United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-88/033
March 1988
Superfund
Record of Decision
Alpha Chemical, FL
-------
50272 .1111
REPORT DOCUMENTATION 11. REPORT NO.
PAGE EPA/ROD/R04-88/033
2.
3. Recipient's Acc:..alon No.
.. Title and Subtitle
SUPERFUND RECORD OF DECISION
ha Chemical, FL
~t Remedial Action - Final
50 Report Dite
05 18/88
6.
a--
7. Author(s)
8. Performing O...anlzatlon Rept. No.
9. Performing O...anlzatlon Name and Address
10. Project/Task/Work Unit No.
_._. --.
--
11. Contrect(C) or Grant(G) No.
CC)
(G)
12. Sponsoring Orpnlzatlon Name and Address
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
Agency
800/000
14.
15. Supplementary Notes
I
I
I.
I
16. Abatr8c:t (Umlt: 200 worda)
The Alpha Chemical site, located in Kathleen, Florida, consists of over 32 acres,
that comprise the Alpha Resins Corporation (ARC), a facility of the Alpha Chemical
corporation. Surface water from the site d~ains into a swampy, low-lying wetland area.
Karst topography is evidenced by sinkholes in the area. The facility has produced
unsaturated polyester resin for fiberglass manufacturers since 1967. A waste stream,.
~erred to as the .water of reaction-, is produced as ~ by-product of polyester resin
mation. This waste stream is composed primarily of water containing small amounts of
organics. ARC obtained a State permit in 1967 to place this waste stream in two unlined
surface impoundments. The permit allowed for the ponds to act as percolation basins,
allowing for the natural biodegradation of the organics. The percolation ponds have not
been used since 1976. At that time, a thermal oxidizer was installed to incinerate the
waste stream rather than place it in the percolation ponds. After switching to
incineration, Pond 4 dried up. It was then used for one year as a solid waste landfill
by ARC and its employees. In 1977, the landfill was covered with two feet of native
soil. In 1982, ARC contacted the Florida Department of Environmental Regulations (DER)
to obtain a permit to line Pond 3 with concrete for caustic wash water disposal. As a
condition of the permit, DER required ARC to install ground water monitoring wells. In
(See Attached Sheet)
I
\
. .
. .17. Document Analysis a. Desc:rlPlora
Record o.f Decision
Alpha Chemical, FL
First Remedial Action - Final
Contaminated Media: gw
Kev C,ontaminants: organics (ethylbenzene)
"b. 1deritlflers/Operi.Ended Terms
....Ii8IIi.0SATI .Fleld/Group
I1aJ ~blllty Statement
-
19. Security Class (This Report)
None
21. No. of Pages
53
-
20. Security Class (This Page)
None
--
22. Price
(See ANSI-l39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTI5-3S)
Department of Commerce
-------
DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT
INSTRUCTIONS
Optional Form 272, Report Documentation Page is based on Guidelines for Format and Production of Scientific and Technical Reports,
ANSI Z39.18-1974 available from Americ...n National Standards Institute, 1430 Broadway, New York, New York 10018. Each separ'"
bound report-for example, uch volume in a multivolume set-shall have its unique Report Documentation Page.
1. Report Number. Each individually bound report shall carry a unique alphanumeric designation assigned by the performing orga.
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Report Number (STRN). For registration of report code. contact NTIS Report Number Clearinghouse, Springfield, VA 22161. Use
uppercase letters, Arabic numerals, slashes, and hyphens only, as in the following examples: FASEB/NS-75/87 and FAA/
RD-75/09.
2. Leave blank.
3. Recipient's Accession Number. Reserved for use by each report recipient.
4. Title and Subtitte. Titte should indicate clearly and bnefly the subject coverage of the report, subordinate subtitte to the main
titte. When a report is prepared in more than one volume, repeat the primary titte, add volume number and include subtitle for
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5. Report Date. Each report shall carry a date indicating at least month and year. Indicate the basis on which it was selected (e.g.,
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6. Sponsoring Agency Code. leave blank.
7. Author(s). Give name(s) in conventional order (e.g., John R. Doe, or J. Robert Doe). List author's affiliation if it differs from
the performing organization.
8. Performinl Ortanimlon Report Number. Insert if performing organization wishes to assign this number.
9. PerformlnlOrpnization Name and Mailing Address. Give name, street, city, state, and ZIP code. list no more than two lewfs of
an 0rtanizational hlenlrchy. Dlspl8Y the name of the organization exactly as it should appear in Government indexes such as
Government Reports Announcements & Index (GRA & I).
10. Project/Task/Work Unit Number. Use the project. task and work unit numbers under which the report was prepared.
11. Contr8ct/Gt8ftt Number. Insert contract or ,rant number under which report was prepared.
12. SponlOrln, Apncy N8me and Maillnl Address. Include ZIP code. Cite main sponsors.
13. Type of Report 8nd Period Cowred. State interim, final, etc., and, if applicable, inclusive dates.
14. Performln, OrpniZ8tlon Code. Leave blank.
15. Supplementary Notes. Enter information not included elsewhere but useful, such as: ?repared in cooperation with, . . Trenslation
01 . . . PN..nt8d at conference of . . . To be published In . . . When a report is revised, include a statement whether the new
report supersedes or supplements the older report.
16. Abstract. Include a brief (200 words or less) factual summary of the most sianifica.,t information contained in the report. If the
report contains a silniflcant bibliography or literature survey, mention it here.
17. Document Analysis. (a). Descriptors. Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms
that identify the major concept of the research and are sufficiently specific and precise to be used as index entries for cataloging.
(b). Identifiers and Open. Ended Terms. Use identifiers for project names, code names, equipment desianators, etc. Use open-
ended terms written In descriptor form for those subjects for which no descriptor ~1(ists.
(c). COSATI Field/Group. Field and Group assignments are to be taken from the 1964 COSATI Subject Category Ust. Since the
majority of documents are multidisciplinary in nature, the primary Field/Group~c;signment(s) will be the specific discipline,
area of human endeavor, or type of physical object. The application(s) will be r:ross.referanced with secondary Field/Group
assllnments that will follow the primary postina(s).
18. Distribution Statement. Denote public releasability, for example "Release unlimited", or limitation for reasons other than,
security. Cite any availability to the public, with address, order number and price. if known.
19. & 20. Security Classification. Enter U.S. Security Classification in accordance with U.S. Security Regulations (i.e., UNCLASSIFIED).
21. Number of pages. Insert the total number of pages, including introductory pages. but excluding distribution list, if any.
22. Price. Enter price in paper copy (PC) and/or microfiche (MF) if known.
: :383 0 - 381-526 (8393)
O",ONAL FOil.. 272 BACK (4-
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EPA/ROD/R04-88/033
~. .a Chemical, FL
~ Remedial Action - Final
16.
ABSTRACT (continued)
April, 1983, a DER ground water assessment report indicated industrial impacts on the
surficial aquifer. Further soil and ground water sampling investigation did not reveal
a definable plume of contamination. Of the 23 organic constituents identified in the
ground water, ethylbenzene was found to be the most frequently detected, having a high
concentration of contamination.
The selected remedial action for this site includes placing a low permeable cap over
the unlined pond area, and long-term ground water and surface water monitoring. The
estimated capital cost for this remedial action is $142,400 with present worth O&M of
$186,200.
. .
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DECLARATION FOR THE RECORD OF DECISION
ALPHA RESINS CORPORATION SITE
LAKELAND, FLORI~
Statement of Purpose
This Decision Doc\.Unent presents the selected remedial action for the Alpha
Resins Corporation site which was developed in accordance with the
Catlprehensive Envirormental Response, Canpensation and Liability Act
(CERCIA), as amended by the Superfund Amendments and Reauthorization Act
(SARA), and to the extent practicable, the National Contingency Plan (NCP). .
The State of Florida was consulted in the selection of this remedy.
Statement of Basis
This decision is based upon the Administrative Record which is on file in the
EPA Region IV office, 345 Courtland Street, N.E., Atlanta, Georgia and is
available at the Florida Department of Environmental Regulation, 2600 Blair
Stone Road, Tallahassee, Florida, 32399-2400.
Description of Selected Remedy
The remedy chosen is capping of the srriall unlined pond. Long-term
monitoring of the ground and surface ~ater will be conducted to assure the
remedy is effective and that the landfill continues to meet ARAR's.
Declaration
The selected remedy is protective of human health and the environment,
attains federal and state requirements that are applicable or relevant and
appropriate (ARARs) and is cost effective. The ARARs are min~lly exceeded
in the current situation. The statutory preference for treatment was not
satisfied because treatment of the waste material is not necessary to meet
the standards of performance. Additionally, treatment would be significantly
more expensive than the selected remedy. This remedy will reduce the
generation of leachate at the site and thus effectively reduce the mobility
of the wastes.
This remedy was chosen over an alternative technology because it is cost
. effective and utilizes a technology fully capable of meeting public health,
welfare and envirormental goals.
~~~. ~~f
Regional Administrator
~ 17~tf
Date
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SITE NAME, LOCATION, AND DESCRIPTION
Alpha Resins Corporation is located three miles north of Lakeland, Florida at
4620 N. Galloway Road. (Figure l) This facility is a wholly owned subsidiary
of The Alpha Corporation of Tennessee. Land' was purchased and the plant was
constructed in 1967. Currently the facility boundaries encompass 32+ acres
of land in the SE 1/4, Section 28, Township 27 S., Range 23 E of Polk County,
Florida.
Prior to the construction of the Alpha Resins Plant in 1967, the site was
used primarily for agricultural purposes. The land was clear of any
construction, with the exception of sane agriculture related structures such
as sheds and barns. The land was also relatively clear of major vegetation
and trees. No previous industrial practices are known to have existed at .
this site prior to utilization of the site by Alpha. .
