United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-90/060
September 1990
oEPA
Superfund
Record of Decision
Hipps Road Landfill
(Amendment), FL
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50272.101
REPORT DOCUMENTATION 11. REPORT NO. . I ~ 3. Reciplenra Acceulon No.
PAGE EPA/ROD/R04-90/060
4. n.. end Subl.. " 5. Report Dal8
SUPERFUND RECORD OF DECISION 09/21/90
Hipps Road Landfill (Amendment), FL
6.
First Remedial Action - Final
7. AulhOl(a) 8. Perlonnlng Organization Rapt. No.
.. Pwfonnlng Org8ln1zalon Nan. and Add,... 10. ProjecllTa8k/Work Unit No.
11. Contnct(C) or Grant(G) No.
(C)
(G)
12. ~ Organization Nan. and Addr... 13. Type 01 Report. P.rlod Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplemen\8Jy No...
11. Ab8...ct (Um/t: 200 wolda)
The 7-acre Hipps Road Landfill site is an inactive landfill in Jacksonville, Duvall
County, Florida. Surrounding land use 1s rural residential. The site overlies a
sedimentary surficial aquifer system, used as a source of drinking water, which has
been affected by the site. Prior to the start of landfilling operations in 1968, the
site was a cypress swamp. Types of hazardous waste disposed of onsite included cans of
TCE and artillery rounds from U.S. Navy facilities. After onsite operations ceased,
the property was divided into lots, and five homes were constructed on the landfill.
Subsequently, biota in an adjacent pond died, and area residents began to complain of
deteriorating well water quality. In 1983, State investigations confirmed the presence
of ground water contamination, and bottled water was supp~iedto the affected
residents. Consequently in 1985, area homes were connected to the municipal water
supply. In 1989, remedial actions stemming from a 1986 Record of Decision (ROD)
commenced, and included properly closing the landfill and implementing institutional
controls. In addition, the 1986 ROD documented ground water pumping and treatment at a
publicly owned treatment works (POTW) as part of the overall site remedy. In 1990, the
landfill was capped to control the source of the contamination. Ground water
(See Attached Page)
17. Document Analy8la L D88cr1ptora
Record of Decision - Hipps Road Landfill (Amendment), FL
First Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: VOCs (benzene), metals (chromium, lead)
b. 1den11ler81Open-Ended Tenna
-
c. COSAn ReIcIICroup
18. Av_.abilty Statement lB. Secwity Clasa (This Report) 21. No. 01 Pagea
None 233
20. Secwity Cia.. (Thia Page) .22. PrIce
Nonp
. fORM 212 (4-77)
(SM AHSl-Z3B.18)
See Instruc&ons on RevetBe
(Formerly NTl5-35)
Depertment 01 Commerce
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EPA/ROD/R04-90/060
Hipps Road Landfill (Amendment), FL
First Remedial Action - Final
.
Abstract (Continued)
investigations after 1986 revealed that the ground water contaminant ion plume was not as
extensive, and the overall site quality was better than.previously estimated. This ROD
amends the 1986 ROD for the ground water component. The primary contaminants of concern
affecting the ground water are VOCs including benzene; and metals including chromium and
lead. .
The 1986 selected ground water remedial action included ground water pumping, followed
by offsite discharge to a POTW for treatment. This amendment provides for onsite ground
water treatment using air stripping to remove VOCs, followed by onsite discharge of the
treated water to a storm water retention basin, and monitoring of onsite and offsite
ground water. This amendment will substantially decrease the overall cost of the remedy
from that of the POTW treatment alternative. The estimated present worth cost for this
amended remedial action is $1,242,000, which includes an O&M cost of $370,600 for five
years.
PERFORMANCE STANDARDS OR GOALS: Ground water cleanup standards were chosen as the more
stringent of State standards or Federal MCLs. Chemical-specific goals for ground water
include benzene 1 ug/l (State), chromium 50 ug/l (MCL), and lead 15 ug/l (Federal
Recommended Cleanup Goal). Lead and chromium contamination were determined to be
non-site related, but cl~anup goals wil~ be met in water discharged to the rete~tion
basin. ~
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RECORD OF DECISION AMENDMENT
SUMMARY of REMEDIAL ALTERNATIVE SELECTION
HIPPS ROAD LANDFILL SITE
JACKSONVILLE, DUVAL COUNTY, FLORIDA
Prepared by:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
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AMENDED RECORD OF DECISION
SITE NAME AND LOCATION
Hipps Road Landfill Site
Groundwater Remediation
Jacksonville, Duval County, Florida
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Hipps Road Landfill site in Jacksonville, Florida, which was
chosen in accordance with CERCLA, as amended by SARA, and, to
the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). This decision is
based on the administrative record for this site.
The State of Florida concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of~Decision (ROD), may present an
~inent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The September 1986 ROD specified recovery of contaminated
groundwater with disposal at the local Publicly OWned Treatment
Works (POTW). The groundwater contains elevated concentrations
of the site related contaminants vinyl chloride, benzene and
other volatile organic compounds. The Florida Department of
Environmental Regulation has concurred with EPA on the cleanup
levels established for this remedial alternative. The
alternative remedy selected by EPA in this Amended Record of
Decision consists of a groundwater treatment remedy which is
consistent with an overall risk goal for this site.
To address the contamination at the site, the selected remedy
includes the following design.
o Recoverv Well Network - The remedial design consists of a
system of wells installed to capture the zone of
contaminated water.
o Recoverv System Monitorina - The area
the recovery system will be monitored by
levels inside and'outside of the capture
the hydraulic performance of the system.
being affected by
determining water
zone to evaluate
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o Off-Site Monitorina Svstem - The off-site monitoring
system will consist of monitoring wells located in the
vicinity of the off-site groundwater recovery operation.
During the groundwater recovery operati~n, these wells .will
be sampled quarterly for volatile organic compounds to
determine the effectiveness of the recovery system.
o Recovered Water Treatment - Recovered groundwater will be .
routed via a pipeline to the closed landfill site. Volatile
organic contaminants (VOCs) will be removed by air stripping
on the site. A statistical analysis of metals contamination
was done to determine if a significant difference existed
between the upgradient and downgradient metals
concentrations. Because the analysis demonstrated a lack of
significant difference in the metals concentrations, the
lead and chromium found in the ground water are not
considered site-related and will not be the target of
ground-water recovery. However, metals concentrations in
recovered ground water will be reduced to MCLs before the
ground water is discharged to the retention basin.
EXPLANATION OF FUNDAMENTAL REMEDY CHANGE
The September 1986 ROD specified recovery of contaminated
groundwater with disposal at the local POTW and that recovery
would continue until the groundwater was in compliance with the
standards established in the Safe Drinking Water Act (SDWA).
Contaminants not addressed under SDWA would be removed until
compliance with the 1980 Water Quality Criteria Human Health
Standards was reached. According. to the ROD, where no standards
existed, a concentration that would result in no more than the
risk of one additional cancer in a lifetime~for an exposed
population of one million would be used as the cleanup target.
This has not changed. The ROD also specified continued
monitoring for twenty (20) years after the standards are met and
that the system would be reactivated if groundwater contaminants
are detected above target clean-up values.
However, new information has been developed since issuance of
the ROD in 1986. The quality of the contaminated groundwater is
now understood to be better than previously described in the
RIfFS reports. Sampling conducted after the Issuance of the Rob
has shown that concentrations of contaminants are lower than
were previously detected. In addition, the area containing the
contaminated groundwater is smaller than originally thought.
Extensive sampling has more precisely defined the location of
the contamination. The contaminants that are currently found in
the aquifer can be effectively removed by the process of air
stripping.
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Also, based on the current POTW rate structure, the cost for
disposal of the Contaminated water at the POTW will be
substantially higher than estimated in the FS. In summary, the
contaminants currently at levels of concern at the site are
amenable to air. stripping and the relative costs of air
stripping and POTW treatment have changed. ,Air stripping
on-site will not present any hazard to human health. For these
reasons, the selected alternative for groundwater remediation at
the Hipps Road Landfill will be .modified to include air
stripping, and disposal on-site instead of at the POTW.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment technology, to the
maximum extent practicable, and satisfies the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element~
"
SIP 2 1 tjSC
Date
~ ~ *"=
Greer C.~l
Regional Administrator
~
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1..0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
TABLE OF CONTENTS
INT'RODOC'rION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.1
1.2
1.3
Site Location and Description...........................l
Site History-.......................8..................... 1
Explanation of Fundamental Remedy Chanqe...............2
ENFORCEMENT .AN.AL YS IS. . . . . . . . . ~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
CO!mU'NITY REIA.TIONS.......................................... 4
4.1
4.2
CURR.ENT SITE STATUS.......................................... 4
On-site Soils.......................................... 4
Hydrogeoloqy'. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
5.1
SUMMAR.Y OF SITE RI SKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Public Health and Environmental Objectives.............7
ALTERNATIVES CONSIDERED FOR GROUND-WATER REMEDIATION
IN SEPTEMBER 1986 ROD........................................ 9
6 . 1 Al ternati ve Screening................................. 9
6.2 Alternative Previously Selected......................12
6.3 Description of Alternative Currently
Being Considered for Ground-water Remediation........12
6.3.1 Alternative 1 - Extraction, Air Stripping
and Disposal On-s i te. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
6.3.2 Alternative 3 - Extraction and Treatment
at the Publicly Owned Treatment Works................12
Comparative .Analysis..................... . . . . . . . . . . . .13
6.4
SELECTED REMEDY............................................. 14
1.1
7.2
7.3
Design of Selected Remedy.........;'................... 15
Cost Est.imate......................................... 19
Operation and Maintenance.............................19
STATtJTORY REQUIREMENT............... . . . . . . . . . . . . . . . . . . . . . . . . 21
8.1 Protection of Human Health and the Environment........21
8.2 Attainment of the Applicable or Relevant and
Appropriate Requirements (ARARs)......................21
Coat Effectiveness.................................... 22
Utilization of Permanent Solutions and
Alternative Treatment Technology or Resource
Recovery Technoloqies to the Max.imum Extent
Practicable. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23
8.3
8.4
8.5
Preference for Treatment as a Principal Element.......23
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LIST OF FIGURES
Figure 1 - Methane Borehole Location
Plan. . . . . . . . . . . . . . . . . . . . . . . . . .6
Figure 2 - Boundary of Potential Off-site
Groundwater Contamination...............................8
Figure 3 - proposed Recovery well Layout..........................16
Figure 4 - Monitoring Well Location Plan.~........................17
Figure 5 - Down-Gradient Well Spacing Diagram.....................20
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LIST OF TABLES
TABLE 1 - Ground-water Remediation
Goals. . . . . . .'. . . . . . . . . . . . . . . . . . . . 10
TABLE 2 - Summary of Feasible Alternatives and
Cost-Effectiveness Comparison............................ll
~
LIST OF APPENDICES
Appendix A - Record of Decision, September 1986
~
Appendix B - Responsiveness Summary
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Record of Decision Amendment
of Remedial Alternative Selection
Hipps Road Landfill Site
Jacksonville, Florida
1.0 IMTRODUCTIOH
This Amendment provides a current status of activities that
have been completed since the Record of Decision was signed for
the Hipps Road Landfill Site on September 3, 1986, and
documents the Agency's decision to treat recovered ground water
on site instead of at the Publicly Owned Treatment Works
(POTW).
