United States        Office of
             Environmental Protection   Emergency and
             Agency           Remedial Response
EPA/ROD/R04-90/059
March 1990
&EPA    Superfund
             Record of Decision:
             City Industries, FL

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50272-101
 REPORT DOCUMENTATION
         PAGE
1. REPORT NO.
     EPA/ROD/RO4-90/059
                                           3. Recipient* Acceceion No.
  4. Trie end SJbtrte
   SUPERFUND RECORD  OF DECISION
   City  Industries,  FL
   First  Remedial Action - Final
                                           5. Report Date
                                                    03/29/90
  7. Au*ior(e)
                                                                     8. Performing Organization Rept No.
 9. Performing Organization Name and Addret*
                                                                     10. ProjecVTaek/Work Unit No.
                                                                     11. ContracqC) or Grint(G) No.

                                                                     (C)

                                                                     (G)
   Sponsoring Organization Name and Addrcs*
   U.S.  Environmental  Protection  Agency
   401 M Street,  S.W.
   Washington, D.C.  20460
                                           11 Type of Report t Period Covered

                                                800/000
 15. Supplementary Note*
 16. Abetract (Limit: 200 worda)

 The  City Industries site  is  a former hazardous waste  recycling  and transfer facility in
 Goldenrod Township, Orange County, Florida,  near the  cities of  Winter Park  and Orlando.
 The  city of Winter Park's water supply  well  field  is  located approximately  1,900 feet
 west of the site.   These  wells draw from the deep  Floridan aquifer,  which is separated
 from a  surficial  aquifer  by  a 140-foot-thick confining layer.   In 1971, a former fuel
 oil  business at the site  was developed  into  a waste-handling facility.  Activities at
 the  site included receiving,  handling,  storing, reclaiming, and disposing of various
 waste chemicals.   Improper disposal practices and  intentional dumping led to onsite soil
 and  surficial ground water contamination.   In 1983, after the State  ordered the business
 closed,  the site  was abandoned.  The State subsequently removed the  onsite  waste drums,
 some contaminated soil, and  waste sludge.   In 1984, EPA removed and  thermally treated
 1,670 tons of contaminated soil and disposed of the residuals onsite.  Additionally,  EPA
 removed 180 cubic yards of highly contaminated soil and transported  the soil to an
 offsite hazardous waste landfill.  This  Record of  Decision (ROD)  addresses  contaminated
 ground  water, which is migrating through the surficial aquifer,  a potential drinking

 (See Attached Page)
 17. Document Anelyeie a. Deecftptgni
    Record of Decision -  City Industries,  FL
    First Remedial Action - Final
    Contaminated Medium:   gw
    Key Contaminants:  VOCs (benzene,  PCE,  TCE,
                          toluene)
                jTerme
   c. COSATI Held/Group
 1*. AvaUabllty Statement
                            19. Security CUee (Thle Report)
                                   None
                                                     20. Sacirtly Claae (Thie Page)
                                                            None  	
21. No. ofPege*
       71
                                                                                22. Price
(See ANSJ-ZM.1S)
                                      See Instruction* on Atwtnw
                                                      Uf* IIONAL rUHM ZrZ (+-f f)
                                                      (Formerly NTIS-35)
                                                      Department of Commerce

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EPA/ROD/R04-90/059
City Industries, FL
First Remedial Action - Final

Abstract  (Continued)

water source,  and prevention of contaminant migration to the deeper Floridan aquifer.
The primary contaminants of concern affecting the ground water are VOCs including
benzene, PCE,  TCE,  and toluene.

The selected remedial action for this site includes pumping and treatment of ground
water using air stripping, followed by offsite discharge to a' publicly owned treatment
works (POTW),  if treatability studies show the discharged water meets pretreatment
standards; and ground water monitoring.  If a local POTW will not accept the treated
effluent, a contingency remedy will be instituted, which includes ground water pumping
and treatment using air stripping followed by precipitation, filtration, carbon
adsorption, and possibly biological oxidation; conducting treatability studies to ensure
compliance with surface water discharge criteria; and discharging the treated effluent
offsite to a nearby drainage canal.  Both the selected and contingency remedies include
implementation of institutional controls, including land use and deed restrictions,  and
securing construction rights-of-way and easements at the site.   The estimated present
worth cost for the selected remedial action is $4,575,632,  which includes an annual O&M
cost of $292,500 for 15 years.   The estimated present worth cost for the contingency
remedy is $4,262,101,  which includes present worth O&M costs of $2,849,191 for 15 years.

PERFORMANCE STANDARDS OR GOALS:  The surficial aquifer is a potential source of drinking
water,  therefore,  contaminant levels must be reduced to drinking water standards,
including benzene 1.0 ug/1 (State drinking water standard), PCE 3.0 ug/1 (State drinking
water standard), TCE 3.0 ug/1 (State drinking water standard),  and toluene 2,000 ug/1
(Proposed MCLG).

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                                RECORD  OF  3ECISION


SITg NAME AND LOCATION

City Industries (City Chemical)
Winter Park, Florida

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action tor the City Indus-
tries Site in Winter Park, Florida chosen in accordance with CERCLA, as amended
by SARA and, to the extent practicable, the National Contingency Plan.  This
decision is baaed on the administrative record file for this site.

The State of Florida concurs on the selected remedy.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in this ROD, may present
an imminent and substantial endangerment to public health, welfare, or the
environment.

DESCRIPTION OF THE REMEDY

This remedy is the final action for the site.  It addressee the ground-water
contamination, which is the principal threat remaining at the eite.  This is
accomplished by pumping and treating the contaminated ground-water.  The
treated ground-water will be discharged to a publicly-owned treatment works
(POTW).

The major components of the selected remedy include:
     *    Institutional Controls or Other Land Use Restrictions;
     *    Ground-water Monitoring of Surficial and Floridan Aquifers;
     *    Ground-water Recovery via Wells;
     '    Ground-water Treatment by Aeration to Pre-treatment Standards;
     *    Discharge of Treated Effluent to the Iron Bridge POTW or  other local
          POTW;
     '    Treatability Studies to Ensure Compliance with  POTW Pre-treatment
          standard*
     *    Backup Discharge Plan; and
     *    Review of Ground Water Use for Surficial Aquifer Every  Five Years.

EPA has also selected a contingency alternative, in the event that  the POTW
does not agree to accept the discharge.

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The major components of the contingency remedy include:

          Institutional Controls or Other Land Use Restrictions;
          Ground water Monitoring of Surficial and Floridan Aquifers;
          Ground water Recovery via Wells;
          Ground water Treatment by Aeration, Precipitation, Filtration,  and
          Carbon Adsorption; and
          Surface Water Discharge of Treated Effluent.
     '    Treatability Studies to Ensure Compliance with Surface Water
          Discharge Criteria
          Review of Ground Water Ose for Surficial Aquifer Every Five Years.

STATUTORY DETERMINATIONS

The selected and contingency remedies are protective of human health and the
environment, comply with Federal and State requirements that are legally
applicable or relevant and appropriate to the remedial action, and are
cost-effective.  These remedies utilize permanent solutions and alternative
treatment (or resource recovery) technologies to the maximum extent practicable
and satisfy the statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element.  Because these
remedies will not result in hazardous substances remaining on-site above
health-babied levels, the five-year review will not apply to this action.


                                                                  MAR 2 9 1590
Greer C. Tidwell, Regional Administrator ' T                      Date

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           Record of Decision


Summary of Remedial Alternative Selection
   City  Industries  (City Chemical) Site

          Winter Park, Florida
               Prepared by:
   U.S.  Environmental Protection Agency
                Region  XV
             Atlanta, Georgia

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                               TABLE OF CONTENTS

1.0  Site Location and Description	1

2.0  Site History	1

3 .0  Community Relations History	4

4.0  Scope and Role of Response Action	6

5.0  Summary of Site Characteristics	6

6.0  Summary of Site Risks	10
     6.1  Exposure Assessment Summary	10
          6.11  Surficial Soil Contact	11
          6.12  Drainage Ditch Exposure	11
          6.13  Ground Water Exposure	12
     6.2  Toxicity Assessment	13
          6.21  Cancer Potency Factors	13
          6.22  Reference Doses	,	13
     6.3  Risk Characterization	15
          6.31  Cancer Risk	15
          6.32  Noncarcinogenic Risk	IS
     6.4  Environmental Risk	18

7.0  Description of Alternatives	13
     7.1  Alternative 1 - No Action	18
     7.2  Alternative 2 - Extraction, Aeration, POTW Discharge	21
     7.3  Alternative 3 - Extraction, Aeration, Filtration, Precipitation,
                          Carbon Adsorption, Surface Water Discharge	24
     7.4  Alternative 4 - Extraction, Aeration, Biological Oxidation,
                          Filtration, and Carbon Adsorption, Reinjection...29
     7.5  Alternative 5 - Extraction, Aeration, Precipitation, Filtration,
                x         Carbon Adsorption, Reinjection	30

8.0  Summary of Comparative Analysis of Alternative*	31
     8.1  Protectiveness of Hunan Health and the Environment	32
     8.2  Compliance with Applicable or Relevant and Appropriate
          Requirements (ARABS)	32
     8.3  Reduction of Toxieity, Mobility, or Volume	32
     8.4  Short-tan Iffectiveness	-.	33
     8.5  Long-tan If fectiveness	.,	33
     8.6  ImplesMoteJsility	33
     8.7  Cost	33
     8.8  State Acceptance	33
     8.9  Community Acceptance	34

9.0  The Selected Remedy	34

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                           TABLE OF CONTENTS (CONT.)

10.0 Statutory Determinations

     10.1  Protection of Human'H.aUh'and'^'Environment ."!.' '. '. '.'. '. '.	JJ
     10.2  Attainment of Applicable or Relevant and Appropriate
           Requirements	

     10.3  Cost-Effectiveness	.'.'.'	41

     10.4  Utilization of Permanent Solutions and'Alternative'Treatment'or'
           Resource Recovery Technologies to the Maximum Extent
           Practicable	

     10.5  Preference for Treatment as a Principal Element	42


11.0 Documentation of Significant Changes	42

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                                LIST OF FIGURES


Figure 1-1   Site Vicinity Map	2

Figure 1-2   Site Location Map	3

Figure 5-1   Little Econlockhatchee Drainage Basin	7

Figure 5-2   Estimated Plume Boundary	9

Figure 7-1   Conceptual Layout of Sewer System Discharge Alternative	22

Figure 7-2   Process Schematic for POTW Discharge	23

Figure 7-3   Conceptual Layout of Surface Water Discharge Alternative	27



                                 LIST OF  TABLES


Table 6-1   Weight of Evidence and Potency Factors for Suspect Carcinogens
            Reported at the City Chemical Site	14

Table 6-2   Indicator Chemical Reference Doses for Short-Term
            and Chronic Exposure	16

Table 6-3   Summary of Potential Toxic Responses of Constituents	17

Table 6-4   Cancer Risks and Hazard Indices for Ground Water Exposure
            at Potable Well	19

Table 6-5   Cancer Risks and Hazard Indices for Ground Water Exposure
            at Non-Potable Well	20

Table 7-1   Ground Water Cleanup Goals for City Chemical Site	25

Table 7-2   Freeh-water Aquatic Life Criteria	28

Table 9-1   Detailed Cost Breakdown for Preferred Alternative	_.	36

Table 9-2   Detailed Cost Breakdown for Contingency Alternative	39
LIST OF APPENDICES

Appendix A - Remedial Investigation Sampling Data and Locations

Appendix B - Responsiveness Summary

Appendix C - State Concurrence Memorandum

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1.0  SITS LOCATIOH ft DESCRTPTTftu

     The City Industries (City Chemical) - Forsyth Road site is located at 3920
     Forsyth Road, winter Park, Florida.  It should be noted that while the
     mailing address for the site is Winter Park,  it is actually located in the
     unincorporated township of Coldenrod.  The City Chemical Company operated
     a waste storage, disposal, and recycling facility at the Forsyth Road site
     from 1971 until August 1983.  The one acre site is situated in a light
     industrial area in the eastern section of Orange County, Florida,
     approximately 1.2 miles east of Winter Park and 2.2 miles northeast of
     Orlando.  A map showing the site vicinity is  provided in Figure 1-1.

     The site is bounded by Cato steel, a metal fabricator,  to the north, Top-
     gun Gunite to the west, Forsyth Road to the east, and a wooded area to the
     south.  A site location map showing the City Chemical site and adjacent
     properties is presented in Figure 1-2.  Activities at the facility
     included the receipt,  handling, storage, reclamation, and disposal of
     various waste chemicals.  General classes of  wastes handled included
     chlorinated and nonchlorinated organic solvents, paint and varnish wastes,
     acid/alkaline plating wastes, and waste ink.

2.0  SITE HISTORY

     In 1971, City Industries, Inc., purchased the fuel oil business previously
     owned and operated by Charles Blackburn.  Mr. Blackburn retained ownership
     of the property at Forsyth Road.  In 1977, it developed into a recycling
     and transfer facility for hazardous wastes.  Due to inadequate plant
     practices and intentional dumping, soil and ground water at the site
     became contaminated.  From 1981 through 1983, EPA and Orange County found
     the company to be out of compliance with safety and Resource Conservation
     and Recovery Act (RCRA) requirements, and ordered the business to be
     closed in July, 1983.

     In August 1983, the site was abandoned by the owner/operator of City
     Industries, Arthur Greer, leaving approximately 1,200 drums of hazardous
     waste and thousand* of gallons of sludge in a number of large holding
     tanks on the lite.  A removal of these wastes, funded by the Florida
     Department of Bnvironmental Regulation  (FDER), was conducted during August
     and September 19t3.  In early 1984, EPA .issued an Administrative Order
     under CBROJI requiring City Industries to clean sludge  from holding tanks,
     remove contaminated soils, and treat contaminated ground water.  The
     company did not comply with the EPA order.  Beginning in February 1984,
     the remaining sludge and storage tanks were removed by  the IPA.  In May
     1984, the EPA removed 1,670 tons of contaminated soil,  heat treated it,
     and returned it to the site.  Additionally, 180 cubic yards of highly
     contaminated soil were removed and transported to a hazardous waste
     landfill.  The City Chemical site was proposed for the  National Priorities
     tist (NPL) in August 1984.  EPA notified approximately  250 potentially
     responsible parties (PRPs), primarily waste generators, of their potential
     liability for remediation of the  site and demanded payment for cost
     incurred during the removal of wastes.  A settlement with approximately
     163 PRPs for $520,722 was obtained in July,  1988.

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      FIGURE 1-1

VICINITY MAP
          City Chemical Site
           Unlvtrslty Boulevard
    Winter Park
    approximately 1 milt

    Orlando
    approximately 2

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       FIGURE 1-2
SITE LOCATION MAP
     SOURCE: ESE, 1984

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                                       -4-

     In December 1985,  Arthur Grser was indicted on thirty-three counts
     involving mail fraud and environmental Crimea.  In June 1986,  he was
     convicted on seventeen counts' involving fraud and RCRA violations and
     received a jail sentence.

     In 1984, the FDER contracted with Environmental Science and Engineering
     (BSE) to conduct a Contaminant Assessment (CA) study,  or Remedial
     Investigation (RZ) of the site.  ESS completed a multi-phased  Contami-
     nation Assessment in May 1986.  The final CA concluded that a  contaminant
     plume in the surficial aquifer had migrated to the east,  approximately 600
     feet.  A surface depression was discovered in close proximity  to the site,
     causing concern that a sinkhole had developed and formed a connection
     between the surficial and Floridan aquifers.  BSE completed an
     investigation of the area in October 1986.  This study recommended
     monitoring of the Floridan aquifer, which is the primary source of
     drinking water in the area.  Installation of a Floridan Aquifer monitoring
     well was completed in July 1988, and sampling results  from this well
     indicated that the Floridan Aquifer has not been contaminated  by the City
     Industries Site.  Approximately thirty-two of the 250  PRPs identified by
     EPA formed a Steering Committee and entered into a consent agreement with
     FDER to perform the Feasibility Study.  A draft Feasibility Study (FS)
     report was submitted by the Potentially Responsible Parties (PRP)
     contractor in December 1988.  Efforts to modify the FS were unsuccessful.
     In March 1989 at the state's request, the lead management role for the
     site was transferred from FDER to EPA.  Revised FS reports were submitted
     to EPA by the PRPe in June and December 1989.