Since beginning operation in 1967, the plant has produced unsaturated
polyester resins for manufacturers of fiberglass boats, shower stalls,
cultured marble vanities, and other products which are key components of the
construction and recreation industries. Polyester resins are produced by an
esterificatio" reaction of various difunctional organic ~~cohols and acids
which yield ester salt and corresponding water.
The Alpha site is located within the Hillsborough River drainage basin which
comprises approximately 4 percent of Polk County. Land in the Hillsborough
river drainage basin is flat, fairly high, and often extensively overgrown
wi th pine and palmetto. (Figure "2) .
The Alpha site is located on a ridge in the Hillsborough River drainage basin
which has restricted internal drainage. Surface water f~ the site drains
into a swampy, low-lying wetland area at the southeastern corner of the
property. Water drains from the swamp east-"ortheast into a bayhead east of
Galloway Road. .
Two aquifers exist at the Alpha site: a shallow unconfined aquifer comprised
of unconsolidated coarse to fine sands and clayey sands; and the artesian
Floridan Aquifer consisting of a thick sequence of lUnestones and dolomites
with several distinct water-producing zones.
SITE SPECIFIC GEOLOGY & HYDROGEOLOGY
The Alpha site is located on the southwest limb of the OCala Uplift, a
northwest-southeast trending anticline in Polk County. Sand covered ridges
of Pleistocene to Recent age overlie sandy clays and clayey sands of the .
Miocene age Hawthorn Formation at the site. Relatively impermeable clays and
marls of the Hawthorn protect and confine the underlying Floridan aquifer
system, the main source of ground water for the region. (Table 1)
Karst topography is evidenced by sinkholes in the area. Fifty-four sinkholes
have been identified within a one4mile radius of the plant. The sinkholes
follow a general northwest trend related to thinning of the Hawthorn
-1-
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110
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Figure 1
LOCATION MAP
SCALE 1:32000
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S'ud, A.eo I C Dun', I
f.!!! and Commun..,
T.olI.( A..e.ie.
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Bounda.,
Bounda. .
o 1 4
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Alalia Ri.e. Ba.on
Peon
Rlv., Bo,in
FlCUR£ 2
MAJOR DRAINAGE BASINS Of
POLK COUNTY, FLORIDA.
-------
TABLE 1
STRATIGRAPHIC UNITS AND A~UIFER SYSTEMS AT THE 'ALPHA SITE
Geologic Age Stratigraphic Unit Thickness lithologic Aqui fer Wa ter-beari ng
(in feet) Characteristics Svs terns' Properties
Recent and Recent and 29.51 - 35.01 Coarse to fine sands. Sha 11 ow Surficial deposits'
P 1 e is tocene Pleistocene deposits and clayey sands aquifer yield small amounts
of water
Miocene (middle
to late)
Eocene
Hawthorn
Formation
Aquitardl
Aquiclude
Relatively imperme-
able clays and sandy
clay~ yields small
supplies of water
701-791
Gray to green
calacareous, phos-
phatic, sandy clays
and clayey sands.
Dolomite lenses a'id
small. fine sand
lenses
Ocala group
White to cream, chalk Floridan
massive fossiliferous Aquifer
"marine limestone, system
cherty
Marine limestone
formations. Utilized
as the primary source
of water in the area.
Drill ed 36 1
into forma t ion
-------
Formation. The sinkholes vary in size fran approximately 410 acres to less
than one-quarter of an acre and are the resul t of chemical weathering of
carbonate rocks. (Figure 3)
The geology of the upper 32 to 40 feet at the Alpha Resins site consists of
unconsolidated sands, sandy clays, and clayey sands. Fine grained quartz
sands occur fran ground surface to depths of approximately 17 to 35 feet.
Below the sands are found clays and clayey sands to a depth of approximately
50 feet. ' Fran 50 to 100 feet below ground surface are found clayey sands
interbedded wi th 1 imestone and dol ani tes. The lower several feet of these
. clays and clayey sands lie uncanformably above the Floridan Aquifer which
begins at depths varying fran 95 to 100 feet below ground surface. (Figure 4)
Surface Aquifer Characteristics - ground water levels, flow direction, and
flow rate - were determined for the surficial aquifer. Eighteen piezcneters.
were installed in August, 1983, and water level measurements recorded on
March 19, 1984 during a period of stable hydrologic conditions.
In places, the surficial aquifer may be divided into a shallow surficial
aquifer and a deeper surficial aquifer by varying layers of clayey sand and
sandy clay ranging fran 1 to 13 feet thick. The deeper surficial aquifer at
a depth of 12 to 16 feet is in a clayey sand layer overlying the thick clay
confining unit. Differentiation of the shallow and deeper surficial aquifers
varies across the site. The shallow and deeper surficial aquifers appear to
be interconnected in the area between monitoring wells AC-102, AC-I06, and
AC-107 but separated elsewhere by a less permeable unit of sandy clay.
Ground water flow in the surficia1:2aquifer is towards the south/southeast at
flow rates varying fr~ 3.45 x 10 feet/day for the northwest corner of
the site to 1.18 x 10 feet/day for the southeast corner of the p~rty
based on an assumed porosity of 20% and a permeability of 2.83 x 10
feet/day for the surficial aquifer. (Figure 5)
Ground water flow in the surficial aquifer is apparently limited to
downgradient and lateral flow with only minor vertical percolation downward
in the sediments. D:7wnward percolation of ground water is limited due to the
surficial aquifer being underlain by impermeable clay and marls of the
Hawthorn formation.
Ground water flow in the Floridan aquifer system, the main ground water -
supply in the area, was determined fran a well inventory in the inmediate
area of the Alpha site. (Figure 6) The Floridan aquifer is an artesian
system due to the confining nature of the overlying, relatively ~rmeable
sediments.
SITE HISTORY
The Alpha Chemical Canpany owns and operates a custanized polyester resin
'manufacturing facility which is about 32+ acres in size and located in
Kathleen, Florida, near Lakeland. Since the beginning of operations in 1967,
the plant has produced unsaturated polyester resins. Polyester resins are
produced by an esterification reaction of various difunctional organic.
-5-
-------
r~ ,
~ L_-
I r Plant City East \
-_-lJ., Qua dr angle ,
I \
I.lph, Chemic,' '\0-
PI.nt Ar.' _7
t\"-v
-
Lakeland Quadrangle \.l
'\
,
-_POL~.£.Q.lLN..!:!.- -~
:r:
t:)
::J>
01-
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=-~1___-
Are, 0' Sub.ld,nc,
Unn,m, d L.k.
.
. ..
.' .
(j
. .
.
EXPLAHA TION
D. SInk Hot..
+-- S....o.r" ".lIro."
T.'." F... AI. ,..... '''~
C.III.'.'.' '" "". ....
,.., .II~ ""
~
0.' 0
~
--
0.' II"
t
Chemlc.1
,. ( w --... . --- ....
'-J'.'.
FIGURE
LOCATION OF KARST FEATURES WITHIN A ONE MILE RADIUS OF
THE ALPHA RESINS PLANT.
-6-
-------
'A
NORTH
~ ~
Q en
. .
o 0
.. ..
I I
Uu
cc
A'
SOUTH
145
1ft
o
..
I
U
.: :;.:/X~~:~'\~::~'::;:;:;;::~-:;:}~:,:;:'=f:'::f::,::;.;:::''';;~::£':::~.:;:;;;j;;":~i'~:.:;;:;:,::~::;:':\;{":~';';::";::":'::"";::';,:,:;;":;;'.::': .', ;;." . ,; ::.;::~,: ..:.. ,;": ,::..,.C
: . ::"':~T:i:i;",':i.:t~:.~~:;~~:~~::;~~;?);:::'~:: SHALLOW SURFICIAL AaUIFER '~~~i:l~::.~~~~.;:.:~.\~'~
.. : , ..:.:' '::: ',:::.' :.: :...~:,~" :':::'::':::::,;~ ;:':~::;:.:~~~: t~~:;::,:::~::,::,::::-:;\'::"?!W::?l:;'!:t'~~~;~';::f!..~:.~~0;~::;~'f:::}~::~f;~~::i~::t~{:~~~~~~~~fz~~
::..~:ACUITA"D.:-.;'.f.:".; .....:, .-. - ----..:'.-._- -. .-..' '.:::~.''':''~''''''''''''''::'''''''''':::
8. - '- ,. .~.:- ...'. - - -- ----- -.-.-.1'.-_._-.-.-.-.-.,- -~_._-~.:a.---.-:- -.- -..--..,.-_.-~ -- -~ --
. .. '. - - . - -r_---.-_+:-=-r:-:~::-:~-:~------~----_-":_--------~-'._--.:-"::J;-:---~.:-:~
. --- -_'r_'J'- -- --_..~._.._.-~.L~SS PERMr ..ILE ZONE- -- --- - ..:1----.
: '-.-.-.-.-.-.-.--':'::.-1_:.-.-.-. --.-.,-.-.---.. .. ..... ~-~-:-':=:-:-:-~:-:-:-~:-:
: ;.; (.~: '.~: ~:~~i~:": :~'.:i:;::!'t:':~ ,"~~::'~':::,~!~.;:;:':.lJi.-'f1!?;!~-;::"~':'::~:::"''':::,::~,,, ;,;; :...;.::.: ;~'i: :';: :;:,~ ~.~ i ~~':,.': :"..':~:::~':':-8:', : ~ ~'.~.';' :,:; :;;.-t.'