1.1 Site Location and Description
The Hipps Road Landfill Site is located at the corner of Hipps
and Exline Roads west of Jacksonville, Florida. The landfill
lies in a rural/residential setting in Duval County. The seven
(7) acre landfill area is generally flat and occupies a site
500 feet by 600 feet.
1.2 Site History
In September 1986, EPA selected a remedial alternative for the
Hipps Road cleanup which included:
o proper landfill closure;
o implementation of institutional controls including fencing
the site, grouting existing private wells, instituting a
well drilling ban for a minimum of 20 years, and acquiring
affected properties;
o recovery of contaminated ground water with treatment at
the local Publicly Owned Treatment Works (POTW);
o continued monitoring of the ground water for 20 years
following the final ground-water recovery phase;
o operation and maintenance (0 & M) activities including
operating and maintaining the ground-water recovery
system, ground-water monitoring, maintaining the landfill
cap and associated system, maintaining the connector sewer
lines which access mains to the POTW, and maintaining the
site security systems.
After the ROD was signed on September 3, 1986, EPA negotiated a
Partial Consent Decree with Wastecontrol of Florida, Inc., one
of two Potentially Responsible Panv'^" I'«TSO<»\ *r>v «-v,«. «»**«.
The Partial Consent Decree was eu^^,: v- :rt on January
25, 1989.
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Under the Consent Decree, Wastecontrol of Florida, Inc., agreed
to design ~h. landfill cover and the ground-water recovery
system, and to deve10p the institutional controls.
Wastecontrol also agreed in the Consent Decree to implement the
landfill closure aDd institutional controls. Although
Wastecontrol had agreed to design the ground~water recovery
system, Wastecontrol did not agree to construct and operate the
ground-water recovery system. The Landfill Closure Design was
completed and approved on May 22, 1989.
Previous records of the site indicate that in 1970 the landfill
was covered with soil and five homes were constructed on the
property. As stipulated in the Consent Decree, Wastecontrol
acquired these (5) homes and removed them from the site in the
spring and summer of 1988.
Construction of the landfill cover began in October 1989. A
clay cap system was placed over the landfill to reduce
infiltration and minimize contaminant migration. An eight-foot
security fence was installed around the site. A perimeter
ditch was constructed to carry runoff from the cover to a large
retention basin southeast of the actual landfill area but
within the fenced area. The basin was designed to retain the
100 year storm event entirely on-site. Prior to construction
of the clay landfill cover, t~ees and large vegetation were
close-cut and removed from the site. To prevent erosion of the
clay cover, a vegetative soil cover was placed over the clay.
Eleven (11) additional monitoring wells were also installed.
Construction of the landfill was completed in April, 1990.
The initial Groundwater Recoverv Svstem Desian ReDort (30%
Completion) was submitted to the Agency in April, 1989. The
design of the ground-water recovery system is 4based primarily
on the information gathered during the Remedial Design. Data
collected from existing wells and new temporary monitoring
wells constructed during the Remedial Design (RD) phase of the
project were used for predicting the area of off-site
ground-water contamination. Data generated during the RIfFS
was used to supplement the RD information. The ground-water
recovery design and additional ground-water data collection are
described in Section 7.0, Selected Remedv, of this document.
Based on the additional technical information and changing rate
structure of the POTW (or escalating costs associated with the
POTW), the Agency decided to amend the September 1986 ROD.
1.3
B%Dlanation of Fundamental Remedv Chanae
The September 1986 ROD specified recovery of contaminated.
. ground water with disposal at the local POTW and that recovery
would continue until th~,ground water was in compliance with
the standards established in the Safe Drinking Water Act
(SDWA) .
-2-
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Contaminants not addressed under SDWA would be removed until
compliance with the 1980 Water Quality Criteria Human Health
Standards wa* reached. According to the ROD, where no
standards existed, a concentration that would result in no more
than the risk of one additional cancer in a lifetime for an
exposed population of one million would be used as the cleanup
target. This has not changed. The ROD also specified
continued monitoring for twenty (20) years after the standards
are met and that the system would be reactivated if
ground-water contaminants are detected above target clean-up
values.
However/ new information has been developed since issuance of
the ROD in 1986. The quality of the contaminated ground water
is now understood to be much better than previously described
in the RI/FS reports. In addition/ the area containing the
contaminated ground water is smaller than originally thought.
Extensive sampling has more precisely defined the location of
the contamination. The contaminants that are currently found
in the aquifer can be effectively removed by the process of air
stripping. Also/ based on the current POTW rate structure/ the
cost for disposal of the contaminated water at the POTW will be
substantially higher than estimated in the FS. In summary, the
contaminants currently at levels of concern at the site are
amenable to air stripping and Łhe relative costs of air
stripping and POTW treatment have changed. For these reasons/
the selected alternative for ground-water remediation at the
Hipps Road Landfill will be modified to include air stripping/
and disposal on-site instead of at the POTW.
2.0 ENFORCEMENT ANALYSIS
EPA and Wastecontrol of Florida/ Inc., signed a Partial Consent
Decree which was entered by the U.S. District Court on January
25, 1989. The other responsible party/ the United States Navy/
did not sign the Consent Decree but did enter into a separate
agreement with Wastecontrol whereby the Navy agreed to
contribute funds to the costs of the remedial action. Under
the Partial Consent Decree/ Wastecontrol agreed to design the
landfill cover and the ground-water recovery and treatment
system/ and to develop the institutional controls for the
site. However*, Wastecontrol did not agree to construct and
operate the ground-water recovery and treatment system. As of
the date of this Amended Record of Decision/ the landfill cover
has been designed and constructed by Wastecontrol. Subsequent
to the entry of the Partial Consent Decree/ EPA reevaluated the
ground-water remedy selected in the Record of Decision and
determined that an alternative remedy requiring air stripping
would be more appropriate.
-3-
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3.0
cnVillU1'I.l ft pRY ~IOBS
EPA prepared a Record of Decision (ROD) on September 3, 1986, taking
into consideration. the comments from the public and the results of
the FS. The most environmentally sound and cost-effective remedy
was then selected as a part of the Record of Decision (ROD) phase of
the Superfund process. EPA selected capping ~f the landfill,
institutional controls and recovery of contaminated ground water and
discharge to the POTW.
In September, 1988, a fact sheet was published to inform the public
of planned remedial design activities. A public meeting was held on
AprilS, 1989 to present a schedule for implementation of remedial
design activities at the site. The meeting also served to inform
citizens that the court had entered the Partial Consent Decree and
had required that EPA submit a revised community relations plan and
file an Administrative Record.
EPA conducted a public information meeting on August 15, 1989 to
present the design for the landfill closure to interested citizens
and local officials and to provide an opportunity for further
discussion of concerns raised by citizens during the previous April
5, 1989 meeting. (Summarv of Public Comment and Aaencv ResDonse,
HiDDS Road Landfill Site SUDerfund Fact Sheet. August 1989.) EPA
conducted a more recent public meeting on July 11, 1990. At the
meeting, EPA, in consultation with FDER, announced to citizens that
the Agency was considering modifying the proposed alternative for
ground-water recovery based on new information affecting the cost
effectiveness of two alternatives. A 30 day public comment period
was initiated and was extended for 30 days at the request of local
citizens. The comment period ended on August 31, 1990. A summary
of the comments received and the Agency's response is included as
Appendix B.
~
4.0
4.1
CURREHT SITE STA'l'US
On-Site Soi1s
As stated previously, the landfill closure system is completed. To
address the concern that placement of a low permeability soil cover
over the landfill might cause the methane typically generated in
landfills to 8igrate laterally, a methane monitoring system was
placed around the perimeter of the landfill.
Methane gas surveys were con~ucted in December 1988 and April 1989.
During the earlier survey (December 1988) measurements of gas
concentrations were made at 13 locations evenly distributed around
the landfill boundary. No methane was detected at any of the
locations tested indicating that methane was not migrating laterally
from the landfill at that time. However, the results of the April
1989 gas survey indicated- that, of the six locations. surveyed within
the boundaries of the landfill, methane gas was detected in five
borings.
-4-
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Of the five detections, methane was detected at concentrations above
the Lower Explosive Limit, or LEL (5% methane by volume in air) in
two of the boreholes. This shows that, while methane is being
produced within the landfill, it is not migrating off site.
Detailed results of both the December 1988 and April 1989
investigations are included in Appendix A of the Landfill Closure
Desian. The locations tested in e~chsurvey are shown in Figure 1.
Since completion of the clay landfill cap, adjacent retention basin,
perimeter ditches, and accompanying vegetation cover, further
migration of contaminants via percolation into the ground water,
lateral migration of the ground water through the soils, or storm
water runoff from the surface soils is controlled.
4.2
Hydroaeoloav
Ground-water Contaminants
The current areal and vertical extent of ground-water contamination
was delineated from two sources of information. One source was a
new temporary monitoring well system (TMW-series wells) installed
for the Remedial Design investigation. The other source was data
obtained by resampling the MW-series wells which were installed and
sampled as part of the RI. Because the primary purpose of the
TMW-series was to define current ground-water contaminant plume
boundaries, these wells were installed farther downgradient from the
site than the MW-series well system.
The TMW-series wells consist of eleven (11) monitoring well
clusters. Each cluster is comprised of three ,3) wells installed in
separate boreholes: a shallow well (35 ft.), an intermediate well
(65 ft.), and a deep well (95 ft.). Sampling and analysis of the
MW-series wells and the TMW-series wells indicate the following.
