Superfund Record of Decision: Hipps Road Landfill, FL


            United States
            Environmental Protection
            Agency
              Office of
              Emergency and
              Remedial Response
EPA/ROD/R04-86/010
September 1986
&EPA
Superfund
Record of Decision
            Hipps Road Landfill, FL

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             TECHNICAL REPORT DATA           
   ,     (P/~1U1 nGd /lfllfllctions on the 'tvtn~ INIon com"lltilllj         
1. ".~O"T NO.     r.         3. AECIPIENT'S ACCESSION NO.  
EPA/ROD/R04-86/010                    
.. T'TLE AND SU,TITLE                5. AEPOAT DATE      
SUPERFUND RECORD OF DECISION               September 3, 1986
Hipps Road Landfill, FL           5. PERFORMING ORGANIZATION COOE 
7. AUTHOR'SI                   8. PERFORMING ORGANIZATION AEPORT NO.
8. I'ERFORMING ORGANIZATION NAME ANO ADDRESS        10. PROGRAM EL.EMENT NO.  
                     11. CONTRACT/GRANT NO.    
12. SPONSORING AGENCY NAME AND ADDRESS         13. TYPE OF REPORT ANO PERIOD COVEREO
u. s. Environmental Protection Agency            Final ROD Report 
401 M Street, s.w.                14. SPONSORING AGENCY CODE  
Washington, D.C. 20460                 800/00    
18. SU~I'LEMENTARY NOTES                        
18. ABSTRACT                             
Hipps Road Landfill is located at the intersection of Hipps Road and Exline Road in
Jacksonyille Heights,  Duval County, Florida. The area is a semi-rural residential 
neighborhood. Two homes are physically on the landfill and three other residences are
immediately adjacent to it. The landfill is situated above the 500-year flooo plain and'
there are no ecologically sensitive areas nearby. Surface water is not used to supply
dr ink ing wa te r in the  area,.and recreational purposes consist of swimming, boating '
fiShing, ano similar activities. Present lateral distance of ground water contaminatio .
extends approximately 1,000 feet northeast of the site. In 1968, the property owner,
Mr. G. o. Williams (now deceased) contraced with Waste Control of Florida, I nc., a loca
disposal company, to fill in the site t' No ie~ord of the fill material exists.  
Operations ceased in 1970 when a permit request to extend the landfill eastward was 
denied.  Problems were first reported in the early 1970s when a pond adjacent to the
landfill developed a thick, smelly film, and fish and nearby vegetation died. No recorc
of action was noted.  In February 1983 area residents began to complain of a foul odor
and taste in the drinking water. We 11 sampling identified the presence of VOCs in the
drinking water. During re-sampling studies in March, April and August 1983, large r 
suites of VOCs and metals were discovered. Between June and October 1983, the city 
installed waterlines supplying the site residents with city water. By January 1985 
- (See Attached Sheet)                        
'~7.        .. KEY WORDS AND DOCUMENT ANALYSIS           
~.    DESC"'~TOAS       b.IDENTIFIEAS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision                          
Hipps Road Landfill, FL                       
Contaminated Media: gw, sw                     
Key contaminants: organics, VOCs, inorganic ,              
toluene, metal                           
18. DISTRIBUTION STATEMENT          1e. SECURITY CLASS (This R,ponl 21. NO. OF PAGES 
                   None        191
                 20. SECURITY CL.ASS (This pag,) 22. PAICE  
                   None         I
!PA ,- 2220-1 (Re.. 4-77)
PlllltVIOUI EOITIO... II O.IOl..tTE

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EPA/ROD/R04-86/010
Hipps Road Landfill, FL
16.
ABSTRACT (continued)
ground water was no longer a source for drinking water in the area. The
primary contaminants of concern include: VOCs, TCE, metals, xylene,
toluene, benzene.
The selected remedial action incluaes ground water recovery and treatment
at the POTWi Subtitle D landfill closure, and institutional controls. The
estimated cost for this remedy is $3.9-4.4 million. Capital and O&M costs
were not specified separately, however, EPA will fund O&M activities for one
year after completion of the remedial action. O&M will continue for 20
years using funds provided by the State of Florida.
. .

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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
SITE
Hipps Road Landfill
Jacksonville, Duval County, Florida
IXX:UMENTS REVIEWED
I am basing my decision primarily on the following docLrnents describing
site specific conditions and the analysis of effectiveness and cost of
the remedial alternatives for the Hipps Road Landfill Site:

- Hipps Road Landfill ~medial Investigation Report,
- Hipps Road Landfill Feasibility Study,
~ Summary of Remedial Alternative Selection,
- Hipps Road Landfill Public Health Evaluation,
- Agency for TOxic Substances and Disease ~istry - Health
Assessment: Hipps Road Landfill,
- Department of the Interior - Release framClaims for Damages
to ...he Natural Resources Under 001 Trusteeship.
DESCRIPTION OF' THE SELECTED REMEDY
- Proper landfill closure under Subtitle D of RCRA and Chapter 17-7
of the Flo~ida Administrative Code.
- Recovery of contaminated ground. water with treatment at the Local Publicly
ONned Treatment v«>rks (POIW). Contaminants will be recovered until the -
ground water quality is in compliance with the standards set forth under
the Safe Drinking Water Act. f S~). C()ntaminants not addressed U1der
the SDWA will be removed until compliance with the 1980 Water Quality
Cri teria HllIIan Health Standards is reached. Where no standards exist,
a cancer risk of 10-6 will be used as the clean-up target; however, this
will be redefined in the design phase.
- 1he ground water recovery systems will be maintained in place and re-
activated if subsequent levels of ground water contaminants are detected
in levels above the predetermined standards.
- Continued roonitorinJ of the ground water after recovery and treatnent
of the contaminated ground water is canpleted, according to the standards
established durinJ the Remedial Design Phase. fok:>nitoring will continue
for twenty (20) }lears following the final ground water recovery phase.

- Institutional controls, which will be fully identified during remedial
design, will be implemented. 'Ihese controls may include, but will not
be limited to:

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- fencing the site,
- grouting existing private wells,
- instituting a well drilling ban which can be lifted at the
conclusion of the 20 }oear monitoring period, and
- acquiring affected properties under the policies and practices
established by the Federal Emergency Management Agency (FEMA).
- Operation and maintenance (O&M) activities will include:
- operating and maintaining the ground water recovery system,
- ground water monitoring,
- maintaining the landfill cap and associated systems,
- maintaining the connector sewer lines which access mains to
the PCflW,
- maintaining the site security systems.
Additional O&M activities may be identified during the Remedial Design.
DEClARATIONS
Consistent with the Oamprehensive Environmental aesponse, Compensation,
and Liability Act of 1980 (CERCrA), and the National Contingency Plan (40
CFR, Part 300), I have detennined that the above Description of Selected
Remedy for the Hipps Road Landfill Site is a cost-effective remedy and
provides adequate protection of public health, welfare, and the environment.
'!he State of Florida has been consulted and agrees with the approved
remedy. '!hese activities will be considered part of the approved action
and eligible for Trust Fund ,monies until ground- water clean up levels are
attained or for a 10 }oear period, whichever occurs first. '!he basic
'assllTlption is that the responsible parties fail to undertake the design
and implementation of the selected remedy. If clean up levels are not
reached wi thin the 10 }oear period, the Ramedial Design and lenedial
Act ion will be re-eval uated.
I have also detennined that the action being taken is appropriate when
balanced against the
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SECTION I
SITE UXATION AND DESCRIPTION
The Hipps Poad Landfill is located on the southeastern corner at the
intersection of Hipps Road and Exline Road in Jacksonville Heiqhts, Duval
County, Florida (Figure 1). The area is a semi-rural residential neiqhbor-
hood. TWo homes are physically on the landfill and three other residences
are llTImerliately adjacent to the landfill.
The landfill has relatively low topographic relief and is sparsely covered
with qrasses, brush, and pine trees. Fill material extends to a depth of
approximately 25 feet, and debris is scattered across the surface. Due to
deqradation of the fill material and resultant subsidence, many of the
disposal cells can be visually identified. There are no ecologically
sensitive areas near the Hipps Road Landfill, and it is situated above the
SOD-year floodplain. Surface water is not used as a drinking water supply
in the area, and recreational nurposes consist of swimming, boating, fishing,
and s~ilar activities.
Until receAtly, the area residents relied exclusively on ground water
resources for their water supply. In 1984, the City of Jacksonville extended
the city water mains into the area. Citizens who had not elected to hook-
up to the city water supply were connected during 1985 under an EPA emergency
reSf.X)nse action.
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...
Figure 1.
Site location map. Hipps !bad
Landfill, Jacksonville, Duval
COtmty, Florida.
/.
Hipps
II
.
Marlee Road
Unnamed Tributary
Road
D~HjPPS Road
landfill
Taylor Field Road
\
1.
QJ
~
....
Q:
"0
fa
o
0:::
L
QJ
,......
"0
C
.c
VI
0'
.
1000'
,
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SECTION II
SITE HISTORY
Initially, the landfill area was a cypress swamp.' In the mid-1960's, the
property was owned by Mr. G. O. Williams. Mr. Williams (now deceased)
contracted with at least one local disposal company to fill in the swamp in
1968.
Before 1970, landfills were not required to undergo permitting and, therefore,
no records of the fill materials were made. In 1970, a request was submitted
to the City of Jacksonville for permission to extend the landfill eastward.
The request was denied and operations ceased in 1970.
At that time, the landfill was covered by a thin layer of soil and divided
into lots. '!hese lots are currentl y owned by Mr. and Mrs. D:>nald W:xxtnan
(9084 Hipps Road), Mr. Henry Vorpe (9110 Hipps Road), Mrs. W. H. Gore (9032
Hipps Road), and Mr. A. tblan (7145 Exline Roaf.:.
TWo parties have been identified as Potentially Responsible Parties. '!he
first is a hauling canpany that lB'ldertook the landfilling operations, Waste
Control of Florida, Inc., which was acquired by Waste Management, Inc., of
Oak Brook, Illinois. Based on this chain of ownership, Waste Management,
Inc., was issued a notice letter on tbvember 18, 1985.
Materials recovered fram the landfill indicate that one source of the fill
material was the U. S. Navy facilities (N.A.S. Jacksonville and N.A.S.
Cecil Field), which are near the site. The materials inclLrle cans of
trichloroethene (which have Navy serial numbers and identification), practice
artillery rOlB'lds, microfilm of military equipment designs, and miJitary
training manuals. Anecdotal information fram retired employees of Waste
Control of Florida, Inc. indicates that material fram the Naval facilities
was hauled to the Hipps .Road Landfiil by Waste Control of Florida. '!he
notice letter to the U. S. Navy was issued on March 22, 1985. At that
time, representatives of the U. S. Navy indicated that they would be
unwilling to conduct the RI/FS and the negotiations were suspended.
Problems associated with the Hipps Road Landfill were first reported in the
early 1970's when the pond adjacent to the landfill, now owned by AI and
Gail Speicher (9040 Hipps Road), developed a thick, smelly film and fish
and nearby vegetation died.
In February 1983, residents in the area began to canplain of a foul odor
and taste in the drinking water. At that time, the City of Jacksonville
sampled private wells and folmd vinyl chloride and methylene chloride to be
present. A re-sampling was conducted in March 1983 to verify contamination
and toluene, vinyl chloride, and methlyene chloride were found. A third
sampling was conducted in March/April 1983 by the Department of Health and
Rehabilitative Services. A much larger suite of volatile organiccanpounds
were folmd: benzene, ethylbenzene, toluene, xylene, methylphenol,
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o-cyclohexene, dichlorobenzene, methylene chloride, dichloroethane,
trichloroethene, vinyl chloride, dichloroethylene, 2-butanone, and 4~thyl-
2-pentanone.
At that tllTIe, the City of Jacksonville began to provide residents with
emergency bottled water. By June 1983, the City had initiated the installation
of city water lines to the affected area. Construction of the water lines'
was completed in October 1983.
In August 1983, a joint study by the Florida Department of Environmental
Regulation, the St. Johns Water Management District, the U. S. Geological
Survey, Jacksonville Bio-Environmental Services Division, and the Duval
County Public Health Division was canpleted. The study found a similar
suite of chemicals noted in the March/April 1983 investigation: 1,1-
dichloroethane" benzene, toluene, ethylbenzene, xylene, n-butylbenzene,
dichlorobenzene, o-chlorotoluene, methylene chloride, chloroform, 1,2
dichloroethane, 1,1,2,2 tetrachloroethane, 1,2-dichloroethylene,
trichlor~thene, tetrachloroethylene, 2-butanone, tetrahyrofuran,
mercury, lead, zinc.
In August 1983, the Hipps Road Landfill was proposed for inclusion on
the National Priorities List with a Hazard Ranking System score of 31.94.
A year later, in August 1984, the site was approved for remedial activities
under CERCIA. EPA's REM II contractor, Camp Dresser & McKee was tasked to
perform the RI/FS in September 1984. The site was finalized on the NPL in
September 1984.
In January 1985, EPA initiated an Emergency Response Action to connect
local residents who were still u~ing ground water supplies to the City
water supply. This response action was completed in September 1985.
After finalization of the Hipps Road Landfill WOrk Plan in April 1985, the
Remedial Investigation field investigation was initiated. The Remedial.
Investigation Report was finalized in February 1986, and the Feasibility
Study was released for public camtent in April 1986. A public reeting was
held in Jacksonville, Florida, on May 7, 1986.
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SECTION III
CURRENT SITE STATUS
ONSlTE SOILS
Soil samples were collected from 17 locations within the landfill (Fiqure
2). The identified contClTlinants were not found to be pervasive due to the
heteroaeneous nature of the landfill. The base of the landfill was
identified to be 24 to 26 feet below the surface.
The contaminants found include nickel, zinc, aluminum, mercury, lead,
sodium, benzene, chlorobenzene, ethylbenzene, xylene, carbon disulfide,
methyl ethyl ketone, di-n-octylphthalate, 1,4-dichlorobenzene, 2~thyl
napthalene, di-n-butylphthalate, bis (2 ethylhexyl) phthalate, and
napthalene (Table 1). However, the risk assessment found that none of
these' compounds were present in concentrations of toxicological concern
( FS, P . 3-11).
Potential miqration of the soil contaminants is via percolation of rainwater
into the ground water, lateral migration of the ground water through the
soils, or storm water runoff from the surface and into the small pond
adjacent to the landfill.
Soils in the landfill are poorly consolidated and sandy in nature. AI though
the landfill was never capPed, it was covered with a thin discontinuous
layer of sand at the time operations ceased.
SURFACE WATER AND SEDIMENTS
The rx>nd, wh ich 1 ies alonq the eas tern border of- the 1 andf i 11, is recharged
by rainfall and ground water, and discharge is by lateral movement into the
surficial aauifer. Sediment and water sampl€s collected from this pond
indicate that it has not been contaminated by the landfill (RI, p. 5-7).
To the north of the site is an unnamed tributary, which flows east into the
Ortega River, and ultimately into the St. Johns River. This unnamed
tributary also captures ground water flowing fram the site. Samples fram
the streCITI water and sediments indicate that there is no contcrnination
which can be attributed to the landfill (RI, p. 5-7).
HYDRCX;EQr.cx:;y
Ground Water Characteristics. At the Hipps Road Landfill site ground water
contaminants are present in the Surficial Aquifer System. The surficial
aaui fer is comprised of three zones: the water table zone, the semi-confininq
unit, and the 1 imestone unit. QJring the Remedial Investigation it was
established that contClTlinants had invaded both waterbearing units. Ground
water level elevation measurements from wells in the vicinity of the site
indicate that the ground water under the landfill has a steep vertical
downward component of flow, based on tri-level measurements. The ground
water oenerally flows to the northeast and east. As the ground water
approaches the unnamed tributary, it exhibits an upward vertical component,
and may ult~ately discharqe into the unnamed tributary.
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R = Residence
o = Outbuilding
0' 100'
I I
scale
N
1
~~
HIrPS ROAD
G
G
@
R
BH-IO
8
BE-IS
8 BH-8
o
-=:. 8 BH-I 7
c BH-138
~ BH-6 8
~ OJ -BH-5
z
H
~ ~-25
x
~ BH-2
BH-2I 8
8BH-27
{Y 8 8BH-4
BH-24
8BH-3
BH-268
~pproximate ./
landfill boundry
-
BH-29
Figure 2.
Onsi te Soil SaIt;>ling IDeations Used During the
Hipps Road Landfill Field Investigation.
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Table 1.
Contaminants Identified in Onsite Soil Samples.
Milligrams Per Kilogram (IIQ/kg).
Concentration is in
BH-2 BH-3 BH-4 BH-5 BH-6 BH-7 BH-8 BH-IO BH-13
PCB (Aroclor 1260) I
Methyl Ethyl
Ketone
Ethyl Benzene ,
'Ibluene ( .64) ( .16) (1.6) ( . 48) (1.1)
Di-N-Octylphthalate
Benzyl Butyl
Phthalate
1,4-Dichlorobenzene
2-Methyl Napthelene
Di-N-
butyl phthalate
Bis (2-ethylhexyl)
Phthalate .096
Napthalene
Benzene
Chlorobenzene
Xylene
Carbon Disulfide
Aluninun 470 l5x
Arsenic ( .04)
Cadmi un (1.2)
Chraniun ( .8) ( .9)
Copper 0.0)
Iron
lead
Manganese
Mercury

Nickel
Sodi un
Zinc
I I I I I :~: I . I 13.6 I
I I I (1.8) I (.8) I (.7) I I I
(o.oJ
~
I 3.2
r = data rejected under QA/OC
x = estllnated value
() = locai lab data
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Table 1 (cont.).
Contaminants Identified in Onsite Soil Samples. Concentration
is in Milligrams Per Kilogram (m;J/kg).
BH-15 BH-17 BH-21 BH-24 BH-25 BH-26 BH-27 BH-29
PCB (Aroc1or 1260)
Methyl Ethyl
Ketone .003
Ethyl Benzene .011 .03 ( 1. 59)
'Ibluene 1.48 ( .26) (1. 23) ( .20)
Di-N-Octy1phtha1ate .043x
Benzyl Butyl
Phthalate 4.3
1,4-Dich1orobenzene .l4x
2-Methy1 Napthelene .058 .55
Dl-N-
buty1phtha1ate .19x
9is (2-ethylhexyl)
Phthalate 330x 1.4
NaPthalene .093x .45
Benzene .004 .004 .005
O1lorobenzene .052 .02 .11
Xylene .32
Carbon Disulfide .001
Al unimrn 1700 3400 8600x 1900 6300x
Arsenic
Cadmi LITl
O1raniLlTl
Copper
1<.6)"' I. I. I I I (1.2) I (1.9) ~
Iron 420 500x 740x 1100x
lead (1.3) 12x 6.3 18
Mana ane se 8.7
Mercury .10
Nickel 14
Sod i LITl 2100x
Zinc ( 22) 33 (2.4) (2.8)
r = data rejected under QA/OC
x = estUnated value
() = local lab data
"
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Ground Water Contaminants. Several contaminants were found in ground water
collected fran on site bore holes. O1site ground water sample collection
locations are shown in figure 3. The contaminants found are listed in
table 2.
A larger suite of contaminants was found downgradient from the site.
Sanples were collected fran three types of wells: existing (ffiGS) monitoring
wells, private water wells, and new monitori~ wells installed durinJ the
RI field investigation. Sanple locations are shown in figures 4, 5, and ~.
The concentrations of contaminants in each respective type of well are
listed in tables 3, 4, and 5. Ground water contaninants can be recovered
under the remedial response selected for the site. The present lateral
distance of ground water contamination extends approx~tely 1000 feet
northeast of the site.
Recovery scenarios are complicated by the detection of contamination in the
limestone unit at significant distances upgradient fram the site. The
upqradient contaminants are lLrnited to toluene, carbon disulfide, and
xylenes in the USGS rnonitorinJ wells; C-5 alkylbenzene sulfenamide, C-6
alkylphenol, carbon disulfide and toluene in the EPA monitoring wells; and
toluene and hrcmodichloramethane in the private wells. Only toluene is
pervasive. It is not within the scope of this project to directly address
contaminants migrating fran other unknown sources. However, these canpoums
are present at levels below the 19RO Water Quality Criteria.
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R = Residence
o = Outbuilding
0' 100'
I I
scale
N
1
~l
HII'PS ROAD
o
C2J
@
R
BH-I0
8
BH-15
8 BH-8
o
.-.:: 8BH-17
c BH-138
~ BH-6 8
tIJ rn 8BH-5
z
H
..::I ~-25
x
~ BH-2
BH-21 8
8BH-27
{Y 8 8BH-4
BH-24
BH-268 8BH-3
approximate ~
landfill boundry
8
BH-29
Figure 3.
Q1si te Ground ''later Sanpling IDeations Used During the
Hipps !bad landfill Field Investigation.
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Table 2.
Contaminants Identified in Ground Water Samples from Onsite Bore Holes.
Concentration in Micrograms Per Liter (ug/l).
BH-2 BH-3 BH-4 BH-5 BH-6 BH-7 BH-8 BH-IO BH-l
PCB (Aroclor 1242)
PCB (Aroclor 1254)
PCB (Aroclor 1260)
(5.8) (7.3)
Benzene (27) (18.3) ( 20. 5 ) ( 408) 5.2 2.5x 3.3 I
(4.9)
Toluene (2.1) (10.8) (5.4) 3.8x (2.1)
Carbon Disulfide
011orobenzene (105) (89.7) (45.3) ( 397) (68.7)65 (66.4)26 (5.2) (4.5
Ethyl Benzene (98.5) (5.3) (162) (24.9) (20.4)17 (85.3) (5.0
1,2-Dich1orobenzene (22) (18.9) (18.4) ( 21.6) (7.8
1,4-Dich1orobenzene llx
Xylene 38 3.3x
Methylphenol .
Methyl Napthelene
N-Nitro-
sodiphenylamine l7x
Napthalene llx
Bis (2-ethylhexyl)
phthalate
Phenol
AI unimrn 28,000 180,000x 12,000
Arsenic (60) (40) (20) ( B8) 88 (40) 140
Bariun
Berylliun
Cadrni un (10) (8) (12)12
Ca1ciun 3400 10,00Ox 14, OOOX
O1raniun (30) (40) (40) (50)50 (60)
Cobalt
Copper (20)
Cyanide
Iron 44,000 42,00Ox 4400x
Lead (12)12 (30)26
Magnesiun 8100 13,OOOx
Manganese 490
Mercury 1.6
Nickel ( 26) 26 (50) (10) (30)
Potassiun 10,000
Seleniun
Sod i un 6600 6500x
Vanadiun
Zinc
( 20
r = data rejected under OAIOC
x = est~ted value
() = local lab data
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Table 2 (cont.).
Contaminants Identified in Ground Water Samples from Onsite
Bore Holes. Concentra t ion in Micrograms Per Li ter (ug/1).
BH-15 BH-17 BH-2l BH-24 BH-25 BH-26 BH-27 BH-29
PCB (Aroc1or 1242) 4.6 36x
PCB (Aroc1or 1254) 1.8
PCB (Aroc1or 1260) 38x
Benzene 14 7.9 8.4 (101)
'Ibluene 49 38 ( 23 .9)
Carbon Disulfide 18 4.8 5.4 13
Chlorobenzene 110 19 37 (237)
Ethyl Benzene 7.7 6.2x (17l)
1,2-Dichlorobenzene ( 39.3)
l,4-Dichlorobenzene 3.4x 3.2x
Xylene 13 220 120
Methylphenol 5.7x 4
Methyl Napthe1ene 3 2.6x
N-Ni tro-
sodiphenylamine 9.6
Napthalene 16x 1.3
Bis (2-ethylhexy1)
phthalate 96 29
Phenol 34 I
Aluninun 1,000,000 31,000 15,000 690000x 650000x
Arsenic 220 (5) ,
Bariun 540 1200x 3900
Berylliun 19 (10)
Cadmi un (60)8.4 1400x (7) (50) (50)
Calciun 40,000 24,000x 2700x 2800x 54,00Ox
Chrani un ( 50 )100 1000x 1100x (10) (20) (20)
Coba1 t 42
Copper (50) 220 1200x
Cyanide - 310
Iron 54,000 83,000x 1400x 200000x 280000x
Lead (150) 40 100 34,000 5300x
Maanesiun 18,000 2500x 1200x 6900x 5700x
Mai1q-anese 300 lOOOx 1400x
Mercury .18x 18
Nickel (50)370 (30)
FOtassiun 13,000 1400x 1800x 4800
Seleniun 27
Socii un 30,000 5200x 1600x 76,000x
Vanad i un
Zinc
1100
(860)1400
r = data rejected under QA/OC
x = estUnated value
() = local lab data
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(
~.
~1arlee Road
\
1..
C1.i
>
~
Unnamed Tributary
/
. EMW-8

Er1~'J-7 . . EMW-2
Road .EMW-3
.

D~HiPPS Road
EMW-5. Landf; 11
N
~
10
o
c:
Hipps
. H!W-1
~
cu
~
~
s:
.~
.s:::
c.f)
Taylor Field Road
0'
L...
-
1000'
,
Figure 4.
IDeation of Existing J.t:>ni taring Wells (USGS 1
Used During the RI Field Investigation.
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~'arl ee Road
\
~
CJ
:::.
.-
Q:::
Unnamed Tributary
/
. PW - 22
N
PH-21
. .
.PW-15 "C
ItI
o
e:::
So..
GJ
.- . PW-23
"C
s:
....
PW-8
.r:.
V')
PW -17.
:. -
Taylor F
0'
1000'
,
Figure 5. Pri vate ~lls Sanpled During the RI Field
Investigation
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. .
~'arl ee Road
\
~
QJ
>
a:
Unnamed
Tributary
/
8 t1W-G
N
~
ItI
~1\-1-F 0
cc::
Hipps Road
8 8---~1W-E
~1H - C 8 D~HiPPS Road
~
8t1,v/-B Landfill QJ
..-
r~vl- 0 ~
c:
~n'l-A. .~
~
Vi
Taylor Field Road
0'
.
10fOI
Figure 6.
IDeation of New M:>ni toring Wells Installed and
Sanpled During the RI Field Investigation.
-------
Table 3.
Ground Water Contaminants Identified Existing (USGS) Monitoring wells.
Concentration in MicrO'Jrams Per Liter (UJ/1).
rnw-1 rnw- 2 EMW- 3
10' 40' 10' 55' 80' 10' 60' 80'
Tol uene 64(68)
Carbon Disulfide 8.9 6.0
O1lorobenzene 4.7 (4)
Tetrahvdrofuran llx
Methyl Isobutyl
Ketone 22
Methyl Ethyl Ketone 9.7
Total Xylenes 52 93
Trans 1,2-
Dichloroethane 27 24(33)
Ethyl Benzene 24 3l( 68)
Vinyl Chloride 28 31(73)
Benzene 4.0x 3.8x(8)
l,l-Dichloroethane 5.3(8)
Trichloroethene ( 2)
Ethyl Ether 4.0x 7x
Acetone 3 380 190 800 I
Propanol 40x j
N-Nitrosodiphenyl-
amine/ I
Diphenylamine - ,- 14
2,4-Dimethylphenol 13x
2-Methylphenol 46 20 26
Methylpentanediol 20x 20x
C-3 Alkylbenzene lOx lOx
Qxy Bis Ethoxythane SOx 100x
Methylnonanediol 70x
C-5 Alkylbenzamide lOx
C-4 Alkylbenzene 20x
Ethvlhezanoic Acid 40x
Trimethylbicyclo-
heotanone 70x
Nepthalene 9x 20
Phenol 13x
r = data rejected under QA/QC
x = est~ted value
() = local lab data
-------
Table 3 (cont.).
Ground Water Contaminants Identified in Existing (USGS)
Monitoring wells. Concentration in Micrograms Per Liter (l1J/1).
EMW-1 EMW- 2 EMW- 3
10' 40' 10' 55' 80' 10' 60' 80'
AlllT\ i nlm 5500x 530x 19,000 4500 730 14,000 1100 1200
Arsenic 5.3 '
BarillT\ r r 57 60 110
Cadmi lIT\ r r
Ca1cillTl r r 15,000 2900 60,000 7700 3400 5200
ChranillT\ r r 35 15
Coba1 t r r
Copper r r 25 51 32
Iron r r 3900 1200 310 1300 2600 710
Lead 3 38 4.3 13 11 19 14
Manganese r r 43 37 37 7 29 26
MaonesillT\ r r 1100 1800 13,000 4000 2000 62,000
Nickel r r 23 24
PotasSillT\ 1700 1100 1200 1600 750 1500
Sod i lIT\ r 13,OOOx 2200 51,000 5200 13 ,000 44,000 5000
54
~;j
150 I
Van.ldillTl
Zinc
r
r
r
r
61
t
64
I. 42-i
r = data rejected under QA/QC
x = estUmated value
() = local lab data
-------
Table 3 (cont.).
Ground Water Contaminants Identified in Existing (USGS)
Moni toring Wells. Concentration in Micrograms Per Liter (ug/1).
EMW-4 EMW-5 EMW-6 EMW-7
10' 65' 30' 65' 16' 50' 10' 50'
'Ibluene 7.5 4.7x 41 4.4x
Carbon Disulfide 3.6x
Chlorobenzene
Tetrah ,,~::rrof uran
Methyl Isobutyl
Ketone
Methyl Ethyl Ketone 6.3x 5.1x 5.1
'Ibtal Xylenes 23 23
Trans 1,2-
Dichloroethane 6x
Eth~l Benzene.
Vin 1 Chloride
Benzene
3x
32
f
1,1-Dichloroethane
Trichloroethene
Ethyl Ether
Acetone I
Propanol
N-Nitrosodiphenyl- -
amine/
Diphenylamine 16x
2,4-Dllnethylphenol
2-Methylphenol
Methylpentanediol

