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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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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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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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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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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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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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.
-------
-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.
-------
-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 ~* -*•««•••-••>«
-------
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
-------
-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
-------
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
-------
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.
-------
-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.
-------
-' 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«.
-------
-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
-------
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
-------
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
-------
-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.
-------
-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
1
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
•-
C2
SHOP
8
Cl
*
4
6 •
C4
5
, •
C3
«
7
OFFICE
/
9
*
1
T
i
O:
rS
€
x •
SK)
f1]
ENTRANCE ROAD
WOODED AREA
EXPLANATION
n
fS
a:
i
ft
or
.
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
-------
APPENDIX B
R««pon«iv«n««« Summary
-------
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
-------
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
-------
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
-------
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
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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.
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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.
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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.
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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.
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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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