: .~::');~~;;\~;.:.~~~i:~:';';':::~':.~';::~~(!:;'f.~:~~,:;:;;: DEEP SURFICIAL AQU'FER' ~;::~::~::~!~::i.'.:.;~~,::,:&.:,:;.
~ " .h' ., ",.,..'. '" ~ ..'. . :.,.." .'.. .. '. . '..'. '. : ..:...'. -:,~'~:,:,~,:r'~~~;.~':~:,:-~:~).:~~:.~.;
LAND SURFACE
. 140
C
.
> 135
.
C
Z 1 3.1)
.
- 125
z
2 120
..
c 115
>
'"
:: 110
105
100
.
en
o
"
Q 140
.
=-:'35
e
z 130
en
Z 125
o
; 120
c
> 115
w
..J
W '10
- -
.:.= :": = =.
:'=.:'=.==
- = ::. :. = =.
.- s:.~~~=:.:.~~
T.D.
- -'~,-'- -'- - -'- -'--
'::'~ = = ='. .'..= =-.:: ~ =
~~':_C ONFfNING LA Y ER.=..:.=-_=::-.
---...----...----
:.: ~.=.=.- -.-.-.: :.-- ~ '
21.1- ---- -- T.D.
"8.1'
~ ~.
1'.28 ~4~'
WIO'
0"[ H HOL£-O,oa.
T.D."?'
[]2J
E3
~
~
~
S.n~
SU.htlr Clar'r
Sand
.rown cra,.,
San~
White Sand,
Cia,
EXPLANATION
r;;:a"iiI Green San~, .2... Wa"'r Tabl. Surface
~ Cia, - EI..,..tlon 1-"-..
~ .,o.n Sand, .3t. Potentiometric Surface
~ Cia, .. Ele"aUon .-,.-..
.. arout m Senen Section
~ Fill Material (Loo.e S.nd.. Gr...'.
~ Organic D.brl. .nd Pia. tic.)
FIGURE4
HYDROGEOLOGIC
CROSS-SECTION
OF
THE
ALPHA
SITE.
-7-
-------
,
00
I
AC-7
too 0
~
tOO
,
100'IIT.
I
,.--- .,.
P.E. hMore8u8 I A880d..... Inc.
1-31-'"
.
EXPLANATION
AC-3. PI..om.t.r
OW-10 Old Ob..r,,8Uon w.n
AC-101. Monitoring W.II
C-5. Surflc. Wat., Sit.
~------ Flow DIr.ctlon Lln.
-138.0- Contour Lln.
Contour 'nl.'''8' .. 0.5 Foot
Oltum .. H.O.Y.D.
fJ GURE 5
: pROUNQWAT£R CONTOUR MAP OF THE SURFICIAL AQUIFER AT THE ALPHA SITE
-------
.
III
fit
"
.
Ie
KATHLEEN
-::';r:'=:'
II
.
.
.
.
.
'.
-
T.278.,
.,
.
..
~
I ~-.
EXPLANATION
21. Floridan Aquifer Well and
.. '1.11 Potentiometric Eleyatlon
.. ,000 0
~
"'- ...
".1. U....... & ,
1-'1-8.
.. ,000 ,..,
I
.-'8--- Contour Line (N.G.Y.D.)
Contou, Int.,y.1 18 I".,ul.r '
I
I,
FJ GURE 6
POTENTIOMETRIC SURFACE MAP OF THE FLORIDAN AQUIFER - 6/26/84.
-q~
-------
alcohols and acids which yield ester salts and corresponding water. During
1986, Alpha used an average of 430,00 gallons per day of non-contact cooling
water. This water is discharged through the cooling water pond and into the
swamp. Peak daily demands in 1987 resulted in as much as 750,000 gallons of
water being discharged into the swamp. As a result of the reactions which
produce polyester resins, a waste stream referred to as the 'water of
reaction' is generated. This waste stream is c~ primarily of water
containing small .:mounts of organics. A waste stream of noncontact
(noncontaminated) cooling water is also generated as a result of the
production process. The cool ing water is used to slow the resin production
reactions.
In conjunction with the building of the plant in 1967, one small 80,000
gallon unlined surface pond (referenced as Pond number 1) was constructed to
receive the noncontact (noncontaminated) coolil'rJ water and one large unlined
surface ~ndment (referenced as Pond number 2-3) was constructed to
receive the 'water of reaction' waste stream from the plant (See Figure 7).
In 1972, a third unlined surface ~ndment (referenced as Pond number 4)
was constructed to contain additional 'water of reaction'. D~nsions of
Pond number 2-3 when it was originally constructed were approximately 110
feet by 90 feet and 4 feet deep with 2 feet of freeboard. Pond mmber 4 was
approximately 100 feet by 200 feet and 4 feet deep with 2 feet of freeboard.
Alpha obtained a permit from the Florida Department of Environmental
Regulation (Operation Permit No. 1053-2182) to place this waste stream in the
two unlined surface impoundments (Pond 2-3 and 4) from 1967 to 1976. The
permit was obtained for the ponds to act as percolation basins, allowing
natural biodegradation of the organics in the 'water of reaction' as they
were exposed to the environment.
As a measure for min~izing odor and treating the 'water of reaction' in a
more environmentally sound manner, a thermal oxidizer was installed at the
facility in 1976. Incineration of the water of reaction by the thermal
oxidizer also provided for energy recovery which was funneled back into the
production process. After the installation of the thermal oxidizer, the
water of reaction was no longer placed into the ponds. All of the water of
reaction has been incinerated since 1976.
Immediately after the installation of the thermal oxidizer, Pond number 4
began to dry up. By 1977, Pond mJnber 4 was cCltt'letely dry. For a period of
one year the pond was used as a solid waste landfill for Alpha and Alpha
employees. According to Alpha, the following items are indicative of the
types of materials placed in the pond: boxes, pallets, old resin dnns,
tires, empty bags, grass cuttings, old furniture, and shrubbery. The resin
drums placed in the pond were either empty or contained discarded resins.
The resins in these drums are most likely solid since the solidification
reaction occurs quickly regardless of whether the appropriate catalyst is
added.
-10-
-------
'00 0
~
fIt...-.
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t
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RAILROAD SPUR . 0
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~:~:.:'~ '~~a to
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D
PROD.
AREA
~
TREE LINE
.
FIGURE 7 Site Map 0' the Alpha
Facility showing location of the'
ponds.
-------
In addition to the above items, solid phthalic acid was also placed in one
corner of the landfill (Pond nLltlber 4). Phthalic anhydride is one of the
primary raw materials used in the production of resins. When phthalic
anhydride is exposed to water it is converted to phthalic acid and is no
longer suitable for use in the resin process. Eighty thousand pounds of
nonusable solid phthalic acid was placed in the landfill.
In 1977, in addition to Pond nLltlber 4 drying up, Pond number 2-3 also began
to dry up. A dam was constructed through the middle of Pond mnber 2-3,
creating t,«> ponds, which are new referred to as Pond number 2 (east side),
and Pond nlnber 3 (west side). Sludge and water were plI1t)ed fran the east
side (Pond nlnber 2) into the west side (Pond mnber 3) at the time of
division. Pond nlltlber 2 was then lined with concrete to be used exclusively
for purposes of storing and evaporating caustic floor wash waste fran the
plant. 'n1e caustic waste stream which enters the lined Pond mnber 2 is
never discharged to the environment. Use of Pond number 3 was discontinued
completely. (Figure 8)
In November 1981, EPA's Field Investigation Team (FIT) contractor conducted
an investigation of on-site wells at the Alpha plant and at selected off-site
wells in the surroundi~ area. Accordi~ to the findings of the
investigation, butanone was detected in two off-site wells in the vicinity of
the plant. Also, a shallow well on-site was found to contain detectable
levels of arsenic, cadmium, chromium, and lead. Based upon the results of
this investigation, the Alpha site was given a Hazard Ranking System Score
(HRS) of 55.6 (ground water route = 96.15, surface water route = 5.24, air
route = 0). The detection of arsenic at levels above background
concentrations was important in the decision to place Alpha on the NPL in
1982. Arsenic was not found in subsequent investigations, including the
Remedial Investigation site work.
In 1982, The Alpha Corporation contacted Florida DER to obtain a pe~it to
line Pond number 3 with concrete so that the pond could also be used to store
and evaporate caustic wash water. At this time, Florida DER required that
groundwater monitoring wells be installed as a condition of the permdt.
In April 1983, DER published a detailed Environmental Groundwater Assessment
report which discussed the results of the sampling efforts. 'n1e results
showed no contamination of the private off-site wells in which butanone was
previously reported. 'n1e investigation found only on-site indications of
industrial impacts to the surficial aquifer. Contaminants detected on-site
were ethylbenzene, xylene, napthalene, and benzene. No metals, incl\l1ing
arsenic, were detected in any of the wells. No contamination of the Floridan
aquifer on-site or off-site was detected, and there was no indication of any
impact on the surficial aquifer beyond the property boundary. As a result of
this resampling effort, the HRS score for this site was recalculated and
lowered to 43.2. A HRS score of 28.5 is sufficient for a site to be placed
on the NPL. 'n1e site was proposed for the NPL in OCtober 1981 and went final
in December 1982.
-12-
-------
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,
ALPHA RESINS CORPORATION
.'1 Of UtI, "7-.
