United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-90/066
September 1990
&EPA Superfund
Record of Decision:
Coleman-Evans Wood
Preserving, FL
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1CIZ72.101
REPORT DOCUMENTATION 1" REPORT NO. I ~ I. A8cIpIent8 "-elan No.
PAGE EPA/ROD/R04-90/066
4. 1118......... 5. A8port D8t8
SUPERFUND RECORD OF DECISION 09/26/90
Coleman-Evans Wood Preserving, FL
I.
First Remedial Action (Amendment) - Final
7. AuItar(8) .. F\Irtotmlng Organlzallon ~ No.
1. PwIonI... OIpilA..Ion ..... ... ~ 10. ProiKtIT8IIIIW0ItI UnIt No.
11. Cor88d(C)., ChnI(QJ No.
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1~ Ipoi....q ar..,.~........ ~ 11. TJ118 of R8p0rt. P8IIod eo-.d
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
11. . rP' .......... No..
11. AII8nct (\JIIIIt: 2DD wonI8)
The 11-acre Coleman-Evans Wood Preserving site is a former wood treatment facility,
which was operated from 1954 to the late 1980s, in the community of Whitehouse, Duval
County, Florida. The surrounding land use is primarily residential and light
commercial/industrial, and there are approximately 1,000 local residents who rely
exclusively on ground water for their drinking water supply. The site is divided into
2 areas, including a wood treatment facility on the western portion of the site, and a
landfill area used for disposal of wood chips and other facility wastes on the eastern
portion of the site. In addition to the treatment and storage areas there is an onsite
drainage ditch that carries site runoff into nearby McGirts Creek. Prior to 1970,
wastewater from the facility was precipated and discharged to the onsite drainage
ditch. The precipitated sludge was deposited into two unlined pits until 1970, when
the sludge was stored in tanks. The wastewater treatment process was also enhanced in
1970 with lime precipitation and chlorination. In 1980, onsite ground water
contamination was detected and activated charcoal filters were added to the treatment
process to remove organics.. The primary contaminant in onsite soil and ground water
has been identified as pentachlorophenol (PCP). The highest areas of PCP concent~ation
(See Attached Page)
17. IIoa88tI An8IJ8Ie & 0.. ~
Record of Decision - Coleman-Evans Wood Preserving, FL
First Remedial Action - Final (Amendment)
Contaminated Media: soil, sediment, <,
gw
Key Contaminants: PCP, metals /
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(4-77)
(See AN!II-Dt.11)
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(F0I'IIIIIty NT1s.35)
Department of Commerce
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EPA/ROD/R04-90/066
Coleman-Evans Wood Preserving, FL
First Remedial Action - Final (Amendment)
Abstract (Continued)
'I
were '~n the vicinity of onsite chemical tanks and the unlined pit areas. In 1985, EPA
conducted an emergency response, which included excavating and disposing of pit
material offsite and filling excavated areas with clean fill. PCP-laden fuel is
thought to be floating on the water table surface: however, only limited low, level
ground water contamination has been detected onsite. This Record of Decision (ROD)
amends a 1986 ROD, which documented the selection of incineration for an estimated
9,000 cubic yards of contaminated soil. Since that time, additional studies during the
remedial design phase indicated that there are approximately 27,000 cubic yards of
contaminated soil.. Based on the excessive volume of soil and the high cost of
incineration, treatability studies were conducted and an alternative source control
treatment was selected. The primary contaminants of concern affecting the soil,
sediment, and ground water are organics including PCP and metals.
The selected amended remedial action for this site includes excavating approximately
27,000 cubic yards of soil and sediment contaminated with PCP levels greater than
25 mg/kg, and pre-treating these materials using soil washing: separating clean soil
fractions from contaminated soil fines and woody wastes, followed by
solidification/stabilization of any soil fines or sludges, which exceed cleanup
criteria: placing a cover over the solidified mass: replacing the solidified soil and
sludges onsite: treating residual soil wash water using bioremediation, followed by a
granular activated polishing unit with subsequent onsite discharge to the drainage
ditch: pumping and recovering ground water to facilitate soil excavation, followed by
onsite treatment using the GAC adsorption unit, if PCP levels exceed 1.0 ug/l, and
'sing chemical precipitation for metals removal prior to discharging ground water to
~he onsite drainage ditch: covering the area with vegetatiqn: and implementing
institutional controls including deed restrictions, and site access restrictions
including fencing. The estimated total cost for this remedial action is $8,567,304.
There are no O&M costs associated with this remedy.
PERFORMANCE STANDARDS OR GOALS: Soil contaminated with PCPs greater than 25.0 mg/kg
will be excavated and treated to the established cleanup level below 25 mg/kg. After
bioremediation, solidified/stabilized contaminant fines will meet Toxicity
Characteristic Leaching Procedure Criteria of 3.6 mg/kg. Ground water recovered during
soil dewatering will be treated to below PCP 1.0 ug/l (State).
. .
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Amended Record of Decision
Declaration
SITE NAME AND LOCATION
,- Coleman Evans Wood Preserving Site
Duval County
Jacksonville, Florida
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Coleman Evans Wood Preserving (Coleman Evans) Site de~eloped
in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA)
and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). The Amended Record
of Decision (AROD) documents the fundamental changes in the
remedy previously proposed by the Agency in the 1986 Record of
Decision (ROD).
This AROD is based on the administrative record file for the
Coleman Evans Site.
The State of Florida's verbal concurrence on the selected remedy
will be followed by writteri concurrence.
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 AROD, may present an imminent and substantial
endangerment to p~blic health, welfare and/or the environment.
DESCRIPTION OF 1986 ROD REMEDY
The 1986 ROD specified the remediation of approximately 9,000
cubic yards of soils and sediments contaminated with
concentrations of Pentachlorophenol (PCP) greater than 10 mg/kq
..and the recovery and treatment of groundwater with PCP
concentrations levels greater than 1.01 mg/l.
. .
The major components of the 1986 ROD included:
o
Excavation of a11s011s and sediments with PCP
levels greater than 10 mq/kg.
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o
Incineration of excavated soils in a temporary on-site
incineration unit. Soils would be decontaminated in a
primary chamber where PCP and No.2 fuel oil would be
driven off in a gaseous phase. PCP would then be
thermally destroyed in a secondary chamber.
Decontaminated soils would be backfilled on-site.
o
o
Dewatering would occur to facilitate excavation.
Groundwater recovered during the dewatering process
with PCP levels greater than 1.01 mg/l would require
treatment. Upon reducing PCP levels to 1.01 ug/l,
recovered groundwater would then be stored and
analyzed for conformance with discharge requirements.
If PCP levels exceeded 1.0 ug/l, the ground water would
be treated by an 'on-site Granular Activated Carbon (GAC)
adsorption unit to a level below 1.0 ug/l in accordance
with Chapter 17-3.061.3(m) of the Florida Administrative
Code before discharge to the surface water environment.
via the onsite drainage ditch. If EPA promulgates
further regulations in the future which would be more
stringent than. those' outlined in the ROD, the future
regulations would be observed. .
o
Other incidental site-specific Hazardous Substances
List (HSL) compounds ident~fied in groundwater during
the implementation of this remedy would be cleaned up
to levels which comply with Federal Drinking Water
Standards (DWS). If the DWS did not address
site-specific compounds, clean up would be consistent
with the human health criteria identified in the 1980
Water Quality Criteria. Clean up levels for compounds
for which no Water Quality Criteria standards exist
would be to non-detection levels. In cases where
standards exist would be to non-detection levels. In
cases where standards promulgated by the State of
Florida are more stringent, the State standards would
have precedence.
o
Due to complete destruction of site-specific contami-
nants by incineration, no post-remedial monitoring or
operation and maintenance activity would be required.
. .
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EXPLANATION OF FUNDAHENTAL REMEDY CHANGE
As a result of conducting f~~th~~-studies during the initial
Remedial Design (RD) for the site, it was determined that the
1986 ROD soil volume estimate was significantly underestimated.
An estimated soil volume of 9,000 cubic va~ds was identified for
treatment in the 1986 ROD, while an esti;ated soil volume of
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. 27,000 cubic yards was identified in the RD. This significantly
'.volume increase and subsequently cost increase resulted in an
;,evaluation of other alternatives for the site.
" In response to.the alternative evaluation, EPA initiated
. "'Treatability Studies (TS) to examine bioremediation and
Stabilization/Solidification (S/S) as viable technologies for
the Coleman Evans Site. Results from the TS confirmed that
these technologies would satisfy EPA's requirement for source
control. Since this change in the method of source control is
significantly different than the previously selected 1986 ROD
remedy, a ROD amendment is required.
In summary, the 1986 ROD determined incineration of soil
followed by on-site disposal to be the proper source control
method. This AROD selects a technology train consisting of soil
washing, bioremediation, S/S and polishing of the washwater
. using a GAC adsorption unit to be the most effective overall
source control method.
This fundamental change will produce an effective solution to
remediation of contaminants present at the site, and would
require only minimal removal of hazardous constituents off-site
for disposal in the form of granular activated carbon filters
spent during the remediation of contaminated groundwater.
Further, the fundamental change meets all Applicable and
Relevant and Appropriate Requirements (ARARs) at a substantial
cost savings. .
DESCRIPTION OF AMENDED REMEDY
The major components of the selected amended remedy include:
o
Excavation of contaminated soils and sediments with
PCP levels greater than 25 mg/kg; approximately
27,000 cubic yards.
o
Volume reduction by soil washing to separate clean
fractions from contaminated soil fines.
o
..5/S of soil fines or sludges exceeding cleanup
<'criteria.
o
Redisposing of the clean soil fraction and the "fixed"
S/S sludges on-site.
Dewatering and recovery of groundwater to facilitate
excavation; recovered ground water would be analyzed.
If the level of PCP is greater than 1.0 ug/l, the
ground water will be treated by an on-site GAC
o
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adsorption unit to a level below 1.0 ug/l. Both PCP
and metals cleanup criterion would be in accordance
with Florida Water Quality Standards Chapter
l'-3.061.3(m) of the Florida Administrative Code before
discharge to an on-site drainage ditch leading to
McGirt's Creek.
o
Treatment of the soil wash water by bioremediation
followed by a GAC polishing unit for discharge to
an on-site drainage ditch leading to McGirt's Creek.
Removal of metals from the ground water by chemical
precipitation.
o
o
Installation and maintenance of a 6-inch vegetative
cover over the solidified mass (monolith).
o
. Installation and maintenance of a fence around the site
during remedial activities.
Institutional controls would include deed restrictions.
o
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate for this remedial action
and is cost effective. This remedy satisfies the statutory
preference for remedies that employ treatment that reduces
mobility, toxicity, or volume (MTV) as a principal element and
utilizes permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum extent
practicable. .
Because.this remedy will result 'inha~ardous substances
remaining on-site above health-based levels, a review will be
-conducted within five years after commencement of remedial
action to ensure that the remedy continues to provide adequate
protection of human healt~ and the enviro~ent.
S£P 2 6 1990
DATE
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1.0
2.0
:"3.0
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5.0
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6.0
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:~ 7.0
COLEHAH EVANS
Introduction
1.1 Executive Summary: Record of Decision..............1
1 . 2 Subsequent Action.................... . . . . . . . . . ~ . . . . 2
1.3 Explanation of Fundamental Remedy Change for
Source Control.................................... 3
1.4 Site Location and Description......................4
1. 5 Site History.............. . . . . . . . . . . . . . . . . . . . . . . . . .6
Site Operations and Enforcement History.................9
Highlights of Community Participation...................9
Remedial Design Studies and Investigations..............9
4.1 Soil Sampling Activities and Analyses..............9
4.2 Geostatistical Analyses........".................... 9
Treatability Study Summary.............................12
5.1 Soil Washing......................... . . . . . . . . . . . . . .12
5.2 Bioremediation..................................... 12
5.3 Stabilization...................................... .13
5.4 Treatability Study Findings........................13
5.4. 1 Bioremediation Study............."................ 13
5.4.2 Solidification/Stabilization Study...............14
5.4.3 Washwater Remediation Technologies...............15
5.4.3.1 Biological Treatment of Contaminated
Washwater. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
5.4.3.2 Treatment of the On-Site Water Treatment
Sys tem. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
5.5 Summary of the Proposed Remedial Technologies
for Soils and Washwater.. . . . . . . . . . . . . . . . . . . . . . . . . .17
Summary of Site Risks and Cleanup Goals
6.1 Human Health Risks..................................18
6.1.1 Contaminants of Concern
(Indicator Chemicals)...................... . . . . .18
6.2 Exposure Assessment Summary........................19
6.2.1 Identification of Potential Receptors............19
6.2.2 Identification of Exposure Pathways..............19
6.3 Toxicity Assessment................... ..... .... ....22
6.3.1 Primary Contaminant-Pentachlorophenol............22
6.3.2 Qualitative Descriptive of Health Effects........22
6.4 Risk Characterization..............................23
6 .5 Environmental Risks................................ 23
6.6 Cleanup Criteria.................................... 24
6.6.1 Soils/Sediment Cleanup Goals.....................24
6.6.2 Groundwater Cleanup Goals........................24
1986 ROD Soil Remediation Alternatives Considered.......25
7.1 1986 ROD Alternatives Considered...................25
. 7 .2 Al ternati ve SUJIIIDary................................ 25
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8.0
7.3 Alternative previously Selected for Soil...........25
7.4 Development of Remedial Alternatives...............25
Description of Remedial Alternatives for Soils
Reduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
8.1.Alternative 1-No Action............................27
8.2 Alternative 2-Soil Washing, Bioremediation
and Solidification/Solidification.................28
8.3 Alternative 3-Incineration.........................29
Summary of-Comparative Analysis of Alternatives.........31
9.1 Overall Protection of Human Health and the
9.0
Environment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31
9.2 Compliance with Applicable or Relevant and.
. Appropriate Requirements (ARAR'S).................31
9.3 Long-Term Effectiveness and Performance............33
9.4 Reduction of Mobility, Toxicity and Volume.........33
9.5 Short-Term Effectiveness...........................33
9.6 Implementability................................... 34
9 . 7 Cos t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
9.8 State Acceptance................................... 34
9 . 9 Communi ty Acceptance... . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
10.0 Selected Amended Remedy.................................. 35
11.0 Statutory Determination................................ .36
11.1 Protection of Human Health and the.
Env ironment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
11.2 Attainment of the Applicable Relevant and
Appropriate Requirements (ARARS).................36
11.3 Cost Effectiveness................................38
11.4 Utilization of Permanent Solutions and
Alternatives.................................... .38
11.5 Preference for Treatment as a Principal
E 1 amen t. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 9
Section 1.1
Section 3.0
Section 4.1
Section 6.4
Section 9.8
APPBImICBS
- Appendix A - 1986 ROD
- Appendix B - Responsive Summary
- Appendix C - RI/RD Analytical Results
- Appendix 0 - Revised Soil Cleanup Level
-.Appendix E - State Concurrence Letter
,.. .
'lABLES
Section 7.2-
Section 9.0. -
Section 6.2.2 - Table lA/1B - Risk Assessment
Analysis. . . . . . . . . . . . . . . . . .20/21
Table 2 - ..Previously Evaluated Remedial
Alternatives.....................26
Table 3 - Evaluation Criteria...............32
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FIGURES
,:-Section 1.4 - Figure 1 - Site Location Map..................5
,Section 1.5 - Figure 2 - Soil Sample Locations Used in
-. Previous Investigations........... 7
~Section 4.1 - Figure 3A/3B - RI/RD Sample Location
and Results....... . . . . . . . . 10/11
Section 8.2-- Figure 4 - Treatment Train Process...........30
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AllBRDKEH'l' TO ~ RECORD OP DECISION
StDlMARy OP REMEDIAL ALTERNATIVE SELECTION
COLEXAH EVANS WOOD PRESERVING SITE
DUVAL COOH'l'Y
WHITEHOUSE, FLORIDA
1.0
1.1
INTRODUCTION
Executive SnmmAry: Record of Decision, 1986
The Coleman Evans Wood Preserving (Coleman Evans) Site was
included on the National Priorities List (NPL) in March 1983.
In September 1984, the United States Environmental Protection
Agency (EPA) tasked Camp, Dresser and McKee, Inc. with
initiating a Remedial Investigation/Peasibility Study (RI/FS) at
the Coleman Evans Site. The RI/FS was conducted to determine
the extent of contamination by identifying the types,
quantities, and locations of contaminants, and subsequently, to
evaluate alternatives for solving those problems found
associated with the site.
The RI revealed that pentachlorophenol (PCP) was the main
contaminant of concern associated with this site. PCP was found
present in the following site media:
o Sediment
o Soil
o Surface water
o Groundwater (upper
surficial aquifer)
The FS evaluated various remedial alternatives before
recommending the preferred alternative for remediation of the
site. Subsequently, in the 1986 Record of Decision (ROD), EPA
selected the preferred alternative for remediating the Coleman
Evans Site. . The 1986 ROD is included in Appendix A. The major
components of the 1986 ROD included:
o
Excavation of soils and sediments with PCP
. concentration levels greater than 10 mg/kg,
(approximately 9000 cubic yards).
Incineration of excavated soils in a temporary
on-site incineration unit. Soils would be
decontaminated in a primary chamber where PCP and
No.2 fuel oil would be driven off in a gaseous
"'.',' £h..phase. PCP would -then be thermally destroyed in a .
secondary chamber. Incineration would be undertaken
in accordance with federal, state, and local laws.
A detailed Quality Assurance/Quality Control (QAtQC)
plan would be developed during the Remedial Design
(RD) . -
o
, .
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-1.2
o
Decontaminated soils would be backfilled on-site.
o
Dewatering would occur to facilitate excavation. ,
Groundwater recovered during the dewatering process
with PCP levels greater than 1.01 mg/1 would require
treatment. Upon reducing PCP levels to 1.01 ug/1,
recovered groundwater would then be stored and
analyzed for conformance with discharge
, requirements. If PCP levels exceeded 1.0 ug/l, the
groundwater would be treated by an on-site Granular
Activated Carbon (GAC) adsorption unit to a level
below 1.0 ug/l PCP in accordance with Chapter
17-3.061.3(m) of the Florida Administrative Code
before discharge to the surface water environment
via the onsite drainage ditch. If EPA promulgated
further regulations in the future which were more
stringent than those outlined in this ROD, the
future regulations would be observed.
Other incidental site-specific Hazardous Substance
List (HSL) compounds identified in groundwater
during the implementation of this remedy would be
cleaned up to levels which comply with Federal
Drinking Water Standards (DWS). If the DWS did not
address site-specific compounds, clean up would be
consistent with the human health criteria identified
in the 1980 Water Quality Criteria. Clean up of
compounds for which no standards exist would be to
non-detection levels. In cases where standards
promulgated by the State of Florida were more
stringent, the State standards would have
precedence.
o
o
Due to the complete destruction of site-specific
contaminants by incineration, no post-remedial
monitoring or operation and maintenance activity
,would be required.
Subsequent .Action
,...,.
,-Additional'sampling during the 1988 'RO determined that the
;" . reassessed amount of soil requiring remediation would be
, approximately 27,000 cubic yards. ,Incineration of this vqlume
."would result in a cleanup cost of over $25 million. . This cost
:"" would be' six times greater than the cost identified in the 1986
,', FS.," In 'a ,letter dated September ",'~;1988 to EPA,.the "Florida
Department of Environmental Regulation (FDER) raised concerns
, because the state's remedial action'cost share would increase
"{,"'.~' ,from ,less "than '$400,000 to :over ::$2,500,1)00.,;; ..In this letter FDER
stated ~hat now the original .remedy was ,not :necessarily a cost
effective ,solution' and 'due to recent~dvance8 in 'other
: ,technologies, other alternatives might 'be more feasible.
Therefore, in light of the changed:site conditions, increased
costs and limited state resources, EPA and FDER decided that
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other alternatives would be evaluated. In early 1989, EPA
initiated a Treatability Study (TS) to determine whether
bioremediation and/or stabilization and solidification, (S/S)
'would be a viable alternative for site remediation. The TS was
concluded in June 1990. Results of the TS showed that a
treatment train consisting of soil washing, bioremediation and
S/S would effectively achieve the cleanup goals for the site.
1.3
Explanation of Fundamental Remedy Change Por Source
Control
The National Contingency Plan (NCP) requires that if EPA
proposes a fundamental-change to a ROD, the ROD must be
amended. The 1986 ROD required that the contaminated soils be
incinerated. However, treatability studies conducted by EPA now
indicate that other technologies may be more feasible for the
site. The results of these studies demonstrated that a
treatment train consisting of soil washing, bioremediation and
S/S would effectively achieve the specified clean up goals at a
lower cost. Cost-effectiveness is determined by comparing the
costs of all alternatives being considered with their overall
effectiveness to determine whether the costs are proportional ~o
the effectiveness achieved. OVerall effectiveness for the
purpose of this determination includes long-term effectiveness
and Permanence; reduction of mobility, toxicity, or volume (MTV)
through treatment; and short-term effectiveness. The treatment'
train would afford a compatible degree of long-term
effectiveness, MTV, and short-term effectiveness to
incineration.
Specifically, the fundamental change in the previous 1986 ROD
remedy and the new selected remedy, described herein, is as
follows: ' '
o 'The new selected remedy utilizes an innovative
technology consisting of-soil washing, bioremediation,
and S/S. Soil washing of the contaminated soils, prior
to treatment, will reduce the final volume of soils to
be treated, down from 27,000 cubic yards, to
approximately 2,700 cubic yards. Approximately 25,000
cubic yards of 80i18 containing PCP levels of less than
25 mg/kgafter soil washing will be backfilled into the
, ' --.'8xcavated areas. .Washwater produced from the soil
~ ':y~ ;:' ~:,;;washing 'process will ibe';bioremediated. Contaminated
'soil fines and woody 'fractions will be stabilized and'
",--:-:' -:,!r,J'-placed tback -into 'the excavated areas. '-Stabilization
reagents may inclduecement, pozzolans (flyash, l~e,
'" - "kiln dust), organophilic clays, asphal t/bi tumen and
,,,'::::':: 'thermoplasticizers . ,...a'he '.pilot study will determine
, which reagent (s) are more suited for the site. The
:remedy~elected.in:the,1986-ROD is significantly
~ifferent in ~hat 'it would require thermal treatment of
the total esttmated:~7,000 cubic yards of contaminated
excavated soils. ' , ' -
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o
In the amended remedy additional soil/sediment samples
.in off-site locations (drainage ditches in particular)
will be collected. Soils exceeding the cleanup levels
will be remediated as described above.
This fundamental change
contaminants present at
change meets Applicable
Requirements (ARARs) at
will produce an effective solution to
the site. Further, the fundamental
and Relevant and Appropriate
a lower cost.
1.4
Site Location and Description
The Coleman Evans site is an II-acre facility located in the
community of Whitehouse, Duval County, Florida, approximately 8
miles west of Jacksonville. The site is bordered on the north
by the Seaboard Coastline Railroad, on the south by a
residential area, on the west by Celery Avenue, and on the east
by heavy vegetation (Figurel). Residences with private well
water sources are located along both Celery Avenue and General
Avenue.
The Coleman Evans Site is composed of two distinct areas. The
first area comprises the wood treatment facility and is located
on the western portion of the property. The eastern portion is
a landfill area which has been used for disposal of wood chips
and other facility wastes. Site surface features include two
unlined disposal pits, the contents of which were partially
removed in July 1985, under an EPA emergency response, and the
active wood treatment facility. The treatment facility is
composed of a large pressure filter system and several storage
sheds. .
The Coleman Evans Site is relatively flat, with less than 10
feet of relief over the entire site. The site drains into a
ditch which eventually enters a swampy area to the south, which
subsequently drains into McGirts Creek. .
Within a l-mile radius of the site, land use is primarily
residential and light commercial/industrial. Outside the l-mile
. radius, the area is primarily undeveloped rural land up to the
outskirts of Jacksonville, about eight miles to the east.
Locally, there is no municipal water supply. Thus,
approximately 1000 residents rely on groundwater resources for
drinking water. The two groundwater resources are the surficial
.~.aquifer system and the Floridan aquifer. Surface waters in
.... Duval County are used exclusively for sport fishing and
recreation. Agriculture near the site is limited to small
gardens.
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2.0
Site Operations and Enforcement History
The Coleman Evans facility produced preserved wood products that
were pressure impregnated with PCP from 1954 until the late
1980s. The treatment process included steaming, drying and
pressure soaking the wood, all of which were carried out within
a single pressure chamber.
-
During the'steaming process, the wood products were impregnated
.~with PCP and No.2 fuel oil, using 2SS-degree Fahrenheit steam
for a period of eight (8) hours. During this period, wood
.~. extracts were driven from the wood pores, settling on the bottom
. of the chamber along with PCP and wastewater from the condensed
..~ steam.
Prior to 1970, the effluent wastewater from the treatment
process was precipitated with caustic soda and aluminum sulfate,
passed through a sand filter and discharged into a drainage
ditch which channeled the water south to McGirts Creek (Figure
2). The precipitated sludge was deposited into two unlined pits
of unknown depth, each approximately 100 feet by 50 feet,
located along the southeastern edge of the site. Usage of the
sludge disposal pits was discontinued in 1970 when the company
began storing its waste sludge in above ground storage tanks
located adjacent to the pit area on the west and northwest.
Also in 1970, the company voluntarily engaged the engineering
firm of ReYnolds, Smith and Hill to design a wastewater
. treatment system. As a result of the consultant's
.recommendations, chlorination and lime precipitation was
incorporated to produce a clearer wastewater.