Three detections of metals were above MCLs:
Maximum Level
Detected
Maximum Contaminant
Level (MCL)
(Federal/State)
0.05 mg/L
0.05 mg/L
0.05 mg/L
chromium - MW-21(Cluster G)
chromium - TXIf-2D (Deep)
lead - MW-9 (Cluster D)
- 0.056 mg/L
- 0.074 mg/L
- 0.068 mg/L
-
Four detections of organic compounds were above MCLs:
vinyl chloride -
benzene - TMW-7I
benzene - TMW-3I
~inyl chloride -
TMW-7I
20.0 ug/L
7.9 ug/L.
7.9 ug/L
1. 3 ug/L
-5-
1.0
5.0/1. 0
5.0/1.0
1.0
ug/L
ug/L
ug/L
ug/L
TMW-8I
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-------
Based on the above ~ta, the zone of off-site ground-water
contamination is confined to the "lower portion of the Sand Aquifer. .
The boundary of the contamination plume is defined by those wells.
which did not have chemicals detected above the Max~um Contaminant
Level (MCL) and non-zero HCLGs. The zone is bounded on the
northwest side by wells TMW-111 and TMW-10I, on the southeast by
wells TMW-4I and MN-9 (Cluster MW-D) , on the-northeast by a
northwest/southeast trending line approx~ately 16 feet
down-gradient (northeast) of well TMW-8I, and on the southwest by
TMW-6I. With the exception of TMW-8I, these wells bounding the zone
of off-site ground-water contamination did not have organic
contaminants detected above MCLs.
The boundary of potential off-site ground-water contamination is
depicted in Figure 2. The analYtical results of sampling both the
MW-series and TMW-series wells are contained in Appendix F of the
draft Groundwater Recovev Svstem Desion Report.
The isolated chromium detection of 76 ug/l is above the Maximum
Contaminant Level of 50 ug/l. However, the chromium level detected
is below the current proposed Maximum Contaminant Level(MCLG) of 100
ug/l and is, therefore, considered protective of human health.
To address the concern that lead might be site related, a
statistical analysis of lead contamination was done to determine if
a significant difference existed between the upgradient and
downgradient lead concentrations. Four sets of data (results from
four separate sampling events spanning a five year period) were
analyzed by this method. Because the analysis demonstrated a lack
of significant difference in the lead concentrations, the lead found
in the ground water is not considered site-related and will not be
the target of ground-water recovery. However, lead concentrations
in recovered ground water will be reduced to MCLs before the
groundwater is discharged to the retention basin.
Finally, to predict the extent and concentration of vinyl chloride
beyond (down-gradient of) TMW-8I, a ground-water model was used.
The model results (Appendix G, draft Groundwater Recoverv System
Desion) predict only minimal movement (16 feet) of the plume
down-gradient of TMW-8I at this t~e, well within the capture zone
of the recovery wells.
5.0
5.1
SUJlMARY OJ' SID IUSKS
Public II8a1th and Environmental Ob1ectives
. At the time the ROD was signed in September 1986, the current public
health threat was through physical contact with the fill material.
This exposure pathway has been eliminated by ~plementation of the
landfill closure. Recovery of the contaminated ground water is the
. remaining remedial objective. .
-7-
-------
.
r-
,...
,
.
'.
.
- -
---..
---
. - ---:;.....Q'T'hW1'"
-
...
'-
.
- -'
- -
-
--.
- -- -
LEGEND
-- B 0 U N D A A V 0 F POT e N T I A L 0 F F - SIT E
GROUNDWA TER CONT AMINA TlON.
BOUNDAR V OEFINEO BY THose WELLS WHICH
010 NOT HAve CHEMICALS DETEC TED ABOVE
MAXIMUM CONTAMINANT LEVEL (MCL).
(CHEMICALS ONLY DETECTED IN LOWER PORTION
OF THE SAND AQUIFER).
TMW-11 WELL WITHOUT CHEMICALS DETECTED
. NO . ABove MCLS.
...
-
,.....
....../
. Q
NO
'd TMWD -7 weLL WITH CHEMICALS DETeCTED
~ . ABove MCLS
1
.. '''.''0
NO
-
I
./
./
.j
c:.--8
._-4
NO
: /i-,,!
:: ~ / l '\.. ~!CALCULA TED
:1 . / ,,1,c1mgIlYC
il i Y:0UNDARV LINE
/'1 i ,-" :'T"."
Ii" . 0 'I
, !I f"NO" il '" "'L~ ~'D' t'~ ,
JL it !L ~N° jl" .\
1 r - '''.ot -- ItOAA ': ( '- .' '''.-1 .:r....;!
.-NO - NO ,I "': 0., ---- NO I
IEJ' ~:~ ; ~ ~NO DETECTION :1
, 1M ~ L""'II ;I! BOUNDARY LINel
i- ~, ! "
II I I a:
, ~ ~;, ~!
~
I
:,
q
,
.-"'.-.
; NO
II
I!
.1
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,
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--"
In! .
:u;
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.
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'M ...
...
...
,:
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'-.~Ider Associates
"TLf
Atl8n18.OeorgI8
BOUNDARY OF POTENTIAL
OFF-SITE.
GROUNDW A TER CO NT AM IN A TION
~("r~
W ASTECONTROL OF FLORIDA, INC.
HIPPS ROAD LANDFILL
0---- IC~CKEO
JLW ~."" 'Af"'EWŁO
A.
OATE
12/11/88
~IE
AS SHOWN
OWQ NO I REV NO
'01/2
..oe NO
883-3eoe
Of.."" ..
'I~Ł NO
883-321:,<
'IGYFlI!
..,
ALUII"I .~_.. ..-
-------
The contaminated ground water in the sand aquifer is not
currently being consumed by residents in the vicinity of the
site. All r88idents near the plume have access to municipal
water. In addition, the City of Jacksonville has environmental
health regulations which prohibit drinking water wells within
the contaminated area. ~though the sand aqu~fer does not pose
a current risk to area residents, it is classified under the
Groundwater Protection Strategy as a potential source of
drinking water or a Class IIB aqui~er. A potential source of
drinking water is one which is not currently being used as a
drinking water source but is capable of yielding a quantity of
water that satisfies the needs of the average family and has a
total dissolved solids concentration of less than 10,000 mg/l.
Class IIB aquifers must be remediated to drinking water
standards, if available, or to health based levels if standards
are not available. This has th! corregponding effect of
placing the risk within the 10- - 10- range which is the
overall goal of Superfund remedies. Recent sampling data
indicate that several contaminants in the leading edge of the
plume exceed drinking water standards. In addition to being
classified as a IIB aquifer, the plume is migrating toward the
Ortega River where it could also have an environmental impact.
Ground-water remediation goals are presented in Table 1.
6.0
ALTERNATIVES CONSIDBRED I'OR GROUND-WATER RBJIBDIATIOlf Ilf
SEPTEMBER 1986 ROD
Remedial alternatives considered for the Hipps Road Landfill
are listed below:
A.
Ground-water Technologies
1-
2.
3.
4.
. ...
Extraction, Air Stripping and Disposal On-site
Extractiin, Flocculation, Sedimentation, Filtration, and
Disposal
Extraction, and Treatment at the POTW
Extraction, Air Stripping, Flocculation, Seiimentation,
Filtration, Carbon Adsorption, and Disposal
Extraction of Ground Water from Hydraulic Barrier
Wells On-site, Ling Term Air Stripping, and Disposal to
the Ortega River
Extrac~ion of Ground Water from Hydraulic Barrier Wells,
Trea~t According to A-4, and Discharge to the
POTW
Installation of a Hanging Slurry Wall around the
Landfill, Surface Capping, Reverse Gradient Wells
Within the Slurry Wall
s.
6.
7.
6.1. Alternatives Screenina
,..~~+-- ~ ~
The alternatives and
were screened out in
-, "!-,..-- -....: .".~e
technologies identified with a {*)
the January 1986 ROD. The reasons
~"~ ~~=~_~~lo9ies were screened out
Table 2.
above
why
at that
~.uuQ ~:. f'-. ":.
..a~: in
-9-
-------
TcLble 1
Ground-water Remediation Goals
Chemical
Remediation
Goal (ug/l)
1
4
100
50
75
100
700
15
140
1
Basis
Benzene
Bis(2-ethylhexyl) Phthalate
Chlorobe~zene
Chromium
1,4-Dichlorobenzene
trans-1-2-Dichloroethylene
EthYl Benzene
Lead
Naphthalene
Vinyl Chloride
PDWS
PMCL
PMCL
MCL
PDWS
PMCL
PMCL
RCG
RfD
PDWS
"
PDWS - State of Florida Primary Drinking Water Standard
PMCL - Proposed Maximum Contaminant Level
Recommended Cleanup Goal for lead at Superfund sites
(Correspondence from the Directors of Office of Emergency &
Remedial Response and Office of Waste Programs Enforcement,
June 21, 1990)
MCL - Maximum Contaminant Level
RCG -
RfD -
Reference Dose. This is the systemic threshold concentration
calculated as RfD (mg/kg-day) x Body Weight (70 kg)/Daily
Water Consumption (2 liters). The RfD for naphthalene is 4E-3
(Health Effects Summary Tables 3rd Quarter, FY90)
Lead and Chromium are not considered site-related and will not
be the target of ground-water recovery. However, metals
concentrations in recovered ground water will be reduced to
MCLs before the ground water is discharged to the retention
basin.
*
-10-
-------
Table 2.
S"~Ary Table of Feasible Alternatives and
C08~-Bffectiveness Comparison. Cost in Millions
of Dollars. .
Remedial Alternative
Estimated
Cost Range
A-1. Air Stripping,
Disposal On-site
Extraction, Floc-
culation, Sedi-
mentation, Filtration
and Disposal to the
Ortega River
A-3. Extraction & Treatment
at the POTW
A-2.
A-4.
Extraction, Air-
Stripping, Floc-
culation, Filtration,
Carbon Adsorption, &
Disposal to the Ortega
River
A-5.
Extraction from
Hydraulic Barrier
Wells, Long Term
Air Stripping, and
Disposal to the POTW
A-6.
Extraction from
Hydraulic Barrier
Wells, On-site
Treatment According to
A-4, and Discharge to
the POTW
A-7.