3.0  COMMUNITY RELATIONS HISTORY

     The City Industries Site has come to be associated with the town of Winter
     Park, as it has a Winter Park mailing address.  It is  situated, however,
     outside the city limits in the unincorporated township of Goldenrod, which
     is where the majority of community interest is centered.

     In 1983, the community of Goldenrod held meetings for the purpose of estab-
     lishing eaargetncy evacuation procedures.  These meetings included represen-
     tatives fresj FDXR, Orange County, Seminole County, neighborhood watch and
     homeowners aMOciationa, apartment complexes, private citizens,.and var-
     ious media fsjcsonnel.  The threat at the time was considered to.be that of
     explosion at fir*.  In addition, a concern was voiced that City Industries
     trucks traveling through the streets carrying drums might have an
     accident, or the drums might fall from the truck, spilling contaminants.
     On one occasion, evacuation procedures were begun in the immediate area  in
     response to an onsite spill, but were later determined to be unnecessary.

     When onsite investigative activities began, the protective suits worn by
     the workers alarmed the people both  in the  immediate vicinity, where they
     questioned why they were allowed to  be so close if the suits were
     necessary.  Those who were a  little  further away but close enough to be
     affected should an emergency  situation arise, were also  concerned.

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                                 -5-

Citizens who own private wells in the surficial aquifer voiced concern
about the quality of their water.  None of these wells have been used
for drinking water, but the concern was mentioned that pets or children
playing in water from lawn sprinklers - or possibly drinking some of the
water - may have been at risk, or that someone walking through freshly
watered grass may have absorbed contaminants through the skin.

Several of the well owners stated that they had never received
information regarding the results of samples collected from their
wells.  The question was raised by one individual whether a number of
deaths attributed to cancer were related to possible contaminants in the
water.  It was suggested that a health survey be conducted to assess the
possibility, and be used as a learning opportunity should a connection
exist.

One businessperson found monitoring wells installed on his property
without his permission, and attempts by PDER to rectify the installation
deficiencies had been unsatisfactory.  (These wells were among the ones
installed in early attempts to monitor the movement of contaminants in
the ground water).

The question of effect of the site on property values was raised,
predominantly by residential property owners.  In the business area,
property seems to be at a high enough premium for values not to be
significantly affected, although some businesses contacted expressed
concern about the possibility.  The problem for the business sector
seems to be that property ownership may be nontransferable until the
property is declared clear of contamination.

Virtually everyone interviewed expressed extreme dissatisfaction with
the nominal sentence received by Arthur Greer, the owner/operator of
City Industries, Inc.

Recently, the site is mentioned only when reference is made to pollution
or contamination in general.  The Environmental Health Division of
Orange County Health Department reported that no recent comments or
concerns had boon voiced to that Department.  Moet people indicated that
the critical issue now is to expedite the implementation of the final
remedial effort*.

In the course of investigative and remedial activities at the site,
federal response to community needs and concerns has been perceived as
sufficient.  Criticism regarding the response by officials usually
pertained to difficulty in locating the correct contact. Inquiries were
always referred elsewhere.

The primary concerns of people in the vicinity of the  site are that the
necessary remedial actions at the site be completed as soon as possible,
and that the community be kept informed of the status  of the  site or  any
potential threat resulting from site conditions.  For  those who  do  not
feel their health may be threatened, the main concern  is property

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                                      -6-

     devaluation.  The leniency of punishment sustained by Mr.  Greer is also
     a focal point in the mind* of many of the citizens interviewed.

     The RI/FS and Proposed Plan for the City Chemical Site were released to
     the public in January 1990.  These two documents were made available in
     both the administrative record and an information repository maintained
     at the EPA Records Center in Region IV and at  the Winter Park Public
     Library.  The notice of availability for these two documents was
     published in the Orlando Sentinel on January 23 and January 31, 1990.  A
     public comment period was held from February 6, 1990 through March 8,
     1990.  In addition, a public meeting was held  on February 6, 1990.  A
     press release was issued February 2, 1990 announcing the public meeting,
     comment period, and availability of documents  at the repository.  At the
     public meeting, representatives from EPA and the Agency for Toxic
     Substances and Disease Registry (ATSOR) answered questions about the
     findings of the RI/FS and the remedial alternatives under
     consideration.  A response to the comments received during this period
     is included in the Responsiveness Summary, which is part of this Record
     of Decision.  This decision document presents  the selected remedial
     action for the City Chemical Site, in Winter Park, Florida, chosen in
     accordance with CERCLA, as amended by SARA and, to the extent
     practicable, the National Contingency Plan.  The decision for this site
     is based on the administrative record.

4.0  SCOPE ANP ROLE OF RESPONSE ACTION

     This ROD addresses the final response action for the City Chemical Site,
     which consists of extraction and treatment of contaminated ground
     water.  This remedy is being implemented to protect public health and
     the environment by controlling the migration of contaminated ground
     water in the- surficial aquifer, which is a potential source of drinking
     water in the future for area residents and businesses.  It will also
     prevent migration to the deeper Floridan Aquifer, which is the current
     drinking water source.  The response actions are consistent with the NCP
     (40 CFR 300.68).

5.0  SUMMARY OF »)ICT CHARACTERISTICS
     The major surface-water features in the area of the site are th* Crane
     Strand wetlttd directly to the north, which is being developed; various
     small wetland areas to the south and east; the Little) Econlockhatchee
     River approximately 2.5 miles to the southeast; and a series of county
     maintained drainage canals traversing the Little Iconlockhatchee Drain-
     age Basin.  Figure 5-1 shows the drainage canal system  in the vicinity
     of the City Chemical  Site.  The closest major lakes are Lake Waunatta,
     Lake Nan, and Perch Lake, located less than one mile east of the site
     (BSE, 1985).  Primary surface drainage across the site  is by overland
     flow from west to east.  Discharge to a ditch along Forsyth Road occurs
     along the east side of the property.  The Forsyth Road  ditch drain*  to
     the north past Cato Steel and then to the east under Forsyth Road  to a
     storm-water catch basin.  The basin discharges to the north through  an
     underground storm culvert and an open ditch to a large, county
     maintained, drainage  canal.

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                                            /    L.T7LI ECCNLCCXHATCHEE .= :'.£
	GRAlNiGS SASiN
         SCUNCArr
         CRAiNAGS CANALS
  IGURE  5-1:  LITTLE ECONLOCKHATCHEE DRAINAGE BASIN

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                                 -8-

The Bite is underlain by approximately 60 feet of sands,  silty sands and
clayey sands containing variable amounts of unconsolidated limerock,
chert, and phosphate fragments.  Silt and clay content of the soils
generally increases with depth.  The surficial soils are  underlain by
the Hawthorn Formation at depths of 60 to 70 feet bis. The Hawthorn is
characterized by up to 170 feet of inter-layered clayey gravel,  clayey
sand, clay, and limestone layers.  The karstified,  erosional limestone
surface of the Ocala Formation is found beneath the Hawthorn at  depths
ranging from 140 to more than 230 feet below land surface (bis).

The surficial aquifer occurs in the uppermost 60 to 70 feet of permeable
sands and is reportedly separated into an upper unconfined zone and a
lower, semi-confined zone.  The water table is encountered at depths of
3 to 5 feet bis.  Ground water flow is to the east at flow velocities
ranging from about 10 to 145 feet per year.  Flow rates generally
decrease with depth and are greater during the summer wet season than
during the dry season.

The Floridan aquifer, widely used as a source of potable  water in the
region, occurs in a thick sequence of limestone units generally en-
countered at the top of the Ocala Formation.  The Ocala was identified
at a depth of 237 feet during drilling of the Ploridan Aquifer monitor
well; however, depth to t-he Floridan from land surface may vary from
about 140 to more than 230 feet in Orange County.

The findings of the RI, September 1986, confirmed the presence of
chemical constituents in the shallow ground water aquifer underlying the
City Chemical Site.  Plume delineation results established that the
areal distribution of impacted ground water extended beyond the site
property boundaries.  A data augmentation program was conducted in  1987
to provide more recent data for constituents previously detected at the
site and define the migration of the ground water plume since the RZ was
performed.

Contaminants of concern identified during these two studies are acetone,
benzene, 1,1-dichloroethane, 1,2-dichloreothane, 1,1-dichloroethene,
ethylbensens), Mthylene chloride, methyl ethyl ketone  (MEK), methyl
isobutyl kvtoos) (MIBK), tetrachloroethene, toluene,
1,1,1-trichlorosrthane, and trichloroethene.

The results of the RZ and data augmentation program indicate that
several of the target list compounds are present in the shallow
aquifer.  The data also indicates that the ground water plum* identified
by BSE has migrated downgradient  from the City Chemical Site and  is now
centered in the vicinity of monitoring well  12.   (See Figure 5-2).

Constituents were not detected above detection  limits during soil sam-
pling  and analysis completed  in  the data augmentation program.  No con-
stituents analyzed during air monitoring exceeded  detection limits.  RZ
and Data Augmentation sample  analysis  results  along with  corresponding
sample locations are provided  in Appendix  A.

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                                CITY
                             CMIfMICAL
                                SITE
    MONITOR WELL AND NUMBER
S.  SHALLOW
 .  INTERMEDIATE     '   '
0-  I if I)'
    IN»I MflfDIKHINDAMYOU i»N
    TAMINANT PLUME tXCLEUING
    PROPOSED ARARs
              & Mil in JNC . (]|HJIM)WAI|IIUIIVIi:LS
 i
•i.
 i
                                                              KKHIRK  S-.';  KSTIMATKH I'l IIMi:  I1OHNHAKY

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                                     -10-

     Cround water is not currently being pumped for use at the City Chemical
     Site.   An inventory of wells within a two-mile radiua of the cite
     indicated that 1) exieting wells downgradient (east)  of the site are
     open to permeable intermediate units in the Hawthorn Formation or to the
     Floridan Aquifer and 2) these wells are used for non-potable purposes
     (e.g.  cooling water and irrigation).  The well inventory identified
     several wells located north and south of the site which are open to the
     eurficiai aquifer and are being pumped for landscape irrigation and heat
     pump exchange water.  No users of the surficial-aquifer as a source of
     potable water or for irrigation of edible crops in areas downgradient of
     the site were identified.

6.0  SUMMARY OF SITS RISKS

     The following discussion provides an overview of the baseline public
     health and environmental risk evaluation for the City Chemical Site.  It
     is based on the "Endangerraent Assessment for the City Chemical Company,
     Forsyth Road Site, Winter Park, Florida", which is Appendix C of the
     FS.  The baseline evaluation helps determine if a remedial action is
     necessary at the site.  It represents an evaluation of the "no-action
     alternative", in that it identifies the risk present if no remedial
     action is taken.  The baseline assessment also provides the framework
     for developing the preliminary remediation goals for the City Chemical
     Site.   Field observations and analytical data as presented in the Reme-
     dial Investigation and Data Augmentation reports provided the basis for
     the risk evaluation.  The media of concern at the City Chemical Site is
     the ground water.  Risk from dermal exposure from contact with the soil
     was mitigated by the soil removal conducted in 1984.

     The compounds mentioned in Section 5.0, which were detected in the
     ground water, were selected as indicator compounds for the site.  The
     selection is based on the frequency of detection, the concentrations
     detected, and the toxicological properties of the contaminants which
     were detected.  Concentrations of the indicator compounds detected
     during the RI and Data Augmentation Program can be found in Appendix A.

6.1  EXPOSURE ASMaSMINT SUMMARY

     Major pathways) of potential exposure to these 14 constituents were iden-
     tified act

     '    Contact with, and ingestion of, small quantities of surficial soil;
     *    Contact with, and ingestion of, drainage-ditch waters; and
     *    Contact with, and/or ingestion of, ground water pumped for bathing,
          hypothetical drinking-water usage, landscape irrigation and/or
          other non-potable usages.

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                                     -11-

6.11  Surficial  Soil  Contact-

     Exposure scenario for exposure to the soil*  were  evaluated for  a  worker
     (i.e.,  Cato Steel employee)  or a child trespasser.   The average  daily
     dose (ADD)  for reasonable worker exposure was calculated based on  the
     following assumptions:  (l)  a 70-kg adult body weight;  (2)  exposure  to
     surficial soils  for 120 working days (once per month over a 10-year
     period); (3)  exposed skin surface area of 870 cm2  (both hands);  (4)
     incidental  soil  ingestion rate of 100 mg/day; (6)  a dermal absorption
     factor of 0.02;  and (7) exposure to average concentrations of con-
     stituents detected in the soil.

     Worst-case  assessment for worker average daily dose from soils would use
     the parameters listed above  with the following exceptions:   (1)  exposure
     frequency is doubled to 240  working days; (2) dermal absorption  factor
     is 0.10; and (3) exposure is to the maximum concentrations detected  in
     soils.

     The exposure scenario for reasonable child trespasser climbing over  the
     security fence,  accessing the site, and being exposed to soils is
     calculated  based on the following assumption*:  (1) a 31-kg child
     (average of age  6 to 12); (2) trespassing 6 times  per year over  the
     6-year age  period; (3) incidental ingestion of 100 mg of soil per  day;
     (4) exposed skin surface area of 360 cm  (both hands);  (5) dust
     adherence factor of 1.4S mg/cm ; (6) dermal absorption factor of 0.02;
     and (7) exposure to average  concentrations of constituents detected  in
     soils.

     Worst-case  exposure for the  child trespasser is the same with the  ex-
     ception that:  (1) exposure  frequency is doubled to 12 times per year
     over the 6-year  period; (2)  dermal absorption factor is 0.10; and (3)
     maximum soil concentrations  are used at the exposure point.

6.12  Drainage Ditch gypoeure

     The drainage) ditch is the other point of potential current exposure.
     wading and SjOCidental immersion are potential exposure scenarios.   The
     drainage dltob is located along a street.with relatively high traffic
     volume; thsMjfore, the frequency of exposure at this sit* is assumed to
     be relatively low.  In addition, flow in the ditch is intermittent and
     throughout  most  of the year  the ditch is dry; therefore, swimming in the
     ditch is not a reasonable exposure scenario.  For this reason, the rea-
     sonable exposure scenario for ditch water wading was calculated based on
     the following assumptions:   (1) a 70-kg adult or 31-kg child; (2)  wading
     the ditch 2 hours per day;  (3) 4 times per year for 6 years  for the
     child or 1  time per year over a 10-year period for the worker;  (4) an
     exposed skin surface area for one-half the hand and neck, two-thirds of
     the upper limbs, and one-half of the lower limbs (3,105 cm2  child and
     6,210 cm2 adult); (5) water  flux across skin of 0.5 mg/cm -hr;  (6)
     100 percent dermal absorption of organic constituents; and  (7)  exposure
     to maximum concentrations detected in surface water.  The maximum con-
     centration data are used due to the limited  number of surface-water
     samples available.

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                                     -12-

     The worst-case scenario assumes that the adult  or  child falls  into the
     ditch and receives total immersion exposure:  (1) with the same frequency
     of 24 times for the child and 10 times for  the  adult;  (2)  for  a period
     of 0.25 hrs/day; but (3) incidental ingestion of 0.01 liters of water
     per immersion.

     Future exposure to the soils or ditch waters  are assumed to be com-
     parable to the current exposure scenarios.

6.13  Ground Water Exposure

     The other possible future exposure scenarios  include  exposure  to ground
     water from a potable or non-potable well.   There are  presently no wells
     screened in the shallow aquifer identified  downgradient of the site,  so
     these scenarios consider a hypothetical well  installed downgradient in
     the future.

     For potable well exposure, the reasonable exposure scenario ADDs were
     calculated based on the following assumptions:  (1) a  70-kg adult; (2)
     ingests 2 liters of water per day; (3) exposure occurs over a  70-year
     lifetime; and (4) exposure is to average concentrations detected in the
     ground water.  The worst-case exposure scenario assumptions are the same
     except maximum detected concentrations are  used.

     Potential non-drinking water exposures considered  as  hypothetical future
     exposure scenarios include use of the ground  water for bathing
     (showering), landscape irrigation, or for filling  small swimming pools.
     The bathing exposure is considered independent  of  the drinking water
     because some receptors may utilize tap water  for bathing but  use bottled
     water for drinking.