~~ ~~y~=~~ane I

Me thylnonanediol ,
.'1
f
C-5 Alkylbenzamide
C-4 Alkylbenzene
Ethylhezanoic Acid
II I I I
II ~
Trimethylbicyclo-
~tanone
Ne thalene
Phenol
r = data rejected under QA(QC
x = est~ated value
() = local lab data
-------
Table 3 (cant.).
Ground Water Contaminants Identified in Existing (USGS)
Monitoring Wells. Concentration in Micrograms Per Liter (ug/l).
EMW-4 EMW-5 E7-tW-6 EMW-7
10' 65' 30' 65' 16' 50' 10' 50'
AI uni nLm 8500x 620x 9300x 980x 5400x 610x 2400x 560
Arsenic 18 13
Bariun r r r r r r r
Cadrni un
Ca1ciun 6700x r r r 21,00Ox 8400x r r
Chranil.JTl r r r r r r r r
Cobalt
Copper r r r r r r r r
Iron 3900x 440 700x 980x r 5000x r r
lead 15 29 4 34 4 14 3
Manganese r r r r r r
Maqnesil.JTl r r r r 6600x 2900x r r
Nickel r r r r r r
Potassiun 5600 5100
Sod i I.JTI r r 8200x 10,000 50,000x 24,000x r 5600
Vanadiun
Zinc
r
r
r
r
r
r
t
r
28
r = data rejected under QA/QC
x = estLmated value
() = local lab data
-------
Table 3 (cont.).
Ground Water Contaminants Identified in Existing (USGS)
Monitoring \'Ells. Concentration in Micrograms Per Liter (U'J/l).
EMW-8
10' 50'
'lbluene
Carbon Disulfide
Chlorobenzene
Tetrah rofuran
Methyl Isobutyl
Ketone
Meth 1 Eth 1 Ketone
'lbtal X lenes
Trans 1,2-
Dichloroethane
Ethyl Benzene
Vinyl 0110ride
Benzene
l,l-Dichloroethane
Trichloroethene
Ethyl Ether
Acetone
Pro anal
N-Nitrosodipheny1-
amine/
Di hen lamine
-.
Trimethylbic~lo-
heptanone
Nepthalene
Phenol
r = data rejected under QA/($:.
x = estllTIated value
() = local lab data
-------
Table 3 (cont.).
Ground Water Contaminants Identified in Existing (USGS)
Monitoring Wells. Concentration in Micrograms Per Liter (llJ/l).
EMW-8
10' 50'
AlI.JT\ i n I.JT\ 7000 r
Arsenic
Baril.JT\ r r
Cadm i I.JT\
Calcil.JT\
Chranil.JT\
3;00 I
I
;3 I
I
I
C.obal t
Copper
Iron
r
Lead
Ma~anese
Ma nesil.JT\
Nickel
Potassil.JT\
Sod i I.JT\
r
r
Vanadil.JT\
Zinc
r
r = data rejected under QA/QC
x = est~ated value
() = local lab data
. .,.
f
f
f
5:00 f
t
r
r
r
r
r
r
3
r
r
r
r
-------
Table 4.
Ground Water Oontaminants Identified in Private wells.
Concentration in Micrograms Per Liter (~/l).
PW-4 PW-5 FW-6 PW-7 PW-8 PW-9 FW-IO
Acetone 400
Braoc>di-
chloranethane
Carbon Disulfide 4.1
1,2-Dichloroethane 5.2
Methyl Ethyl Ketone 300
Methylene Chloride 5700
'It>luene 4.3 3.3 4.2 24
Bis (2-ethylhexyl)
phthalate
Alunimrn 200
Bariun .
Cadmi un 21
Calciun . 54,000 58,000 53,000 56,000 51,000 29,000 52
Copper 2.8 3.5 6.3 19
Iron 700 780 1000 610 12,000
lead 35 690 32x
Maqnesiun 12,000 13 , 000 12,000 11 ,000 12,000 4400 8700
Manganese 33 40 28 34 25 34 31
Nickel 15 19 17 12 I
Potassiun 5400 550 I
Sodi un 5000 5000 I
Tin
Zinc
120
t
8.8
68
100
700
41
113:~~0 I
r = data rejected under QA/QC
x = estLmated value
() = local lab data
-------
Table 4 (cont.).
Ground Water Contaminants Identified in Private wells.
Concentration in Micrograms Per Liter (ug/l).
PW-11 PW-12 PW-15 PW-16 PW-17 PW-18 PW-19
Acetone
Braocx:1i-
chloranethane 5.3
Carbon Disulfide
1,2-Dichloroethane
Methyl Ethyl Ketone
Methylene Chloride
'Ibluene 8.0 8.0 5.9 5.8
Bis (2-ethylhexyl)
phthalate
Aluni n un
Bariun 29 35 39
Cadmi un
Calciun 33,000 67,000 47,000 43,000 78,000 78,000 43,000
Copper 5.2
Iron 100
Lead 11
Magnesiun 14,000 16,000 9700 18,000 22,000 23,000 9500
Manqanese 4.4 41 29 6.9 56 42 23
Nickel 18 13 - 18 26 23 13
Fbtassiun 1800 570 . 510 510 810 630
Sodi un 5300 ,5900 12,000 6500 6300
Tin
Zinc
2
37
53
or
45
73
460
710
r = data rejected under QA/OC
x = estUffiated value
() = local lab data
L
-------
Table 4 (cant.).
Ground Water Contaminants Identified in Private wells.
Concentration in Micrograms Per Liter (lg/l).
FW-21 FW-22 FW-23
Acetone
Brarodi-
chloranethane
Carbon Disulfide
1,2-Dichloroethane
Methyl Ethyl Ketone
Methylene Chloride
'Ibluene 5.9
Bis (2-ethylhexyl)
phthalate 27
Aluni nlm 250 250 280
BatiLlT\ 32 11 25
Cadmi LIT\
Calciun 75,000 43,000 59,000
Copper 11 4
Iron 720 180 60
lead
Maqnesiun 20,000 10,000 19,000
Manganese 49 20 23
Nickel 23 12 21.-
FbtassiLlT\
Sod i LIT\ 7200 .6100 6400
Tin
Zinc
,.
16
-\
27
\
280
t
r = data rejected under QA/(1:.
x = estimated value
() = local lab data
-------
Table 5.
Ground Water Contaminants Identified in New (EPA) Monitoring wells.
Concentration in Micro:Jrams Per Liter (ug/l).
Cluster A Cluster B Cluster C
MW-l MW-2 MW-13 MW-7 MW-8 MW-16 MW-3 MW-4
55' 80' 10' 55' 80' 10' 55' 80'
Toluene 3.2x
Carbon Disulfide 3.2x 5.6x 4.6x 4.1x
Chlorobenzene
Bramochloramethane
Braro-
dichloranethane
C-5 Alkylbenzene
Sulfenamide 20x
C-6 Alkylphenol 20x J
AI uninun
Bariun
Cadmi un 7900 4 5 4
Ca1ciun 9800 7300 4800 44,000 2600 3500 68,000
Chraniun 17 44 7 6
Cobalt 3
Copper 24 6 15 9 4 12 7
Iron 23,000 1300 700 460 140 730 920 230
Lead 31 13 10 6 13 6
Manganese 40 79 96 55 25 99 83 40
Magnesiun 680 24,000 1500 2800 10,000 1200 1300 12,000
Nickel 18 21 24 23
Potassiun 3500 1900 2400
Sodi un 17,000 13,000 7600 12,000 8700 14,000 4800 7200
Vanadi un
Zinc
6
26
110
100
36
t
44
35
21
50
r = data rejected under QA/OC
x = estLmated value
() = local lab data
-------
Table 5 (cont.).
Ground Water Contaminants Identified in New (EPA) Monitoring Well~
Concentration in Micrograms Per Liter (u;;I/l).
Cluster D Cluster E Cluster F
MW-9 MW-10 MW-17 MW-ll MW-12 MW-18 MW-5 MW-6 MW-:
55' 80' 10' 55' 80' 10' 55' 80' 10
'IbllJ3ne 3.Ox
Carbon Disulfide 8.8 2. (
011orobenzene 4.2x
Braoochloranethane
Braro-
dichloranethane .
C-5 Alkylbenzene
Sulfenamide
C-6 Alkylpheno1 .
Alunimrn
Baritrn
64(
1,
Cadmi un
Calciun 26,000 60,000 8400 12,000 59,000 59,000 4600 60,000 57(
O1raniLm 10 14 9 .
Cobalt I
Copper 25 6 10 29 7
Iron 2900 550 1100 1500 1900 1900 610 220 I ~
Lead 13 9 8 4.9 4.9 15 11 I
Manaanese 230 78 220 130 120 120 28 33 2:
Maqnesiun 7900 16,000 5100 3000 14,000 13,800 1900 13,000 18!
Nickel 14
~tassiLm .18,000 1700 13,000 1900 19,000 840 1000
Sodi un 35,000 96,000 9600 8200 16,000 16,000 6600 19,000 86(
VanadiLm
Zinc
3
200
3
23
66
33
5
19
42
33
33
r = data rejected under QA/QC
x = estilnated value
() = local lab data
-------
Table 5 (cont.).
Ground Water Contaminants Identifed in New (EPA) Monitoring Wells.
Concentration in Micrograms Per Liter (ug/l).
Cluster G
~20 ~2l
55' 10'
'lbluene 5.0 2.9x
Carbon Disulfide
O1lorobenzene
Bramochloramethane 4.Ox
Braro-
dichloramethane 3.7x
C-5 Alkylbenzene
Sul fenamide
C-6 Alkylphenol 910 910
AI uninun
Bariun
18
26
t
Cadrni un
Calciun 2800 34,000
Chraniun 4 22
Cabal t ~
Copper 37
Iron 880 310
lead 8
anese 51 14
Ma nesiun HOO 12,000
Nickel
Fbtassi un I 9200
Sodi un I 12,000 13,000
Vanadiun
Zinc
14
26
t
r = data rejected under QA/OC
x = estimated value
() = local lab data
-------
SECTION IV
ENFORCEJ.1ENT ANALYSIS
The PRPs (Waste Management, Inc. and the United States Navy) have indicated
to EPA that they are interested in perforMing the remedial actions at the
site, provided an aq reement can be reached wi th F:PA on the scope of the
ranedy. Both PRPs sutmitted written ccmnents on the RI/FS during the
three week publ ic canrnent periex:'!. Subsequent to receipt of the carments,
EPA, at the request of the PRPs, met with the PRPs in Atlanta. Waste
Management, Inc. (WMI) requested the meeting to provide its consultants,
Golder Associates, an opportunity to present to EPA their interpretation
of the RI/FS as well as their iudqments and conclusions as to what remedy
ough t to be impl anented .
Based on w.1I' s written carrnents, Golder's presentation, and coornents
made during the meeting by W1I's attorney, it appears that EPA and WMI
may be far apart fran any [X)tential agreement on the appropriate remedy.
WMI indicated that it did not bel ieve that capping or ground water
ranediation was necessary but did acknowledge that sane level of
monitori~ will be required.
It seans unlikely that w.1I initially will agree to a remedy which includes
ground water remediation and capping (proper closure of the landfill).
The Navy did not make a presentation at the meeting and appears to concur
with Golder and WMI. .
EPA has determined that proper landfill closure, qround water remediation
and monitoring, and institutional controls is a proper and defensible
ranedial action for the Hipps Road Landfill site. Therefore, EPA need
not be flexible during negotiations. The purp::>se of the remedy is to
mitiqate and minimize human health risks and damaqe to the environment.
EPA's selected remedy is the most technologically feasible, cost-effective
alternative, which the Aqency should support vigorously.
Th.1ring the FS publ ic canment periex:'!, WMI contended that t,he only remedial
actions appropriate for the site were ground water monitoring and
institutional controls. WMI has indicated a belief that the existing
landfill cover will be sufficient if it is repaired. They ha'7e also
indicated that the only issue surrounding the site involves the health
threats which were eliminated when municipal water supplies were provided
to the Hipps Road residents. The existing landfill cover is a thin,
intermittent layer of sand which affords no protection fran dermal eXJ"1Osure.
The cleanup scenerio offered by WMI ignores the degradation of a potential
water supply, which EPA must address.
The U. S. Navy, in their comments submitted during the public comment
period, concurred on the need for landfill closure, institutional controls,
and ground water monitori~. Fbwever, like WMI, the Navy has indicated a
hel ief that ground water recovery is not necessary due to the low
concentrations of contaminants, which will eventually enter into the
surface water regime.
-------
Al thouqh both PRPs have indicated a will ingness to neqotiate, the prospect
for agreement with Waste Management, Inc. is poor. Negotiations will
beqin durinq the ROD finalization process. A neqotiation period will be
allowed per the OCP, and EPA will be prepared to initiate remedial design
in the event thatneqotiations are unsuccessful.
-------
SECTION V
ALTERNATIVES CONSIDERED
PUBLIC HEALTH AND ENVI~ENI'AL OBJECTIVES
Public Health. The Hipps Road Landfill has historically posed a public
heal th threat throU'Jh tV>1O routes of exposure: consllllption of contaminated
ground water and physical contact with the fill material. Exposure to
contaminated ground water ceased when EPA and the City of Jacksonville
connected local residents to the municipal water supply. The remaining
exposure pathway (physical contact with the fill material) must be remediated.
In addition, failure to address ground water contamination will result
in the loss of a potential drinking water supply.
Environmental Concerns. Contamination of the ground water has degraded
the quality of this resource. AlthoU'Jh there is currently no threat to
environmental resources, any landfill has unknown potential for further
releases. Leaching of additional contaminants from the landfill may
produce a contaminant loading to the ground water which could harm the
envirornnent once the ground water reaches the surface water envirorment.
Since the ground water leaving the site discharges into an unnamed
tributary of the Ortega River, there is a potential for future environmental
harm. Therefore, ground water protection must be part of any remedial
action proposed for this site.
ALTERNATIVES CONSIDERED
Alternatives were identified for remediating the problems surrounding the
Hipps Road Landfill. These alternatives were presented in groups targeted
to address a single aspect of the site. Table 6 shows the technologies
considered for remediation of the ground water contamination (group A
alternatives). Table 7 lists the alternatives considered for remediation
of problems associated with the landfill material (group B alternatives).
Table 8 lists the alternatives which address other aspects which must
be considered for site ~iation (group C alternatives).

Several canbinations of group A, group B, and group C alternatives will
provide remedial actions which comply with applicable environmental
laws. One example is a canbination of ground water recovery and treatment
(group A), contairmentjencapsulation (group B), and institutional controls
(group C). Ground water recovery and treatment will respond to issues
raised under the Clean Water Act (CWA), the 1bxic Substances Control Act
(TSCA), and the Resource Conservation and Recovery Act (ReM). These
same laws are also addressed by contairmentjencapsulation of the landf~ll
material. No problems were found to affect the air quality at the site,
so there is no need to address issues raised under the Clean Air Act (eM).
..,.- ,..- ~..-
-------
Table 6.
Remedial Technologies Considered for Remediating Ground
water Contamination at the Hipps Road Landfill Site.
Group A Alternatives.
1. Ground Water Containment
a. Slurry Wall
b. Grout Curtain*
c. Sheet Piling
d. Surface Capping
e. Impervious Liners
f. Hydraulic Barrier
2. Ground Water TreatIrent
a. Flocculation
b. Filtration
c. Air Stripping
d. £team Stripping*
e. Spray Irrigation
f. Activated Carbon Adsorption
g. Resin Adsorption*
h. Reverse Osmosis*
i. Ozonation*
j . VEt OXidation*
k. Biological Treatment*
3. Ground Water Recovery and Disposal
a. PLrnping
b. City Publicly Owned Treatment WJr ks
c. Surface Water Discharge.
d. Ground Water Recharge
(*) = ~notes technologies which \roere eliminated during the preliminary.
screening phase.
-------
Table 7.
Remedial Technologies Considered for Remediating the
Landfill Material at the Hipps Road Landfill Site. Group B
Alternatives.
Soil Treatment, Storage, or Disposal Technologies
1. Offsite Disposal
2. Onsite Extraction*
3. Onsite Stabilization/Solidification
4. .Onsite Containment and Encapsulation
5. Onsite Incineration*
6. Venting*
(*) = Denotes technologies which were elllninated in the initial screening
phase.
Table 8.
Technologies Which Address Other Factors Affecting Remediation
of the Hipps Road Landfill Site. Group C Alternatives.
1. No Action Alternative
2. Closure and Monitoring
3. Institutional Controls
-------
SCREENING OF TECHNOr..cx;IES
Potential remedial alternatives identified for the Hipps Road Landfill
site were initially screened on the basis of technical feasibility, level
of protection provided to public health and cost-effectiveness. For
exanple, the use of grout curtains was el iminated during this phase
because a slurry wall will produce similar results at a lower cost.
Similarly, reverse osmosis was eliminated at this point because it requires
specialized operation and maintenance and because it is not cost-effective.
Another example is onsite incineration which was eliminated because that
technoloqy was not applicable to the site characteristics.
The next phase of alternatives screening was based on a detailed review
of each remedial alternative based on ~ite specific criteria. The second
phase review considered technical feasibility, the level of public health
and environmental protection provided, and on a relative cost-estimate
basis. The alternatives eliminated during this phase are listed in table
9.
The alternatives which were retainerl after screening were then described
in detail with regard to engineerin) considerations, equipnent needs,
oneration and maintenance needs, monitorinq requirements, health and
safety, permitting requirements, scheduling projections, and cost estimates.
Alternatives shown in table 10 meet the site specific needs and are feasible
for the Hipps Road Landfill site conditions.
Technolooies Eliminated
Several alternatives were eliminated in the preliminary screening phase and
in the detailed screeninq. The following is a list of remedial options
which were el iminated during the screening phases and the reasons for
elimination.
Ground Water Technoloqies
Grout Curtains. The use of qrout curtains was considered as a method for
containing contaminated ground water. However, slurry walls provide the
same l~Tel of effecti~eness for about one-third the cost.
Sheet Piling. This alternative was eliminated for the same reasons as
the qrout curtain.
Steam Strippinq. This alternative was considered as a method for treating
contaminated ground water; however, air stripping is equally effective
and less costly.