Installation of
Hanging Slurry Wall,
Surface Capping,
Reverse Gradient
Wells within the Slurry
Wall and Discharge to
POTW
Reason for Non-Selection
Less cost effective than
treatment at the POTW and
failure to address all
ground water contaminants
Less cost-effective than
treatment at the POTW
and fails to address
all ground-water contaminants
The recommended alternative
for ground water remediation
Addresses all ground-water
~ontaminants, but is expensive
compared to treatment at POTW
Less cost-effective than
treatment at the POTW
and fails to address
all ground water contaminants
Less cost-effective than
treatment at the POTW
and fails to address all
ground water contaminants
Expensive, containment only;
does not restore aquifer
! 0,.-
1. 6 to 3. 3
1. 3 to 1. 8
1. 3 to 1. 9
3.1 to 4.0
9.0 to 10.6
3.2 to 17.3
4.1 to 6.9
-------
6.2
Alternati.ve Previouslv Selected For Ground Water
. The selected remedy for ground water, as specified in the 1986
ROD, was Alternative A3 - Extraction and treatment at the
POTW. The selection of this alternative is now being
reevaluated a8 a result of additional information about the
nature and extent of contamination at the site and changes in
the relative costs of various remedies since the ROD was signed
in 1986.
6.3
Descriotion of Alternatives Currentlv Beina Considered
for Ground-water Remediation
Alternative 1
Extraction, Air
Stripping, and Disposal
On-site
Alternative 3
Extraction and Treatment
at the Publicly Owned
Treatment Works
Alternative 1 - Extraction. Air Striooina and Dis9Qsal
On-site
This alternative involves imp~ementation of a ground-water
recovery system designed to recover the existing plume of
contaminants. The contaminated ground water will be passed
through a counter current air column which will enhance the
exchange of organics from the aqueous stream to the effluent
air stream. A high degree of water detoxification is
possible. The clean water would be discharged to the On-site
stormwater retention basin for disposal. This~alternative is
not expected to emit organic vapors in levels which would cause
environmental or public health concerns due to low contaminant
levels and rapid dispersion. However, site specific testing
during RD and RA would be required.
6.3.1
6.3.2
Alternative 3 - Extraction and Treatment at the
Publiclv Owned Treatment Works
Extraction of the ground water would be implemented with a
system designed to recover the existing plume of ground-water
contaminants. . The untreated ground water would be discharged
to nearby municipal sewer lines for treatment at the local
POTW. Disposal to the POTW is not expected to have a
. significant effect on the level of volatile organic compounds
in the treatment plant effluent, due to dilution at the POTW
head works. Also, the concentration of volatile organic
compounds would diminish during transport to the treatment
. plant as a result of aeration. The level of ground-water
contamination is sufficie~tly low to allow the POTW to accept
the wastes without violation of the operational permits. The
flow rate will not add ~:..~;~:_2.2..=:..:.~"~ :::~.~":'"~,,'~,.. ',,~~~~~ ~i;. the
POTW.
-12-
-------
6.4
This analysis will compare the alternatives, A-l and A-3, for
the nine evaluation criteria detailed in the National
Contingency Plan (NCP).
Overall protection of human health and the environment - Both of
the alternatives accomplish this criterion. Both of the
alternatives are within Agency guidelines and would provide
adequate protection by reducing or controlling the threat to the
environment by remediating the contaminated ground water.
Compliance with ARARs - Both alternatives would meet the
respective ARARs and cleanup goals. No waiver from ARARs would
be necessary to implement either cleanup alternative.
Long-term effectiveness and performance - Ground-water treatment
and recovery would provide a permanent remedy; therefore, either
alternative would meet this criteria and reduce the risk
associated with ground water at this site.
Reduction of toxicity. mobility, and volume - Both alternatives
would reduce the toxicity, mobility and volume of ground-water
contamination by decreasing the.size of the contaminant plume
and the threat of further degradation of the ground water.
Short-term effectiveness - Both options provide similar
short-term effectiveness since the only difference is in
off-site or on-site treatment. The remedial design indicates
that emissions from the system will be much lower than Florida
standards and neither would pose significant health risks to
nearby residents or sewage treatment plant workers. In order to
better define air impacts associated with operation of the
ground-water recovery and treatment system, a more detailed
analysis of the system was conducted and is detailed in Sections
7.0 and 7.1, Selected Remedy and Design of Selected Remedy.
respectively.
Implementability - Both alternatives are technically feasible
using technologies that have demonstrated performance records.
Although the POTW facility already exists, a transfer pipeline
would have to be built and the existing sewer line enlarged.
The on-site facility does not now exist. The two alternatives
appear to be technically equal for this criterion. However, the
City of Jacksonville has expressed concerns regarding rather or
not the city would be assuming liability by accepting discharge
from the Hipps Road Landfill. In addition, city officials were
concerned that the treatment plant (POTW) might violate its
NPDES permit. Therefore, the air stripping treatment and
disposal on-site is administratively more feasible than
treatment and disposal at. the POTW.
-13-
-------
~ - Because of escalating POTW costs, the remedy selected in
the ROD cou~d now C08t $3.9 to $4.4 million. The on-site
treatment option is currently estimated at $1.2 million
(February, 1990) aDd is, therefore, the less expensive
alternative.
State AcceDtance - ~e State of Florida concurs with the on-site
treatment alternative.
Community AcceDtance - Some members of the community have been
quite vocal in criticizing the on-site air stripping remedy.
They cite a history of exposure to contaminants from the
landfill and of governmental inaction. Many of the citizens at
the public meeting were willing to accept on-site air stripping,
but they asked that off-gas control be evaluated. In response
to these concerns, the Agency conducted screening air modeling
for the contaminants of concern. The results predict exposure
well below even very conservative criteria (see p. 18 of this
document). Another condition for citizen acceptance concerned a
cost analysis for a filtration system to eliminate emitting any
contaminants into the air. Using activated carbon to control
very low levels of vinyl chloride is problematic. There is not
much experience in using it for such low levels and its
performance is questionable. The is a broad range of
uncertainty as to the size of ~he system required. Estimates
obtained from various vendors in August, 1990 ranged from
$40,000.00 to $250,000.00. The Agency believes that the remedy
is protective as described.
7.0
SBLBCTBD REDDY
Based upon consideration of the requirements of CERCLA, the
detailed analysis of both alternatives, and public comments, EPA
has determined that Alternative 1 is the most appropriate remedy
for the contaminated ground water at the Hipps Road Landfill
Site in Jacksonville, Florida.
The selected remedy includes implementation of a ground-water
recovery system designed to recover the existing plume of
contaminants. The contaminated ground water will be passed
through a counter current air column which will enhance the
exchange of ozqanics from the aqueous stream to the effluent air
stream. A hiVh degree of water detoxification is possible. The
clean water would be discharged to the on-site stor.mwater
retention basin for disposal~ This alternative is not expected
to emit organic vapors in levels which would cause environmental
or public health concerns due to low contaminant levels and
rapid dispersion.
-14-
-------
7.1
Desian of Selected Remedv
o Recoverv Well Network -The Remedial.Design consists of a
. system of five wells pumping at 36 gpm eac~ installed to
capture the zone of contaminated water. ,The wells would be
spaced along the down-gradient boundary of the contaminant
zone with a well at the center and each of the other wells
spaced 260 feet apart. Five (5) wells were selected in
order to provide a margin of flexibility for increasing
pumping rates and for selectively pumping at different
portions of the zone of contamination as other portions
begin to clean up. The recovery well locations are
presented in Figure 3.
o Recoverv System Monitorina - The area being affected by
the recovery system will be monitored by determining water
levels inside and outside of the capture zone to evaluate
the hydraulic performance of the system. During system
start-up these levels will be measured frequently to assess
system performance. Later, water levels will be measured on
a quarterly basis in the recovery wells and a system of
water level monitoring wells will be installed to monitor
the recovery well system. ~his will ensure that the
recovery system is recove~ing water from the proper area
within the aquifer.
o Off-Site Monitorina System - The off-site monitoring
system will consist of monitoring wells located in the
vicinity of the off-site ground-water recovery operation.
The system will consist of five (5) of the TMW-series
wells. The well depths for this monitoring system are of
the intermediate depth (60-75 ft.) in the aquifer - the same
zone where the contaminated ground water is located. The
location for these wells is depicted in Figure 4.
During the off-site ground-water recovery operation, these
wells will be sampled quarterly for volatile organic
compounds and for metals. The system goal is to meet the
remediation goals (listed in Table 1) in the wells,
indicating that the plume has been recovered.
o Recovered Ground-water Treatment - Recovered ground water
will be routed via a pipeline to the closed landfill site.
Volatile orqanic contaminants (VOCS) will be removed by air
strippinq on the site. The system desiqn consists of two
"air stripping towers (36-inch diameter, 14 feet high) rated
at 100 gpm of water each and capable of removing the
volatile concentrations to below KCLs. Metals
. concentrations in the water discharged to the stormwater
retention basin will meet MCLs. .
-15-
-------
- -
---- - -.-
-.-- ----
.' --:;.....0--""'''...
--- .
LEGEND
BOUNDARY OF POTENTIAL OFF-SITE
GROUNDWATER CONTAMINATION. '
BOUNDARY DEFINEO BY THOSE WELLS WHICH
DID NOT HAVE CHEMICALS DETECTED ABOVE
MAXIMUM CONTAMINANT LEVEL (MCL).
(CHEMICALS ONLY DETECTED IN LOWER PORTION
OF THE SAND AQUIFER).
r-...
...-1'
I
.--.!'
-.
~~ ;
~' '
-----
\
,
.,:1
',I
'\
I'
'!
.II,
~
.
PROPOSED RECOVERY WELL LOCATIONS
PROPOSED PIEZOMETER LOCATIONS
o
~
PROPOSED ADDITIONAL TEMPORARY
MONITORING WELLS
1
I~ ,..~.'O
. '.
~,
ii,
I:
II;
i;
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.;
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- -
"
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, '
-------
, ~
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l )
-.----...-----
.. .. ...... ,.."...,..
+>+",'-- -~-_. -
c.";t
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-
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-
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...
~-_._-_._----
-'
,... I.
1_-8
1...-8 .e ,....,
----
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....-1
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.
t
il
II
---.---------....
LEGEND
N'
.~
,..
.=-.. ,... I'
0'
. "
J
--- .--...
.... ".'''.DuI. ...~.
Mll"..VI ,., 0 ,.U~.IIOII u, &A t..,
''''E.'8H.'I" '..8.u )UAllUW ..al. ~
- -.- .......... ."'.'"''''''
WA:.II. """""'1
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'IN'f", 'h"'I". I "'''''11'
MON.,OHIN<. Wt II
i OCA liON .'1 AN
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.......
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Fiq.
-------
o Ground-water, Recoverv and Treatment System Air Impacts -
In order to better define the air impacts associated with
the operation of the ground-water recovery and treatment
system, a detailed 'analysis of the system was conducted.