     To consider the potential exposure if the potable  supply is  not
     ingested, the ADDs were calculated using the  following assumptions:  (1)
     a 70-kg adult;  (2) bathes or showers for 20 minutes per day;   (3) every
     day of the year for 70 years;  (4) a skin surface area of 18,150 cm ;
     (5) a water flux across the skin of 0.5 mg/cnr-hr; and  (6) average
     constituent concentrations in ground water.  For worst-case bathing
     exposure, tfes) assumptions are the same except the maxlmvim constituent
     concentration* are used.

     Potential exposure to landscape irrigation water  is assumed to occur as
     a result of accidental dousing of the body and clothing while setting up
     the sprinklers.  The assumptions used to calculate the ADDs are:  (1) a
     70-kg adult;  (2) doused once per week over the 12-we«k  summer period for
     10 years;  (:  exposure to water or wet clothing for 1 hour per dousing;
     (4) over a     i surface area of 18,150 cm2 (total body);  (5)  water
     flux across   .-.a skin of 0.5 mg/cm2-hr;  (6)  dermal absorption  of  or-
     ganics of  100 percent; and  (7) average constituent concentrations in
     ground water.  The worst-case  exposure assumptions are  similar except
     that:  (1)  exposure occurs three times per week; and  (2)  exposure is  to
     the maximum detected constituent concentrations.

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                                      -13-

     Ground water used to fill a child'• swimming pool is the other hypo-
     thetical non-potable exposure scenario considered.  The assumptions used
     in calculating the reaionable exposure are: (1) a 16-Jcg child (average
     age 4, between age 2 and 6); <2) swims in the pool once per week over
     the 12-week summer period;  (3)  i hour per day; (4) incidental ingestion
     of 0.05 liters per hour; (5) skin surface area of 7,000 cm2; (6) cross
     the skin of 0.5 mg/cm -hr;  (7)  dermal absorption of organics of 100
     percent; and (8) exposure to average constituent concentrations detected
     in the ground water.  Worst-case exposure assumptions are similar
     except: (1) the child swims 5 days per week over the 12-week summer
     period; (2) the child swims for 2 hours per day; and (3) exposure is to
     the maximum constituent concentrations detected in the ground water.

     Inventories of wells within a two-mile radius identified no potable
     wells downgradient of the site, or nonpotable wells screened in the
     shallow aquifer within one mile downgradient of the site.  There is one
     nonpotable well 500 feet north of the site.

     The City of Winter Park's well field is located approximately 1,900 feet
     west of the site; however, these wells draw froa a minimum of 700 feet
     below the ground surface in the Floridan Aquifer, and there is a
     140-foot thick confining layer separating the contaminated surficial
     aquifer from the Floridan Aquifer.  The well field serves over 115,300
     people in the towns of Winter Park, Maitland, Coldenrod, and
     Casselberry.

6.2  TOXICITY ASSESSMENT SUMMARY

6.21  Cancer Potency Factors

     The discussion of adverse effects for the  indicator chemicals is divided
     into carcinogenic a~nd noncarcinogenic effects.  Cancer potency  factors
     (CPFs) have been developed by BPA's Carcinogenic Assessment Group for
     estimating excess lifetime cancer risks associated with exposure to
     potentially carcinogenic chemicals.  CPFs, which are expressed  in units
     of mg/kg-day)" , are multiplied by the estimated intake of  a potential
     carcinogen, la sjg/kg-day, to provide an upper-bound estimate of the
     excess lifsjtiM cancer risk associated with exposure at that intake
     level.  The) tan "upper-bound* reflects the conservative estimate of the
     risks calculated from the CPP.  Use of this approach makes
     underestimation of the actual cancer risk  highly unlikely.  Cancer
     potency factors are derived from the results of human epidemiclogical
     studies or chronic animal bioassays to which animal-to-human
     extrapolation and uncertainty factors have been applied.  Cancer potency
     factors for compounds of concern are listed in Table 6-1.

6.22  Reference Doses

     Reference doses  (RfOs) have been developed by  EPA for  indicating the
     potential for adverse health effects from  exposure to chemicals
     exhibiting noncarcinogenic  effects.  RfDs, which  are expressed in  units
     of mg/kg-day, are estimates of  lifetime daily  exposure  levels  for
     humans, inciudir.a sensitive individuals.   »«*•••• •»«-o/j  ;-«-«vao ~* -*•««•••-••>«

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                 1*ble 6-1 Weight of Evidence and Potency Factors for
                Suspect Carcinogens Reported at the City Chemical Site
EPA Level of
Constituent Classification §/ unman«
10"
Evidence Cancer
^Animals b/ Risk e/
Potency
Factor *'
(mg/L) (ogAg/day)"'-
Benzene
1 , 1-Dichloroethene
Methylene chloride
Tetrac.uJ.oroethene
Trichloroethene
Bis ( 2-ethylhexyl )phthalate
A
C
B2
B2
B2
B2
S
I
I
I
I
I
S
L
L/S
L/S
L/S
L/S
0.0012
0.000033
0.005
0.0008
0.0027
0.003
0.029
0.60
0.0075
0.051
0.011
0.014
a/  A - Hunan Carcinogen: sufficient epidemeologic evidence
    B - Probably Human Carcinogen:
        Bl - Limited epidemiologic evidence; sufficient evidence in animals
        B2 • inadequate or no epidemiologic evidence; sufficient evidence in animals
    C • Possible Human Carcinogen: absence of human data; limited evidence in animals
    D - Not Classifiable as to Human Carcinogen!city: inadequate or no data

b/  S - Sufficient evidence; L • Limited evidence; I • Inadequate evidence

c/  Concentration which could potentially result in 1 additional cancer in 1,000,000
    population drinking 2 liters of water per day over a 70-year lifetime.

d/  Potency factor • 95% upper-bound slopes on the linearized multistage model

Sources: USEPA, 1986a
         USEPA, 1985a
         IRIS, 1989

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                                     -15-

     from environmental media (e.g.,  the amount of a chemical ingested from
     contaminated drinking water) can be compared to the RfD.  RfDe are
     derived from human epidemiological atudiea or animal atudiea to which
     uncertainty factors have been applied (e.g., to account for the uae of
     animal data to predict effecta on humans).  These uncertainty factors
     help ensure that the RfDs will not undereatimate the potential for
     adverse noncarcinogenic effecta to occur.   RfDa for indicator compounds
     are listed in Table 6-2.

     Of the 14 indicator chemical*, benzene,  1,1-dichloroethene, methylene
     chloride, tetrachloroethene, trichloroethene, and
     bis(2-ethylhexyl)phthalate are clasaified  by the USEPA as suspect
     carcinogens.  Of these suspect carcinogens, benzene is the only one
     having sufficient evidence that it is carcinogenic in humans.  The USEPA
     classifies methylene chloride, tetrachloroethene, trichloroethene, and
     bis(2-ethylhexyl)phthalate as having sufficient evidence of
     carcinogenicity in laboratory animals but  insufficient evidence of
     carcinogenicity in humans.   There is only  limited evidence of the
     carcinogenic potential of 1,1-dichloroethene in laboratory animals and
     no evidence of carcinogenicity in humans.

     All of the six carcinogenic constituents discussed in the previous sec-
     tion are also mutagenic, except for bis(2-ethylhexyl)phthalate, and all
     have elicited teratogenic or adverse reproductive effecta in laboratory
     animals, except for trichloroethene.  Ethylbenzene, methyl ethyl ketone,
     and toluene, have elicited adverse reproductive or teratogenic effects
     in laboratory animal tests.  A summary of  toxic responses to all site
     contaminants is contained in Table 6-3.

6.3  RISK CHARACTERIZATION

6.31  Cancer Risk

     Excess lifetime cancer risks are determined by multiplying the intake
     level with the cancer potency factor.  These risks are probabilities
     that are generally expressed in scientific notation (e.g., 1X10   or
     1E-6).  An excess lifetime cancer riak of  1X10"6 indicates that, as a
     plausible upper bound, an individual has a one in one million chance of
     developing eaacer as a result of site-related exposure to a carcinogen
     over a 70-yemr lifetime under the specific exposure condition* at a
     site.

6.32  NoncareinoQenie Risk

     Potential concern for noncarcinogenic effects of a single contaminant in
     a single medium is expressed as the hazard quotient (HQ) (or the ratio
     of the estimated intake derived from the contaminant concentration in a
     given medium to the contaminant reference dose).  If the estimated
     intake is greater than the RfD, the HQ will exceed one.  By adding the
     HQs for all contaminants within a medium or across all media to which a
     given population may reasonably be exposed, the Hazard Index (HI) can be
     generated.  The HI provides a useful reference point for gauging the

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           Tabls  6-2  Ir.di r = tr : Char.irai ?.sf=rer.ce Dcses  fr:
                    Shcrt-Tarn a r. z  C h r c.". i r  I x c c s - r s
Crr.sti tuer.t                        Cr.e-Dav                Chrcr.ic
                              (mg/kg/dayj'Scurse     (mc/kg/day S = -

Arstsr.e                             —                    C.i:      c
Ser.rar.e                            2.33     a
l,l-Dic:-.lcrreth2r.9                  —
l,l--ic'"''crcetr.sr.9                 0*0     b
t-I,:-ri=:-.l = : = 9ther.e               0.27     b             O.C1      c
Ithylzer.zer.e                       20.7     b             0.1C      c
Ketr.ylar.e  cr.isride                 1.3      b             O.C5      c
.".ethyl ethyl  ketsr.e                7.5      b             O.C5      c
Methyl isobutyl  ketcr.e              —                    O.C:      c
Tetrachlcrcether.e                  3.4      a             C.C1      c
Tcluer.a                            18       b             0.30      c
1,1,1-Trichlorsethar.e              14       b             C.C5      c
Tr ichlc rcethsr.e                     —                    0.0073:   ~
Tctal phthalates                   —                    0.02      c
  (as bis-2-ethylhexyl)
Xvler.es                            11.9     b             2.0       c
a - USZ?A  Office  of  Drinking Watsr  10-day  Health  Advisory.  CJS£?A,
    1385b)
b - USZ?A  Offic*  of  Drinking  Water  1-day  Health  Advisory  (US£?A,
    lS35b)
c - IBIS,  19S9

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          a-^iy; ttisr.t
T«:r>c»;e.-3«:r.ir.t

Taiutnt

1.1, l-TritV.sraat.i
X'.tnti
    A4aptt< frst ";>>i«lcal, fhr''--»l. «"« l'.o.s|'.:«l trsttr-.'.ii of Caa;our.4i  frt«*nc    a.< u  cnac  »i  :-H.
:-§«lCJ'. M*:I th* cr'.ttrt* autiintd b» Own fir tn« particular caaic  tf!ic:  clataificactan.   T>t  '.m
:.«n'.!isa:lon .«»•  a  taate  c:td  human  earetnoftn:  1!  It  1««  ittn  b««n i-e«n  :: :•
    ear::nefaRi< at a particular at:a in «crt  tr.an »n«  iptcita or ft:  In a  anlaal biaaaiav:  or t!  it  *«•  St«n  f.ovr  :s
    incraaia :n« inci«anea of at:i-apaci!ic Mi'.|nanc tjaori la a a'.3|l* apactat or ««i,  ana eitara ia •   vn«la  aniaali  la  claarir poiltiv*.  Uniupparta<  in  »'. t;» avilanca la eanaiaaraa  «u.';.:nit :o
    elaaal!^ • «fco»t»al «< • f«*r*4uat'.«* tasicitr/taraeafanlcitr haiari.

c/  A ehcalul ta cluaKla* aa •itifanic i!  t: *tai  fivan a  poatii'a raau'.t In  at  laaac ona t! c.ta uvaiiin  ir.  /yvo •>•
    •Mmmt'.im oXU |g Tltra aaaara  far •utafanicitr-

a/  A ttffttft it •M*t4orW to ••  tcutalr  taii: t!  it  haa an  oral 12)0  <  or  •  100  af.'kj, an^.iHalat-.an  '.:!0  < or • -10
    •f/cmU« *»tajf. M • 4«nMl U10 < at • »00 a|/t|.   U Maaa '-atnal  0«aa, 1C Maaa U trial Cancantratian.

•/  CScmlcal* «tU k* t»n*t4araa ta  cauaa chronic tasicity tf  tlof cauaa tart out IrrtvarttSlt afiacta ac»ar t^an ctnetr ac
    rtora«uccl«< tfftctt after titaoJa* aifoaurt ta  arai tttta tf laaa (Kat 100 tc/k|/aa», innalatian canctntratiar1.! '.'."
    *l/\tHtj, ItAalatlt* toetaatracvaaa laaa  tn»n 400  aj/eu»te *ttar. tr  4tr»*l •'.•
    offtlca.
I/  A eha«leal ta claaaldad aa haiaratut  tt  nuatu «Ualift  if  aa aeuta USD ia < 1000 u|/^ tr chroatc af'tcti it < '.'.3
    ut/X: tt tarrtatrla.1 •tUltfa  tf  ctttctcr haa ttta ta«a la tha (lalt. tf te\italy totle. or cauttt  taproaucti^t
    to*lcttr/taract|tnlcttr ac oral 4aiat  <  100 aj/t| »o«r »ti|nt; tr art portttttne ia tha aavtrenMnt an* art tat: : it
    lavalt up et 10 tit»a  Ittt tnaa chttt  tiUtettt* akt«t.

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                                     -18-

     potential significance of multiple contaminant exposures within a single
     medium or across media.

     The risks from exposure to contaminated ground water from the City
     Chemical site via potable and non-potable wells are included in Tables
     6-4 and 6-5, respectively.  These tables show that both carcinogenic and
     non-carcinogenic risks from ingestion of the ground water are
     unacceptable.  Risk from non-carcinogenic effects from dermal exposure
     to the ground water is also unacceptable.

     At the present time, individual exposure via the ingestion of contami-
     nated ground water is not occurring.   However, unacceptable risk levels
     for the baseline assessment indicate that ground water treatment is
     necessary to prevent the potential human exposure to unacceptable levels
     of contaminants in the future.

6.4  ENVIRONMENTAL RISK

     As the site is located in an urban area with surrounding industrial and
     commercial land use, it has limited potential for utilization as a ter-
     restrial ecosystem.  The site is partially fenced.  Movement of animals
     onto the site is limited but not completely restricted.

     Crane Strand Wetlands are located to the north of the site; however,
     there is no hydrologic connection between the City Chemical site and the
     wetlands.  Drainage-ditch waters from the City Chemical site flow east
     to an Orange County drainage canal, then south away from the wetlands.
     Concentrations reported in the drainage-ditch waters at the site do not
     exceed any USEPA Ambient Hater-Quality Criteria established to protect
     fresh-water aquatic life.
                 s\
     Based on the above  information concerning human health and environmental
     risk, it is concluded that actual or threatened releases of hazardous
     substances  from this sit*, if not addressed by implementing the response.
     action selected in  this ROD, may present an imminent and substantial
     endangerment to public health, welfare, or the environment.

7.0  DESCRIPTION Cf MiTlTJ'>ftTIVBS

     Five alternatives were considered for remediation of the ground water,
     which contain* unacceptable levels of organic compounds.

7.1  Alternative  1

     Alternative 1 is the no action alternative  retained for baseline  com-
     parison purposes in accordance with  40  cm  300.68  (f)(v).   Alternative 1
     does not incorporate any  remedial actions at  the site.   It would,
     however, include monitoring the ground  water  for up to 30  years.   It
     would allow for continued migration  of  the  contaminant plume in the
     surficial  aquifer.  The baseline  BA  identifies  the potential human
     health  and the environmental  risks associated with Alternative 1.

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                                                          -' Q_
TA3" r  6~-    -i"-3" *'«» ana -
-------
TABLE  6-3
                            «r.C
                                                                           3.5
                  3.3
                                                                           i.:
ics::.-e :.•;

'• . 2-/3 •:-..:.-;•:-•-• ;.;•
£:> '. rerjere ;.-;
«s:-.y. = :-./'. * 15).
  s    Harare  :.-.cex  « OACO't or SPACO (Tabu 15)/r«'9r»r.es ess«.