SITE MAP SHOWING
THE EXISTING
FACILITY STRUCTURES
FIGURE 8
PROPER' Y BOUNDARY
MIlliON»
fUCIS
,
,
,
,
\
seAl. ' ,. . 200'
ft' - '100' 200'
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-------
TABLE 2
Samp1tng and Ana1ysts Resu1ts
Groundwater
\:,,,, S.... '0\11"
A!.102 ~.IO-t... ~.ID6 ~-IOI A!-IOI At -101 S'.1 S'.I S'.2 S,-) S'-8 SP-$ S'-' S'.7 SP.I sp., S'-IO S'.ll
'Ou,liuI" '.,u.."I,dl '."''''iII,d)
,.0.1, Ou, of Sr."I1".
11-88 11-88 11-88 11.88 11-8' 8-8$ 11-88 8.U 11.88 11.88 11-88 8.85 8-85 1.85 1-85 I-IS I.IIS 1.8$
".109,,,.:,d 'ol.lil,
Or,.i""
I) eror:.;.~tl"""
11 ("Iorofo.. Do ODe --
JI 1 ~ 1-0ICblorOt,".nt 000lM --
'1 1.1-;Jitnloropro,.", C.018 0.01'
$1 ~'I.,I...., (lIIorld,
!,"".!I.lo),n"..d V~I.1i 1,
Or,.ni" 00002 00001
II 8~"ltn, Do 01))
21 UII,lb,,,,..,,, 0.£9' ll.' '068 $.IS 00011 0001' 0.128 0019. 00115 0.108
)1 SI,r,ro, 0.001
'1 10lutllf D.OCO 00120 O.ODS 0.019
$ I .,I,n, 0.00' 0.610 0.'" 00692 -- 0001J
,~ '",noll
~ I I.C-Oi...1",1 '",nol O.O:lIJ O.OO'J
/1 1-",,",1. '",nol OoOOIJ ." "" ." IIA IIA U IIA "" IIA
)1 '-:"0#1..,1 ''',nol DoO!1 OoOlJ "" '" 00018 ." ." ." lie. .. "" II"
8 J '...nol 00 OOSJ 0.011 0.008J
'ol,,"utl,ar "'08.1 it
",drourbo",
II ..,11111.1,,,, 0001.
11 1-~"",I"".h'hll,.., 0.OD7J .. u .. .. IIA Q Q IIA ..
'hili."'"
11 Itn,,1 !u,,1 'MII,"" 0.07) 0.011
11 III 11 (lh,I",.,1I 00061 O.OIJ 0."0 0.088 0.110
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1 j er"JOit At III 10.00 O.OJJ 17.00 '0.6J1 IS. 00 'C.IJI 'O.UJII '0.16J1
11 ..""I Altollol 0.020 0.015 "" u 0.081 ~ I" .. .. IIA Q J:A
)1 ho~- O.OOl.l
AI1 "IuIU ',porltd ,,, ..~11 for .-81'. ,..,111.
-------
lr ., r.rld 81,., O..I..CI io.. 0..1.." 10.
e 1,., 81,., l i... l i_it
11- f4 11-8. 6.85 11-8. 8.85
NA 0.001 0.01
NA 0.001 0.01
NA 0.001 0.01
NA 0.001 0.01
0.1/!5 NA CI.DOI 0.01
IIA 0.001 0.01
~A 0.001 0.01
NA 0.001 0.01
0.002 NA 0.001 0.01
NA 0.001 0.01
0.01 0.025
0.01 I
0.01 I
0.01 0.025
0.01 0.01
0.01 I
0.01 0.01
0.01 0.01
0.01 0.01
0.01 0.01
I I
0.01 I
0.01 0.01
-------
TABLE 3
ing and Analysis Results
Soil/waste, Soil/sludge and Soil/sediment
C;;l0J'
I.Z'. ..~' a.6' ..B'
0.:,
1\-" 1\.9' II-It 11.'1
.-
'-2'
c(
8.1' 8-6' 8.B' C-2' C-I' C.6' . C-B' 0-2' 0-8' 0-1'
II-BI II-BI II.Be II-S8 II.B8 II-at 11-81 11-81 11-88 11-88
11.3'
H.I~1P~.!~d Yol..II,
O..;.ainCI .
II 8r~~,'h.~,
11 (..Iororono
JI 1.I-OiChlorOP'h.ft~
81 I.Z-OiChlorooropoft,
51 ~llh,l.ft, Chlorid,
0.099
0.Z20
O.lle
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, Or9.nlc,
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JI St,r~fte
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O. Jl6
0.1)2
0.219
1.11
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1.10,
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1.10
0.928
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0.880
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11.81
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1.08
0.129
II
-------
(""0 (0-;) (OTO O~ I ~CI ia" D'!t.ct.or
. C 0 '. ir... t !.1.it
!-'5 8-!5 8-85 11-8' 8-as
0.01 0.10
0.01 0.10
0.01 0.10
0.01 0.10
0.01 0.10
0.01 6_10
0.6 ~6I 0.'11 0.10
1.6 I'~O 0.' 0.01 0.10
0.01 0.10
0.01 0.10
8.2 0.5
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~. ~. ~..\ 8.2 I
8.2 0.5
8.1 0.01
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0.01 0.10
0.01 0.10
0.01 0.20
8.5 7.) 0.01 0.20
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-------
'I'A8L1 4
AL'.A .1.1.5 CO.'O.A'I'IO.
.18UL'I" O' O.OU.OWA'I'I. "081'1'0.1.0 '0. I.OICA'I'O. C81"ICALI
.Ju.. I'll
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Ch..tc.l 8...
AC-Ut
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AC-lO'
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18-11-5
1,J Oicblo..o,..o,...
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-- . ...1,..41 but .ot d.t.ct.d
8 . fou.d in blanll
.J . .ati..t.d, ( d.t.ctio. li.it
-------
Until May 1984, there was a question as to Whether Pond nt..mber 2. qualified as
a RCRA regulated unit. Testing was performed in mid-1984 to determine if the
pond was a RCRA regulated hazardous waste unit. Sampling was performed by
P.E. Laf-breaux and Associates (PEIA) and the samples were split between PEIA,
Mead CanpuChem, and Savannah Labs. The samples were analyzed for corrosives,
reactivity, ignitability, and EP Toxicity characteristics. The results of
the sampling showed that the pond was not a hazardous waste unit regulated
under RCRA. Therefore, there are no RCRA regulated land treatment, disposal
or storage units on-site at the Alpha facility. '
In 1984, a Remedial Investigation CRI) began at the Alpha Resins COrporation
facility. The investigation consisted of sanpling and analysis of soil
on-site and groundwater on and 'off-site. The soil and groundwater sampling
investigations were centered around an area considered to be the probable
source of contamination. Specifically, this area is the location of the
previously used percolation ponds, one of which is now dry and one of which
was used as a solid waste landfill.
A total of 18 groundwater samples were collected and analyzed fran ground
water nonitoring wells and sand point wells. (Table 2) Additionally, seven
samples were collected fram private wells within a two mi!e radius of the
facility. Nineteen soil/waste samples were taken f~ the inactive solid
waste landfill which, until 1976, had been used as a percolation pond. The
soil/sediment samples were collected from the swamp located to the south of
the landfill and the ponds area.
Soil and ground water sampling on-site indicated the presence of low levels
of 23 positively identified organic constituents. Of the ~3 organic'
constituents positively identified, ethylbenzene was found as the most
prevalent contaminant at the site, both in concentration and in the number of
samples in which it was detected. (Table 3)
,Other positively identified organic constituents include phthalates,
halogenated, and non-halogenated volatile organics, phenols, polynuclear
aromatic hydrocarbons, and non-priority pollutants such as benzyl alcohol and
benzoic acid.
Concentrations of constituents found in water samples were typically les~
than 1 ppm, except for ethylbenzene which was detected at a high of 22.6 ppm.
Concentrations of constituents found in soil/sediment and soil/waste samples
ranged fran a high of 1480 ppm to less than 1 ppm. Styrene was detected only
in the soil/waste samples and occurred at the highest concentration of all'
positively identified constituents at 1480 ppm. This concentration was found
in one sample fram the landfill, and is likely the result of a direct .
-placement of same of this material in the landfill. .
,During the initial sampling effort, inorganic metal constituents were tested .
for but were detected at or below backgroond levels: therefore, these
inorganic constituents were not re-tested for during the final round of
sampling.
On-site contaminants were noted only in the surficial aquifer, not in the
Floridan aquifer. No contaminants were detected in any of the private well
samples off-site. .
-14-
-------
Based upon the results of the hydrological investigation conducted at the
site and the results of sampling and analysis performed during the Remedial
Investigation, it has been concluded that the potential for off-site
migration of contaminants via the surface aquifer does exist. Although the
level of contaminants detected in the groUnd water are low,. it was
recannendedthat an Endangerment Assessment (~) be performed to determine
the hazard, if any, these contaminants pose to human health and the
environment.
During 1986, an Endangerment Assessment was performed, using the approach as
outlined in EPA' s Superfund Health Assessment Manual (U. S. EPA, 1985), that
focused upon the findings of the RI. The ~ evaluated resources,
populations, and environment threatened and human exposure.
Resources, Populations, and Envirorment 1breatened- The site is located on
developed land cleared of native cover except for the wetlands (swamp). The
wetlands in the southeastern corner of the property drain east/northeasterly
to the wetlands east of Galloway Road.
Human Exposure- The ITDst probable pathway for hl.UMn exposure is via
contaminated groundwater from the surficial aquifer. Sir.~e air and surface
water runoff are not i~rtant pathways at the site, grou~jwater JtlJVement of
contamination potentially poses the most likely vehicle for the contamination
to affect the human population. Drinking of contaminated water would appear
to be the most likely way for the contamination to affect humans: however,
the pr~ry drinking water source in the area is the Floridan aquifer.