The analy8is assumed that the recovery effprt was divided
into three t~e intervals. Each interval would last roughly
six months and would approximate the time required to
recover one-third of the volume of the plume (one-third of
the pore volume). Using the information from the capture
zone analysis prepared as part of the system design, average
concentrations for specific contaminants were calculated for
each time interval. Using these concentrations, the flow
rate through the strippers, and assuming continuous
operation, the pounds/day released into the air was
calculated for each contaminant. The total emission rate
per day was calculated for comparison with the guidelines
presented in the EPA guidance document titled Control of Air
Emissions from Superfund Air Strippers at Superfund
Groundwater Sites (OSWER Directive 9355.0-28). This
guidance document says that control of air emissions from
Superfund air strippers should be considered when the actual
emission rate exceeds 15 t/day and the release is in an
ozone non-attainment area. (The Hipps Road Landfill Site is
located in a non-attainmen~ area.) The emission rate from
, this air stripping system is calculated to range from 0.013
t/day during interval one~to a system maximum of 0.048 ./day
in interval two. It drops off to 0.04 '/day in interval
three. Monitoring during operation will confirm the actual
emission rate. Clearly the emission rate anticipated from
the air stripping system is much below the criteria for
considering controls established for the Superfund Program.
An air pollution model was then used to predict the
concentration at the nearest residence. Certain
conservative assumptions were used for the air model - the
wind was assumed to blow the contaminants toward the
residence 100% of the time and meteorological conditions
contributed only minimally to dispersion. The resulting
concentrations were compared with the guidelines provided in
the Florida Department of Environmental Regulation
interoffice memorandum titled Final Air Stripper Review
Procedure8' October 20. 1987. Finally, the concentrations
at the neare8t residence were compared to those
concentrations that might be expected to contribute one
excess cancer in a population of 1,000,000 individuals if
they were all exposed to, this concentration continuously for
a period of 70 years. As a result of this analysis, the
predicted concentrations of contaminants at the nearest
residence to the Hipps Road Landfill are well below both
FDER standards for acceptable allowable concentrations and
EPA guidelines for ca~cer risk associated with exposure (to
contaminants) for a 'lifetime. '
-~o-
-------
o Treated Water DisDosal - ~reated water will be discharged
to the ator.m water retention basin on site and will recharge
the aquifer. An analysis of the effects of this discharge
on area ground-water flow characteristics shows that the
effect is minimal. . . .
o Near-Site Monitorina Well System - A ground-water
monitoring system will be established at the Hipps Road
Landfill site to provide an early warning system for the
release of contaminants from the landfill. If site related
contaminants are detected by this system, the ground-water
recovery operation will be initiated or continued. This
system will be monitored for 20 years. The appropriate
monitoring well locations are shown in Figure 5.
7.2
Cost Estimate
The ground-water recovery and disposal system has
down into four components: recovery system costs,
treatment and disposal system costs, ground-water
costs, and inspection and maintenance costs.
been broken
on-site
monitoring
The recovery ~ystem cost is estimated to be $88,000. The
on-site treatment and disposa+ costs would be approximately
$76,600. The ground-water monitoring system cost is estimated
to be $499,500. These estimates are calculated at present worth
for 5 years at 5% interest. The inspection and maintenance
(I&M) program will include routine weekly inspections, a yearly
monitoring and performance report, and a major capital
replacement contingency. The I & M program is estimated at
$370,600. The total remedial action cost is $1,242,000.
. ~
7.3
Operation" Maintenance
Ground-water Recove~
The ground-water recovery and disposal system will be monitored
weekly for the first month after the initial phase or start-up,
monthly for the first quarter and quarterly thereafter. This
applies to both the water level monitoring and the off-site
monitoring well systems. The operational life for the project
has been assU88d to be approximately five years.
Institutional Controls
The amended ground-water remedy will not require any
institutional controls beyond those envisioned in the 1986 ROD.
.... I '-: .".,
-------
N
Y- ZONE Of OfF-aRE OROUNOWATER
"CONTAMltATION (BEE FIOURE '4)
D
YW-B
TYW-I- --
. II (:()N T nOL OF FLORIDA. INC.
1111 'liS reOAD LANDFILL
o
Golder Asaocla'..
AII.nl..G..,.'.
"
"
D TYW-7
o
.. .1
."1' "I..
,. '''1
Ita \lit WUI
IJAlt
5CA& 1
AS SHOWN
"NO 883-3801
6/21/90
~
~
A.
'"
SCALE IN fEE T
200
400
IIIU
DOWN-GRADIENT WELL.
SPACING DIAGRAM
'.1 toO
"w.. HLI' lot II ..0
39
'10011" 5
8d3-3291
-------
8.0
STATU"J."ORY RBOtnRmm1n'S
The U.S. SPA and PDER believe that this remedy will satisfy the
statutory requirements of providing protection-of human health
and the environment, attaining applicable or ~elevant and
appropriate requirements of other environmental statutes, will
be cost-effective and will utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies to the max~um extent practicable. Sections 8.1
through 8.5 below are the statutory requirements for this site.
8.1
Protection of Human Health and the Environment
The selected remedy provides protection of the public health and
environment through extraction and treatment of contaminated
ground water.
Attainment of the ADolicable or Relevant and ADorooriate
Reauirements (ARARs)
Remedial actions performed under CERCLA must comply with all
applicable or relevant and appropriate requirements (ARARs).
All alternatives considered for the Hipps Road site were
evaluated on the basis of the degree to which they complied with
these requirements. The selected remedy was found to meet or
exceed the following ARARs, as discussed below.
8.2
Clean Water Act/Safe Drinkina Water Act
EPA's determination of appropriate ground-water cleanup criteria
involves an evaluation of contaminant concentrations relative to
available health-based standards. Maximum Concentration Limits
(HCLs) and Maximum Concentration Limit Goals (HCLGs) of the Safe
Drinking Water Act (SDWA) (40 CFR Part 141 and 142) ,and Federal
Ambient Water Quality Criteria (AWQC) of the Clean Water Act
(CWA) (40 CFR 122.44) will be met at this site.
Pederal Clean Ai? Act
The objective of the Clean Air Act (CAA) is to protect and
enhance the quality of the nation's air resources in order to
..promote and maintain public health and welfare and the
productive capacity of the population. The CAA achieves this
. objective by regulating emissions into the air. Pursuant to the
CAA, EPA has promulgated National Ambient Air Quality
. Standards. The CAA is an ARAR and the regulatory standards of
the CAA will be complied, with during implementation of the
remedy. .
-21-
-------
Bndanaered Soecies Act
The selected remedy is protective of species listed as
endange~ed or threatened under the Endangered Species Act.
Requirements of the Interagency Section 7 Consultation Process,
50 CFR Part 402, will be met. The Department of Interior, Fish
and Wildlife Service, will be consulted during remedial design
to assure that endangered or threatened species are not
adversely impacted by implementatio;n of this remedy. There is
currently no information to indicate that the Site is visited
by, or contains any endangered or threatened species.
Rational Historical Preservation Act (HHPA)
The NHPA requires that action be taken to preserve or recover
historical or archaeological items of importance which might be
destroyed as a result of site activities. There is no
information to indicate that the Hipps Road site contains any
items of historical or archaeological significance.
Pederal Occuoational Safety and Health arlmi~istration
Act (OSHA)
The selected remedial action contractor will develop and
implement a health and safety program for its workers. All
on-site workers will meet the minimum training and medical
monitoring requirements outlined in 40 CFR 1910.
State Reaulations:
Florida Administrative Code ChaDter 17-3
Water quality standards for surface water and ~round water
affected by leachate and storm runoff from the-site will be met.
Florida Air and Water Pollution Control Act
This act makes it public policy to achieve and maintain such
levels of air quality to be protective of human health and
safety and, to the greatest degree practicable, prevent injury
to plant and animal life and property. The Florida Air and
Water Pollution Control Act (Chapter 403 F.S.) is an ARAR and
the regulatory standards of the Act will be complied with during
implementatioB of the remedy.
8.3
Cost Effectiveness
Because of escalating POTW costs, the remedy selected in
September 1986 ROD could now cost $3.9 to $4.4 million.
on-site-treatment option is currently estimated at $1.2
(February, 1990) and includes operation and maintenance.
the
The
million
-22-.
-------
8.4
Ut~l~.at~oD of'Pe~ent Solutions and Alternative
-~ftt Technoloov or Resource Recoverv Technoloaies
to ~h8 ..~i~Bxtent Practicable
u.S. EPA believes the selected remedy is the most appropriate
cleanup solution for the Hipps Road site and provides the best
balance among the evaluation criteria for the remedial
alternatives evaluated. This remedy provides effective
protection in both the short- and long-term to potential human
and environmental receptors, is readily implemented, and is cost
effective.
Extraction, Air Stripping and Disposal of the contaminated
ground water represents a permanent solution (through treatment)
which will effectively reduce and/or eliminate mobility of
hazardous wastes and hazardous substances into the environment.
8.5
Preference for Treatment as a PrinciDal Blement
Treatment of the contaminants will effectively prevent them from
posing a threat through direct contact or by leaching to ground
water.
"
~
-23-
-------
APPENDIX A
RECORD OF D~CISION, SEPTEMBER 1986
..
-------
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
. SITE
..po
...~---
Hipps Road Landfill
Jacksonville, Duval County, Florida
r:x:x:uMENTS REVIEWED
I am basing my decision primarily on the following documents describing
site specific conditions and the analysis of effectiveness and cost of
the remedial alternatives for the Hipps Road Landfill Site:
- Hipps Road Landfill Remedial Investigation Report,
- Hipps Road Landfill Feasibility Study,
- Sl1tI11aryof Remedial Alternative Selection,
- Hipps Road Landfill Public Health Evaluation,
- Agency for tOxic Substances and Disease Registry - Health
Assessment: .Hipps Road LanPfill,
- Department of the Interio~ - Release fran Claims for D!mages
to ...he Natural Resources Under 001 Trusteeship.
DESCRIPl'ION OF 'mE SELECTED ~
- Proper landfill closure under Subtitle D of RCRA and Chapter 17-7
of the Florida Administrative COde.
-I
- Recovery of contaminated ground water with treatment at the Local Publicly
rks (POIW). COntaminants will be recovered until the
ground water quality is in canpliance with the staooards set forth under
the Safe Drinking Water Act t SIJIlA) . Contaminants not addressed lnder
the SD'lA will be removed until canpliance with the 1980 Water Quality
Criteria Hunan 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.