Groundwater contamination was confirmed at the Coleman Evans
Site by the City of Jacksonville, Department of Health, Welfare
and Bio-Environmental Services (BES) on September 9, 1980. As a
result of these findings, in 1980 the company incorporated
activated charcoal filters into the wastewater treatment system
. to improve the removal of organics and, in 1981 completed
construction of a closed-loop steaming system in the treated
..cylinder that resulted in zero discharge. In 1981 the company
was found in violation of Resource Conservation Recovery Act
(RCRA) hazardous waste reporting planning and safety
requirements. In 1983 the company was found to be a generator
and storer of hazardous wastes which was in violation of RCRA
j" requirements.
" .
.'
. In October 1981, the Coleman Evans Site was proposed for
~inclusion on the National Priorities List (NPL) based'on a
Hazard Ranking Score of 59.14. The site was finalized on the
. NPL in March 1983.
, .~ .
:. ~': (~;'"
.:In,:September 1984, EPA obligated funds for an RIfFS. By October
'U984, EPA had tasked Camp, Dresser and McKee, Inc., the REM II
contractor, to execute the RIf~S.,w.Thefield investigation was.
-".' delayed by Coleman Evans' refusal to allow EPA onsite to conduct
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MONITOR WELL LOCATIONS (1983)
HAND AUGER SAMPLE LOCATIONS 'jil_.-~3)
-------
the removal and remedial activities. As a result, EPA and the
Department of Justice (DOJ) filed a motion in Federal Court to
obtain an order granting site access. By June 1985, EPA and its
agents were granted site access and field operations were
initiated.
In 1985, EPA issued a Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA) Section 106
Removal Order to Coleman Evans. Coleman Evans did not comply
with the Order. As a result, in June and July 1985 an Immediate
Removal Action (IRA) was conducted by EPA to control the major
source of PCP contamination in the shallow aquifer. Two unlined
pits were excavated and the contaminated material was shipped
off-site to a hazardous waste management facility in EmelIe,
Alabama. The pits were backfilled with clean material and
french drains were installed.
The RI Report was completed in April 1986 and the draft FS was
released to the public on July 21, 1986.
A public meeting to present the FS was held on August 7, 1986.
The public comment period closed on August 28, 1986. The ROD
for the Coleman Evans Site was signed September 25, 1986.
In October 1986, general notice was given to Coleman Evans
regarding implementation of the RD/RA. Citing financial
in~bility, Coleman Evans declined to implement the RD/RA. A
Special Notice Letter was issued in December 1987 giving Coleman
Evans the opportunity to enter into negotiations with EPA to
implement the RD/RA. Coleman Evans again declined, citing
financial inability. In April 1988, a CERCLA Section 106 Order
was issued to Coleman Evans to implement the RA. In response,
Coleman Evans requested a settlement conference with EPA.
Demand letters for past costs incurred in the 1985 removal
operation were issued to Coleman Evans and Jack Coleman in April
, and May 1988, respectively. The DOJfiled a civil action
against Coleman Evans in July 1988, seeking recovery of those
funds and punitive damages for failure to comply with the
Order. In April 1990, Coleman Evans settled this matter with
the United States Government for $350,000 and a complete
covenant not to sue.
";. In September 1988EPA and FDER decided that based on an'
5. increased soil volume to be.remediated,:a TS to evaluate other
. remedial options would be initiated.' In March 1989, EPA
" T obtained PCP contaminated soil samples from the Coleman Evans
. Site in order to investigate the technical effectiveness of
treatability methods such as soil washing, bioremediation and
,'.8/S at the site. The TS was completed. in March 1990. .
" ~.' . .
~ ,
'- ~ \... ~~ 00-" ~.
The Coleman'Evans Site still
. activities conducted.gn site
untreated lumber inventory.
Operation has ceased.
remains"; act! ve. "Commerc lal
consist of. sawing, kiln drying and
However, the PCP Wood Treatment
-8-
-------
A public meeting to present the TS recommendations was conducted
on August 23, 1990. The public comment period was initiated on
August 9, 1990 and ended on September 9, 1990.
3.0
BIGBLIGB'l'S OF CODUHITY PARTICIPATION
The TS.Report and the Proposed Plan for the Coleman Evans Wood
Preserving.Site were released to the public on August 9, 1990.
These two documents were made available to the public for review
in the Administrative Record, located at EPA Region IV, and in
an information repository maintained at the Whitehouse
Elementary School in Whitehouse, Florida. The notice of a
public meeting was published in the Florida Times Union on
August 9, 1990. A public comment period was held from August 9
through September 9, 1990. In addition to invitation for public
comments and the accessibility of the site information, a public
meeting was conducted on August 23, 1990. At this meeting,
representatives from EPA answered questions and addressed
community concerns. Responses to comments received during the
public comment period .are included in the Responsiveness
Summary, Appendix B of this Amended Record of Decision (AROD).
4.0
4.1
REKEDIAL DESIGN STUDIES AND INVESTIGATIONS
Soil Sampling Activities and Analyses
Additional studies and investigations performed during the RD
included ground surveying, soil sample collection and analyses,
. geostatistical analyses and thermal treatment testing. Field
activities included surface soil sampling and borehole sampling
to obtain 81 samples to add to and compare with two-year old RI
data. These samples were collected from areas requiring
verification of contours using geostatistical techniques to
further define the volume necessary for cleanup. The locations
of the samples, with the results of the PCP analyses from the RI
and RD are plotted in Figure 3A and 3B. Analytical results
below the PCP cleanup level of 2S mg/kg are not shown on this
figure below a depth of 10 feet. A detailed listing of the
combined PCP analytical results from the RI and RD is included
in Appendix C. '
Total organic carbon (TOe) and moisture analyses were also
performed on the samples prior to air drying and the thermal
treatment test.
. .
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4.2
Geostatistical Analysis
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ItlM II
RI & RD SAMPLE LOCATIONS AND CONCENTRATIONS
--- ------ .. -- ._-. " . - .- -- __4 ----- - - ---- - ~-------- .
COLEMAN EVANS WOOD PRESERVING SITE
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REM II
PCP CONCENTRATION CONTOURS BY DEPTH
----
COLEMAN EVANS WOOD PRE~RVING. SITE
~(,U"t; Nt t
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-------
contaminated soil and the associated confidence intervals. The
estimated concentrations and volumes were determined using the
geostatistical technique known as Kriging. A more extensive
analysis and discussion on the Kriging technique can be found in
the RD Report.
The minimum volume of soil to be rjmediated based on soil
.< collection locations is 16,000 yds. This estimate assumes
low mobility of contaminants'3 Using the Kriging method, an
estimated volume of 26,800 yd was cal~ulated.
~ .,
...
.
5.0
TREATABILITY STUDY SUJOIARY
Based upon the characteristics of the waste and the requirements
of the 1986 ROD for the Coleman Evans Site, bioremediation and
slS technologies were selected for bench-scale assessment. The
soil washing technology was used as a pretreatment step to
bioremediation. Representative soil samples were treated using
the aforementioned technologies. Treated samples were then
analyzed to determine the effectiveness of the combined
technologies in destroying or stabilizing the contaminant to the
~ estabiished clean-up level of 3.6 ppm of PCP in a Toxicity
Characterization Leaching Procedure (TCLP) leachate test.
Treatment processes and operating features are described for
each technology in Section 5.1 through 5.3.
5.1
Soil Washing
The soil washing technology removes organic contaminants from
the soils by an extraction process with a leaching medium. The
removal technique can be employed either in-situ as a water
flushing system or by scrubbing the excavated soils through a
counter current extraction system. By use of an intensive
scrubbing action, soil aggregates are broken,lup, freeing the
highly contaminated fine particles from the coarser sand and
gravel. The fluid normally used in the soil washing is water
which may contain varying additives such as detergents, acids
and alkalis. During the washing process, adsorbed contaminants
are mobilized into solution which requires further treatment by
means of biological treatment, chemical precipitation and carbon
adsorption. .
: At the Coleman Evans Site, soil washing would be carried out in
: a continuous process in.treatment vessels, using water as the
extraction solvent.
'..,.5.2 ," Bi~remediation
.. ''P
Bior~~ediation is the ,use of bacteria or other microorganisms
.for destruction of .t~rget compounds through microbial
metabolism. Bench-scale and pilot-study demonstrations have
-12-
-------
shown that PCP and a wide variety of other organic compounds can
be removed from soil and water matrices. The economic
feasibility and success of biological treatment of soils depends
upon many site-specific factors. These include the amount of
PCP available for degradation by microbes, the ability of
naturally-occurring or introduced microorganisms to survive and
proliferate under site-specific conditions. (presence of heavy
metals, contamination by other organics, etc.) and the
availability o~ nutrients, oxygen, secondary carbon sources, pH,
etc. necessary for optimal microbial growth and degradation.
In the biotreatment study performed, the contaminated soil was
screened to remove coarse debris and then slurried with water in
a soil washing circuit to transfer the contaminants from the
soil to the aqueous phase. Following the slurring phase, the
clean coarse soil (sand fraction: > 200 mesh) was then separated
from the contaminated wash water and fine soil particles. The
washwater and soil fines were then subjected to biotreatment.
5.3
Stabilization/Solidification
Stabilization refers to the chemical modification of the soil to
render the contaminants of concern less mobile or leachable.
In this process wastes (soils) And reagents are mixed to
chemically bind or isolate the entire waste within a solid
matrix. In some cases, remediation of a site using stabilization
results in a volume increase in the amount of remediated soil
requiring final disposal. Solidification is the conversion of a
waste to a more solid form.
S/S at this site would apply primarily to soil fines and woody
fractions.
5.4
Treatability Study PiDdinqs
5.4.1
Bioremediation Study
. ,
.." 4 >'
~ - - - ."'. ~ -
Results of the treatability studies were evaluated against the
performance criteria 'of 25 part per million (ppm) of PCP in
residual .oils for all bioremediation testtng, and a maximum
TCLP concentration of 3.6 ppm of PCP in the leachate from
samples produced in the stabilization processes.
. .. ".
. ..' . .
. Critical.Analysis of the biological .studies demonstrated the
following:
o
Biological treatment of soil in a slurry reactor
achieved cleanup levels from below detection to 100
ppm of PCP depending upon soil composition. Soils'
"containing woody-fines achieved the less efficient
: levels . .Removal -rates of PCP from the aqueous phase
were dependent upon slurry concentrations and type of
initial soil fed into the slurry.
-13-
-------
I
- .
...
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5.4.2
jo:
o
~crobes more rapidly degraded PCP in soils containing
woody waste and sawdust up to 2.7 % by weight. The
woody component of this soil could be responsible for
enhanced microbial degradation of PCP. Mixing of
soils with high woody presence with those soils that
exhibit min~um woody presence, showed increased
degradation rates of the PCPs in all soils during the
slurring process.
.0
, .
Soil containing a woody compdnent was present in at
least 1/3 the total volume of soils from the site.
Analysis of soil fractions; however, showed that PCP
is partitioned preferentially into fractions of soil
above +10 mesh (woody fraction) .and -200 mesh (soil
fines), with the sandy fraction containing
concentrations near or below the soil target of 25
ppm. Soil washing studies using water as a solvent
demonstrated that soil fractions above -200 mesh could
be efficiently "cleaned" to below 25 ppm PCP in soil
without woody fractions, and to a level of
approximately 234 ppm PCP in soils with a woody
component. TS evidence suggests that removal of the
woody component would lead to total removal of PCP
from this fraction of the soil. This study suggested
that between 90% and 95% of the site soils (by weight)
could be remediated to the target cleanup level for
PCP by soil washing alone. The remaining 5% to 10% of
site soils (woody wastes and soil fines) would require
some other form of treatment such as stabilization.
Some of the woody fraction wastes would need to be
ground. or shredded prior to stabilization.
Chlorinated dioxins, if present would also be expected
to be immobilized by this process. However,.
additional testing (pilot study) would be required to
assess the full impact of stabilizing dioxins.
Off-gases from the bioreactor, while expected to be
negligible, would be treated by a vapor-phase GAC
adsorption system or another process determined to be
.effective in the de~ign"phase if deemed necessary.
.0
..
. ,
:~;: ..1'>t.>-
. J ~~ -'< ... .
Stabilization/Solidific~~ion Study
.~ Crlticaf' analysis of the' stabIlization process shows the
. ~--;.; followi~9".~':~:~'1' :~ ~ " o:.,.:.4:.f~~.)r. >- :""~;-,;f~,~:::t~~~#(;;~?f:'r:. ..c::..~;"... 0t>111.-:n..:t;_~~.,.~,.,.- :::.~.~"
o
Using the formulations set forth by the representative
,. vendors, stabilization?q~. the prov~ded soil sample
f, ;,L. \r:. :. ';.: .~(which did not contain a woody component) was achieved
." .. .". to the required TCLP concentrationfand, ,based .on
.;,-;;;, ",' ~ 'initial TCLP results,-.,percent reductions ranged from
:. '; . 79 . 23 to 98. 54 .: .: ;~..~ .. - .." .. . . . '.
o
Minimum strength parameters were met for all vendor
. .
-14-
-------
o
tests on fully-cured samples. Two samples experienced
acceptable property changes in immersion testing. One
sample broke under finger pressure.
Some vendors require prescreening or crushing of soil
prior to stabilization. .
o
The stabilization reagents used by two of the vendors
contained relatively high levels of arsenic and
barium. It is not known whether the presence of these
elements in the treated waste would pose a hazard to
human health. Further evaluation of these reagents
would occur during the pilot treatability study.
Detailed information on the TS can be found in the Final TS
Report.
5.4.3
Washwater Remediation Technologies
During soil remediation at the site, contaminated soil
washwater from the soil washing process will be produced.
Considering the anticipated high PCP concentration in the soil
washwate~, two stages of treatment were determined to be
required during the TS. The first stage of treatment will reduce
PCP from a level of approximately 20 ppm down to 1 ppm prior to
implementing the second stage which will reduce the PCP from a
level of approximately 1 ppm to 1.0 part per billion (ppb) or
below prior to surface water discharge. Evaluation of several
technologies determined that biological treatment followed by
treatment in an on-site water treatment system will be effective
in meeting these cleanup levels.
5.4.3.1 Biological Treatment of Contaminated Washwater
The function of biological treatment is to remove organic matter
from the waste stream through microbial degradation.
'Treatability test results iridicated'that biological treatment of
PCP-laden process water could achieve" removals of PCP from
~ influent concentrations as high as 25.ppm, down to less than 1
'"'ppm. It was also reported that performance remained consistent
throughout periods of .widely varying influent PCP .
concentration. This suggests that the biological system has a
capability:for self-regulation such that cycles of high and low
" iorganic loading do not necessarily produce 'poor quality
effluent.
.~,~
''';
" 0J...- ,'.
The .process -considered employs a submerged fixed-film reactor in
: 'which an acclimated microbial consortium is immobilized. The
biological process. requires--no' pretreatment or post settlement
for suspended solidsc-removal/-because the overall mass balance
showed an equivalent flux of solids in and out of the reactor.
..
. '
-15-
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The system can be operated with minimum attention since the
fixed-film system does. not require a biomass separation step or
recirculation.
However, biological reactors require stable operating
conditions. Maintenance of stable levels is crucial for a
number of key environmental parameters including:
o J,:>issplved oxygen (2 to 4 mg/l minimum)
o pH (7.5 to 9)
o Temperature (150 to 30 °C)
o Nutrient Ratio (COD/N/P=100/S/1)
o Alkalinity (provides buffering capacity).
.,
The biological treatment system wo~ld be designed to treat
process water with 20 mg/l PCP and 500 mg/l Total Suspended
Solids (TSS) at a flow rate of 20 gallons per minute (gpm). The
required effluent quality should contain less than 1 mg/l PCP
and no more than 500 mg/l TSS. The biological treatment system
in itsel~ will not reduce the TSS present in the process water.
Biodegradation of PCP by biological treatment has been
demonstrated to be effective. The TS determined that PCP
concentrations were reduced to undetectable levels from initial
levels ranging from 10 ppb to 100 ppm with 48 hours of
biological treatment. PCP removal is most effective between
150 and 300 C and between pH 7.5 and 9.0. Inoculation of
water with as few as 105 cells/ml of Flavobacterium resulted
in effective PCP removal. It was also reported that maintaining
proper alkalinity in the bioreactors might be a problem because
PCP biodegradation releases hydrochloric acid. Thus, pH
adjustment is needed for the treatment system. .
For on-site biological treatment, modular treatment units are
available from a number of vendors. Aeration equipment and
plastic tower packing are also readily available from numerous
vendors. The chemical feed systems .and chemicals needed for pH
adjustment and nutrient additions are also available in modular
units for easy installation. At least one vendor could supply
PCP-degrading strains of Flavobacterium. The system can be
operated with minimal attention. ~hus, the implementation of
the biological treatment at the site appears promising.
5.4.3.2.
Treatment at the On-Site Wate~ Treatment
System .
"
.t Treated effluent would be pumped to an on-site water treatment
- system for further treatment before discharge to the surface
" water. The on-site water treatment system, would be designed
for 120 gpm, which would be adequate to receive the 20 gpm soil
wash water along with the groundwater from recovery and
dewatering wells. Also, the on-site water treatment system is
equipped with GAC adsorption units. Thus the sufficient removal
-16-
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of PCP to meet the surface water discharge criteria would be
achievable without substantial additional capital expenditures.
However, the discharge and treatment of 20 qpm PCP-laden soil
washwater would cause an increase in the operating and
maintenance costs for the groundwater treatment system.
5.5 . SnmmAry of the Proposed Remedial Technologies for Soils
and Washwater
The following discussion presents one approach to site
remediation consistent with the TS results, which is based upon
the volume of material to be treated at the site and the
criteria set forth in the "Guide for Conducting Treatability
Studies Under CE~CLA -Interim Final." This approach involves a
technology train incorporating both biotreatment and S/S,
applied to the different fractions of the waste and wastewater
as follows:
o
Soils from the site would be pretreated using a soil
washing system to move PCP into the aqueous phase.
Cleaned soi1 fractions (anticipated 95% of the initial
volume) would be replaced into the excavated area.
PCP in the aqueous phase from the soil washing
pretreatment system would be treated in bioreactors.
Strains specific to biodegradation of PCP used as
inoculum and biological degradation along with
polishing by a GAC system could be used to achieve
cleanup criteria.
o
o
Residual fines (and woody residue from some areas)
would be subjected to stabilization. Concentrations of
PCP in this fraction are expected to be higher than
those found in the initial feed soil but, based on a
linear extrapolation, should meet the overall cleanup
standard in terms of TCLP testing after stabilization.
Stabilization reagents and mixtures will be optimized,
during the RD, with regard to both the physical
properties of the stabilized waste, and its leaching
characteristics. . Chlorinated dioxin, if present, are
.highly likely to be ~obilized by this process. .
However, additional testing would be required to assess
both short-term and long-term effectiveness. This
additional testing would be performed as part of the
pilot treatability 8tudy.
. ,
~.. -
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. ". .
. .
.. ~
- .
-17-
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6.0
SUMMARY OP SITE RISKS AND CLEANUP GOALS
CERCLA directs that the Agency must protect human health and the
environment from current and potential exposure to hazardous
substances at superfund sites. In order to assess the current
and potential risks for the Coleman Evans Site, a RA was
conducted as part of the RI/FS. This section summarizes the
findings concerning the risks from exposure to soil and
groundwater related to the site.
E' 6.1
'Human Health Risks
6.1.1
Contaminants of Concern (Indicator Chemicals)
A relatively small number of chemicals were detected at higher
than ambient concentrations at the Coleman Evans Site. The 1986
Risk Assessment found PCP to be the only contaminant of concern
at the site. Results of onsite sample analyses revealed the
widespread occurrence of PCP in the soils at the Coleman Evans
Site. Analytical results of on-site samples revealed levels of
PCP in the groundwater that exceeded the 1980 EPA Water Quality
Criteria (1.01 mg/l) in one borehole sample (BH-40) and two
existing well samples (EM-25 and EM-34). Groundwater associated
with this site is identified as a class II aquifer. Analyses of '
surface water and stream sediment samples revealed the presence
of PCP in the water and sediments of the drainageway leading
from the site to McGirts Creek.
The areal extent of PCP contamination in soil has been
identified. The highest concentrations occur in the vicinity of
the chemical tanks and the pit area, which are or have been used
to store the process wastes.
The depth of PCP contamination in the soil is variable across
the site. The highest levels generally occur at the 3-foot
depth, which coincides with the top of the water table. It is
speculated that PCP-laden fuel oil is floating on the water
table surface, and is spread over the 1- to 5-foot depth
interval as the water table fluctuates seasonally. However, PCP
can be found to a depth of 10 feet in the landfill area, and to
about 35 feet in the chemical tank and pit areas. The extent of
off-site PCP contamination within groundwater is limited to an
area approximately 200 feet south of the site, and occurs only
within the water table zone aquifer (boreholes 49 and SO).
These levels of PCP are below Pederal Water Quality Criteria,
and because PCP is not mobile in the groundwater environment,
the potential for future migration is low. No metals, .
polychlorinated biphenyls (PCBs) or Dioxins were detected in
off-site groundwater in either the water table zone or limestone
unit. .. .
-18-
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6.2
Ezposure Assessment SllIIIIIIAry
6.2.1
Identification of Potential Receptors
Potential receptors of site contamination located in the
vicinity of the Coleman Evans Site include the workers at the
Coleman Evans Wood Preserving Company, the residents of
Whitehouse, Florida, who live in the vicinity of the site, and
users of private water supply wells located downgradient from
the site..
Approx~ately15-20 people continue to work on-site as employees
of Coleman Evans. They are likely to come into daily contact
with contaminated soils.
Approximately six houses in Whitehouse, Florida; share a common
boundary with the site. . All of the residences in the vicinity
of the site use private wells as a source of drinking water. It
is estimated that there are 180 domestic wells within one mile
of the site and 1,620 wells within three miles. Several homes
are downgradient and very close to the site and their wells may
be candidates for contamination from wastes percolating into the
surficial aquifer system which supplies these wells. . The
Florida Department of Health and' Rehabilitative Services (HRS)"
has scheduled sampling of private wells within the ~ediate
.vicinity of the site.
6.2.2
Identification of Exposure Pathways
Based on considerations of potential receptors discussed above
and migration characteristics of PCP, the possible current
complete pathways identified in the RA are identified below:
1.
Ingestion and dermal contact with contaminated
.soil/sawdust.
Inhalation of airborne dust/sawdust.
Dermal contact 'with drainage ditch water.
2.
. . ..3.
,\ . 4 ..
In .addition, two potential ;future pathways were identified in
. the RAI
, . .
.-
. - ...:........:, oo("J'~ 4' ~.. . _. -'$ "'-. .. .
1. Ingestion of contaminated :ground water.
..;;.. " ,2..' ~I~gestion of vegetables. grown in contaminated soil.
.~ ~,... "-.' '.'" '-. ~ .::~. ~'. . :"''''~'.:;_:~~.'u. : .. .
",.potential exposure levels were'determined for each pathway based
-,,".:;.< ;on the mean .and maximum :concentration .'of PCP detected in --
..
,'. ~.-19-
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TABLE 1A .
ASSUXPTIONS USED IN ESTIXATING EXPOSURE
TO COHTAHINAHTS va DIRECT CONTACT WITH
SOILS OR SAWDUST AT '!'BE COLEHAH EVANS SITE
Realistic Worldb
Case
Parameter -
Most Probablea
Case'
./,. 1.
<.
,
Frequency of contact
(chronic exposure)
2.
3.
Receptor
Average weight of
exposed individuals
5 days/week
50 weeks/year
5 days/week,.
50 weeks/year
4.
Concentration of
contaminants contacted
On-site workers
On-site workers
5.
Quantity of soil
contacting skin per
exposure event
70 kg
70 kg
6.
Percentage of
contaminants absorbed
through the skin
5.6 mg/kg PCP
2.9 mg/kg xylene
3.1 mg/kg PCP
4.2 mg/kg
xylene
7.
Incidental ingestion
of contaminated soil
per exposure event
1.5g
4.4 9
20%
20%
50 mg
100 mg
Percentage of ingested
contaminants absorbed
aUsing most-probable exposure scenario parameters and
most-probable (geometric mean) concentrations
busing realistic worst-case exposure scenario parameters and
maximum concentrations
..
~.
8.
100%
100%
-20-
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TABLE 18
ASSUXPTIONS USED IN ESTIMATING EXPOSURE
-ro CONTAHIMANTS VIA DIRECT CONTACT WITH
SOILS OR SAWDUST AT THE COLEHAH EVANS SITE
Parameter
Assumption
1.
Frequency of contact
(chronic exposure
8 hr/day, 5 day/wk,
50 wk/Yr
2.
3.
On-site worker
Receptor
Average weight of exposed
individuals
70 kg
4.
22 m3/day
Daily inhalation rate'
(during work only)
5.
Percentage of contaminant
in ooil dust absorbed
25%
6.
15 mg/m3
Air concentrations of particulate
matter
7.
Average concentrations of
contaminants in airborne
particulate matter
310 mg/kg PCP
4.2 mg/kg xylene
-21-
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6.3 ~xicity Assessment
6.3.1
PrLmary Contaminant-Pentachlorophenol
Commercial PCP preparations contain ~purities that include
hexachorobenzene, polychorinated dibenzofurans, and.
polychorinated dibenzo-dioxins. It is difficult to determine
the extent to which the toxicity of the commercial products are
due to PCP or to the very toxic ~purities. The PCP used in
comparative studies is generally free of impurities.
6.3.2
Qualitative Description of Health Effects
PCP is rapidly absorbed following oral, dermal or inhalation
exposure. Absorption following ingestion of drinking water is
reported to be essentially complete. Absorption following
inhalation has been reported to be in the range of 76-88%.
PCP is an uncoupler of cellular oxidation and phosphorylation,
resulting in an increase in the basic metabolic rate. PCP
poisoning in humans is characterized by a profuse sweating,
often accompanied by fever, weight loss and gastrointestinal
complaints. Liver and kidney involvement have been ~plicated
in cases of fatal poisoning. The major targets of PCP toxicity
seem to be the liver, kidneys, and central nervous system.