The EA concluded the following:
-
Contaminant concentrations detected are low, as are the-number of
contaminated samples. The data do not suggest that any large source
or plume exists.
Off-site transport and exposure is expected to be minUnal for two
reasons: (l) the pr~ry exposure is the discharge of ground water
from the surface aquifer into the swamp on the Alpha property, where
biotic receptors may potentially be exposed, and, (2) a limdted
number of human receptors are close to the site.
The est~ted exposure concentration are based on a number of highly
conservative assumptions.
Using their conservative assumptions, the risk calculations showed .
no expected increase in risk over background because of present
conditions at the Alpha facility.
mFORCEMENT SUMMARY
In March 1985 two consent orders were signed between the FDER and Alpha
Resins COrporation.
-17-
-------
One consent order dealt with penalties which required a $5,000.00 payment
frcrn Alpha for permi t and groundwater violations. The other consent order
required the Alpha Resins Corporation to perform a Remedial Investigation,
Endangerment Assessment, and if necessary, a Feasibility Study in order to
carry out a Remedial Action.
A condition of this consent order required that the investigations and
stooies be prepared in a manner consistent with the requirements of the
Comprehensive Environmental ResPonse Compensation and Liability Act and
implementing federal regulations and federal guidance doc\nents developed by
the USEPA. Under this condition, EPA was to review and camnent on all
reports and proposals related to the site.
In November 1981, the EPA' s Field Investigation Team (FIT) performed an
investigation of on-site and off-site groundwater wells at the site. In
April 1982, a groundwater assessnent was performed by the FDER.
The Alpha Resins Corporation, the Responsible Party, has cooperated with the
FDER and the EPA and has conducted a Remedial Investigation, an Endangerment
Assessment, and a Feasibility Study for the site. These studies have been
fully funded by the Alpha resins Corporation and the Reme~ial Action is to be
performed by Alpha as well.
CURRENT SITE STAruS
The area where contamination has been detected at the landfill and ponds area
contains no structures which would interfere with or hinder remedial actions
taken at the site.
..
The percolation ponds have not been used since 1976. At that time a thermal
oxidizer was installed to incinerate the 'water of reaction' from the resin
production process that was previously placed in the percolation ponds.
After switching to use of the thermal oxidizer, percolation pond *4 dried
up. It was then used for 1 year as a landfill. The landfill was covered
with 2 feet of native soil in 1977. In 1984, an extensive groundwater
monitoring system was installed to monitor for groundwater contamination at
the site. During 1985 and 1986, an RI was conducted at the site to properly
characterize the nature and extent of contamination.
As discussed in the RI report, 18 groundwater samples were collected and
analyzed frCJn groundwater monitor wells and sand point wells. These wells
were screened in the surficial aquifer. The analyses of the samples showed
low levels of several organic caupounds. Seven groundwater samples were
collected from private wells within a 2-mile radius of the facility.
Nineteen soil/waste samples were taken fram the closed solid waste landfill,
which up to 1976 has been used as a percolation pond. One soil/sludge sample
was also collected fram the unlined pond which was previously used as a
percolation pond. The soil/sediment samples were collected from the swamp
located to the south of the landfill and the ponds area.
-18-
-------
I ----
Soil and groundwater sampli~ on-site duri~ the RI indicated the presence of
'low levels of 23 positively identified organic constituents. Ethylbenzene
was found as the most prevalent contaminant at the site, both in
concentration and in the m.mber of samples in which it was detected.
Other positively identified organic constituents include phthalates,
halogenated and non-halogenated volatile organics, phenols, polynuclear
aranatic hydrocarbons, and non-priority pollutants such as benzyl alcohol and
benzoic acid. . .
Concentrations of consti tuents found in water samples were typically less
than 1 ppn, except for ethylbenzene which was detected at a high of 22.6 ppn.
Concentrations of constituents found in soil/sediment and soli/waste samples
ranged fran a high of 1480 ppn to less than 1 ppn. Styrene was detected ooly
in the soil/waste samples and occurred at the highest ~oncentration of all
positively identified constituents at 1480 ppn. This concentration was found
in one sample fram the landfill, and is likely the result of a direct
placement of some of this material in the landfill.
Inorganic metal constituents were tested' for duri~ the initial sampli~
effort, but were detected at or below background levels: therefore, these
inorganic constituents were not re-tested for duri~ the final round of
~ampli ng .
.
On-site contaminants were noted in the surficial aquifer, not the Floridan
aquifer. No contaminants were detected in any of the private well samples
off-site. .
No deflnable plume of contamination was shown to exist at the site. The
positively identified constituents detected at the site were found to be
. sporadic regarding their location and concentration. .
Sampling and analysis of all groundwater monitor wells and sand point wells
was conducted again in June 1987. The results of this sampling effort showed
an overall trend of decreased levels of constituents in the groundwater.
(Table 4) No positively identified constituents were detected in the shallow
monitor wells located immediately south of the swamp.
The pathway of greatest concern is contaminant migration via grou~ater of
the surficial aquifer. The surficial aquifer is not a primary source of
drinking water in the area. Testing of groundwater fram a private drinkirrJ
water well in the surficial aquifer on land adjacent to the Alpha p~rty
showed no contamination.
'The surficial aquifer is separated fran the Floridan aquifer by an underlyirrJ .
confining clay layer. Testing of potable water fran six nearby wells drawing
fram the Floridan aquifer showed no contamination.
-19-
-------
ALTERNATIVES EVALUATIOO
RE.~DIAL ACTIOO ALTERNATIVES DESCRIPrIOO
Three categories of Remedial Action Alternatives are a~licable to the Alpha
Site. 'l11ese three categories are as follows:
'Alternatives that c~ly with all applicable and/or relevant and
appropriate public health and enviromental stardards incl\ding:
Alternatives for off-site treatment and/or disposal
Alternatives that exceed requirenents of all applicable and/or
relevant and appropriate public health, and envirormental standards
No action alternative
ALTERNATIVE WHICH MEETS AU. APPLICABLE OR REI.E.VANI' AND APPRJPRIATE PUBLIC
HEALTH AND ENVIR:>NMENTAL STANDt\RDS
CAPPING AND MONI'roRING
This alternative involves cappi~ the unlined pond area and monitorin;J of the
surficial aquifer.
A cap will be placed -over the entire' surface of the unlined pond area to
prevent'the vertical.migration of water through ~e unlined pond. 'n1e cap
will be designed to achieve a permeability of 10 atVsec and graded to
divert water away from the unlined pond area.
Groundwater monitoring will be conducted for the surficial aquifer using the
following system of wells: AC-I07, AC-I06, AC-I02, SP-2, SP-6, SP-7,' SP-8,
and SP-9 to determine the effectiveness of the remedy. (Figure 9)
Gramdwater samples will be collected quarterly and will be analyzed for the
,following indicator chElfticals: ethylbenzene, styrene and xylenes. After one
year of quarterly sampling, the data will be reviewed. At this time !PAis
Regional Administrator may choose, based upon experience gained during' the
first year's sampling, to alter the frequency of monitoring, the n\lllber of
wells s~led, the parameters bein;J analyzed for, or any caabinati~ of
~_. '
OFF SITE DISPOSAL
The alternative for off-site disposal involves excavation, transportation and
off-site landfilling of the contamdnated soil.
-21-
-------
\--
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I
IV
IV
I
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--I
.
.
I
,
. ,
ALPHA RESINS CORPORAnON
.q . -, ..,..
LOCAtiON MAP FOR THE PROPOSED
,
SURFICIAL AQUIFER MONITORING WELLS
. .
FIGURE 9
SCAt. '8 . ...
PROPER' Y BOUNDARY
--I.~
: ~
Mll-
I.US
\
\
\
\
.\
~. T'
....I( WAIl II "II
I>
~
AC 105.
.....
MIA
N88r1l.
MIA
..,
...
I
J
--
---
."....
I
..-
III"
-------
The excavation portion of the action involves r~ing an estUDatedS185
cubic yards of soil and waste fran the landfill which is 100 feet wide, 200
feet long and 7 feet deep. The excavated soil and waste will be stockpiled
prior to being loaded on trailers, each with a capacity of 20. cubic yards,
for transportation to a permitted 'l'SD facility. Once the excavation of
contaminated soil and waste in the landfill has been caapleted, the
excavation area will be backfilled and graded to mintmdze erosion.
In addi tion to the excavation work at the landfill, soil and sediment will be
excavated fran the bottan of the unlined pond to an estimated depth of 2
feet. 'lbe estimated 400 cubic yards of excavated soil and s8d1ment will be
stockpiled, alOl'¥1 with the soil and waste fran the landfill, prior to
shipnent to a permitted 1'5D facility for disposal.
ALTERNATIVE WHIOi EXCEEDS ALL APPLICABLE OR RELE.VAm' AND APPROPRIATE PUBLIC
HEALTH AND ENVI~AL STANI:WIDS
The alternative to be evaluated for this category consists of groundwater
collection and treatment.
Groundwater will be collected by an interceptor drain/barrier wall to be
installed in the surficial aquifer hydraulically downgradient of the landfill
and the unlined pond area. The drain would be installed on top of the low
permeability clay at the location shown on Figure 10. A geologic
cross-section along the. length of the drain showing the approximate location
of the proposed interceptor drain is included. (Figure 11) .
~e to the length of the interceptor drain, its position on top of the clay,
and the ~rmeable barrier walls below the drain, the system would be
effective in controlling all of the groundwater fran theupgradient areas.
'n\e advantages to using an interceptor drain/barrier wall systEID over the use
of withdrawal wells are several. They include the followilV1:
The shallow depth (20 feet) of the surficial aquifer below the
landf ill and pond area are catpatible with this type of system.