- '!he gro\ft1 water re
-------
- fencing the site,
- grouting existing private wells,
- instituting a well drilling ban which can be lifted at the
conclusiCjp. of the 20 ~ar monitoring period, and
- acqu1?!?ig affected properties under the policies and practices
established by the Federal E)net"C4ency Management ~ency (FEMA).
- q:>eration and maintenance (O&M) activities will inchde:
- operating and maintaining the ground water recovery system,
- ground water nonitoring,
- maintaining the landfill cap and associated systems,
- maintaining the connector sewer lines which access mains to
the PO'IW,
- maintaining the site security systems.
Additional O&M activities may be identified during the Remedial Design.
Dex:~TlOOS
Consistent with the Carc;>rehensive 'Environmental Response, COtp!nsation,
and Liability Act of 1980 (CERCIA), and the National Contingency Plan (40
CFR, Part 300), I have determined that the above Description of Selected
Ramedy for the Hipps !bad Landfill Site is a cost-effective remedy and
provides adequate protection of public health, welfare, and the environment.
The State of Florida has been consulted and agrees with the approved
remedy. These activities will be considered part of the approved action
and eligible for Trust Fund monies until groU'1d water clean up levels are
attained or for a 10 }ear period, whichever occurs Hrst. '!he basic
assumption is that the responsible parties fail to undertake the design
and implementation of the selected remedy. If clean up levels are not
reached within the 10 ~r period, the Remedial Design and Remedial
Action will be re-evaluated.
I have also determined that the action being taken is appropriate when
balanced against the availability of Trust Fund monies for use at other
sites. In addition, the selected remedy is nore oost1ffective than
other remedial actions, and is necessary to protect p\blic health, welfare
or the environaent. All off-site disposal shall be in ccmpliance with
the existing policies of EPA.
If additialAl remedial actions are determined to be necessary, a Record
of Decision will be prepared for approval of the future remedial action.
1/3 1ft,
Date
~a:M.~1 r,4
Jack ~.. Ravan
Regional Administrator .
-------
SECfION I
SITE LOCATION AND DESCRIPI'ION
The Hipps ~ Landfill is located on the southeaste~n co~ne~ at the
inte~section of iiPPs Road and 8xline Road in JacKsonville ~iahts, Duval
r.ounty, norma-( Fiaure l). The area is a semi-rural ~es idential neiC1hbo~-
hood. Two homes are ohysically on the landfill and three other ~esidences
a~e Unmerliately arl;acent to the landf.ill.
The landfill has ~elatively low topog~aphic relief and is spa~sely covered
with arasses, brush, and pine t~ees. Fill material extends to a depth of
approxifotately 25 f.eet, and deb::-is is scattered across the surface. DJe to
decradation of the fill material and resultant subsidence, many of the
disposal cells can be visually identified. There are no ecoloqically
sensitive areas near the Hipps Road Landfill, and it is situated above the
SOD-year floodplain. Surface water is not used as a drinkirY;1 water supply
in the area, and recreat ional f"urooses consist of swirrming, boatirq, fishing,
and sUnilar activities.
Until ::-eoently, the area ::-esidents ::-elied 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 h~ not elected to hook-
up to the city water supply were connected during 1985 under an EPA arergency
respOnse act ion. "
-------
~-:--
~
0,0
DUVAL
COU"'.
Figure 1.
Site location map. Hipps Ibad
Landfill, Jacksonville, Duval
Comty, Florida.
I
Hipps
.>
...
Marlee Road
Unnamed Tributary
Road
UcHiPPS Road
Landh 11
Taylor field Road
\
L
GI
~
Q:
I
.~
~.
N
"0
IQ
o
IX
L
GI
.-
"0
C
....
oJ:
V)
O'
.
1000'
t
-------
R . Residence
o ~ Outbuildi::g
J' 1 "f"
"'.;
I I
scale
N
1
-tit
-...
~l
HIrps ROAD
o
~
@
SH-IO
8
BH-1S
"
Q
< 8SH-17
c
Co; BH-6 8 SH-138
ra (]J 8SH-5
z
1-1
... \8-25
><
~
SH-21 ~ SH-2
8
5J 8BH-27
8
SH-24
8 BH-8
.BH-4
SH-268
8BH-3
approximate ./
landfill boundry
8
BH-29
Pigure 2.
Qusi te Soil Scmpling IDeations Used DJrinq the
Hipps Pcad Landfill Field Investigation.
-------
ble 1. Contaminants Identified in C\1sit~ Soil Samples.
Milligrams Per Kilogram (~/kg). .
. .
Concentration is in
88-2 BH-3 BH-4 BH-5 BH-6 BH-7 BH-8 BH-10! BH-13
PCB (Aroclor 1260) - I :
Methyl Ethyl -- _. I ;
Ketone !
Ethyl Benzene I
Toluene ( .64) ( .16) ( 1.6) (.48) (1.1) I
Di-N-Octylphthalate I
Benzyl Butyl T
Phthalate
1,4-Dichloroben:ene i
2-Methyl Napthelene
Di-N- !
butylphthalate I
Bis (2-ethylhexyl) I
Phthalate .096 I
Napthalene I
Benzene I
Tnzers
xylene
- Disulfide
Aninun
I I I' I I 47D I I 115X I
l
Arsenic (.04) I
Caani un (1.2) !
Chraniun ( .8) ( .9) .> I
Copper (1.0) ,
I I I I j:: I I 13.6 I
I I 111.8) I (.8) I (.7) I I I
IO'02)~
Iron
Lead
Manganese
Mercury
Nickel
Sodi un
Zinc
-I 3.2
r = data re jected ~r OA/rx
x = estUnated value
() = local lab data
-------
Table 1 (cant.).
Contaminants !dentified in Onsite Soil Sarn~les.
is in Milligrams Per Kilcgram (lTg/kg).
Concentrat Lon
BH-15 BH-17 BH- 21 BH-24 BH-2S BH-26 BH-27 BH-29
PCB (Aroclor 1260)
Methyl Ethyl -- ~:~ -
Ketone .003
Ethyl Benzene .011 .03 ( 1. S9)
Toluene 1.48 ( .26) ( 1. 23) (.20)
Di-N-Octy1phthalate .043x
Benzyl Butyl
Phthalate 4.3
1,4-Dichlorobenzene .14x
2-Methvl Nacthelene .058 .55
Dl-~
butylphthalate .19x
Bis (2-ethylhexyl)
Phthalate 330x 1.4
NaPthalene .093x .45
Benzene .004 .004 .005
C'\lorobenzene .052 ' .02 .11
Xylene " .32
',rOOn Dlsulflde .001
. unimm 1700 3400 8600x 1900 6300x
Arsen~c
cadmi un
C'\ranll.m
Co~per
I I I ., .I I (1.2) I (1.9) ~
1(.61
Iron 420 500x 740x 1l00x
Lead (1.3) 12x 6.3 18
Manaanese 8.7
Mercury .10
Nickel 14
Sod i un 2100x
Zinc (22) 33 (2.4) (2.8)
r = data re jected tnler OAIo::.
x = esttmated value
() = local lab data
-------
R . ~esidence
o ::0 Outbuildi~q
J'
-I
1,,"',
~J
I
scale
,~.-#
~
1
~l
HIrps ROAD
o
GJ
@
88-10
.
BH-1S
" . BH-8
Q
II( .88-17
c 88-13.
c: BH-6 .
~ aJ .BH-S
z
....
oJ \a-25
)C
~
BH-21
.BH-27
~ BH-2:
.88-2
.811-4
BH-26.
.BH-3
approximate /
landfill boundry
.
BH-29
Pigure 3.
Q,site Ground Water Salq?linq IDeations Used During the
Hipps !bad Landfill Field Investigation.
. -
-------
SEC!ION II
SITE HI5roR'i
~
Initially, "t!'Mr"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 ~rmission to extend the landfill eastward.
The request was denied and operations ceased in 1970.
At that time, the landfill was covered by a thin la~r of soil and divided
into lots. 'these lots are currently owned by Mr. and Mrs. Donald W:mman
(9084 Hipps Road), Mr. Henry Vorpe (9110 Hipps Road), Mrs. W. H. Gore (9032
Hipps Road), and Mr. A. ~lan (7145 Exline ~ \ .
1\«) parties have been identified as Potentially Responsible Parties. 'the
first is a hauling ccmpany that lI'\dertook the laOOfilling 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 N:wember 18, 1985.
Materials recovered fran 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. 'l1'e materials incl\.rle cans of
trichloroethene (which have Navy serial n\.lti)ers and ~identification), practice
artillery rounds, microfilm of military equipnent designs, and military
training manuals. Anecdotal information fran retired emplo~s of Waste
Control of Florida, Inc. indicates that material fran the Naval facilities
was hauled to the Hipps Road Landf ill by WaSte Control of Florida. 'the
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 suspeOOed.
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 Al and
Gail Speicher (9040 Hipps Road), developed a thick, smelly film and fish
and nearby 'Mgetation died.
In February 1983, residents in the area began to ccmplain of a foul odor
and taste in the drinking water. At tt\at time, the City of JacksOnville
sampled private wells and found vinyl chloride and methylene chloride to be
present. A re-sampling was conducted in March 1983 to verify contamination
and toluene, vinyl chloride, and methl~ne chloride were found. A third
sampling. was conducted in' March/April 1983 by the Department of Health and
Rehabilitative Ser;vices. A much larger suite of volatile organic ~lI'\ds
were found: benzene, ethylbenzene, tsl".. -.- ,-:.-. -~- ~t:.nylpnenoi,. - ~
-------
o-c~loheX8n8, dichlorobenzene, methylene chloride, dichloroethane,
. t.richloroethene, vinyl chloride', dichloroethylene, 2-butanone, and 4~thyl-
2-pentanone.
....
--
rlt that tUne, the City of Jacksonville began to provide residents with
emergency bottled water. ay 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 Envir~ntal
Regulation, the St. Johns Water Management District, the U. S. Geological
Survey, Jacksonville Bio-Envirorurental Services Division, and the Duval
County Public Health Division was canpleted. The stLdy 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,
trichloroethene, tetrachloroethylene, 2-butanone, tetrahyrofuran,
mercury, lead, zinc.
In August 1:983, the Hipps Road Landfill was proposed for inclusion on
the National Priorities List w~th 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 using ground water"supplies to the City
water supply. This response action was canpleted in September 1985.
After finalization of the Hipps Road Landfill Wbrk Plan in April 1985, the
Remedial Investigation field investigation was initiated. The Remedial
Investigation Report was finalized in February 1986, and the Feasibility
StLdy was released for public ccmnent in April 1986. A public meeting was
held in Jacksonville, Florida, on May 7, 1986.