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                                 -21-

                            Alternativa 1

Alternative 2 consists of implementing the following remedial actions:

     Institutional Controls or Other Land Use Restrictions;
     Ground water Monitoring of Surficial and Ploridan Aquifers;
'    Ground water Recovery via Wells;
     Ground water Treatment by Aeration to Pre-treatment standards;
     Discharge of Treated Effluent to the Iron Bridge Publicly-Owned
     Treatment Works (POTW) or other local POTW;
*    Treatability Studies to Ensure Compliance with POTW Pre-treatment
     Standards;
'    Backup Discharge Plan; and
'    Review of Ground Water Use for Surficial Aquifer Every Five Years.

Alternative 2 was developed for treatment of constituents recovered in
ground water to levels suitable for discharge to a POTW.  The conceptual
design is described in this paragraph.  Specific design criteria will be
developed during the Remedial Design stage.  Recovered ground water
would be piped to an on-site treatment system consisting of an
equalization tank in series with a forced draft air stripping tower for
removal of volatile organic compounds.  Other treatment could be added,
if necessary, to meet POTW pre-treatment standards.  This alternative
includes institutional controls or other land uee restrictions necessary
to prevent adverse effects to the remedy. This may invlove deed
restricitons, easements, and other rights of way.

After testing to verify that pre-treatment standards are met, the
treated effluent would be piped to a clarifier .  Prom there it would be
pumped to the nearest City of Winter Park Sewer System manhole, located
east of the site across Forsyth Road and approximately 250 feet south of
the Sears warehouse.  Other transport mechanisms may be used if
determined feasible during design.  Treated ground water discharged to
the sewer system would ultimately undergo additional biological
treatment at the City of Orlando Iron Bridge Wastewater Treatment
Facility.  Figure 7-1 illustrates a plan view of the conceptual system
layout.  Figure; 7-2 show* a treatment process schematic.

Implementation of the treatment and discharge scenario proposed for
Alternative 2 would require responsible parties to secure the approval
of administrative personnel from the city governments of both Winter
Park and Orlando.  The treated effluent.would have to meet pretreatment
criteria established by these administrative officials as well as comply
with EPA guidelines for discharging of a CIRdA wastewater to a POTW.

Bench-scale treatability studies performed during the PS indicated that
aeration would be effective in reducing the concentration! of all the
target list compounds to levels that satisfy drinking water criteria
except for the highly soluble compounds acetone, KEK, and MXBK.
Existing literature indicates that these constituents are biodegradable
and exhibit little propensity to bioaccumulate.  Thus,  it ie reasonable
to assume that residual concentrations of acetone, MBK, and MZBK not
removed by the on-site air stripper system would be readily oxidized  by

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                        I-ICUKK 7-1
               CONCEPTUAL LAYOUT
                 OF SEWER SYSTEM
             DISCHARGE ALTERNATIVE
  PMVOSCO CMOUND-NMUN
  MtCO*tHf WELLS
      I	1
CITY CHEMICAL
SITE
    OM-MTC
TMATMCNI SfSfCM
                   O -•	VMICN MNK UWCM
                       SVSTLM MANNOLC
                                                         I
\
          SOURCE: FIGURE 3-1. FEASIBILITY STUDY. CITY CHEMICAL SITE

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  FICIIKK 7-2:   PROCKSS SCIIKMATIC FOR I'O'IW 1)1 SCIIAKCK
                   EQUALIZATION TANK
RECOVERY WELL
                                                                                                           DlSCHAnGL

                                                                                                            TO POIW
                                                                                       sguDsjo
                                                                                       DISPOSAL
                                                 SOURCK :
                                                       HI Y 6/MILLLK
                                                i:NCiiNi:i:i
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                                 -24-

the rotating biological contact process employed at the Iron Bridge
Wastewater Treatment Facility.  Additional treatability studies will be
performed to demonstrate compliance with the POTW's pre-treatment
standards.  Nevertheless, a contingency plan will be developed in case
these studies show that the pre-treatment standards cannot be met.

The O&M will include monitoring of system controls which will be
incorporated to ensure the effluent quality meets established
pretreatment criteria prior to discharge to the POTW.   The routine O&M
procedure would require an operator present on-site to monitor
performance of the recovery, aeration, and discharge system components.
Efficient operation of an air stripper also requires periodic cleaning
or replacement of the tower's packing media to avoid clogging from
accumulated biological growth or precipitated matter.   Periodic
monitoring of the ground water would be performed to assure that the
remedy was working.

An emergency backup surface water discharge plan must be developed so
that if, at any point during the remediation, the POTW personnel
determine that they will no longer accept the discharge from the City
Chemical site, extraction and treatment of the ground water can resume
in a timely manner.  An emergency by-pass pipeline is needed for
transmission of the treated effluent to the county maintained drainage
canal east of the Sears Warehouse during periods when reinjection is
precluded by saturated conditions.  The inclusion of the bypass pipeline
would necessitate securing an NPDES permit in addition to the OZC permit
required for discharge to reinjection wells.

Extraction and treatment of the ground water will continue for an
estimate- 14 years in order to restore concentrations in the surficial
aquifer to the cleanup standards listed in Table 7-1.  These standards
are either applicable or relevant and appropriate requirements (ARARs)
or "to-be-considered* health-based levels  (TBCs) which must be achieved
to make the ground water safe for drinking.  The surficial aquifer is
classified by the State of Florida as a Class ZI aquifer, which means
there is potential for it to be utilized for drinking water in the
future.  Therefore, drinking water standards oust be met.

                            Alternative 3

Alternative 3 consists of implementing the following remedial actions:

*    Institutional Controls or Other Land Use Restrictions;
*    Ground water Monitoring of Surficial  and Flcridan Aquifers;
'    Ground water Recovery via Wells;
*    Ground water Treatment by Aeration, Precipitation, Filtration,  and
     Carbon Adsorption;
     Surface Water Discharge of Treated Effluent;
     Treatability Studies to Ensure Compliance  with Surface Water
     Discharge Criteria; and
     Review of Ground Water Use  for Surfieial Aquifer Every Five Years.

-------
                                               _GUIDELrNTS
       Constitue.it
 Acetrr.s
 = = .-.:: er.e
 l, l-dichlcrrethar.e
 1, 1-dichlorcether.e
 t-i, 2-Dichloroethene
 Ethyl Benzene
 Mezhyier.e Chloride
 Methyl Ethyl Ketcr.e
 Methyl Isctutyl  Ketcr.e
 Tetrachlcrcether.e
 Tcluer.e
 1,1,l-Trichlcr=ethane
 Trirhlcrce-he.-.s
 Tctal Fr.thalates
   (as tis-2-ethylhexyl)
Standards
or Criteria
ruo/LT
700
1.0
5
7.0
70
700
5
200
! 350
3.0
2,000
200
3.0
3.0
)

Scur
a
w
c
c
e
e
f
£
a
u
e
•_
•-
£

a
b
Ke-e-ence  Dose Lir.it;  (IRIS, January 1989)
i-!?-C?.£rir:'ary drinkir-S va-er standard; F.A.C.
^ '  •^•&Xw

Novi^!f ,*«*  J?;a d>reCtiCn Of the  USEPA  (^t
                   frOIa °iane SCOtt O
c
e
                                                     ....
                        L for 1'2-dichloroethane.
          r     ,drinking water standard; 40 CTR 141.62
         13* ""as  MaXiinUIn  Cont«»in"t  Level. Goal;  Fed

      °      °f Drinkin5 Water Lifetime Health Advisor/;
             , or a  10-6 concern risk for carcinocer.s.  "

-------
                                -26-

Alternative 3 was developed for treatment of constituents recovered in
ground water to levels suitable for surface-water discharge.  The system
developed is considered to be technically adequate to meet discharge
criteria baaed on existing data.  Volatile organics with the exception
of the ketonea would be removed from the ground water by aeration using
a forced draft air stripper system.  Oxidation, precipitation, and
sedimentation in a conventional gravity settling device would then
reduce the ambient concentrations of iron,  aluminum, and other metals
which may be recovered in the ground water.   Although all the target
list compounds are organics, the inorganic composition of the treated
effluent is pertinent to the feasibility of discharge to surface
waters.  Filtration is required for further removal of metals and
suspended solids which may blind adsorption sites on the activated
carbon.  Carbon adsorption is included as an additional step prior to
surface-water discharge, to remove ketones and provide assurance for
compliance with discharge criteria.  Should treatability studies show
that carbon adsorption is infeasible for meeting surface water discharge
criteria, other treatment methods, such as biological treatment, could
be implemented.

Bioassay studies would be conducted to verify system performance.  The
bioassay studies would include testing of influent samples collected
from the recovery system as well as effluent samples from each component
of the treatment system.

The treated effluent from the process would be discharged to surface
waters, via a NPDES permitted outfall in the county maintained drainage
canal.  This canal is part of the Little Econlockhatchee River Drainage
Basin.  A 6-inch pipeline, approximately 2,250 feet in length, would
transport the treatment plant effluent across Porsyth Road and east to
the drainage canal outfall.  A plan view of the conceptual system layout
is shown in Figure 7-3.

This alternative includes institutional controls or other land us*
restrictions accessary to prevent adverse effects to the remedy. This
may involve deed restrictions, easements, and other rights of way.
ARARs and TBCSj for the ground water as described in Alternative 2 oust
also be achieved under this alternative.  Reaching these levels.will
take an estimated 14 years.  Standards for discharge to surface water as
incorporated in the NPOBS permit must be met as well.  Table 7-2 lists
fresh-water aquatic life criteria for the contaminants of concern at the
City Chemical site.  As in Alternative 2, OftM requirements for
Alternative 3 would include weekly inspection of the performance of
recovery, treatment, and discharge system components and periodic
cleaning or replacement of air stripper packing media.  Additional O&M
required for Alternative 3 would include the collection and
stabilization of sludges generated in the precipitation unit and the
spent-backwash water sedimentation tank.  The supernatant from  the
backwash water sedimentation tank would be recycled through the
treatment system.  The carbon adsorption system would require periodic
replacement and regeneration of the spent granular activated carbon

-------
                        HC1IKK 7-1
                CONCEPTUAL LAYOUT
                OF SURFACE WATER
             DISCHARGE ALTERNATIVES
  PHOPOSCO CAOUMO-MMTCN
  NttOVCNf WiLLS
                                              ^
PNOPOMO OM Slit
tMATMCNT SVBTCM
          SOURCE: FIGURE 3-3. FEASIBILITY STUDY. CITY CHEMICAL SITE

-------
                           TA5LZ  7-2

               Fresh-water Aquatic- Life criteria
      For Constituents Detected at: the City Cheaical  Site
      Constituent
   (as bis-2-ethylhexvl)
Xylenes
                                Standards
                               or Criteria
                                 (ng/L)
                                   0.260
Source
Acetcne
Benzene
1 , 1-dichloroethane
1, 1-dichloroether.e
t-1 , 2-Dichloroethsne
Ithyl Ssnzene
Ksthvlsne Chlcriie

y.str.vl Zthvl Xerer.e
Xsthyl iscbutyl Kerens
Te-rachlcroethene
T c 1 — = n 2
1,1, 1-Trichloroethar.e

Total Fhthalates
88
0.
1.
0.
1.
0.
1.

56.
42.
0.
0.
"o.
4 .
0.

C53
16
303
16
453
i_

4
8
054
175
530
5
0003
a-/
b-/
K
b2/
b
fc2/
b
i /
C-'
c-/
e-/
t-/
1 2/
«J/

   fV
I/
2/
3/
ICr-,  for Dasr.r.la pul^x.  43  hour;  ccncentratic- divided by a
factor  of 10 to provide a safety factor because chronic data
net available  (Slocf et al.,  1983).
Federal  Water  Quality  Criteria;  acute  criteria  have been
divided  by  a factor of 10 to provide a safety factor because
chro.nic  criteria  vas not available (USZPA, 1986) .
LC5nxfcr Leocr.is  r.acrochirus. 48 hours; concentration divided
by a  factor of 10 to provide a safety factor because chronic
data  net available  (Turnbull  et al., 1954).
LC50  for Daphr.i-i g.asr.a. 24 hours; concentration divided by a
factor  of 10 to provide a safety factor because chronic data
not available  (Brincr.an and Kuhn, 1977).
Fedaral  Water  Quality  criteria;  chronic  criteria  (USEPA,
1986) or IRIS.
LC5p   for   Pimeohales  pronelas.   96  hours; - concentration
divided  by  a factor of 10 to provide a safety factor because
chronic  data not  available  (Pickering and Henderson, 1966).
Safety  factor of 100 has been added to  acute  values  at the
direction of the USEPA  (letter dated  November 20, 198S from
Diane Scott  of the USEPA to Robert L. Rhodes).
Value included at the  direction of  the USEPA (see reference
in footnote  1).
Safety  factor  of 10  has  been added  to chronic values at the
direction of the  USEPA (see reference  in  footnote  1).
Acute value  with  safety factor of 100 substituted  for chronic
value  at  the  direction  of  the  USEPA  (see  reference  in
footnote  1).

-------
                                 -29-

(GAC).  At that time spent GAC would be collected and transported to an
off-site regeneration facility.  O&H for Alternative 3 would also
include bioassays to assure that surface water discharge standards
continue to be achieved.
                            Alternative 4

Alternative 4 consists of implementing the following remedial actions:

     Institutional Controls or Other Land Use Restrictions;
     Ground water Monitoring of the Surficial and Floridan Aquifers;
*    Ground water Recovery via Wells;
     Ground water Treatment by Aeration, Biological Oxidation,
     Filtration, and Carbon Adsorption;
     Reinjection of Treated Effluent to Surficial Aquifer;
*    Backup Discharge Plan; and
*    Review of Ground Water Use for Surficial Aquifer Every Five Years.

Alternative 4 involves the reinjection of treated effluent into the
shallow aquifer; thus ground water would be treated for compliance with
remediation goals for potential drinking water supplies.  The treatment
scenario proposed for Alternative 4 includes aeration, biological
oxidation, and filtration followed by carbon adsorption for polishing
prior to reinjection of the treated effluent.

Aeration would be effective in removing all of the target list organics
except for the highly soluble compounds acetone, MBK, and MZBX.
Alternative 4 incorporates the use of biological oxidation for
destruction of the ketones and compliance with remediation goals for
drinking water.  Filtration and carbon adsorption are also included in
this alternative for polishing of the waste stream prior to disposal of
treated effluent by reinjection.  The carbon adsorption unit would also
provide a backup in case of temporary interferences or upsets in the
biological system performance.

The insoluble precipitates formed following aeration would settle and be
removed from the wastewater in the biological clarifier.  Suspended
solids carried over would be removed in the filtration unit prior to
carbon adsorption.  The settled sludge from the biological oxidation
process wools! be channeled through a gravity thickener followed*by a
belt filter press for volume reduction prior to disposal.

Two lines of reinjection wells would be needed to discharge the treated
effluent.  Twelve wells would be located along a north-south  line
downgradient of the contaminant plume and an additional 12 wells would
be located in a north-south line upgradient of the plume.  The final
system configuration will be designed once better definition  of the
impacted ground water plume is conducted.

Under unusually severe weather conditions, discharge  to reinjection
wells may result in the upwelling of impacted ground  water, as it may be
pushed to the surface by treated water being reinjected at depth.  The

-------
                                 -30-

rainjection well system, therefore, would include an emergency provision
for management of treated effluent during severe weather to avoid this
occurrence.  An emergency by-pass pipeline for transmission of the
treated effluent to the county maintained drainage canal east of the
Sears Warehouse or an on-site storage tank is needed during periods when
reinjection is precluded by saturated conditions.  The inclusion of the
bypass pipeline would necessitate securing an NPDES permit in addition
to the UIC permit required for discharge to reinjection wells.  This
alternative includes institutional controls or other land use
restrictions necessary to prevent adverse effects to the remedy. This
may invlove deed restricitons, easements, and other rights of way.

It is anticipated that ARARs and TBCs for the ground water will be
achieved after an estimated 14 years of extraction and treatment.
Treated ground water to be reinjected into the surficial aquifer must
also meet these drinking water standards.