A 1 imi ted voll.Jtle of water would be collected frau an interceptor
drain/barrier wall system. Collection wells would draw water in a
radial pattern resulting in greater vol\JIIBs of vater and an
additional organic loading fran sw~ water to be treated by the
wastewater treatment systEm
. .
The passive nature of the drain system - A ~ ~ i8 the only
equipaent which would need to be maintained on a routine buia.
The collected groundwater would be filtered to remove particulates and then .
carbon filtered to reaDVe organic ocnp:JUnds, which incl\lSe the organic
priority pollutants. Sarrples of the treated g~ter would be collected
and analyzed to ensure the groundwater has been properly treated. '!'he
treated groundwater would then be discharged along with Alpha's oon-<;cntact
-23-
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,
,
1
I
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l~
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I
rAit ROAD .P-
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.
.
.
.
.
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- - - - - - . - . - . . - - -, - - . . . - . . - - . - - . -
.
.
.
.
.
.
.
1
-
r
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.
PROPOIEO LOCATION FOR ~
INTERCEPTOR ORAIN I 8ARRIER WAll
--
1-----1-1--
H
o
R
,
II
G
A
I
l
o
W
A
Y
a
A
o
SWAMP
FIGURE!O. : LOCATION OF INTERCEPTOR ORA.lN ! BARRIER W.ALL
-------
I
N
't'
U[VA lION
C 'erl )
140-
lJO-
120-
--
110-
WEST
A£. .05
8
.-
lAND ~..C(
SHAllOW
SURrIClAl AQUIf"[R
l£SS PfRM£A8l[
ION(
101- 1IE"1M
1J7 ft.
f'Ro.I C I( D lANOf U
oun.,.
~
51'.
f'RO.Cf(O
UNlIN(D
PfJNf)
ounlN(
\ .CO~
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/
j
SPJ
AI' 101
51'2
\
\
-~
.- -..J
SHALLOW
SUR. ICIAl
AQUifER
EAST
H( VA 11<:»4
(Irel)
N:. IDa
Sf> I
140
-- -
--
<~ -
OUP SURrtCIAl AQUIfER
FIGUR( 11
CONfiNING
LA YER
. MOlE: fH[ canl_' G" H
lNfIlfU All) IH( UNl_D POND
AA[ PIIO,EC1[D OHIO 1M[ . AJCIS
G(OlOGlC CROSS SECllON _LOW IHE
lANDFill AND UNlIH£D POND AlONG
- IHE liNt fROW MONIJORING .LL
AC 105 10 SP I.
,.:,~~.. ..-~"~--- ._"~I ,-,.
- 130
----:::
- 120
CONfINING
LA YER
- 110
~[ .rv[
50'
.. lOX
,.
. --~.' C'".' -=- -,-,-,
,:~R...
-------
FIGURE 12
PROCESS FLOW DIAGRAM FOR
GROUND WA TER COLLECTION
AND TREATMENT
INTERCEPTOR
DRAIN
P ARTICULA TE
FIL TERS
I
CARBON
FIL TERS
r
DISCHARGE
WITH
NON-CONTACT
COOLING WATER
-26-
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cooling water to the swamp. Figure 12 shows a process flow diagram for a
groundwater collection and treatment system.
NO ACTION WI'ni LONG-TERM ~IroRING
The No Action' with Long-Term Monitoring Alternative at the Alpha site
involves .periodic nDnitoring of groundwater in the surficial aquifer. 'lbe
groundwater monitoring system will consist of the following wells: AC-I07,
AC-I06, AC-I02, AC-IOS, SP-2, SP-6, SP-7, SP-8, and SP-9. Monitor well
locations are shown on Figure 13. Additionally, surface water !lClq)les fran
the swamp and fran the culvert leaving the property will be collected.
All groundwater samples and surface water sanples will be collected quarteJ;ly
except for the groundwater sample fran Well AC-IOS (Floridan), which will be
sampled semiannually for the first year and annually thereafter. 8aq;)les
will then be analyzed for ethylbenzene, styrene and xylenes. Monitoring will
be performed until Alpha petitions for and receives fran FDER and EPA a
reduction in the requirement for groundwater rta\itoring.
NO ACTION ALTERNATIVE
Under the No Action Alternative, no remedial activities would be performed.
This remedy is currently unacceptable because well AC-106 is not in
~liance with MAR's, e.g. primary drinking water standards.
CINI'AMINATION MIGRATION
The major exposure pathway to human receptors is through the rtDveraent of
contaminated ground water in the surficial aquifer. The ground water flow
regime can be sumnarized as' follows:'
An lmpeImeable confining clay layer, approximately 20 plus feet
thick, separates the surficial aquifer fran the deep Floridan
artesian aquifer. The Floridan aquifer is the primary source of
drinking water for the area.
water levels in the surficial aquifer under the landfill are
approximately 4 feet below the surface. SOil/waste S8IIples
collected at 4 feet and below could be in the saturated =nee
The surfi!:ial aquifer has a £1latively low permeability ranging fEal
2.83- X 122 feet/day (1 X 126 centimeters/sec:cnd (aD/sec)] to
1.8 X 10 feet/day (4 X 10 aD/sec). '!be surficial aquifer
contributes grcund water to the swamp southeast of the landfill
area. .
-27-
-------
The volatile organic compounds (ethylbenzene and xylene) found in
the soils and ground water are generally lighter than water
(specific gravity = 0.867 and 0.89, respectively): consequently, if
any gravity separation can take place in the aquifer, these
constituents will be found at higher concentrations near the surface
in ground water from the surficial aquifer.
Other factors related to the environmental fate of the aliphatic
hydrocarbons, ethy1benze and xylene, found in 5Oi15 and ground water include:
These catpJUnds are amenable to evaporation if there is an air
interface involved, e.g., in the swClllp surface water.
They have relatively leM soil adsorption coefficients and moderate
water solubility: consequently, they are mobile in the soil
environment.
They are not subject to hydrolysis in the aqueous environnent: thus,
they will remain in slow-noving ground water and will not attenuate
to a high degree.
The air pathway was not considered critical for two reasons: (1)
concentrations of the aliphatic hydrocarbons, particularly ethy1benzene and
xylene, are relatively low in soil near the top of the landfill and the
contaminated soils are covered with at least 2 feet of clean fill, and (2)
most of the contaminant mass was detected in samples in the saturated zone
and, thus, is less susceptible to volatilization to the atmosphere.
Volatilization from surface water (swamp) would be min~l because of the 1eM
concentrations detected in shallow wells and the leM discharge rate of ground
water into the swamp.
EXPOSURE ASSESSMENT
Data gathered duri~ the Remedial Investigation (RI), the Endan;;)erment
Assessment (EA) and the Feasibility Study (FS) performed at the Alpha Resins
si te is surrmarized in Tables 2 and 3.
Concentrations of constituents found in soil/sediment and soil/waste &aq)les
rar¥Jed fran a high of 1480 ppt\ to less than I pptt. Styrene was detected only
in the soil/waste s~les and occurred at the highest coocentration of all
positively identified constituents at 1480 ppm. This concentration was found
in one sample from the landfill, and is likely the result of a direct
placement of 8CI1I8 of this material in the landfill.
Inorganic metal constituents were tested for during the initial Ulllpli~
effort, but were detected at or below backQround levels1 therefore, these
inorganic constituents were not re-tested for during the final round of
sanpl ing .
Onsite contaminants were noted in the surficial aquifer, not the Floridan
aquifer. No contaminants were detected in any of the private well 88IIple.
offsite.
-28-
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No definable plume of contamination was shown to exist at the site. The
positively identified constituents detected at the site were found to be
sporadic in nature regarding their location and concentration.
Sampling and analysis of all groundwater ~nitor wells and sand point wells
was conducted again in June 1987. See Table 4 for the results of this
sampling effort. The results of this sampling effort showed an overall trend
of decreased levels of constituents in the groundwater. 'No positively
identified constituents were detected in the shallow monitor wells located
i.nrnediately south of the swamp.
Groundwater fran the landfill and unlined pond area discharge mainly to the
surface water in the swamp with a portion underflowing the swamp' and
remaining in the surficial aquifer on site. The endangerment assessment
concluded that the resulting concentrations entering the swamp via
groundwater discharge would be significantly below grourdwater and surface
water standards. Contamination detected in wells iJmediately adjacent to the
landfill are belOlii groundwater standards. However, at the well (Ae-I06)
Uumediately downgradient of the unlined pond, concentrations have .
consistently exceeded groundwater standards. The concentrations detected in
this well have decreased with successive sampling events.
COST ANAL'iSIS OF REMEDIAL ACTIOO ALTERNATIVES
The cost analysis involved the determination of two critical cost elements
for each of the remedial action alternatives. The two cost elements are (1)
present worth cost, and (2) the cash flow (operation and maintenance). over .
the life of each alternative. These cost elements for each alternative are
presented in Table 5. The details of the cost analysis of the selected
remedy is presented in Table 6.
In reviewing the Cost Analysis, it should be noted that alternatives which
include groundwater monitoring have their costs based upon quarterly sampling
and analysis of eight wells and two surface water samples for ethylbenzene,
styrene and xylenes. .
DESCRI?I'IOO OF THE SELECTED REMED'i
Four remedial alternatives have been discussed for the Alpha Resins Site.
Data obtained fran monitor wells located irrmediately down;;Jradient fran the
landfill area indicates the landfill is meeting all AJAR's for this site.