Resin Adsorption. Resin adsorption is potentially feasible as a treabment
method for contaminated qround water. Full scale applicability of this
technol00V for the contaminants found at the Hipps Road Landfill site has
not been proven. Carbon adsorption can produce similar efficiencies at
lower costs.
-------
Table 9.
Screened Out Technologies.
Screened out Technologies
Reason
GROUND WATER TSD TECHOOUX;IES
GRCXJND WATER COOTAINMENr
Grout Curtain
Sheet Piling
GROUND WATER TREA'IMENT
Activated Carbon Adsorption
Onsite Biological Treatment
Spray Irrigation
GRCXJND WATER DISPOSAL
Ground Water Recharge
SOIL TSD TECHNOUX;IES
TOtal Offsite Disposal
TOtal Onsite Stabilization/Solidification
L~ited Effectiveness
L~ited Effectiveness
[bes Not ReIrove Vinyl
Chloride, Must be .
Canbined with Other
Technologies
High Cost and
L~ited Effectiveness
Not Compatible with
Site Characteristics
TOo High Ground Water
Table and Low Recharge
Rate
High Cost
High Cost
-------
Table 10.
Remedial Technologies Retained for Detailed Evaluation
A.
Ground Water Technologies (GrOup A)
B.
C.
l.
2.
Extraction, Air Stripping and Disposal
Extraction, Flocculation, Sedllnentation, Filtration,
and Disposal
Extraction and Treatment at the POTW
Extraction, Air Stripping, Flocculation, Sedimentation,
. Filtration, Carbon Adsorption, and Disposal
Extraction of Ground Waterfram Hydraulic Barrier
VEIls Onsi te, Long Term Air Stripping, and Disposal to
the Ortega River
Extraction of Ground Water fram HydraUlic Barrier
VElls, Treatment According to A-4, and Discharge to
the POTW
Installation of an Hanging Slurry Wall around the
Landfill; Surface Capping, Reverse Gradient VElls
within the Slurry Wall.
3.
4.
5.
6.
7.
Soils Technologies (Group B) .. ..
1.
2.
3.
4.
Partial Solidification and Stabilization
Onsite Decontamination of Bulk Solids
Partial Removal and Offsite Detoxification
Partial Solidification and Stabilization, Onsite
Decontamination of Bulk Solids, Partial ReIroval and
Offsite Detoxification, and Resource Recovery
Containment and Encapsulation
5.
Other Alternatives (Group C)
l.
2.
3.
No Action
Landfill Closure and Monitoring
Institutional Controls
-------
Reverse Osmosis. Reverse osmosis systems are difficult to implement and
operate. A canbination of carbon adsorption and metal precipitation is
equally feasible with lower costs.
OZOnation. This process requires that ozone be produced onsite. Because
the production of ozone is expensive and requires specialized operations,
ozonation was eliminated.
\et OXidation. Wet oxidation requires excessive arrounts of energy, which
make it unfeasible on a cost-effectiveness basis.
Activated Carbon Adsorption (alone). The ground water contaminant found
to be most pervasive was vinyl chloride. Carbon adsorption cannot effec-
tively remove this contaminant.
Disposal of Treated Ground Water Via Recharge. Recharge rates of the
local soils are too low to utilize this alternative effectively. Imple-
mentation would require very low pLlIlpil1CJ rates and a large nunber of
wells, -wh~ch is not cost-effective.
Spray Irrigation. The application of spray irrigation to the contaminants
found at this site will have low removal efficiencies. In addition, the
land surface area required for this operation is not available, and soil
permeabilities are too low.
SOIL TECHNOLCX;rES
O'lsite Extraction. D=contamination of the soils was not found feasible
due to the large degree of variation of the contaminants and their
distribution, which would require a cunbersare washing process.
O'lsite Incineration. The concentrations of contaminants found in the
soils are very small. Incineration would be costly when ccrnpared to the
levels of contaminants present. Also, metals contamination is sufficently
high to expect that air emissions will be in excess of existing air quality
standards.
venting. The levels of volatile organic canpounds found in the soils are
low. The major threat is posed by the potential presence of containerized
canpounds. Venting would not address this concern.
Biological Treatment. The low levels of contaminants found at the Hipps
Ib2d Landfill cannot be addressed by biological treatment in a cost-
effective manner.
Offsite Disposal. Off-site disposal produces unnecessary risks during
excavation and transportation. The costs are also prohibitively high.
cnsite Solidification and Stabilization. This technology produces
unnecessary risks during excavation. The costs are prohibitively high.
-------
ALTERNATIVES RETAINED
The technologies which were retained for final consideration as remedial
responses to the conditions at the Hipps Road Landfill site are listed in
table 10. Each alternative was evaluated based on technical feasibility,
environmental ~ct, and rublic health concerns (Table 11). The present
worth and operations and maintenance costs associated with each alternative
are presented in table 12. The remedial alternatives found to be feasible
for this site are described below.
GROUND WATER TECHNOIJXIES
Alternative 1 - Extraction, Air Strippina, and Disposal. This alternative
involves implanentation of a ground water recovery systE!II designed to
recover the existing pI ume of contaminants. The contaminated ground
water will be passed through a counter current air column which will
enhance the exchanqe of orqanics from the aqueous stream to the effluent
air streaM. A high degree' of water detoxification is possible. The
clean water ~uld be discharged to the Ortega River for disposal. This
alternative is not expected to E!Ilit organic vapors in levels which would
cause environmental or public health concerns due to low contaminant levels
and rapid dispersion. However, site specific testing ~uld be required.
Alternative 2 - Extraction, Flocculation, SedUTIentation, Filtration, and
Disposal to the Ortega River. Extraction of the ground water would be
bTIplemented with a system designed to recover the existing plume of
contaninants. The ground water would be flocculated usirq a chE!fT\ical
additive which would coagulate the contaminants and the colloids would be
allowed to settle out of the solution. The effluent solution would then
be passed through a filter to remove solids which are too small to settle
fran the water column. The effluent water would be discharged to the
Ortega River.
Alternative 3 - Extraction and Treatment at the Publicly Owned Treatment
Works. Extraction of the ground water would be implemented with a system
desiqned to recover the existing pltm\e of qround water contaminants. The
untreated ground water ~uld be discharged to nearby municipal sewer
I ines for treatment at the local roIW. Disposal to the roIW is not
expected to have an effect on the level of volatile organic compounds in
the treatment plant effluent, due to dilution at the POTW head ~rks.
Also, the concentration of volatile organic compourrls ~uld diminish
durinq transport to the treatment plant as a result of aeration. The
level of ground water contCl'l\ination is sufficently low to allow the FO'IW
to accept the wastes without violation of the operational permits. The
flow rate will not add significant hydraul ic loadirq at the FO'IW.
Alternative 4 - Extraction, Air Stripping, Flocculation, Filtration,
Carbon Adsorption, and Disposal to the Ortega River. This alternative
combines Alternatives 1 and 2, with the addItion of an activated carbon
filter. The addition of carbon adsorption adds a final finishing process
which would insure the quality of the water being discharged to surface
waters and provides an improved level of protection for the environment.
-------
Table 11.
Summary of Evaluation of Remedial Alternatives.
Altemat Ive
Technical Feaalbility
ntvl rol8!ntal lJIpact
Public Health Ooncema
Inltltutlonal Requlre8entl
A-I Air Strlpplna
Colt Confldenee
Level + 50%
Un I t Coat Range.
9.05 to 12.20
$/1,000 la1.
A-2 Flocculation,
Sedf8!ntatlon,
and Filtration
Cost Conrtdence
Level + 50%
t.-.ft Coat Range .
6.90 to 7.80
$/1,000 gal.
A-] TTeAt~t at
Wastevater Plant
Ooat Oonftdf'nee
Leve 1 + 50%
Unl t Colt RII"8e
6.50 to 8.CJU
"1,000 gal.
A-4 Flocculation,
Spd llientat lon,
Filtration, Air
Stripping and
Carbon Adsorption
Cost Conflde'nee
. Level + 50%
Un It Oost RAnge
16.20 to 11.80
$/1,000 gal.
CoMon equlp8!flt and procedurea
used for thla alternative. Elpert
technical peraonnel required to
aupenlae operat Ion. Cleanup
effectlvenell 8Ult be verified
by effluent 8Dnltorl"8. Only
provldea VOC reductlona. ttetah
and PCB8 are not ~ved by thla
operation.
In addition to apec:lflcatlona
for A-I above, this option
l8IOYea heavy _ta18.
eo.on equl.-nt and pro--
cedurel used for thll
alternative. Places actual
task of re80Ylng or neutral-
izing cont.lnatlon In handa
of secondary party.
Technologle!l and equlp8ellt
used In thll process are well
proven. requires expert
personnel due to m_raus
process luges. This alternative
provides the highest renoval
efficiency of cont88lnants.
Air stripping volatile
orp,lInlc c
-------
Table 11 (cont.).
Sununary of Evaluation of Remedial Alternatives.
Alternlltlve
'n'tltutl~1 Requlr~nts
TechnicII Fe88lblllty
Envl~tll '-rICt
Public Hellith Concerns
A-~ Air StrlpplnR end
I'01V Dischlrge
Cost Conf Idl'nce
~vel .. 501
Unit Cost ltImge
9.8~ to 10.72
$/1,000 811.
A-6 PUll Trelt.ent end
River Discharge
Con Confldf.'nce
Level .. ~
Unl t Oo8t 1t8l18e
7.86 to 16.RCJ
"1,000 Ill.
A-7 Slurry Wll1,
Surfece Caprlna,
end Reverse-
Gradient ""111
Colt Oonfld@nce
Leve I .. 50%
Unit Cost Range
10. JO to 13.119
'/1,000 III.
It-! Plrt III
Solldlflc.tlQQ end
SUhlllzltlon
Cost Confidence
Leve 1 .. 50%
IInlt Cost Range.
76.30 to 96. ~O"
. ,/ton
S8I! .1 '\-1
,",
Technologies end equl,.ent used
In this procellll Ire well p~ven,
rf'qulres expert pef1Om81 due to
mlllerous procells sUges. Thl~
81ternetlve provides the highest
re8O¥lI efficiency of
cont-INlntll.
ao.on equlplll!nt used for
cllpplna. Trllined penonne\
required for slurry wall
IMtlllllltlon.
ec-x. equlp8ent Ind procedures
used for 8011 exc8Y8tlon, lIolld-
Iflclltlon end 8tllhlllzlltlon. "
Cleenup effectiveness 8Ullt be
verified with leach tellts.
s- 8S A-I
R_vlIl of IIOCII, 1'C88, end
hell'" lleultl will .Inl..he
1111 8dver8e effect8 to the
lIqulfer.
Oontllllinents In the IIInII-
fill ~re 8tored, not
destroyed.
Solldlficatlon!8tablllZlltion
will provide ~dllltior. for
hellYy l81!ullI contAlII Inllt Ion.
Effects on VOCa ere unknovn,
but thoup,ht to be .lIrgllVll.
S- liS' A-I
Thill C08b1lV1t Ion of A-I
Ind "-2 llbove, provldfoll
hl"hest degree of public
health protection.
Reducell the P0881bllltle8
of def8ll1 contlld with
landfill ...terili. Controlll
pos81ble future cont-INlnt
relells811.
The rlllk of expollure to
vnrken during exc8Ylltion
end reillted actlvltl..s Is
high. After lIolldlflclitlon!
IItablllzotlon. the rlllk of
expo"ure to contR8lnllted
8011 Is low. FUrther
cantAIIIlnotlon of y,round
wllter with heAVY ~tAIII
will bP ..Inl..lzed. future
rf.'lell"es of V()('.II could he
pollslble.
S- 8S A-I
S~ 1!18 A-I obo~ (except III so
-1St COlllp \ Y "I t h roT lrsnllport
8tftndlirdS, Hllzllrdou8 Woote
RegullltloM, IInd Trllnllpnrt Rule!!.
~8t co.ply with Hllzllrdous Wlilte
Regulllt Ions end RQt.A !Jeslgn
QJ Ide II nes .
~st c08p1y with 1111 hllzllrdoull wsste
",p,UlltIOflll, EPA R~ dpslR" KUlde-
lines, KUlde to dl~po"lIl of
ch~lcl11y stllbllzpd And lIo11dlried
wIIste, IInd pretre8t~nt p,uldllncp.
"hlch lippI, to this IIlternAtlve.
-------
Table 11 (cont.).
Summary of Evaluation of Remedial Alternatives.
Alternllt Ive
Inlltltutl0n81 Requlre8entll
Technlc.l Fell81bliity
Envlro.-ental IJIpIlCt
PublLc Heilith COncernl
B-2 llulk Sol Ldll
Decontlllllniltion
Cost Oonf Idence
Level + SOl
\)1lt Colt Range -
43.90 to 72.'>0
Slton
8-) PDrUIIl Re80vlll
.nd OffsLte
Detod fl.CIIUon
Cost Conf Idence
Leve 1 + ~O%
UnLt Colt Range -
42.60 to 71.80
Slton
S~ll.r to B-1 llbove for
excllvlIUon, etc. DecontMI-
n8tlon effectlvenelll II
quest lonllble due to unkn.-.
nllture of bulk 801ld8.
c-n equ I p8ent and procedures
used for soil excllvatlon and
trucking. Cleanup effectlvenes8
allt be verified with leach
telltl.
B-4 OoIIblnatlon of B-1, S- .. B-1, 8-2, and 8-) .bove.
8-1, and 8-)
Oolt Oonfldf'nce
(,eve I + SOl
Unit Cost Rllnge -
74.90 to 108.10
Slton
8-~ Oontill.-ent IInd
f.ncaI'SU lilt Ion
Oost Confidence
Leve I + SOl
Unit Cost Range.-
~2.RU to 83.10
SIt on
~ equlp8eRt and procedures
used for soil exclIVstlon,
contslnMent, snd encapsulation.
Trilined peraoonel required for
liner Inatallatlon.
WLII produce WAstewster
requiring trellt.ent.
(Wallte produced onslte
IA controllable.) Unproven
IIlt'thods lIIake envlro.-entlll
L8psct ellt~te8 difficult.
ReDDvlll Is effective 8ean8
of Nltlgstlng the probleMS
of cootllllination at the
8Lte. Conta.lnlltlon III
re80ved not dellt royed .
lleavy ..,tals not removed
during detoxlflclltlon
lire l.-obllized during
lIolldlflcstlon. Possibility
of cont Inued VOC conta.l-
nllHon re8181ne.
Cont_lnantll lire stored, not
destroyed or re8OVed.
'lbOURht to be lells effect-
Ive thsn stllblllzlltloo,
or t relltlllellt .
Risk during site work II
hlp,h. F~tent of risk
sbllt_nt Is unkllOM'l. 'lbe
procedure should dl.lnlsh
the potentlill for further
ground wllter contMlnlltion
fnJ8 both heevy 8etllll IInd
VOC8, but the degree to
which the overllil risk Is
dl.lnlshed Is difficult to
e9t~te.
S- lis 8-1 for workers.
Would .Inl.lze the rllk of
future cootMlnstlon.
Poillbility of future
relellses fnJ8 contMI-
RlllIon lit dellgnated
dllposlll site or durlns
tl"llMport .
OoIIblnllllon of 8-1, 8-2,
and B-3 llhove.
S- ss 8-1 (excludlns
stsblllzlltion IISpeet.)
Reduces. but doell not
.Inl.lze rlllk. Entllil.
storege of wlI8te, In
Its prelent fOr8,
onslte. Potentlill for
future releille.
S- III 8-1 llbove (except 11"0 ftlst
c08ply with the Clean Air Act,
pretreab8ent.ltandardl for
dlschllrge Into POTU, Federsl
Water Quality Criterlll, IInd
NPDES goldllnee.)
S- liS 8-1 llbove (except IIlso alst
c08ply to DOT HaZArdous
Haterlllis and Transport Rules
(RI«1) but doel not IIpply to
dlspolBI che.lclllly stabilized
and solidified wIIste.)
S- .s tho8e required for IIlternstlves
8-1, 1-2, and 8-3.
Host c08ply with Hllzllrdoul WIIste
Regoilltlonll end EPA RCRA Design
Guidelines.
-------
Table 11 (cant.).
Summary of Evaluat~on of Remedial Alternatives.
Altemat IVI!
Institutional Requlrenents
~hnlc.l ~881bllity
Environlll!llt81 1~8Ct
Public Health ODncem8
C-2 Clo8ut'C! and
PIonitoring
C-) Institutional
Controls
Plac-t of COYet' ..tet't81 end
8OI'Iitorins ve11s 18 considered
C0880ft engineering prectlce.
cu..on practice.
No ~n!duct Ion In cont..lnant
t rllnsport . Increase8
runoff. SIow8 vertical
MOv~nt of ground water
thnlU/:h the laOOfl11.
No reduction In ground
water transport.
Reduce8 the chance of
de~1 ContAct with
lendflll 8AterIAI. Also
reduces the poRslblllty
of soil Ingestion by .
children.
Reduce8 chance of conhct
with cont-Inated soli and
ground wllter.
Restriction on do8e8tlc U8e o(
of ground water fr08 the surficial
aquifer. Closure of private wellR.
Deed 8JdUlcat1on. Relltrtctlon on
dl8!sttc use of ground wnter ftot the
surficial aquifer. CloRure of prlv8te
vell8. Fenclns of landfill.
-------
Table 12.
Cost Estimates for the Petained P.erredial .r.~ terne.ti ves .
Cost, $1,000 Cost $1,000 Cost, $1,000
Construction O&M Present Worth
AI ternati ve Present Worth Present Worth ( 1 ) Total
GR:X.ND W1crER
&-1 Extractioo Wells 355 0 355
&-2 Hydraulic Barrier Wells 213 0 213
~1 Discharge to Ortaga River 252 0 252
~2 Discharge to POIW 435 700 1135
A-1 Air .Str.ipping 2,120 0 2,120
A-2 Flocculation, Sed. & FUt. 1,674 0 1,674
A-3 Treabnent at the POIW 736 700 1,436
A-4 Canbination of A-1 & A-2 3,920 0 3,920
plus Cartxm Adsorptioo
A-5 Long-Term Air Stripping 1,219 8,363 9,582
and POIW Di sposal (2)
A-6 Long-Term Treabnent and 1,467 13,159 14,626
River Disposal (2)
A-7 Slurry wall, CaWing, (2) 3,800 1,263 5,063
arrl Reverse-<;radient Wells
SOILS
B-1 Part. Solidificatioo & Sta. 13,535 54 13 ,589
B-2 Bulk Solids Decontaminatioo 8,697 54 8,751
B-3 Part. Rem::Jval-<>ffsite Detox. 8,453 54 8,507
B-4 Canbination of B-1, B-2, & B-3 13,670 54 13,724
B-5 Contairment & Encapsulatioo 9,268 672 9,940
G£NE:P.AL
C-2 Closure Plan and lUtitoring 530 530 1,060
C-3 Institutia1al Alternative 527 54 581
(1) O&M costs for activities shCMing $0 value are indicated with capital costs. It is
assurred that O&M for these activities last rly en! year and is harrlled by the
cleanup contractor.
(2) Inc1u:led at the request of mER.
-.- -h ~.- ,- .
... . . ~.._-.-... -
.-",--. '-'.-. . -.., -,'
-------
Alternative 5 - Extraction of Ground Water from Hydraulic Barrier Wells,
Long Term Air Stripping, and Disposal to the POTW. This alternative is
shnilar to Ground Water Alternative 1, with the exception that the
ground water recovery system would be designed to capture the 1eadirxj
edQe of the contaninant plume. The recovery well system would be maintained
indefinitely to provide protection fram the threat of future releases by the
landfill to the ground water environment. Disposal of the ground water
would be to the nearby F01W rather than to the Ortega River to insure
that there are no threats posed to the environment.
Alternative 6 - Extraction of Ground Water fram Hydraulic Barrier wells,
Onsite Treatment According to Ground Water Alternative 4, and Discharqe
to the Ortega River. '!his alternative would use a ground water recovery
system designed to capture the leading edge of the contaminant plume.
The recovery well system would be maintained indefinitely to provide
. protection fram the threat of future releases by the landfill to the
ground water envirorrnent. Full treatment of the qround water WJuld be
implanented to insure that waters bei~ diScharged to the Ortega River
would not adversely impact the surface water envirorrnent.
Alternative 7 - Installation of a Hanging Slurry Wall around the Landfill,
Surface Capping, Reverse Gradient Wells within the Slurry Wall, ard
Discharqe to the POTW. This alternative WJuld use a hanginq slurry wall
around the landfill perimeter to prevent leachate fram leaving the
site. A surface cap would be installed to reduce the infiltration of
rain water, and to reduce the level of leachate generation. Since there
is no accessahle fully confining unit in which the slurry wall can be
based and since the Ranedial Investigation demonstrated a downward
component of ground water flow under the landfill, reverse gradient wells
WJuld be installed to prevent leachate fram migrating under the slurry
wall. low levels of ground water contaminants a't'e expected from the
landfill so that discharge to the F01W would not adversely affect
municipal operations.
SOIL TECHNOLCX;IES
Alternative 1 - Partial Solidification and Stabilization. Partial
solidification and stabilization WJuld entail that the soil component of
the fill material WJuld be excavated and combined with a solidifying
a;:}ent to reduce the level of leachate ananating fram the contahninated
soils. This may improve the handling and physical characteristics of the
wastes, decrease the surface area of contaninated materials, arrl I imi t
the solubility or detoxify the hazardous constituents of the wastes. The
sol idifying a;;}ent WJuld entail using either a canent based process or
same other pozzalanic process. Stabilization WJuld involve the use of
inorganic chanicals which produce insoluble camp:>unds which are not
affected by chaRJes in site specific conditions. However, the hazardous
constituents would ranain within the monolithic block of material generated
during the process.
-------
Alternative 2 - Onsite Decontamination of Bulk Solids. The contents of
the landfill include a large quantity of metalic objects which cannot be
addressed in other alternatives which rernediate the soils component of
the fill material. This alternative would involve excavation of the fill
material, transport to a decontamination area, and decontamination of
bulk solids with steam or solvents. The decontaminated solids would be
replaced into the landfill or disposed of at a local sanitary landfill,
and decontamination waste streams would be treated in a temporary onsite
treabnent system.
Alternative 3 - Partial Removal and Offsite Detoxification. This
alternative would require excavating the most highly contaminated soils
fram the landfill, and offsite treatment by incineration for orgainics
or landf ill i ng for materials which cannot be incinerated. However, the
nearest facility to which the wastes may be transported for treatment or
disposal is approximately 600 miles fram the site.
Alternative 4 - Partial Solidification and Stabilization, Onsite
Decontamination of Bulk Solids, Partial Removal and Offsite Detoxification,
and Resource Recovery. This alternative is a canbination of Soil
'Iechnologies 1, 2, and 3, with the addition of resource recovery. IEsource
recovery would involve certification that decontaminated metals are free
of hazardous wastes and would then be presented for recycling.
Alternative 5 - Containment and Encapsulation. This alternative would
involve the excavation of the landfill contents and sealing the base of
the landfill with an impenneable liner. The landfill materials would be
re-deposited into the landfill and an impenneable cover would be placed
over the surface of the landfill. The purpose of this alternative is to
limit the leachability of toxic materials by constructing a physical
barrier which separates the ~oxic materials fr~ the environment.
alliER ALTERNATIVES
Alternative 1 - No Action. The" No Action alternative implies that the
site poses no threat to public health, welfare, or the envirorment and
that EPA will undertake no remedial response at the site. This alternative
was considered under the marrlates of the National Contingency Plan,
however, the threats posed by the site and identifed in the ~medial
Investigation indicate that the No Action alternative is unacceptable.
Therefore, this alternative will not be addressed further.
Alternative 2 - Landfill Closure and Monitoring. 'Ihis alternative will
include the placement of a high integrity cover over the landfill, closing
the existing private wells in the area, and monitoring the ground water for
further releases. This option will remove the potential for human contact
with the landfill materials and insure that the nearby residents will not
,consune contaminated ground water.
Alternative 3 - Institutional Controls. This alternative includes any
activity which would facilitate remedial action and the protection of any
remedy implemented during the remedial action. This option may include,
. ... - .. ~-~- . - -
-------
but is not limited to, installation of a perimeter fence around the site,
institution of a drilling ban within the affected area, relocation of
affected residents under the Federal flnergency Management Agency, and
closure of existing monitoring wells. Specific institutional controls
would be identified under the remedial design phase.
-------
SECTION VI
CCMMUNITY RELATIONS ACTIVITIES
In May 1983, the first public meeting was held by concerned citizens who
live in the Hipps Road Landfill vicinity. The citizens formed an organi-
zation known as the Jacksonville Heiqhts Concerned Citizens Against
Contaninated W:iter (JHCCACW). The organization is now known as Jacksonville
Citizens AQainst Contaminated Water (JCAa-J). The formation of the JCAa-J
was initiated in reaction to what was perceived as a lack of response to
contanination of private water supplies by the City of Jacksonville.
JCACW has been active in ensuing years. 'I\t.o members (Spokesperson Yvonne
Wbodman and Secretary Gail Speicher) testified before the House of
JEpresentatives Envirorrnent, Energy, and Natural JEsources Subcanmittee
of the Committee on Government Operations on June 22, 1983. Their
test imony deal t with the effects of ground water contanination and the
lack of responsibility assumed by the waste generators and qovernment
officials (See appendix A).
On July 9, 1983, Yvonne Wbodman met with EPA Administrator William
Ruckelshaus, along with 14 representatives fram other SUperfund sites.
The meeting was held to inform Mr. ~ckelshaus of the pervasive citizen
concerns surrounding SUperfund sites.
The Hipps Ibad Landfill was finalized on the NPL in September 1984. That
sane month, EPA obligated funds for the RIjFS. In October 1984, the REM
II contractor was tasked to perform the RIjFS.

Region IV has conducted extensive community relations activities at the
Hipps Road Landfill site. On Novenher 13, 1984, EPA officials and their
contractors met informally with the Hipps R:>ad residents. The meeting
was held to give the residents an opportunity to present their concerns
and to allow EPA to explain what actions ~uld be conducted under the
RIjFS. One major concern raised by the citizens was a request that JCACW
leaders be informed whenever "outsiders" will be in the vi~inity. This
request stemmed fram previous events in which unmarked government vehicles
ware seen standiNJ idly in the area. EPA subsequently informed the JCACW
leadership of any official EPA activity in the area.
On May 23, 1985, EPA held an informal public meeting with the Hipps R:>ad
area residents to present the final RIjFS work plan. The meeting was
preceded by the release of a Fact 91eet in April 1985 and by a press
release. Copies of the W:>rk Plan, Canmunity JElations Plan, and auxiliary
docunents W3re placed in the local information refX)Sitory at the Wabb
Wisconnett Branch of the Jacksonville Public Library. Copies of the same
docurents ware provided directly to the JCACW officers.
Fran January 1985 thrOlQh September 1985, EPA conducted an imnediate
ranoval response in which all area residents who were usinJ ground water
resources were connected to munic ipal water suppl ies. Th is el iminated
the fear of continued exposure to contaninated drinking water.
-------
Throughout the RI/FS process, EPA frequently maintained contact with
JCACW officers with telephone calls and onsite visits. Each final document
was provided to the JCACW officers and the information repository.
Once the draft FS was complete, EPA issued a Fact Sheet and the formal
public rreeting was scheduled. JCACW was given a copy of the FS two and a
half weeks before the public meeting, which was held on May 7, 1986. The
public rreeting initiated the FS public comment period.
During the public comment period, EPA received a large response. The
primary rrechanism used by JCACW was a petition form letter which was
sutrnitted by approximately 150 persons. Several personal letters were also
received. Response to the comments was made via the ResPonsiveness
SlItItIary which was released in July 1986. (Appendix B).
The major remaining issue of public concern surrounds the Public Health
Evaluation and the assessment conducted by ATSDR-COC. The types and
levels of contaminants encountered during the RI field investigation
and the period of exposure indicated that the population is not at risk
from contaminated ground water since that route of exposure has been
eliminated. The predominant contaminants were VOC's which the body
rapidl y excretes when exposure ceases. Therefore, there is no basis on
which COC can perform a health survey. The citizens disagree with the
ATSDR-COC position and the issue is likely to remain active.
-------
SECTION VII
CONSISTENCY WITH OTHER ENVIROt-J1ENTAL LAWS
Environmental laws which may be applicable or relevant to the remedial
activity are:
-- Safe Drinking Water Act (SrwA)
-- Resource Conservation and Recovery Act (RCRA)
-- Toxic Substances Control Act ('!'SCA)
-- State of Florida Administrative Cbde Chapter 17-7
(17-7 FAC)
-- 1980 EPA Water ()..tality Criteria
-- Pre-treatment Glidance for DisIX>sa1 at the rom

In 1983, the City of Jacksonville extended public water supply lines into
the Hipps Road area. Several residents elected to connect to the city
supplies at that time. In 1985, EPA conducted an emergency resIX>nse
which provided all remaining Hipps'Road Landfill area residents with
municipal water suppl ies. Thereby, the local residents were provided
with safe drinking water per the SrwA.
- Landfill Closure
D=sign and implementation of the landfill closure will be conducted in
accordance with Subtitle D of RCRA and Chapter 17-7FAC. This action
includes capping the landfill in accordance with RCRA requirements,
recovery of contaminated ground water, and long-term ground water monitoring.
These three requirements are included in the selected remedy.
~cause of the tX'tential uses for the surficial aquifer, ground water
recovery will be conducted until the ground water quality is in oampliance
with the standards established under the SrwA. Contaminants which are
not addressed under the SDWA will be removed until compliance with the
1980 Water C\Jality Criteria Human Health Standards is reached. Any
contaminants for which there are no standards will be removed to levels
which are mutually agreeable to EPA, Florida Deparbment of Environmental
Regulation, and the City of Jacksonville Bio-Environmental Services
Division. These levels will be defined during the Remedial Design phase
of Remedial Implementation. Any state water quality standards which are
more. stringent than federal standards will have precedence.
The recovered ground water will be discharged to the local ro'IW for
treatment and disIX>Sal. Discussions regarding access to the ro'IW were
held in November 1985 with officials fram the Jacksonville Public Wbrks
Division. The City of Jacksonville indicated a willingness to accept the
effluent for treatment. Pretreatment standards are the operational
standards by which discharge to the ro'IW will be assessed. If the
contaninant levels are above the pretreatment standards, dilution of
the contaminated ground water will be acceptable. (Appendix C).
The Unplementation of institutional controls will require that the
existin;1 local drill ing ban enacted by the Jacksonville Bio-Environmenta1
Services Division (BESD) be continued. BESD officials have indicated a
willingness to implement this restriction.
-------
During the field investigation, ground water samples indicated the presence
of PCB's in concentrations above the partitioning coefficient in water.
The presence of PCB can probably be attributed to the unfiltered water
samples in which PCBs adhered to the soils. However, concentrations
detected were several orders of magnitude below levels which would invoke
TSCA regulations.
The Natural Resource Damage Assessm:mt, conducted by the Fish & Wildlife
Service concl wed that no federal trustee resources have been impacted by
the site (Appendix D). There are no threatened wetlands, and the site
is above the SOD-year floodplain (Figure 7).
-------
.,
'.J'.' . StUHT
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Figure 7.
Hipps Road landfill site flC:XX} potential map. Zones designated
with the prefix "A" indicated areas of 10o-year flood levels
(dark shaded areas). Zones with the prefix "8" indicate areas
between the 100 and SOo-year flC:XX}S (light shaded areas).
Zones with the prefix "e" are areas of minimal flooding.
National Flocxi Insurance Program Flocxi Insurance Rate Map
t120077-0150-D.
~.' .-...._...-.~.
-------
SECTION VIII
RECCW1ENDED ALTERNATIVE
SELECTED REMEDY
The recammended alternative is a combination of alternaties A-3, C-2, and
C-3 (Table 5-1, FS ~rort). This canprises ground water recovery and
treatment at the POTW, proper landfill closure, and institutional controls.
The ground water recovery system would entail the installation of a
recovery well network and construction of a pipe line to access the POTW.
!he point of connection lies approxnnately 20,000 feet fram the site.
The recovery system will capture the existing plume of ground water
contamination to prevent the degradation of additional portions of the
aquifer. Once the clean-up qoals, as outl ined in Section VII of this Suntnary
of Remedial Alternative Selection are attained, the recovery will be
discontinued and the ground water monitoring phase will be initiated. If
monitoring indicates further release of contaminants to the ground water,
the recovery operation will be reinstituted. Each recovery well will
have an ind ividual pump so that future recovery operations (if necessary)
can be llTIplemented to address new release conditions.
!he landfill cap will be constructed in a manner consistent with all
applicable Federal, State, and local regulations. The cap will preclude
physical contact with the landfill contents and will reduce the vertically
downward hydraul ic gradient caused by the ground water "mounding" due to
infil tration.
Institutional controls may include, but are not lllTIited to, fencing the
site, continuance of the local well drilling prohibition, land use
restrictions, qrouting existing private wells, and public or PRP acquisition
of private lands. Property on which the landfill is located is residential
and two homes are physically on the landfill. A third home is~ediately
adjacent to the landfill. A total of seven (7) residential lots will be
affected in part or in whole by llTIplementation of this remedy.
Ground water monitor~n;1 willpe conducted quarterly for the first two
years. If no further'releas'es are identified during that time, monitoring
will then occur semi-annually. All analyses will consist of full priority
pollutant scans. If the recovery systems need to be reactivated in the
future, the subsequent rocmitoring scenerio will be initiated with two
years of quarterly monitoring.
Operation and maintenance (O&M) will include upkeep of the landfill cap,
ground water monitoring, and maintenance of the ground water recovery
system. O&M will continue for 20 years after the final ground water
recovery operation. EPA will provide operation and maintenance costs for
one year after completion of the remedial action. After that time, the
State of Florida or its designee will assume responsibility for operation
and maintenance associated with the site.
-------
COST-EFFECTIVENESS
Section 40 CFR Part 300.68 (j) states:
The appropriate extent of remedy shall be determined by the lead agency's
selection of the remedial alternative which the agency determines is cost-
effective (i.e. the lowest cost alternative that is technologically
feasible and reliable and which effectively mitigates and minLmizes damage
to and provides adequate protection of public health, welfare, or the environment.
The remedy selected for remediation of the Hipps Road Landfill site is
consistent with this requirement. All other feasible alternatives which
perform equal or superior to the selected remedy are m::>re eXPensive. All
of the less costly alternatives presented in the Hipps Road Landfill
Feasibility Study are either not sufficient to fully remediate the health
and environmental threats posed by this site or are not consistent with
applicable envirOl'1Irental laws. A slltlTlaryof feasible alternatives which
were rejected is presented in table 13. .
The selected remedy is estimated to cost between $3.9 million and $4.4
million.
-------
Table 13.
Summary Table of Feasible Alternatives and Cost-Effectiveness COmparison.
Cost in Millions of Dollars.
Remedial Alternative
A-I. Air Stripping
I Reason for Non-Selection
I
I
I
Less cost effective than treatment at
the POTW and failure to address all
rOLU1d water contaminants
I Estimated
I Cost Range
I
I 1.6 to 3.3
A-2. Flocculation
Sed~ntation and
Filtration
Equally cost-effective when compared
I to treatment at the POTW but fails to
address all around water contaminants
I 1.3 to 1.8
A- 3 (RA-6). GroLU1d Water
Treatment at the POTW
'l11e reccmnended alternative for groLU1d
water remediation
1.3 to 1.9
I
I 3.1 to 4.0
A-4 (RA-l). Combination of
RA-l and A-..2, plus
Carbon Adso tion
A-5. Air Stripping and
Disposal at POTW
I
I Addresses all groLU1d water contaminants,
but is expensive compared to treatment
at the POIW
I Less cost-effective than treatment at the I 9.0 to 10.6
POIW and failure to address all groLU1d
water contaminants
A-6. Full Ground Water
Treatment and Disposal
to the POIW
Less cost-effective than treatment at the
POTW and failure to address all ground
water contaminants
3 . 2 to 17.3
A-7. Sl urry Wall, Surface
Capping, and Reverse
Gradient VEIls
B-1. Partial Solidification
and Stabilization
Expensive, and not sufficient alone
.' ..
I '

I Technically effective but expensive
compared to capping and institutional
controls
4.1 to 6.9

I 8.4 to 15.0
B-2. Bulk Solids
Decontamination
Must be used in conjunction with B-1 and
is not cost-effective canpared to capping
and institutional controls
4.1 to 12.7
B-3. Partial Rem::>val and
Off-Site Detoxification
Insufficient alone, must be used in
conjunction with B-1. ~t cost-effective
compared to capping and institutional
controls
4.0 to 12.3
8-4. Canbination of B-1, B-2,
B- 3, and Resource
Recover
I
I Fully addresses landfill contents but
expensive compared to capping and
institutional controls
I '
I 7.7 to 18.7
B-5. Containment and
Encapsulat ion
I Effectively addresses landfill problems,
but is expensive compared to capping and
institutional controls
I 5.5 to 14.2
-------
Table 13 (cont.).
Summary Table of Feasible Alternatives and Cost-Effectiveness
COmparison. Cost in Millions of Dollars.
Remedial Alternative
Estimated
Cost Ranqe
Reason for Non-Selection
C-2 (RA-2) Closure Plan and
ftt:>ni toring
Insufficient alone to address effects
posed by the landfill althollJh it is
cost-effective
1.0 to 1.5
C-3 (RA-3) Institutional
Controls
I
I Alone, this option fails
any aspects of the site,
inexpensive
to remediate
althollJh it is
I
I 0.6 to 1
RA-4. Combination of
C-2 and C-3
Cost-effective but fails to address
ground water contamination
1. 6 to 2. 5
RA-5. Canbination of A-4,
C-2, and C-3
RA-7. Canbination of A-3
and C-2
RA-8. Canbination of A-3
C-2, and C-3
RA-9. Canbination of A-4
and C-2
RA-IO. Canbination of A-6
and C-2
I Feasible remedy which addresses all
aspects of the site, but not cost-
effective
I
I Insufficient to deal with all aspects of
the site altho h relativel inex nsive
Addresses all aspects of the site in the
most cost-effective manner
Expensive compared to RA-8 and fails to
include cost of institutional controls
Expens.i ve canpared to RA-8 and fails to
include ,cost of institutional controls
I 5.0 to 6.2
I
I
2.4 to 3.4
3.9 to 4.4
I
I 10.3 to ~
I
8.4 to 17.5
4.7 to 7.5
RA-Il. Combination of A-3
and A-7
Addresses all aspects of the site, but
is ex nsive red to RA-8
..... c., ~ .
-------
SECTION IX
OPERATION AND MAINTENANCE
The remedy selected for the Hipps Road Landfill site is a canbination of
three alternatives: ground water recovery and treatment at the PCYIW (A-
3), landfill closure and monitoring (C-2), and institutional controls (C-
3). Each aspect of the remedy has unique O&M requirements.
GROUND WATER RECOVERY AND TREA1MENT AT THE PCYIW
This remedial alternative requires discharge of recovered ground water
to the local sanitary sewer line located on 103rd Street. Operation
activity will include sampling the untreated ground water at .
intervals to be negotiated with the City of Jacksonville Public WOrks
Department to insure that the pretreatment criteria are not exceeded and
to rroni tor flow rates. If the contaminant concentrations exceed the
pretreatment criteria, the operator will adjust withdrawal to provide
dilutants to the recovered ground water and readjust flow rates.
Maintenance required after completion of ground water recovery will
incll.rle bi-annual inspection of the pllY1ps, monitoring equipnent, and pipe
lines to insure that the ground water recovery system is in \1K>rking order.
This is a contingency in case the landfill should produce further
contaminants in excess of the recovery criteria. The maintenance activity
will continue for 20 years fram the last recovery operation.
IANDFILL CAPPING AND MONITORI~
Once the cap is in place, the operations will entail bi-annual inspections
of the cap. If the integrity is breached, repair operations will be
instituted to insure that the contours are restored. Maintenance will
inclooe keeping the vegetative cover intact, prevent deep root plants
fram encroaching on the cap, and keeping the landfill drainage system in
proper condition.
O&M for the cap will continue for 20 years fram the final ground water
recovery operation.
INSTI'lUTIONAL CONmOLS
The institutional controls inclooe installation of a fence to restrIct
access and protect the cap fram encroachers. O&M will require bi-anm2l
inspection of the fence and repair as needed.
FUNDI~
The State of Florida has instituted a program for dealing with hazardous
waste sites. Thi-s program is designed on the CERCIA IOOdel and is operated
-------
sUnilarly to Superfund through the Florida Department of Environmental
Regulation. '!he State of Florida has agreed to fund 10% of the cost for
Unplementing the selected remedial action.
'!he relocation of residents who are affected by the implementation of the
selected remedial action will be conducted by the federal government
under Federal Emergency Management Agency (FEMA) r with acquired lands
being deeded by the federal government to the State of Florida.
After the remedial action has been implemented r EPA will provide O&M
costs for one ~ar. At the end of the first ~ar r the State of Florida
will asslJtle the responsibility for O&M. A letter expressing concurrence
by the State of Florida is in Appendix E.
These arrangements will be negated should the PRPs agree to mdertake the
RD/RA operations as outlined in this document.
-------
SECTION X
PRQJECT SCHEOOLE
The schedule for the RD/RI phases of the Hipps Road Landfill site
remediation are dependent on the success of enforcement negotiations.
the PRPs agree to undertake RD/RA, the schedule will be negotiated to
accamodate EPA, FDER, and the PRPs.
If
If, however, negotiations with the PRPs is unsuccessful, EPA will follow
the schedule outlined below:
Schedule Landmark
I Date for
Implementation
I 9/1/86
I
I. 10/31/86
I
I 12/31/86
I
I
I 2/1/87
I
8/1/87
8/30/87
10/1/87
10/1/89
1.
Finalization of the ROD
2.
Oamplete Enforcement Negotiations
3. Award Superfund State Contract (and
lAG) for ~sign
4.
Initiate ~sign
5. CaTIplete ~sign