O&M requirements for Alternative 4 include monitoring the performance of
the recovery air stripper, and discharge systems, and media cleaning or
replacement for the air stripper, similar to that described for
Alternative 3.  O&M requirements for a biological treatment system would
include daily inspections and adjustments by an operator.  Zn addition,
waste activated sludge and settled sludge from the spent backwash water
sedimentation tank would be collected and stabilized.  The supernatant
from the spent backwash water tank would be recycled through the
treatment system.  Spent carbon from the carbon adsorption system would
be transported to an off-site regeneration facility and regenerated
replacement carbon would be delivered to the site on a monthly basis.

Alternative S  -  (Alternative 6 in PS)

Alternative 5 consists of implementing the following remedial actions:

     Institutional Controls or Other Land Use Restrictions;
*    Ground water Monitoring of Surficial and Floridan Aquifers;
*    Ground water Recovery via Wells;
*    Ground water Treatment by Aeration, Precipitation, Filtration, and
     Carbon Bdeorption;
     Reinjettton of Treated Effluent;
     Backup Discharge Plan; and
*    Review of Ground Water Use for Surficial Aquifer Every Five Years.

Alternative 5 utilizes carbon adsorption as a primary treatment process,
unlike Alternatives 3 and 4, which incorporate carbon adsorption treat-
ment as a final polishing step following primary treatment by other
processes.  This distinction is significant when identifying carbon
usage rates and annual operational costs associated with  replacing
carbon.  In Alternative S, recovered ground water  is treated by aeration
for removal of volatile organic compounds and pretreated  for  removal  of
iron by precipitation and filtration.  Carbon adsorption  would  then be
used for primary treatment of the remaining organics,  including ketones,
prior to reinjection of the treated effluent  into  the  shallow aquifer as
described  for Alternative 4.

-------
                                      -31-

     Under unusually severe weather conditions, discharge to reinjection
     wells may result in the upwelling of impacted ground water,  as it may be
     pushed to the surface by treated water being reinjected at depth.  The
     reinjection well system, therefore, would include an emergency provision
     for management of treated effluent during severe weather to avoid this
     occurrence.  An emergency by-pass pipeline for transmission of the
     treated effluent to the county maintained drainage canal east of the
     Sears Warehouse or on-site storage tank is needed during periods when
     reinjection is precluded by saturated conditions.  The inclusion of the
     bypass pipeline would necessitate securing an NPDES permit in addition
     to the UIC permit required for discharge to reinjection wells.

     This alternative includes institutional controls or other land use
     restrictions necessary to prevent adverse effects to the remedy. This
     may invlove deed restricitons, easements, and other rights of way.

     As for the other alternatives, 14 years has been estimated for achieving
     drinking water ARARs and TBCs.  These standards must be met in the
     treated groundwater before reinjection in the sufficial aquifer.

     The O&M requirements for Alternative 5 are similar to those required for
     Alternative 3 with respect to the recovery, aeration, precipitation, and
     filtration.  Estimated carbon usage rates indicate that regeneration and
     replacement of spent carbon would be required every 48 hours.
8.0  SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

     The major objective of the Feasibility Study (PS) was to develop,
     screen, and evaluate alternatives for remediating the City Chemical
     Site.  This decision document deals with the ground water, for which
     several remedial technologies were identified.  These technologies were
     screened based on their feasibility given the contaminants present and
     site characteristics.  Those which remained after the initial screening
     were evaluated in detail based on the nine selection criteria required
     by SARA and listed in the HCP, which are listed belowt

     1)   Overall protection of human health and the environment;
     2)   Compliance with applicable or relevant and appropriate requirements
          (ARAM)|
     3)   Long-term effectiveness
     4)   Reduction of toxicity, mobility or volume
     5)   Short-term effectiveness
     6)   Implementability
     7)   Cost
     8)   State acceptance
     9)   Community acceptance

     Cost was used to compare alternatives only when they 'provided similar
     degrees of protection and treatment.  Five alternatives remained after
     the detailed evaluation and were listed in the previous section.  A
     summary of the relative performance of the alternatives with respect to
     each of the nine criteria is provided in this section.

-------
                                     -32-

8.1  DPQTECTIVENBSS OP HUMAN HgiTTH AND THE ENVIRONMENT

     All alternatives presented in this document except for no action would
     be protective of human health and the environment.  The no action alter-
     native is not protective because it would allow further migration of the
     contaminants, leading to possible ingestion of contaminated water if
     drinking-water wells were to be drilled into the surficial aquifer or a
     connection between the surficial and Floridan aquifers were to form in
     the vicinity of the plume.  The other alternatives would be protective
     because ground water with unacceptable levels of contaminants would be
     removed from the aquifer.  The water would then be treated to make it
     safe for discharge or reinjection.

8.2  COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
      (ARABS!

     All alternatives except for no action would comply with applicable or
     relevant and appropriate requirements (ARARs).  The no action alter-
     native would allow contaminants to remain in the ground water at concen-
     trations above drinking water standards,  thus violating the Safe
     Drinking Hater Act (SDWA), which is an ARAR for this site.  The other
     alternatives would restore the levels of contaminants in the aquifer to
     drinking water standards, and comply with the SDWA.  Water discharged to
     the canal in Alternative 3 would meet NPDES permit limits and the
     f-esh-water quality criteria listed in Table 7-2, which are requirements
     o: the Clean Water Act (CWA).  In Alternative* 4 and 5, the extracted
     ground water would be treated to meet drinking water standards prior to
     reinjection into the surficial aquifer.

     The primary ARARs for the ground water are maximum contaminant levels
     (MCLs) under the Safe Drinking Water Act (SDWA).  These are applicable
     where water will be provided directly to 25 or acre people or will be
     supplied to IS or more service connections.  MCLe are relevant and appro*
     priate where the surface water or ground water is being used or may
     potentially be used for drinking water.  Although the surficial aquifer
     at the City Chenical site is not currently being used for drinking
     water, it haa the potential to be used in the future.

     Other ARARa that must be complied with are surface water discharge re-
     quirements of the National Pollutant Discharge Elimination System
     (NPDES) covered under the clean Water Act  (CWA).  Air emissions
     specifications for the air stripper established by the clean Air Act
     must also be met.

8.3  REDUCTION OF TOXICITY. MOBILITY. OR VOLOME

     All alternatives except  for no action reduce the  toxicity, mobility  and
     volume of the ground water contamination by decreasing the size  of the
     plume and removing it from the surficial aquifer.  The no action
     alternative would allow  the plume to continue to  spread.

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                                      -33-

8.4  LONG-TERM EFFECTIVENESS

     All alternatives except for no action would have long-term effectiveness
     and permanence.  Once the contaminant plume hai been captured,  the risk
     associated with drinking the ground water would be in the acceptable
     risk range and would remain acceptable.

8.5  SHORT-TERM EFFECTIVENESS

     An estimated fourteen (14) yean will be necessary to achieve the
     remedial action goals for all alternatives except no action.   During
     that time the community would be protected from short-term risk by
     institutional controls which would prevent drinking water and drainage
     wells from being drilled into the plume.  Any short-term risk to workers
     involved in construction of the remedy would be mitigated through
     implementation of a health and safety plan.  The no action alternative
     would not be effective in the short or long term.

8.6  IMPLEMENTABILITY

     The implementability of an alternative is based on technical
     feasibility, administrative feasibility and the availability of services
     and materials.  Services and materials are available for all
     alternatives.  Reinjection of treated water into the surficial aquifer
     as included in Alternatives 4 and 5 is not technically feasible because
     of the shallow ground water table.  Reinjection will cause mounding of
     the ground water table which could result in ponding of water on the
     ground surface during wet weather conditions.  However, the treatment
     methods in these alternatives are feasible.  Alternative 2 may not be
     administratively feasible if the POTH will not accept discharge from the
     site.

8.7  COST

     A present worth cost of $103,700 for ground water monitoring would be
     associated with Alternative 1, the No Action alternative).  Alternative 2
     has an estimated present worth cost of $4,575,632 including Operations
     and MainteaeJK* (OftM) coets.  The estimated present worth of Alternative
     3 is $4,262,101; Alternative 4 is $6,472,000; and Alternative 5_ie
     $54,901,000.  Alternatives 2 and 3 are based on a ten  (15) year present
     worth coat at a 5% interest rate.  The other alternatives are based on
     10 year present worth cost.  Alternative 5 is not cost-effective because
     it does not provide an additional decree of protectiveness necessary to
     justify the increased cost of remediation.

8.8  STATE ACCEPTANCE

     The State of Florida, as represented by the Florida Department of
     Environmental Regulation, is in  favor of extraction of the ground water
     and treatment via aeration.  The State will concur with discharge of the
     treated water to the City of Orlando Iron  Bridge  POTW  or other local
     POTW for further treatment if the POTW  is  willing to accept  the waste.

-------
                                     -34-

     In the event the city does not accept the waste,  FDER concur* with EPA's
     contingency alternative of ground water extraction and treatment by
     aeration,  precipitation, filtration,  and carbon adsorption followed by
     surface water discharge.

8.9  COMMUNITY ACCEPTANCE

     Based on comments made by citizens at the public meeting held on
     February 6, 1990, and those received  during the public comment period,
     the community agrees that an extraction and treatment system will
     effectively protect human health and  the environment.  Citizens at the
     public meeting indicated opposition to surface water discharge and a
     preference for discharge to the POTW.

9.0  THE SELECTED REMEDY

     Based on available data and analysis  to date,  the OS EPA selects Alter-
     native 2,  which involves ground water extraction and treatment via
     aeration with discharge to the City of Orlando Iron Bridge POTW or other
     local POTW.  However, in the event that a POTW has not agreed to accept
     the discharge from the City Chemical  Site within a reasonable period of
     time  after the date of signature of  the Record of Decision, EPA has
     selected Alternative 3 as a contingency alternative.  Alternative 3
     consists of ground water extraction and treatment by aeration,
     filtration, precipitation, and carbon adsorption followed by discharge
     to a county-maintained drainage canal.  Both the selected and
     contingency alternatives include institutional controls or other land
     use restrictions necessary to prevent adverse effects to the remedy.
     This may invlove deed restricitons, easements, and other rights of way.

     Alternative 2 was developed for treatment of constituents recovered in
     ground water to levels suitable for discharge to a POTW.  The proposed
     ground water recovery system will include installation of 12 recovery
     wells below grade in a north-south alignment east of the City Chemical
     Site.  The anticipated flow rate from the entire system is estimated to
     be 100 gpm.  Tte exact location of each well will be determined after
     the areal aaf vertical extent of the  plume is defined during a plume
     delineation ctody.  This study will require samples to be collected and
     analyzed fr«B existing monitoring wells.  Based on these data, the
     design of the recovery system will be refined.

     Recovered ground water will be piped to an on-site treatment system
     consisting of an equalization tank in series with a  forced draft air
     stripping tower for removal of volatile organic compounds.  The air
     stripper effluent would be tested to verify that pre-treatment standards
     are met and piped to a clarifier.

     The effluent from the treatment system would be pumped to the nearest
     City of Winter Park sewer system manhole, which is  located  approximately
     350 feet east of Forsyth Road and approximately 250  feet  south of  the
     Sears Warehouse.  The transmission main would be approximately  1,350
     feet in length and would require a 4-inch diameter  pipe to  handle  the
     100 gpm flow.  At the proposed manhole connection,  the treated effluent

-------
                                 -35-

would be discharged to the existing City of Winter Park 8-inch
vitrified-clay gravity s«wer line which terminates approximately 2,300
feet downstream at the Showalt Lift Station.  The discharge would then
be transported, via the sanitary sewer, to the City of Orlando Iron
Bridge Wastewater Treatment Facility where it would undergo biological
treatment.

Implementation of the treatment and discharge scenario proposed for
Alternative 2 would require the responsible parties to secure the
approval of administrative personnel from the city governments of both
Winter Park and Orlando.  The treated effluent would have to meet
pretreatment criteria established by these administrative officials as
well as comply with EPA guidelines for discharging of a CERCLA
wastewater to a POTW.

Easements and construction rights-of-way would be required for instal-
lation of the recovery wells and piping and the discharge piping to the
sewer interconnection.  These easements and rights-of-way are essential
to the implementation of any remedial action because the plume has mi-
grated past property boundaries.

A security fence would be installed around the perimeter of the treat-
ment system.  Installation of the fence would restrict unauthorized
access to the treatment area which ultimately minimizes the potential
for direct human contact with the impacted ground water that is
recovered.
 %
The O&M will include monitoring of system controls which will be
incorporated to ensure the effluent quality meets established
pretreatment criteria prior to discharge to the POTW.  The routine OSM
procedure would require an operator present on-site to monitor
performance of the recovery, aeration, and discharge system components.
Efficient operation of an air stripper also requires periodic cleaning
or replacement of the tower's packing media to avoid clogging from
accumulated biological growth or precipitated matter.  Periodic
monitoring of the ground water would be performed to assure that the
remedy was working.  Detailed cost analysis for Alternative 2 is
contained ia Table 9-1.

Alternative) J, the contingency alternative, is proposed in the event
that the PORT is unable to accept the effluent from City Chemical.  The
primary differences between the preferred Remedial Alternative 2 and
this contingency Remedial Alternative 3 are twofold.  First, Alternative
2 involves discharge to the POTW whereas Alternative 3 discharge! to
surface water.  Second, additional treatment unit* have been included  in
Alternative 3 to meet surface-water discharge criteria.  In both
alternatives, volatile organics with the exception of the ketonee would
be removed from the ground water by aeration using a forced draft air
stripper system.  Consequently, further treatment of the ketones is
required.  In Alternative 2, this additional treatment is the POTW's
rotating biological contact system.  Alternative 3 utilizes carbon
adsorption to reduce the ketone concentrations to levels acceptable  for
surface water discharge.  In addition to carbon adsorption, oxidation,

-------
        G_

    NC.: 2 ., e
    *GCOVEBv. PBETREAT i DISCHARGE TO PGTW
      EMERGENCY SYSTEM iN-PLACE
•ttm* CTTY CHEJuiCAUlMOcSTRjES
loca-on: WINTER PW^. PLOPJDA
 a Ootntionf ij YRS
              CAPITAL COSTS
ALT. NO. 2 WITH EMERGENCY


A
B






c



fTEM DESCRIPTION
PLUME DSJNEATION
GROUND WATER RECOVERY
R*c»w> W*u (*-ineri)
Puwcs. *Vn9. v»v«a. Me.
CcrttroB/B«Crxji
^—^_-_
FnQcnQ
Pivcnwa RwiacMTtsnt
PiMCroiBng
GROUND WATER TREATMENT
Efflum Studies
Avauen

UNITS
»

M
M
It
H
It
tt

IS
IS

QUANTITY
1

12
12
1
1.400
1JOO
1

1
1
uwrrpwce
DOLLARS
(•9 000

•300
$3.200
$27.000
$1*
•11
•15.000.00

•30.000
$35.000
TOTAL COST
DOLLARS
128 OOC i
;
$7|. 300
$36.400
$27.000 I
$1».60C
$14.300
$15.000

$30.000 1
$36.000
Efflum Studies
Avauen
D. EFRUENT DISCHARGE SYSTEM
CUnftsr
•wro
IS
IS

*
IS
1
1

1
1
•30.000
$35.000

•.000
ri.ooo
$30.000 1
$35.000

•.000
$1.000
*^f^ It 1JBO «i« $18.900
C«waWS«ctrK4l
P*«Crasw>g
P^^RBVK •tflO PjrtOHQ CTQilvnQ
S*w Cennsaion imoaci FMS
PCTTW AuBMnuiien
E. EASEMEKTS AND CONSTRUCTION ACC
F. CONSTRUCTION MGUT SERVICES
G. TEBMNATiON Of REMEDIAL SERVICES
Fm* rttpeft. EA. Cta«jf» PUn
Piugjpv^Q and AfianOonsffisnt
— RseeMwy w«is
Muamujwsm
RMTMMM « Eau^PWmg
CoEunlMMgsffMnt
ttButSJGEMCY TREATMENT SYSTEM
Prseonalar
FiRraon


L SUBMO WATER DISCHARGE SYSTEM
Hggj
BJBM(|
•tjyJBiJ
OB*MMBKBieal
•^•CresMig
MPDES A WVTDS PvnMt
PiuWMm 4 Pvung CresMflQ
J. LAB AMALYSS Of SLUDGE
SUBTOTAL - CAPITAL COST
IS
IS
IS
IS
IS
IS
IS
ft