. (Figure 14) Concurrent data obtained fran the monitor wells located
inmediately dOWl'VJradient fran the unlined pond area indicates AJAR's are
. being exceeded. in this area. (Table 7)
-29-
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Contaminant concentrations in wells immediately downgradient of the landfill
are below all applicable or relevant and appropriate (ARAR) State and federal
standards. While additional remedial action at the landfill is not
necessary, the nature of landfills and the continued degradation of
containers in the landfill argue strcn;;Jly for continued monitoring. The well
llnmediately downgradient of the unlined pond area currently exceeds ARAR's.
Constructing a low permeability cap over the pond area will substantially
reduce leachate generation and should result in meeting ARARs at the well
downgradient of the pond. Continued monitoring to assure the effectiveness
of the cap in meeting ARAR's is necessary.
In s~ry, the selected remedy for this site is to place a low petmeability
cap over the unlined pond area which, the EPA believes, will reduce
percolation of atmospheric precipitation into the unlined pond and reduce
leachate production into the surficial aquifer. In addition, for both the
unlined pond and landfill long term monitoring of ground and surface water
will be required to ensure the remedy is effective and to be certain the
landfill continues to meet ARAR's.
-3~
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~LIANCE WITH SEcrION 121 SARA
The remedy selected for the Alpha Resins site is considered to be the Jtl:)St
effective alternative in terms of removing the threats posed by the site, and
is considered the most effective choice given both the clean-up technologies
available and the size of the site. The remedy provides protection which
will meet all ARAR's (applicable or relevant, and appropriate requirements)
and is cost effective. Finally, the remedy utilizes permanent treatment
technologies to the maximum extent practicable given the nature and vol~ of
contaminated materials.
OPERATION & MAINl'ENANCE
Operation and Maintenance for the selected remedy at the Alpha Resins site
will consist of maintenance of the cap CNer the unlined pond area and
long-term moni toring of ground and surface water. For a 30 year maintenance
and monitoring program the total cost in 1988 dollars would be $186,207.00.
This cost sumnary is explained in Table 7.
mNSISTENCY WITH MAR'S
Applicable or relevant and appropriate requirements (ARAR's) for the Alpha
Resins site were identified which apply to the site prior to remedial
activity. They are:
1. Chapter 17-3, Florida Administratiye Code (FAC), Water Quality Standards.
(contains requirements for groondwater ltO\itoring plans. .
. ..
. ..
2. Clean Water Act, water quality criteria.
3. Resource Conservation and Recovery Act, alternate concentration limits.
. 4. Chapter 17-4, FAC, Permits: specifically 17-4.07 and 17-4.24S(6)(d).
S. Chapter 17-7, FloI-lda Administratiye COde (FAC), Resource Rec:overy and
Management.
6.
17-25, FH:., regulations for StoI'1\1llater Discharge.
7. 17-30, FAC, Hazardous waste
8.
17-40, FAC, Water Policy
9. 401>-2, F1I:., Rules of the . Southwest Florida Water Management District
(Ca1s~ion Use Pemf. t)
11'1e Florida Statutes which support naat of the preceding regulations aE8
403.087 and 403.707 which deal with permits and landfills, respectively.
The selected remedy of capping the unlined pond with long-tem monitoring of
both ground and surface water will achieve ~iance with all of the
identified ~'s. .
-31-
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AC-
AC-
-f-H
1O4SW ^
1Q4DW ( \ L fN-
I J OFFICE
STORAGE
*
DPROO.
• 1 AREA
AC-10J
AC-102
RAILROAD SPUN
»•*»•• 111-444 4 4 — 4—1 1 i 1—
"- | •~T " *f "" f ' t" III" fiifttiii
ILANDFILLJI 1
1
sw
IDfl.
n
AC-^IOS $2; 2o^|-.- ?r.^
-1O1
THEE LINE
SWAMP
EXPLANATION
• Surflclal Aqulfar Shallow Monitoring Wall
• Surflclal Aqulfar Daapar Monitoring Wall
A Florldan Aqulfar Monitoring Wall
O Sand Point Wall
_
FIGURE 14
LOCATION nr THE INITIAL
GROUNDHA SAMPLES
-------
TABLES
SUMMARY OF COST ANALYSIS FOR REMEDIAL ACTION ALTERNATIVES
I
u*
Alternative
1) Offsite Disposal
2) Capping t
qroundwater
Description
Capital
Excavation and disposal of
contaminated soil at a
hazardous waste landfill
Cap unlined
Pond area. Monitoring
Cost Estimate
.(SI, 000)
O t H
None
Maintain cap
and monitor
Capital
2,813.6
Clay: 142.4
Concrete: 244.0
O * H
155.6
186.2
161.3
3) Groundwater
collection and'
treatment
4) No Action
with long term
groundwater
monitoring
Install interceptor drain
and carbon filter system
system
None
groundwater
Provide energy 795.7
labor and material
to collect and treat
groundwater.
Monitor groundwater
Monitor groundwater 0
213.0
155.6
Groundwater monitoring costs are based on quarterly sampling of the monitor wells for Styrene, Ethylbenzene, and
Xyl«
Operation and Maintenance Costs
-------
Table 6
S 1 tt "III' AlOhA RIllnl CorDorltlon OPERATION' NAIMTEMAIC£ COSi3
S!tt Loution: KAthl.tn. ~lariaA
T.chnola9Y: Cllv C.,Din9 of L.ndfill .nd
1111111.0 Palld Artl Dat'l J.nl&&rY., 1'"
I UffITS ~.IT "ICE' TOTAL IIIIIL i OPERITIDI 'ROOT
Ifill D£SCRl~T1OM IIIMT ITY OOLlARS CDST. DOLL'" WE, YEARS .TN
I I I ,
I 1 , '
, I
I.SPEC~IOH I 'I I 1500 I 1500 30 14,713
I..
IIOW I JI6 I 12 I 1200 I 1,.400 I 30 I '~,'2S
I I I t
j ' 11.000 I 12,000 I
MIIITEMANCE I" 21 30 111.85'
I
I ,
SHORT TER" "DNI~ORIN6 I I ! I I
P,rlo"n.l .no SUDall.1 I d.y I : I '1. ~OO i 14,500 ! . 4 114,284
I
LIOoritorv II I 30 ! .500 ' 115.000 4 147,548
I
, I I I
LONS TER" NQNITCRIN& I i
I
I d.v I
P.rlonn,1 .nd SUDoll.1 I 1 11,500 I 11 , "'0 30 114,140
l...or.t or y I" I 10 1500 '5.000 30 147, US
I I : !
SUITOT AI. 1169.2"
CONTIM&£NCY . ~Olt 811.0 on 101 04 Sybtat.1 11o,'"
TOTAL i 11".207
O'''.2.lW-l
-34-
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Table 7' Environmental Criteria Beised on Potential Health Effects (ARARs)
Max imun Reccmnended Inhalation Ambient
Maxinun Sample (bserved Est i~t~ Max imun Allowable Reamnended Criteria
Saq>led Concentration Maxwun Contaminant Daily Time-Weighted for Protect ion
uSEPA.. 1984; -SUmlary of CUrrently Acceptable Daily Intakes CADIs) for Oral Exposure".
ca;HA. 1981, -General Industry Safety aoo Health Standards", 29 CFRl910.
«\.sEPA, 1980, -Dicholoropropanes/Dichloropropenes: Ambient Water Quality Criteria."
~EPA, 1980, .~ient Water Quality Criteria for Ethylbenzenen.
fUS8'A, 1984, -Health Effects Assessment for Xylene"'.
gSittig~ 1985, Handbook of Toxic and Hazardous Chemicals and Carcinogens
NA . Not ~ppllcabl.
NR . None reported in toxicology database.
NO . Not detected,
-------
f'uture Actions
When the construction of the cap is accepted as complete by EPA and FDER, EPA
will begin the process to delete the site f~ the NPL.
/
-------
cx:Ho1UNITY RESPOOSIVEM:SS StM1ARy
ALPHA RESINS CORPORATI~ SITE
Lakeland, Florida
The Alpha Resins Corporation has been the subject of preliminary assessments
by the United States Envirormental Protection Agency and the Florida
Department of Envirormental Regulation in 1981 and 1982 respectively. '!'he
Alpha Resins contractor carried out a Remedial Investigation and an
Endangerment Assessnent that were caapleted by OCtober, 1986. '!'he
Feasibility Study was canpleted in February, 1988. '
"nle use of unlined percolation ponds, which was then permitted by the PIER,
led to low level contamination of onsite soil and the surficial grcund vater
aquifer. One of the ponds was used as a solid waste landfill for a short
period of time and has also probably contributed to the present conditions at
the site. The site was placed on the National Priorities List (NPL) in
OCtober, 1981. Since this time the FDER, EPA, and Alpha Resins Corporation
have kept the local carmunity informed through notices in the newspapers,
public meetings and through updates of information to the local site
information repository.
This Ccmnunity Responsiveness S1.m1\ary has been prepared to present a S\mIIary
of the EPA's and FDER's community relations activities wi.th respect to the
Alpha Resins site.
.
The Response S1.m1\ary is divided into three section:,
Section 1 - Overview - This section discusses the FDER's and EPA' s
recamnended alternative and possible public reaction to this alternative.
'Section 2 - Community Relations Activities - This section describes ccmmunity
relations activities performed by the FDER and EPA. '
Section 3 - Ccmnunity Relations Responsiveness S\mDary - This section
describes FDER and EPA responses to questions asked during a February 22,
1988 public meeting held to discuss the results of the Feasibility Study (PS)
performed for this site and to answer questions about the proposed remedy for
the site.
1.0 OVERYIEW
1.1 ~1U.&nded Altemati ve
'1'he r~-nded alternative for this site is cappino of the. small unlined
pond with long-term gJ:'QIJ'd water nadtorino. Low levels of organics are
present in the Oft-site soils and surficial ground vater ~if.r.