-------
SECTIQN III
CL'RPENT S rTE STATUS
ONS ITE SO ItS
. ...
Soil samDles~ collected fraM 17 locations within the landfill (Fiaure
2). The identified contcrninants Ioere not found to be p!:vasive due to the
heteroaeneous nature of the landfill. the base of the landfill was'
identifierl to be 24 to 26 feet ~low the surface.
The contaminants found include nickel, zinc, aluminum, mercury, lead,
sodium, benzene, chlorobenzene, ethyl benzene, xylene, carbon disulfide,
methyl ethyl ketone, rli-n-octylDhtha1ate, 1,4-dichlorobenzene, 2-methy1
napthalene, di-n-butylphthalate, bis (2 ethylhexyl) phthalate, and
narthalene (Table 1). However, the risk assessment found that none of
these compounds were present in concentrations of toxicological concern
( FS, n . 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 jX)nd
adjacent to the landfill.
Soils in the landfill are JX)Orly ~nsolirlated and sandy in nature. Al thouqh
the landfill was never capped, it was covered with a thin discontinuous
layer of sand at the time operations ceased.
SURFACE ~TER AND SEDIMEm'S
The rend, which 1 ies alorQ the eastern border of the landfill, is recharged
by rainfall and ground water, and discharge is by lateral movement into the
surficial aauifer. Sediment ard water samples collected fran this pond
indicate that it has not been contaminated b~ 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 f1owi~ fran the site. Samples from
the stream water and sediments indicate that there is no contamination
which can be attributed to the landfill (RI, p. 5-7).
HYDRCX;ror..cx;y
Ground Water Characteristics. At the Hi~s ~d Landfill site ground water
contaminants are present 1n the Surficial Aquifer System. !he surficial
aauifer is comprised of three zones: the water table zone, the S8'1i-confinino
unit, ard the I imestone unit. D.Jri~ the Remedial Investigation it was
established that contaminaot.s had invaded both waterbeari~ units. Ground
water level elevation measurements from wells in the vicinity of the site
indicate that the qround water under the landfill has a st~!' 3;:'~'"'; ~=~l
downward component of fl~, based on tri-level rneasuremem:s. "'''-" -
water lJenerally flows to the no!:'theast and east. As the qround water
approaches the unnamed tributaLY, it exhibits an upward vertical component,
and may ult~ately discharoe into the unnamed tributary.
-------
Ground water Contaminants. Seve~31 .contaminants we~e found in g~ound wate~
collected fran on site bo~e holes. ())site ground water semple collectlon .
locations "are" shown in Figure 3. The contaminants found are listed in
table 2.
A la~er su!te 06Pc0ntaminants was found downgradi~nt f~am the site.
Samples Yoere-oorlected fram three types of IoElls: existina
-------
Table 2 (cont.). Contamihants Identified in Ground Water Samples f~ Onsite
. ~re Holes. Concentration in Micrograms Per Liter (ug/l).
BH-15 BH-17 BH-2l BH-24 BH-25 BH-26 BH-27 BH-29 i
PCB (Aroclor l24Z) 4.6 36x r
PCB (Aroclor 1254.l, ... 1.8 I
PCB (Aroclor 1260) 38x r
Benzene 14 ' 7.9 8.4 (101) I
Toluene 49 38 ( 23.9) i
Carbon Dlsulflde 18 4.8 5.4 13 I
O1lorobenzene 110 19 37 (237) I
Ethyl Benzene 7.7 6.2x (171) I
1,2-Dichlorobenzene ( 39 . 3 )
1,4-Dichlorobenzene 3.4x 3.2x
Xylene 13 220 120
Methylphenol 5.7x 4
MethYl Napthelene 3 2.6x
N-Nitro-
sodiphenylamine 9.6
Napthalene 16x 1.3
Bis (2-ethylhexyl) "
phthalate 96 29
rt1enol 34 !
All.II\ln 1.11\ 1,000,000 31,000 15,000 690000x 650000x !
Arsenic 220 ( 5) ,
Baril.ll\ 540 1200x 3900 I
Berylliun . 19 '. (10)
Cadrni un (60)8.4 l400x (7) (50) (50)
Calcil.ll\ 40,000 24,00Ox 2700x 2800x 54,00Ox
Chrani 1.11\ (50)100 1000x llOOx (10) (20) ( 20)
Cobalt 42
Copper (50) 220 1200x
Cyanide 310
Iron 54,000 83,00Ox 1400x 200000x 280000x
U!ad (150)40 100 34,000 5300x
Magnesil.ll\ 18,000 2500x l200x 6900x 5700x
ManJanese 300 lOOOx l400x
Mercury .l8x 18
Nickel (50)370 (30)
Potassiun 13 ,000 l400x 1800x 4800
Selenil.ll\ 27
Sodil.m 30~000 '5200x 1600x 76,00Ox
vanadil.ll\
"inc
1100
( 860>1400
(30j-T '
r = data rejected under OAIOC
x = estLmated value
() = local lab data
-------
Table 2.
Contaninant9 Identified in Ground Water Samples fran Chsite Bore Holes.
Concentr~tion in Micrograms Per Liter (I.Q/l).
88-2 BH-3 BH-4 BH-5 BH-6 BH-7 BH-8 BH-10 I aH-13
PCB (Aroclor 1242) !
PCB (Aroc lor 125.u...., _.~ 1
PCB (Aroclor 1260)
(5.8) (7.3)
Benzene (27) <18.3) ( 20.5) ( 408) 5.2 2.5x 3'-3
(4.9)
Toluene (2.1) ( 10.8) (5.4) 3.8x (2.1)
Carbon Disulfide
C\lorobenzene ( 105) (89.7) (45.3) (397) (68.7)65 (66.4)26 (5.2) (~. S)
Ethyl Benzene (98.5) (5.3) (162) ( 24.9 ) (20 . 4 )l 7 ( 85.3) I (5. C ~
1,2-Dichlorobenzene (22) ( 18.9) ( 18 .4) ( 21. 6) (-::.3)
1,4-Dichlorobenzene llx
Xylene 38 3.3x
Methvlphenol
Methyl Napthelene
N-N1tro-
sodiDhenvlamine " 17x
Napthalene llx
.1i9 (2-ethy1hexyl)
) phthalate
Phenol
AllJt\i n\.ll1 28,000 180,00Ox 12,000
Arsenic (60) (40) (20) (88)8~ (40) 140
BarilJt\
Beryll1lJt\
Cadmi lJt\ (10) (8). (12)12
Calc i \.111 3400 10,00Ox 14,00Ox
C\rani lJt\ (30) (40) (40) (50)50 (60)
Cobalt
Copper (20)
Cyanide
Iron 44,000 42,00Ox 4400x
Lead (12)12 ( 30) 26
Maaries 1\.111 8100 13 ,000x
Ma~anese 490
Mercury 1.6
Nickel ( 26) 26 (50) (10) (30)
PotaSS1lJt\ 10,000
SelenllJn .
.:::od i lJt\ 6600 6500x <-
~anad i lJt\
Zinc
( 20)
r = data rejected under OA/\f;
x = esttmated ~alue
() = local lab data
-------
"'arl ee Road
\
. .
Unnamed iributary
/
~
~
~
\ .
I
c:t:
. EMW-8 N
~
Ef-n.[ - 7 . ItS
.EMW-2 Q
=:
Hipps Road .EMW-3
.
D~H;PPS Road So.
EMW-S. Landfi 11 Go!
.-
~
., =
--
~
. n'W -1 II')
Taylor Field Road
->
0'
FigaN 4. Iocatia"1 of Existing M:mitoring Wells C.USGSl
Used During the RI Field Investigatia"1.
1000'
,
-------
f !
.~ ~1arl ee Road.
'\
\
Unnamed Tributary
/
PW-21
.
.PW-15
" PW-8
PW -17 .
Taylor F
. PW-22
~
,! . PW-23
"0
c:
-
~
'"
N
Figure 5. Private Wells Sanpled CUring the RI Field
Investigation
0'
1000'
l
-------
\
Unnamed
:ributary
iL
I
I
I
: . r1W-f,
--
\ .
... I
I.~ I
I'" I
-<~~ i
'1
!
~'a r 1 ee Road
\
I
N
~
IG
~1\o1-F 0
cz::
Hipps Road
8 .--~1W-E
~J\.l-C 8 D~HiPPS Road
~
8MW-B. Landf; 11 ~
-
"r-1W-D ~
=
t-1W-A. .-
.=
VI
iaylor Field Road
~
0'
I
10?O'
Fiquaa 6. Uxation of New M::nU.toring Wells Installed and
Sarrpled During the RI Field Investigation.
-------
Table 3.
Ground W$ter Contaminants Identified Existing (USGS) Monitoring wells.
Concentratioo in Micr~rams Per titer (u;;/l).
EMW-l EM\+- 2 EMW- 3
.-- ~-""'iO' 40' 10' 55' 80' 10' 60' 80' T
Tol uene 64(68) I
Carbon Disulfide 8.9 6.0
O\lorobenzene 4.7 (4) I
Tetrah'tdrofuran llx
Methyl Isobutyl
Ketone 22
Methyl Ethyl Ketone 9.7
Total Xylenes 52 93
Trans l, 2-
Dichloroethane 27 24(33)
Ethyl Benzene 24 31(68)
Vinyl Chlonde 28 31(73)
Benzene 4.0x 3.8x(8)
l,l-Dlchloroethane 5.3(8)
Trichloroethane ( 2)
~hyl Ether 4.Ox 7x
~etone 3 380 190 800 I
1 40x I
N-Nitrosodiphenyl- I
aminel I
Diphenylamine 14 I
-,
2,4-D~thYlphenol 13x r
2-MethYlchenol 46 20 26 I
Methylcentanedlol 20x 20x I
C-3 AlkYlbenzene lOx lOx
OXy Bis Ethoxvthane SOx lOOx
Methylnonanediol 70x
c-s AlkYlbenzanude lOx I
C-4 AlkYlbenzene 20x I
EthylhezanolC Acid 40x !
Tr~thylbiC~lo-
heotanone 70x
Nepthalene 9x 20 '.
Phenol 13x :
r = data re jected under OAIOC
x = est~te(~' .
') = local lab data
-------
Table 3 (cont.).. Gro\D1 Water Contaminants Identified in Existing (USGS)
M2titoring Wells. Concentration in Micrograms Per Liter (ug/l).