M
M
IS
•

IS
IS

IS

IS
« r
IS
IS
IS
IS
IS
IS

1
1
1
1
1
1
\
1

12
1
1
t

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1

1

1
BO
1
1
1
1
1
1

•2.000
rs.ooo
•12.000
$3.000
rs.ooo
BM.OOO
•$0.000
00.000

•BOO
nooo
•72.300
e* xe

•42.000
•100.000
BH^ft MV\
riooo

rjoo
•14 .'
•.000
•2.000
rsjoo
B&OOO
B&OOO
BUM


Sutxott

TOTAL CAPTTAL COST
PRESENT WORTH OftM COST









• $2.000
•15.000
$12.000
$3.000
$15.000
•64.000
•80.000
$20.000

•10JOO
$12,000
$72.000
$75.000

•42.000
$100.000
•141.000
$15.000

•1.000
•31.500
B.OOO
•2.000
$15.000
$30.000
•25.000
•.000
$1.123300
•224.700
I1JOJOO
$1«J2S
«*v*
•3.0M.907


-------
7,=-. N,.Tcer: 9- 1 OPERATION & MAINTENANCE COSTS
x;e^a: ve Nc .: 2 w/ Emergency Discnarge System ALT. NO. 2 EMERGENCY
A,:er.-;a:.ve: RECOVERY. PRETREAT i DISCHARGE TO POTW
WTTH EMERGENCY SYSTEM IN-PLACE
Sre Nane. CITY CHEMICAL/INDUSTRIES
See Location: WINTER PARK. FLORIDA
T«-T ~t Ooerai.crs: 15 YRS
ITEM DESCRIPTION UNITS
GSGUND WATER MONITORING
Sarrrimg year
Sarnsiing year
RECOVERY SYSTEM OPERATION
Electrical Power year
Operator Operation year
Maintenance year
Sewer Usage Fee year
System Management year
SUBTOTAL
HEALTH AND SAFETY (10%)
CONTINGENCY (15%)
TTTAL
1 W 1 ^t N

OTY UNfT COST

1 $24.000
1 $24.000

1 $8.000
i $8.000
1 $16.000
1 $158.000
1 $20.000
$234.000
1 $23.400
1 $35.100



TOTAL ANNUAL
OST, DOLLARS

$24.000
$24,000

$8.000
$8.000
$16.000
$158.000
$20.000
$234,000
$23.400
$35.100

S292400

OPERATION
TIME, YEARS

15
1

15
15
15
15
15

15
15



PRESENT
WORTH

$249.1 : 2
$2Z3£7

$63.037
$83.^37
$166.075
$1.639.966
$207.533
$2.451.697
$242384
$364.226

$3.0S&907
F-eoared By Roy F. Wtston. Inc.
tor U.S. EPA Contract No. 6fl-W9-0057
Document Control No. 4400-01-AADO

-------
                                -38-

precipitation, and sedimentation in a conventional gravity settling
device would be utilized to reduce the ambient concentrations of iron,
aluminum, and other metals which may be recovered in the ground water.
Although all the target list compounds are organics, the inorganic
composition of the treated effluent is pertinent to the feasibility of
discharge to surface waters.  Filtration is required for further removal
of metals and suspended solids which may blind adsorption sites on the
activated carbon.  Should treatability studies show that carbon
adsorption is infeasible for meeting surface water discharge criteria,
other treatment methods, such as biological treatment,  could be
implemented.

Bioassay studies would be conducted to verify system performance and
compliance with surface water discharge criteria.  The bioassay studies
would include testing of influent samples collected from the recovery
system as well as effluent samples from each component of the treatment
system.

The effluent from the treatment system will be transported via a gravity
pipeline approximately 2250 feet to the east and discharged to the
County maintained drainage canal.   A minimum 6 inch diameter pipe is
proposed to adequately handle the 100 gpm flow rate.  The drainage canal
in the vicinity of the discharge location is about IS feet deep and IS
to 20 feet wide.  The canal is a part of the Little Econlockhatchee
Drainage Basin and, based on visual inspection, is believed to be more
than adequate to handle the 0.2 cubic feet per second discharge flow
rate from the City Chemical Site.   A NPDES discharge permit will be
required which will include the monitoring program to ensure compliance
with surface-water discharge criteria.

As in Alternative 2, O6M requirements for Alternative 3 would include
inspection of the performance of recovery, treatment, and discharge
system components and periodic cleaning or replacement of air stripper
packing media.  Additional O&M required for Alternative 3 would include
the collection and stabilisation of sludges generated in the
precipitation unit and the spent-backwash water sedimentation tank.  The
supernatant froa the backwash water sedimentation tank would be recycled
through the) treatment system.  The carbon absorption system would re-
quire periodic replacement and regeneration of the  spent GAC.  At that
time spent OAC would be collected and transported to an off-site
regeneration facility.  A detailed cost breakdown for Alternative 3 is
contained in Table 9-2.

Under both the selected and contingency alternatives, ground water moni-
toring of the surficial and Floridan aquifers would be performed to
assess the efficiency of organic constituent recovery utilizing the
system proposed.  Approximately 12 samples would  be collected  and
analyzed  for target list compounds quarterly  for  the  first  year and as  a
minimum  semiannually thereafter.  Analytical  results would  be  used to
track the progress in achievement of remediation goals.

Both alternatives will  require an estimated  14  years  to  achieve the
ground water  cleanup goals  listed  in Table  7-1,  based  on ground water

-------
 '«:•
                9-2
         WCOVERY. ONSTTE TREATMENT.

            DISCHARGE TO SURFACE WATER 3CCY
$.!• Namr. CTTY CHEMICAL/INDUSTRIES
S'l« Lxzion: WINTER PAR*. FLORIDA
  ^_:i_0o«niiors: 10 YRS . 5
                                                                  CAPITAL COSTS
                                                 ALT. NO. 3 WITH ADDITIONAL
                                                        5 YRS, AERATION ON LY
           ITEM DESCRIPTION

   A. PLUME DELINEATION

  JB. GSCUNC WATER RECOVERY
    R«C9v«ry W«ilj (4-incfl)
     '•J.TCS. Pvomg. Varv«. «e.
   Pip* Crossng

  C. GROUND WATER TREATUENT
   Aeration
 Fllrraiion
 Careen Absorption
 S!L<;« D«wat*nng

D. SURFACE WATER OSCHAflGE SYSTEM
 Pump
  Contrco/E«etncal
  Pi&i Crossing
  NPOES i IWTDS Ptrmrts
  Pavtmtnt and Parking Crossing

S. EASEMENTS AND CONSTRUCTION ACC

F LAB ANALYSIS Of SLUDGE

G. CONSTRUCTION MGMT SERVICES

 L TERMMATX9N Of REMEDIAL SERVICES
 Final Rcpvt IK, Ctoiurt PUn
  C;o*ur§ Managtmvn

SUBTOTAL . CAPTTAL COST
UNfTS

  IS


 *a
 •a-
 is
 ii
 it
 is
                                         is
                                         Is
                                         is
                                         is
                                         IS
                                        IS
                                        It
                                        is
                                        IS
                                        IS
                                        is
                                        is

                                        is

                                        is

                                        IS
                                     M
                                     is
                                     is
                                     IS
                                               OUANTTTY
                                                     12
                                                     12
                                                      1
                                                   1.400
                                                   1.300
                                                      1
                                                      1
                                                  2.250
                                                      1
                                                      1
                                                      1
                                                      1
                                                      1

                                                      1

                                                     1

                                                     1
                                                      12
                                                      1
                                                      1
                                                      1
&igiRMfing>dminisira(iv« i H«aitn and Saitty (20% ot Caoitai Caa)

SuOtotai

Sammgancy f 15H el Caoitai Coal)

TOTAL CAPTTAL COST

PRESENT WORTH OU4 COST

TOTAL PRESENT WORTH COST
                                                               UNIT PRICE
                                                                DOLLARS

                                                                  $28.000
                                                                   M.500
                                                                   10.200
                                                                  J27.000
                                                                     $14
                                                                     $11
                                                                  S15.00C
                                                               S75.000
                                                               S3S.OOO
                                                               S42.000
                                                               1100.000
                                                               $14«.000
                                                               115.000
                                                                 SI .000
                                                                    $14
                                                                 ts.ooo
                                                                 S2.000
                                                                S1S.OOO
                                                                130.000
                                                                S25.000

                                                                SS3.000

                                                                 tt.000

                                                                $82.000


                                                                •20.000

                                                                  $900
                                                                112,000
                                                                $61.000
                                                                $55.000
                                                                            TC7AL CCST
                                                                               DOLLARS

                                                                                 $28.000
                                                                                 $73.000
                                                                                 $38.400
                                                                                 $27.000
                                                                                 $19.600
                                                                                 $14.300
                                                                                 $15.000
                                                                                 $75.000
                                                                                 $35.000
                                                                                 $42.000
                                                                                $100.000
                                                                                $146.000
                                                                                 $15.000
                                           $1.000
                                          $31.500
                                           $5.000
                                           $2.000
                                          rs.ooo
                                          $30.000
                                          $25.000

                                          $63.000

                                          $8.000

                                          $82.000


                                          $20.000

                                          $10.800
                                          $12,000
                                          $41.000
                                         $55.000

-------
OPERATION
Taeie Numoer g_2
Afternative No.: 3
& MAINTENANCE COSTS
ADDITIONAL 5 YRS
AERATION ONLY
Arternative: RECOVERY, ONSTE TREATMENT. DISCHARGE TO SURFACE WATER 800Y
Srte Name: CITY CHEMICAL/INDUSTRIES
Srte Location: WINTER PARK. FLORIDA
Term of Operations: 5 Yrs

fTEM DESCRIPTION UNITS
GROUND WATER MONITORING
Sampling year
SYSTEM OPERATION
Gectricai Power year
Operator Operation year
Maintenance year
Siuage Diseosai year
Caroon Replacement year
System Management year
SUBTOTAL
HEALTH AND SAFETY (10%)
CONTINGENCY (15%)
SUBTOTAL
PRESENT VALUE AT 10 YRS 
-------
                                     -41-

10.0 STATUTORY DETERMINATIONS

     The US EPA has determined that both the (elected and contingency
     remedies will satisfy the following statutory requirement* of section
     111 of CERCtA:  protection of human health and the environment,
     attaining ARARs, cost-effectiveness, and utilization of permanent so-
     lutions and alternative treatment  technologies to the maximum extent
     practicable.

10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

     The selected and contingency remedies adequately protect human health by
     reducing the riak of consumption of contaminated ground water.  This
     will be accomplished through the capture of the ground water contaminant
     plume.  Environmental risk will be reduced by preventing the use of
     contaminated water for irrigation.  No unacceptable short-term risks
     will result from the implementation of these remedies.

10.2 ATTAINMENT OF APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

     These remedies assure that drinking water supplied to current well users
     will meet available MCLs under the Safe Drinking Water Act (SDWA).  For
     those chemicals which do not have assigned MCLs, to-be-considered
     health-based values will be attained.  Discharge from the ground water
     treatment system will meet either the POTW's pretreatment standards or
     NPDES permit discharge limits under the Clean Water Act (CWA).  The CWA
     is an applicable requirement, while the SDWA (MCLs) is relevant and
     appropriate.

10.3 COST-EPPgCTIVgNBSS

     Alternative 2, the selected alternative, is the most cost-effective
     remedy analyzed.  The total present worth cost is $4,575,632.
     Alternative 3, the contingency alternative, would provide a comparable
     level of protection, and has a lower present worth cost of $4,262,101.

     The OS SPA hM determined that the costs of the selected and contingency
     alternative* ore proportionate to the overall effectiveness and-both are
     a reasonable) value for the money.

10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT  (OR
     RESOURCE RECOVERY) TECHNOLOGIES TO THE MAXIMUM B?
     Both the selected and contingency alternatives utilise permanent solu-
     tions and treatment technologies to the maximum extent practicable.
     Both provide short-term and long-term effectiveness and would reduce the
     toxicity, mobility, and volume through extraction and treatment of the
     ground water.  Both would require an estimated 10 years to achieve clean-
     up goals.  The selected alternative, Alternative 2, is the most
     cost-effective remedy but may not be implementable if the City of
     Orlando Iron Bridge POTW or other local POTW is unable to accept

-------
                                     -42-

     discharge from the City Chemical Site within  a  reasonable period of time
     after the signature date for this ROD.   Alternative 3  coats about SO. 3
     million more and would become the selected remedy for  the site if the
     above contingency is not met.

10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT

     The statutory preference for treatment will be  met because the principal
     threat from the City Chemical Site is ingestion of or  dermal contact
     with contaminated ground water.   Both the selected and contingency
     remedies will reduce this risk to public health through capture of the
     ground water plume.

11.0 DOCUMENTATION OF SIGNIFICANT CHANGES

     Two significant changes from the proposed plan  are incorporated in this
     decision document.  The first is the possible substitution of biological
     treatment for carbon adsorption in Alternative  3.  The State presented
     new information which indicated that biological treatment may be more
     cost-effective for an equivalent degree of protectiveness.  Additional
     public comment is not necessary because incorporation of this technology
     in Alternative 3 is considered a logical outgrowth of the information on
     which the public already had the opportunity to comment.

     V.e second significant change is the length of  remediation and
     susequently the cost for the preferred and contingency remedies.  It was
     discovered that the period of treatment for one of the contaminants is
     longer than the other* and will require an extended period of
     treatment.  Public comment is not necessary because the additional time
     period required for this contaminant was documented in the Endangerment
     Assessment, which is an appendix to the Feasibility Study Report and was
     available for public review during the public comment period.
     Therefore, this change could have been reasonably anticipated by the
     public.

-------
       APPENDIX A

  Remedial Investigation
Sampling Data and Locations

-------
                                 TAIUE A-]
pi^mry <


Oonstituent
Acetone
Benzene
Chloroform
1, 1-Dichloroet hane
1 , 2-Dichloroethane
T-l , 2-Diohloroethene
1 , l-Diohloroethene
Ethyl Benzene
Methylene Chloride
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Fnenol
TatraohloLt-t. . >«sne
IhalliiM
Toluene
Total Rithalate Esters
(as Bis-2-ethylhexyl)
1,1, 1-Tr ichloroethane
Trichloroethene
Xylenes, Total
ChraftiuM, Total
Gdppar, Total
Lead, Total
Zinc, Total
1 |
nr imnc 1 1 11 i


Number of
Detections
12
6
1
13
0
14
14
8
13
10
5
4
11
0
13
19

11
15
12
3
3
1
3

imnt-Miirer :wv


vile Analyses

Range of

Inntl irn of
Mwtoer of Ctanoentrations -«t
Analyses
33
33
33
33
33
33
33
33
33
33
33
33
33
33
33
33

33
33
33
33
33
33
33

1. Data conpiled from ESE Phase IIB Report, Appendix
2. location of highest
concentration
is designated
)
262,000
74
39
2,000
	
7,200
18,000
0.378
126,000
10.800
60,OOO
0.060
1,100
	
26,700
0.008

10,000
150,000
1,200
3-18
2-8
46
4-21

D.
by the monitor
OniLx* iLration2
81
BI
121
HI
	
131
8D
81
121
81
81
121
8D
	
81
18D

15S
81)
81
24S
24S
241
24S


well number ant
the following depth range notation:
S:  10 ft - 20 ft
I:  25 ft - 35 ft
0:  50 ft - 60 ft

-------
                             «s   CITY '  * 5SI°
                               CHEMICAL
                                  SITE
                                    I7SIO
                                 •    I
                                 ItSIO H
                                      x
                                      9
SSIO
 s
 I
 0
EXPLANATION

•BUN.DING

MONITOR WELL AND NUMBER
SI (ALLOW             ,
INTERMEDIATE

DEEP
                                                     101
 I K.liKi: A- I :   I'li.isc  fill Croiiiul Wat IT
                          Local inns
                                                SlHIKCK:
                                               (ii i
-------
                              of Iliaae TT B Soil  Sample Anal vacs
Constituent
1,2 Dichlorobenzene
T-l , 2-Dichloroethene
Di-N-Butyl Fhthalate
Di-N-Octyl Rithalate
Ethyl Benzene
Mtai»»'M •»»!»•»«» Etot-ml
Hathylene Chloride
Naphthalene
Tbl_r&dilOi.vJtiUitaHi
•toluene
Bifl-2-«thylhexyl Fhthalate
1,1, l-Trichloroethane
Trichloroethene
xylene
Mater of Maber of
Detections Analyses
2
1
7
2
2
8
1
1
a
i
9
3
2
2
11
11
11
11
11
11
11
11
11
11
11
11
11
11
Range of Location of
Ctanoentrations nicest
(pp») Oonoentration2
0.09-0.30
5.00
0.3O-2.0O
0.07-0.30
3.90-12.00
0.061-9.73
O.21
11.80
1.61-6.91
281.00
0.35-5.90
1.45-18.70
20.80-22.90
7.00-40.00
IS
IS
1OS
7S
6S
6S
4S
6S
IS
6S
6S
3S
IS
63
1.    Data onpiled frcn ESE Phase IID Report.