Reference Doses (RfDs) 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 estLmates of lifet~e daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking
water) can be compared to the RfD. RfDs are derived from human
epidemiological'studies or anLmal studies to which uncertainty
factors have been applied (e.g., to account for the use of
animal data to predict effects on humans). These uncertainty
factors help ensure that the RfDs will not underestLmate the
potential for adverse noncarcinogenic effects to occur.
The RfDfor PCP that was. used in the RA and is included in the
Agency's Integrated Risk Information System (IRIS) database is
.03 mg/kg day. .
_.
~;,
. ~~. PCP has recently been classified by the Agency as a B2
.: carcinogen. A carcinogenic potency factor (CPF) hat not yet
been verified. However, a CPF of 0.12 (mg/kg/day)- has been
~. proposed by the Agency's Carcinogen Risk Assessment Verification
. -Endeavor (CRAVE) Workgroup.
-22-
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6.4 Risk Characterization
The 1986 RA for this site evaluated the risk from PCP exposure
via the five pathways shown in Section 6.2.2. At that time, the
Agency had classified PCP as a systemic toxicant with a RfD
value of .03 mg/kg day. This PCP RfD value is currently in the
Agency's IRIS database. The calculated exposure dosages from
each pathway were compared to the RfD.
«
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's RfD). 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 potential significance of multiple contaminants within a
single medium or across media. In this case, PCP is the only
significant contaminant and the HI value would apply to this
single compound. (The RA also addressed xylene as a contaminant
at this site; insignificant levels of this less toxic compound
resulted in its elimination from further risk considerations).
All three current exposure scenarios yielded HI values well
below 1.0 indicating that no health risk would be anticipated.
However, both future exposure scenarios gave unacceptable HI
values. Potential future exposure (by ingestion) to the maximum
detected level of PCP in water from the surficial aquifer gave a
HI value of 12. The consumption of root crops irrigated with
this water could produce exposure to PCP in consumers at a HI
level of 4.
•
These potential future exposures to unacceptable levels of PCP
in groundwater plus the existing soil source of PCP discharge to
groundwater requires remediation of.this site.
6.5 Environmental Risks
Potential environmental effects may'also occur from contaminants
.observed in surface waters associated with the site. The
surface water levels of PCP indicate that the site poses a
threat to aquatic species. During the remediation process,
drainage ditch soils which exceed 25 mg/kg will be excavated and
treated in accordance with the proposed remediation plan.
Remediation of the soils will ultimately prevent any potential
adverse environmental impact.
-23-
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6.6 Cleanup Criteria
6.6.1 Soils/Sediments Cleanup Goals
Following a review of additional data generated during the RD
phase/ EPA determined that the soil cleanup level for PCP
outlined in the 1986 ROD could be increased from 10 mg/kg to 25
mg/kg. The 1986 ROD 10 mg/kg cleanup level was based on an
estimated TOC pontent. In the RD phase, actual TOC measurements
were made thereby allowing the cleanup level to be increased to
25 mg/kg. The increased 25 mg/kg cleanup level was selected
using the same methodology used to develop the cleanup criteria
in the September 1986 ROD. Safe levels of PCP are determined by
TOC content (plant and animal matter present in the soil). The
TOC content found was four times the earlier estimate. On the
basis of the new information, modeling determined that a 25
mg/kg PCP concentration would be protective of human health if
groundwater at the site, or vegetables grown in the surrounding
soil were consumed.
6.6.2 Groundwater Cleanup Goals
The 1986 ROD thoroughly addresses the remediation of groundwater
at the Coleman Evans Site. Requirements of the 1986 selected
action include two applicable groundwater criteron. The first
criterion established the cleanup level for PCP and metals
contaminated groundwater. This 1986 ROD cleanup level specifies
that all groundwater with PCP concentrations in excess of 1.01
mg/1 must be recovered and treated in order to protect local
drinking water resources. The second criterion applies to
discharge of treated water to the surface water environment.
This cleanup criterion states that all water recovered during
the remedial action, including waters recovered as a part of the
dewatering program for soils, would be analyzed prior to
treatment and discharge. If the of PCP level exceeded 1.0 ug/1,
the groundwater would be treated by an on-site GAC adsorption
unit to a level below 1 ug/1. Both PCP and metals cleanup
criteria would be in accordance with Chapter 17-3.061.3(m) of
the Florida Administrative Code, prior to discharge to the
surface water environment via the on-site drainage ditch.
-24-
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7.0
1986 ROD SOIL REMEDIATION ALTERNATIVES CONSIDERED
7.1
1986 ROD Alternatives
Soils Technologies:
1.
2.
3.
4.
5.
6.
7.
8.
9.
Excavation/OffsiteDisposal
Excavation/S/s
Excavation/Incineration
Solvent Extraction
Excavation/Thermal Treatment
Land Treatment.
In-Situ Biodegradation.
Contaminant and Encapsulation
Surface Capping
The selected 1986 ROD groundwater remedy of extraction with GAC
adsorption would remain unchanged in this AROD, and therefore
will not be further addressed.
7.2
Alternative Screening
This amended ROD will not attempt to re-evaluate each remedial'
alternative previously evaluated in the September 1986 ROD.
Table 2 presents the reasons why certain alternatives and
technologies identified in Section 7.1 were screened out at that
tLme. A complete evaluation of these alternatives are contained
in the 1986 ROD found in Appendix A of this AROD.
7.3
Alternative Previously Selected por Soil
The selected remedy for soils, as specified in the 1986 ROD, was
Alternative 3 - Excavation/Incineration. The selection of this
alternative is now being reevaluated as a result of additional
information regarding the nature and extent of contamination at
the site and changes in the relative costs of various remedies
since the ROD was, signed in 1986. " '" ',' .
-;: t~ , - . ,,:, !
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7.4
Developaent of Relledial Alternatives
, ,
While both bioremediation and S/S were not selected as viable
alternatives for the site in 1986, they now appear to
be viable alternatives. The basic rationale for the screening
out of bioremediation in the 1986 ROD was based on the the
production of more harmful by-products. In addition, it was
noted that extensive pilot testing and the time involved in
execution of this technology was protracted. The TS that was
performed on the contaminated media and waste streams at this
site indicated that the contaminated soil washwater was amenable
to biodegration. The resultant decrease in PCP was greater than
, ~
,." -~.,
'.~.
I .
-25-
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TABLE 2
SUMMARY TABLE OF FEASIBLE ALTERNATIVES
AND COST-EFFECTIVENESS COMPARISON
Remedial Alternative
Reason for
Non-Selection
Estimated
Cost Range
1. Surface'Capping
2. Stabilisation/
Solidification
3. Containment and
Encapsulation
4. Solvent Extraction
5. On-Site Incineration
6. Off-Site Disposal
t .
7. No Action Alternative
Implementation would not deal
permanently with the site con-
tamination although it provides
a high degree of protection to sur-
face water and air. Groundwater
contamination would remain. Restricts
site use.
This is a viable alternative, but
contamination would remain on-site
and long-term monitoring would be
required. Land use limitations.
This is a cost-effective option, but
contamination would remain untreated.
Greater environmental risk arises from
the potential for linear failure. Long
term monitoring and O&M will be required
This option is fully effective for
migration of all threats, but incine-
ration is equally effective with a
lower cost.
Does not remediate wastes, only
involves transport to a RCRA-approved
facility.
No remediation of site specific con-
ditions potential health and
environmental risks.
0.5 to 0.9
1.4 to 1.9
0.7 to 1.5
4.5 to 9.6
3.0 to 3.8
2.9 to 4.2
0.0
-------
95% within a 48 hour reaction time. The production of more
harmful by-products was not noted in the washwater. It is very
likely that harmful by-products such as dioxins would remain
bound to the fine woody. soil fraction along with the PCP. As
stated earlier, the fine woody fraction of the wastes is about 5
to 10% of the total contaminated soil volume or about 2700 cubic
yards. Based on literature studies, dioxins could be .
Lmmobilized effectively in the fine woody fraction using a S/S
process simil&r to that process conducted during the TS. This
is due to their low solubilities and high chemical stabilities.
Solidification was screened from consideration in 1986 based on
the facts that contaminants wOuld remain on-site, long-term
monitoring would be required and land use limitations would be
in effect. This option is now favorable due to the smaller
volume of soil fines to be remediated and the limited operation
and maintenance associated with it.
Incineration is still a viable alternative for the PCP
contaminated soils. Incineration is a proven technology for the
destruction of organic contaminants present in soils.
8.0 DBSCRIPTION OF RBMBDIAL ~'l'ERHATIVES FOR SOILS
REMEDIATION
Based on the results of additional studies that were conducted,
the following alternatives were re-evaluated for the site:
Alternative 1 - No Action.
Alternative 2 - 50il Washing/Bioremediation/ and S/S
~ternative 3 - Incineration
8.1 ~ternative 1 - &0 Action
Th~ no action alternative is required by the NCP to be
considered within the detailed analysis. It provides a baseline
for comparison of other alternatives. Under the no action
alternative, no source control remedial measures would be
undertaken at the Coleman Evans Site. Given the presence of the
contaminated source, natural soil flushing 1s not expected to
reduce soil contamination to below cleanup levels.
. The No Action alternative would noteltmlnate existing exposure
pathways or reduce the level of risk. Additionally, contaminant
"~~leachinq .to 'groundwater would. be allowed to continue, therefore
exceeding ARARs and cleanup' levels. .
~
b-
,~ ~--
..
-27-
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8.2 Alternative 2 - Soil Washing, Bioremediation and
Stabilization/Solidification
Pre-remedial action activities would include dismantlement and
appropriate disposal of on-site structures in the processing
area. Remaining on site wood treatment equipment would be
" properly addressed. The major activities in implementing this
alternative would include:
o
4, 0
,~.
",
'.
0
Excavation of 27,000 cubic yards of contaminated soils.
Soil washing followed by physical separation of the
clean sand and the fine woody wastes.
Biological treatment of the PCP contaminated water
generated from the soil washing and further treatment
of the bio-treated effluent at the onsite groundwater
treatment system prior to surface water discharge.
o
S/S of the fine woody fraction.
Replacement of clean sand and the fine woody wastes
.into the excavated area.
o
All soils and sediments with PCP concentrations exceeding 25
mg/kg would be excavated. During the RI and RD, soil
contamination was characterized in three areas of the site
including: the landfill area, the waste pit area, and
downqradient from the waste pit area. The volume of soil to be
excavated from these areas was estimated to be 27,000 cubic
yards.' .
The excavated soils would be screened to remove coarse debris
and then slurried with water in a soil washing circuit to
transfer the contaminants from the soil to the water. Soil
washing studies indicate that greater than 90% of the total
contaminated solids could be cleaned to below the cleanup
criteria of 3.6 mg/kg TCLP leachate of PCP and could be replaced
into the excavated area. The remaining less than 10% of the
fine woody fractions of the soil would require prior to
backfilling into the excavated area.
S/S would then be used to treat the remaining fine/woody soil
fraction which soil washing could not adequately address. The
~ end product of the S/S would retard migration of contaminants
~ out of wastes. Stabilization reagents might include cement,
".'..pozzolans, organophilic clays, asphalt/bitumen and,
'1 thermoplasticizers. The results of the treatability study
; indicated that the stabilized products from the contaminated
~ soil samples met both the specified strength parameters and TCLP
l~achate limits set for Coleman Evans wastes. The separated
".fine woody fraction of soils were not studied during the TS.
-28-
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The S/S formulation for the fine woody wastes would need to be
optimized to achieve the best results. This would occur during
the pilot treatability study.
The function of biological treatment is to remove PCP and other
organic matter from the contaminated waste stream through
microbial degradation. The demonstrated biological process for
effective PCP removal is a fixed-fill bioreactor which consists
of several.bialogical cells with submerged packed bed materials
for microbial attachment. Host of the process water used in the
soil washing process would be recirculated for reuse except that
an estimated flow of 20 gpm containing about 20 ppm PCP would be
constantly drained from the system. This contaminated process
water can be effectively reduced to less than 1.0 mg/L PCP
through biological treatment.
The biologically treated effluent would be discharged to the
on-site groundwater treatment system for further treatment prior
to surface water discharge. The on-site groundwater treatment
system will be designed to reduce the PCP and other organic and
inorganic compounds to below the Florida surface water discharge
criteria prior to discharge to the receiving stream. Also, the
on-site groundwater treatment system will be designed with
sufficieht capacity to accept the treated soils washwater
without modification. The on-site groundwater treatment system
consists of chemical precipitation followed by GAC adsorption.
The chemical precipitation process is used to remove metals and
suspended solids, while the GAC adsorption process is used to
remove organics contaminants including of PCP. Figure 4
presents the treatment train process.
8.3 A1ternative 3 - Incineration
This alternative requires the excavation and on-site thermal
destruction of PCP contaminated soils. Approximately 27,000
cubic yards of soil and sediment with PCP concentrations greater
than 25 mg/kg would require incineration.
. .
. .". -. .
A mobile incineration unit would be used on-site to destroy the
PCP found in soi18. The process would involve the use of
" primary and secondary incineration chambers. The contaminated
, soil would be fed into the treatment system where it would be
exposed to elevated temperatures and oxygen. The high
temperatures would drive off volatile contaminants which would
'c,..,. ~, ,then combusted in the presence.. of air:": PCP and diesel fuel
, ' would be converted to gaseous , phases in the primary chamber and
thermal destruction would occur in the secondary chamber. The
. . combination of temperature and residence time to which the soil
"'\";:~'Would be exposed would ensure" a 'decontaminated leachate level of
, . less than 3.6 mg/kg in the ~reated 80il. Decontaminated soils
would retain virtually", their ,initial volume and could be used to
backfill the excavated areas.
. -29-
-------
i~.
...
-
1':
~.
TJ
.,J.~.
~.
-
.2. .
rtl. .
,~~.',.;~/'j;"!~5"~;.:'£. -.
FIG. 4
PREFERRED SOIL REMEDIATION
REMEDY FOR COLEMAN EVANS SITE
.
CLEAN
SANO
BACKFILL
. (AT SITE)
EXCAVATION
.
SOIL
~
SOIL WASHING
/
PHYSICAL '.
SEPARATION
.
'"
MAKEUP WATER
!
RECIRCULATION WATER
WASH
WATER
20 GPM
20 PPM PCP
ST ABILIZEO
SOIL
FINE ORGANICI
WOOD FRACTION
SOlIDIFICATIONI
51 ABIUZATION
GROUNOWATER , 00 GPM
I
.' .;, .;;DeWATEAWG.
GROUND WATER
REMEDIATION
WELLS
'r
..
, ", -' :,"""ONSITE
GROUNDWATER
, TREATMENT
SYSTEM
:~..;- J ~..r.
. i:-
BIOTREATMENT
I
BIOTREA TED
EFFLUENT PCP., PPM
~d . . -. ~ .
..
.
- .~ -
SURFACE WATER DISCHARGE
(MEETS DISCHARGE CRrTERIA)
(30)
-------
SLmilarly, the combination off-gases would be treated before
being discharge into the atmosphere. Regulations require that
exhaust stack gases have particulate emissions not exceeding
10 mg/per dry standard cubic-meter, corrected to 7 percent
oxygen, and gaseous hydrogen chloride (HCL) emissions controlled
to 4 lb/hr or removed at 99 percent efficiency. The acid gases
are likely to be controlled by the use of either calcium
compounds blended with the soil feed or from a flue gas to form
a benign precipitate, ie., calcium chloride. Particulate
emissions may be controlled by several different devices, i.e.,
electrostatic precipitator, baghouse, cyclone, etc. The air
pollution control system, regardless of what method is used,
will produce either solid or liquid waste streams, or both,
which may require treatment before disposal.
9.0
SUKMARY OF COXPARATIVE ANALYSIS OF ALTERNATIVES
This section provides the basis for determining which
alternative provides the best balance of trade-offs with respect
to the evaluation criteria. A glossary of the evaluation
criteria is presented in Table 3.
9.1
Overall Protection of ~uman Beal th and the Environment
Alternative 3 was considered most protective since the PCP
contaminated soil would be thermal treated on site and it would
achieve unrestricted access of the site. Alternative 2, while
considered protective, would require long-term monitoring of the'
solidified mass ani vegetaiive cover. Both Alternative 2 and 3
are within the 10- to 10- cancer risk range and therefore
provide adequate protection by reducing or controlling the
threat to human health and the environment. .
"II
Alternative 1 provides no additional protection to either human
health or the environment. This alternative does not reduce the
on-site PCP concentrations through any remedial action. The PCP
concentrations within the soils and sediments would remain above
acceptable levels for an indefinite period of tLme. Therefore,
this ,alternative was judged to be the least protective.
.
9. '2'-Compl:iance with Applicable or Relevant and Appropriate
RequUemeDts (ARARs) ,.-_..,-...
Both Alternativeis-'2 land 3 would meet the respective ARARs as
,defined in Section 11.2 of this AROD. However, Alternative 3
would require compliance with a larger range of ARARs than .
Alternative 2, therefore increasing the monitoring requirements
during implementation. ~'v.£"Y~;:: .
Alternative 1 does not comply with ARARs.
r.. -:" ;'" .
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TABLE 3
GLOSSARY OF EVALUATION CRITERIA
Overall Protection of Human Health and Environment - addresses
whether or not a remedy provides adequate protection and
describes how risks posed through each pathway are elLminated,
reduced, or controlled through treatment, engineering controls,
or institutional controls.
..
.,
Comnliance with ARARs - addresses whether or not a remedy will
meet all of the applicable or relevant and appropriate
requirements of other Federal and State environmental statutes
and/or provide grounds for invoking a waiver.
Lana-Term Effectiveness and Permanence - refers to the
magnitude of residual risk and the ability of a remedy to
maintain reliable protection of human health and the environment
over tLme once cleanup goals have been met.
.1.
Reduction of Mobilitv. Toxicity. or Volume throuah Treatment -
is the anticipated performance of the treatment technologies
that may be employed in a remedy.
Short-Term Effectiveness - refers to the speed with which the
remedy achieves protection, as well as the remedy's potential to
create adverse impacts on human health and the environment that
may result during the construction and implementation period.
Implementability - is the technical and administrative
feasibility of a remedy, including the availability of materials
and services needed to implement the chosen solution.
Cost - includes capital and operation and maintenance costs.
State Acceptance -indicates whether the State concurs with,
opposes, or has no comment on the Proposed Plan.
Community Acceptance - the Responsiveness Summary in the
appendix of the AROD addresses comments received from the
public.
'"
:'
_.. .: ~
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9.3
Long-Te~ Effectiveness and Performance
Alternative 3 is considered the most eff~ctive from the
perspective of this evaluation criterion since the
PCP-contaminated soil would be permanently treated. There would
be no operation and maintenance activity associated with this
remedy. .
Alternative 2 ~s considered the next most effective in the
long-term perspective since only a small volume of the soil
fines and woody fractions would require 5/5. Therefore, long
term monitoring and maintenance would be required for the
solidified mass. The remainder of the clean soils from the soil
washing procedure and biological treatment would be placed back
on site. The soil washing process has been demonstrated to be a
feasible remedial action technology for treatment of PCP
cont.aminated soils at this site. In conjunction with 5/5, the
combined technology would effectively provide a permanent
~obilization remedy for the contaminated soils. The T5
demonstrated that the treated product from the site would meet
both the specified strength parameters and TCLP leachate limits.
Alternative 1 was the least effective in achieving the long-term
effectiv~ness and permanence criterion. No action leaves the.
potential risk associated with the site. soils in an unaltered
state. .
9.4 Reduction of liability, Toxicity or Volume
Alternatives 2 and 3 were considered effective in
evaluation criterion since all contaminated soils
concentration level of 25 ppm PCP would realize a
either MTV. .
this
above the
reduction in
Alternative 1 is the least effective since no reduction in
either MTV is achieved.
9.5 Short-'1'exmBffectiveness
~ternatives 2 and 3 provide short term potential for releases
of toxic emissions and residues into the environment. However,
the ~plementation of a health and safety plan would minimize
contaminant migration off-site during construction activities.
In addition, alternatives 2 and 3 would require dust control
measures during excavation of soils to minimize exposure risks
to onsite workers.
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Alternative 1 rates most favorably for this site criterion in
respect to adverse impacts on human health and the environment
that may result during the construction and implementation
period since no construction.activities would occur. However,
it is least effective in reference to the time in which the
remedy would achieve protection.
9.6
Implemen~ability
c Alternative 3 is a proven technology for the treatment of PCP
~. contaminated soils. It is technically and administratively
.t feasible to implement. Alternative 2 is considered the next
~ most effective under this criterion. Based on T5's, this
technology has a demonstrated performance record and should be
implementable. A pilot study to optimize the design of this
system would be conducted during the RD and is included as a
component of this alternative.
Alternative 1 is easily implemented since no action would be
required.
9.7
Cost
Costs to implement.Alternatives 2 and 3 were evaluated during
the T5. Both the June 1, 1988 CDM Cost Estimate Letter and the
August 1990 EBASCO T5 Addendum Soil Remedial Cost Estimate were
reviewed to calculate the costs.
The cost to implement Alternative 2 including ground water
treatment would be $5,887,172. The cost of adding a metal
precipitation and GAC adsorption unit would be $1,300,000.
cost of the on-site treatment system would be $1,380,134.
total cost would therefore be $8,567,304.
The
The
The cost to tmplement Alternative 3 including ground water
treatment would be $19,050,644. The cost of adding a metal
precipitation and GAC adsorption unit would be $1,300,000.
cost of the on-site treatment system would be $5,086,383.
total cost would therefore be $25,437,027.
9.8 State Acceptance
The
The
.-
t, The State of Florida has verbally concurred
~ this remedy. Upon receipt, . the concurrence
:;; inc luded in Appendix E.
. .~~
on the selection of
letter will be
.;- 9.9
CODDDunity Acceptance
.,
:,' The JacJcsonville community showed very limited community
interest during the public meeting and public comment period.
Responses to specific.icomments are.available in the'
Responsiveness Summary located in Appendix B.
-34-
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10.0 SELECTED AHENDED REHEDY
The selected amended remedy addresses remediation of soil
contamination by eliminating or reducing the risk posed by the
site, through treatment and engineering and institutional
controls~
The major components of the selected amended remedy include:
.-~. ~.
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"
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o
- . ,
Excavation of contaminated soils and sediments with
PCP concentrations greater than 25 mg/kg; approximately
27,000 cubic yards.
o
Volume reduction by soil washing to separate the clean
soil fraction from contaminated soil fines.
o
s/s of soil fines or sludges exceeding the cleanup
criteria;
o
Redisposing of the clean soil fraction and the "fixed"
sludges onsite.
Dewatering and recovery of groundwater to facilitate
excavation; treated ground water will be monitored for
compliance with 1.01 ug/l PCP and metals discharge
criteria in accordance with Florida's Chapter
17-3.061.3(m) Administrative Code. If the level of PCP
exceeds 1.0 ug/l, the groundwater will be treated by an
on-site GAC adsorption unit to a level below 1.0 ugll
PCP in accordance with Chapter 17-3.061.3(m) of the
Florida Administrative Code, before discharge to an
onsite drainage ditch leading to McGirt's Creek.
o
o
Treatment of the soil wash water by bioremediation
followed by a GAC polishing unit and metals treatment by
chemical precipation for discharge to an on-site ditch
leading to McGirt's Creek. .
Installation and maintenance of a 6-inch vegetative
cover over the solidified mass (monolith).
o
o
Installation and maintenance of a fence around the s~e
during remedial activities. ,-
o
Appropriate disposal of the on-site structures in the
processing area and closure of "the sand filter units;
Off-site contaminated soils would be remediated in
conjunction with the on-site remediation process.
o
Institutional controls would include deed restrictions.
;.' I
The t~e to~plement the 8ourcecontrol po'rtion of this
alternative is eXPected to be approx~ately 120 days. While
. the
- -35-
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groundwater component was included in the amended selected
remedy it will be implemented in accordance with the September
1986 ROD. The total cost of this alternative including
groundwater recovery and treatment would be $8,567,304.
11.0 STATUTORY DE'l'ERKINATIOH
EPA and FDER has determined that this remedy will satisfy the
statutory requirements of Section 121 of CERCLA as it provides
protection of human health and the environment, attain ARARs, is
cost effective and utilizies permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable.
11.1
Protection of Human Health and the Environment
The selected amended remedy is protective of human health and
the environment by eliminating the source of contamination and
treating groundwater.
11.2 Attainment of the Applicable or Relevant and Appropriate
Requirements (ARARs)
RA's performed under CERCLA must comply with all ARARs. All
alternatives considered for the Coleman Evans Wood Preserving
Site were evaluated on the basis of the degree to which they
complied with these requirements. The selected remedy was found
to meet or exceed the following ARARs, as discussed below.
FEDERAL REQUIREMEH'rS
Resource Conservation and Recovery Act (RCRA)
40 C.F.R. Part 261 Land Ban ~ The RCRA Land Disposal
Restrictions (LDR) enacted in the 1984 Hazardous and Solid
Waste Amendments (HSWA) require that RCRA hazardous wastes be
treated to Best Demonstrated Achievable Technology (BDAT)
~ standards. prior to placement into the land. At this site,
further investigation may determine that RCRA listed waste, K001
(bottom sediment sludge from the treatme~t of wastewaters from
wood preserving processes that use pentachlorophenol and/or F027
(discarded unused formulations containing compounds derived from
pentachlorophenol) are present at this site. Since these wastes
are listed RCRA Hazardous wastes, LDR may directly apply. If
this is the case, a treatability variance pursuant to RCRA
regulations will be used to set alternative treatability
variances for dioxin wastes. The cleanup methodology proposed
for this site will comply with the LDRs. Sampling for dioxin
will take place to ensure compliance.