6. Award/Amend Superfund State Contract
(and lAG) for Construction
7.
Initiate Construction
8. Canplete Construction
-------
SECTlOO XI
FU'IURE ACTIOOS
Future actions possible with this remedy are reflective of the site
specific conditions. Anecdotal information, borne out by site inspections,
indicates the presence of containers which may contain hazardous materials.
If this is an accurate assessment, there may be future releases which
will require reactivation of the ground water recovery system.
Other future activities will include the O&M actions outlined in the
previous section.
....~
-------
APPENDIX A
Testimony Subnitted by
Yvonne Wx>dman and Gail Speicher
before the
House of JEpresentatives
Envirorment, Energy, and Natural Resources
Subcanmittee on G:>verrment cperations
-------
TESTIMONY FOR
HOOSE PF REPRESENTATIVES
.
ENVIRONMENT, ENERGY, AND NATURAL RESOURCES SUBCOMMITTEE
. . .1.
: - Ol' TaE:
. .
.. ..
COMMITTEE ON. GOVERNMENT OPERATIONS
SOBMITTED ON WEDNESDAY, JUNE 22, 1983
BY:
YVONNE WOODMAN .
GAIL SPEICHER

SPOKESPERSONS FOR JACKSONVILLE HEIGHTS
CONCERNED CITIZENS AGAINST WATER
CONTAMINATION
-------
Thank you, Congressman Bennett, 'for the introduction. and for
our efforts in our behalf. without the support of yourself,
1
Senator Lawton Chiles of the Florida Senate, Mr. Don Gray, and
Lester Brown, we would not be here today to address this'
subcommittee.
Mr. Chairman ... Members ~£ the subcommittee,on Environment,
i"
Energy, and Natural Resources ... ladies and gentlemen: We are

victims of groundwater contamination. . Water .,.. tbe very
resources necessary to sustain lite, Ootb yours and mine, is
being, and in our case. has already be~ni destroyed!
contamination is., indeed, a life and death issue.
.
Groundwater
In'the next few minutes, we will summarize the effects
.,
groundwater contamination has had on residents of the Hipps Road
Additionally we submit our entire
area in Jacksonville, Florida.
.1
. presentation, including physical evidence and documentation, as
~ .
testimony' to this subcommittee. .
In the 1960's, the O~S. Navy contracted witb independent
. '
waste contractors for the disposition of .trash- generated by NAS
.
Jacksonville and NAS Cecil Field.
A former landowner, for the
purpose of fillinq in a cyp~ess swamp and hopinq to create'

.
.useable8 land, agreed to a landfill contract with the disposal
companies. . Residents were concerned with the problems that would
accompany the 6.8 acre landfill.
. '
-1-
-------
At the beginning of the landfill dumping period, the'
~ani tat-ion regulation and supervision shou ld have been assumed by'
~
the County Health Department.
On Ocitober .1, 1968, the City of
Ja~ksonville and Duval County g~ver.nments consolidated.
At this
time, the two became one, meaning the City Health Department
should have acquired the responsibilities of both.
The landfill
was supposedly complet~?:in early 1970. In' December, 1970, Don
and Yvonne Woodman purchased 4.7 acres of 1pnd which included
approximately 3 acres of. landfill.
We were told by the former
..
landfill owner that it was .tras~W from NA5 Jacksonville and
Cecil Field, 'that the landfIll was supervised by the Sani tation
Division, and tHat in 7 years 'we could even build on it.
50 in
blind faith, we purchased the property, being drawn to the
~eighborhood by the refreshing rural lifestyle and pleasant
...;3.
~ .
~eighbors. Bowfver, some people purchased property in the area
',"never kno~ing about the lapd~ill. We discovered that the Hipps
Road landfill was never totally cOmpleted.
It was to have a
.

layer of topsoil and foilage on the surface.
When we asked our
city councilman to investigate, he reported that the Sanitation
Division had released it as satisfactorily completed.
payment was made and there was nothing we could do.
The final
. .
In the early '1970's, a pond bordering the landfill had a
thick foul-odored film on its surface, and fish and surrounding
vegetation died.
Residents cal~ed city olticials.
After
evaluating the situation, the city' ordered the.cleanup.
-2-
-------
.,
Approximately four barrels of a degreasing agent were dumped into
the pond.
..
r
HEALTH DEPARTMENT INVOLVEMENT
According to the Department of Health, Welfare and
.~ :
Bio-Environmental Services report dated April 11, 1983, the
C.
. Public Health Division of the City of Jacksonville took the

8first- water sample at 8903 Hipps Road on Pebruary 15, 1983, in
...
response to a complaint of unusual taste and odor in well water.
'.
Test results, not available, until March 18 showed vinyl chloride
1-
. ---" other solvents and degreas~rs prese"nt...

was -conducted 10/15/79 and found to be satisfactory.
Onable to drink the water due to strong petroleum odor
and taste, Pittmans had a water softener installed on
July 1, 1980.
Still the odor and taste were prevalent.
The situation worsened and they called the water
softener company.
The company stated that it wasn't" a
water softener. problem, but they should call the City
Health Department;
In January, 19S1, the Plorida
. .
-3-
-------
Department" of Health and Rehabilitativ~ Services ran
I(
two drinking water chemical anAlyses, the last of whi~'
Pittmans were told would be sent to Atlanta,
accompanied by certification of suspected imminent an~
substantial danqer documents.
Thp.y did not recp.ivp.
results until March 20 and there was no indication of .
. Atlanta involvemettt.. Tests indicated BDL. At this
point, the pittmans were told by Mr. langford (now
re~ired) of the Health Department that the Health
...
Department had done all the free testing th~y could do.
"-
Any further testing would cost approximat~ly ~800 to
,-
$l!OOO and would have to be done .at their own expense.
He urged them to drill a new well instead, since.
further testing would reveal the need for a new one
anyway.
He also told them not to make waves, tell no
one "about your water.problem, not your neighbors and
especially not the media.
If they did (they were
~old), it 'would cause trouble and their property would
devalue. They we~e neve~ warned not to dr ink the
water. Tired of agonizing over what to do, the
Plt~ans complied on October 8, ~ 981, at the cost of
$1,200. Eighteen months later, April 20, 1983, they
. were told the new well was contaminated.>
Pollowing the testing of the Todd residence, a series of
..

well tests and mud samples from ponds were done (see Attachment
-4-
-------
.
. -
.
During early stages of testing, several residents drilled.
.
.
:lls at their own expense after being led to ~lieve that was
Inly alternative. This presented ca~fusing and conflicting
.tuation~ with which the Jacksonville Heights Concerned Citizens
ad to' dea I .
We were told not to drink the water, but it was OK
) bathe in it.
Also, only ten wells per week could be tested
:cording to the Health Department. This created confusion and.

. ,
.
)ubt since the situation w~s declared an emergency by the Mayor.
iditionally, we have since discovered, on.the tame day, that one
~ber of our Steering Committee was told by the~DER that the mud
"
-- .
unples taken from ?ei~hborhood ponds were completed and. showed
{, another member was at the Bio-Environmental Division and saw
...
te mud samples sitting untested in a refrigerator.
The chemist
toated that they were too busy tQ.get to them.
Another contradiction seemed to be the lack of knowledge
.
ffered regarding health hazards.
When -The Summary of VBO
amples Taken'in the Hipps Road Area- was made available to
esidents, w~ found there were approximately thirteen various
oxins including benzene, methylene chloride, tetrachloriethene,
inylcbloride and methyl isobutyl ketone.
By talkinq with
.xperts and researchinq data, we realized our problem was much
ore than just o~taininq potable drinkinq ~ater, as officials
ould have us believe.
~he quote most readily used was .poses no
.mmedia te. harm - .
By drinkinq a single glass of water, one won't
.

:ee1 immediate effect, but what about long-term consumption?
-5-
,
.
-------
-'. .. .f
.
What about exposur~ through inhalation of fumes and skin
caDsorption?
What about genetic effe~s on future generations?
Obv ious ly, no one can tell us how long. the chemi ca ls have
lea~hed into our water supply.
Some of the well~ that proved to
b~ contaminated did not have the sam~ detectable odor as others.
Mr. Fry was quoted as saying, -just because it comes up clean one
time, doesn I t mean it wo;: t come up contaminated the next time II .
This implies that there are too many variab~~s to measure the
lenqth of exposure.
.w
,
.'-
NAVY AND CITY INVOLVEMENT
Perhaps the most frustratinq of all these issues is the
.apparent apathy pf U.S. Navy representatives towards our
the Navy.
c. ..
First there wa~ a:.~mplete denial of involvement of
Next came an admission from a Navy spokesman of
situation.
knowledge ~f dumpinq at the site, but no records of contents
~umped are available.
Second, accordinq to minutes of the
D~partment of Health, Welfare and Bio-Environmental Services, on
-
April 8, 1983, a meetinq was beld to discuss contaminated wells
on Hipps Road.
It was attended by Sill ~oach, NAS Jax and Dave
Roqers, NAS Cecil Field.
Althouqh the Navy met with ~he city and
state officials to discuss. the ~ipps Road situation, the Navy
apparently chose not to be represented at ci.tizens meetinqs, even
,
-6-
. .
I~
. ,...- .'-. ,....., -.
.. -.. -...0.- - -... - ~._..
-------
'.
.
though inv i ted.'
We hereby submit evidence of waste gen~rated by..
.
lavy .
'(
I
Exhibit A is a five gallon can labeled "methyl ethyl ketone"
with label indicating Naval Air Station Zip Code 32212.
A 1967
dat~ is Ip.~inl~.
Thj~ W;t!; ~xC;:"'.:ttP.rl .in
t.h~ nr~~~n~p.~f
O~n ~r:"lv .
and Lester erown June 4, 1983, from the landfill behind the.
. residence of Donald R. "/tloodman, 9084 Hipps Road.
was approximately six inches below the sur~ace.
Depth of find
Exhibit 8 is official military documents found on the dump
site on the same date.
Exhibit C is photographs of pieces of evidence and other
..
1-
materials taken from the dump site by .residents befo~e
.completion of landfill-, ai~craft tires and sectio~s of airplane'
wings protruding through the landfill surface, and other
photographs demonstr~tinq the crator-like topography of the
landfilli sparse vegetation,' and 8urfacing 'of waste materials.
~h~ City of Jacksonville has ~isplayed various attitudes
. .
regarding our situation.
One surprising element was the .fact
that our own city councilman has never responded in a positive
. manner to calls nor participated in citizen's meetings to'which
be vas personally invited.
~he commitment from the City of Jacksonville to meet our
immediate and long-term needs came with an emergency ordinance
passed by city counc~lmen on May 10, 1983, (see Attachment 8).'
We feel this ordinance set a precedent.
Othe: cities throughout
-7-
. . -. .",
-------
".
the United .States should 'pas~ similar', legislati.on, as it is.

becoming more and more' evident that it will be needed.' It
?
provdes for immediate and long-term safe drinking water needs as
well as providing means of recovery for costs and ~xpenses.
To
date, neither City General Council nor the Mayor's office hav~
released information regarding negotiations on finding a
responsible party.
HEALTH. ASPECT J
.
We enjoyed..relatively good health in this community up until
the last five y~ars.
Our Steering Committee has gathered data
through medical reports and per~onal interviews which We are
submitting to this Subcommittee.
.l. .
everyday life, it would be e~sy to say thes~ are generalized
Because of so many variables in
. "
observa tions .
Bowever,: we suspect many of these problems to be a
direct result of groundwater contamination.
Several cases in
particular are documented in tbis report (see Attachment C -
medical statements from six families).
The nature of the health
problems links directly to the effects of toxins leaching into
our water supply.
For exampie,. unexplained nose bleeds, muscle
spasms, disaccharidase deficiency and bladder cancer have been
diagnosed by the medical community.
All involved live within the
plume area (see Attachment D).
Along with these specific cases,
-8-
-------
;
.

there have ~Qf\reports of numerous t. c,ar iac problems',' losspf
equilibrium, n.~~~a, h~adaches, fatigue, black outs, dizziness, .
YPo21ycemia, h~pertension, kidney infections, pancreas attacks,
depression, learning disabilities among children, and dental
,
pr'oblems .
1n conClU81on, 1 would like to address ~ personal situation.'
My four year ole son, Wayne, is the resident with disaccharidase.
'.
. deficiency, a rare enzyme deficiency which prevents any digestion
of sugar. 1 bad a norma! p'regnancy and defivery, with the

,- .

excepti~n of n.ninq a temperature which 'began fo~r days before

delivery a~ ~sisted for four weeks. The temperature could
.. .' ,...' '
and a(t~r three weeks of testing, finally an

Before I left the
never be e~1a1aed

. --

antibot;c ~~e effect and I could ~o home.
hospital, tr~i~trian told..me Wayne was a screamer.
Little did
,

we ~ow he~ scrp.am for approximately one full year.
, ,
Wayne
wa's an ex~ irritabJ.e,.'baby, never satisfied with toys, food

'.,

. or even US_og bim. ~'began to n,ot"ice after I stopped
nursing .h.~ his stools were not formed. After consulting
~ '

. four diff~'cIDc:tors ~d;'g6i~9, throU;h, ourne_r:~us e,:,~erimental

diets, wetwt. doctor to help him. This process took two and

a half Y" Wbea Dr. Wubbena put bim On a diet for

4isaccha~~iciency, w~.~ill ..w no positive results for a
(1..

period O~thS. Gradua~ly, without ingesting any sugars or
carbohY~tsoever~' Wayne began to show slow ~mprovement. ,
A period~eabl1ity bas just been reached within the pa.st
, .
-9-
-
-------
. -
three months.
Research on the toxic themicals found in area
wells reveals abundant information on all but one -- 4 methyl 2
?
r'entan;-ne, the chemical which measured at. the highest
concentration of all d~tected.
Recently, we did learn another
name for this toxic chemic,!}l -- methyl isobutyl ketone, which
research shows destroys the enzyme system.
CONCLOSION
..
We have 'been devastated by effects of groundwater
.contamination.
.The devaluation o~.property, disruption of lives,
and physical and emotional harms become more apparent each day.
Time has run out.
One does~'t have to hold a doctorate degree to
~alize 1:hat this nation is in the midst of a national crisis.
-. J"
. .The irres.~nsible mishaps of yesteryear are the tragedies of

1:oday. A~proximatelY~O' of Americans depend on groundwater to
survive.
The evidence is clear.
Groundwater contamination has
become a .cancer- of its own - destroying human. live~ ...

.~. .
physically, emotionally~ and 'economically, not by an act of God,
but rather.by man.
. ./"
.
It'. time to quit playing political football with this

.
issue.
The .seriousness of groundwater contamination must be
recognized.
.
An immediate commitment from~9islator~ and action
-must be initiated to stop it.
Those who generate and regulate
-10-
-------
hazardous wQste must be forced to foll:ow through with their'
~sponsibilities.
?
priorities must be rearranged to meet this crisis.
Dollars
can and must be made available to provide the agencies with
manpower,
technology, equipment, and the me~ns to enforce
lAWS
regarding haphazard toxic waste dumping.
If laws are not.
. '

presently effective, they must be changed to be so.
of'
As concerned citizens, we have discovered many discrepancies
. t
and contradictions and have learned to recognize them readily.
.'
; It's amazing how smart and persev!ring a person becomes when his
life and economic stability become endangered.
It's a sad .legacy we leave to our children, ladies and
gentlemen~ ~ ~ 1F.P!. .c ..... i.--~ ...:iG-~ Ri-A.a...
-11-
-------
"
\.
. ADDITIONAL COMtmNTS
f
.' According to llorida Department of Environmental &egulation'. 1982-83 "Summary of
.OVD Ca.e. of GrOlll!4water Contamination". in. Fiorida there ....re 65 recorded .ite. of
>OVD groundwater contamination. Seven of the.e were in Duval County. Now there are eight.
nonda ck1lddng va~t contamination .ites as 1nclicated by c1ata from the EPA
latioo&1 Ground "atet Supply Survey in 1981 reveai varIous ....latile orsanie, chemical. .uch'
. .
.., 2-D1c:b10~t-. Cetrac:b1oroetbylana. and rlnyl c:b1oride vere detected in tV8I1ty (20).

. .
c.GllDun1~ ~ter ,uPJl1.u that ..nee! almost' 700,000: norid1&D11
,'"
. .
In Duval C08q" (Jackaonville) alol1e the city bwth apartment estimate. there are.
....srly fl£t~ (50) iii landfills; 26-28 can be 1c1e.1tl£ioa acutude -- 811- in tld. - aat1on. 1Ie tbank you for Cbe opportunity to sp88k.. .aDd prey.Milt
our tes timon, bUt fal,1eD. upon
-deaf ears 8 .
.....8.
-------
APPENDIX B
~sponsiveness Summary
-------
u.s. EPA REGION IV
, r~r'~:~~}>r;':, -

, I / i I.I / L ,"",.' .r-.' -

:/UC~~;i;:;! ~2;:7!£!:"

, " -
".
HIPPS ROAD LANDFILL SITE
RESPONSIVENESS SUMMARY
DOCUMENT NO.:
126-i:R l-RS-CYVW-l
",
-------
TABLE OF CONTENTS
Executive Summary[[[
Comments and Responses
Deficiencies in Recommended Alternative.......,....................
Inadequacies of Health Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Excesses of Recommended Alternative........... . . . . . . . . . . . . . . . . . . . . .
Insufficient Data to Show Connection Between Landfill and

Contaminat.ion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Unknown Contaminants. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Quality of Public Involvement Process and Reports..................
Spread of Contamination Unknown.... ......:....'................. ...
Re locat.ion of Res idents . . . . . . . . . . . . . . . . . . . . . . . . . . .'. . . . . . . . . . . . . . . . .

Local y.'ater Runoff........ . . . . . . . . . . . . . . . . . . . . . . . . .'. . . . . . . . . . . . . . . .

Ground-wat.er Flow.............. '....................................

use of Innovative Technology....... .-...............................

use of Cost Criteria............................ ...................

Safety of New \o,'ells. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Responsiveness to Risks of LandfilL...............................

Capping Local wells............................. ...................

Inaccuracies in RI and FS. . . . . . . . . . .-. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Department of the Navy's Recognition of Need for Remedial Action...

RCRA Applicability............................,....................

Air Stripping.............................. .': . . . . . . . . . . . . . . . . .. . '"