Health-based standards for ethylbenzene are exceeded in one _11 which i.
-1-
-------
directly d~radient fran the small unlined pond. Capping will reduce
infiltration of rainwater through the unlined pond, thus reducing the
concentrations of contaminants.
The recarmended alternative also includes long-term lID1itoring of ground
water and surface water to assure that concHtions at the site are not .
degrading. By continuing to nw::>nitor the site, the natural attenuation of the
organics in the ground water can be IIDnitored on a lc:xg-term basis. In the
unlikely event that conditions worsen, a contingency plan with h\.lllal1
health-based and aquatic staooards will be developed to assess site
conditions and implement remedial actions if necessary.
1.2 Expected Public Reaction
Overall, the public is satisfied with the findings of the RBmedial
Investigation/Feasibility Study and with the r~nded alternative. '!'bere
were a moderate n\Dber of people attending the two public meetings that were
held and IIDSt people were concerned wi th concH tions and events of the past
that did not pertain to existing conditions at the Alpha Resins site. 'l'be
mER and the USEPA did not receive any carments during the three week public
comment period (February 22, 1988 to March 11, 1988) subsequent to the public
meeting that was held to discuss the Feasibility Study.
2.0 Community Relations Activities
A number of CCJm1Unity relations activities have been conducted at the Alpha
Resins site by the mER, EPA, and the Alpha Resins Corporation. A public
informatiQn repository was established at the Lakeland library, Lakeland;
Florida. 'l11e Remedial Investigation and Eooangerment Assessnent were placed
in the repository in November, 1986 and the Feasibility Study in February,
1988. .
Two public meetings have been conducted for the Alpha Resins site. 'l'be first
was held on November 6, 1986 for the purpose of discussing the Remedial
Investigation and the Endangerment Assessment. 'n1e second, held on February
22, 1988 was to discuss the findings of the Feasibility Study and the
reccmnended alternative for the Alpha Resins site. Both meetings were held
in Lake 1 and , Florida and turnout was moderate. Public concerns were
expressed and were addressed by the FDER, EPA, and Alpha contractors.
Problems of the past with cdors fran air emissions were solved with the
installation of an incinerator. The only real concern that i8 remainiR1 was
a caaplaint by neighbors who claim their water was containated with
butanone. A later study showed this to be a laboratory or S8IIpliR1 error and
that there was no ground water contamination in any private, off-site water
wells.
Prior to and throughout the Remedial Investigation/Feaaibility Study pt'OO888
the public has been infol8d of site cxnUtions, CDpiR1 stucU., and the
future intent of the P'IER and EPA with respect to r.-dial action. '1'ben vas
little or no opposition to the nn......-'8_nded alternatiYe at the latest pJblic
-2-
-------
-~-- -_._~_. -~- -- - .--- -~ .--. -
meeting and no ccmnents were received. mER published the proposed plan in
the local CCIII1IW\i ty newspaper. FDER also published a fact sheet prior to the
public meeting containing addresses to which public ccmnents would be .
received.
3.0 Carmunity Relations Responsiveness S\mDarY
-------
2. What Separates the Surficial Aquifer from the Floridan Aquifer Beneath:
Citizens asked speakers to explain why water from the surficial aquifer
does not go down into the Floridan Aquifer below.
Response: Speakers explained this was a classical case of Floridan
geology. 'l11ere is a surficial aquifer, a clay confining layer, and the
underlying Floridan Aquifer. 'n1e clay layer at the Alpha site is very
continuous and impedes the flow of water down into the Floridan Aquifer.
3. Move the Material in the Landfill Off-site: Citizen asked who pays for
excavating and moYing all of the landfill materials.
Response: Speaker stated Alpha would pay for it and ooe of the main
reasons this was not r~'8..nded as a treatment alternative was because
the benefit gained was not warranted by the cost. Another speaker noted
that according to current industry practice, landfilling of wastes 1. not
considered a permanent solution.
4. Resin Barrels in the Landfill: Citizens asked about what the Agencies
were going to do about the barrels of resins d\mlPed in the landfill.
Response: Speaker responded by explaining once the resins have hardened
they are no 10rw;;1er considered a hazardous waste and the sampling showed
that the contents were not causing a problem.
5. Air Quality in the Plant Vicinity: Citizens asked why air qual~ty has
not Qeen addressed in past and current studies.
Res~: Speaker explained that local DER district offices are
responslble for monitoring air quality at this facility. Camplaints and
concerns '«>Uld be tOOre effectively directed towards that office.
Questions Relating to Past DER and EPA Groundwater Investigations
1. Phthalic Acid in the Landfill: Citizen asked about the toxicity and
aoount of phthalic acid d\..JDP!d in the landfill.
Response: Speaker answered the testing has not shown a significant
--=unt of phthalic acid concentration in the water uaples frail wll.
located near the landfill. 'lbe primary source of this con~nant is
1II)r8 likely the past WI8 of the unlined percolation pord.
2. Offsite Te8tina to the East of the Alpha Property: Citizens asked about
the teat!iij'O'f water and soil to the east of the Alpha pEOperty where
water drains into the swalllp frail the ~ on the Alpha site.
:~=: th~~ = ~A ~f=yswa:~ =~ba~ Al: c:t~l~ter
standards. Soils have not been tested based (Xl the results of the water
quality data.
-4-
-------
3. Surficial ifer North of the S ra Fields West and South where
Robinson Pr~rty is: Citizens asked if the surf cual aq\Jlfer north of
the spray belds and west and south on the Alpha site is now clean.
Response: DER responded by saying all testing indicates they are clean
and that the surficial aquifer damage is confined to the iIrmBdiate area
of the unlined percolation pond.
4. 1984 Anal sis Reveali Butanone in Citizen's well: Citizen asked about
1984 letter fran EPA lnfomlng them butanone had n detected in their
well.
:=~ u::~~rc~~~~ned ~~~=t~:S i:O~ =:~ in
the analysis. Specifically, non laboratory grade acetone vas used to .
rinse the sample bottles. '!'his grade of acetate contains butancne - a
contaminant which was detected in all of the samples taken during that
sampling event, including the laboratory provided blanks and spikes used
for Ouali ty Assurance/Control.
s. Citizen Concern for Data Obtained fran Most Recent Groundwater
Investigation Cffizen stated there was a problem in -oelleving the data
both EPA and DER collect because of the past errors in lab data.
Response: Speaker responds that DER certifieS the labs doing these
analyses and that EPA splits samples with these labs as an additional
Quality Assurance/Control.
ReS~: After the first analysis (NovEl1lber, 1981) of the site in which
arsenlc was detected, arsenic was never again detected after that.
Metals were then excluded fran the June 1986 analyses because theY had
not been detected in samples taken since that first time.
Camlents on the Ploposed Remedy for the Site
1. Feasibilit~Study States Cap would not be Cost Effective Citizen states
t:hitfeasibl1ity stw,--rncncates a cap would not be CC8teffective beca\188
of the small 8IDJftt of rain water likely to be contBinated wt.n it
filters down to the waste. He then goes on to _k if EPA aQl'~ with
that assessment ard why EPA reo ..,\'V~ capping the unlined pont! inst88d
of r--_nding the no action titemati.. .
~:~re ~;~l r:=t~e=~:i: ':-=~t; ~-=~
to a point where they are no longer a prabl_. EPA agk...A6 with ..t of .
the us\IIIPtions made in the PS oo.ver, EPA' s calculatians on the ....t
of rainfall entering the unlined pond predict a greater benefit fma the
cap than the PS concludes. .
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2. Air Quality:
Resins Plant.
Citizen asked who will monitor the air around the Alpha
Response: Speaker responded that as far as this study goes, this is not
an air problem. For problems with air, citizens should call the local
DER in Tampa and have them cane and check into it.
3. ~Term Monitoril'VJ Citizen asked if they (citizens) could be
canfortable knowir¥J ltIX1i torilVJ of the ground and surface water would be
continued for as long as the water shows BaDe fom of containation,
possibly as lOr¥J as 20 or 30 years.
Res~: Speaker responded that a more accurate description might be to
say actlon levels, if exceeded, would be used to detemine whether the
chosen remedy is effective. These action levels are established at
values below reccmnended maxinun contaminant levels. If lIICnitorilVJ aver
time indicates a decreasir¥J trend of contamination, then lIICnitorilVJ
frequency will probably be reduced.
4. Collection of Samples: Citizen asked who would collect the saaples of
ground and surface water. ~ld it be a contractor C~ Alpha personnel?
Response: Speaker explained that decision was not made at this time,
however EPA and DER typically split these samples with the people
collectir¥J them to ltIX1itor for Quality Assurance/Control.
5. How ~ Between the Three week Ccmnent Period and Eventual Settlement
Agreement with Alpha: Citizen asked how long a time between the three
week carment period and a settlement agresnent was likely to elapee.
Res~: Speaker explained there is preparation of a Record of Decision
enV1Sloned by April 1, 1988. Law allows for a 120 day negotiation
period. Alpha '-'OUld have 60 days to make a good fai th offer to EPA to
design and construct a remedy. There is an additional 60 day period to
canplete negotiations on an agreement with EPA. 'lbis represents the 120
day total.
6.
If Monitoril'VJ Stops, ~ld it be Made Public: Citizen asked if .
ltIX1itoril'Y;1 were stopped, is this a decision that would be made public or
would there be another public meetilVJ to discuss that decision.
~ Speaker responded by answering that it would be a part of the .
publlc record, however no requir8D8nt exists, at this time, for a public
meeting to discuss that decision.
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