-36-
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Clean Water Act/Safe DrLnking Water Act
EPA's determination of appropriate groundwater cleanup criteria
involved an evaluation of contaminant concentrations relative to'
available health-based standards. Such limits, including
Maximum Concentration Limits (MCLs) and Maximum Concentration
Limit Goals (MCLGs), Federal Ambient Water Quality Criteria
(AWQC), and Section 304 of the Clean Water Act (CWA) used as
prescribed- in 8ection 121(d)(2)(b)(i) of CERCLA, defines the
Safe Drinking Water Act (SDWA) respect~vely and will be met at
this site.
Federal Clean Air Act
The Clean Air Act (CAA) identifies and regulates pollutants that
could be released during earth-moving activities associated with
the excavation of soils on-site. The CAA Section 112 identifies
those substances regulated under the Federal National Emission
Standards for Hazardous Pollutants for which there are no
applicable Ambient Air Quality Standards. The CAA is an ARAR
and the regulatory standards of the CAA will be complied with
during implementation of the remedy.
Endangered Species Act
The selected remedy is protective of species listed as
endangered or threatened under the Endangered Species Act.
Requirements of the Interagency Section 7 Consultation Process,
50 CFR Part 402 will be met. The Department of Interior, Fish
and Wildlife Service, -will be consulted during remedial design
to assure that endangered or threatened species are not
adversely impacted by implementation of this remedy. There is
currently no information to indicate'that the site is visited or
contains any endangered or threatened species.
National ~is~orical Preservation Act, (~A)
The NHPA requires that action be taken-to preserve or recover
historical or archaeological data which might be destroyed as a
result of site activities. No information exists to indicate
that the Coleman Evans Site has any historic or archaeological
,signific8;nce. "", .
.
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Federal Occupational Safety and Health Administration Act
(OSHA )
The selected remedial action contractor will develop and
implement a health and safety program for its workers. All
onsite workers will meet the minimum training and medical
monitoring requirements outlined in 40 CPR 1910.
-37-
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STATE REQUIREJlERTS
Florida Administrative Code. Chapter 17-3
Water quality standards. for surface water and groundwater
affected by leachate and storm runoff from the site will be met.
Florida ~n~trative Code Chapter 17-6
Effluent limitations and operating requirements for wastewater
facilities treating contaminated groundw~ter will be met.
11.3
Cost Effectiveness
Cost-effectiveness is determined by comparing the costs of all.
alternatives being considered with their overall effectiveness.
to determine whether the costs are proportional to the
effectiveness achieved. Overall effectiveness for the purpose
of this determination includes long-term effectiveness and
permanence; reduction of MTV through treatment; and short-term
effectiveness. The new remedy will afford an acceptable degree
of long-term effectiveness, MTV, and short-term effectiveness. .
The present estimated cost of EPA's selected remedy is $6.2
million dollars. The selected remedy affords overall
effectiveness proportional to its costs such that the remedy
represents value for the money. When the relationship between
the cost and overall effectiveness of the selected remedy is
viewed in light of the relationship between the cost and overall
ef!ectiveness afforded by other alternatives, the selected
remedy appears to be the most cost effective.
11.4
Utilization of PeDDaDent .solutions and Alternati.ve
EPA believes the selected remedy is the most appropriate cleanup
solution for the Coleman Evans Site and provides the best
balance among evaluation criteri.a for the remedial alternatives
evaluated. This remedy provides effective protection in both
. the short- and long-ter.m to potential human and environmental
r~ceptors;is readily implementable, and is cost effective.
- .
Soil washing and.S/S of the soils and bioremediation of the
contaminated washwater represents a permanent solution (through
treatment) which effectively reduces andlor eliminates mobility
of hazardous wastes and hazardous substances into the
env ironment. .
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-------
~
11.5
Preference for Treatment a8 a Principal Element
Treatment of the contaminated washwater and soils will
effectively reduce the mobility of contaminants into the
environment. Therefore, the statutory preference for remedies
that employ treatment as a principal element is satisfied.
}"
-39-
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. APPENDIX A
1986 RECORD OF DECISION
(ROD)
~.~
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-40-
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RECORD OF DECISIOO
REMEDIAL ACTIOO SELECTIOO
SITE
Coleman Evans W:xJd Preserving Co.
Jacksonvil1e,-OUVal County, Florida
IXX:lJMEm'S REVIEWED
I am basing my decision primarily on the followi~ docunents which describe
site specific conditions and the analysis of effectiveness and cost of
the remedial alternatives for the Coleman Evans Site:
- Coleman Evans W:x:)dPreserving Co.
- Coleman Evans W:x:)d Preserving Co.
- Coleman Evans W:x:)d Preserving Co.
Selection,
- Public Health Evaluation, . .
- Agency for TOxic Substances and Disease Registry -Health
Assessment, .
- repartment of the Interior - Release fran Claims for Damages
to the Natural Resources Under OOI Trusteeship.
Site Remedial Investigation Report,
Site Feasibility Study,
S\.I1tT\a.ryof Remedial Alternative
DESCRIPTION OF THE SELECTED REMEDY
- All soils and sediments with pentachlorophenol (PCP) concentrations
greater than 10 ~/kg will be excavated; approximately 9000 cubic
yards. .
- Excavated soils will be incinerated in a temporary onsite incineration
uni t . '!he soils will be decontaminated in a primary chamber where PCP
and fuel oil will be driven off in a gaseous phase. '!he PCP will be
thermally destro}ed in a secondary chamber. Incineration will be
undertaken in accordance with federal, state, and local laws. A
detailed Quality Assurance/Quality COntrol plan will be developed
. _during the temedialI2sign.
- recontaminated soils will be backfilled onsite.
- Gro\J'd water recovery will be conducted for dewatering to facilitate
excavation and to treat ground water with PCP concentrations greater
than 1.01 nrJ/l. Recovered ground water will be stored and analyzed.
If the level of PCP exceeds 1 ug/l, the grol.rld water will be treated by
an onsite carbon adsorption unit to a level below 1 ug/l PCP in accordance
with Chapter l7-3.06l.3(m) of the Florida Administrative Code before
discharge to the surface water environment via. the onsite drainage
ditch. If EPA pranulgates further regulations in the future which are
more stringent than those outlined in this ROD, the future regulations
will be observed. ': .
-------
- Other incidental Hazardous SUbstance List carpounds identified in gramd
water during the irrplementation of this rer.edy will be cleaned up to
levels W'liCh cx:rrply with Drinking Water Standards. If the Drinking
Water Standards do not address these cul~ds, clean up will be consiste.'1t
wi th the hU'lBn health criteria identified in the 1980 Water QJ.ali ty
Criteria. Clean up of carp::unds for ~ch no standards exist will be
to na1~etection levels. In cases ~ere staIxiards prarulgated by the
State of Florida are rrore stringent, the State starx1ards will have
precedence. .
- DJe to the CCI'Iplete destructioo of site specific contaminants by
incineration, no post-renedial rronitoring or operations arrl rraintenance
activity is required.
DEX:'IARATIONS
Consistent with the Catprehensive Envirorrnental Response, CaTpensation,
and Liability Act of 1980 (CERCIA), and the National Contingency Plan (40
CFR, Part 300), I have determined that the above Description of Selected
Raredy for the Colemm Evans Wcx>d Preserving Co. Site is an effective
renedy and provides adequate protectien of p.Jblic health, ~lfare, and
the enviroment. 'the State of Florida has been consulted and agrees with
the approved remedy. 'these activities will be considered part of the
approved action and eligible for Trust Fund rraUes until renedial action
is ccrrplete. ''!he basic asS\.I'IPtion is that EPA will undertake
inplemmtation if the resp::>nsible parties fail to undertake the design
and ilrt:>lenentation of the selected remedy.
I have also determined that the actioo being taken is apprcpriate when
balanced against the availability of Trust Fund rrcnies for use at other"
sites. In addition, the selected reredy is rrcre pernanent than other
renedial actions, and is necessary to protect. public health, welfare or
the enviroment.
If additional renedial actioos are detennined to be necessary, a Record
of Decision will be prepared for approval of the future remedial action.
','
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SEP 2 5 1986
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SErrIOO I .
SITE LOCATIOO ~1) DESCRlFTION
The Colerran Evans WoOO. Preserving CaTpany (CoIE!'T'aI1 Evans) is located on
Celery Avenue in Whitehoose, D.Jval Ca.lnty, Florida (Figure l). The
site is an active ll-acre ~ preserving facility W'hich uses pentachloro-
phenol (PCP) as a ~ preservative.
o .
'!he Coleran Evans site is ~I~ed of two di~tinct areas. The first area
catprises the 'WOOd treating facility and is located on the western portion
of the prc:perty. The eastern portion is a landfill area which has been
used for disposal of 'WOOd chips and other facility wastes.
1.
Site surface features include boO unlined disposal pits, which 'Nere partially
reroved in July 1985 under an EPA errergency response, and the active ....ax:l
treatzrent facilities. The treabTent system is carposed of a large pressure
chamber, several tanks for storage of the preservative fluids, a sand
filter system, and several storage sheds.
The Colerra.n Evans site is relatively flat, with less than 10 feet of relief
over the entire site. The site drains into a ditch \Iohl.ch eventually enters
into a swartpy area to the sooth, and then into McGirts Creek.
wi thin a 1-mile radius of the site, land use is primarily residential and
light ccmrercial!industrial. CX1tside the l"inile radius, the area is
prilrarily undevelcped rural land.
locally, there is no central water supply, thus approximately 1000
residents rely on groond water resoorces for their drinking water source.
SUrface waters in D.Jval County are used exclusively for sport fishing and
recreation. Pqriculture near the site is limited to snell gardens. The
only natural reSC1lrces are the surficial aquifer system and Floridan
aquifer.
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SEX:TIOO II
SITE HIS'roRY
OPERATIc:NM, HIS'roRY
Since 1954, Colenan Evans has produced preserved wood products which are
inpregnated with pcp. '!he treatment process incllrles steaming, dzying,
and pressure sOaking the wood, all within a single chaIiber. '!he wood
products are ilrpregnated with PCP c;lissolved in #2 diesel fuel.
Prior to 1970, the process effluent was precipitated with caustic soda
am aluminum sulfate, passed throogh a sand filter, am disd1arged into
the msite drainage ditch. . '!he recovered sludge was deposited into ~
unlined pits onsite. '!he pits, located almg the soothern romdaIY, were
approximately 100 feet by 50 feet am extended to unkna-m depths. In
1970, Colerran Evans beg?-'1 storing the sludge in storage tanks located
ad jacent to the pits. At this time, the c:nrpany engaged an engineering
finn to design a \l\8ste water treatzrent system. TreatJTent of the effluent
with d1lorination and lime precipitation was adopted to produce a clear
waste water.
In September 1980, the City of Jacksonville Bio-Environrrental Services
Division (BES) confinred the presence of ground water contaminatioo 00 site.
As a result, Colenan Evans incorporated an activated carbon filter system
into the treatzrent process in late 1980. In 1981, the catpany corrpleted the
construction of a closed-loop treatment system.
PER-1IT AND REnJIATORY HISTORY
In June 1972, Colenan Evans received an Industrial Operation Pemit fran
the State of Florida Department of Air and Water Fbllution Control. '!he
penni t was for design am cp!ratioo of a 2500 gpd industrial waste
treatrrent system and for discharge of effluent to ~rts Creek via the
onsite drainage ditd\. A renewal pennit was issued in Septerrber 1977 and
expired in August 1980.
A National Pollutioo Disd1a.rge Elimination System (NPDES) Pennit was
issued to Colercan Evans in Au9JSt 1975. Upc:n institution of a closed-loop
system, the carpany al1a.1ed this permit to expire in August 1980. EPA
fonmlly inactivated the NPDES pennit in June 1982.
In NoVl!l'l'b!r 1980, O:>lEl'lBn Evans filed a Part A EPA Hazardous Waste Permit
ApplicatiCXl as required under Section 3005 of !eRA. In its application,
. '.the carpany stated that with the closed-loop system there was a capacity
for storing 2000 gallCXlS of waste. '!he estinated annual quantity of
..hazardcus waste generated was ;:.~~gall~." ~.. .,.. .
After BES confirned the presence of gramd water oontamination, O:>lere.n
Evans was served a lIbtice to CaTply for violatioo of ground water standards.
It was under this lX'tice that O:>lere.n Evans submitted plans for the existing
closed-lcq:> system. In an-effort to remedy violations, the ccrrpany
~
-------
slbni tted a plan and schedule for construction of the closed-loop system
in April 1981. The Florida Department of Environmental Regulation (FDER)
issued a construction permit in June 1981.
Also in 1981, an FDER Inspection found that Coleman Evans was in violation
of RCRA hazardous waste reporting, planning, and safety requirements.
FDER issued a Consent order in November 1982 which required Coleman Evans
to implerrent a plan for sampling, analysis, tt.::mitoring, and reporting.
The company hired a contractor to assist in meeting the terms of the
Consent order. Final reports were issued by AlQust 1983.
A further Site Inspection was conducted by mER in April 1983. FDER
found that Coleman Evans was a generator and storer of hazardous wastes,
and was in violation of RCRA requirements. As a result, FDER required
.. Coleman Evans to sutmit an application for a Temporary ~ration Fermi t
by April 19, 1983. ~ application was sutrnitted. In September 1984,
FDER filed a lawsuit against the canpany, seeking relief which would
require the canpany to conduct remedial activities at the site. The suit
is still pending.
In October 1981, the Coleman Evans site was proposed for inclusion on
the National Priorities List (NFL) based on an Hazard Ranking Score
of 59.14. The site was finalized on the NPL in March 1983.
In September 1984, EPA obligated funds for an RI/FS. By October 1984,
EPA had tasked Camp Dresser and McKee, the REM II contractor, to execute
the RI/FS. The field investigation was delayed by Coleman Evans' refusal
to allow EPA onsite to conduct the rerroval and remedial activities. As a
result, EPA and OOJ filed a JOOtion in Federal Court to obtain an order
granting site access. By June 1985, EPA and its agents were granted site
access and field operations were initiated.
In an Inmediate Rem:>val Action, EPA excavated the contents of the two
unlined pits, and the pit material was shipped to £)nelle, Alabama. This
action was conducted in June and July 1985. The pits were backfilled
with clean material arrl french drains were installed.
The Remedial Investigation Report was completed in April 1986 and the draft
Feasibility St\.dy was ready for release to the public on July 21, 1986.
, .
'.
" :A p\bl1c meeting to present the FS was held on AlIJust 7, 1986. The public
"meeting was the initiation of the public oamment period which closed on
August 28, 1986.
~---:Due'.to-the fact that Coleman Evans is an active facility which periodically
" ,.:~~ "-continues to have releases of hazardous substances, EPA requested that.
Region IV RCRA personnel perform a site inspection. The EPA inspector
folnd several RCRA infractions: however, the infractions identified are
being addressed in the State of Fiorida's lawsuit. EPA will continue to
roonitor the RCRA aspects of this site.
.. ~ .
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(4)
-------
PREVIOOS mJDIES
Several site investigations were conducted between 1980 and 1983. Studies
of air, soil, ground water, surface water and sedirnents were conducted by
federal and state agencies, as well as two consultants to Coleman Evans.
DJring the period £ran August to December 1980, BES, FDER, Ecology and
Environment, Inc. (E&E), and NUS Corp. conducted separate soil and
ground wat~ st!;ldies. In Decerti:>er 1980, Law Engineering & Testing CaTpany
(LEro) installed and sanpled rrcni tor wells, soil test borings, and
shall"", soil auger holes. In June 1982, EPA 'conducted an air investigatioo.
using a photo-ionization meter (PI) and an infrared spectrophotc:meter,
and in March 1983, Groundwater Technology, Inc. (GTI) conducted a well
installatioo and sampling program at the site. In 1985, EPA subcontracted
with Haztech, Inc. to rerrove the contents of the oosite sludge pit. The
results are surmarized belON.
o Air Studies - Air investigations were conducted by EPA in 1982. None
of the measurements recorded ~ levels above 'background. The GI'I
investigation indicated that ambient air quality was within acceptable
levels «5.0 ug/l) except in a single borehole which had VOC levels of
14.0 ppm and in the area of the sludge pits where \0::: levels were
recorded to be 5.0 ug/l.
o Soil Studies - In 1980 LEI'C:) collected three soil borings on site,
h~ver, analysis was conducted on only t'NO of the sarrples. These two
samples indicated PCP concentratioos of 320 and 430 mg/kg. In 1983, GI'I
analyzed soil samples £ran eight locations. PCP concentrations ranged
£ran 11 mg/kg along the soothern edge of the disposal pits to 1, 490
mg/kg along the oorthern edge of the disposal pits (refer to Figure 2
and Table 1). In addition to PCP, chranium and copper were found in 5
locations in concentrations ranging £ran less than 1 to 15 mg/kg
(Table 2).
o Ground Water Studies - PCP contamination in the ground water of the
upper surficial aquifer was confirmed by the 1980 LEro) study, the 1980
E&E study, and the 1983 GTI study (Figure 3 and Table 3). Several
other organic carpounds 'NeI'e identified during the E&E and GTI
investigations (Table 4). Metals contamination was also identified
during these investigatioos: h~ver, only the E&E study found lead and
chrani\.l1\ above the 1980 Water Quality Criteria. Lead was found at a
concentratial of 105 ug/l in ncni.taring well M-l and d\ranium was found
at 300 ug/l and 1960 ug/l in wells M-l and M-2 respectively.
In the E&E study for EPA and in the 1983 LEI'CX) study, shallON auger holes
were also sarrpled far gramd water contamination. These wells, ~ch
range in depth fran 2 to 5 feet belON the surface, revealed PCP concentrations
in the ground water ranging fran 12 ug/l to 4,900 ug/l (Table 5).
Private wells 'NeI'e sarrpled in 1980 by E&E and by the Florida Departrre."1t
. ,.. of Health and Rehabilitative Services (tHRS). No contamination of private
wells was famd. This is primarily due to - the presence of a catpetent
confining unit within the surficial aquifer, bel"", which private wells
receive water, and to the 1"", solubility level of PCP.
~
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(5)
-------
LEGEND
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Figure 2.
HAND AUGER SAMPLE lOCATIONS (1980)
MONITOR WElllOCATlON$ (1883)
HAND AUGER SAMPLE lOCA nONS (1983)
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-------
Table 1. Results of Previous Soil Investigations for FCP Contamination
FCP
Depth Concentrations
Location (ft) Sartp1e By rate (rrg/kg)
B-1 3.5-5.0 LE'K'O 12/2-4/80 320
B-2 3.5-5.0 LE'K'O 12/2-4/80 430
P-1 0.0-3.0 GTI 3/4-14/83 <12.5
P-2 0.0-3.0 GTI 3/4-14/83 1,170
P-3 0.0-3.0 GTI 3/4-14/83 2,090
M-5 0.0-3.0 GTI 3/4-14/83 1,490
M-5 6.0-8.0 GTI 3/4-14/83 990
M-6 3.0-6.0 GTI 3/4-14/83 616
M-6 7.5-9.0 GTI 3/4-14/83 346
M-7 0.0-3.0 GTI 3/4-14/83 11.0
M-7 3.0-6.0 GTI 3/4-14/83 53.6
M-8 0.0-3.0 GTI 3/4-14/83 787
M-8 3.0-6.0 GTI 3/4-14/83 504
~,
~
(7)
-------
Table 2.
Results of Previous Soil Investigations for Metals Contamination
Co nee n t rat ion s
Locatioo tate O1ranilln (mg/kg) Co~r (rrg/kg)
5-1 3/83 4.94 4.01
5-2 3/83 3.97 1.42
5-3 3/83 4.69 1. 56
5-4 3/83 15.46 12.55
5-5 3/83 4.55 <1. 0
Scurce: lEIa), 1981
~
(8)
-------
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g r:~__~'m"-~;~~~;1i/-;!I- ~~n______----
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(-~~
LEGEND .
~EXI8TING MONITOR WELLS
. P-1 PRIVATE DRINKING WELLS
. A-1 HAND AUGER SAMPLE LOCATIONS
I-'iquru J.
Penldchlorophl'nnl GrolUul Will PI- ~;.\lI.d illq '~x'ill iOlls 1I~.;(~d ill l'II'vi,ItI~; IIIVI'~;' i.,.III""~;
of the CulemUi EVilllS Wood I'n!~.'lvill" COllp.IIIY Sill~.
j
-------
Table 3. Resul ts of Previoos Groond Water Investigations for fCP
Contamination.
pcp
Depth Concentrations
I.Dcaticn . (ft) Sanple By IBte (ug/l)
M-1 13 E&E 12/16/80 4,000
M-2 13 E&E 12/16/80 12,000
M-3 15 GTI 3/4-14/83 ND
M-4 15 GTI 3/4-14/83 1,480
M-5 15 GTI 3/4-14/83 332
M-6 15 GTI 3/4-14/83 1,370
M-7 15 GTI 3/4-14/83 525
M-8 15 GTI 3/4-14/83 714
M-9 15 GTI 3/4-14/83 560
M-IO 15 GTI 3/4-14/83 ND
M-11 15 GTI 3/4-14/83 ND .
M-12 14.5 IEro) 12/2-4/80 2,000
M-13 14.5 I.ZIU:> 12/2-4/80 3,200
ND - none detected
'.. .. -"
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(10)
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-------
Table 4.
Results of Previoos Ground Water Investigations for Contamination
1:1.i C1errii.cals Other than PCP.
Con c e n t rat ion s
in ug/l
M-l
M-2
M-3
M-4
M-5
M-6
M-7
M-8
M-9
M-10
M-ll
Naphthalene 15 16
Bis(2-ethylhexy1)phtha1ate 16 75 58.3 15.7 --
Di~~ylphtha.1ate 55.3 --
Anthracene 23
R1enanthrene 23
Phenol 170 680 41.5 12.9 -
'lbluene 86 300 14.3 --
Di-n-buty1 phthalate 10.6 - 10.6 --
F100rene 19.7 -- -- I
~horone 10.3 -
-- - nooe detected
Sa.1rce:
Ecology and Envircnnent, Inc., 1980 (MW-l and MW-2)
Groundwater Ted1no1ogy, Inc., 1983 (Wells Other 'lhan MW-l and MW-2)
~
(11)
-------
Table 5. Resul ts of Previous ~er fble Ground Water Investigations for
PCP Contamination.
. PCP
Depth Concentratioos
Locatioo tft) SartFled By tate (ug/l)
A-I 5.0 BF.S 9/9/80 537
A-2 3.0 BF.S 9/9/80 4,800
A-3 2.0 BF.S 9/9/80 12
A-4 3.0 BES 9/9/80 1,070
A-5 7.0 BF.S . 9/9/80 12
A-6 5.0 IErCO 12/2-4/80 4,900
A-7 5.5 IErCO 12/2-4/80 20
~
(12)
i
I
~
-------
o Surface water Studies - The 1983 GTI investigation documents the
existance of contaminated surface water runoff. During a rainstorm on
March 7, 1983, GTI collected two samples from the onsite drainage ditch
(Figure 4). The upgradient sample (5W-2) contained less than 10 ug/1 of
PCP in background runoff. The downgradient sample (~1 )yie1ded 1,760
Iog/l of PCP.
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(l3)
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SECI'ION III
CURRENI' SITE STATUS
Soils
Soil samples ~re collected fran seven 'Nell defined areas as shewn in
Figure 5. The ct:111ect.ion ,areas 'Nere based on operation sites. Sanples
'Nere analyzed by an oosite laboratory, a local laboratory, and a Contract
laboratory Program facility in a three-tiered quality control program.
'the areal extent of pcp C01tamination at a ooe foot depth, as shewn" in
Figure 6, inclooes the landfill area in the eastern portioo of the
site, a broad area east of the treatment cylinder, a broad east-west
trending area carprising the waste pits and storage tanks, and the north-
south drainage ditch -nid1 is south of the Colenan Evans property.
Al though the pattern of pcp occurrences is similar for ooth of the depth
intervals sampled, the 3-foot interval (Figure 7) was found to contain
the highest concentration. 'this is reasonable, because the PCP-laden oil
was observed to float on the water table,. which typically fluctuates fran
t\1\O to five feet belcw the surface.
'the vertical extent of contamination 'NaS identified fran soil sarrples
collected at 5-foot intervals fran 12 ooreholes (Figure 8). O'\ly
trace levels of pcp 'Nere found in boreholes located along the northern
p:>rtions of the site~ hOiever, boreholes 38, 40, 41, 44, and 49 encounterer.
pcp ccncentrations above background levels (Table 6). Generally, FCP
CCI1tamination was limited to the upper 10 fe.,::,: of the soils, except in
t\1\O ooreholes -nich showed pcp contaminatior. :'0 a depth of approximately
35 feet ~ hOiever, contamination found at depth did not exceed action
levels.
Several netals such as arsenic, cyanide, mercury, thallium, and vanadium,
'Nere also identified in onsi te soil sanples ~ hOllllever, the Public Health
Evaluation (Appen::lix A, FS) states that the metals occur at levels below
or within the nomal ranges foond in typical soils of the southeastern
lhited States. 'therefore, metals are not of concern at this site.
CLP data oonfinned the presence of oosite PCP contamination. The only
other dU.orinated pherx:>l detected in oosite soil was at sarrple location
D-50, ~d1 cx:ntained tet.rachloIqi1enol at an estinated cc:ncentratioo of
4,000 ug/kg. Additiooal organic contaminants detected include, rot are
. not limited to, a variety of napthalenes, alkanes, and xylenes, which
are thought to be associated with the fuel oil. "Also found was Aroclor
1254, a polychlorinated biphenyl, (ECB),..m.ch was foord at semple F-29 at
a concentration of 30,000 ug/l.