Jacksonville Waste Water Treat.ment Capability................. .....
Effectiveness of Ground-water Extraction Procedures.......... ......
Appendix 1 - Source of Comments. """"""""""""""""""'"
Appendix 2 - Names and Addresses of Commenters.........................
Page
1
4
14
21
36
48
50
56
58
61
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EXECUTIVE SUMMARY
HIPPS ROAD RESPONSIVENESS SUMMARY
1.
INTRODUCTIO!\
The Public Comment Period on the Hipps Road Remedial Investigation/
Feasibility Study (May 7-28, 1986) began with a public meeting held on May 7
at the Webb Wesconnett Branch of the Jacksonville Public Library.
Approximately ninety residents attended the meeting, which lasted from 7 p.m.
to 10 p.m. During the Public Comment Period following the meeting, the U.S.
Environmental Protection Agency (EPA) received approximately seventy written
comments from residents, Potentially Responsible Parties (PRPs), environmental
groups, and others. In general, these comments reflected the same types of
concerns that were expressed at the public ~eeting.
These comments and EPA's
Responsiveness Summary. The
public meeting.
responses to them comprise the first part of the
second part is the official transcript of the
This Executive Summary lists all the written concerns and describes, in
more detail, the written comments and EPA responses for the four major areas
of concern. These four areas of concerns are as follows:
.
EPA's preferred (not yet selected) alternative does
not sufficiently address certain considerations;
.
The health assessment is inadequate and flawed;
.
EPA's preferred alternative is excessive and
attempts to achieve standards that are too stringent;
and
.
The corinec t ion 'Between
contamination of local
established.
the landfill contents and the
wells has not been sufficiently
The remaining areas of concern that received fewer comment letters
incl uded:
.
Unknown contaminants;
Quality of public involvement process
Spread of contamination unknown;
Relocation of residents;
Local water runoff;
Ground-water flow;
and reports;
.
.
.
.
.
-------
-'>-
...
.
Use of innovative technology;
Use of cost criteria;
Safety of new wells;
Responsiveness to risks of landfill;
Capping local wells;
Inaccuracies in the RI and FS;
Department of the ~avy's recognition of need for remedial action;
RCRA applicability;
Air stripping;
Jacksonville waste water treatment capability; and
Effectiveness of ground-water extraction procedures.
.
.
.
.
.
.
.
.
.
.
In preparing the Responsiveness Summary, EPA paraphrased each separate
concern in each letter and prepared a response addressing that point. The
individual or organization writing the comment is cited in each response:
Some concerns were raised by more than one writer; in that case EPA wrote one
response and cited each source of the comment.
II. MAJOR CONCER~S AND EPA RESPONSES
A. INADEQUACY OF RECmmE~DED PLAN
Comments in this category specifically criticized the reco~~ended plan for:
.
the use of a clay cap, since the technology is not
sufficiently reliable;
.
failure to address onsite containment or removal of
contaminants;
.
failure to clean up the aquifer; and
.
failure to address soil contamination.
In general, EPA emphasized that no solution has been selected, and
~hatever remedy is selected will fully clean up the site according to the
dictates of the National Contingency Plan. Specific EPA responses were:
cap is used it will be used along with other measures; it is not feasible
excavate the soil to remove the contaminants; the solution will control
contamination threats to the ground water; and that soil contamination is
addressed in the B group of alternatives.
ita
to
-------
-3-
B. EXCESSIVENESS OF RECO~MENDATIONS
Many comments from the Department of the Navy and
stressed that the recommended plan was too extensive.
ground-water extraction and restoration of the ground
standards is unnecessary. .
Waste Control of Florida
In particular,
water to drinking water
EPA's response is that the ground water in this area is a potential
drinking water supply and extraction may be necessary for its protection as
such. In addition, other remedial measures such as capping the landfill may
be necessary to close the landfill properly and to guard against future
exposure hazards from known and unknown contaminants.
C. INSLTFICIENT DATA TO SHOW CONNECTION BETWEEN LANDFILL AND CONTAMINATED WELLS
. Waste Control of Florida provided several comments saying that the RI
procedures were flawed and did not produce data sufficient to establish that
the landfill is the only, or even the primary, source of contamination.
EPA's response is that the procedures used were completely sound, and that
while EPA had never stated that the landfill was the only source of
contamination, the RI had indeed found that it was a significant source. In
addition, while investigating other potential sources of contamination does
fall ~ithin the purvie~ of the Superfund program, it is not within the scope
of the Hipps Road RIfFS.
D. HEALTH RISKS
Residents ~ere also concerned that the healt.h assessment minimized the
true exposure risk. and did not cons idea very sensitive populations, other
potential pathways of exposu~e '(mainly household uses of water), synergistic
effects, the effects of episodic high exposure levels, and the possibility of
developing sensitivities that could be aggravated by future exposure to
various substances.
EPA's response was that the conditions that presently exist in the Hipps
Road community indicate that the current health assessment is sound. City
water has been provided to all residents with private wells living near the
landfill. That action has reduced the threat of contamination for local
residents. Second, the planned remedial actions will lower the level of
contamination to ~afe levels. Third, the human body has its own complex
methods of ridding itself of the major contaminants of concern. Furthermore,
there is not enough information or scientific knowledge to evaluate many
synergistic effects and hypersensitivities.
The next section contains the written comments and EPA responses. The
source of each comment is noted at the top of the page. A key to the sources
is included as Appendix 1.
-------
-4-
DEFICIENCIES IN RECOMMENDED ALTERNATIVE
Source of Comment
1 & 3
Comment:
If the solution proposed by EPA [at the public meeting] is not revised,
the public health and environment will remain at risk.
Response:
During the Public Meeting held for discussion of the Hipps Road Landfill
Feasibility Study, a concerned citizen questioned EPA about the remedy being
proposed for this NPL site. In response, the audience was told that EPA was
considering a full landfill closure (capping) and implementation of
institutional controls, i.e.. fencing, dril:ing bans, possible relocation of
residents affected by implementation of the selected remedy, etc. However, it
was made clear that this position is very flexible, pending comments received
from the public during the Public Comment Period. It has become apparent that
mechanisms to control ground-water threats to the environment must be part of
any acceptable remedy. The public health threats posed by consumption of
contaminated drinking water were eliminated when the local residents were
connected to city water supplies in actions conducted by both the City of
Jacksonville and the U.S. EPA. If the landfill is covered by a protective
cap. the threat posed by contact with landfill contents will also be mitigated
by placing a barrier between the landfill and the public.
-------
-:> -
DEFICIENCIES IN RECOMMENDED ALTERNATIVE
Source of Comment
2
Comment:
EPA has recommended [at the public meeting] the use of a clay cap to
contain the site. Clay caps will not suffice as a permanent solution and
historically require large levels of funding for repairs and main~enance.
Response:
EPA has not finalized any recommendations for remediating the Hipps Road
Landfill site; recommendations will be presen~ed to the EPA Regional
Administrator who will ul~ima~ely decide on the desirability of the proposed
remedy.. Tbe Feasibility Study has projected.present worth costs for all
remedial alterna~ives which were found to be feasible for this site. Capping
the landfill was estima~ed to cost approximately $1.5 million to implement and
main~ain for 30 years, along wi~h ground-water monitoring. This is one of the
mos~ cost effective measures available for this site. However, EPA does not
feel that a cap alone will provide adequate protec~ion for human health and
the environmen~, therefore the cost of the final remedy will probably be much
higher.
-------
-6-
DEFICIENCIES IN RECOMMENDED ALTERNATIVE
Source of Comment
2
Comment:
Given the geological (crater-like) condition of the site, a clay cap will
also settle, crack, and leak.
Response:
Part of any landfill capping procedure is site stabilization, which in
this case would require that the lower areas be filled and compacted up to
grade to provide a smooth surface. This would prevent settling. Any cap will
require continued maintenance to prevent dessication cracks and erosion. If
EPA were to select this option as part of the remedial response for the Hipps
Road Landfill site, provisions for maintaining the cap would be arranged prior
to final selection.
-------
-7-
DEFICIENCIES IN RECOMMENDED AL TERNA TIVE
Source of Comment
5
Comment:
I strongly oppose EPA's proposal to cap and monitor the Hipps Road
landfill. we cannot keep covering up and taking the easy way out, because it
will cost more la~er in wildlife, money, property, and the well-being of human
life.
Response:
Landfilling waste materials is, at best, a marginal technology. However,
the was~es generated in this country are primarily disposed at landfills.
Technologi~al advances have been made which improve the quality of landfilling
operations, but further improvements are still necessary. Until the volume of
waste generated is reduced significantly,. landfilling will probably continue
~o remain the primary feasible solution.for disposal of municipal wastes. If
EPA determines that the Hipps Road Landfill will be treated as any other
similar landfill, the solution will be to close the site properly by placing a
cap on the landfill in accordance with state and federal standards and to
provide a design which reflects the highest technical integrity possible.
-------
-8-
DEFICIENCIES IN RECOMMENDED ALTERNATIVE
Source of Comment
2
Comment:
Using a cap for the slow do~n of percolation in no way qualifies as
containment. In addition, lateral and vertical flow of the ground water is
not restricted in any way, thus allowing continued contamination of the ground
~ater.
Response:
The purpose of a cap is three fold:
1-.
It does reduce the downward migration of water from
the surface through the fill material;
"
It significantly reduces the possibility of anyone on
the site contacting contaminants that might be exposed
on the surface; and
3.
It is required for a proper closure of the landfill.
In view of these factors, a cap does qualify as containment. Lateral flow
~ill continue, but there are mechanisms evaluated in the Feasibility Study
which are capable of dealing with this. If EPA chooses to cap the landfill,
these additional actions would necessarily be included.
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-9-
DEFICIENCIES IN RECOMMENDED ALTERNATIVE
Source of Comment
10
Comment:
Several EPA alternatives (Alternatives C-2 and C-3 from the FS) would
result in the use of a surface cap without any further containment or removal
efforts. This would have little, if any, effect on controlling migration from
the site. Ground water could easily move laterally below the cap and pick up
contaminant~. spreading them away from the site. CDM [EPA's contractors for
this project] expressed this same concern (FS, p. 2-20). This step alone
provides inadequate protection and would be ineffective.
None of the first five preferred [remedial] options address contaminants
in soil. Ground-water extraction (Alternative A-4) would only remove water
soluble chemicals and would not remove chemicals present in the soil. As a
result. chemicals would continue to leac~ into the. ground water at a very slow
rate for years.
Response:
All remedial alternatives that were found to be feasible were presented in
Table 5-1 of the draft Feasibility Study. This table is a list of
alternatives which can be used to remediate the Hipps Road Landfill, and the
final remedy selected for this site may encompass any combination of the
alternatives presented in Table 5-1. The alternatives which have the initial
letter "A" address remediation of the ground-water contamination. Those
alternatives with the initial letter "B" deal with remediation options. for the
landfill. Finally. the alternatives with a "c" designation address "other"
considerations. EPA has never indicated that consideration is being given to
implementing any "c" option by itself, and no such remedy will be 'recommended.
The "first five preferred [remedial] options" include four options which
treat ground-water contamination and the fifth option (B-1) eliminates
leachate production. The compounds which enter the ground water are water
soluble, by definition, and would effectively be recovered" in a ground-water
recovery scenario. Contamination in the soils is fully addressed by the group
"B" remedial alternatives. .
-------
-10-
DEFICIENCIES IN RECOMMENDED ALTERNATIVE
Source of Comment
10
Comment:
All three Group C Alternatives are inappropriate as cleanup alternatives
because none addresses the problems of contamination at the site. Alternative
C-l - no action - is clearly unacceptable. C-2 - landfill closure and
monitoring - calls for capping the site, meeting the Florida Department of
Environmental [Regulation] closure regulations, and not using the contaminated
ground water as a drinking ~ater source (see FS, pp. 3-35 to 3-37). While
these steps may be helpful, the site has already failed, leaking contaminants
into the community. A closure plan will not address these problems and is
inappropriate for this situation. Alternative C-3 calls for using
"institutional" controls such as insta.lling "fences, plugging wells, banning
future well drilling and relocating residents in affected homes (FS, pp. 3-37
to 3-39). This alternative assumes mat~rial in the landfill will not migrate
la completely false assumption - it already has), and that there will be
closure of the site. Again, nothing is stated about cleanup either on- or
offsite. None of these alternatives should be considered and each should be
dropped from the report.
Response:
Alternative
remedial option
300.68(F)(V)).
deemed to be an
eliminated from
C-l, the no-action alternative, must be considered as a
under the mandates of the National Contingency Plan (40 CFR
However, during the Feasibility Study process, no action was
unacceptable alternative site and this alternative was
further consideration.
Alternatives C-2 and C-3 are feasible alternatives. However, they are
not sufficient by themselves, and EPA has never indicated any intention of
implementing either alternative alone. The site characteristics, e.g.,
residences physically onsite, are such that alternative C-3 cannot be
eliminated from this study. Alternative C-Z, combined with other remedial
actions, is a feasible alternative which complies with the mandates of the
National Contingency Plan, under which Superfund operates. Therefore,
Alternative C-2 will also remain part of the Feasibility Study.
Finally, EPA and its contractors never stated that these alternatives
would prevent migration of contaminants into the environment. The major
pathway of exposure to the community was through drinking the ground water.
That pathway was eliminated when EPA and the City of Jacksonville elected to
connect all residences in the area to municipal water supplies. The remaining
exposure pathway is via potential physical contact with the landfill. Should
landfill closure be selected as part of the remedial action, exposure to the
landfill ~ould be eliminated.
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-11-
DEFICIENCIES IN RECOMMENDED ALTERNATIVE
Source of Comment
1 & 3
Comment:
The recommended plan [at the public meeting] does not address onsite
containment or removal of contaminants.
Response:
Options addressing both on-site containment of the landfill and removal of
contaminants were evaluated in the Hipps Road Landfill Feasibility Study.
Both options require excavation of the landfill -- an action which could pose
significant health threats to both the residents in the landfill area and to
on-sitewor.kers. In addition, both options were found to be prohibitively
expensive in the cost-effectiveness analysis. The National Contingency Plan,
under which "Superfund" is implemented, requires that applicable technologies
be screened in terms of technical feasibility, level of protection provided to
the public and environment, and relative cost effectiveness. The two options
cited above can potentially present a risk to the public and are not cost
effective, and were therefore eliminated from further consideration. The
remedy which EPA selects will satisfy all criteria mandated by the National
Contingency Plan.
.
-------
-12-
DEFICIENCIES IN RECOMMENDED ALTERNATIVE
Source of Comment
2
Comment:
A remedial action at this site must be a permanent solution which will not
require additional expenditures, and which includes a complete aquifer
cleanup. A plan for remediating this site must address onsite containment and
restrict the lateral flow of ground water or remove contaminants.
Response:
Under the National Contingency Plan. remedial actions are "... those
responses to releases that are consistent with a permanent remedy to prevent
or minimiz~ the release of hazardous substances or pollutants or contaminants
so that they do not migrate to cause substantial danger to present or future
public health or welfare or the environm~nt ..." (40 CFR 300.68[a]). At no
point is it stated in the law that a r~edial action must not require
additional expenditures. or that specific remedies must be implemented. Any
remedy selected for the Hipps Road Landfill will be executed in accordance
with the National Contingency Plan and the Comprehensive Environmental
. Response. Compensation, and Liability Act (CERCLA), and in accordance with the
known site specific conditions.
-------
-13-
DEFICIENCIES IN RECOMMENDED ALTERNATIVE
Source of Comment
1 & 3
Comment:
The recommended plan [at the public meeting] does not address cleanup of
the aquifer and is not a permanent solution. This will lead to the
contamination of additional water resources and require expenditure of
additional funds for maintenance.
Response:
The remedy discussed at the public meeting did not address protection of
ground-water resources, however, EPA has not yet selected a remedy. It has
become apparent that any remedy selected for this site cannot ignore the
contaminants present in the ground water or those which may later threaten the
ground water, and EPA will implement a remedy which addresses this issue. Any
remedy which would destroy the landfill-contents was not found to comply with
all mandates of the National Contingency Plan. Therefore the selected remedy
will inherently have provisions for maintaining the integrity of the remedial
action.
-------
-14-
INADEQUACIES OF HEALTH ASSESSMENT
Source of Comment
')
..
Comment:
The total health assessment within the Feasibility Study was used to
minimize the true exposure risk.
Response:
This comment is unjustified and unwarranted. The major source of concern
at the Hipps Road Landfill site was eliminated by the extension of city water
supplies to the Hipps Road area residents. Health assessments produced by
CDC/ASTDR and by EPA contractors address the. relevant public health issues
present at this site. These works were produced with the utmost integrity
from legal, scientific. and technological perspectives. The findings may not
please public reviewers, but the veracity cannot be questioned.
-------
-15-
INADEQUACIES OF HEALTH ASSESSMENT
Source of Comment
2
Comment::
EPA must assess past exposure [of the Hipps Road area residents to the
contaminants] in order to prepare an assessment of potential future health
risks.
~o assessment was performed to address the effects of the contaminants
found at Hipps Road on unborn children, newborn children, or the elderly.
Response:
The .ma~n exposure pathway and the main health threat posed by the Hipps
Road Landfill was eliminated when EPA and the City of Jacksonville provided
the Hipps Road area residents with city water supplies. When the exposure to
the contaminants in the ground water ce~ses (predominantly Volatile Organic
Compounds-VOCs) the body rapidly rids itself of these contaminants. The
concentrations of the other contaminants found at the site are at levels below
public concern. Thus, there is no medical, epidemiological, or scientific
justification to now conduct a health assessment to evaluate past or future
health issues, especially on very narrow populations such as unborn children,
infants or the elderly.
-------
-16-
INADEQUACIES OF HEALTH ASSESSMENT
Source of Comment
2
Comment:
Citizens may continue to be exposed to contaminants that may have pervaded
household items such as water heaters or ~ater softeners. So assessment of
this potential has been made.
ResDonse:
~o assessment of this exposure route is warranted. Once the source of
contamination (ground ~ater) is removed, the exposure ceases. Volatile
organi~ compounds will rapidly volatilize off or degrade. The length of time
since the exposure has ceased has been too long for VOC's to still pose any
significant threat.
-------
-17-
INADEQUACIES OF HEALTH ASSESSMENT
Source of Comment
2
Comment:
During the public meeting, citizens were told
cleanses itself of the chemicals found during the
Investigation. Research disputes this.
that the body naturally
Hipps Road landfill Remedial
No consideration was given to household uses, such as showering or washing
dishes, of water containing the compounds found at Hipps Road. Nor is there
any plan to address these circumstances.
Response:
The first comment is inaccurate. The citizens were informed that when
exposure(s) -- especially to volatile organic compounds -- ceases, the body
rapidly excretes the substance(s) or their metabolites, usually through the
urine. While this is not always true with exposures to inorganics, the key
public health issue is the concentration and duration of the exposure. There
is no present or past analytical data to indicate that any concentrations were
sufficiently high at any time to warrant concern that exposures may have
occurred which would result in physical burdens from the compounds or their
metabolites.
The literature and the research that
and in occupational and non-occupational
The results are accepted in toxicologic,
health fields.
has been conducted in laboratories
settings, are clear on this issue.
epidemiologic, medical, and public
In addition, the concentrations of contaminants identified over time were
too low to warrant concern about dermal exposure and absorption.
-------
-18-
INADEQUACIES OF HEALTH ASSESSMENT
Source of Comment
2
Comment:
It appears that throughout the Public Health Evaluation that the full
range of toxic chemicals was not properly considered, especially those that
are retained by the body and pose a serious health risk, particularly with
long term exposure. There was also no presentation of the [synergistic]
effects of various contaminants, although it is reasonable to assume that the
presence of any toxic chemicals in any combination increases the total health
risk.
Response:
A health risk is determined and assessed by three factors; all of which
must be present and "operating" in a dynamic fashion, over time. These
factors are:
A.
Documented presence of a chemical(s)
B.
Receptor population(s)
C.
Environmental exposure pathway(s) by ~hich contaminants are
transported by pathway(s) at sufficiently high concentrations
(at or significantly above primary drinking water criteria) over
sufficient periods of time to allow body burdens and hence,
health risks or effects to develop.
Critical to the issue here for this site is C. Concentrations of vac's and
metals were not high enough (per historical and RI Data) to allow "serious
health risk" to develop. The potential for such to occur is always there --
but also once the pathway for exposure was identified, it was eliminated by
the extension of. the city water lines.
Very little is known about synergistic effects, especially since at least
60 separate compounds were identified at this site. Science is unable to
assess synergistic effects of multiple substances and varying concentrations.
Research has shown synergism can result in additive and negative effects in
research settings. It's virtually impossible to extrapolate this to human
exposures -- especially those that are retrospective.
-------
-lq.
INADEQUACIES OF HEALTH ASSESSMENT
Source of Comment
2
Comment:
Indicator compounds used in the Feasibility Study are
corresponding to the mean concentrations found during the
Investigation. However, this precludes the consideration
caused by episodic high exposure levels.
assessed at levels
Remedial
of the effects
Response:
Using the mean concentrations of the indicator compounds identified during
the investigation of the Hipps Road Landfill .is the only rational and
reasonable method of assessing potential adverse health effects. None of the
historic or current ground-water or private well data indicated any
contaminants to be present, over time, at. levels above the primary drinking
~ater standards or at levels of public health concern. Concern regarding
"episodic high exposure levels" cannot be assessed because the facts do not
provide information to evaluate what is now only an anecdotal issue.
-------
-20-
INADEQUACIES OF HEALTH ASSESSMENT
Source of Commen~
2
Comment:
No assessmen~ was made ~o de~ermine if ~he compounds found at Hipps Road
could cause people to develop sensitivities which could be aggravated by
fu~ure exposure ~o ~race levels of organic compounds or metals.
ResDonse:
CDC/ASTDR has de~ermined tha~ an assessment of this na~ure cannot be
conducted. Such hypersensitivities have been found to develop from o~her
causative factors or agents, such as high occupational exposures. They have
no~ been found ~o develop from the consump~~on or use of wa~er contamina~ed
with ~he relatively low concentrations of vola~ile organic compounds and
metals ~hat were found a~ the Hipps Road.Landfill.
-------
-21-
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of Comment
8
Comment:
The ~avy submits that the remedial actions undertaken should not include
extraction and treatment of the contaminated plume at this time. The
Feasibility Study at page 2-3 makes the statement that cleanup goals "require
removal of priority pollutants from the ground water if their concentration
exceeds the limits of the drinking water standards or detected at
concentrations higher than background (or detection limit)".
We find no basis for this conclusion in the underlying reports. Indeed,
the statement is inconsistent with both the "cleanup goals" at pages 1-27 to
1-28, arid ~he findings of the risk assessment at Appendix A. The law does not
require treatment of ground water unless the risk of public harm makes such
treatment reasonable and necessary.
Response:
The issue of ground-water contamination will have to be addressed in the
selection of a remedial action. The National Contingency Plan states that the
remedy selected is one "... which attains or exceeds applicable or relevant
and appropriate Federal Public Health and environmental requirements that have
been identified for the site." [40 CFR 9 300.68(i)(1)] Although there are
some exceptions outlined in 9 300.68(i)(5), none are applicable to the Hipps
Road Landfill. The surficial aquifer, within the site area, is a potential
drinking water source and as such, dr~nking water criteria are applicable.
-------
-22-
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of Comment
9
Comment:
The Remedial Investigation concludes that ground-water contamination will
discharge in nearby surface waters at levels that would be in compliance with
applicable state and federal regulatory standards. Public drinking water has
been provided to residents in the Hipps Road area. Accordingly, extraction of
ground water before natural discharge provide~ little benefit and could
involve significant cost. Therefore, any ground-water extraction system must
be carefully analyzed.
Response:
Although there are currently no residents in the Hipps Road area who are
using ground water as a drinking water source, the ground water is still
considered to be a potential drinking water source. As such, the ground-water
resources must be considered in terms of the highest potential use. EPA does
not propose remedial actions without analyzing all significant aspects of a
Superfund site.
-------
-23-
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of Comment
8
Comment:
The Remedial Investigation and Feasibility Study state that the
contamination of the ground water at Hipps Road creates a hazard should that
water be used as a source of drinking water. The standards of Table 1-8 are
those for drinking water. If the aquifer is not used as a drinking water
source, then there is no need to achieve or maintain drinking water standards
of purity in the ground water.
The levels for potable water for lifetime consumption are broadly used in
the Feasibility Study as a standard for purity, and for establishing levels of
public risK. The use of these levels is, in some circumstances, inappropriate,
Response:
The surficial aquifer system in the vicinity of the Hipps Road Landfill is
a potential source of drinking water. As such, EPA believes that the highest
level of use (as a potential drinking water supply) must be protected.
Protecting this potential drinking water supply must be addressed in the
selection of a remedial response for the Hipps Road Landfill site.
-------
-2~-
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of Comment
8
Comment:
The Remedial Investigation concludes that ground-water contamination will
discharge in nearby surface waters at levels that would be in compliance with
applicable state and federal regulatory standards. The municipal water supply
has been extended to the residents in the Hipps Road area. Accordingly,
extraction of ground water before natural discharge provides little benefit
and could involve significant cost. Therefore, any ground-water extraction
system must be carefully analyzed.
Response:
Ground-water extraction has been carefully analyzed and discussed in the
Hipps Road Landfill Feasibility Study. The benefit provided by ground-water
recovery operations would be protectio~ of a potential water resource.
-------
-25-
EXCESSES OF RECOMMENDED AL TERNA TI VE
Source of Comment
9
Comment:
Many of the remedial alternatives proposed in the draft Feasibility Study
are not appropriate because: (1) the wells where chemicals have been detected
are not used for human consumption; (2) public water is available to all well
owners; and (3) the contamination found in ground water is predicted to be in
compliance with applicable standards when it discharges into nearby surface
streams.
Response:
Although this comment does not identify the specific remedial alternatives
which are not appropriate, it presumes that site conditions have no potential
for change. In addition, an aquifer cannot be neglected simply because it is
not currently being utilized. Future use is a significant consideration in
the selection of a remedial response to a hazardous waste site. For this
reason, EPA feels that all preferred alternatives listed in the Hipps Road
Landfill Feasibility Study are applicable and feasible.
-------
-26-
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of Comment
8
Comment:
The implementation of a closure plan, providing for additional earth
cover, continued monitoring for an expected period of up to 30 years,
institutional controls to inhibit excavation, drilling, and the use of wells
in the contaminated zone, as well as relocation, if needed, of homes affected
by the remediation, satisfactorily meets all of the needs of the public
health, welfare, and the environment at Hipps Road.
This option leaves open a more elaborate response, should data developed
through monitoring reveal flaws in the original study or significant
additional"releases of chemicals, or risks to the community at Jacksonville
Heights. The option also makes data available to the larger Jacksonville
community which may relate to other sources of contamination, yet to be
identified. The record on which this decision must be made clearly supports
this resolution.
Response:
The remedial action alternative described was discussed at the public
meeting held on Hay 7, 1986. At that time EPA was considering this
alternative as a final remedy for the Hipps Road Landfill site, however
subsequent evaluation has shown that this remedy probably does not go far
enough to protect the ground-water resources. The data generated for this
site supports the implementation of several remedial alternatives. EPA will
select a remedy for the Hipps Road Landfill site based on technical
feasibility; level of protection provided to the public health, welfare and
the environment; and cost effectiveness.
-------
-27-
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of Comment
8
Comment:
The cost associated with extraction and treatment are a significant
increment over other, more conservative, remedial actions. Table 5-2, which
summarizes the alternatives and costs for treatment at Hipps Road, indicates
costs ranging from 56.5 to 512 million for the variety of technologies
available to treat ground water. All of these options assume no removal of
the basic materials in the site and a continuing leaching of material from the
site into the aquifer (FS page 3-16).
A more accurate picture of the comparative costs is presented by the
Present Worth Analysis at Table 4-1, at page 4-5 of the Feasibility Study.
The costs are compared by funds which. if invested now, would produce the
funds required to make future payments. lt is unclear how operating and
maintenance (O&M) costs fit into this p~ojection. Table 4-1 seems to limit
the projected O&~ for ground-water treatment to one year, when the continuing
leaching would require activity beyond the one year period. But even assuming
this understatement of comparative cost, the addition of ground-water
treatment to closure, institutional controls, and monitoring, adds an average
cost of 52 million to the present worth. cost of the remedial action. We
submit that the gain in public health and welfare achieved by the increased
expenditure is minimal, given our present knowledge of the site conditions.
Response:
The ground-water scenario portrayed above is an accurate description of
that which was used for cost estimating purposes. The cost estimate figures
have only a relative degree of accuracy since the specific factors affecting
implementation cannot be identified until a remedy has been fully designed.
This type of cost estimation is carried out to allow evaluation of several
remedial alternatives. all of which are feasible.
In addition, several more detailed evaluations are being conducted in
order to address scenarios in which there are further releases of contaminants
to the ground water. These additional evaluations will address contingency
needs to re-activate ground-water recovery systems, if necessary after an
initial recovery action.
-------
-28-
EXCESSES OF RECOMMENDED AL TERNA TIVE
Source of Comment
9
Comment:
While a connection between the Hipps Road Landfill and
adjacent wells has not been established, it is appropriate
remedial measures that will ensure ~ha~ public exposure to
minimized or eliminated.
con~amination in
to consider
the landfill is
Our review sugges~s tha~ ~he following remedial measures are appropriate:
1
1.
Conduct addi~ional investiga~ion and moni~oring to identify all
sources of contamination in the area and verify predictions
regarding contaminant levels in the ground wa~er;
2.
Seal all private wells which indicate con~amination; connect the
proper~y owners of sealed wells in~o the municipal water sys~em;
3.
Repair ~he exis~ing cover of the landfill and maintain it as is
necessary to provide a physical barrier ~o accidental exposure
~o con~ac~ with the landfill con~en~s;
4.
Ins~all a series of institutional controls, including fencing,
cautionary signs and deed restrictions, which would prevent
fu~ure use of ~he landfill site;
5.
Consider relocating persons residing on or within the landfill
boundaries.
Implemen~ing these recommendations will protect human health and the
environmen~ by removing direct exposure to contaminants via the surface of ~he
landfill, and by eliminating access to contaminated ground water. [These]
proposed measures will ensure that any future releases of contaminants from
~he landfill can be handled in the mos~ effective way.
Re5ponse:
Taken as a whole, the combination of alternatives outlined above, is not
suffi~ient. The existing cover for ~he landfill consists of a permeable sand
layer which is thin, discontinuous, and affords no protection from dermal
exposure. In addition, there is no pro~ection of ground-wa~er resources in
the area. Addi~ional inves~iga~ion of po~ential sources of ground-water
contamination in the area are not within the scope of this remedial response;
site discovery is a separate action under CERCLA.
-------
-29-
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of Comment
9
Comment:
The Feasibility Study identified 11 different remedial action alternatives
or combinations of those alternatives. Based on the ranking of these
alternatives, as well as discussions held during a public meeting on ~lay [7],
1986 in Jacksonville, Florida, it appears that EPA's preferred alternatives
are: (1) ground-water extraction and treatment and/or discharge for a period
of one year; and (2) construction of a closure cover over the site. In
addition, EPA has proposed ground-water monitoring of the site. In our
opinion, neither ground-water extraction nor the construction of a low
permeability cover is justified.
Response:
EPA has not, as of yet, proposed a remedy for the Hipps Road
site. The proposal will be made when a Record of Decision (ROD)
to the Regional Administrator. The remedy selection is approved
Regional Administrator signs the ROD.
Landfill
is submitted
when the
The ground water in the area of the site is a potential drinking water
supply. Simply because it is not currently in use is not justification for
allowing further degradation of a resource.
Finally, the Hipps Road Landfill was never closed properly under Chapter
17-7 of the Florida Administrative Code, as only a thin layer of sand was used
to cover portions of the landfill. If EPA selects ground-water recovery
and/or placement of a low permeability cap over the landfill, there is ample
justification for this decision.
-------
-30-
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of Comment
8
Comment:
There is no significant risk of surface ~ater contamination associated
~ith a failure to undertake extraction and treatment of the ground ~ater at
this time. As reported at page A-36 of the Feasibility Study and in more
detail at page 6-20 of the Remedial Investigation, ground-water modeling
predicts that contaminated ground water is not expected to discharge into the
unnamed tributary of the Ortega River near the site for at least seven years
with maximum concentrations entering the tributary within 25 years. The
maximum concentrations released into the surface waters are estimated to be
less than 0.7 ugJl, by a conservative estimation process that does not
consider such factors as biodegradation, adsorption, or volatilization which
would tend to reduce the levels of concentration even more.
The Remedial Investigation goes further to quantify this risk to surface
waters in this language:
"The model results also indicate that even if actual total
contaminant mass in the ground water is 50 percent higher
than estimated, the maximum concentrations of contaminants
entering the tributary will still be below 1 ugJl,
presently the most stringent water criteria."
It is important to note, of course, that surface
used as a source of potable water, and any ingestion
occasional and not systematic.
water in this area is not
could be expected to be
Surface waters are not otherwise a significant health hazard according to
the Feasibility Study. Lead, arsenic, and mercury detected in pond sediments
are at levels comparable to background concentrations in the B horizon of
soils in the eastern United States, and as such do not represent a significant
excess risk to humans or aquatic organisms. FS at A-36.
Response:
Current health threats posed by surface water contamination are minimal,
as are environmental threats. However, any landfill has unknown components
~hich could pose a future threat to health or the environment, and such a
scenario must also be considered when evaluating the threat posed by a site
such as the Hipps Road Landfill.
-------
-31-
EXCESSES OF RECOMMENDED AL TERNA TIVE
Source of Comment
8
Comment:
The Feasibility Study raises risk concerns in several categories other
than ground-~ater hazards. These can be summarized as minimal risks of
ingestion of, or dermal contact ~ith, contaminated soils or surface waters.
This includes a concern that heavy rains or other accumulations of water would
create "ponding" of surface waters containing hazardous levels of contaminants.
It is the Navy's position that these problems are significant if no
closure or monitoring is conducted--an option that we do not support. Closure
that includes the deposit of a layer of clean soil over the site will minimize
ponding and the accumulation of surface waters~ Restricted access to the site
should make incidental any dermal exposure cr ingestion of soil by children.
We note again that determining a risk for dermal contact on contamination
levels for drinking water is not credible. The risks are totally different in
nature and extent.
The suggestion that levels of contamination in surface soils are low is
supported by the fact that no vegetation is apparent at the site. The
Feasibility Study itself concludes that there is little potential for uptake
of contaminants by vegetation offsite. See A-25, FS.
The Feasibility Study also expresses
will migrate downward into the limestone
"more highly used" ground-water reserve.
some concern that the contaminants
aquifer, thereby endangering that
See 4-18, FS.
This theme is not developed in the Feasibility Study; the Remedial
Investigation studies of the hydrology and geology of the site do not support
a finding of a significant risk based on that theory. The limestone aquifer
to which the report refers is not the deep Florida[n] aquifer upon which so
much of Florida's water supply depends. That Florida[n] aquifer is found at
500-600 feet, is artesian, and is protected from water above it by pressure
and a heavy layer of clay.
The smaller limestone aquifer identified at Hipps Road is located at a
depth of more than 70 feet and is isolated from the shallo~ aquifer by a layer
of clay of discontinuous sandy and plastic properties. This semi-confining.
clay layer, at monitoring well 21, indicated a hydraulic conductivity of 5.7 x