2.    Dooation of hi^test concentration is designated by the sanpling point r»nrt)er ami
      the depth range.  "S" indicates the sanple was taken from a depth of o-b feet.

-------
| CATO STEEL PLANT |


CITY CIUMICAI

AWOI'LHIY UOUNOAMY
M

1
/•
II
•^

•
CHEMCAL
tRTY BOUNDARY— ».















9
•-



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8

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*

4
6 •



C4



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, •


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ENTRANCE ROAD

WOODED AREA
EXPLANATION




n
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i
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.

















              APPROXIMATE 60IL SAMPLING LOCATION



          -«- CHAIN LINK FENCE
                                                    SOINICI I M
K A-:»:   PIIASI-: I 111  SOU. SAMI'I.INC  MICA

-------
                                            TABLE A-3

                                                   te«utts for 6rg
                                      CMCEITMTtQd (Ml) OETECTEB II SELECTED HOOJlTOt WELLS'
COISTITUE1T
t. *»r3et Sraan's Camooyn*.
Aeetsne
Icnztnt
2-lu:snone (*eo
Chloroform
1 , 1 -Oiehtoroethane
1 , 2-0 iehioroethme
' , 1 -Otehlarsecrtene
Ethyl beniene
Mthvlene chloride
4 -Methyl -2-pentanone
(M1|K)
Phenol
Tttrachloroethene
Talutnt
1.1. 1-Triehloroetftene
Triehloroethene
Total lyltntt
I '. . Stt ee?»d Meta! s
A t u« i nun , Total
Aluminum, Dissolved
larign. Total
larium. Dissolved
Chromium, Total
Chromium, Dissolved
t-:n. Total
Iran. Dissolved
Lead, Total
Lead, Dissolved
Manganese, Total
Manganese, Dissolved
Seleniuai, Total
Selenium, Dissolved
Silver, Total
Silver, OUoolved
ThoUlMB, Tot* I
Thai Ilia, tUoolved
•W-SI

UJ.OOO
10 L
20,000
IOL
SOO
IOL
1.900
IOL
87,000

78,000
68
IOL
9,000
IOL
27,000
IOL

&.800
4,300
IOL
IOL
IOL
IOL
2,600
2,400
2
IOL
IOL
IOL
IOL
IOL
101
IOL
5
5
Dw-ao

9.600
IOL
4,800
IOL
IOL
IOL
4,700
IOL
6,100

IDL
5
IOL
900
IOL
3,800
IOL

4,400
700
IOL
IOL
IOL
IOL
1,200
1,200
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
1
IOL
W-12I

146,000
IOL
IOL
IOL
IOL
IOL
6,000
•OL
165,000

IOL
C3
IDL
6,000
IOL
15,000
SOO

8.400
8,000
100
100
IOL
IOL
3,200
3,100
2
IOL
IOL
IOL
IOL
•OL
IOL
•OL
4
4
HV-120

IOL
IOL
IOL
IOL
IDL
IOL
240
IOL
300

IOL
IOL
IOL
40
IOL
IOL
IOL

IOL
IOL
IOL
IOL
20
IOL
200
120
IOL
IOL
10
10
IOL
IOL
•OL
IOL
7
*
NV-131

ics,:c3
IOL
a,:c:
IOL
801
I3L
t , ;oo
aoi
4,300

11 ,900
6/009 6
IOL
130
IOL
1 .700
IOL

800
800
IOL
IOL
10
IOL
1.600
1,500
4
IOL
IOL
IOL
IDL
IOL .
IOL
IOL
4
2
•W-130

' i •
»:•„•"
• ;;
a:.
3:.
•*:
30
2.":
set
JT;

IOL
1C:
ICL
170
IOL
ICO
23

3X
831
9:u
S:L
SOL
IOL
160
160
I
SOL
23
20
IOL
SOL
IOL
8CL
2
IOL
NQTfS

(1) All dot*  •ufBontatlort ground-vater saaples xere  analyzed for phenol  and soleeted netais  on
    March  U,  1«U.  ond for target  Hit compounds on March IB,  19U.

(2) The aonftor  veils  seeded  for  data  augw> • - -1 on analysts  *«'e those  situated nearest  the
    eenterline of tho expected plM Migration pa:    Constituent concentrations detected in sanoitt
    free) this  group  of awn it or Hells, thorofore,   «ro believed  to 60 representative of  the  worst
    case concentrations in tho contaminant pluM emanating from tho City eheancal site.

(3) The designation IOL  Indicates  thot tho  constituent  concentration In tho  saaple  Has  below the
    detection  limit  associated nith tho laboratory analysis mothod used.

-------
                            «s  CITY '  **sio
                              CHEMICAL
                                SITE
        BUHWNG
.10   •  MONITOR WELL AND NUMBER
S     •  SHALLOW
I     •  INIlMMt.UIAIL          '
>     -  DEEP
:ilKr. A-l:   LOCATION OK MON1TOKINC WKI.I.S
             SANI'I.KI) I <>K SI IK  DATA
             AIK.MKNTATION
  SOIIKCK:
 (,l KA(,III Y .VMM I I It
I  N(,INI I KV INt

-------
                                             TABLE A-4
CMCEMTIATIOM (PPI) DETECTED IN OIAIIA6E
CONSTITUENT
! . *a.*3et Orainic Cxwovindi
Aettent
Banztnt
2-lut»non« (MEK)
CMorsfora
1 , 1 -Oi thloroeth»n«
1,2-0ichlorotthan«
1.1-0 iehlorotth«nt
Ctnyl Btnunt
Mtthyltn* chloride
4-nttnyi-2-ptntanen« (Milt
Phtnol
TttracMoroath***
Tolutna
1,1,1 - Tri eh tore* than*
Trichlore«thtn«
Total xylants
OETECTIM
LIMIT

10
1
100
s
s
3
S
1
5
) 50
5
3
1
5
1
S
SAMPLE A

§OL<2)
SOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
SAMPLE 1

IOL
IOL
ICL
IOL
SOL
IOL
ICL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
DITCH SAMPLE!
SAMPLE C

9 .
a .
a .
3 '.
S .
a .
IOL
IOL
IOL
ICL
IOL
IOL
IOL
IOL
9CL
9:.
NOTES

(1>    Or«in«gt ditch  SMplt» M«rt  truly ltd for phtnel »nd tirgtt list compound* on March IS, 198S.

(2)    Tht dtsignition IOL  indie»tt»  that  tht constituent cenetntrttion  in tht f*mett  was bt'.:« '.">
       dtttction li«tt  atsociattd uitn tRt laboratory analysis Mthod ustd.

-------
                           'CITY CHEMCAL
                            PROPERTY BOUNDARY
                                      F.O
                  SHOP
      LEGEND
           SAMPLE LOCATIONS  D AND E - ON-SITE SO*. SAMPLES


           SAMPLE LOCATION A i DRANAGE DITCH SOL SAMPLES
                                                                                OFFICE
                                                                                  A
                                                                                 Ujt
                                                                                               •
                                                                                               II
                                                                                                        N
                                                               O
                                                               6
                                                               cc
                                                               vr

                                                               S
VIRE A-/I:  STTK DATA AUOMKNTATldN
           SOU. SAMPI.INC  LOCATIONS
                                           SOIIRCK:
GMCE
I.&M CUNSIH HN(. I NI.INI I lib IN(.

-------
                                               TABLE A-5
C3ISTITUEMT
                            OETECTIOSJ
                              LtRIT
   OaCElTlATIOSl  <••!>  DETECTED II TCL» COMPOSITE SABK.ES


SAMPLE 0     SAMPLE  E     SAMPLE F    SAMPLE 6   SAMPLE C2
                   Comcoundi
»eetone
Icnztnt
2-lutanone (NEK)
Chloroform
1, 1-Oichloroethane
1 ,2-Oienl8ro«thin«
1, 1-OieMero«tfttnt
Etfiyl btnunt
*tt!»yltnt cMoridt
&-M«tftyl-2-p«ntanen« (M1IK)
Pntnot
T«tr»ehlorotthtn«
Tolu«nt
1 , 1 , 1-Tr iehlorotthin*
T.-ieMorottHtnt
Total Xyltnc*          ,
                                     10
                                      1
                                    100
                                     5
•OL
IOL
IOL
IOL
IOL

IOL
IOL
IOL
IOL
IOL
IOL

IOL
IOL
                                                  (2)
                IOL
                IOL
                IOL
                IOL
                IOL
                IOL
                IDL
                IOL
                IOL
                IOL
                IOL
                IOL
                IOL
                IOL
                IOL
                IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
IOL
•OL
IOL
                                                                                                   IOL
MOTES

(1)  TCLP  eempotitt  staples  vert  analyzed  to  dtttriint  th«  teachability of  phenol  and  target  list
     esmpounfli on March IS, 19M.

(2)  The  d«iignatio« 101  fndfeatea  that  the  constituent  concentration  in  the  ta«ple  net  be ton ti«
     detection liarit aaaociated «lth the laDoratory analysts  ewtned used.
(3)  S««*le 62 «as • cenfirsution stable analyzed for total  toluene only.

-------
                                             TABLE  A-6
                                                    CMCZITIATIM  
-------
                      x:
CHEMICAL
  ITY BOUNDARY
                    SHOP
                                                ..AL
            LEGEND:

            A'  AD SAMPLE, PUMP LOCATION t
KIC1IKI-:  A-r>:  SITK DATA  AIICMKNTATION
             AIU SAMI'I.K Cdl.l.l'.CIItlN

             LOCATIONS
                                          SOIIRCK:
                                                                              OFFICE
                                                                                         *.3
*
N
I
                                                                                                   v>

                                                                                                   g
            GMCE
            I, AM CONMM I INI. |
                                INC

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      APPENDIX B
R««pon«iv«n««« Summary

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       RESPONSIVENESS SUMMARY
          CITY INDUSTRIES SITE
         WINTER PARK, FLORIDA
           (WORK ASSIGNMENT C04024)
              CONTRACT NO. ee-wa-ooos
             (RAI PROJECT No.
                MARCH 26, 1990
                PREPARED FOR:
U.S. ENVIRONMENTAL PROTECTION AGENCY
                REGION IV
                 PREPARED BY:
       RESOURCE APPLICATIONS, INC.
        ENGINEERS • SCIENTISTS • PLANNERS
         1000 CAMBRIDGE SQUARE, SUITE D
             ALPHARETTA, GA 30201
                404/664-3618

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                             CONTENTS
 Section                                                                    Page


 1.0   OVERVIEW  	          . .             	1
2.0   BACKGROUND ON COMMUNITY INVOLVEMENT
      AND COMMUNITY CONCERNS ..................................... 2

      2.1   Community Profile  ......................................... 2
      2.2   History of Community Involvement and Community Concerns  ............ 2
      2.3   Summary of Key Issues and Community Concerns ................... 3
3.0   SUMMARY OF MAJOR PUBLIC COMMENTS AND AGENCY RESPONSES
     3.1   Remedial Alternative Preferences  ............................... 4
     3.2   Hearth Issues  ............................................ 4
     3.3   Technical Questions Regarding Remedial Alternatives  ................. 5
     3.4   Public Participation Process Comments  ........................... 8
     3.5   Costs/Funding Issues  ....................................... 8
     3.6   Enforcement Concerns ...................................... 8
     3.7   Decision Process Questions  .................................. 9


4.0   REMAINING PUBLIC CONCERNS ................................... 10
       ATTACHMENT A:     Community Relations Activities Conducted to Date

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 1.0  OVERVIEW

 This Responsiveness Summary is a continuation of the community relations activities for the City
 Industries  Superfund site (also known as the City Chemical  site) east of Winter Park, Florida.
 During  the Public  Comment Period held from February 6, 1990 to  March 8, 1990, the  U.S.
 Environmental Protection Agency (US EPA) encouraged community Input on the subject of various
 alternatives under consideration for site remediation. This report includes a summary of the major
 comments  received by EPA, and documents the resultant responses.  EPA responses which are
 quoted  verbatim are enclosed In quotation marks.

 Groundwater contamination Is the principal  threat remaining  at the  City Industries site; its
 remediation will be the final action for the srte.  The remedial  alternative preferred by EPA involves
 pumping and treating the contaminated groundwater, then discharging the treated water to the City
 of Orlando's Iron Bridge publicly-owned treatment works (POTW) for further treatment.  The major
 components of the  preferred remedy include:

        Deed/regional well restrictions;
        Groundwater monitoring;
        Groundwater recovery via wells;
        Groundwater treatment by aeration;
        Discharge of treated effluent to the Iron Bridge POTW.

 EPA has also selected a contingency alternative, which consists of the following  remedial actions:

        Deed/regional well restrictions;
        Groundwater monitoring;
        Groundwater recovery via wells;
        Groundwater treatment by aeration, precipitation, filtration, and  carbon  adsorption;
        Surface water discharge of treated effluent.

The majority of opinions  presented throughout the course of the public comment  period were in
support of the preferred remedy. Those who voiced objections stated that their  concurrence with
the selection of EPA'a preferred  alternative would be  contingent upon resolution of technical
Issues.


Information  regarding ether  aspects of the site cleanup are available at the City Industries site
Information  Repository, located at the following address:

   Winter Park Public Library
   Robert  Melanson, Director
   460  E. New England Ave.
   Winter Park, FL  32789
   (407) 647-1638

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      2.0  BACKGROUND OF COMMUNITY INVOLVEMENT AND COMMUNITY CONCERNS

      2.1  Community Profile

      Winter Park !• located just north of Orlando In Orange County.  The unincorporated township of
      Goldenrod la adjacent to the eastern city limit* of Winter Park.  While the population of Goldenrod
      can only be estimated, Winter Park I* home for almoet  4% of approximately 654,000 people In
      Orange County. Major employers In the area Include Walt Disney World Amusement Park, banks,
      and schools.

      Nearby natural features include the Crane Strand Wetland and several small lakes,  such as Lake
      Osceola, Lake Corinne, and Lake  Waunatta.  Augmentation of some of the wetland  area  has
      provided additional room  for  the  rapid growth  of  residential developments  and commercial
      ventures.  Fields and wooded areas comprise the balance of the undeveloped land.

      The City Industries site is located In an Industrial area, with many different businesses in close
      proximity.  The closest  residences are within 2000 feet of the aite.


      2.2  History of Community Involvement and  Community Concerns

      The City Industries srte  has come to be associated with the town of Winter Park due to its Winter
      Park mailing address.  It  Is  situated, however, outside the  city limits In  the  unincorporated
)     township of Goldenrod.  Some Winter Park citizens feel they have been affected by the conditions
      at the site, but the majority of public Interest comes from the Goldenrod community.

      In 1983, the community of Goldenrod held meetings for  the purpose of establishing emergency
      evacuation procedures.  These meetings included representatives from the Florida Department of
      Environmental Regulations (FDER), Orange County, Seminole  County, neighborhood watch  and
      homeowners associations, apartment complexes, private citizens, and various media personnel.
      The threat at the time was considered to be from explosion or fire.  In addition, a  concern was
      voiced that City Industries trucks transporting  drums on city  streets could be Involved in  an
      accident, or drums could fail from the trucks and spill contaminants. On one occasion, evacuation
      procedures were Initiated In  the immediate  area In response to an onslte spill; this  was later
      determined to be unnecessary.

      When  onslte Investigative activities  began, protective suits worn by workers alarmed  both  the
      people In the Immediate vicinity and those Irving on the further perimeter, but close  enough to be
      affected should «i emergency situation arise.  Their concern was why they were permitted to
      remain so clove) to the facility H the  suits were required.