", Several sanples contained o...l(~ds that have been identified as possible
'laboratory contaminants. These inclooe acetone, methyl ethyl ketone,
methylene chloride, and bis (2-ethylhexyl) phthalate. .
':
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: AREA A - TREATED' WOOD 8TORAGE
AREA 8 - TREATED WOOD 8TORAGE
AREA C - LANDFilL AREA
ARE~ 0 - CHEMICAL TREATMENT AREA
AREA E - WASTE DISPOSAL PIT AREA
AREA f - DRAINAGE AREA
,AREA 0 - REMAINDER OF SITE
Figure 5.
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OINERAl AVENUE
Fiqure 6.
Pcntdchlor'ophenol Concentrations in Soils ..It a t1e(lth 01 (1I1t~ Flul.
J\1'eas with ('(mt.1chlorophenol COIlc(~l\t I...t iOl\s Gredtt'l' 111.111 I IIJI/k".
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(I.~. .~. t.~II.. I~~ .~.I~.,. \ .... ,.."...:;::; '-;';'.--""..I:~~,.- 0:. .18 ".
II"~-' ?l., 01.' 8e ,,- "04, : ....-""" ,..
L .' "'.~"--'.88M ,'u '\. :
..'. ......~ !!,!, ...i..J L--J 01 sn. -.. .... \ . 18~ 0'8'
"~~::L1;-40-0;;4 r --'-.'s.-;/ L' -- '5:---/-(-- -.' -SOUtH PAOPiHIV UHf
-.. ~ . /(. o.G.~'/
. ...0 '.0 04JOJ -
:. I I ;. .0.0
I 88M / ': 0 0.0 : HG£ND
I i 0.0 J . ,.L'. ,.41.11... _,-
I ..... l () - .... ..... .....
1::.1 t "... I . .~=.
, . .108Afot 'A..
::::, l I O.'U 0.0
.u
---..-- '---. ---- --~-_... ..- --"----- ---- -- --
.
Il~
U u.
G.". .
..--
..../
,.'
.,
-~
.
I.'
.
..... I
La_-L AMla
.
'8
.
,.n
"ACI
IU_.. UCIIC8I L_I
'C' tC8CI.I.al.. LOItIUU81
U_a.. __I
- -. ..- .__. ---.- - - ... .- - - -- - -----
OUI£AAI AVI.NU(.
--,--- - -.--',
'--I r'- -. --- .--.
- -- -.- -
,
..
, .
Figure 7.
PentachlorDl-'heool Conccntrat ions ill ~;.
Outline Areas with Pentdchlonlphellol
I ....t .... IA'pl1i III '('1111'1' j"I'C". (.,",....1',
1'1'''' r''''I'I''~. <:'1'.81.'/ 11..111 ( ml,'k...
,.-..
Uu
.
."'-
t..
'-"
uu
.
'
Y'"
. I I.~. .
. I J I
8H40 I
/
''1./,"
. .
/
/
. 00
rl
u.u
."",
.
,.
!
..
I
~..... ...... I
-------
(J\
r-i
o 0
oDD 0 ~ DO
n
I !;'
I -t
GO ...
.
CJ ...
-t
.
C::J ...
...
-t
BH36.
8H38
-="
----= --
[
AREA 0
- BH43
8H42
[
8H37-
.r .
o
...
r;; BH38
J8 "
..
~
<
~
;w
c
'"
~
o
--=
~
"
-' J
-.---
.1.
-" -
. 1 .
,
.-
]
,
,
,
'//
",.
LEGEND
AREA A - TREATED WOOD STORAGE
AREA B - TREATED WOOD STORAGE
AREA C - LANDFILL AREA
AREA D - CHEMICAL TREATMENT AREA
AREA E - WASTE DISPOSAL PIT AREA
AREA F - DRAINAGE AREA
AREA 0 - REMAINDER OF SITE
F I' Jill" II.
I~Jl\lliOIl Moll' 01 lI()rehule~ lI~d ru.' Soil ~:;'UI,,Jt~~ DIU"illq th.' 1-:1'1\ H"III',II..1
III VI .:;, I' I. II II III .
-------
Table 6.
Resu':ts :: PC? A.'"lal~'ses c: So:': Sa.r:;;:es C=:':'ec:=~ ==:r..
aor~~oles DurL~cr ~~e :?A ~~cial :~Ve3~:~a~::~.
- .
,.
~e .Cepth 0151 te PCP inS 0 i 1 ~q) DJp. Local
~. CN1te
Cede (ft bls) Lab Lab Lab Lab '=..¥
~
111-35-1 5 ~
111-35-2 10 ~
8B-35-3 15 ~
111-35-4 20 ~ ~
111-35-5 25 ~
811-35-6 30 ~ ~
111-36-1 5 ~
111-36-2 10 tr
111-36-3 15 ~ 0.04
8B-36-4 20 ~ ~
111-36-5 25 tr 0.06
III-~ 30 ~ ~
"'37-1 5 ti) ~
"'37-2 10 ti)
"'37-3 15 ~
...37-4 20 ti)
111-37-5 25 ti) ti) ~
111-38-1 5 1,025 585
111-38-2 10 37
111-38-3 15 205
: ~38-4 20 2.3
. "'~5 ZS 0.01
'.~"'~ 30 tr ~
""~7 35 tr 0.3
..38-8 40 tI) ;..."..1 '.
" '8-38-9 45 tr ~
--~10 50 U
... ' .
:s-4G-l 5 10 ~
... t~Z 10 .45
... . .~J 15 tr
,..
.. , ... C().-..C ZO U
, .. .CH" a :U ..,..~ .,".: ':'- ~'~_"::.:-".:- "'-' ....~..
..H 30 U ti)
'. .,-
.' .~~. . .
'-
'; .
(20) .
-------
Table 6 (cont.). Results of PCP Analyses 0: Soil S~les C:)l:sc-:ec =r:r..
aoreholesDuring the EPA Remedial I~vestigatlon.
SIIIple CIpth 01ai te PCP 1 n S 0 i 1 ~q) DJp . t.cc:al
~. .Clnaite '
Q:d8 (tt bl') LIb LIb LIb LIb a,p'
czp'
111-41-1 5 0.6 ~
111-41-2 10 tr
111-41-3 15 tr
!H-41-4 20 fC)
8-41-5 25 tr
111-41-6 30 fC) ,~
BH-42-1 5 fC) N)
111-42-2 10 fC)
111-42-3, 15 !IH
111-42-4 20 fC)
111-42-5 25 N) N) ~
BH-43-1 5 tr ~
BH-43-2 10 fC)
BH-43- 3 15 fC)
~, 111-43-4 20 fC)
BH-43-5 25 fC)
BH-43-6 30 fC) fC) N)
BH-44-1 5 2.1
BH-44-2 10 15.1
BH-44-3 15 0.9, <1.6
8K-44-4 20 M> 1.6
8K-44-5 25 7.0
8K-44-6 30 1.25 2.7
8K-44-7 35 JC)
~1 5 11) ~
8H 4&.- 2 10 JC)
8H t&.- 3 15 tI)
BH 1'-'4 20 tI) .
BH t&.-5 25 tI),
BH-46-6 30 11) M> ~
BH-49-1 5 tr 0.1
~9-2 10 1.1
BH-49-3 15 0.45 <1.6 O~54
, 1&049-4 ' 20 tr-
8H-49-5, 25 tr 0.3 fC)
':
(21)
-------
Table 6 (cont.).
Results of PCP Analyses of Soil Samples Collec~ec :=:~
Boreholes During the EPA Remedial Investigation.
~.
0xI8
D8pth
(ft bls)
PCP inS 0 i 1
cnsite ~. OWlte
Lab . Lab
(~)
LAb
~. Loc:aJ.
Lab
a.P
as-
t BII-~l 5 tr
1II-~2 10 tI)
--~3 15 tI)
111-50-4 20 tI)
BH-~5 25 tI)
111-50-6 30 tI)
BH-~ 7 35 tI) tr
l'I)
l'I)
l'I)
tr
Not Dttected AboY8 Dtt8c:tiCl'1 tJai t
trace «0.45 m;!kg) .
. .
-: ....'
. ,.~ . t '. .~.., # '..,.,..
~... .. c. ..; .
-..
, .
.."', '-. .
I;
(22)
-------
Surface Water a.nj Sediments
. SUrface W!ter and sediment sanples were colleCted at the locations sh~
in Figure 9. The background sediment sanple, SD-1S, taken upgradient
along McGirts Creek, was found to contain a suite of metals, which included
antirrony (69 mg/l), lead (11 m:;/kg), mercury (0.13 mg/kg), and nickel (31
mg/kg). The surface water sanple (9\1-15) collected at this "locauoo, was
estimated to contain 9 ug/l chranium. Nei ther sanple contained organic
CCITpOUl1ds above the laboratory detection limits (Table 7).
Analyses of stream and stream sediment sanples revealed the presence of
PCP in the water and sediments of the drainageway leading £ran the site
to McGirts Creek. Surface water concentrations near the site exceed the
surface water criteria established in Chapter 17-3061.3 (M) FAC, but
attenuate to below these criteria prior to reaching General Avenue. The
mechanism for this attenuation is probably a canbination of dilution in
water and adsorption to soils. Sediment sanples were found to contain
low levels of PCP south of General Avenue, and 00 indication of PCP at
McGirts Creek.
HYDRC:Xm)I.CCi
Groundwater O1aracteristics
At the Coleman Evans site groundwater contaminants were identified in the
upper portion of the water table zone of the Surficial Aquifer System.
The Surficial Aquifer System is catprised of three units: the water table
zone, the semi-ca1fining unit, and the limestone unit. In the site area.
private groundwater supplies are obtained fran the limestone unit which
is locally well-protected by the seni~fining unit. Groundwater flews
to the south and south west of the site.
Groundwater Ca1taminants
Groundwater sanples were collected fran 12 new rronitoring wells (Figure
10) a.nj 13 private wells (Figure 11). The well sanples were analyzed
under the CLP program, and. no oc:ntaminants except for methylene chloride
were foond, but it was identified a.s a laboratory contaminant.
New ncnitoring well sanple results are presented in table 8. The ooly
metals identified with concentratioos above existing standards were
. berylliun and magnesi\.8'l\, but based on the soils data, this occurrance is
believed to be natural. Several CCIIpOUnds were identified in background
wells and in blank water aanples and cannot be attributed to the site.
These CCIIpOUnds are bis (2-ethylhexyl) phthalate, hexahydroxepi.ncne,
acetale, and toluene.
~ - ~.
Several CCItpOUJ'1ds were identified downgradient £ran the site, but oot
oosite, carbon disulfide, 1,1, l-dichloroethane, and 3,3-dichlorobenzene.
-Finally, PCP was identified in four cnsite toreholes, rot only EIi-40
oc:ntained levels above the 1980 Water ()Jality criteria of 1.01 mg/1.
I:
(23)
-------
. -.,
, , ,
eo Ios,...--
.J
\ -+ :' -,':-:"7, ' ~.
-""'---...;.. ~
, ,...!''''. ~" ,;
- ..,r-,,"~
. , . , -
\ ~"''l. .....-
~~'. -
; "K, '",
c', _:~ '-1 \ ( I \ :.: ~' . ------ - -- - . , -;
~ .. II. I -" ~
I ' \,' :1
~ ; - , .
,.. .. ( . ',' -.". - - -. - -', . - .. ~ II
''':-. \ "'," . "',' -~:7 ~
I. ., . . eoo'
I ,,' . ' , ' ": '
. " -" ' \ " ~~ : .6 -.. . . I. 0" .. ~ .,
: .. ,: ,'I : ,', ' ,:.: ~l --... -' Ji,,' .. . ':"',' '.' -. -. . . - - - - ~ : -',
. \../8i I .' ,:_.0 ! / -.: ',~ I . .=i . ...Jh --:-~aeo. .":':':''''--- -- - ;:":'~~- - "=
r~'::,'''-~-i' \ 'J (),:.;~/;'o ..:~ ) t~t"l~ '11",~~1: :" COLEMAN EVANS:
-"" \, ~, '" \ r' ',"'': ;..~~ ~ ~~': 'r.: -~. ';;. _WOOD PRESERVING, '
~'.: ' " ~ " ' ;" ;- --.-- ~ :.~hit.'H.US~~" '-.;G~:~ _SITE '---',' ,
(I ., ., "'.. ~ -.. ~ '.--J
, " ' .: \ '~" \ :;. - -=t~:\ :~: ' \ .1. S {r.:C ' :, - - - , '.' .., r
' ',- \ :;. ~. . - \~.) . ..' "...' .'..,.' ~ -, .-:
./ ," ,\:8 -, ---~.: '- ,.; :-.", " AltO' ..."" ", .
, j"'~' -15 I , , " - ',-.
'!::!&!Hma.:./ J,,'-' ~. .."",:': "'-'" ..-- -"',.1' -- -
".,.", ',. -. - 0 - "~ ~ -_... --,:.--.,. --.....
. . 0 . -' ,', 0- -_.2.~ ~ ~-~ 0' '" '0 0 0 :,... ,,:r--, , . .
,.~: ' fo::~" ',- ....-" -_: .. :,;. ~~~J:\y . '~,-, , q .~ - -'- -
,,' .., ' (..' '\--;;..:~,..- ': ;,.,~ ,,:, -: -- 0 , .
. 'I . - a t""-
I :,/./ ~..- ~ '--. 'N -.-- - n '
~ "--. --- .' .. u.; . ,. ,I)
. . t: --: £ . '. , ' , - ,.. . I
, ..-::.-..'- . , ,.." ~ - -; - "81 ~ .' ' \:."'~:~ ': ..~. !\
1- , ,A'" ::".----- .' - ,.....: ..1.-,'-' ,
~: . -.:----_..~. '."'.'. ,:,".~l-'\" ,,', ',..
~: : :-_---~~r """""~b2' ................., .:~.;"'-':?-(' ~" . . '!ft'--", ~.'.'~'~'
o .'0 .,".':'- ":..--'~" o.""-':";".:::.":;."~~ .;~~'o -,... -. "..:' '.~' .'a. '.:' '."
, '" ' ~ -. - ~ - ~- -::: -- - ~ , ;:I£:,~ ' ,', -
,. : ~- ~ ~. ~' ~'
. '" "'" Z ... - . '..
" '.' : ' /~ ;::~-W-:2r' , ~ "51" ' ,', '. - _S.~-
/ -. .-.a 1.-...- U I ", .
;';"'-.~ . :.~':.,~ - . ~ /' . - - ~ - - - - I "\..'
., . .~ ,. '\. I' ---- - ... .. . - .1 -':1
I' '''," , ...... ., / Q~' '- -:.; =. -:: . L / I. - ~
"I .f"~...,. //' ., ..-'"
.:J i.1 I ". . 7' I ~- - - -.-.
'J." j ,_: " : '. : - --- I .' ~ -: - _:: . t, ~
.: .= .~ - -..- 2 . i .~ .. . . . ~. - - 0 j '- a .,.." 0 -0\ '.
. '. ,. , I, ,--
, ' ... - -
,~ / .~..' ..~. J::
/ C"
~- ,,-..-..,",...' ,,' \, ,j::~ . ~.; "il
. . -' - 0:.' ~ . . "'1.. ,-c.-
,." " I.. 'I .r ~ 'I
.' ''''''. .. .. ~,c:'\
'. .. I. ..." + =i
' '~.' ','/' ',~~~-,: ~.:, ~~~ '--\;'-=- -H
~...._.. ':SE "'P IS -. POIOTION Of' THE L-:: . ._-<:..,w~ 1. ' " .:'
U.S.G.S. MAftlETT A. FL.OIi'IDA SD- 1 e 0' I 000'
QUADftANGL.E 7.5 MINUTE SEftlES ~
.VA"..."" '-.AN. (PHOTO REVilED t 970) NORMANDY BL.VD
r'...'
l.
'I
-
'i,
I.:
- -
.
.. -
- -
- -
..'
---"-:9-
- -
..
.. -...: - 0,
----
"-
, ' '
~
, ,
-N-
~
~
Figure 9a,
IDeations at .which Surface Water and Sedirrent Sanples
~llected During the EP~2~ial Investigation,
VJe!"e
-------
, .
-
IV
U1
t LJ {
I , 0 D
oDD CQ DO
j,::-,~D
/
,-(iiiiii ,AVIMi('-
! if
18W~20 ClO
S0-20 Cl
~
..."
= -==
~
.'
ub4~~ i
~ ~-1.I"IU.u.UI,UJ 11 ...-.,.
, t. ...-~ '.=:::,- ~;-;,,-~n.uu:I",
.
~. - -- -. ..
.. . J~~WlD I
f .
I I'
~ tt~.:rJ
. tiiit '000 ljJ
I ~...
.
J
.. ;
.,
__0
.
-.-
~ SW-17
So-17
/
/
k
,
!1
,
,
I
,...... ......
......
OJ
[
/'" «::::::J
~-
i b
..
.
...
~ ~
It: '
-.--J
; l ~.. 0
~ --..--.----.-
11
. ,
LEGEND
---- - ------
SW-17. WATER SAMPLE
So-17 SED"ENT SAMPLE
-' j
. T
,I,
- .. -
'I'
,
,.. il/lln' ~)b.
IlJ(;at ions at which Surface Waler alld &"(Jim.~nt 's.:u'1d('!) \ooA'rt! ('olll-("I.d PlIli'l'l 'h,' ,
EI'1\ HI........fi,11 Imll!1o)thpt iJ::l1Io
-------
Table 7.
Analytical Results of SUrface Water SarTples Cbllected during tr.e
Renedial Investigation. Concentration Presented in ~crograms
per Liter (ug/l).
,<.
Sanple Lcx::ation Mmber
Si-1S 9'1-16 Si-17 9'1-18 5W-19- SW-20 S-;-21 g..; ~
-1-
Pentad\l.oro-
Phenol 4700x 77x 360x 3lOC
C-ll Alkene 3Ox*
Total. xYlenes 7.lX , 7. /
.
,.
Al\.lnin\.lT\ 870x I 790x I 640x 240x 570x I 600x 4lOx 200x
Ant.ina1y 6lx 58x 5Sx
Arsenic 6.5
.. Cadmi1.m\ 7x I 1
O1rani\.ln 9x 9x
Cob&l t llx
Ira1 880x 760x %Ox .36Ox lOOOx 430x
Ma esl.1.m\ l400x l600x 2800x 2800:
~''''' ;=: 1 29x I 27x I 2lx 1 1;1 2ax 33x 1~~ I 62x
1200:
Sl.lver 6x
Sodi \.In 6900x 4800x 20,000x 7000x 22,000x 21,00Qx 23,000x 83()())
Tin JlX 42x
Zux: 26x lSx lax 2lx 44x
...
x = estiDated value
* - tennatively identified oarp::und
(26)
~
-------
. .
1 :
: t ;
,.." '-,.: J ..~ ~ ;
"'-6 ( . . MW..;62 .: i. ..."...."u --=-" - ---- -:::.::..-
- ......-- - .. "uU II'" J1.,U 1=
.. -==.
~
-- WWlO
r~
i ~.=~... OJ
---
.r
MW-80
.
F i (JUn.! I 0 .
{
j u CJ
f"oo
{~ 0 [] N
o
I
J
_.--~::.::--
-~
-~
-.---
-.
-.-
. .
..:....-;---..----.........-
.--
.- . . .
.-
/
/'
I'
n
'.
Ii
[
1
[
J
~
J 11
MW-82l....-.v
'8MW-64
, I
rJ LJ
~
o
... . . - . --- - - ..-
. I
-' I
MW-688\
,,( N( RAI AvtJwUI
-
MW-67
.
-- - ---- .
MW-68
.
(~
. ~J
C-=:J
LEGEND
MW-81
.
.
.
.
LOCATION Of SHALLOW MONITOR WELL >
LOCA TION OF DEEP MONITOR WELL
LOCA TlON OF INTERMEDIATE
MONITOR WEll
CLUSTER WELL
t'
~. ~
,
,
,
'",'"
.,..
[-._-~ )
u.x:al ion Mdl' of New M II Ii lor iller
HCf1L'(jidl Illvesl iqdl iOIl.
\ I S III~; l. aI Il:d ,llId :;, UI. d,.d I JIll III' I t lit, 1.:1 '/\
. . .
-N-
. . .
,
..
~
.
...
:a
,
.
'"
...
~
-------
-~
. PW-2
.r
. , ;!:t::
.PW~ 1 1.- ---' ::=~::.:=:=:~-- ~ ).. "
&,,&'I'U~'~
'J&~~ ~~---.II~Uill~~~~.n"uuu:U::
c::--" -::::: ::::::::=u
.. .----.------.--------
-0'
~---:a~.!U.wCJ
'tt~
1 ~.;OJ
. .
.
I . PW-3
~ C=:::t
z
...
>
4
--.- --
-.~
[
]
E .,,- --....
" "
/ \
~// ,
~/ ,
/ ,
~ / LANDFILL,'
I ~ AREA "
" \ I
. , I
'1' --- ,
,.". ... ,
,-" ',-'
I
.
III L~
0\'" C.: *:'.1.~J ,
I
I ~W-6 I
Jtlt U PW-7 1pw-a oPW-I~ D
o !I pw-p,..plO, 0 ~
~-- ..' .____l.-- --.- J
-'--, G(H(""" AVOtU(
. .
. PW-14 \
..
~ PW-4
....
~
tJ
~
II'
~-- ~ ~
,I.
- H -
. 1 .
,
,
,
,
'//
..../
. PW-8
-------
Table 8.
Analytical Re!;iults of Gro..md Water Sanples Collected fran
New t-bnitoring Wells Installed D.1ring the Rerredial
Investigation. Calcentration Presented in Micrograms per
Liter (ug/l).
Well Identification Number
Ktl-51 ~-52 foItl-53 Ktl-54 Ktl-55 ~-S6
3,3-Dl.chloro-
benzidine
Carbon
Disulfide 11
l,l-Dichloro-
'-ethane
Alllninum 3100 I 410 880 380 1800 I 380 I
Bery~lium 6.0
Cadmium
Calcium 602~ I 89001 71 , 000 I 11.000 I 110,000 [
=um 18 30
Iron 790 2500 270 2000 470
Ma esiun 3200 3400
r * I 53.~1. 58 I 24~~1 37 I 17.~ [
6000x 2800x
Po+- "u'~i\m\
.... eru\m\
.Sodi\.m\ 22,000 I 26,000 I 89,000 I .18,000 I 40,000 I 19,000 f
Zinc 85x 23x 30x
.. .......--....~~ . "''''.''' .-,.... ....
x = estinated value
.. ;
""."';:""'~"''''''''''''',;,'');.'''r...,.;.-......
..- . ....
':
(29)
-------
Table 8 (cont.).
Analytical ~sul ts of Ground Witer Sartples Collected
fram New Monitoring Wells Installed During the
Rerredi.al Investigation. Concentration Presented in
Micrograms per liter (ug/l).
Well Identification Number
~-S7 t+J-58 t+J-59 t+J-60 ~-61 ~-62
3,3-D1.ch1oro-
benzidine 200
Carron
Disulfide a.lx 4.3x 6.2x a.6x
1,1-Dich1orcr
ethane 4.3x
Aluninum 810 440 550 ~ 860 1200 1400 ~
=lium 7.Ox
Ca um
Calcium 3800 I 3400 I 3600 I 3100 ~
=um 11 11 13
46
- Iron 4200 3600 2700
Ma esium 2500
~= 61 69 28 20 33 I
3100x 4800x 2800x 4200x 2700x 6000x
Selerutml 7.4x
Sodil.m 14,000 , 33,000 I 24,000 I 22,000 I 24~ I 36,000 t
Zinc 39x 2lx . 4lx 102x 26x
"
x = esti.nBted value
~
(30)
-------
SErrION IV
ENFORCEMENI' ANALYSIS
As ooted in Section II of this &xument, the Coleman Evans Wood Preserving
Catpany has been involved in litigatioo with both the State of Florida
and U.S EPA. In September 1984, Flcrida filed suit against Colsnan Evans
seeking relief''Nhidl would require the canpany to perform 00th short-term
and long-term remedial actioos at the site. That suit is ongoing and
has recently been arrerxied to include charges of violatioo of R:RA
requirements. In October 1984, EPA issued an administrative order pursuant
to Sectioo 106 of CERCIA, r8}Uiring CoIE!lTBn Evans to cooduct sanpling
an.1 perform imnediate rerroval activities. Coleman Evans refused to carply
with the crder, and denied EPA access to the site to perform the respa1Se
activities. Therefore, in March 1985, EPA filed a notion in Federal'
Court, seeking an order which would pennit EPA to enter the site and
CCX1duct response activities. That notion was granted and EPA conducted
an imnediate rem:>val actioo in J~ 1985.
I:Uring the public cxmrent period ~ich follCWed the release of the RI/FS,
ColE!lTBn Evans suanitted a proposal for remedial action at the site. That
proposal suggested treatment of the contamination by biodegradation. As
noted in Sectioo V, that alternative has been rejected due to concern
over the extensive time period required ,and the possibility of incarplete
digestion of PCP leaving a dioxin residue.
Upon finalization of the Record of Decision, the ~ intends to formally
notify the carpany of the renedy which has been selected, and initiate
negotiations with then for the conduct of the remedy. If the cxmpany
does not farnally exmnit to perform the remedy, and provide assurances
that adequate funding is available to CCIt1?lete the remedy in a timely
manner, EPA'will prcx:eed with a Fund-financed Remedial Design/Remedial
Actioo. .
It is inportant to note that inplementation of the remedy r~lII.ended in
this Sumnary of Remedial Alternative Selection may terrporarily disrupt
operatioos at the Coleman Evans Wood Preserving Catpany during the
in'plementatioo of the Remedial Actia'1. The extent of the disruptioo,
if ~, will be determined during design of the selected remedy.