10-5 ft/day (2.0 x 10-8 cm/sec); these figures indicate that it will take
approximately 100,000 days for waters to move 5.7 feet. Pages 4-32 and 4-30
of the Remedial Investigation indicate the limestone aquifer pinches out
toward the northeast. the direction of the gradient in this area. As waters
move through the clay at this very slow rate, they discharge into the
limestone aquifer, through which a volume of more rapidly moving waters are
passing. Thus the waters moving into the limestone aquifer through the
semi-confining clay layer are subject to significant dilution, as well as
attenuation of contaminants due to the adsorption of elements by the clay.
-------
-32-
The contaminant levels identified in the limestone aquifer do not sugges~
a greater overall risk in this aquifer, once local ~ells are controlled and no
longer used for drinking. The added cover material contemplated by the
closure plan will also reduce the vertical ground-water movement through the
landfill. Page 4-26, FS.
Response:
EPA concurs with the position that the problems noted above are
significant if no action is taken at the Hipps Road Landfill site. However,
the hydrogeologic data used to justify the lack of risk to the limestone unit
is misleading. Hydraulic conductivity is the rate at which a fluid will pass
through a medium, but other factors must be considered when evaluating a
dynamic, semi-confined condition. Leakage is the rate of vertical movement
through a semi-confining unit. This parameter takes into consideration the
driving force of the head differential between the source bed (upper portion
of the surficial aquifer) and the leaky aquifer (limestone unit). This rate
is significantly more rapid. In addition, the contaminants of concern at this
site (volatile organic compounds) are typic~lly more mobile through clay
material than water is. For these reasons, EPA cannot ignore threats posed by
the Hipps Road Landfill to any portion of the surficial aquifer system.
-------
-33-
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of Comment
8
Comment:
The draft Feasibility Study recommends the installation of 20 extraction
wells with the withdrawal rate of 20 gallons per minute per well for a period
of one year. The total flow from this extraction system would be
approximately 600,000 gallons per day, or 210 million gallons per year. This
proposal is unrealistic and of limited remedial value.
As previously noted, the landfill is located in a localized recharge
zone. Assuming arguendo that contamination in the area emanates exclusively
from the Hipps Road site, the removal of 210 million gallons of ground water
would not isolate the landfill from continued exposure to ground-water flow.
while withdrawal at a high rate for a period of one year could withdraw the
existing ground water underlying the site, it would not treat future flows.
Therefore, any contaminants which had adsorbed onto the solid phase or were
still containerized at the landfill would be unaffected by such an extraction
proposal.
The proposal is technically problematic in that some 600,000 gallons of
ground water must be treated and discharged per day. At the present time, the
nearest receiving stream, the Ortega River, is the subject of a wasteload
allocation study by the Florida Department of Environmental Regulation, and it
is unlikely that new discharges will be allowed to the river, given its
existing poor water quality. The proposed volume would also exceed the low
flow rate of the river, indicating that dilution would not be available and
that violations of class 3 water quality criteria could result.
An alternative would be to discharge the extracted ground water to a POTW
operated by the City of Jacksonville. However, the nearest POTW is over two
miles away and is not connected to the Hipps Road site by sewer. This means
that over t~o miles of sewer would have to be constructed before the ground
water could be discharged to the treatment works, and the proposed extraction
volume would represent about 12~ of the POTW's existing capacity and at least
6~ of its projected upgrade capacity. .
Since ground water contains only low levels of contaminants and withdrawal
and treatment of ground water may not remove all of these contaminants, the
efficacy of ground-water withdrawal and cleanup must be questioned. Moreover,
the replacement of the private drinking water wells with city water eliminates
aquifer contamination as an exposure pathway. Therefore, it is more
appropriate to seal the existing private drinking water wells to ensure that
the potential for future exposure is minimized.
Response:
An extensive study was conducted to develop a feasible ground-water
recovery scenario (Appendix C-2, FS); the scenario as outlined is realistic.
-------
-3':'-
EXCESSES OF RECOMMENDED ALTERNATIVE
The remedial value of protecting a potential water resource is obvious. EPA
is a~are that recovery of currently contaminated ground water would not
address threats posed by potential future releases. If ground-water recovery
were implemented at the Hipps Road Landfill site, the design would include
monitoring to detect future releases. If releases do occur, the recovery
system, ~hich would remain in place, would be reactivated.
Discharge to the Ortega River system was not presented as a preferred
remedial option. However, if it were to be recommended, EPA would ensure that
violations of Class 3 ~ater Quality Criteria would not occur. EPA contractors
have already met ~ith City of Jacksonville Public Works Officials. The
expanded capacity of the nearest POTW will be completed ~rior to
implementation of any remedial action. It has been ascertained that discharge
to the POTW is feasible. Finally, removal of contaminated ground water has
been determined to be feasible. This is fully discussed in the Hipps Road
Landfill F.easibility Study.
-------
-35-
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of Comment
9
Comment:
The draft Feasibility Study identified two alternatives to control surface
exposure at the landfill site. One alternative involves installation of a low
permeability cover over the landfill. The other alternative is to repair the
existing cover. Based upon the hydrogeology underlying the Hipps Road
Landfill, a low permeability cover is not justified. While the predominant
water flow direction through the soils underlying the site is vertical, a low
permeability cover over the landfill will not hydraulically isolate the unit
from the ground water flows. The site lies between areas of higher elevation
and is, therefore, as has been previously noted, a localized recharge zone.
In addition, some of the landfill contents are apparently located within a
water table zone. Therefore, the installation of a low permeability cover
will have little impact on the ground water exposure to the contents of the
landfill. These factors suggest that surface activity is warranted to repair
the existing cover to prevent exposure 6f the landfill contents.
ResDonse:
At no time was "repair of the existing cover" proposed as a remedial
alternative. The existing cover is a highly porous, loosely packed,
discontinuous layer of sand which provides no protection. The predominant
direction of ground water flow in the site area is horizontal. Tables 6-1 and
6-2 of the Remedial Investigation Report indicate that the horizontal.
conductivity is higher in all units of the surficial aquifer system than the
vertical conductivity. The purpose of a low permeability cap is two-fold: 1)
to provide a high integrity barrier between the landfill contents and nearby
residents and the surface environment, and 2) to prevent additional
contaminants from reaching the surface environment through infiltration from
rainfall events. While a cap will reduce infiltration through unsaturated
soil, it will not decrease lateral migration of ground water through the
saturated fill material. A low permeability cap was never proposed as a
method for reducing lateral flow. It will, however, reduce the vertical flow
rates by reducing the ground-water mounding attributable to the landfill.
-------
-36-
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of Comment
9
Comment:
~either the hydrogeologic findings nor the analytical data establish that
the landfill is the only sour~e of contamination. Since the Remedial
Investigation presumed that the Hipps Road Landfill was the sole source of
contamination, it failed to investigate the possibility that other sources may
have contributed to or caused the contamination found in off-site ~ells.
Response:
The Remedial Investigation did not presume that the landfill was the only
source of c~ntamination. This contention is based upon several previous
studies conducted by state and local agencies. However, it is clearly stated
in the Remedial Investigation that the Hipps Road Landfill is not the only
source of contaminants. The Remedial Irivestigation process is conducted on a
site specific basis, and can only be conducted in a site specific manner.
Discovery of additional sites is a separate process under Superfund.
-------
-3i-
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of Comment
9
Comment:
The principal problem presented by the Remedial Investigation is that the
work performed has not demonstrated a clear relationship between the Hipps
Road site and the chemicals found in adjacent wells.
Response:
In designing the strategy for investigating the Hipps Road Landfill field
investigation, EPA and its contractor included permanent background wells, two
temporary background wells, and 5 existing (USGS) background wells. A total
of 64 wells were sampled. Some of the background wells revealed the presence
of low lev~ls of contaminants. This was st=ted in the Remedial Investigation
Report (Executive Summary, page two), along with the probability that there is
an additional source of contamination as. yet unidentified. However, the
predominant contamination was found to be downgradient from the landfill
site. The suite of compounds identified downgradient was larger than the.
suite present in background wells, and had a more variable composition. EPA
does not question the fact that the Hipps Road Landfill has significantly
impacted ground-water resources within the area.
-------
-38-
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of Comment
9
Comment:
Given the poor correlation between landfill contaminants and contaminants
measured in the wells, the [Remedial Investigation] should include an
investigation of other potential sources of contamination. ,However, no such
investigation was conducted. There may be many sources of contamination of
the adjacent wells and the landfill may be only a minor contributor.
Response:
The scope of the Hipps Road Landfill Remedial Investigation was to
investigat~ the Hipps Road Landfill, not to identify diverse sources in the
region. That latter task is executed within the Superfund program, but not in
site specific investigations. The Hipps ,Road Landfill Remedial Investigation
indicated that although the site is not-the sole source of contamination, it
is indeed a significant source. .
-------
-39-
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of Comment
9
Commen~:
The hydrogeologic da~a combined wi~h ~he loca~ion
significan~ly con~amina~ed samples a~ wells E~'-2 and
no~ demons~ra~e ~ha~ the [Hipps Road] landfill is the
con~amination,
from which the
DfW-3 were obtained does
sole source of
Response:
The hydrogeologic da~a indicate tha~ thc. wells from clusters E~~-2 and
E~~-3 which are screened in ~he 50-60 foo~ zone are positioned ~o receive
con~aminated ground-water flow from the Hipps Road Landfill. Although this
does not prove ~ha~ ~he landfill is th~ sole source of contamination, it does
demons~ra~e that the landfill is indeed a source.
-------
-40-
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of Comment
9
Comment:
[The potential for other sources of contamination] is supported by the
electromagnetic surveys conducted by the NUS Corporation as part of the
[Remedial Investigation] Report. The electromagnetic surveys indicated two
hot spots, one southwest of the Hipps Road Landfill site immediately across
Hipps Road, and the other in the immediate area of wells EHW-2 and E~-3.
Response:
~US.CoFporation did not perform a geophysical survey at the Hipps Road
Landfill site. The survey that the State of Florida conducted, however,
showed increased conductivity readings southwest of the Hipps Road Landfill
site. No analytical data from cluster ~ells in that vicinity account for
these readings. However, clay zones which were identified in the geological
investigation of the site are likely to account for the higher conductivity
readings, which the State believed may be a contaminant plume.
-------
-41-
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of Comment
9
Comment:
Ground-water and soil samples were taken from bore holes drilled through
the landfill and from wells adjacent to the site. A comparison of the
compounds identified in these samples indicates a low degree of correlation
between samples from the landfill and samples from the wells. Many of the
compounds found in the landfill were not also found in the downgradient soil
and water samples. Conversely, many of the compounds identified in the
off~site locations were not also found in the landfill samples.
Foi eXEmple, E~~-2 and E~~-3 are the off-site wells with the most
significant contamination. In well E~~-2, two compounds were identified in
the upper part of the sand unit, but neither compound was identified as one of
the 16 organic compounds located in the landfill. Similarly, of 23 compounds
identified in the lower part of the sand unit at E~~-2, only 7 were identified
in the landfill; and of 6 compounds identified in the limestone unit, only 2
were identified in the landfill.
Response:
Several scenarios can explain variations between contaminants found in
onsite and offsite monitor wells. First, several compounds found downgradient
from the landfill may be degradation products of compounds onsite, e.g., vinyl
chloride is a known degradation produc~ of dichlorobenzene. Second, some
compounds found downgradient may have entered the ground-water regime as a
result of containerized releases. which would be very localized in the
landfill. It is possible that onsite sampling could have missed such a
release point. Third. anecdotal information indicates that in the early days
of the landfill operation, uncontainerized fluids were poured directly into
disposal cells. After such a long time (about 18 years), these
uncontainerized materials could have leached from the landfill entirely (or to
concentrations below detection limits). Finally, as stated in the Remedial
Investigation Report (p. 10-1), some of the compounds found offsite may be
derived from other sources. There are certainly other scenarios which could
be devised. However. whatever the actual case may be, EPA has shown that the
landfill is a major source of ground-water contamination in the Hipps Road
area.
-------
-42-
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of Comment
9
Comment:
The analytical data from the ground-~ater samples sho~s that there is an
area of significant contamination northeast of the site. This area includes
~ells E~M-2 and E~-3. The analytical data obtained from samples at EMW-2 and
E~~-3 indicate the contamination to be present within and throughout the
aquifer (sample depths 10 feet, 55 feet, and 80 feet) with higher compound
concentrations in the lower of the sand unit (55 to 65 feet) and in the
limestone unit.
Response:
The analytical data from ground-~ater samples show that there is an
of significant contamination northeast o~ the site. This area includes
clusters E~~-2, E~~-3, and E~M-6, at the 50-60 foot depths. There are
virtually no contaminants in the 10 and 80 foot wells in the same well
clusters.
area
well
-------
-43-
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of Comment
9
Comment:
The [Remedial Investigation] report implies lateral flow from the landfill
to the northeast as the only lateral flow direction [Figure 6-11, RI report).
However, the RI report is biased because most of the ground-water monitoring
wells were installed between the landfill and the contaminated wells north and
east of the landfill.
Response:
. The Remedial Investigation report shows that lateral ground-water flow
from the Hipps Road Landfill site may move toward the northeast or east.
(Figures 6-j and 6-11. RI Report).
The report is not biased because although there are several (9) wells
northeast of the site, there are more wells (24) to the east, south, and north
of the site.
-------
-44-
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of Comment
9
Comment:
At E~~-3 only one compound was identified in the upper sand unit which was
also identified in the landfill; of 30 compounds identified in [the] lower
sand unit, only 11 were identified in the landfill; and of 3 compounds
identified in the limestone unit, o~ly one was also identified in the
landfill. These low correlations do not demonstrate that the landfill is not
the source of organic contamination at these wells. However, the existence of
so many compounds at the wells which were not also found in the landfill
indicates the existence of other sources of contamination.
Response:
EPA agrees that the Hipps Road Landfill is not the sole contributor of
ground-water contamination in the local area (RI report, p. 10-1), but there
is no doubt that the landfill is a major source of contamination.
-------
-45-
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of Comment
9
Comment:
The [Remedial Investigation] ignored possible explanations for problematic
samples. For example. the construction oj the bore holes indicates that the
cadmium detected may have been caused by the construction techniques employed,
rather than actual contamination. The high lead concentrations measured in
the private wells may be caused by problems associated with the construction
of those wells. The RI, however, did not attempt to identify the true source
of these contaminants, preferring to attribute them exclusively to the Hipps
Road Landfill.
Response:
The Remedial Investigation Report contained an explanation for the cadmium
found in the temporary wells (p. 4-40). The temporary wells were the only
ones installed using the driven casing method which used a metal alloy hammer
containing cadmium. All other wells were drilled using the mud rotary
method. The presence of lead in PW-9 was only one facet of the overall data
base that indicated that wells were contaminated by ground water from the
landfill. Lead was found in ground-water samples from the landfill at levels
(3.400 and 5.300 ug/l). which could account for the level of lead in the
private well.
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-46-
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of Comment
9
Comment:
Only one sampling event occurred and the samples taken were not filtered,
contrary to commonly accepted sampling procedures. This raises the question
as to the extent of which metal ions, particularly arsenic, are actually
present in solution at such high concentrations.
Response:
Several ground-water sampling locations used in the EPA investigation have
also been used before. Most significant were wells EMW-2, EMW-3, and E~~-6.
These three wells were contaminated in 1983 and are still contaminated with
basically the same suite of chemicals. Therefore, this cannot be construed as
an isolated sampling event. In addition, all samples which were analyzed by
an EPA Contract Laboratory Program facility were subjected to a detailed
verification process in which collection and analytical phases of the sampling
process are scrutinized in detail.
There is still an ongoing debate on whether or not samples should be
filtered. As recently as May 20. 1986. the ~ational Water Well Association
held a debate in Columbus, Ohio to discuss the pros and cons of filtering
ground-water samples. As of yet, the issue is still debatable. However, EPA
Region IV Standard Operating Procedures and Quality Assurance Manual mandates
that the ground-water samples collected in hazardous waste site investigations
remain unfiltered.
-------
-47-
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of Comment
9
Comment:
The [Remedial Investigation] raises significant questions about the source
of metals in the ground-water samples. While zinc, cyanide, mercury, cadmium,
lead and arsenic were identified in samples taken from bore holes drilled in
the landfill. there is no data on major ion chemistry or pH associated with
these samples. ~ithout this data, especially the pH, the mobility of these
metals cannot be assessed.
Response:
The metal compounds (FeD. FeS, etc.) are not commonly determined for
samples sent to the CLP, and although pH.was determined for the borehole
ground-water samples, it is of little value in determining the mobility,
unless the specific compounds are known.
A more useful evaluation is to determine the concentrations of the metals
in ground-water samples both upgradient and downgradient of the site. If the
downgradient samples contain higher amounts of the metals than the upgradient
samples, the metals are probably added by the landfill. If the downgradient
samples contain lower values, the metals may not be coming from the site.
At the Hipps Road site, the average concentration of the metals mentioned
in the comment that are upgradient of the landfill is 10.2 ug/l.
Downgradient. the average concentration is 13.4 ug/l. This strongly indicates
that the landfill is a contributor of metals to the local ground-water system.
-------
-48-
UNKNOWN CONTAMINANTS
Source of Comment
7
Comment:
EPA's consultant indicated that most of the rusting and therefore release
of toxics to ground ~ater has reached a peak. I argue with this because I
still can locate cans (~ith ~.S.N. #), medicine vials, hypodermic needles and
such that appear in excellent condition. Based on this it is anyone's guess
when some unkno~n container may rupture in the landfill and release
contaminants.
Response:
The sc~nario is a valid concern ~hich EPA has realized and must be
addressed in the selection of any remedial action. The remedy selected by EPA
~ill address this issue.
-------
-49-
UNKNOWN CONTAMINANTS
Source of Comment
10
Comment:
The contents of the landfill ~ere not clearly established in the Remedial
Investigation report (FS, p. 3-17). This makes it difficult to properly
evaluate the effectiveness of a cleanup alternative because you do not know
all the chemicals you are trying to clean up. While it is not practical to
expect to kno~ 100~ of the landfill contents, enough must be known to feel
that you have got the "worst actors".
Response:
The "bor-ehole study was designed to sample all sections of the landfill
aerially and vertically. Although much of the site contains metal that
prohibited drilling, all areas of the site were sampled, and there is no
reason not to believe that the "worst actors" have been identified.
However, the possibility that either something could have been missed or
that some containers might eventually deteriorate and release additional
chemicals has prompted the installation of a monitor well system around the
site. In addition to monitoring for possible releases from the landfill
(downgradient) the monitor wells upgradient of the site also will be sampled
to test for background data.
-------
-50-
QUALITY OF PUBLIC INVOLVEMENT PROCESS AND REPORTS
Source of Comment
"I
..
Comment:
EPA has chosen to ignore the real concerns of the public.
Response:
~ithin ~he jurisdiction of the EPA, under the requirements of the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
and the National Contingency Plan (NCP) , EPA has addressed the public health
and environmental concerns surrounding the Hipps Road Landfill site. Early in
this project, through many forms of communication ~ith the Hipps Road area
residents,.EPA determined that the resident~.t concerns appeared to focus on a
desire for more complete information about actions taken at the site,
enforcement actions against potentially responsible parties, health issues,
ground-water contamination, and deprec~ation of property values.
EPA has responded to these concerns as follows:
1. Desire for more complete information about actions taken at the site.
From the beginning of this project, the JCACW president and spokesperson were
contacted by the Regional Superfund Community Relations Coordinator and
assured that the appropriate regional technical, legal, and public affairs
personnel would be in contact with them throughout the project. An invitation
was extended to call or come to the regional office at any time for
information on this project. Routine calls, meetings, fact sheets, and news
releases have been initiated by EPA during the course of this project. This
information flo~ included the citizens of Hipps Road as well as local and
state officials and the news media. An informal public meeting was held to
explain the project work plan, and a formal public meeting with a public
comment period was held to discuss the alternatives for remediation. The EPA
project officer has been in frequent contact with the JCACW president and
spokesperson.
2. Need for enforcement action. The EPA attorney for this site is
pursuing the potentially responsible parties and has been available to answer
questions by the citizens both by telephone and at the public meetings.
3. Health issues. As part of EPA's extensive Remedial Investigation
and Feasibility Study, the EPA contractors have developed a comprehensive
Public Health Assessment. The Centers for Disease Control ASTDR office has
been involved since the inception of this project. ASTDR has reviewed all
data generated from the Hipps Road Landfill and have made their findings
available. In addition, EPA and the City of Jacksonville have connected all
residents who were using ground-water supplies with the municipal water supply
system in order to remove the major exposure path~ay.
-------
-51-
QUALITY OF PUBLIC INVOLVEMENT PROCESS AND REPORTS
4. Ground~ater Contamination. The findings of the site investigation
indicated contamination of nearby ground-water resources. The data has been
made available to the citizens through the information repository and by
directly providing reports to the concerned citizens group, Jacksonville
Citizens Against Contaminated Water.
5. Depreciation of property values. The depreciation of property
values due to the Hipps Road Landfill is a concern that EPA recognizes.
Ho~ever, EPA has not been empowered to make restitution for depreciation to
individual landowners. Private parties whose property has depreciated in
value may pursue a cause of action for damages against parties liable for the
depreciation.
-------
-52-
QUALITY OF PUBLIC INVOLVEMENT PROCESS AND REPORTS
Source of Comment
2 & 3. 9
Comment:
The public was allocated a very short time for review of the Feasibility
Study and to submit comments.
Response:
The National Contingency Plan, under which "Superfund" is implemented,
mandates that "... feasibility studies that outline alternative remedial
measures must be provided to the public for review and comment for a period of
not less than 21 calendar days. Such review. and comment shall precede
selection of the remedial response. Public meeting(s) shall, in most cases,
be held during the comment period." (40 CFR Part 300.67(b)). The materials
on which the selection of a remedial measure will be based were placed into
the information repository and provided to a local citizen's group
(Jacksonville Citizens Against Contaminated Water) for review 17 days prlor to
the public meeting. Twenty-one days were allotted after the public meeting
for submission of comments. Under the NCP. EPA could have extended the public
comment period if such a request had been made. The public comment period was
conducted in accordance with the manner mandated in the National Contingency
Plan.
-------
-53-
QUALITY OF PUBLIC INVOLVEMENT PROCESS AND REPORTS
Source of Comment
2
Comment:
The goals of a Remedial Investigation and Feasibility Study are to: 1)
identify the source of contamination; 2) determine the extent of
contamination; and 3) determine the potential for contamination. Jacksonville
Concerned Citizens Against Contaminated Water feels that EPA has not met these
goa)s.
Response:
EPAhas met these goals. The landfill has been identified as a major
source of contamination (p. 10-1 RI Report). Neither surface water nor
sediments in the area were shown to be contaminated by the site (p. 10-2 RI
Report), however. the extent of ground-water contamination has been determined
(p. 10-3 RI Report). The potential for 'contamination of ground water and
surface water has also been determined, as well as a prediction of the area of
contamination and the level of contamination (Sections 6 and 10 RI Report).
-------
-54-
QUALITY OF PUBLIC INVOLVEMENT PROCESS AND REPORTS
Source of Comment
3 .
Comment:
At the Public ~eeting, the representative from CDC [ASTDR] was
non-committal and unprepared. The manner in which he talked do~n to the
public was un excusable.
ResDonse:
The ASTDR's multi-disciplinary review of the current and historical data
from the Hipps Road Landfill site and the extensive work with EPA since 1983
led to the extension of public water supplies to the Hipps Road area residents.
. .
The inference that ASTDR's manner was condescending to the meeting
attendees is unjustified. ASTDR is mandated, by Congress, to serve as EPA's
public health advisor and consultant. ~he role of CDC/ASTDR is to be an
objective, yet medically and scientifically sound public health agency. The
conclusions drawn by ASTDR's evaluation of the Hipps Road Landfill are sound,
if not popular.
-------
-55-
QUALITY OF PUBLIC INVOLVEMENT PROCESS AND REPORTS
Source of Commen~
7
Comment:
I have found numerous contradictions and inconsis~encies which cloud the
entire [Remedial Investigation/Feasibili~y Study] study. My comments come
from only a small review ~ime on my par~ and I feel that many more questions
could be addressed. As an engineer I unders~and the position tha~ EPA mus~
try and ful(::l, it is an extremely difficult and complex one ~o say ~he leas~.
Re5ponse:
Several of the inconsistencies mentioned previously have been answered.
I~ is likely tha~ many of the inconsistencies appear ~o be such because of the
limited revie~ time. However, i~ is gratifying that the commentator
apprecia~es ~he EPA position as a diffic~lt and complex one.
-------
-56-
SPREAD OF CONTAMINATION UNKNOWN
Source of Comment
10
Comment:
The Feasibility Study is intended to define appropriate alternatives for
cleaning up a waste site. This cannot be done if you do not know how far the
contamination has spread. From the data collected in the Remedial
Investigation, chemicals have reached as far as wells sampled by the C.S.
Geological ~urvey (USGS), identified as EMW-2, EMW-3 and E~~-6 (FS, p. 2-4)
and estimated to be approximately 1000 feet northeast of the site (FS, p.
A-2). This is the extent of what is known about off-site migration. CDM
[EPA's contractor for this project] actually assumes that this is the furthest
contaminants have travelled (FS, p. A-2). Yet there is no reason to think
this is-the case without additional testing.-
Response:
Taking the range of site conditions into consideration (lithology,
contaminants, and hydraulic conditions) the greatest distance, predicted by
modeling, that the ground ~ater could move in the time that has elapsed since
deposition of the land fill material is 1000 feet northeast of the site. The
presence of contaminants in ~ells ~ithin that 1000' distance and the absence
of contaminants in wells installed outside that distance provides a high level
of confidence in these data. In addition, the temporary wells drilled during
the site investigation were drilled in a manner as to "close in on" the
contamination by progressively approaching the landfill, rather than by
drilling directly into areas of high contamination.
-------
1-
-5i-
SPREAD OF CONTAMINATION UNKNOWN
Source of Comment
10
Comment:
Deeper wells are needed to better evaluate how deep the contamination has
spread. Since CDM [EPA's contractors for this project] states that ~ater in
the deep limestone and shallower water table "appear to be connected" (FS, p.
1-13), chemicals migrating from the site will eventually reach this aquifer.
Contamination of this aquifer poses significant health risks since it connects
to the drinking ~ater supply for the City of Jacksonville.
None of the first 5 preferred [remedial] options address this concern. If
any are selected as the remedial action of choice, then nothing will be done
about conta~ination in either the upper ground-water table or the deeper
limestone aquifer.
Response:
The limestone unit of the surficial aquifer referred to pinches out
downgradient (northeast) of the site. There are several monitor wells that
intercept this aquifer between the landfill and where it pinches out. The
aquifer is adequately monitored. The city water supply wells obtain water
from the Floridan aquifer, which is several hundred feet below the site and
thus is protected by the Hawthorn Formation.
-------
-58-
RELOCATION OF RESIDENTS
Source of Comment
2 & 7
Comment:
Based on EPA's own "Biggest Bang for the Bucks" comments [at the public
meeting], I do not feel that you have gotten your bang for perhaps one half of
the monies that have been expended to date. Affected residents could be
removed from possible danger. a temporary cap placed, and all the while a more
permanent solution to the contamination problem be thoroughly researched.
During the meeting it was brought up that to date EPA has expended in
excess of 5980.000.00 for studies. This figure excludes salaries for
personnel. Based on the Remedial Investigatjon and Feasibility Study, capping
and insti~tional controls appears to be adequate measures to remedy the
landfill. Therefore, before further exorbitant amounts of monies are spent
for design. etc., I would recommend the immediate removal of residents in and
around the landfill and a temporary cap be placed until a future more
equitable solution can be reached. If you cannot eliminate the source, keep
everyone away from the problem.
Response:
To date, EPA has expended funds to'accomplish three primary goals. The
first was to prov: :3 safe drinking water to the public. The second was to
identify those parties potentially responsible for the conditions found
surrounding the Hipps Road Landfill. The third was to develop a data base on
which a remedial measure can be identified and selected. The costs for these
actions are determined by free competition of qualified contractors under the
Federal Procurement System, and are presumably reflective of fair market
prices. The removal of citizens and installation of a temporary cap would be
considered emergency response actions if implemented prior to the execution of
a Remedial Investigation and Feasibility Study. under the mandates of the
National Contingency Plan. an emergency removal action is restricted to
approximately $1.000,000.00 in funding and 6 months in implementation. (40
CFR 300.65[63]). Such action as suggested above would likely exceed this
limitation.
-------
-59-
RELOCATION OF RESIDENTS
Source of Comment
3 & 4
Comment:
The Feasibility Study did not specify which residents would be relocated
in order to implement a remedy at this site. I recommend that these people be
contacted.
Response:
The Hipps Road area residents whose property will be affected by the
selected remedial action cannot be fully identified until the remedial design
is completed. At that time. the extent of property affected by the remedial
action will. be precisely identified. Owners .of those homes directly on the
landfill will be affected by the implementation of any remedy, except the
"no-action" alternative which EPA has already rejected. When design
specifications are known, discussions with the affected property owners will
be conducted in order to reach a fair solution.
-------
-60-
RELOCATION OF RESIDENTS
Source of Comment
10
Comment:
The cleanup goals are misleading, poorly stated and do not address cleanup
of the site. Instead. they address the removal of risk. While this is
important, the point of Superfund is to clean up hazardous waste sites while
at the same time removing risks. These goals do not do both. As they read
no~. these goals could be achieved without doing anything to clean up the
site. This would result in leaving all contaminants where they are, causing
deterioration of the environment and damage to the ground water and deeper.
aquifer.
These goals could be achieved simply by relocating nearby residents and
implementing institutional controls similar to Alternative C-3. This is not
what the community ~ants or expects from. a Superfund cleanup effort.
Protection and cleanup of the environmeht and aquifers is important and should
be included in the statement of cleanup goals.
Response:
The purpose of "Superfund" is to mitigate the threats posed to human
health, welfare, and the environment. There is a mandate to reduce the risk
presented by a hazardous waste site to acceptable levels, not to "remove" the
risk. Low levels of contaminants were found at the Hipps Road Landfill site,
and the major pathway of exposure has been eliminated by providing municipal
water supplies to the Hipps Road area residents.
While community concern is an issue to be addressed, it is not the only
consideration involved in remediating a hazardous waste site. EPA has the
ultimate responsibility to select a remedial action which is feasible, cost
effective, and is responsive to the public health, welfare and the environment.
The selection of alternative C-3 alone will not mitigate any threats to
the environment, and in fact, will leave the landfill exposed.
-------
1-
-61-
LOCAL WATER RUNOFF
Source of Comment
6
Comment:
We are about across the road from the Hipps Road landfill on Exline Road.
We have a city drain ditch in front of our property which takes care of run
off water from Hipps Road and the landfill area. We are concerned of how many
contaminants we may be getting from the soil during long periods of rain when
the water lies in the ditch.
Response:
Based on sampling data from the remedial investigation in the vicinity of
the drainage ditch there is no evidence of any contaminants present in the
ditch that can be considered related to the landfill.
-------
-62-
LOCAL WATER RUNOFF
Source of Comment
7
Comment:
A contradiction arises from consultant and EPA comments concerning their
opinion that contaminants only leave the area by way of shallow surface