      Several people stated thai their private wells were sampled during the City Industdes  Investigation,
      but they never received Information  regarding the analytical results.  None of these wells have
      been used for drinking water, but the concern was mentioned that children or pets playing In the
      water from lawn sprinklers, or  possibly drinking some of the water, may have  been at risk. A
      similar concern was that someone walking through freshly watered grass may have absorbed
      contaminants through the skin. The question was raised by one Individual whether a number of
      deaths attributed to cancer might be related to  possible contaminants In  the water.   It  was
      suggested that a hearth survey be conducted to assess the possibility, and be used  as a learning
      opportunity should a connection exist.

      One businessman discovered that monitoring wells had been Installed on his property without his

-------
permlMlon and to has not been satisfied with attempts by FDER to rectify Installation deficiencies
(These  wells  «•»•  among  the ones Installed  In  early efforts to monitor the movement  of
contaminants In tfM  groundwater).

The question of property value depreciation has been raised, predominantly by residential property
owners.   Some  businesses expressed concern  about the possibility of depreciation; however,
property In the commercial zone remains In high demand and commercial land value appears to
be  unaffected by site conditions. The problem for the business sector Is that property ownership
may not  be transferable until the property Is declared clear of contamination.

Virtually everyone contacted expressed extreme dissatisfaction with the nominal sentence received
by  Arthur Greer, the owner/operator of City Industries, Inc.

Recently, the Issue  of the  site seems to  surface only when reference is made to pollution  or
contamination in general. The Environmental Hearth Division of Orange County Hearth Department
reported that no recent comments  or concerns had been received.  Most people feel the critical
issue now Is to  expedite the  implementation of the final remedial efforts.


2.3  Summary  of Key Issues  and Community Concerns

The primary concern In the area is that the necessary remedial actions at the site be completed
as soon as possible. The community also wants to be kept Informed of the sits status and any
potential threat resulting from site conditions.  For those who do not feel their health  may  be
threatened, the main concern Is property devaluation.  The leniency of punishment sustained  by
Mr.  Greer Is a source of dissatisfaction to many  of the citizens interviewed.

-------
 3.0  SUMMARY OF MAJOR PUBLJC COMMENTS AND AGENCY RESPONSES

 3.1   Remedial Alternative Preference*

 3.1.1    The Potentially Responsible Party (PRP) Steering Committed la In agreement with
         EPA that the preferred alternative presents the best solution to the City Industries
         site contamination.

 3.1.2    Mr. Tom Lothrop, director of environmental services for the City of Orlando, stated
         that the city and the Iron Bridge POTW were strongly opposed to EPA's preferred
         alternative at  this time.  Mr. Lothrop's position was based on several  Issues,
         which are addressed  Individually In the following sections. Mr. Lothrop believes
         that, at present, the City of Orlando would consider EPA's contingency alternative
         (Involving  surface  water discharge) to be  the most viable  method  of  site
         remediation. The City of Winter Park, represented by Mr. Dan Mercer, supports
         this position.

 3.1.3    Several private citizens voiced a strong desire that  the preferred alternative be
         implemented Immediately.   One resident, however, stated that the people of
         Goldenrod would be  satisfied with EPA's preferred alternative, but would not
         accept the discharge  of  City Industries effluent to surface waters.

 3.1.4    On behalf of Orange County, Deputy Fire Chief Edwin Spahn expressed support
         of EPA's  actions and Indicated the  county's willingness to cooperate In the
         remediation of the site.
3.2  Health Issues

3.2.1    Mr. Alex Alexander of the Florida  Department of Environmental Regulations
        questioned possible effects of the site effluent on drinking water sources.

        EPA Response:  There are  no such risks at the present time.  The contamination
        la  located In the surflclal  aquifer, which Is  not used as a source  of drinking
        water.  The  underlying Florldan Aquifer Is a source of drinking water; If cross*
        contamination occurred, however, the regional flow of the lower aquifer would
        transport any contaminants from  the City Industries site away from the nearby
        Winter Park  welifleld. The  municipal water supply wells are being monitored as
        a precaution.


3.2.2    Several private citizens   expressed concern  about  what  Impact the  site
        contamination would have on residents who have had contact with groundwater.

        EPA Response:  The EPA Remedial Project Manager determined the location of
        the residences In  question, then  asaured these cKlzena that the contaminant
        plume does  not currently encompass that area, and la moving away from their
        vicinity.
3.2.3    A local resident requested Information regarding the  long-term and short-term
        physical effects of the contaminants on both humans and anlmala.

-------
        EPA Response: The organic chemicals In the groundwater, when present In high
        enough concentrations, can cause various acute (short-term) effects depending
        on the chemical.  Some of these are drowsiness, dizziness, headaches,  and
        nauses. Chronic (long-term) effects are chemical-dependent as well and Include
        damage to  liver,  kidneys, heart, lungs,  and nervous system,  reproductive
        disorders, and cancer.   However,  based on  s map  of  the  extent of  the
        contaminant plume, groundwater  In the vicinity of your home Is not currently
        affected by the City Chemical site.'


3.2.4    An Interested party Inquired whether water discharged to the county-maintained
        drainage canal would present  a potential risk to birds or  children should the
        contingency alternative be chosen. This party also asked the eventual destination
        of the water.

        EPA Response:  Ambient  water quality standards must be  met before treated
        water can be dischsrged to surface waters.  This precludes contlnuancs of site-
        related hearth  risks.  The  discharged water will eventually  reenter the surficial
        aquifer, again posing no srte-related risks.
3.2.5    A citizen voiced the concern that a volatile vapor phase may emanate from the
        surficial aquifer.

        EPA Response:  A risk would exist only In a low-level, enclosed, unventilated
   »    area.
3.3 Technical Questions Regarding Remedial Alternatives

3.3.1    A public meeting participant Inquired  what the projected pumping  rate of the
        extraction wells would be.

        EPA Response:  The rate would be 100 gallons per minute, or 144,000 gallons
        per day.
3.3.2    A resident of Qoldenrod queried whether the aeration tower would emit odors,
        and raquae*ad the names of local representatives who  could be contacted with
        complaint* regarding emitted odor.

        EPA Response: Some odor may be Inherent In aeration treatment due to some
        of the compounds which are present  Two factors would preclude noxious odor:
        1) controlled concentrations would be released from the tower, and 2) the release
        height would be twenty to forty feet above the breathing zone.  Ma. Diane Scott,
        EPA Remedial Project Manager, named herself as a Region IV contact, and Mr.
        Don Harris  and Mr.  Jim Jarmolowskl of FDER-Orlando were named as local
        contacts.
3.3.3    Several residents requested the time frame until remedial action begins.

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        EPA Response:  The Implementation of the remedy will begin In approximately
        two years.


 3.3.4   Another concern voiced was whether EPA had been given the right of eminent
        domain for access to land where extraction wells may be placed.

        EPA Response:   EPA  does not have that right.   EPA attempts to persuade
        reluctant landowners by explaining the need for access, and a court order would
        be necessary If education of the landowner was not sufficiently persuasive.


 3.3.5   A local businessman asked If the contamination would go away by  Itself if left
        alone.

        EPA Response:  No.


 3.3.6   A citizen Inquired  whether air stripping treatment would  merely  be removing
        contaminants from  the groundwater and placing them In the atmosphere.

        EPA Response:   The  years-long span of the treatment  would  minimize  the
        concentration entering the atmosphere at any one point In time, and pollution
        control equipment will be utilized If monitoring at the top of the tower  reveals the
        need. In addition,  sunlight Itself can reduce the hazard of contaminants.


3.3.7   A public meeting participant asked If the Florldan aquifer was being  monitored.

        EPA Response:  Yes. No contaminants have been detected In that aquifer at this
        time.
3.3.8    The City of Orlando'* technical objection to EPA's preferred alternative concerns
        pretreatment of the  site groundwater.  Orlando official* state that before Iron
        Bridge POTW will consider accepting City Industries effluent, an agreement must
        be reached  with the PRPs In reference to pretreatment requirements.

        EPA Reaponaa:   The  POTW  personnel have been Invtted to participate  In
        RemedM OaalgrVRemedlal Action (RD/RA) negotiations with EPA and the PRPs
        as wei m technical review of RD/RA documents to ensure thai their legal and
        technical concerns are addressed.*
3.3.9   The PRP Steering Committee believes administrative obstacles to Implementation
       of the preferred alternative (I.e., discharge of effluent to the Iron Bridge POTW)
       should be reserved prior to flnallzatlon of the Record of Decision.  In addition,
       the Steering Committee requested that all Its previous correspondence and other
       submrttala be Incorporated Into the City Industries site Administrative Record.

       EPA Response:  'Delaying Issuance of the Record of  Decision until negotiations

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        with ttM Iron Bridge POTW are complete would cause an unnecessary delay In
        remediation of the site.  All previous tubmrnals by the Steering Committee have
        been Included In the Administrative Record.*


 3.3.10  Officials al  the  South  Semlnole and  North  Orange  County  Wastewater
        Transmission Authority are concerned that chemicals present In the groundwater
        from  the  City  Industries site  might  cause  deterioration  of  the  Wastewater
        Transmission Authority's pump  station and force main system.

        EPA Response:   The chemicals are present  In high enough concentrations to
        have  an effect on human health, but not on pipes or pumps.'


 3.3.11  Mr. Dan Mercer, representing the Crty of Winter Park, expressed an Interest in
        ensuring that safety and quality contingencies are  build into the design of  the
        remedy selected for the site.

        EPA Response:  That Is a part of the ensuing  Remedial Design/Remedial Action
        process.
3.3.12  A resident questioned whether EPA had reviewed an alternative which considered
        the contingency of storage for substandard effluent.

        EPA Response:  That contingency has been considered, and provisions will be
        made  during the remedial  design  phase.


3.3.13  Mr. Byron Brooks  of the  Orange County Administrator's Office raised several
        concerns regarding EPA's contingency alternative,  which Involves discharge to
        a county-maintained drainage canal.  Mr. Brooks requested Information regarding
        the estimated rate, volume, and duration of the discharge from the  site to  the
       'Crane Strand Canal, and the effect on the water surface profile and hydro-period
        In the  area.  He also advised EPA  that  the connection to the Crane Strand Canal
        would require a Rlght-of-Way Utilization Permit Finally, Mr. Brooks requested that
        an on-ette pilot project be Incorporated Into the deliberation and testing process
        If the contingency alternative Is the remedy selected.

        EPA Reopens*: The rate of discharge to the Crane Strand Canal is lOO.gpm or
        0.2 ft*/tm  The) total volume of water  to b« discharged based on  pumping and
        treating tor 14 years at the above  rate to 736 million gallons. This discharge to
        not antMpeted to have a significant effect on the water surface profile when the
        canal to it flood stage.  The  proposed discharge should not affect the hydro-
        period of the conservation area east of Goidenrod  Road.

        •EPA will coordinate the Rlght-of-Way Utilization Permit with Orange County In the
        event that the  treated water from the City  Chemical site to discharged to the
        Crane Strand Canal.

        •Pilot testing of Alternative 3 [the  contingency alternative] would be conducted
        prior to Implementation If this alternative becomes  necessary.'

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 3.4  Public Participation Process Comments

 3.4.1   City of Orlando officials were unsatisfied with the level of Involvement offered to
        the City during the development of the Feasibility Study.  They believe that  the
        City of  Orlando should  be more  Involved  In the planning and design of  the
        preferred  alternative if Iron Bridge Is to accept the City Industries effluent.

        EPA Response: 'EPA has met with the City to discuss the deficiencies in  the
        Feasibility Study and will  make sure that these issues are addressed during
        remedial design.*
 3.5  Costs Funding Issues

 3.5.1    Mr. Tom Lothrop questioned the high estimated cost of the Feasibility Study's
        Alternative #5, which  includes  groundwater extraction, treatment by aeration,
        precipitation, filtration  and carbon adsorption, and reinjection  into the surficial
        aquifer.

        EPA Response:   The  high estimate is due  to  two factors:  1) the  carbon
        adsorption process, as the primary treatment for this alternative, would  require
        frequent carbon  regeneration,  and  2) reinjection of the  treated water  would
        necessitate more stringent control of the effluent  qualm/.


 3.5.2»   An  attorney for a local bank was  Interested  in whether  the  bank would be
        responsible for the expense should they  request the  Installation of a monitoring
        well on their property.

        EPA Response:  No.
3.6  Enforcement Concerns

3.6.1    Mr. Alex Alexander asked who the responsible parties were.

        EPA Response:  There are approximately 180 generators named as Potentially
        Responsible Parties (PRPs).
3.6.2    A citizen Inquired whether other businesses In the area may have contributed to
        the contaminant plume.

        EPA Response:   Through sampling  of the  monitoring wells,  ft  has  been
        determined that City Industries was the sole source of this plume.


3.6.3    One Individual was Interested  In determining who will  be responsible for facility
        operation once the remedial design has been  Implemented.

-------
        EPA Response:  The PRPs will ultimately be responsible, but will probably hire
        a contractor to handle the remedial operation.


 3.6.4   Officials  it the  South  Semlnole  and  North  Orange  County  Wastewater
        Transmission Authority stated that If the City Chemical site faculty malfunctions,
        tt would teem appropriate that penalties should  be  levied directly against  the
        operators of the Ctty Chemical facility and not the owners of the treatment plant
        nor the collection system.

        EPA Response:   •While  the  POTW Is  responsible for  any violations of their
        NPDES  permit,  there  are mechanisms  available to the POTW, such as  the
        possibility of an agreement with the PRPs to obtain reimbursement for penalties
        incurred.*
3.6.5   The question of liability has prompted the City of Orlando to require assurances
        that the POTW will not be held liable for problems resulting from accepting the
        City Industries water.

        EPA Response: 'EPA understands the City's concerns about liability as It relates
        to  accepting the City Chemical discharge.  The POTW personnel  have been
        invited  to participate In Remedial Design/Remedial Action (RD/RA) negotiations
        with EPA and  the  PRPs  as well as technical review of RO/RA  documents to
        ensure  that their legal and technical concerns are addressed.   EPA  has also
        proposed automatic shutdown of  the Intercept system  In the event that  high
        effluent concentrations are detected, In order to prevent NPDES permit infractions
        by  the  POTW.'
3.6.6   A local businessman was curious to learn what controls are imposed on EPA.

       EPA Response:  The Judicial system watches EPA's activities through the consent
       decrees Issued  to the agency.
3.7 Decision Process Questions

3.7.1    A resident  asked what criteria were  used In the selection  of  the  remedial
        irterruttvt*.

        EPA RMBODM: The EPA Remedial Project Manager outlined the nine  standard
        selection criteria utilized by EPA.

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4.0  REMAINING PUBUC CONCERNS

The only  remaining IMU« which EPA was unable to resolve concerns the question of potential
property value depreciation.
                                          10

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 ATTACHMENT A • Community Relation* Activities Conducted to Date

 November 1999

    .   EPA representatives conducted personal  Interviews with local  officials and
        Interested citizens In the City Industries area;
    .   An Interested-parties mailing list was compiled:
    •   The development of a site-specific Community Relations Plan was initiated.


 January 1990

    •   The Community Relations Plan was finalized;
    •   EPA mailed fact sheets to everyone  on the mailing list;
    •   EPA announced the upcoming Public  Meeting with a printed notice in the Orlando
        Sentinel.


 February 1990

    •   An Information Repository was established at the Winter Park Public Library (see
        Section 1.0 for location).  Relevant  site-related documents were placed in  the
        repository to facilitate community access;
    •   EPA held  a public meeting February 6 at the  Elks Lodge In Winter Park to present
        the  Remedial  Investigation/Feasibility  Study and  the  Proposed  Plan to  the
        community.  The meeting was attended by approximately  60  people, Including
        local officials,  private citizens, members of the PRP Steering Committee, and
        other Interested parties.  A transcript of the meeting is available at the Information
        repository;
    •   The Public Comment Period began February 6;
    •   The mailing list was updated and expanded.


March 1990

    •   The public comment period closed March 8.  Due to continued Input, however,
        EPA accepted correspondence after  the closing date;
    •   This Responsiveness Summary documented the major comments and responses
        presented during the public comment period.

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