~
-------
5EX:TION V
ALTERNAT IVES EVAIl.IAT ION
PUBUC HEAL'IH AND ENVIRCN-tENl'AL OBJECI'IVES
Public Health.. The public health threat posed by the Coleman Evans 5i te,
as identified in Public Health Evaluation (Appendix A, FS), is minimaL
'. Several exposure pathways are CXlTplete including. physical ccntact with
! the contaminated soils, sa'Ndust, and surface waters, inhalatioo of airborne
y: particulates, and the potential for ingestion of CO"ltaminated ground
:' water. The Public Health Evaluation fomd that the site currently appears
to pose significant health threat based 00 the levels of CO"ltamination
which were identified in the Remedial Investigatioo, but potential exposures
are a risk. .
Environmental Ca1cerns. The surface water levels of PCP identified in
. the ren-edial investigation indicated that the site poses a threat to
aquatic species. Unless the PCP runoff into the drainage ditch and
ultimatel}: into McGirts Creek is prevented, there is significant
:..potential for adverse envirOl1lt'ental inpact.
Alternatives Considered
Several alternatives were considered for remectiating the Colenan Evans
site. The alternatives were presented in groups targeted at remediating
a single aspect of the site. Table 9 shJws the technologies identified
for remediation of the ground water contamination (Grc:up A alternatives),
and technologies considered for remediation of soil ccntaminaticn (Group
B alternatives).
Several c:x:rri::>inatioos of group A and group B alternatives will provide
ren-edial actions which catply with applicable environmental laws. One
exanple is a oc:Jt'binatioo of ground water recovery and .treatment (Group
A), and containment/encapsulation (Group B). Ground water recovery and
. treatment will respood to issues raised under the Clean Water Act (~),
the Toxic Substances Ca1trol Act (TSCA), and the ~source Conservation
and Reoovery Act (R:RA). These same laws are also addressed by containment
encapsulatia'lof the landfill material.
," Screening of Tec!luologies
,-;: Potential remedial alternatives identified for the Coleman Evans site
1- were initially screened en the basis of technical feasibility and level of
", protectien provided to public health. Far exarrple, biological degradatioo
of PCP was eliminated during the initial screening phase because of the
':'protracted time frame necessary to aCOCltplish cleanup and because incarplete
~'ClegradatiQ:l can lead to a residue of dioxin in the 8Oi18. Similarly,
. therrral treatment was eliminated because this technology does not provide
any additiooal effectiveness <:::CIt'{)ared to incineration of soils and it is
not cost effective carpared tcT incineratien.
. ~
-------
Table 9.
Technologies Considered for Rerrediation of the Coleman Evans Site.
A.
Ground Water Technologies (Group A Alternatives)
B.
1.
Trea tment Technologies
a. Flocculation, Seciirrentation, and Filtration
b. . Activated Carbon Adsorption
2.
Recovery and Disposal Technologies
a. Rea>very. .
b. Surface Water Discharge
c. Ground Water Red1arge *
Soils Technologies (Group B Alternatives)
1.
Treatment Technologies
a. Off Site Disposal
b. Solidificatioo and Stabilization
c . Incineration
d. Solvent Extractioo .
e. Thermal Treatment *
f. land Treatment *
g. Insi tu Biodegradation *
h. Cattaimw!nt and Encapsulation
j. &n-face ~ing
ReaJvery Transpcrt
a. Excavation
b. Transpcrtatioo
2.
(*) . Deootes technologies MUch were eliminated during the
. . lX'elim:i.nary .screening phue.
..
.;. '" .
. .
'. . .~.. .
", ......- .
_.~ "" "-..'" -
.; ..........,...':.'
.;,..' f'" .-:,.:", "'.'" - ' -
,"' ''''''.,r' .
-r~
. . :.: .~~ ~_'-: .
, .
..
:?;:~_'r ~- - ~..t~:-c.:~ -It: - ~:Jt....:.:'. 'f <)'~
... .'2 ~ ._.;.: ":3- -" r.:-~-:".."
. ,'.
... ...- -....
- . . "";'.'"'. ""¥,.
.... ~... .........,~ -.
. . t";
~
(33)
-------
The next phase of alternatives screening was based on a detailed review.
of each remedial alternative based on site specific criteria. The second
phase review CCI'18idered technical feasibility, the level of public heal t..'1
and envircunehtal protect.ionprovided, and on Q relative cost-estirT'ate
basis. The alternatives eli.rninated during this phase are listed in
Table 10.
The alternatives which were retained after screening were then described
in detail with regard to engineering considerations, equipment needs,
operation and maintenance needs, rronitoring requirerrerits, health and
safety, permitting requirements, scheduling projectioos, and cost estimates.
Technologies Eliminated
Several alternatives were elirninated in the preliminary screening phase
and in the detailed screening. The follCMing is a list of remedial
cptions which 'Nere eliminated during the screening phases and the reasons
for elimination.
Gt'ound Water Technologies.
Groun:1 Water Recharge. rue to the locally high water table, ground water
recharge of recovered grourxi water 'NOUld likely flood the surface
envirament. This alternative was eliminated in favor of discharge to
surface waters. -
Flocculation, SediJtentation, an;j Filtration. This technology is feasible
and the risks to 'NOt'ker safety and the envirament are short-term.
HCMever, carbon adsorption was found to be Equally feasible and had none
of the short-term risks. Therefore, this remedy was screened out in
favor of carbon adsorptioo. .
Soil Technologies ~
Therrcal Treatment. Thermal treatment was eliminated because the effective-
. ness of this ted1nology is .equivalent to incineratioo, but incineratioo
is significantly mre oost effective. ...-'
Land Treatmmt.. This technology requires a large land area, extensive
rra.terial traMlpOLt. and handling, am extensive rrcnitad.ng. Other
t.edmoloqies identified have fewer irrplementatioo CCI'18traints and are
:equally effective.. " .~.' . .
- .
In 5i tu - Biological Dest.ructi~:' .', .1nCXItPlete i-a.i.gestioo "of 'pcp OOlld leave .
dioxin by-products. Biological treatment requires extensive pilot testing
:,and the time involved in executi.oo of this .t~logy is protracted.
.. ~ ....-~:. ..- ~...~'~\-:..~~._..~;~~:::~...u:.::. ..:.. ", :.. .-.. '...:... ,"':. -.
".
-::;.....- -.'" .,.
., :' r:r-""::.- -:- ~ ~.
.. ".- -.'--:: -;".~ .! - ..
l .- ~ -
;""'."..--
':
. ."'". - ~.. "..
(34)
-------
AUERNATIVES REI'AINED
Several technologies were retained for final ccnsideration as al ternati ves
for remediat.iD3 the site. Those alternatives retained are listed in
Table 11. With the exceptioo of the No Action Alternative and surface
cawing, all technologies inherently include grounj water recovery and
treatment due to the fact that these technologies require dewatering for
excavation. -
Each of the remaining alternatives was evc;lluated based on technical
feasibility, environmental inpact, and public health concerns (Table 12).
The present worth and operatioos and maintenance costs are presented in
Table 13. Technologies which were founj to be feasible far the Colenan
Evans site are described below.
Ground Water Technologies
Alternative 1. Well Point Ground Water Recovery, Carbon Msorptioo, and
Surface Water Discharge. This techz'x)logy involves a m::>bile well point
configuration for recovery of CCI'1taminated grC)l..1Dj water and far dewatering
of excavation areas. Recovered gr~ water would be analyzed, and treated
if contamination is found. Treatment will involve passing contaminated
gr~ water through a carbon adsorption unit. This technology is well
proven and can have rerroval efficincies up to 99%. Discharge '-OJld
be to the surface water environmemt. The CO'1taminant CCI'1centration in
effluent rrust be less than 1 ug/l in order to o::rtply with State surface
water standards for PCP.
All excavation technologies inherently will require use of this recovery /
treatment/disposal ~tion. Therefore, this technology has been included in
all excavation options, and carbon adsorption has not 'been cost evaluated
as a single item.
Soil Technologies
Alternative 1 - Surface eaw~. This option involves leaving CCI'1taminated
soils in place and constructing a RCRA-approved cap over identified areas
of PCP Soil contaminatioo;-'"A '-cap will prevent runoff of PCP into the
surface water envircnrent, reduce air emissia18 , and prevent further -
migratioo .of PCP into the 8Oils. - -. - -
.' - .. . . ,j,-..... . ~ '. ,Co' ?~,':'or.:.tl.f: )r~': 'if:: . . . .~... ''''':: -._,.. -.~..
Alternati~2 - Ca1ta.innent and ~la~. 'This tec::1w?logy ~ists of
- const.ruct.ing an ih~u.eable barr1.er, excavating the oontam1natedso1.1s and
-;;,. -
placing the 80118 within the inpeIu.eable -barrier, and capping the soils
.~-". ...,.t.oprovide _full ~encapsulatiCX'1 pnsit.e.,. Ultimately, the contaminated ,soils
- would be renDVed £ran contact with- ate~'enviram!l1t~ -' - . -, --:. "
~,. ~..~..::. .'
. ,
. .-:-. '.. .1" . . .
,.,.,:,Alternative 3 -Solidificatioo -andStabilizatioo. "This tedmOlogy would
-- require excavation of CQ1taminated so11s and sol1dificatioo by - using a
mixture of soils with either a cement - based process or other pozziline
process, arx1 on-site storage to solidifY the contaminated soils. Althoogh
pilot testing 'NOUld be required, this technology will reduce the solubility
or nebili ty of the wastes Or J11ay detoxify the CCX1tarninants.
. (t"... :
(36)
-------
TABLE 11.
Remedial 'I'ed\rx)logies Retained for Detailed Evaluation.
1. Surface Capping
2. Containment/Encapsulation*
- 3. 'Solidification and Stabilization*
4. Off Site Disposal *
a. Em!lle, Alabarra
b. Pinewo:xl, South Carolina
Incineration *
Sol vent Extraction *
No Action
5.
6.
7.
(*) = Denotes technologies that inherently require gro.mdwater
recovery operations to facilitate excavation activities.
~
(37)
-------
Table 12.
S\imary of EValuation of Relredial Alternatives.
Altern.t he
T8C~.lc.1 'e..lbtllt,
------_._.~--_.- -'.
I. SlIr18c:.
C.ppl".
co.t eon'ld...
Un It eo.t ..n..-
H.n to U.~I
.r ,
2. Solldlllc.tlon
-
tAl
CD
-
Co.t eon'ide.-
liftl, Cos...n..-
81.81 to ".11
1. C..nt.l...nt .
[..c:.p..I., 10.
Co.t Conll,I."c:.
Unit eo., 1'''le-
)8. n to 16.11
4. S..I,,~..t
.,.. r.,'t Ion
c;.."t c'un' IcI.nce
1111 i . - C.o~ i -..;;11;.
1111,110-"1011.11
Co....tlo..'
. ,roc."r..
'or c."I...
.,III,.ent
.r. ....
eo".."tI08.1 e,.lp...t
. ,roc.'.r",...d 'or .011
.u..,.tl_' .01t'"lc.tlun.
CI.enu, .".~tl.,.n... ....t
be .,.rl'I.' .Itb le.~b
t..t..
eon.,..'.on.1 .,..I,.ent
... ;roc.4.r.. u..,1 lur
.011 ..~..,.t Inn'
c:ont .I._"t. ,.'.I..~.I
'.1'.18..11.1 nee.led tur liner
Spec: 1.III.d "'Iu I..-.nt , I'. r -
.u..nel ne.ded .... ...I"...t
... r.c. lOIn, .:..-.." e'lul...."t
. ..r",:~,"...e ...e,' '''1'
..,:.".. ......
- - - .. ---- .
t:"" I..u"..nt . I
I....c t
. --. - _.- _. ..---..
1I~.I"ce. "1' e.I..lun., .ur-
1.,'. 1'...01", 'de....1 co..-
t .ct. (;..nu"tI ..ter r...""
c..... ... n.. ed.
S..II""I.:..lo" 18' cont_l-
n.'etl ...11. .111 .lnl.ll~
......".Ie .,I"er.. envlrun-
.ell...1 I....c t. .
n,h _thotl .111 .Inl.".
......Ibl. .",,1 ru...en'.1 liI-
1'." t ., c;. .... e.. It"" I.u._n-
..1 rl". .h... AII..II.t h..
I . J. dn. I.. 1"...lbla '.11-
,"e ... Ihe IInlt...
...:.. ,:,,"'..In.le" .011. ...
r "' . ..'. ".1 .. I"" e ". 1.1 ...-
vel lie ~..-II..u.ell,..1 '8.'''.''
.. ... ,'11.' ..1. '
.---... ----
P.b II c lIe.1 t h Concern.
In8.1...tlon.1 1.,.lre.It....
.
Po'entl.1 rl... 0' p.ople
...ln~lnl cont..ln.t... ..tar
or Inle..ln. .alet.bl..
b..11I1 .cc:u...,.ta' PC,..
II.' e.po.ur. o' wor'er.
tlurlnl ..c...tlon I. hl.h.
AI'.r .01Idl'lc..IOII, 1'1.'
01 ..po.ure 10 c:on.-I..t.tI
.011. I. Iou. Tha 1'1.'. 0'
.ro.nd ..t.r c:o"I..I..,IOII
.111 be .llnl'lc."II,
reduced.
II.'. ...oc:l.l.d .I'h proc:e..
Inclutl. .0.'.1'.' e.,...ura 10
C:nnl .uln.. atl .011. . tI..t
,.rtlcl.. durlnl '.c:...'lon.
Tha IO"I-.ar. In~r...nl.1 re-
tldCllon In 1'1.' Inrl..tI.. ell.-
In..lon 0' .1., .url.~e ,
Iround ...I.r ...Ihu.,..
5... ~on~e..n. rel-rdlnl ..-
..."b.tlon -. Allern.tlve I.
".1"11 . nun-'ollic ...Iven.
.111 ...hle.e .n 0....11 .llIk
. ""I...,. I..n I.... I'l;l' (' u..' ..1 -
...110..,
.e,ulr~.en" 'ur 4OC'1I I'll".
260 thruUlh 264 'or cl.........
pl.". .ppllc.bl. to .ur'.c.
c.pplnl. OE. p.r.II.
Loc.1 pe...lI. .., be r....ulr....
'or .lte .c'l ,,111... St.t. 1Jt':1C
pe..." RCRA p...11 r.'lulr.d I...
dl.~h.rllnl Ir..'." ".'.r In
"et:l.... Cr.... .e....lr....... ..,
01 4OC'1 P.r'. 260 .hluuKh 1t4.
1'0 , 124 .... .ppllc.hl. '..r
.0Iltllllr.llon/...hllIl..I....,
"
Requ Ireuenl. 1..1' 40 I;fll 1'.....
260 thrnuKh 1"4 RCIIA .I"~C I' I.,,,
lion. 'ur TSII '."11111....
s... II!! AI..",.... 1",., I, ,.1.." I~II
p...I'. .... 1,,,,,,,,""'''1'''"..1
o. "0"'".11"'" c.,t r.", a. c....
f lul.l. .,.111' "''''''1( I', "", ".,.
..nl'~1I1 ",...........". 1',11
'I'4,u'rr.l.
-------
Table 12 (oont.).
Ah...ael "'.
SlIIIIBIY of Eval~tion of Raredial Alternatives.
Tec"lc.a '~..I~IIII,
----- -. .--
[n.1 ..o_nl.1 l.p.CI,
In.1 lIul lon.1 lequl ....enl.
.,. \! Incl"".1 I-
-
w
\0
-
':0.1 Coa'I"are
rrnlt Co.I' .."...
188.02-206.94
6. 0'''1.1.
DI.po..1
Co.I CoIt'I'.ne.
unl. 1:0.1 I..,..
188. "-U4."
7~ 180 Acllo..
c-o. ...1,.... , ,..on-
'...... .... .... '011 ..c.we-
II... s,.clell... .qul.-.nl
, ..,..., tech.lcel ,....onHI
...q.II.'. l.cIRe...II08 ,..
..ch..lr.1 C08f08..I' ..~-
J.CI I. .....,.... , CO.I.,
"Ie,..
eo..o. ...1,...1 , ,..oc..
...... .... '0.. .011 ..ce".-
1108 , 0...11. '''8C'I.,.
'0..1'1111, 0' .,111 '.IIAI
1"..,,,"1.11- 0' .011..
180 .'.1110..1 .qulp8enl 01
'.cll'I'.. ...qull.'.
----,.. -----.-.
.,Unlt co.I. .r. ..,......eI I. 'ull.... p." loa.
'ubllc He.llh Conc...n.
-----. - .
51,011-1.... polenl..1 lu..
...1..... 01 loalc ..1..10..
, ....a.u.. anlo .n.a..o.-enl.
[f'.cla.. .nllne...ln, '..n;
.K..rnl 01 .1.. pollullon con-
11'01' quench"'1 ,,'le...11I
.'11,.1. po..lble ...I..o.-nl.1
..1.11.
tit.. .11.1'...1 Iv. ..all h.".
.~dllaun.1 (low) .n.l..o....~
1.1 1'1.11. d.. 10 '0..1'1111,
u' .plil. 'u..ln, Ir.n.purl.-
'Ion.
III ah a"'.. I bllll, o. ....1.
.'ar.llO" va. .....c. ...80"
, Iruund ".'.1. ru..I~I.
1.,..:1 Oil I.cehl.. ...1.....
-. ---,---."...._-
Hl,h pOlenll.1 '0" ..I.'
".'ucllon o~ or,.nlc PC,
co.I..I...I..
Thl. .11.rn.II.. ..III h.v.
Inere.enl.1 ,.'Ilc h..llh
..I.'. le'.ellon '-c.... PC,.
...e ........ , I...n.po..I.'.
'0..1111. ..I... o. Inae.llon,
".1'..1 conl.c. , 'nh.l.t'"n
0' PC,. .1 level. con.I'e..e'
to.lc 10 hua....
'. -... . -- -.
'11\1. opllo. -, '...ncl .1 I'
q..III,',....... Ir08I'''.
SI.le , ,.......1 IIIIT p.r.".
..equ he' . ur I.. .... p'" . ., lun "I
con' ,,'n.1 e' ...11.. U'A ."..1,'
. e.t .o&: _..1.1 I.... 1 "'1" I I' .". .
"one
--.-..------..--. .....-.
-------
Table 13. Cost Estinates of Retained Remedial Technolcgies
Present Warth
Techn:>1ogies Construction Present Worth Total Present (1)
. Co&<:: I:bllar s O&M Cost, COllars Worth Cost Rat1.=
Surface Capping 447,950 334,000 781,950 1
Containment/Encap- 992,000 334,000 1, 326, 200 1. 70
sulauoo *
So1idificatioo * 1,496,000 218,000 1, 714, 900 2.19
Offsite Disposal *
Pinerwccd, SC 3,606,000 0 3,606,600 4.61
EmelIe, . AL 5,088,000 0 5,088,000 ~51
Incineratioo '* 3,703,000 0 3,703,000 4".74
-~lvent Extract.ioo 5,767,400 41,700 5,809,100 7.43
( I) = Ratio of technology costs over the cost of the techmlogy with the
lo-west present worth cost.
* = Costs include grcund water recovery and treatment operatia'1S.
~
(40)
-------
Alternative 4 - Offsite Disposal. '!his technology involves excavation of
contaminated soils and transport to an offsite RCRA-approved facility for
treatment, storage, or disposal. Approved facilities exist in EmelIe,
Alabama and Pinewood, South Carolina.
Alternative 5 - Q1site Incineration. '!his option would involve the use of
a temporary incineration facility to destroy PCP in contaminated soils
excavated fran the site. Contaminated soils would pass thro~h a primary
chamber to -flash" the PCP fran the soils and PCP destruction would occur
in a secondary chanber with higher temperatures. '!he soil residue would be
used to backfill excavation trenches after analysis had demonstrated that
the PCP had been efficently renoved.
Alternative 6 - Solvent Extraction. "Soil Washing" would consist of using
sane type of solvent such as methanol to renove toxic substances (PCP) fran
the soil. Treatability stlrlies conducted during the Remedial Investigation
demonstrated that this technology is feasible for this site on a bench
scale. Hawever, full scale testing will be required.
Alternative 7 - ~ Action. '!his option would preclooe further EPA involvement
with the Coleman Evans site and no further expenditures of Superfund m::>ney.
Institution of the no action alternative may not immediately impact public
health or welfare, but it would allow PCP contaminated site runoff to
continue to enter the surface water regUne, thus contributing to the
deterioration of the environment.
':
(41)
-------
SEer 100 VI
C'CI-MJNITY RElATIONS Acr1VIT1ES
Ccmnuni ty relations efforts for the Colenan Evans site were initiated in
November 1984..men EPA personnel visited the site along with personnel frc:rn
the REM IIcx:m:nuni. ty relations contractor, IeF, Inc. Attenpts were rrade
to contact area. residents: ha,.rever, neighborhood response ranged fran dis-
interest to strongly negative sentiment. Only two area residents agreed to
discuss the site: -Mr. H.G. Moore, 10917 General Avenue, and Mrs. Mamie Nor!:an,
10904 General Avenue.
An information repository was established at the Whitehouse Elementary
School near the site, and all finalized dOCUI'!ents were placed on file to
provide local public access.
r:uring the rufFS process, EPA was never contacted by ooncerned citizens with
regard to the Colerran Evans site: although sporadic press -interest was
generated.
At the carpletion of the rufFS process, EPA published and mailed a fact
sheet to interested part.ies as identified in the March 1985 Ccrmunity
Relations Plan. On August 7, 1986, a public meeting was held to discuss the
findings of the rufFS. Attendance was light and the questioo and answer
session was not extensive. The public meeting served to initiate a 3 week
PJblic cc:mnent period wuch closed on August 28, 1986. The only written ccmnent
received during this pericx1 was a proposal for a remedial action sul::rn.itted by
Coleman Evans contractors. The responsiveness surmary was catp1eted on
Septerrber 16, 1986, and placed into the information repository. A copy of
the responsiveness sumnary is presented in 1q:pendix A.
':
-------
SErrIOO VII
CCNSIS'1'rncY WrIH CJniER EN\TI~AL lAWS
Environrental Laws ...mich may be applicable or relevant to the remedial
activity are:
Safe Drinking Water Act (SIJtlA)
-- Res~ce .Conservation and Recovery Act (RCRA)
-- State of Florida Administrative Code Chapter l7-3.061.3(m)
- &1rface Waters: General Criteria
-- Federal Water C).1ality Criteria (WJ:)
-- Clean Air Act (eM)
Locally private wells obtain water fran the limestone unit of the surficial
aquifer system, ...mich is protected 1:¥ a high integrity confining unit.
D.Jring the RI field study, nurrerous private wells were sanpled and analyzed.
The results indicated that the private wells have not been ilTpacted ~ the
site. Therefore, the residents currently have a safe drinking 'Nater supply,
as specified .under the SI:W\.
'n\e no-actioo alternative wculd not catply with the Hazardous Waste
Regulations identified in Subtitle C of RCRA. . HoEver, all other
alternatives being considered are in accordance with RCRA Subtitle C. 'n\e
selected alternative, as O1tlined in Seetin VIII, inclooes excavation of
contaminated soils. In order to iIrplement soil excavation, the upper
portioo of the aquifer will require dewatering. Contaminated ground water
m.lst be treated until the pcp concentratioo is less than 1 ug/l in order to
carply with the surface water discharge levels set forth in Chapter 17-3
061. 3 (m) FAC. 'n\is level was established by the State of Florida to
protect aquatic species. 'D'1e Federal Water OJality criteria has not
established a standard for pcp to protect aquatic species: ~ver, a
hLJran health criteria of 30 U;/l was established to prevent organoleptic
effects. A soil cleanup level of 10 rng/kg was based on risks identified in
the Public Health Evaluation (FS, ~ix A).
. Incineratioo activites ~d be O::)I~ucted in accordance with the applicable
pennitting standards am cperations protocols established in the Clean Air
Act. A quality assurance program 'NCUld be developed under the renedial
design P\aSe.
'lbe Natiooal Rescurce DimBge Assessment cooducted 1:¥ the Fish & Wildlife
Servive concl\aJed that the Colertan Evans Site has not inpacted any federal
trustee resa.zroes (Apperxlix B). 'Ihere are currently no threatened
~lands and the site is atove the 5OO;oear flood plain (Figure 12).
.. .
~
-------
x,~
o~
1;
~
_.
..
; ~
\ ,/.
\~-,
~r- -.
...~~
"" ~.
C~ ~,~ "
A' ,'" \
11'...'1: ..
.-~
....-
.,,}
,_\.'
66 \.
-
)"
, .,. c
-,'. -
~',
~~ "-
.",0 -
r-
x,~
. O~
'-V
- -
~
-------
SEer 100 VI II
REX:CMIDIDED ALTERNAT 1VE
SELEx:'TED RfME[1l
The recamended alternative for the Colerran Evans site ca1Sists of excavating
all soils which have PCP cootaminaticn in excess of 10 mg/kg, and destruction
of the contaminanta. throogh onsite incinerati::n. In order to excavate the
contaminated soils, dewatering will be necessary.
A nobile incinerator will be used ensi te to destroy the PCP found in soils.
The process will involve use of primary and secondary incineration chambers.
FCP and diesel fuel Will be converted to gaseous phases in the primary
chamber and thermal destructicn will occur in the secondary chamber.
Decx:>ntaminated soils will retain virtually their initial volume and can be
used to backfill excavation areas. The total volume of soils to be treated
is estimated to be 9, 000 cubic yards. '.
Ground water recovery will involve localized use of well p::>ints, which are
sufficient for the shallOllo' excavation depths (less than 20 feet) necessary
at this site. Areas in ~ich ground water contaminatioo was identified
coincide with areas of soil contamination, thus there is little risk of
allOllo'ing contaminated ground water to escape: hcwever, all ground water witl1
FCP concentratioos greater than 1 mg/l will be recovered. The recovered
ground water will be analyzed and treated by activated carron adsorption if
FCP ccncentrations exceed 1 ug/l. 'Treated effluent will be discharged to
an on site drainage ditch. The sPent carbon will be thermally regenerated,
~ich will destroy the remaining PCP contamination. The volume of ground
water containing PCP in excess of existing standards is conservatively
estimated to be 900,000 gallons.