waters. They justified their opinion by stating that rain water percolated
rapidly, producing little or no runoff. Earlier during the consultant's
comments it was brought out that a monitoring well southwest of the site could
not be installed due to severe flooding. I argue that the area does not
percolate well, and from long term personal observations I have observed
flooded areas on my own property that appeared to have a visible sheen. These
same low areas discharge to the drainage ditch on Exline Road. thereby
carrying contaminants with them.
Response:
The commentator is correct in stating that there are areas in the vicinity
of the landfill that do not drain well. However, the landfill was excavated
in phases to allow deposition of fill material, then covered with sand
excavated previously. Such reworked sand is typically much less tightly
packed. and tends to be considerably more permeable than undisturbed soil.
This results in faster percolation of surface water into the subsurface at the
site than in most of the surrounding area.
-------
-63-
GROUND-WATER FLOW
Source of Comment
9
Comment:
Under natural gradients, seepage from the landfill would enter the
limestone upgradient of these wells and flow through the limestone at the well
locations [E~~-2 and E~M-3] toward the river valley. This natural flow system
does not provide a flow pathway for contaminated ground water to migrate into
the sand unit at these wells from either the limestone unit or from the
landfill. The natural gradients do provide a flow pathway vertically downward
from the surface near or at the wells to the open intervals of the wells.
These conditions are exaggerated by potential pumping from the limestone unit
(as exhibited by the 1985 ground-water level data in all monitoring levels).
Such pumping would increase the downward vert'ical gradient in the vicinity of
the wells and further prohibit upward flow from the limestone unit.
Response:
The site investigation revealed both horizontal and vertical components of
ground water flow. The hydrogeologic and modeling data presented in the
Remedial Investigation Report show that instead of flowing into the limestone
unit in the area of wells E~~-2, EMW-3, and E~~-6, contaminants from the Hipps
Road Landfill would most likely be in the lower water table zone (above the
semi-confining unit).
When the limestone unit pinches out, as shown in the Remedial
Investigation Report (p. 4-30), the water must continue migrating. The
Hawthorn Formation, which is the regional confining unit, underlies the
limestone unit. The confining characteristics of the Hawthorn Formation will
force at least some of the ground water into the water table zone. This is
supported by the upward vertical gradient which is shown by the water level
measurement data. Therefore, pumping in the limestone unit would not prohibit
upward flow from the limestone unit.
-------
-64-
GROUND-WATER FLOW
Source of Commen~
9
Comment:
The [Remedial Investigation) report implies much more lateral flow in the
sand unit part of ~he aquifer system than is suppor~ed by ~he infiltration
rates, potentiometric data and hydraulic conductivity -- hydrogeologic model
-- in the [Remedial Investigation) report.
Response:
The lateral flow was calculated from aquifer tests conducted at the site
in each zone of the surficial aquifer system, as well as from transport
modeling. . Implications in the Remedial Investigation Repor~ are uniformly
supported by data.
-------
-65-
GROUND-WATER FLOW
Source of Comment
9
Comment:
The lateral component of flow in the entire system is radially outward (to
the north, east, and south) from the site area toward the Ortega River system.
Response:
The lateral component of ground-water flow in each of the zones of the
surficial aquifer is predominately toward the northeast and east from the
site. The Field Investigation indicated no lateral flow to the south.
-------
-66-
GROUND-WATER FLOW
Source of Comment
9
Comment:
From the area of the site, ground-water flow is primarily vertically
downward to the limestone unit, then lateral toward the discharge area.
Response:
The data collected for the Hipps Road Landfill site investigation
indicated both vertical and horizontal components to the ground-water flow at
the site (pp. 6-8 and 6-9, RI Report). The data show, and the Remedial
Investigation Report clearly states that the contaminants are most likely to
move in. the lower water table zone, which is' above the semi-confining layer
and well above the limestone unit (p. 6-20, RI Report).
-------
-67-
USE OF INNOVATIVE TECHNOLOGY
Source of Comment
2 & 10
Comment:
Technologies capable of containing or limiting the migration of
contaminants should be considered as part of the Feasibility Study.
Innovative methods such as those described by OTA in Superfund Strategy
should be considered and evaluated as appropriate.
Response:
Several technologies capable of containing or limiting the migration of
contaminants at the Hipps Road Landfill site .were considered in the
Feasibility. Study. These alternatives. included a large suite of technologies
for recovering and treating contaminated ground water. Site stabilization
technologies include full encapsulation of the landfill contents, full
excavation and removal of the landfill contents, solidification and
stabilization of the landfill contents, decontamination of the landfill
contents, and biodegradation of contaminants. Although several of these
options are considered innovative technologies, they were fully evaluated
through several screening phases.
-------
-68-
USE OF INNOVATIVE TECHNOLOGY
Source of Comment
10
Comment:
CDM considered a small number of technologies capable of addressing the
contamination at the site. Several which would be effective were eliminated
in the initial screening stage, based on cost alone (reverse osmosis, wet air
oxidation, ozonation, resin adsorption). ~hile cost is a factor to consider,
several of these methods could be very effective while posing less risks than
the more preferred alternatives such as air s~r~pping.
Furthermore, more innovative technologies are now available which were not
considered at all. Methods such as biological treatment as developed by
Groundwater Decontamination Systems or Detox" Industries could be very
effective at reducing contaminants in the soil and ground water. A vacuum
extraction procedure developed by Terra Vac, Inc. of Puerto Rico could r~move
many contaminants present in the soil. -Combining these technologies could
provide very effective, permanent cleanup without transferring risks (by"
removal to another site or by air stripping) and without leaving much (if any)
residual contamination. These and other Innovative Technologies are described
in more detail in a report prepared by the Congressional Office of Technology
Assessment (OTA) entitled Superfund Strategy (OTA-ITE-253, April 1985).
Response:
The initial screening of alternatives in a Feasibility Study is conducted
from three aspects: technical feasibility, public health and environmental
protection, and cost effectiveness. The last criterion is as important as all
others, providing that the remaining viable alternatives address the first two
criteria, as the Hipps Road Landfill Feasibility Study clearly demonstrates.
The innovative technologies mentioned above are diverse. Biodegradation
was considered in the Feasibility Study; however, ground-water treatment was
found to be more technologically feasible. The vacuum extraction technology
mentioned above produces concentrated wastes which must either be further
treated or disposed of at a landfill approved to accept hazardous waste,
thereby incurring additional costs.
-------
1-
-69-
USE OF COST CRITERIA
Source of Comment
2
Comment:
Some technologies which would effectively clean up the site were
eliminated primarily on the basis of cost. Eliminating a technology solely on
the basis of cost should not be part of the evaluation process, especially
since EPA has identified two Potentially Responsible Parties with sufficient
resources to implement a permanent cleanup.
Response:
The Hipps Road site is considered to be ~ "fund-lead" site. As such, the
Remedial Investigation and Feasibility Study (RIfFS) was performed by EPA's
contractor and paid for by EPA with Superfund monies rather than funds
contributed by potentially responsible p~rties (PRPs). Where EPA performs the
RIfFS with Superfund money, it is required under the provisions of the
National Contingency Plan (NCP) to select the most technologically feasible,
cost-effective remedial alternative which will mitigate and minimize damage
to, and provides adequate protection of, public health, welfare, and the
environment. (See NCP, 40 CFR .~ 300.68(i) and (k))
The fact that EPA has identified PRPs does not eliminate the need for
EPA's compliance with the requirements of the NCP. At the present time, no
PRP has formally entered into a consent order or agreed to perform andfor fund
any remedial action at the site. Though EPA may later engage in negotiations
~ith PRPs for the PRPs' performance of a more expensive remedial action which
produces equal or better results than EPA's most cost-effective technology,
EPA still must comply with the NCP for purposes of a fund-lead RIfFS. (See
~CP, 40 CFR ~ 300.68(c))
-------
-70-
SAFETY OF NEW WELLS
Source of Comment
8
Comment:
It is clear from the study data that the most significant problem
appearing at the site is the contamination of ground water under the site, and
in a plume area extending approximately 1000 feet to the northeast of the
site. The single most significant remedial action available was completed in
January of 1985, when city water systems were made available to all families
in the Hipps Road area and the use of local wells which may have fad from a
contaminated aquifer was eliminated.
It is both cost effective, and in the best interests of the public
and welfar~, that steps be taken to ensure that the wells drawing from
aquifer in question are not used and that no new wells are established
assurance that the water drawn is free f~om contamination.
health
the
without
Response:
The writer demonstrates a clear understanding of the situation at Hipps
Road. It is, indeed, in the best interest of the public to ensure that
possibly contaminated ground water is restricted for consumption until free
from such contamination.
-------
-71-
RESPONSIVENESS TO RISKS OF LANDFILL
Source of Comment
8
Comment:
The cleanup objectives on pages 1-27 and 1-28 more correctly state the
heart of the decision made by the EPA.
[to] Establish institutional controls to prevent the use of existing
wells or installation of new wells in the ground-water zone
impacted by priority pollutants which exceed the concentration
limits presented in Table 1-8, and/or provide extraction and
treatment of the contaminated plume to levels below those
established on Table 1-8.
[and]
Removal or containment of landfill material that pose [sic] a
risk to nearby residents by exposure of contaminated soils by
dermal contact, ingestion- (by children) or consumption by humans
or analysis of vegetables or grasses grown in the contaminated
soils. (Emphasis added).
The remedial actions taken must be responsive to the risk presented by the
specifics of the site.
Response:
The cleanup objectives cited above are not presented as a final decision,
but as proposed goals. Any selected remedial action will reduce or mitigate
the risks present at the Hipps Road Landfill. These risks, however. are the
actual risks posed by the current site conditions, and the potential risks
that may arise from existing conditions (i.e.. an heterogeneous landfill).
-------
-72-
CAPPING LOCAL WELLS
Source of Comment
6
Comment:
The [Duval County] Health Department tells us all wells on Exline Road are
OK, with the exception of a lot of iron. Why will all wells in this area have
to be capped? Instead, why not keep all wells safe by moving the landfill?
Response:
The remedial alternative has not been selected for the site at this time.
In the event that capping wells became an option, only those wells affected or
potentially affected by contamination from the landfill would be capped. It
is unlikely that many wells on Exline, which. is mostly considered upgradient
of the site, would be affected.
-------
-73-
INACCURACIES IN RI AND FS
Source of Comment
7
Comment:
Several items disturb me, in both the Remedial Investigation/Feasibility
Study and the Feasibility Study summary. If such thoroughness was observed in
such studies why does the fourth paragraph of the summary say that three homes
exist just outside the landfill, when in fact my home and one other are
located directly on the landfill.
Response:
Both the RI and FS Reports state that". ... the landfill was covered with a
layer of soil and sold as residential lots. The lots were purchased by D.
woodman, H.A. Vorpe, A. Nolan, and W.H~ Gore. There are two homes located
between the landfill and Hipps Road"
-------
-74-
DEPARTMENT OF THE NAVY'S RECOGN ITION OF NEED FOR REMEDIAL ACTION
Source of Comment
8
Comment:
The Department of the Navy recognizes and supports the
at Hipps Road which will effectively mitigate and minimize
provide adequate protection of the public health, welfare,
40 CFR 300.68(c).
ReSDonse:
~o comment necessary.
need to take action
damage to, and
and environment.
-------
-i5-
RCRA APPLICABILITY
Source of Comment
8
Comment:
The Feasibility Study, at page 4-17, attempts to summarize the
institutional requirements which could apply to the proposed closure. .While
we understand that this summary is not legally binding, we note that we
believe this summary is in error, insofar as it suggests that the Hazardous
~aste Regulations, (RCRA Subtitle C, 40 CFR 264) and the EPA RCRA Design
Guidelines would apply. This site was not active after 1970 and received no
waste after ~ovember 19, 1980. Those facts limit the applicability of the
statutes and regulations to the disposition of this matter by EPA.
Response:
The fact that the site may not have -received waste after November 19,
1980. does not preclude the Agency's consideration and application of RCRA 40
CFR Part 264 requirements to a determination of the relevant and appropriate
standards for CERCLA remedial actions. As stated in the November 20, 1985
Federal Register, "the date on which the waste was disposed or managed is not
germane to the determination of what response action will adequately protect
public health and welfare and the environment. The jurisdictional date would
not be grounds for determining that a requirement is not relevant and
appropriate to a particular site." ($ee 50 Federal Register 47917, Section
III, "Revisions to Subpart F," November 20,1985.)
-------
-76-
AIR STRIPPING
Source of Comment
2 & 10
Comment:
The air stripping procedure poses an unnecessary threat and possibly
dangerous risks to nearby residents. The top preferred alternative includes
using air stripping to remove chemicals from extracted ground water. This
process ~ill put chemicals into the air where they will be dispersed into the
community. This procedure unnecessarily transfers the risks from the ground
~ater that nobody drinks to the air that everybody breathes. If this process
is used, residents will be exposed to contaminants that they would not have
been exposed to simply because the process is cheaper than other
alternatives. Carbon adsorption can achieve the same result, perhaps even
removing m~re chemicals without exposing anyone. Air stripping should not be
used under any circumstances.
To emphasize the importance of this, let me share an experience from Love
Canal. During the cleanup there, residents established a "hot line" for
reporting illnesses and problems in the community. Invariably, the hot line
rang off the hook on those days when chemicals were disturbed onsite.
Residents had no way of knowing what was happening onsite, but children got
sick, people with respiratory problems complained and others developed
symptoms of chemical exposure. Apparently, the residents at Love Canal had
become sensitized, especially the children, to concentrations of chemicals
that scientific evidence would predict to be "harmless". Clearly this was not
the case, but nobody could explain it. Since many of the same chemicals
present at Love Canal are also present in the Hipps Road landfill, it makes
sense not to repeat the errors of Love Canal and avoid contamination of the
community.
Response:
The CDC/ASTDR health assessment has assessed and commented on the health
threat that may be posed by any remedial actions which would bring
contaminants into contact with humans. Air stripping is not a desirable
remedial action at this site, and EPA agrees with this decision.
-------
-77-
JACKSONVillE WASTE WATER TREATMENT CAPABILITY
Source of Comment
7
Commen~:
In the
the ground
This would
same plant
expansion.
Remedial Investigation/Feasibility Study one method of disposal of
water is disposal in the Privately Owned Treatment Works (POTW).
be the City's southwest Was~e Water Treatment Plant (wwTP) This
is currently hydraulicly overloaded and is only recently beginning
It appears that little or no thought was put into this concept.
Response:
In November 1985, EPA's contrac~or met with officials from the
JacksonVille Department of Public Works (Water and Sewer) to discuss the
possibilities for discharging contaminated ground water from the Hipps Road
Landfill Site into the City of Jacksonville POTW. At that time, the EPA
contractor was informed that the Southwest WWTP is being expanded to provide
the necessary capacity. The increased capacity will be available before the
implementation of a remedial action. Therefore, the option to dispose of
con~aminated ground water at the POTW is feasible, and that option will remain
as part of the Feasibility Study.
-------
-78-
EFFECTIVENESS OF GROUND-WATER EXTRACTION PROCEDURES
Source of Comment
10
Comment:
CDM [EPA's contractors for this project} proposed a single ground-water
extraction procedure using 20 extraction wells pumping 20 gallons per minute
(FS, p. 3-2) to be used with all Group A alternatives. This procedure
(developed as a computer model) estimates that 95~ of the contaminated ground
water would 'be recovered ~fter one year of continuous pumping (FS, p. 3-2).
Several important factors were not considered in this estimation: the
influence that surface capping will have on water table levels, the lack of
containment system to keep contaminated wastes within a limited area, the
limited - ability to remove soil contaminants, ,and the selective removal of only
water-soluDle contaminants. It is highly unlikely that 95% of the
contaminants will be removed because of these factors. As a result,
additional testing and further estimates -are needed to address these factors.
Resoonse:
The primary role of a ground-water model is to help obtain quantitative
answers of sufficient accuracy and detail to guide in the decision making
process for whatever decision needs to be made. In this case,a ground-water
model was used as a tool to help evaluate the best extraction well system for
cleaning up ground-water contamination at the Hipps Road Site. The model
results indicate that 20 extraction wells, each pumping 20 gpm, is the best
system. The model results also indicate that under the worst possible
contamination scenario, as previously defined by the model, 95~ of the
contamination will be removed with this extraction well system within a year.
The role of ground-water models is not to provide precise answers to questions
posed. but rather to produce results which will guide the decision making
process. This value of 95% is not meant to be a precise answer. It was
reported only for use in comparing the results of the different extraction
well system simulations. Therefore, do not assume that after this extraction
well system is in operation, exactly 95~ of the contamination may be removed
in less than one year. Because of the many unknowns and uncertainties with
respect to the ground-water system, it may be more than a year before 95% of
the contamination is removed. Continued monitoring of ground-water quality in
the area will be necessary in order to evaluate the impact of the' extraction
well system.
In our analysis. the influence of surface capping of the landfill on water
levels was not considered because this influence will be negligible. Without
extraction wells, ground-water flow at Hipps Road is influenced primarily by
the regional hydrologic conditions. Capping the landfill, affecting a
relatively small area, will have a very small impact on water levels. With
extraction wells, ground-water flow at Hipps Road will be dominated by well
pump age and capping the landfill will have essentially no effect on water
levels at the site.
-------
-79-
EFFECTIVENESS OF GROUND-WATER EXTRACTION PROCEDURES
~ith regard to a containment system, the extraction well system itself
creates a hydraulic barrier in the aquifer. This barrier prevents the
contaminants from leaving the area, while pumpage draws the contaminants into
the wells. Therefore, a physical containment system is not necessary.
With regard to removing soil contaminants, the extraction well analysis
addressed only ground-water contamination. The percent removal calculations
are based only on contamination of ground water. Soil contamination is
addressed elsewhere in the FS report.
"ith regard to the removal of only water-soluble contaminants, a two-phase
ground-water flow model was not used because two-phase (fluid) flow 1s not
evident at the site. Only contaminants dissolved in ground water were
discovered in the monitor wells during the r~medial investigation and they
.were in very small quantities. The quantities of contaminant substances found
are not great enough to cause two-phase flow as might occur in gasoline
spills, for example. Therefore, the analysis only addressed extraction of
ground water. .
In conclusion, additional testing and further evaluation to address the
above factors are not needed. For the reasons explained above, further
analysis will not lead to a better answer or solution.
-------
Source ::
-80-
APPENDIX 1
SOURCE OF COMMENTS
1
Source
Petition form letter received from more than 140 individuals in
response to the initial remedial actions considerations stated by
EPA at the May 7. 1986 Public ~eeting
2
Jacksonville Concerned Citizens Against Contaminated Water, signed
by Alvin Speicher. President
3
Yvonne & Donald Woodman. Hipps Road area residents
4
Ike Nolan. Hipps Road area resident
5
Gloria Stratton, Hipps Road area resident
6
Paul & Jean Ott, Hipps Road area residents
7
Henry Vorpe. Hipps Road area resident
8
Department of the Navy, submitted by D. R. Spell, Environmental
Branch Head
9
Waste Control of Florida. prepared by Golder Associates,
consultants; submitted by Charles H. Tisdale. Jr.
10
Citizens' Clearinghouse for Hazardous Wastes,
Steven U. Lester, Science Director; submitted
Hipps Road area resident
Inc., prepared by
by Yvonne Woodman,
-------
-81-
APPENDIX 2
NAMES AND ADDRESSES OF COMMENTERS
NMfE
ADDRESS
DATE LEITER
WAS RECEIVED
Henry Vorpe
9110 Hipps Road
Jacksonville, FL
5/22
32222
~ary Beth Woodman*
9084 Hipps Road
Jacksonville, FL
5/22
32222
S~even Woo9man":
9084 Hipps Reacf
Jacksonville, FL
5/22
32222
Ronald Gagne":
4545 Cambr~dge Road
Jacksonville, FL 32210
5/23
Paul & Jean Ott
7180 Exline Road
Jacksonville, FL
5/23
32222
Kenne~h S~evens*
6769 Lauriana Place
Jacksonville, FL 32216
5/23
Donald \Oioodson'':
P.O. Bex 7842
Jacksonville, FL
5/23
32238
~far jorie Gagne'':
4545 Cambridge Road
Jacksonville, FL 32210
5/23
William Brewer, Jr.*
7005 Greenholly Drive
Jacksonville, FL 32211
5/23
Dee Cain":
2744 Ocean Drive, Apt. B
Fernandia Beach, FL 32034
5/23
Yvonne Woodman*
P.O. Box 7842
Jacksonville, FL
5/23
32238
Sheryl K. Baker*
498 Eldridge Gelly Street
Orange Park, FL 32073
5/27
-;":
= Submitted Form Letter
-------
-82-
NA~IE
ADDRESS
DATE LETIER
WAS RECEIVED
Lester D. Senter*
5/27
Joyce Warrick",
Arnold E. Morris*
Mrs. Leroy Alline Starling*
Ron Stevens'"
s . W. Hyman"
Mrs. G. Poppalordo*
Earl ~. Henry, Jr.*
Thomas Bus ler'"
Ray Sne llgrove'"
Jimmy Tenney*
Terrance Johnson*
159 Machelle Drive
Jacksonville, FL 32220
5430 Norde Drive
Jacksonville, FL
5/27
32244
5150 Pennant Court
Jacksonville, FL 32244
5/27
5108 Colonial Av.eneue
Jacksonville, FL 32210
5/27
300 Glenlyon Drive
Orange ParR, FL 32073
5/27
858 Crest Drive East
Jacksonville, FL 32221
5/27
5952 Blackthorn Road
Jacksonville, FL 32244
5/27
8933 Hipps Road
Jacksonville, FL
5/27
32222
5400 Collins Road
Lot 112
Jacksonville, FL
5/27
32244
413 Ameca Avenue
Orange Park, FL
5/27
32073
8929 Hipps Road
Jacksonville, FL
5/27
32222
8925 Hipps Road
Jacksonville, FL
5/27
3222
.. -
Submitted Form Letter
-------
-83-
NAHE
ADDRESS
DATE LETTER
WAS RECEIVED
James E. Johnson*
5/27
Edward Hall'"
Betty Burnett'':
M. Benton'"
Connie & Tracy Patillo*
wallace A. Witherbee*
William Gann"
Peggy COX"
William M. Szimore*
David W. Strunk
John R. Young*
Doyle HaU*
8925 Hipps Road
Jacksonville, FL
32222
5017 Palmer Street
Jacksonville, FL 32210
8931 Hipps Road
Jacksonville, FL
5909 111th Street
Jacksonville, FL
7040 Exline .Road
Jacksonville, FL
5/27
5/27
32222
5/27
32244
5/27
32222
6865 Miss ~tuffet Lane S.
Jacksonville, FL 32210
5/27
3957 Baim~r Drive
Jacksonville, FL
7030 Knotts Drive
Jacksonville, FL
5/27
32210
5/27
32210
8941 Hipps Road
Jacksonville, FL 32224
5/27
5858 111th Street
Jacksonville, FL
7514 Strato Road
Jacksonville, FL
5/27
32244
5/27
32210
8164 Crosswind Road
Jacksonville, FL 32244
5/27
~:' =
Submitted Form Letter
-------
-84-
~AME
ADDRESS
DATE LEITER
WAS RECEIVED
C. E. Franks"
50S Murray Drive
Jacksonville, FL
5/27
32205
C. D. Hens ley'"
4506 Harlow Boulevard
Jacksonville, FL 32210
5/27
\\' . G. Dickinson'"
6625 Aline Road
Jacksonville, FL
5/27
32244
John O. ~!esmer":
8935 Hipps Road.
Jacksonville, FL
5/27
32222
Susan Marynowski*
2921 NE 13th Street
Gainesvill~, FL 32609
5/27
Clyde A. Brown'"
5936 110th Street
Jacksonville, FL
5/27
32244
Leroy Starling":
5108 Colonical Avenue
Jacksonville, FL 32210
5/27
Everett L. Stratton*
7183 Exline Road #B
Jacksonville, FL 32222
5/27
James \\-. COX":
7030 Knotts Drive
Jacksonville, FL
5/27
32210
Gloria P. Stratton*
7183 Exline Road #B
Jacksonville, FL 32222
5/27
Tony ~. Poppalardo*
5952 Blackthorn Road
Jacksonville, Fl 32244
5/27
Roland Cuevos*.-
1505 LaVilla Drive N.
Jacksonville, FL 32221
5/27
* = Submitted Form Letter
-------
-85-
NMIE
ADDRESS
DATE LETTER
WAS RECEIVED
Danny /l;ewton'"
5873 Oak lane Drive
Jacksonville. FL 32244
5/27
David L. Phelps*
8103 Poe Court
Jacksonville. FL
5/27
32244
Dorothy Johnson*
8925 Hipps Road
Jacksonville. FL
5/27
32222
John Hen
,',+
Route 4 Box 6
Hawthorn. FL
5/27
32640
Delmer L. Mattison*
4841 Homecrest Circle
Jacksonvilie. FL 32244
5/27
Peggy Beaviss'-'
7171 Bunion Drive
Jacksonville. FL
5/2i
32222
R. Hisoire'-'
Bo'x 1137
Jacksonville. FL
5/27
32239
Kathy Henderson*
4224 NW 30 Terrace
Gainesville. FL 32605
5/27
Donald C. Steele*
491 Clermont Avenue S.
Orange Park. FL 32073
5/27
Al ta Adams'-'
6062 Elm Grove Avenue
Jacksonville. FL 32244
5/27
Jimmy E. Johnson*
1031 Lamarcke Drive
Jacksonville. FL 32205
5/27
~lrs. Lyle ~lartin*
6224 Sauterne Drive
Jacksonville. FL 32244
5/27
..
= Submitted Form Letter
= Incomplete Address on Comment
+
-------
-86-
NANE
ADDRESS
DATE LEITER
WAS RECEIVED
Mr. & ~rs. Larry Batton*
5/27
Gary J. Court*
Gloria Strat:t:on
Ike Nolan
Scott ~1. ~1otel":
Submitted by Chet Tisdale
on behalf of Waste Mgmt.
Inc.
D.R. Spell, PE
Jacksonville Citizens
Against Cont:aminate water
Yvone woodman &
Donald woodman
Submitted by Yvonne Woodman
& Donald Woodman - from
Steven V. Lester
Annet:te M. Maxey*
5322 Appleton Street
Jacksonville, FL 32210
7656 Arble Drive
Jacksonville, FL
5/27
32211
7183 Exl~ne Road #B
Jacksonville, FL 32222
5/27
7145 Exline Road
Jacksonville, FL
5/27
32222
3434 Blanding Boulevard
Apartment -#190
Jacksonville, FL 32210
5/28
King & Spalding
2500 Trust Company Tower
Atlanta, GA 30303
5/29
pm 5/28
Department of the Navy
Southern Division
Naval Facilities Engineering
Command
2155 Eagle Dr., PO Box 10068
Charleston, SC 29411-0068
5/30
pm 5/28
PO Box 7842
Jacksonville, FL
5130
pm 5/28
32238
PO Box 7842
Jacksonville, FL
5/30
pm 5/28
32238
Citizens Clearinghouse for
Hazardous Wast:e
PO Box 926
Ar1ingt:on, VA 22216
5/30
pm 5/28
1601 Dunn Avenue #7A
Jacksonville, FL 32218
5/30
pm 5/28
- = Submitted Form Letter
pm = Post:marked
-------
-87-
NAME
ADDRESS
DATE LETTER
WAS RECEIVED
Linda Coffman-::
Kristin A. Case*
Chr is Cummins~':
~rs.Charles F. Anderson*
Gerry E. Suits~"
Margaret E.~. Sullivan*
Richard E. Coffman*
Doris ~. Gates"
:-Irs. Lori Buck~':
Karen \\-ard~'"
Jeanette A. Todd*
Betty J. Dickinson*
Mary P. Nettles*
6232 Sauterne Drive
Jacksonville, FL 32210
5/30
pm 5/28
4246 Hall Boree Road
Middleburg, FL 32068
5/30
pm 5/28
4336 San Juan Avenue
Jacksonville, FL 32210
5/20
pm 5/28
7408 Burlingame. Drive S.
Jacksonville, FL 32211
5/30
pm 5/28
4500 Ramona'Street
Jacksonville, FL 32205
5/30
pm 5/28
220 ~Iyra Street
Neptune Beach, FL
32233
5/30
pm 5/28
7236 Blanding Boulevard #116
Jacksonville, FL 32244
5/30
pm 5/28
5885 Edenfiled Road #726
Jacksonville, FL 32211
5/30
pm 5/28
4216 Old Mill Cove Terrace W
Jacksonville, FL 32211
5/30
pm 5/28
102 NE 22nd Street
Delray Beach, FL 33444
5/30
pm 5/28
8903 Hipps Road
Jacksonville, FL
32222
5/30
pm 5/28
6625 Aline Road
Jacksonville, FL
32244
5/30
pm 5/28
3915 Riverside Avenue
Jacksonville, FL 32205
5/30
pm 5/28
* = Submitted Form Letter
pm = Postmarked
-------
-88-
t-:A~IE
ADDRESS
DATE LETTER
WAS RECEIVED
Linda C. Jenkins*
Claude Oglesley*
Mr. & Mrs. Carroll Pittman*
Ken Taylor"
Michael H. Daniel*
john C. Levigs-::
Anthony S. Fiore*
(plus a cover letter)
Alena Ellie'"
Bonnie D. Perea*
Burna Perea'"
Janie Fiore'"
Dona GoIns'"
8280 Honeysuckle Lane
Jacksonville, FL 32244
5/30
pm 5/28
9280 Hipps Road
Jacksonville, FL
32222
5/30
pm 5/28
9066 Hipps Road
Jacksonville, FL
32222
5/30
pm 5/28
6062 Seaboard Avenue
Jacksonville, FL 32210
5/30
pm 5/28
1419 B. Dancy Street
Jacksonville, FL 32205
5/30
pm 5/28
11651 Fort Caroline Road
Jacksonville, FL 32226
5/30
pm 5/28
4421 San Clerc Road
Jacksonville, FL 32217
5/30
pm 5/28
1300 East Cornwallis Road
Durham, NC 27713
5/30
pm 5/28
1011 E. 33rd Avenue
Tampa. FL 33603
5/30
pm 5/28
1011 E. 33rd Avenue
Tampa, FL 33603
5/30
pm 5/28
4421 San Clerc Road
Jacksonville, FL 32217
5/30
pm 5/28
917 Jones Circle
Durham, NC 27703
5/30
. pm 5/28
* = Submitted Form Letter
pm = Postmarked
-------
-89-
NAME
ADDRESS
DATE LEITER
WAS RECEIVED
Janie L. Hansely*
8ii3 Hipps Road
Jacksonville, FL
32222
5/30
pm 5/28
Neal D. Thomsen*
132 McDowell Avenue
. GA 31520 +
5/30
pm 5/28
132 McDowell Avenue
,GA 31520 +
5/30
pm 5/28
J ewe 11 Thoms en'-'
Janie P. Hansley*
8912 Hipps Road
Jacksonville. FL
32222
5/30
pm 5/28
Gail P. Speicher*
1108 Blazing Ridge
Lawrenceville, GA 30245
. 1108 Blazing Ridge
Lawrencev i lIe, GA 30245
9208 Hipps Road
Jacksonville, FL 32222
9040 Hipps Road
Jacksonville, FL 32222
9040 Hipps Road
Jacksonville, FL 32222
1649 Landing Lane
Neptune Beach, FL 32233
1816 Kings Way
Neptune Beach, FL 32233
1816 Kings Way
Neptune Beach, FL 32233
5/30
pm 5/28
Edward Jaques'"
Holly B. Jaques*
5/30
pm 5/28
Margaret Oglesley*
5/30
pm 5/28
Al Speicher'-'
5/30
pm 5/28
5/30
pm 5/28
Carol Sutkowreik*
5/30
pm 5/28
Mr. & Mrs. W.R. Henderson*
5/30
pm 5/28
William R. Henderson*
5/30
pm 5/28
* = Submitted. Form Letter
pm = Postmarked
+ = Incomplete Address on Comment
-------
-90-
NAME
ADDRESS
DA TE LETTER
WAS RECEIVED
Sco~~ Pine~~e''''
Judith D, ~fozo''''
Thomas K. Burke*
Cecilia Vosper'"
B. Calhon'"
\\' . H. Boky. J r , ,':
~farie Lynch>':
Melissa G. Koralakes*
Laurina Vorndra*
Kim Harey":
o ianne ~larkin~:
Oscar L. Hendrisk*
224 Oak Street
Neptune Beach, FL
32233
5/30
pm 5/28
120 North Street
Neptune Beach, FL
32233
5/30
pm 5/28
2016 Strand
Neptune Beach, FL
32233
5/30
pm 5/28
110 walnut Street
Neptune Beach,FL
32233
5/30
pm 5/28
6265 Merrill Road.
Jacksonville, FL 32233
5/30
pm 5/28
1461 Hopkins Creek Lane
Neptune Beach, FL 32233
1462 Hopkins Creek Lane
Neptune Beach, FL 32233
1618 Landing Lane
Neptune Beach, FL 32233
1648 Landing Lane
Neptune Beach, FL 32233
1454 Hopkins Creek Lane
Neptune Beach, FL 32233
1519 Hopkins Creek Lane
Neptune Beach, FL 32233
1627 Hopkins Creek Lane
Neptune Beach, FL 32233
5/30
pm 5/28
5/30
pm 5/28
5/30
pm 5/28
5/30
pm 5/28
5/30
pm 5/28
5/30
pm 5/28
5/30
pm 5/28
.. = Submitted Form Letter
pm = Pos~marked
-------
1-
-91-
NMtE
ADDRESS
DATE LETTER
WAS RECEIVED
J. Carlson'"
E. Pife,'t
~lartha James,'t
Janet W. Montgomery*
Gregory J. Streeter*
Bernie L. Brewer*
Particia B. Oarnswarth*
Douglas J. Jaegar*
Gary Gene Kirkland*
Paul R. Coombs,'t
Larry Phillips'~
~laria A. Dill""
1409 Indian Woods Drive
~eptune Beach, FL 32233
1304 Forest Marsh Drive
Neptune Beach, FL 32233
1440 Bucknoll Cove
Neptune Beach, FL 32233
1424 Bucknoll Cove
Neptune Beach, FL 32233
427 6th Str~et N.
Jacksonville, FL 32240
1435 Bucknoll Cove
Neptune Beach, FL 32233
1419 Forest Marsh Drive
Neptune Beach, FL 32233
1731 Indian woods Road
Neptune Beach, FL 32233
5/30
pm 5/28
5/30
pm 5/28
5/30
pm 5/28
5/30
pm 5/28
5/20
pm 5/28
5/30
pm 5/28
5/30
pm 5/28
5/30
pm 5/28
1811 Indian Woods Road
Neptune Beach, FL 32233
5/30
pm 5/28
224 Oak Street.
Neptune Beach, FL
5/30
pm 5/28
32233
1512 Big Tree Road
Neptune Beach, FL
5/30
pm 5/28
32233
1501 Big Tree Road
Neptune Beach, FL
5/30
.pm 5/28
32233
- = Submitted Form Letter
pm = Postmarked
-------
-92-
NA~E ADDRESS DATE LEmR
WAS RECEIVED
Renee Albert'': 919 Neptune Circle 5/30
Neptune Beach, FL 32233 pm 5/28
Tom Rady'-' 1314 Big Tree Road 5/30
Nep~une Beach, FL 32233 pm 5/28
Lucille Young'-' 1401 Kings Road 5/30
Neptune Beach, FL 32233 pm 5/28
Linda Whi te'-' 1406 Big Tree Road 5/30
Neptune Beach, FL 32233 pm 5/28
Ken Ki rton'-' 1504 Big Tree Road 5/30
Neptune Beach, FL 32233 pm 5/28
P. Bailey* 1603 Arrowhead 5/30
Neptune Beach, FL 32233 pm 5/28
Alfred W. Shepherd'-' 1510 Windward Lane 5/30
Neptune Beach, FL 32233 pm 5/28
C.~. Johns ton'-' 1643 Leeward Lane 5/30
Neptune Beach, FL 32233 pm 5/28
Colton L. Pus ler": 1528 Leeward Lane 5/30
Neptune Beach, FL 32233 pm 5/28
.. = Submitted Form Letter
pm = Postmarked
-------
-93-
NA~E
ADDRESS
DATE LETTER
WAS REcEIVED
Brenda & Art Zipperer*
8389 Hilma Road
Jacksonville, FL
32244
6/2
pm 5/30
Clifton A. Todd*
8903 Hipps Road
Jacksonville, FL
32222
6/2
pm 5/29
Rose A. Contreras*
7627 Indian Lakes Drive #2
Jacksonville, FL 32210
6/2
pm 5/29
John R. Smith",
6054 Toyota Drive
Jacksonville, FL
32244
6/2
pm 5/29
Frank Smith'"
6301 Roosevelt +
6/2
pm 5/29
Allen Himes':
8314 Dandy Avenue
Jacksonville, FL
32211
6/2
pm 5/29
Dina Pork'" +
6/2
pm 5/29
Earnest L. Walker*
371 Spruce Street +
6/2
pm 5/29
Gerald G. Hill'':
8936 Hipps Road
Jacksonville, FL
32222
6/2
pm 5/29
Daniel J. Hurst*
1290 Lakeshore Boulevard
Jacksonville, FL 32220
6/2
pm 5/29
L.D. Stokes*
11646 Nickel Lane
Jacksonville, FL
32220
6/2
pm 5/29
~1. E. Kelly'"
7135 Shindler Drive
Jacksonville, FL 32244
6/2
pm 5/29
.. = Submitted Form Letter
pm = Postmarked
+ = Incomplete Address on Comment
-------
-94-
~A:1E
ADDRESS
DATE LEITER
WAS RECEIVED
Allen M. ~iller*
2103 Figaso Lane
Jacksonville, FL
6/2
pm 5/29
Henry B, Bo~den, Jr.*
7704 Hare Avenue +
6/2
pm 5/29
Jerome Rivers'"
4662 Roanoke Boulevard
6/2
pm 5/29
W, L. Budgets''''
3019 Roselle S~reet
Jacksonville, FL 32205
6/2
pm 5/29
William Durham"
6606 Kinccrck Drive +
6/2
pm 5/29
Angela D. &
Richard T. Evernder*
8350 Sunflo~er Court #9 +
6/2
pm 5/29
Robert Gidcumb''''
4352 Vicksburg'Avenue
Jacksonville, FL 32210
6/2
pm 5/29
Ernes~ O. Thomas*
2534 Lantites
Jacksonville, FL
6/2
pm 5/29
Fredrick ~, Hughes*
P.O. Box 7006
Jacksonville, FL
32238
6/2
pm 5/29
Donna Car~er'"
6477 Cooper Lane
Jacksonville, FL
32210
6/2
pm 5/29
K.R. Beals":
6455 San Juan Avenue #9
Jacksonville, FL
6/2
pm 5/29
Robert E. Allen*
4754 Burgundy Road
Jacksonville, FL 32210
6/2
pm 5/29
Allen G. App1er
1155 Hamlet Lane E.
Neptune Beach, FL 32233
6/2
* = Submitted Form Letter
pm = Postmarked
+ = Incomplete Address on Comment
-------
-95 -
NA~lE
ADDRESS
DATE LETTER
WAS RECEIVED
Jacquiline ~. Pooler*
Lauric Sorg'"
Allen G. Applar*
Clare A. McCruz*
~enelzo G. Shealy*
William Daly'"
P. A. Robar'-'
Susan L. Zeltway*
Glynn w'ilson'"
~lary Edwards"
Bob ~larshburn':
Charles H. Thompson*
Owen Jolly'"
Gloria Jean Jolly*
1528 Leeward Lane
Neptune Beach, FL
1149 Hamlet Lane
Neptune Beach, FL
32211
6/2
pm 5/30
32211
6/2
pm 5/30
1155 Hamlet Lane E.
Neptune Beach, FL 32211
6/2
pm 5/30
1708 Hamlet Lane N.
Neptune Beach, FL 32211
6/2
pm 5/30
1828 Hamlet.Lane N.
Neptune Beach, FL 32211
1836 Hamlet Lane
Neptune Beach, FL
1110 Hamlet Court
Neptune Beach, FL
1121 Hamlet Court
Neptune Beach, FL
1128 Hamlet Court
Neptune Beach, FL
1140 Hamlet Court
Neptune Beach, FL
1145 Hamlet Court
Neptune Beach, FL
6/2
pm 5/30
32211
6/2
pm 5/30
32211
6/2
pm 5/30
32233
6/2
pm 5/30
32233
6/2
pm 5/30
32233
6/2
pm 5/30
32233
6/2
pm 5/30
1150 Hamlet Lane E.
Neptune Beach, FL 32233
5114 Benning Road
Jacksonville, FL
5114 Benning Road
Jacksonville, FL
6/2
pm 5/30
32205
6/3
pm 5/31
32205
6/3
pm 5/31
* = Submitted Form Letter
pm = Postmarked
-------
j
APPENDIX C
City of Jacksonville
Division of Public Wbrks
Ibsition Letter
Regarding the Availability
of the
Local Publ icl y ()med Treabnent Wbrks
for
Disposal of Recovered Ground Water
fran the
Hipps ~ad Landfill Site
-------
July 31, 1986
~ g
-' ~
C1c- S
i.: ::1 H B ;' Hit.n v.
-------
APPENDIX D
1):!partrnent of the Interior
Fish and Wildlife Service
Natural lesource n:rnage Assessnent
Release fran Claims
-------
e.,-o,o:'";,;ooo
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,..,\:~.;,o
~-:-./
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHI~GTO:--;, D.C. 2024-0
JUh :2 5 1986
ER84/1519
Mr. Gene Lucero, Director
Environmental Protection Agency
Office of Waste Programs Enforcement
401 :\1 Street, SW (Room S362r-;) ','H ~...
""ashington, D.C. 20460
Dear ".1r. Lucero:
The Depart:-nent of the Inte:-lOr has recvaluated the Hipps Road Landfill site,
Jacksonville Heights, Duval County, FL, because of new information made availabl~ oy
EP A, Regional IV. This letter constitutes a revised Preliminary Natural Resources
Survey, and updates the survey sent to you on October 10, 1985.
The area. surrounding Hipps Road Landfill provides habitat suitable for migratory birds,
and the Ortega River/St. Johns River system contains several anadromous fish species.
In addition, several endangered species occur in Duval County. However, there is no
evidence that these trust resources or lands under DOl ste....'ardship have been impacted
by materials from this site.
Accordingly, we are prepared to grand a release from claims for damages to natural
resources under our trusteeship from the Hipps Road Landfill.
Z :. n c e.~ e J y , . ./' 0' / l'

