminated very far off site. There is no documentable
evidence that our trust resources have been affected by materials from this site.
However, we believe the site should be cleaned up quickly so that contaminants do not
move off site.
Accordingly, we would grant a release from claims for damages to natural resources
under our trusteeship from the Coleman/Evans site, provided that timely remedial
action consistent with the NCP is taken to clean up the site.
Sincerely,
Blanchard, -Director
Office of Environmental Project Review
CC:
/__Steve Klein/EPA
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APPENDIX C
State of Florida
Letter of Concurrance
for the
Selected Remedy
Coleman Evans
Wood Preserving Company
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STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULATION
TWIN TOWERS OFFICE BUILDING
2600 BLAIR STONE ROAD
TALLAHASSEE. FLORI DA 32301-8241
BOB GRAHAM
f; GOVERNOR
VICTORIA J. TSCHINKEL
SECRETARY
September 24, 1986
Mr. Jack Ravan
Regional Administrator
United States Environmental
Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Jack:
The Florida Department of Environmental Regulation agrees with
the selection of Alternative #5 as described in the final
feasibility study for the Coleman Evans Wood Preserving Superfund
Site in Whitehouse, Duval County, Florida.
This alternative includes the excavation and on-site incineration
of soils and sediments, and the on-site treatment of contaminated
ground water. This alternative will effectively destroy contam-
inated soils and sediments and treat ground water.
The cost estimate for Alternative #5 ranges from $3.0 - $3.8 mil-
lion for the use of a temporary on-site incineration facility,
and groundwater treatment unit. Due to the complete destruction
of site specific contaminants by incineration, no post-remedial
monitoring or operation and maintenance activity is required.
The state will provide ten percent of the total cost, or about
$300,000 - $380,000 from the State Water Quality Assurance Trust
Fund.
We look 'forward to participating with the U
Protection Agency ccring implementation of
at the Coleman Evans v.'ocd Preserving site.
Sincerely,
S. Environmental
remedial activities
Victoria J. Tschinkel
Secretary
VJT/ps
Protecting Florida and Your Quality of. Life
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APPENDIX D
City of Jacksonville
Letter of Concurrance
for the
Selected Remedy
Coleman Evans
Wood Preserving Company
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DEPARTMENT OF HEALTH, WELFARE
& BIO-ENVIRONMENTAL SERVICES
Bio-Environmental Services Division
May 21, 1986
.
">r>v ,. J !'JC J ; 1
.""n
Ms. Kristina Teepen
Remedial Project Manager
U. S. Environmental Protection Agency - Region IV
3f5 Courtland Street
'Atlanta, GA 30365 _.
RE: Coleman Evans Wood Preserving Company •
Draft Feasibility Study
Dear Ms. Teepen:
The Bio-Environmental Services Division (BESD) has briefly reviewed EPA's Draft
Feasibility Study of Coleman Evans Wood Preserving Company, dated May 2, 1986.
The BESD would support the option of incineration, over the other options for
remedial actions, as presented. Incineration provides the following benefits
which BESD feels are noteworthy.
I. Destruction of the organics
II. Usability of the site after contamination disposal
III. No requirement for continual monitoring
Incineration, of course, as an option needs to be better defined prior to
implementation. Specifically such items as retention times, in situ monitoring,
etc. must be detailed. Further, in order for incineration to be viable, just fron
a permitting standpoint, a great deal of public awareness and education on the
benefits--of the program shall be necessary. Otherwise a permit may be delayed as
a result of public concerns requesting Administrative Hearings.
If BESD can be of further assistance, please advise.
Very truly yours,
obert Steven Pace, P.E.,
Bio-Environmental Engineer
cc: Mr. Ernest E. Frey, P.E. DER
John K. Flowe, P.E.
Khurshid K. Mehta, P.E.
RSP/ns
AREA CODE / 904 / 633-3318 / 515 WEST 6TH STREET / JACKSONVILLE, FLORIDA 32206-4397
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APPENDIX E
PUBLIC HEALTH EVALUATION
Submitted
by
CDC/ATSDR
Coleman Evans
Wood Preserving Company
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-•""""'•• Public Health Service
• "'..
(4-
••-.~Z£
DEPARTMENT OF HEALTH & HUMAN SERVICES Agency for Toxic Substances
and Disease Registry
-; Memorandum
Date June 26, 1986
_*.?-!?„/ R,5^,
From Public Health Advisor i ~ vi.^!^.'.^-';'---'-
ATSDR-EPA Liaison :' f
• jr< J!j?:2fi >S3
Subject Coleman-Evans NPL Site; !! j_
Duval County, Florida j; f!" "01 .-•)• i ; i i?
Ll ^ !—' >— '«•— ^ *-'
:•>".•. - ;;;•:• i ;•:; ;v
To Kris Teepen, RPM A7-.'..vr.*. JA.
.,,• EPA ERRB RAS
i
As requested, I have reviewed the Draft Feasibility Study,
dated Hay 2, 1986, for the referenced site. Given my long
term involvement with this site, and in the interest of time
for your program management purposes, I have elected not to
refer this document to the ATSDR for a more indepth review
and comment. I trust you will find the following useful.
Historical EPA and ATSDR review and other site documents on
file have sufficiently identified the actual and potential
public health issues of concern for this site, especially the
factors that must be present in order for a public health threat
to exist. The 1984 EPA emergency response action (excavation
of lagoon sludges) appears to have helped reduce the predominant
public health threat posed by the site (i.e. potential for
percolation and migration of contaminants to adjacent private
wells) .
The qualitative risk assessment that is described in the FS
assesses on both technically and epidemiologically sound bases,
the potential health concerns existing at the site with current
(p. 1-1) and future use (p. A-32) exposure scenarios. As such,
any, or a combination of the three preferred remedial alternatives
(surface capping w/closure,- solidification; incineration) appear
adequate to protect public health and to reduce the potential for
. future exposures to occur that may increase the threat of expos-re
to site contaminants at levels that would be of health concer- .
However, if a "No Action" alternative is selected, it appears
prudent that a monitoring program of private wells at the
residences adjacent to the site be considered. Contingency, plans
should also be developed if such monitoring identifies that site
contaminants at levels exceeding primary drinking water standards
are found at those wells in use for potable purposes.
If I can assist further with the remaining remedial phases of this
site, please let me know.
*
Chuck Pietrosewicr
cc: f ile
ATSDR/Buynosk i
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