Other incidental Hazardous Substance List canpounds identified in the ground
water during inFlementation of this rerredy will be cleaned up to levels
which catply with {kinking Water Standards. If the Irinking Water Standards
do not address these cx::rtpJUIXls, cleanup levels will be consistant with tl1e
human health criteria identified in the 1980 Water ()Jality Criteria. Clean
up of C\.al~ds for which no standards exist will be to ncn-detection levels.
. In cases ~ere standards prarulgated by the State of Florida are ncre
stringent, the state standards will have precedence. Also, should EPA
prarulgate standards ~ch are ncre stringent than existing standards or
criteria, the newer standard will be inplemented.
- Since this a1 ternati ve provides total destruction of the \1IIaStes, lmg term
.ncnitoring is not. required, mr will there be any ~ation and maintenance
costs associated with this remedy. Nor will land use restrictions be
iJrposed .
- exsr-u'r'tCI'IVEmSS .
This remedy selected far the Coleman Evans site is the nost effective
alternative, and is considered to be the nost permanent remedy of choice
which resolves the threats ~ by the site. The environmental benefits
-------
gained outweigh the financial advantages gained by selecting a more
cost-effective solution. A sLlTlTlary of feasible alternatives and rejection
cri teria are presented in Table 14.
'!he selected remedy is estimated to cost between $3.0 and $3.8 million
dollars. The State of Florida has instituted a program for addressing the
problems posed by uncontrolled hazardous waste sites. '!his program is
designed on the CERCLA nodel and is operated similarly to Superfund
through the Florida Department of Environmental Regulation. '!he State of
Florida has agreed to fund 10% of the cost for implementing the selected
remedial action (Appendix C). The City of Jacksonville Bio-Environmental
Services Division has also concurred with the. selected remedy (Appendix D).
-
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Table 14.
Summary Table of Feasible Alternatives and Cost-Effec~iveness
Oamparison. Costs Presented in ~illions of Dollars.
Remedial Alternative
Reason for Non-Selection
.
1. Surface Capping
I
Implementation woUld not deal permanently j
with the site contamination although I
it provides a high degree of protection I
to surface water and air. Groundwater I
~tamination would remain. Restricts \
slte use.
2. Solidification and
Stabilization
This is a viable alternative, but
contaminants would remain on-site
and long-tem rronitori~ would be
required. r.a.ro use limitations.
3. Containment and
Encapsulation
This is a cost~ffective option, but
contaminants would remain \..ntreated.
Greater environmental risk arises fram
the potential for liner fail ure. Long
term rronitoring and O&M will be required.
4.
Solvent Extraction
This option is fully effective for
migration of all threats, but incineration
is equally effective with a lower cots.
5. en-Site Incineration
"
6. Off-Site Disposal
I)::)es not renediate wastes, only involves
transport to a RCRIr-~roved facility.
7.
No Action Altemative
No remediation of site specific ccnjitions
potential health and environmental risks.
~
(47)
Estimated
Cost Rance
0.5 to 0.9
1. 4 to 1.9
-
o.~ ,to 1.5
4.5 to 9.6
3.0 to 3.8
2.9 to 4,.2
0.0
-------
SECI'ION IX
OPERATICN AND ~E
No cperation arrl rra.intenance Will be required for the selected remedy since
all existing contamination will be thermally destroyed.
. ~... . -. .
~
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SEX:TION X
fUI'URE ACTIONS
Successful inplenentation of the selected reredy will ultimately rem:)Ve the
Colaran Evans \ob:Xl Preserving Cbnpany site from under the jurisdiction of
the Q::rtprehensive Ehvirormental Response, Catpensation and Liability Act
once it has been deleted fran the NPL. Future site actions will be limited
to applicable .as~s of the ReSOJI'ce Conservation Recovery Act (~), for
the duration of the facility's existance.
I
~
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S~IOO XI
PRCXTErr SOiEIXJLE
The schedule for the RD/RI phases of the Coleman Evans WxId Preserving Catpany
remediation are dependent on the success of enforcerrent negotiations. If the
PRPs agree to undertake RD/FA, the schedule will be negotiated to aCC"-llIll~te
EPA, FDER, and thE! PRPs.
If, ~ver, negot.iatia1S with the PRP are unsuccessful, EPA will follON
the schedule cutlined belcw:
Schedule IardtBrk
Date for
IrTplementaion
1.
Finalization of the ROD
9/30/86
12/31/86
2.
Carplete Enforcenent Negotiations
3. Award SUperfund State Contract (and
lAG) for Design
2/31/87
4.
Ini tiate Design
4/1/87
10/1/87
5.
Ca1plete Design
6. Award/Amend Superfund State Contract
(am lAG) for Constroctioo
10/30/87
7.
Initiate Constructioo
12/1/87
12/1/8~
8. Catp1ete Construct.ioo
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APPENDIX A
RESPONSIVENESS SUMMARY
Coleman Evans
Wood Preserving Company
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REGION IV
COLEMAN EVANS WOOD PRESERVING CO.
RESPONSIVENESS SUMMARY
September 16. 1986
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RES PONS IVENESS SUMMARY
COLEMAN EVANS W::X)D PRESERVIfI(; COMPANY SITE
u. S. ENVIRONMENTAL PRCYI'EcrIOO AGENCY
REGION IV
This is the ~spo~siveness SU'tIT\ary for the Coleman Evans WJod Preserving
Canpany site in Whitehouse, Dwal County, Florida. Since the EPA received
written earments fran only one source duri~ the Feasibility StlDY public
comment period, this document consists of a summary of the community
relations activities conducted at this site, a response to the one written
response received, the Feasibility Study fact sheet, and the transcripts
fran the public meeti~. . .
Following the Ybrk Plan phase of the stujy fran September 1984 to April .
1985, the Remedial Investigation/Feasibility Study (RI/FS) for the site was
condocted fran June 1985 to June 1986. EPA I:eceived no telephone calls or
letters fran the public concerning the site during that time. A community
relations plan describing community concerns and recommending community
relations activities was prepared in March 1985. In accordance with the EPA
"National Contingency Plan and suggestions made in the Oammunity Relations
Plan, EPA established an information repository at the Whitehouse Elementary
School. The repository contained public documents on the site, incllrling
the RI/FS work plan and the RI/FS report.
" O1ce the draft FS was canpleted, a fact sheet- (Attachment A) was prepared to
describe the remedial technologies that EPA was considering for the site,
" the proposed clean-up goals, and the details of the public meeting and the
public ccmrent period. The fact sheet was mailed to individuals on the
Coleman Evans site mailing list and placed in the infonnation repOsitory.
, Announcements for the public meet ing and the plblic catment period were
placed in local papers. EPA held the public meeting on Algust 7, 1986 and
the public carrnent period covered the period fran Alg.ust 7 to Algust 28,
1986. Approximately 10 to 15 concerned citizens attended the public meeting.
The transcripts of the public meeting are presented in Attachment B.
The only written response received was fran Grol.nd Water Technology, Inc.
(G'I'I), a consultant for the Coleman Evans ~ Preserving Canpany. The GTI
prOkX>Sal is s\llmarized below, and the full doc\Jnent is presented in
Attachment C. .
Qmnent SlItIMry
.'
GTI subnitted a response to the Feasibility Study. '!he doct..ment which was
submitted was a -Response to Feasibility Study" in which GT1 outlined a
proposal to undertake photo/biodegradation of the contaminated waters and
soils at the site and to recovery and rec~le the free-floating pentachloro-
phenol/diesel fuel mixture fran the surficial aquifer. '!he proposal incllDed
site history, a work plan, a~itoring program, a cost evaluation, and a
photo/biodegradation process'Sl.JTI'I\ary.
-------
Respcase
EPA reviewed the potential application of biodegradatioo far the Coleman
Evans site during the Feasibility Study and has reviewed the proposal
sutmitted by GU. This technology was eliminated during the early phases
of the Feasiblity Study because of tedmical problems associated with
biodegradation. First, the feasibility of this prcx:ess would have to be
detennined during C! loog term pilot testing program, especially since there
have been lirni ted previous studies which evaluate biodegradation of
pentachlcrophenol. Seca1d, the volume of ccntaminated soils (estimated to
be 9, 000 cubic yards) would require a 1009 period of time far catplete
digestion of the contaminants, especially at the greater depths of
eontaminatioo identified during the Remedial Investigation. Third, the
contaminants ~ch are at depth nay exist under anaerobic condi tia1S. In
order to evaluate biodegradation as a feasible optiCX1, a very wide range of
oonditions would have to be inplemented during the testing process. Finally,
there is a potential for the creatioo of unacceptable by-products during
the biodegradation process: specifically dioxins. Generation of dioxins
~uld further increase the risK to the public health and welfare, and to
the environment than is currently posed by pentachlorophenol, the rrain
contaminant of concern.
Although the f:Lnar1cial aspects of biodegradatim are attractive, the
potential far greater health and envircnnental risK and the long periods of
time required far testing and inplementation are unacceptable to EPA. For
these reasons. EPA eliminated biodegradation technologies dur ing the Colenan
Evans Feasibility Study prcx:ess. EPA has determined that biodegradation is
not sufficiently proven to be an acceptable option for remediation of the
conditions at the Coleman Evans iobxl Preserving Carpany site.
. -
. . .~.
~
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APPENDIX B
Natural Resource
Damage Assessment
Coleman Evans
Wood Preserving Company
-------
United States Department of the Interior
OFFICF OF THE SECRETARY
WASH:-OTON, D.C. 20240
fev
ER84/1518
Mr. Gene Lueero, Director
Office of Waste Programs Enforcement
Environmental Protection Agency -''
401 M Street, SW (Room S362N) WH 527
Washington, D.C. 20460
Dear Mr. Lueero:
The Department of the Interior has conducted a preliminary natural resources survey of
the Coleman/Evans Wood Preserving Company at Whitehouse, Duval County, Florida, to
determine whether the Secretary of the Interior's trust responsibilities for natural
resources have been affected.
Our survey indicates that there are no lands under the trusteeship of the DOI near the
Coleman/Evans site. However, the Ortega River system nearby can be inhabited by
various trust resources, including anadromous fish, migratory birds, and endangered and
threatened species of wildlife. The manatee, an endangered marine mammal, can be
found in the Ortega River system.
Site visits and review of various reports and studies show that soils and surface waters
have not been seriously contaminated very far off site. There is no documentable
evidence that our trust resources have been affected by materials from this site.
However, we believe the site should be cleaned up quickly so that contaminants do not
move off site.
Accordingly, we would grant a release from claims for damages to natural resources
under our trusteeship from the Coleman/Evans site, provided that timely remedial
action consistent with the NCP is taken to clean up the site.
Sincerely,
7
. I.
"Bruce Blanchard, -Director
Office of Environmental Project Review
ec:
£_Steve Klein/EPA
-------
APPENDIX C
State of Florida
Letter of Concurrance
for the
Selected Remedy
Coleman Evans
Wood Preserving Company
-------
STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULATION
TWIN TOWERS OFFICE BUILDING
2600 BLAIR STONE ROAD
TALLAHASSEE. FLORIDA 32301-8241
BOB GRAHAM
GOVERNOR
VICTORIA j. TSCHINKEL
SECRETARY
September 24, 1986
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Mr. Jack Ravan
Regional Administrator
United states Environmental
Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Jack:
The Florida Department of Environmental Regulation agrees with
the selection of Alternative 15 as described in the final
feasibility study for the Coleman Evans Wood Preserving Superfund
Site in Whitehouse, Duval County, Florida.
This alternative includes the excavation and on-site incineration
of soils and sediments, and the on-site treatment of contaminated
ground water. This alternative will effectively destroy contam-
inated soils and sediments and treat ground water.
The cost estimate for Alternative #5 ranges from $3.0 - $3.8 mil-
lion for the use of a temporary on-site incineration facility,
and groundwater treatment unit. Due to the complete destruction
of site specific contaminants by incineration, no post-remedial
monitoring oe operation and maintenance activity is required.
The state win. provide ten percent of the total cost, or about
$300,000 - $380,000 from the State Water Quality Assurance Trust
Fund.
We look "forward to. participating with the U. S. Environmental
Protection Agency during implementation of remedial activities
at the Coleman Evans .Wood Preserving site.
Sincerely,
Victoria J. Tschinkel
Secretary
VJT/ps
Protecting Florida and Your Quality of Life
-------
APPENDIX D
City of Jacksonville
Letter of Concurrance
for the
Selected Remedy
Coleman Evans
Wood Preserving Company
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DEPARTMENT OF HEALTH. WELFARE
. BIQ.ENVIRONMENTAL SERVICES
Bio-Envil'onmental Ser¥icee Division
May 21, 1986
Ms. Kristina Teepen
Remedial Project Manager
, U. S. Environmental Protection
345 Courtland Street
Atlanta, GA 30365
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RE: Coleman Evans Wood Preserving Company
Draft Feasibility Study
. .,'
Dear Ms. Teepen:
The Bio-Environmental Services Division (BESD) has briefly reviewed EPA's Draft
Feasibility Study of Coleman Evans Wood Preserving Company, dated May 2, 1986.
The BESD would support the option of incineration, over the
remedial actions, as presented. Incineration provides the
which BESD feels are noteworthy.
other options for'
following benefits
..
I.
II.
III.
Destruction of the organics
Usability of the site after contamination disposal
No requirement for continual monitoring
Incineration, of course, as an option needs to be better defined prior to
implementation. Specifically such items as retention times, in situ monitoring,
,etc. must be detailed. Further, in order for incineration to be viable, just from
a permit'ting standpoint, a great deal of public awareness and education on the
benefits of the program shall be necessary. Otherwise a permit may be delayed as
a result of public concerns requesting Administrative Hearings.
If BESD can be of further assistance, please advise.
-:
Very truly
~bert te.en Pace, P.E..
. Bio-Environmental Engineer
cc: Mr. Ernest E. Frey, P.E. DER
John K. Flowe, P.E.
Khurshid K. Mehta, P.E.
RSP/ns
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AREA CODE I 904! a33-3Z181 515 WEST 6TH STREET I JACKSONVILLE, FLORIDA 322~397
-------
APPENDIX E
PUBLIC HEALTH EVALUATION
Submitted
by
CDC/ATSDR
Coleman Evans
Wood Preserving Company
-------
•••""'r,
DEPARTMENT OF HEALTH & HUMAN SERVICES
Pub;.c Hes.:~ Serv ce
Agency 'or Tox.c S~-5stances
and Disease Reg strv
MemorandurtW
Date June 26, 1986
Public Health Advisor
ATSDR-EPA Liaison
Subject Coleman-Evans NPL Site;
Duval County, Florida
To Kris Teepen, RPM
EPA ERRB RAS
As requested, I have reviewed the Draft Feasibility Study,
dated May 2, 1986, for the referenced site. Given my long
term involvement with this site, and in the interest of time
for your program management purposes, I have elected not to
refer this document to the ATSDR for a more indepth review
and comment. I trust you will find the following useful.
Historical EPA and ATSDR review and other site do-cuments on
file have sufficiently identified the actual and potential
public health issues of concern for this site, especially the
factors that must be present in order for a public health threat
to exist. The 1984 EPA emergency response action (excavation
of lagoon sludges) appears to have helped reduce the predominant
public health threat posed by the site (i.e. potential for
percolation and migration of contaminants to adjacent private
wells).
The qualitative risk assessment that is described in the FS
assesses on both technically and epidemiologically sound bases,
the potential health concerns existing at the site with current
(p. 1-1) and future use (p. A-32) exposure scenarios. As such,
any, or a combination of the three preferred remedial alternatives
(surface capping w/closure; solidification; incineration) appear
adequate to protect public health and to reduce the potential for
future exposures to occur that may increase the threat of exposure
to site contaminants at levels that would be of health concern.
However, if a "No Action" alternative is selected, it appears
prudent that a monitoring program of private wells at the
residences adjacent to the site be considered. Contingency plans
should also be developed if such monitoring identifies that site
^contaminants at levels exceeding primary drinking water standards
are found at those wells in use for potable purposes.
If I can assist further with the remaining remedial phases of this
site, please let me know.
Chuck PietrosewicV
cc: file
ATSDR/Buynoski
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APPENDIX B
RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
The U.S. Environmental Protection Agency (EPA) established a
public comment period from August 9, 1990 through September 9,
1990 for interested parties to comment on EPA's Proposed
Remedial Action Plan (PRAP) for the Coleman Evans Wood
Preserving-Site. The comment period included a public meeting
on August 23, 1990, conducted by the EPA, held at the Whitehouse
Elementary School in Jacksonville, Florida. The meeting
presented the results of the studies undertaken and the
preferred remedial alternative for the site.
A responsiveness summary is required by Superfund policy to
provide a summary of citizen comments and concerns about the
site, as raised during the public comment period, and the
responses to those concerns. All comments summarized in this
document have been factored into the final decision of the
preferred alternative for cleanup of the Coleman Evans Wood
Preserving Site.
This responsiveness summary for the Coleman Evans Wood
Preserving Site is divided into the following sections.
II.
III.
IV.
I.-
Overview This section discusses the recommended
alternative for remedial action and the public reaction
to this alternative.
Backaround on Community Involvement and Concerns This
section provides a brief history of community interest
and concerns regarding the Coleman Evans Wood
Preserving Site.
Summary of Maior Ouestions and Comments Received Durina
the Public Comment Period and EPA's Responses This
section presents both oral and written comments
submitted during the public comment period, and
provides the responses to these comments.
Remainina Concerns This section discusses community
~oncerns that EPA should be aware of in design and
_~plementation of the remedial alternative for the
site.
I.
Overview-
"!: :C.
As a result of recent Treatability Studies (TS), the subsequent
remedial technology evaluation and a cost analysis, a preferred
80il remediation alternative has been developed and documented
in the Amended Record of Decision CAROD). This final remedy
addresses remediation of groundwater and soil contamination by
~ .~. ." ,
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-2-
-
eliminating or reducing the risk posed by the site, through
treatment, engineering and institutional controls. The major
components of the selected amended alternative include:
- Excavation of contaminated soils and sediments with
Pentachlorophenol (PCP) concentrations greater than
2S mg/kg; approximately 27,000 cubic yards.
- Volume reduction by soil washing to separate clean soil
fractions from contaminated soils fines.
- Stabilization/Solidification (S/S) of soil fines or
sludges exceeding cleanup criteria.
- Redisposing of the clean soil fraction and the
SIS "fixed" sludges onsite.
- Dewatering and recovery of groundwater to facilitate
excavation; recovered groundwater will be stored and
analyzed. If the level of PCP exceeds 1.0 ug/l, the
groundwater will be treated by an onsite carbon
adsorption unit to a level below 1.0 ug/l PCP in
accordance with Chapter 17-3.061(m)of the Florida
Administrative Code, before discharge to an onsite
drainage ditch leading to McGirt's Creek.
'r
- Treatment of the soilwashwater by bioremediation
followed by a granular activated carbon polishing
for discharge to an onsite drainage ditch leading
McGirt's Creek.
unit
to
- Removal of metals from the groundwater by chemical
precipitation.
- Installation and maintenance of a six-inch vegetative
cover over the solidified mass .(monolith).
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- Installation and maintenance of a fence around the site
during remedial activities. . .
- Institution-of controls which include deed restrictions.
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f The community, in general, favors the selection of the preferred
,; amended alternative.
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II.
Backaround on Community Involvement and Concern
The Jacksonville community has been aware of the contamination
problem at the Coleman Evans Wood Preserving site for several
years. The first public meeting was held on August 7, 1986, to
discuss, with the public, the findings of the Remedial
Investigation/Feasibility Study (RI/FS). The public meeting
served to initiate a three week public comment period which
closed on August 28, 1986. .
During this public comment period, EPA submitted a proposal for
remedial action (RA) at the site. That proposal suggested
treatment of the contamination by incineration. As noted in
this AROD, that alternative was rejected due to concern over the
cost effectiveness of -the.action due to a reassessed volume
increase. Subsequently, the EPA initiated a TS to examine
Bioremediation and/or S/S as a viable remedy for the Coleman
Evans Site. The results of the study confirmed that the amended
remedy described in the previous section satisfies EPA's goals.
for source control.
The TS for the Coleman Evans Wood Preserving Site was released
to the public on August 9, 1990. Also, the Modified PRAP which
revised the remedy EPA had proposed in its initial 1986 Record
of Decision (ROD), was placed in the information repository
maintained at the EPA Docket Room in Jacksonville, Florida on
the same date.
EPA conducted the second public meeting on August 23, 1990. The
purpose of this meeting was to explain the results of the site
studies, to present the recommendations of EPA for site cleanup,
and to accept questions and comments from the public on any
aspect of the site or its cleanup. At this meeting, the key
issues and concerns identified were:
III.
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Summary of Maior OUestions and Comments Received Durina
the Public Comment Period and EPA's Resoonses
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Public Meetina held Auaust 23. 1990
, ...1) -;, The commenter was concerned about where the solidified
.' ,'. material would be finally located, and whether a formal cap
.would be in the plan. . -, ; '-,'
EPA Resoonse: The contaminated soil material will be
sampled and soil with concentration levels greater than 25
mg/kg PCP will be excavated and washed. Wash water will be
. placed in a bioreactor and the remaining contaminant fines
will be S/S. The S/S monolith will then be placed back
onto the site, backfilled, and covered with a 6 inch
protective vegetative cover.
-------
-4-
2). The commenter expressed concern regarding the leachate
of the solidified monolith, and whether additional testing
had been done since the RA.
EPA Response: A leachate level of 3.6 parts per million
(ppm) was set for the monolith that will be placed back
'onsite. The level assures that no leachate of the material
into the groundwater or soils would exist above the
applicable Maximum Contaminant Limits (MCL). The level of
3.6 ppm was achieved in the TS and will be followed up in
the Pilot Study. .
3). .The commenter requested more details regarding the
Bioremediation process, specifically whether or not it
involves insitu treatment.
EPA Response: EPA plans for the contaminated soil material
to be excavated. The excavated material will be washed.
The wash water will be placed into a bioreactor for PCP
destruction. Soils with concentrations below 25 ppm PCP
will be placed back on site. Bioreacted fines with
concentrations above 25 ppm PCP will be S/S in an
appropriate medium. The S/S medium will be placed back on
site. Therefore, the bioremediation process will not be
insitu due to the excavation of-the contaminated soil but
the stabilized medium will be placed back on site.
4). The commenter inquired about the extent of monitoring
after the remediation is complete and requests that
discharge water from bioremediation be tested in insure
drinking water standards.
EPA Response: EPA will conduct extensive monitoring and
sampling of the material prior to and after treatment. In
addition, sampling will be conducted throughout the process
to ensure that acceptable cleanup levels are met. This
includes monitoring of both soils and groundwater. EPA is
required to perform a 5 year review after remediation
begins. .
5).. The commenter inquired as to whether or not any of the
local drinking water wells have been affected.
':', ~.,.~ -- ~of-, . '. ;"-..- r:.r r... t~ ~.~ : " .";' ../. -"a.:.. -~~:, .'
EPA Response: Based on the results of initial sampling
that was conducted by the State of Florida Department of
Health and Rehabilitative Services (HRS), HRS indicated
that none of the drinking wells were contaminated.
-------
-5-
6). . The commenter requested an "action item" to see when
the last sampling of local wells occurred, and if after
1985, could the city be provided with a copy of the lab
report for their files.
EPA ReSDonse: HRS in North Florida has scheduled sampling
October 2, 1990. Upon receipt of the lab results, EPA will
work with the city of Jacksonville to provide the requested
information.
7). The commenter expressed
were going to be tested, the
whether Total Organic Carbon
only procedure used.
EPA Res?onse: EPA plans to continue testing for PCP using
the PCP-specific methods described in the 1986 ROD in
conjunction with TOC testing for means of evaluation.
concern over the way the PCP's
document was unclear as to
(TOC) content is to be the
DeDartment of Health. Welfare and Bio-Environmental Services
(Jacksonville. Florida) dated September 11. 1990 Comment
Letter .
1). The purpose of the treatability study was to study the
various possibilities of treating pentachlorophenol. One
of the possible treatment methods as shown in Figure 13 is
to mine the contaminated soil, water wash the soil clean
and biologically treat the wash water. Soil of some
undefined quality is to exit the process at three separate
stages. Very little information is available on the
techniques and waste stream quality data are contained
within the TS. .
'.
. EPA Resoonsea .SPA provided copies 'of the final TS to a
"- ...'. representative of the Department of Health, Welfare and
.. 1 "Bio-Environmental Services (BES) ~bf Jacksonville Florida.
. Liquid/solid separation techniques and waste stream quality
.;>:--data. are contained within the TS. .
2).' Most of the proposed flowsheet appears to be
theoretically possible; however, the WRD contends that
extensive pilot plant testing must be performed to
determine actual feasibility and to produce acceptable data
on the quality of waste streams, off gases, particulate
~matter .,and treated sand. '.
:t.~2 -.; ;:'" ;.~ ~~ JI..~ ~: ~.
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-------
-6-
EPA ResDonse: EPA plans for a pilot study as a part of the
Remedial Design (RD) phase. The pilot study will address
the above issues of concern.
3). An example of the lack of completion in the proposed
(A) ROD is in the use of a carbon adsorption system to treat
the gases from the bio-treatment reactor. What is the
purpose of treating the gases and how will the used carbon
be treated? In another example the proposed (A) ROD is
concerned with dust emission from mining equipment and
mentions total encapsulation. Is this a guess at the dust
problem? "
EPA Response: During the bioremediat~on phase, any
volatiles present will vaporize (offgas). The purpose of
the carbon adsorption system is to catch vaporized
"volatiles. Most carbon adsorption filter venders offer the
service of collection and proper disposal of the filters.