/~ ~~ -- L--/
~ruce Blancha:;d':Director
- Office of Environmental Project Review
cc:
t!teve Klein/EP A
En........
rm f-. .n H, r, / - " r-
...1 .'-I'~ i. ;:""')

n ' -! - ((}It?JJrf rI t?m!: ')
f L ) J U L On 1 ~ -8°-:~- II i
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~~'r~YL'2IjLrn:;-, U:

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-------
. APPENDIX E
State of Florida
Department of Ehvironrental Regulation
letter of Concurrance
for the
SelectedRanedy
-------
STATE OF FLORIDA
.~', ;',
&,- k-J, ';'. J
, . I'~ I ~
..'. ~ '-L-
'. 'i ' "
DEPARTMENT OF ENVIRONMENTAL REGULATION
TWIN TOWERS OFFICE BUILDING
2600 BLAI R STONE ROAD
TALLAHASSEE, FLORIDA 32301-8241
BOB GRAHAM
GOVERNOR
VICTORIA J. TSCHINKEL
SECRETARY
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
and commits to the recommended remedial alternative, designated
RA-8, proposed in the final draft feasibility study for the Hipps
Road Landfill Superfund Site in Duval County, Florida. This
alternative includes ground water recovery and treatment at the
City of Jacksonville's S.W. Sewage Treatment Plant, proper
landfill closure, institutional controls, and long-term
monitoring. The remedial action will effectively remove ~he
existing ground water contaminant plume and eliminate all
pathways for human exposure.
The state will also accept its responsibility to provide 10
percent of the $3.1 million cost for the project through the
state Water Quality Assurance Trust Fund. We are fully committed
to the continued operation and maintenance of the remedial
activities beginning one year after ground water cleanup goals
are achieved.
We appreciate your reconsideration of the ground water cleanup
element of the remedial action and we will be glad to work with
you to determine site specific cleanup goals during the design
phase. We look forward to continued cooperation with the U.S.
Environmental' Protection, Agency in the successful implementation
of this project. '. .' ,.
-Sincerely,
~Vic
,) Se
P, {))oJkN
Tschinkel
'~-
-------
.-
APPENDIX F
EPA POsition Statement
Reqardirg
Relocation FClicies
for
Affected Property OWners
-------
---- "---
, :. - --
. .
.-...\
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\..;. -':-'::~., ;
Ii; .
'-.
MEMORANDUM
#. -:.
DATE:
AUG 01 1986
SUBJECT:
Hipps Road Landfill; Relocation of Homeowners
TO:
Kris Teepen
Remedial Project Officer
FROM:
Robert W. Caplan
Office of Regional Counsel
EPA has' determined that proper implementation of the remedy
selected by EPA for the Hipps Rd. site will require that approximately
five (5) houses be removed and/or razed and the families relocated.
Several questions have been raised in the Region concerning the
appropriate mechanisms and procedures for funding and implementing
relocation efforts including:
1. Whether relocation of residents is a recognized and
permissable remedy under CERCLA.
Answer: Yes. Under Section 101(24) of CERCLA, the word
"remedy" is defined to include "the costs of permanent re-
location of residents..."
2.
When is permanent relocation an appropriate remedy?
Answer: Under Section 101(24) of CERCLA, permanent relocation
is appropriate "...where the President determines that,
alone or in combination with other measures, such relocation
is more cost-effective than and environmentally preferable
to the transportation, storage, treatment, destruction,
or secure disposition offsite of hazardous substances, or
may otherwise be necessary to protect the public health
or welfare.
3. Is permanent relocation of residents appropriate tor
the Hipps Rd. site?
Answer: Based on its determination that excavation and
removal of landfilled materials from the Hipps Rd. site would
be too costly and dangerous, EPA selected a cost-efficient
and technologically feasible remedy which calls for properly
-------
- 2 -
closing the landfill with an adequate cap, and
groundwater remediation. The selected remedy meets
the reauirements of the NCP that such remedy be a
"cost-effective remedial alternative that effectively
mitigates and minimizes threats to and provides
adequate protection of public health and welfare and
the environment". According to preliminary conceptual
designs of the remedy, several houses need to be removed
or razed to ensure adequate room for construction of
the cap. In short, EPA believes that relocation is
more cost-effective than and enviornmentally pre-
ferable to excavation and off-site disposition of
landfilled wastes.
4. If permanent relocation is selected and approved as
part of the remedy, which federal and/or state agencies
are responsible for handling the administrative of such
effort?
Answer: The Federal Emergency Management Administration
(FEMA) has authority under Executive Order to administer
relocation efforts for CERCLA matters. FEMA'S primary
responsibility in this regard is to negotiate prices with
property owners. Once price is agreed upon, the funds
are provided by Superfund. The State of Florida would be
required to take title to the property. The process
employed in the Hipps Rd. site would be similar to the
Times Beach relocation effort.
5. What compensation, if any, is due to home/property
owners whose homes and/or property are not on the landfill
but will be impacted by construction of the remedy and/or
temporary and permanent monitoring activities?
Answer: This is a troublesome topic for EPA's remedial
activities. As a general rule, EPA does not purchase such
property through condemnation or other procedures, or with
Superfund monies. EPA has advanced the argument that it
has statutory authority to enter such property for purposes
of constructing the remedy or staging for con$truction.
However, in a recent federal court opinion, the Court ruled
that EPA had no such authority to enter off-site property
to construct or stage construction of the remedy. with
respect to the Hipps Rd. site, two such off-site parcels of
property to which EPA may need access are owned by Al Speicher
(located at 9040 Hipps Rd.) and Mr. Strange (Exline Rd.).
Based on their previous comments, it is likely they will
prefer to be relocated. Presently, EPA has no legal authority
to fund relocation of Mr. Speicher or Mr. Strange. Further,
°EPA's policy is that neither Mr. speicher nor Mr. Strange
will be reimbursed by the Agency if part of their property
is needed on a temporary or permanent basis. In the event
-------
- 3 -
EPA does seek access to their respective properties, Mr.
Speicher and/or Mr. Strange may initiate a lawsuit which
may impede the implementation of the remedy.
6. Must permanent relocation be approved by EPA
Headquarters?
Answer: Headquarters has indicated that it must, unless
the Hipps Rd. site ROD is a delegated ROD. I will up-
date this as soon as I receive more information.
-------
.' .
APPENDIX G
D3partIrent of Heal th and Hunan Services
Agency for Tbxic Substance and Disease ~istry
Public Health Evaluation
for
Hipps R>ad landfill Site'
-------
(4'''''~
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Date
From
Subject
To
DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Hea!;:h S,?rVice

Agency for To).c S,,~s:~
and Disease Reg,s:'..
Memorandum
. MAY 1 6 1986
Acting Director
Office of Health Assessment
Health Assessment: Hipps Road Landfill SI-86-046
Jacksonville, Florida
Mr. Chuck Pietrosewicz
Public Health Advisor
EPA Region IV
EXECUTIVE SUMMARY
The Hipps Road Landfill Remedial is a former landfill that ceased opera-
tion in 1970 and was subsequently co~ered with local soil of inadequate
quality for a proper cap. A January 1985 emergency response action
(providing an alternate, permanent water supply) appears to have addressed
the only opportunity for the site to present a potential public health
threat. The site should be properly closed and proper groundwater moni-
toring instituted.
STATEMENT OF PROBLEM
The Environmental Protection Agency (EPA) requested the Agency for Toxic
Substances and Disease Registry (ATSDR) to review and comment on the
health and risk assessment, the Feasibility Study (FS), and the adequacy
of the proposed remedial alternatives for the protection of public health.
The Hipps Road Landfill is located at the southeastern corner of the
intersection of Hipps and Exline Roads west of downtown Jacksonville,
Florida. The landfill occupies approximately 7 acres in what was once a
cyprus swamp. It is presently a relatively flat area sparsely covered
with grass, brush, and pine trees. Fill material is reported to be buried
on the site to a depth of 25 feet.
-------
~
Page 2 - Mr. Chuck Pietrosewicz
The facility, operated by Waste Control of Florida, Inc., ceased opera-
tions in 1970, at which time the fill was covered with a layer of soil and
sold as residential lots.
There are two homes located between the land-
fill and Hipps Road, and one residence located on the west side of the
site on Exline Road.
The area surrounding the Hipps Road Site is residential and, until re-
cently, these residences depended exclusively on private wells for water
supply. After several wells, reportedly tested in April 1983, were found
to be contaminated with volatile organic compounds, those residences were
given bottled water and city funds were appropriated to extend the city
water system to include this area. City funds were not provided to the
individuals to connect to the extended lines, thus, only those who wishe~
and had the funds could connect to the city system. During January 1985,
EPA, through an emergency response action based upon ATSDR advice, con-
nected the remaining residences to the city supply.
~
DOCUMENTS REVIEWED
1.
Request for Assistance, Chuck Pietrosewicz, ATSDR, to Chief, Field
Services, ATSDR, March 14, 1986.
2.
"Remedial Investigation Report for Hipps Road Landfill Site,
Jacksonville, Florida," February 10, 1986.
"Hipps Road Landfill, Feasibility Study, Draft Report," February 24,
1986.
3.
4.
"Site Analysis, Hipps Road Landfill, Duval County, Florida," by
Bionetics Corporation, Warrenton, Virginia, June 1985.
ATSDR site files.
s.
.
CONTAMINANTS AND PATHWAYS
Table 1 presents the maximum concentrations for numerious chemical spe-
cies reportedly found in various sampling locations on and around the
-------
Page 3 - Mr. Chuck Pietrosewicz
Hipps Road Landfill. Based upon the data prdvided for chemical concen-
tration in surface soil and groundwater, and the fact that the groundwater
is no longer being consumed in the area of the site, there does not appear
to be a pathway for significant human exposure related to this site.
DISCUSSION
The already-completed emergency response action of connecting the resi-
dences to the public water supply has addressed the only documented
pathway for potential significant human exposure for this site. Any
remedial action which would excavate the waste or treat the groundwater
would provide a new potential pathway for exposure.
The method by which the data was pr!sented in the review documents makes
it difficult to fully evaluate the site. There does not appear to be any
clear presentation of the data from the private wells on which the initial
remedial action was based. In addition, there appears to be some incon-
#
~sistencies in the Remedial Investigation (RI). For example, in Table 3-4,
the concentration of zinc in borehole BH-15 is reported as 1,400 ug/l,
while in Table 9-1, it is reported as 33,000 ug/l.
In order to interpret the groundwater condition in the vicinity of the
site, it would have been useful to have sampled the same wells on more
than one occasion. This would demonstrate that the contamination was
actually present in the water and show if the concentration of the
contamination was changing with time.
From the data provided, there appears to be one private well, one off-site
monitoring well, and several on-site boreholes with substantial organic
contamination, and one on-site borehole with high metal concentrations.
The private well contamination is with methylene chloride which is ubiqui-
tous in laboratories and notorious as a contaminant in the analytical
-------
Page 4 - Hr. Chuck Pietrosewicz
process. The reported 5,700 ug/l appears to be somewhat higher than might
be expected from laboratory contamination. However, it is also more than
two orders of magnitude greater than any of the other vater samples from
the site. Therefore, it would be difficult to consider the site to be the
source of this compound if it is, in fact, present in the groundwater of
the private well. The reported methylene chloride in this well is also
called into question because the monitoring vells in the immediate vicin-
ity report none of this compound. The other private well data reported
show lov concentrations of toluene below any level for public health
concern for consumption of the water.
There appears to be little relationship between the materials reportedly
found in the soil and the groundwat~r from the bore holes on the site.
Specifi~ally, polychlorinated biphenyls (PCBs) vere reported in the
groundwater from the bore holes at concentrations which appear equal to or
greater than the water solubility for the compounds, while at the same
time, the soil samples from these bore holes shov no PCBs even though they
were analyzed by priority pollutant procedures. This situation in which
the materials were reported either to be present in the 50il and not the
groundwater, or vice versa, appears to call into question the analytical
results.
Another result that calls into question the validity of the analytical
results is that of aluminum. In many of the samples from the bore holes,
the temporary wells, and both series of monitoring wells, the aluminum
concentration is reported to be in the thousands of ug/l, some even tens
and hundreds of thousands of ug/l, while the maximum reported value for
the private vells is 280 ppb, with most of the reported values being
reported as less than the detection limit of 200 ppb. It seems difficult
to explain this vide difference in concentration with at least some of the
-------
Page 5 - Mr. Chuck Pietrosewicz
monitoring wells and private wells in close proximity to each other and
withdrawing from the same aquifer. While this is not the only difference
in results from adjacent wells, it is the most glaring example.
It appears that, at least in the off-site private wells, there is no
substantial indication that the landfill is the source of general contami-
nation.
While the downgradient wells PW-6, PW-7, PW-8, PW-9, and the
on-site well PW-IO show contamination, there is no consistency in the
contaminant; PW-6 has 1,2-dichloroethane, PW-7 has methyl ethyl ketone,.
PW-8 has methylene chloride, PW-9 has lead, and PW-IO has the maximum
report~d concentration (24 ug/l) of toluene. In the other private wells
toluene was less than 10 ug/l.
One of the few consistencies in the data is the reported concentration of
vinyl chloride in the three monitoring wells, EMW-6 (32 ug/l 50'), EMW-2
(28 ug/l 55'), and EMW-3 (31 ug/l 60'), which appear to be in the general
direction of the predicted groundwater flow, i.e., in a northeasterly
direction as well as into the aquifer. This uniformity of concentration
would, along with the general lack of precursor chemicals, indicate that
the vinyl chloride had been produced by biodegradation essentially on the
site and that further rapid increase in concentration is not occurring.
In order for this situation to occur, i.e., essentially complete degrada-
tion of the precursor chemicals, it would require very slow migration from
the source of the contamination to the nearest monitoring well. Since it
has been nearly 15 years since the landfill ceased operation, there has
been ample time to develop an environment for biodegradation. Thus, the
occurrence of substantial biodegradation would not be surprising. In
fact, the concentration of the one possible precursor, trans-1,l-dichloro-
ethene, also a biodegradation product, is not constant in these three
wells, but is higher in the more distant wells, EMW-2 (27 ug/l 55') and
EMW-3 (24 ug/l 60'), than in the nea~by well EMW-6 (6 ug/l 50"). Since
-------
Page 6 - Hr. Chuck Pietrosewicz
there are no reported precursor compounds for the dichloroethene in the
groundwater samples from these wells, this inverse gradient from the
landfill could indicate that the concentration of precursor chemicals in
the landfill has diminished significantly since the water at the more
distant wells left the point of contamination.
If the vinyl chloride can,
in fact, be used as a conservative indicator of pollutant migration from
the site, then the substantial variation in concentration of other chemi-
cal species among these three wells cannot be explained by the assumption
that they all came from the same source. . However, with only one set of
data to evaluate, any conclusions about what may be occurring in the
groundwater is pure conjecture.
COMMENTS
The feasibility study on page 2-12, states that site-specific data for
80il samples show that contaminants such as toluene and methylene chloride
are found in levels capable' of producing a leachate with concentrations
exceeding the cleanup goals. The data cited were not provided for review;
however, the data available for review (remedial investigation) did not
appear to support this claim.
The use of data for-a compound like n-nitrosodiphenylamine as an indicator
compound for this site does not appear to be valid. It was reportedly
found in two on-site wells; however, because of analytical limitations it
could not be distinguished from diphenylamine. If this compound is to be
used as an indicator of contamination for this site, then it is necessary
for its presence to be documented by additional analytical work
identification is positive. Without this effort, the potential
of this compound should not be used in the site evaluation.
so that
presence
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Page 7 - Mr. Chuck Pietrosewicz
CONCLUSIONS AND RECOMMENDATIONS
The already-completed emergency response action of providing an alternate,
permanent water supply has addressed what appears to be the only opportun-
ity for the site to present a potential public health threat. From the
data available, it appears that there is no evidence that the site is
currently presenting a public health threat, or that it likely will in the
future. Since there is no demonstrated pathway for human exposure to the
chemicals associated with the site, most of the proposed remedial action
would be counterproductive for protection of public health because, with
the exception of capping the site, they all propose some effort to remove
and. treat the contaminated water and soil. Even though these media appear
to be, in general, only slightly contaminated, this activity could contam-
inate the air or surface soil at levels greater than currently presen~,
thereby exposing the local population unnecessarily.
Since the site reportedly was not properly closed, proper closure and
monitoring of the site should be provided.
~~Q0
Jeffrey A. Lybarger, M.D.
Attachment
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TABLE 1. SELECTED CHEMICALS REPORTED
IN VARIOUS SAMPLES
FROM HIPPS ROAD LANDFILL
CHEMICAL BORE BORE OFF-SITE ON-SITE OFF-SITE
HOLE HOLE GROUND SURFACE SURFACE
WATER SOIL WATER SOIL WATER
ug/l mg/kg ug/l mg/kg mg/kg
arsenic: 220 18
barium 110
beryllium 19
c:admium 60 1.2
c:obalt 42
c:hromium 1100 1.2 3S
c:opper 1200 51
lead 5300 18 29
merc:ury 18 C). 10
nic:kel 370 14 29
selenium 27
vanadium 1100
zinc: 11000 33 200
ac:etone 800 PRESENT
C-3.alkylbenzene 10
C-4 alkylben:ene 20
C-S alkylben:~mide 10
benzene 408 0.005 8
c:arbon disulfide 18 0.001 8.9
c:hlorobenzene 297 Q.11 4.7
c:hrysene PRESENT
1.2-dic:hloroben:ene 39.3
1~4-dic:hlofoben:ene 11 0.14
1.1-dic:hloroethane . 5.3
trans-1.2-diC:hloroethene 33
endrin ketone PRESENT
ethylben:ene 162 0.011 68
ethyl ether 7
ethyl hexanoic: ac:id 20
ben:o(a)anthrac:ene PRESENT
diben:o(a.h)anthrac:ene PRESENT
Benzo(ghi)perylene PRESENT
ben:O(a)p~rene PRESENT
indeno(1, ,3-C:d)pyrene PRESENT
methylene c:hloride 4.8
methyl ethyl ketone 0.003 9.7
methyl isobutyl ketone 22
methoxyc:hlor PRESENT
1,2-diphenylhydrazine
lazoben:ene 1.0
methylnonanediol 70
methrlpentanediol 20
naph halene 96 0.45 20
N-nitrosodi~henYlamine
Idipheny amine 7.6 16
oX~bisethO)(yethane 10c)
PC -1242 36
PCB-1260 38
PCB-1254 1.8
phenol 34 13
methrlPhenol 5.7
2-me hylphenol 46
4-methYl~henol' PRESENT
2,4-dime hrlphenol 13
blS(2-ethr hexYl)~hthalate 96
di-n-buty phthala e 39 PRESENT
~ropanol 40
etrahydrofuran 11
toluene 49 68 PRESENT
tric:hloroethene :2 PRESENT
trimethhlbiCYloheptanone 70
vinyl c lOl"'ide 73
xylenes (total) 220 0.32 93
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