If no service exists, the filters would be disposed of
offsite in an approved facility. "
During the" s/s phase, the encapsulating agents would most
likely produce dust particles. For this purpose, a closed
system mixer would be used.
4). The WRD's major concern at the present time are the
private wells used for residential drinking water. Local
records indicate that the wells have not been tested for
five years. The WRD urgently requests the testing of all
wells supplying residential dri~king water without delay
and that testing be continued on an annual basis.
EPA ResDonse: HRS in North Florida has scheduled the
sampling of private wells in the vicinity of the site to
begin October 2, 1990. The HRS has identified
approximately 16 wells to be sampled in the immediate area
of the site. HRS plans to sample over a 3 day period. The
samples will be tested for PCP and No.2 fuel oil. Sample
results are eXPected to be received approximately 5-6 weeks
after submittal.
5). Based upon the information not supplied, the WRD
requests an additional public hearing be held for public
comment before the design phase is completed.
-------
-7-
EPA ResDonse: EPA is required by the National Contingency
Plan (NCP) to provide as appropriate a public briefing upon
completion of the final RD for the site. The public
briefing will provide the opportunity for the public to
comme~t o~ the design. EPA will provide the WRD with as
much requested information as possible during the remedial
design phase.
IV.
Remainina Concerns
The community's concerns surrounding the Coleman Evans Wood
Preserving site will be addressed in the following areas:
community relations support throughout RD/RA and incorporation
of comments/suggestions from the community into the RD.
Community relations will ~onsist of making available final
--,' documents.1 i ..e. , . RD Work Plan,RD Reports, etc.) in a timely
'-manner to the local information repository for the site. EPA
will also issue fact sheets to those on the mailing list to
provide further information on progress of the project and
schedules for future activities at the site. EPA will inform
the community of any principal design changes made during the
project design. If, at any time during the RD or RA, new
information is revealed that could affect the implementation of
the remedy or if the remedy fails to achieve the necessary
design criteria, the ROD may be revised to incorporate new.
technology that will attain the necessary performance criteria.
Community relations activities will remain an active aspect of
the Rb/RA phase of the project. .
..
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-------
APPENDIX C
DATA SUMMARY FROM THE REMEDIAL INVESTIGATION
AND REMEDIAL DESIGN
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IS .21-11 \. 2-4 II mas.11 211"".41 0.5 <1.0
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II ,-0]1 ] , II 21".SI 2114514." ".1 S ".1
IS '-111 I II a]l4].11 2"'511." 120 1 120
,-0.. ] II a]l4].11 2114511.55 II.' ] '.2 14
.. '-011 I II 2]1162." 2114566.11 174 2 I" II]
'-012 ] .. 211162." 2114566.11 117 2 111
11 '-029 ] II 2]1119.52 2111195. '2 0.22 1 II . 2.10
.. '-0111 I " a]l19." 21144....2 0.22 1 I'
'-1121 ] .. 2]1119." 2"'41"'2 0.22 ] II
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11-]6-] IS 1].5 2]]906.1 2175021.05 0.02 II 0.04
111-]6-1 20 11.5 2JJtO... 21"'21.05 0.22 " . 2.IU
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111- ]6-' so IS.5 2JJ.... i 217502].05 0.22 " .. 2.IU
" I-DJt I IS.] 2S]l72." 217417...2 0.22 S II
1-040 , IS.S 21]112.41 217417...2 0.22 1 II .. 1.6U
'2 [-oJl I .12.1 21JtlU1 2174716. JI 0.22 1 tr
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n 1-0" I IS. I 2JJ9I7.02 2I74751.2S 10 1 10
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111-49- 2 10 10 mll9.51 2I74StU 1.1 1.1
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102 ,-..S" I m",." 2
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101 '-OD ", I 12 mt:JI.1J 2171612.17 ' "2 sn SIN
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104 '-oI1~"i,\ I II 2SS..U5 217"".1' 0.92 S 0.'2
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107 '-0'1 I II 2JJt4l. JS 2I1151J.St 112 S 112
H2O S II 2m... SS 217151J. Sf I.' I I.'
101 ,-on I II 233m." 2I1151J.27 0.22 S I'
, ..24 S 10 2SJ"S." mlm.21 0.22 S .
1M a-2'''' 2-4 10 213945.26 2171"1.11 105 10:1
IS- 2...2 N .. 213"'.26 ml"I.11 u S..
110 11-2:1"1 . 2-1 II 2SJm.11 21141". J1 11.1 11.7
IS- 2:1-02 ... 10 mm." 2m.... J1 ... I.'
III F -02:1 I 10 m'lI.t1 21141".11 2.J 2.3
IliA '-OJ! I 10 mm.' 2114111.'3 0.22 3 110 n 2.JU
112 (-on I 11.6 mODO. JJ 111119:1.51 0.22 U II
(-831 S 1206 234000. JJ 2I147n.54 0.22 u liD
lIS (-0.' I 12.7 231"1.6' 2114711." 0.45 0.45 liD '.4U
III 11-"-1 5 12.1 231.10. t1 2111161.1 O.22 .D liD UU
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1M" .'-S 15 12.1 23]910." 1114161.1 0.22 liD
111-.'" 20 '12.' 2)1.10..7 2114168. I 0.22 II'
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-------
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--- -- ---- --- - -- ---- ---- --- ---- ---- ----
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1-022 J 12.' 211"1 2174"'.15 5n 1 5n
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.... J 12.5 . 2J4e11." 217"10.87 0.22 1 ".
121 I" .~ I 12.' ISMS.IS 2174711.55 1.7 1 1.7
l-llt S 12.' 2S_.15 2174711.55 1.1' 1 1.1 I.'
122 I"" I IS.' 2J48I8.. 2174m.7' IU , 11.'
I"II '~ J 11.' 2J448.. 217471 1.7. 64. , 64.
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...2 ... IS.' 2J4Mt." 2I7enu 0.' <1.0
a-..s I-II IS.' 2J416.." 2I7enu 0.' <1.0
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12' 1 -tS2 S 11.1 21"".15 217"'1." 0.22 1 . . 14011
125 1-t2J I 11.1 mMS.U m...... 25 2.5 25
1..,4 S 11.1 21"".11 217..1... 4.. 2." 25 411
126 I..St . 12 2_1.42 217462"" 0.22 1 II
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127 l-esl I 12 214"'." 2174615.74 0.22 . . IIU
121 HIS I IS 211141." 2171115.26 0.1' 1 . 0.56
..... J . IJ 2141U." 217"15.26 0.22 1 .
121 1-015 I 11.7 214121.4' 2I741tO. 41 0.22 1 .
1..16 J II.' 214121." 2174100.41 0.22 J .
110 a-IH. 2-t 11.1 21'm.17 m...u, '.2 6.2
iI-as"2 ... 11.1 2141JJ. 17 m46'U' 0.5 (1.0
IJI 8-21'" 2-t 12 214131.02 m46'J.OI 1.7 i.7
1S-2I-02 ... 12 214111.02 m46'1.01 0.' <1.0
m £-oJ, I 12 214141.67 217461 UJ 0.22 J "0
(-018 1 12 21414... 7 m4.. us 0.22 S "'
m t -027 1 .1 21m2." 2174"2.'7 0.22 II
t-021 1 IS 214m." 2174152. t7 0.5 0.5
U. t-OS5 I 12.' 214165.12 217 415 7.5 0.45 0.45
t -t56 1 '2.' 21416'.12 2174157.5 0.22 "'
115 1-009 I '1.' 21416O.0S 2I7m4.n 0.26 175 "' liD
1i-010 1 II.' 234160.01 21747".n 0.22 "'
U6 (-on I 82.S 2141'0,6 2I7mus 0.22 I' --
(-044 1 '2.J 234110.' 2I7mUJ 0.8 liD I< 1.61 "0 2. JU .
-------
i , ~I
PCfCM.81 'CP [IJII(UIRATlOIIS
PCP CIIICtITIATi. '1".,1 RI REPOR' ,..,., I
RD I£POI'
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E-04. S 12.2 234111.6' 21741'1.55 0.22 t, . 2.2U
131 C -ISS I 12.1 2Jt2tI.S5 mmS.42 0.22 <0.45
C -tSt S 12.1 2S4201.S5 mmS.42 0.22 II
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110 C"2I I 11.5 2Jt2ll.14 2175804. SI 0.22 2 ..
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112 C.... I . 2M21U. 2174'54." 1.25 1.5 1.25
C-tll s . 124212." 2m'54." 1.25 1.5 1.25
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C..I2 S IS.' 2"212.54 2174151.7 4.25 I <10 3.5
1M c..n I IS.' 2S422t.75 2174154.54 27.4 2 27.4
.c..311 S IJ.' 2S422t.7S 2174154.54 ... 2 U
I'S C.." I 12.' ISml." zm7..... 17.5 17.5
c-t2t s 12.' 2M211." 217""." <10
Iii C-lSi I 12.1 1S121"" m"u." 0.75 0.75
. C-tD S 12.1 2ml...' m4m." 0.22 <0.45
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11-4\-1 15 IS.I ISIZft.17 2174... n 0.22 t,
11-11-4 2t IS.I 2S4211.1' m.....7S 0.22 ..
11-11-5. n 11.1 214m.17 2174111. 7S 0.22 I,
''; ""1-' so IS.I 2"219.17 217481.71 0.22 .' . IOU
III It-Is..1 N It 1S42".II 2174111. n 0.5 0.0 <1.0
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II-IWI II." It 2142"." 2171111.25 I I
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149 C-Ost I II.' 23UIO.SI 2\14"3.2 0." 2 II 0.7
C-012 1 14.t mS10.1I 2174..3.2 Z
150 C-ItS I IS. 7 2S4S11.0I 21749".24 1.6 1.5 1.6
C -oM 1 13.7 2141\\.01 2mm.24 1.5
IS' C-tu I IS mS81.4] ZI14I47. IS <10
C.... n:it-tl S IS 2S4SOI.U 2\148" . 93 <10
'52 N IS.' mm.2Z 2114115.1' 2.5 2.5
ft-""Z ... IS.' mm.22 2\1.115.1. 0.5 (1.0
.51 C..21 I 11.6 mSlO.7I 2174111.6 <10
c..n 3 11.6 2343\0.71 2\14111.6 4U 4U
I" n- "-01 2-4 IS.' 214m." 2\14162.92 0.5 <1.0
n- 16-02 4-6 IS. I 214352." 2mm.I2 0.5 <1.0
155 C-049 I . IS.S 214S11. I 2114724,65 0.22 S ..
[-O~ 1 IS.S 214J11.1 2114124.65 0.22 S <0.0'.
156 [-057 I ".1 214406.24 2I1~SO.16 0.6' . I ..
[-051 3 ".1 234406.24 2I7~SO.16 0.22 I I'
157 C-039 I 11 214401." 2\15010.58 I." 0.5 I."
[-040 1 IS 214401." 2175010.511 0.9 0.5 0.4 1.& 0.1
-------
tr, {O/"
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-- -- ---- -- --- -- ---...- ---- ---- ------ ----- ---- --- --
151 C -tr.I I IS.' 2J4407.SJ 211"44.41 4.5 1.5 4.5
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1St 11-21-01 2-4 IJ.S 214J11.76 217..U..J 0.5 <1.0
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I" a-2H1 2-4 IS.S 134147.32 21741".17 0.5 <1.0
a-2H2 ... 13.S 23U47.J2 217'911.17 0.5 <1.0
8-2H3 1-1. IS.S 134347.32 21741".17 7 7
a-..' '2-14 IS.S 214J47.J2 2174911.17 0.5 <1.0
, 8-21-15 "-'1 IS.S DU47. 32 217"".17 0.5 <1.0
I" e-ols I ".1 2M4IS." 2174147." 121.75 27.5 210
c-o.. 3 I'" 2J44IS." 2174147." 1575 1515
..2 , c-on . I.., D''''." 2174767.01 51.5 51 59
t -02' 3 ".S 234489." 2174767." 127 114 120
.63 ~C-OJS I " m4lU3 21747U.I 3120 1120
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Pt(l I*
PCPCMC.WI
110
174
177
171
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214407.42
PCP
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0.22
0.22
0.22
1
0.43
0.27
PCP CONCCNtRAllOMS
PCP CONCENTRATIONS lt|Ag) Rl REPORT l*g/k«l
RO RfPORI
ClP
Diitk Duflicatt Ovphciti Otttction
to GN Ontitt Omit* locil loci) licit CMcmtrition Ipcil Duplicitt ClP
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23 -- 53.4 32.1
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1 O.fS --
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1 III
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1 0.43 --
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ii 0.43
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-- li Mi»lf (Ml tl lit ir M Mi
0 M MKM| *I|M i iliiM* pMtlficitign liiit.
J EitlMM vil«.
-------
APPEliDIX D
REVISED SOIL CLEANUP LEVEL
. - ~
..,.. ~
. .
:,;. !{ .)~ '
;.
..: -...:- --
-43-
.. .
-------
DETERMINATION OF TARGET CONCENTRATIONS (BASED CN PV3I.::
HEALTH CONSIDERATIONS) OF PENTACHLOROPHESOL IN SOILS
AND GROUNDWATER AT THE COLEMAN EVANS SITE
The- jaseline public health evaluation performed for the Coleman Ivans site
deterair.ed that it was unlikely that potential human health risks vould
result from, exposure to contaminants at the Coleman Evans sit* under current
land- use conditions. The current use exposure scenarios considered were
(1) dermal contact with contaminated soil/sawdust, (2) inhalation of
airborne contaminated soil or sawdust, and (3) dermal contact with
contaminated surface water.
However, under a no-action alternative that does not include institutional
actions limiting future use and development of the Coleman Evans site and
surrounding area, the PHE determined that additional potential exposure
pathways could occur. The cvo potential future use scenarios considered in
the PHE were consumption of contaminated shallow groundwater at the site and
consumption of root vegetables, in which contaminants have translocated and
bioacc-aulated, by people living adjacent to the site. Under each of these
»
exposure scenarios and assuming exposure to the maximum levels of
pentachlorophenol (PCP) found in groundwater at the site, daily intakes of
POP would exceed acceptable chronic daily intakes for this chemical. Mean
levels of PCP in groundwater would not result in intakes exceeding
acceptable levels under either scenario.
In this document the target concentration of PCF in groundwater based on use
of this water for potable uae, is developed followed by target
concentration* of PCP in soil for the protection of groundwater and
vegetable* grown in these soils.
1. TARGET CONCENTRATION OF PC? IN GROUNDWATER USED FOR DRINKING
,;• The EPA has calculated a reference dose (RfD) for chronic exposure to PC? of
*
' 3.0x10* mg/kg/day (EPA 1987). Assuming that exposure is chronic and that
-------
ex?osed ~~d~7idU&:s ~eigh 70 ~g and ~ons~e : :~:e=s
~: ~~:a= ~e= ~a::.
a
target conceneration in dr~nking water is ~alc~lated as
:o::o~s:
Target conceneration of PCP
in d~inking water
RfD (mg/kg/day) x body '.Ieigh: (~g)
Dr~~k~~g ~a:er cons~ptio~
. . .
',-:..:e::5/ I:a:: .
-
.?
3.0xlO - (=g/kg/day) x 70 (~g)
2 li :ers/day
-
1 mg/li~er
2. !.~~GE: CCNC~~T:ONS OF PCP IS SOIL
~CR !H£ PRC!~~~:CS
OF GRCt~D'.;A::::?
PC? may be released from soil into the soil pore water and i~f~::ra:e i~:o
t~e shallow groundwater. In order to determine the concentratio~ 0: PC? ~~
the soil that will be protective of groundwater. ~JO si=ple models ~ere
used. A simple dilution model is firs~ used to determine the cor.centra:ion
of PC? in the 50il pore water. that on mixing with the water tae:e aquifer
beneath the site, would result in the target concentration of 1 ~g/l of PCP
in the aquifer. It should be noted that this aralysis ,aSSWlles that the
contaminants in the soil pore wat~r are diluted by groundwater that does no:
contain PCP. The second model back calculates a soil concentration that
corresponds to the soil pore water concentration assuming equilibri~~
conditions.
The dilution model is a simple mass balance equaeion:
Qw <;,
Qw + Qgw
Cgw -
where
C - eoncam1D&ftc conceneraeion in the groundwaeer (mg/l):
IV
Qw - voluaeer1c flow raee of recharge '(.oil pore water) into the
. aroundvaeer (fe3/day);
Q~'- voluaecric flow raee - of groundwaeer '(ft3/d&y): and
Cw .- coneaminane conceneraeion in ehe .oi1 pore water (mg/l).
. -
.... - '"
. '-
~ . -- -..
- ...j."v..!1 "
2
~
-------
'!::e rac::arge a:
:::e s~:e ~as es:~~a:ed :~ ~ea?prox:=a:a:y :0
~:-.:::es ;:e::
year based on data preseneed i~ Geraghty et ~l. and ErA 1985. :: .as
determined chat a surface area of approximately 2.43 x 105 fee:2 is
contaminated vith PCP. The resulting volume~ric flow rate of rec~arge ~s
550 ::3/day. The volumetric flow rate of t~e groundwater benea:~ the s~:a
was determined ~y:
Q .- A K dh/dl
gw
where
A
. cross sectional area
K . hydraulic conduc:iv~:y
Ch/dl - hydraulic gradient
The cross sectional area of the site (33.000 f:2) is dete~ined by
multi?lying the width of the site per?endicular to groundwater f:ow (1.:00
ft) by the saturated thickness of the water table aquifer (30 feec). ~e
hydraulic conductivity and hydraulic gradient are defined in the RI to ~e
5.4 ft/day and 0.008 respectively. Using these parameters, and the carge:
concentration of PCP in drinking water of 1 mg/l. an acceptable soil pcre
water concentration (Cw) of 3.6 mg/l results.
!he corresponding target 5011 concentration (Cs) is dete~ined using t~e
following relationship:
Kc1-
Cs
Cw
Where 1
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The KOV (octanol-water p*rticion coefficient) of PCP is dependent on the pH
of the aqueous phase. At high pH values, PCP is ionized and therefore more
soluble and less well adsorbed onto the soil matrix. This can be factored
into equation (2) by calculating a pH-specific log Kov. This calculation
relies on the fact that different values of Kov are associated with varying
degrees of PCP ionization. If the extent of ionization is represented by Q.
*
the following equation which is based on the lojj Kow values for the ionized
and ionized forms may be used to calculate log Kov for groundwater of a
given pH:
log KQw - Q (5.25) * (1 - Q) 2.04
Q, the extent of ionization, is itself calculated from the pH of the
groundvater and the ionization constant for PCP:
where
Q - (1 + (5.62 x lO'S/tH*])'1
and
[H+l - 10*PH
Since the groundvater at the site has a pH of 5.2, substitution in these
three equations yields a site •specific log Kov of 3.73.
Substituting this value of log KgV in equation (2), and .the resultant K0c
in equation (1) together with Che average organic matter content of soil
(0.441)1, based on recant analyses in the unsaturated zone (2 to 4 feet), a
target soil concentration (Cs) of 40 ppm results.
1 The geometric mean of the organic matter in the 2 to 4 ft zone was
considered to be representative of the average organic matter content of the
unsaturated zone. The geometric mean was used because measurements of
environmental parameters are generally log-normally distributed (Dean 1981).
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3. TARGET CONCENTRATION QF PCP IN SOIL SASED ON ROOT Vf-~A3L- '•?-*¥*
Two siapl* models have been used to estimate che target concentrations of
pentachlorophenol (PCP) in surface soil at che Co leman- Evans site based on
plane uptake of PCP and subsequent ingestion by humans. Both models were
developed in Briggs et al. (1982). One model addresses uptake from solution
(i.e., soil water) by roots, and the other, uptake by roots and subsequent
translocation to shoots. In both of these models the degree of
concentration of the contaminant in the plant is dependent on the octan-1-
ol/vater partition coefficient (KQV) -
Log K is used to calculate the root concentration factor (RCF) and the
transpiration stream concentration factor (TSCF) (a measure of the
concentration in leaves) using the following equations:
log (RCF - 0.82) - 0.77 (log KQW) - 1.52
TSCF - 0.784 exp ( - (log KQtf - 1.78)2/2.44)
These calculations yield an RCF of 23.3 and TSCF of 0..165. These
concentration factors are then used in the human uptake model together vith
the reference dose for chronic exposure to PCP (3.0 x 10" mgAg/day (E?A
1987) or 2.1 mg/day for a 70 kg person), to determine an acceptable
concentration of PCP in soil water and its corresponding soil concentration.
The relationship between the AIC of PCP and the acceptable concentration in
soil water (C) is as follows:
AIC - (C^ x RCF x ADCR)
+ (C* x TSCF x ADCL)
where
ADC& - average daily consumption of root crops
ADCL - average daily consumption of leaf crops
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US~A (1977) s~ri:es food consum~tion for households in ~arious ~~:~me
categories in the southern portion of the United States. This sucma~: .as
based on a household survey taken during one veek 1n 1977. For eac~ ::~e 0:
food consum8d. . totals vere presented for all of t~at type and for all of
t~at :ype that vas purchased; the difference of these ~.o categories is food
t~at is home produced or received as a gi:~ or pay. For t~e ~ur?0ses of
this soil cenceatration estimaee. the difference be~.een toeal cons~ed and
purchased vill be assumed to have been produc~d 1n a home garden. Table 1
summarizes the quantities of home-produced root crops and leaf vegetables
consumed perperson in households located in a non-metropoli~an area for
various income groups. S1nce eotals vere preseneed by household si:e, an
average household size of 2.8 persons (USDA 1977) vas used to determine :~e
amount of each ~e of food consumed per person per day.
The acceptable soil concenerations presented in Table 1 are deeer:ined
primarily by the ingestion of root cro~s since the RCF 1s 23.3. as compared
vith the TSCF of 0.165 for leaf vegetables. and more root crops are consumed
than leaf vegetables. The target concentracion of PCP in soil vas
decermined using the partition coefficient and the assumption that the 50i:
vater is in equilibrium vith the soil. Recent soil analyses has shown :~a:
the average organic mateer content of s011 in the unsaturated zone (2 to 4
feet) is 0.44'. As can be seen from Table 1. ba.ed on these assumptions,
the corresponding target concentration in soil for'the specific exposure
scenarios considered varie. from approximately 26 mglkg to 54 mg/kg.
4. SUMMARY
"
In this docu88ne the tarcet concentration of PCP in groundwater vas
calculate. Co be 1 8&lliter. Target concentrations of PCP in loi1 vere
calculated to range froa 26 pp.' to 54 pp. for Che protection of ground vater
and vegetablel grown 1n 1011. '~o deeera1ne a target loll concentration for
the protection of Iroundvater-fro. leaching. a dilution model, which assumed
. ... ""'. -
compleee .ixing by uncontaminated Irounciwater', "'vas used to calculate a
target .oil concentration of 40 ppm. The target loil concentrations of PC?
6
~
-------
. . :". ~,,.,
based on ~pcake by vegecables and ingestion of vegecables by huma~s ~a~ged
from 26 pp. to 54 pp. b..ed on different con.umption patter~s.
~., ~,:,. , .
7
~
", "
".4
... :-" - _r.~ .;!i.,'. .
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TABU 1
SUMMARY OF HOKE-PRODUCED CROPS AND CORRESPONDINC
ACCEPTABLE CONCENTRATION OF PCP IN SOIL
Income Before Root: Leaf
Tax.. in Cropsa Veget:ablesb
1976 (g/penon/ (g/person/
"y) . d&y)
Under $5,000 18.5 10.4
$5,000-$9,999 38.3 17.1
$10,000-$14,999 29.4 18.5
Cw
(mg/l1ur) .
Cs
(alg/kg)
4.8 54
2.3 26
3.0 34
. aIncludes pot:&t:oes, carrot:s, curnipl, b.et:s, and onionl.
bInclud.. leaf veget:ables, cabbage, and let::uce.
8
~
-- - ---
-- . ---- --
-~,
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REF!1lL~C£S
SaICGS. C.C., IROMlLOY. a.H.. and EVANS. A.A. 1982. ae1atio~hip be~Je.n
lipoph11iciry and rooc uptake and translocation of nonionised ch.mica~s
by barley. Pestic. Sci. 13:495-504
CEAN. a.s. 1981. Use of lognormal statistics in environmental moni:ori~g.
Cooper. W.J.. .4. Chemis:ry ,in wacer a.use. Ann Arbor. ~ic:higan. '1ol .
CERAGHTY J.J., MILI.Dl,C.W.. VAli cm U:£DE.~.F, in4 nOISE.F.L. 1973. -a:er
Atlas for ~e Unite4 States. water Infor=&tion Cent~r. Inc. Por:
Washingeon, N.Y.
E.WIIl0NMEN'rAL PIl0TEC'1'ION AGENCY (EPA). 1985. CRASTIC: A Stanc!ardize4
, Syseem for evalu£ting groundwater pollution potential using
hydrogeological settings. Office of aesearch and Cevelopment.
EPA/600/2-85/018
E.~IIl0~~AL PIl0TEC'1'ION AGL~CY (EPA). 1987. Integraced aisk Information
System (IIlIS) Chemfil.. Environmencal Criteria and Assessment Office.
LYMAN. W.J., ee. al, 1982. Handbook of Chemical Properry Eseimacion
Methods: Environmental Sehavior of Organic Compouncia. McGraw-Hill Book
,Company
U.S. CEPAll'IKENT OF ACllICUtTUllE (USDA). 1977. Food Consumption: Households
in the South. Spring 1977. Nationwide Food Consumption Survey 1977-78.
llepore No. H-4
9
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