-
-- ..... - E*-1 EMW- 2 EMW- 3 :
I
10' 40' 10' 55' 80' 10' 60' 80' I
AI LmlnLm 5500x 530x 19,000 4500 730 14,000 1100 1200 i
Arsenic 5.3 !
BariLm r r 57 60 110 I
Cadmi \.1ft r r
Calcl\.lft r r 15,000 2900 60,000 7700 3400 5200
Cirani \.In r r 35 15
Cabal 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
Magnes 1 \.1ft r r 1100 1800 13,000 4000 2000 62,000
Nickel r r "23 24
Potass i \.1ft 1700 1100 1200 1600 750 1500
Sod i \.In r 13 ,ooax 2200 51,000 5200 13,000 44,000 5000
Vanad i \.1ft
Zinc
42 I
r
r
r
r
64
54
68
150 I
61
-I
r = data rejected under Wr:1:.
x = est~ted value
() = local lab data
-------
Table 3 (cent.-). - Grolni Water Contaminants Ident if ied in Exist ing (USGS)
Monitoring wells. Concentration in ~icrograms Per Liter (ug/1).
.
EMW-4 ~5 EMW-6 ! EMW- i
10' 65' 30' 65' 16' 50' 10' I 50' :
Toluene 7.5 4.7x 41 I 4. 4x. .
Carbon Disulfide I 3.6x I I
Chlorobenzene I
...
Tetrah'ydrofuran I
Methyl Isobutyl ,
Ketone I
,
Methyl Ethyl Ketone 6.3x 5.lx 5.1 ;
Total Xylenes 23 23
Trans l, 2-
Dichloroethane 6x
Eth~l Benzene
Vin 1 O1loride
Benzene
~
f:
I
l,l-Dichloroethane I
Trlchloroethene
~th yl Ether
3x
32
"
Acetone I
Propanol I
N-Nitrosodiphenyl- i
aminel -I I
Diphenylamine l6x i
I I ~
I I ~
I I ~
II ~
I I II
I I I I
I I I I I
I I. I I .1
~~~~~~.""l I
Methyl ntanediol ..
g;;; ~~):=~~I
Methylnonanediol .
~:~ ~~~=~=:
Ethylhezanoic Ie
Trimethylbic~lo-
~:~:
Phenol
r = data rejected under QA/r;t:;
. = estimated value
,) = local lab data
-------
Table 3 (cent.).- GromdWater Contaminants Identified in Existing (USGS)
Monitori~ Wells. Concentration in Micrograms Per Liter (t.g/lJ.
--
'-" "'" 9M-4 ~5 - EMW-6 ~'7
10' 65' 30' 65' 16' 50' 10' i 50' T
Al t..mim.m 8500x 620x 9300x 980x 5400x 610x 2400x 560
Arsenic 18 13
Barit..m r r r r r r , r
Cadmi t..m
Cald t..m 6700x r r r 2l,00Ox 8400x r r
Chranit..m r r r r r r r r
Cobalt '
Coocer 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 T
Manaanese r r r r r r i
Maanesiun r r r r 660ax 2900X r r i
N1Ckel r r r r r r r
Potassiun 5600 5100 T
Sod i t..m r r 8200x 10,000 50, ooax 24,000x r 5600 1
Vanadiun
Zinc
28
r
r
r
r
r
r
r
r = data rejected under OAIOC
x = est~ted value
() = local lab data
~
-------
Table 3 (cont.).- Ground water COntaminants Identified in Existing (USGS)
Monitoring ~lls. Concentration in =-ticr~rams Per Liter (~/1).
..
--..-.. EMW-8
10' 50'
'IOluene
carbon Disulfide
Chlorobenzene
1'etrah'rdrofuran
Methyl Isobutyl
Ketone
Methvl EthYl Ketone
'IOtal XYlenes
Trans 1,2-
Dichloroethane
Ethyl Benzene
Vinyl QUonde
Benzene
1,1-D1Chloroethane -,
Trichloroethene
Ethyl Ether
-.
~
f
C-3 =- I
Ox~81S Ethox~
Me Y. 10
~ ~~~=~ I
Yo zancnc Ac1d
Trunethylbic~lo-
heDtanone
Nepthalene
Phenol -
r :: data rejected under OAI~
x = estLmated value
() = local lab data
-------
Table 3 (cont.>. Ground water Contaminants Identified in Existing (USGS)
. - Monitoring wells. Concentration in ~icrograms Per Liter- (ug/1).
... EM+-8
--,
10' I SO'
Ahrnlnl.l'l\ 7000 i r
Arsenic I
Baril.l'l\ r I r
Cadm~ 1.1'1\
Calcll.I'I\
O\rani 1.1'1\
3:00 I
< I
~3 I
': I
I
Cobalt
Copper
Iron
Lead
Ma~anese
Ma nes i 1.1'1\
Nickel
~tassil.Jn
Scx:U 1.In
Vanadi 1.In
Zinc
r
r = data rejected uroer QA/(;1;
x = estimated value
() = local lab data
f
f
f
5:00 f
~ t
r
r
r
r
r
r
3
r
r
~
-------
Table 4.
GroUnd ~ter Contaminants Identified in Private wells.
concentration in ~icrograrns Per Liter (~/1). .
t:W-4 ~5 1?W-6 t:W-7 I?W-B 1?W-9 1?W-10 I
Acetone 400 I
Brarodi- -~ I
chloranethane
Carbon Disulfide 4.1 I
1,2-Dichloroethane 5.2 I
I
Methyl Ethyl Ketone 300 I
Methylene Chloride 5700 i
'Ibluene 4.3 3.3 4.2 24 I
Bis (2-ethylhexyl) I
phthalate
Allminlm 200
Barilm
Cadmllm 21
CalCllm 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
MaaneSll.J'l\ 12,000 13 ,000 12,000 11 ,000 12,000 4400 8700
Manganese 33 40 28 34 25 34 31
N1Ckel 15 19 17 12 I
PotaSSll.J'l\ 5400 550 I
SOO i I.J'I\ 5000 5000 !
Tin
Zinc
700' I
8.8
100
41
113;~~0 I
68
120
r :II data rejected ur'O!r OAIOC
x = estimated value
() :II local lab data
-------
Table 4 (cent.). Ground Water Contaminants Identified ift Private Wells ~
Concentration in ~icrograms Per titer (~/l).
...
--
~ll EW-12 ~15 EW-16 ~17 EW-18 EW-19!
Acetone
Brarodi-
chloranethane 5.3
Carbon Disulfide
1,2-Dichloroethane !
Methyl E:thyl Ketone :
Methylene C1loride
Toluene 8.0 8.0 5.9 5.8
Bis (2-ethylhexyl)
phthalate
Ahrninun
Sari un 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
Maaneslun 14,000 16,000 9700 18,000 22,000 23,000 9500 I
Manaanese 4.4 41 29 6.9 56 42 23
Nickel 18 13 18 26 23 13
FbtaSSlun 1800 570 510 510 .. 810 630
Scx1 i un 5300 5900 12,000 6500 6300
Tin
Zinc
45
73
460 . I
710
2
37
53
t
r ~ data rejected under OAIOC
x = est~ted value
() = local lab data
-------
Table 4.(cont.).
Ground Water Contaminants Identified in Private ~lls.
Concentration in ~icrograms Per Liter (ug/l).
'-- PW-21 PW-22 PW-23 -
Acetone
Brcm::xH -
chloranethane
Carbon Disulfide
1,2-Dlchloroethane
....
Methvl Ethyl Ketone
Methvlene Chlorlde
1'01 \.ene 5.9
B1S (2-ethylhexyl)
phthalate 27
Ahmimm 250 250 280
Bariun 32 11 25
Cadmi un
CalClun 75,000 43,000 59,000
Coccer 11 4
Iron 720 180 60
Lead
Maanes 111'l\ 20,000 10,000 19,000
Manaanese 49 20 23
N1Ckel 23 12 21
FOtassiun
Sod i un 7200 6100 6400
-I
Tin
Zinc
16
27
I .280
t
r = data rejected under OAI~
x = estLmated value
() = local lab data
-------
Table 5.
Ground water COntaminants Identified in New (EPA) MQnitoring Wells.
Concentratioo in Micrograms Per Liter (~/l).
.-
'-'" -- Cluster A Cluster B Cluster C
~l ~2 ~13 ~7 MW-8 ~16 ~3 ~4
55' 80' 10' 55' 80' 10' ~S' . 80'
Toluene 3.2x
Carbon Disulfide 3.2x 5.6x 4.6x 4.lx
Chlorobenzene
Bromochloramethane
Braoo-
dichlor011ethane
C-5 Alkylbenzene
Sulfenamide 20x
C-6 Alkylphenol 20x
Aluni n un
Bariun
Cadrni un " 7900 4 5 4
Calciun 9800 7300 4800 44,000 2600 3500 68,000
hranl un 17 44 7 6
Cobalt 3
Copper 24 6 15 9 4 12 7
Iron 23,000 1300 700 460 140 730 920 230
.1
Lead 31 13 10 6 13 6
Manganese 40 79 96 55 25 99 83 40
Maqnesiun 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
110
100 I
6
26
44
21
50
36
~
Vanadiun
Zinc
35
r = data rejected t.l'der OAI~
x = estLmated value
() = local lab data
-------
Table 5 (cont.h .Gro\.nd Water Contaminants Identified in New (EPA) fobnitoring wells.
CaK»ntration in Micrograms Per Liter (LQ/1).
...".. -- Cluster D Cluster E Cluster F
MW-9 MW-1O MW-17 MW-ll ~l2 MW-1B MW-S MW-6 ' :-\''';'''1 ')
55' 80' 10' . 55' 80' 10' 55' BO' i 10'
Toluene 3.Ox I
Carbon Disulfide 8.8 J 2.6x
Chlorobenzene 4.2x :
Bra'l„Xhloranethane :
Bran:>-
dichloranethane
C-S Alkylbenzene
Sulfenamide
C-6 Alkvlchenol
Alllt\inun
Bariun
640
14
Cadmi un -
Calciun 26,000 60,000 8,400 12,000 59,000 59,000 4600 60,000 5700
C\ranlllt\ 10 14 9 ..
Irobal t I .;
Copper 25 6 10 29 7 I ..
Iron 2900 550 1100 1500 1900 1900 610 220 I 540
Lead 13 9 8 4.9 4.9 15 11 6
Manaanese 230 78 220 130 120 120 28 33 23
Magnesiun 7900 16,000 5100 3000 14,000 13,800 1900 13,000 : 3L20
Nickel 14
Potassiun 18,000 1700 13 ,000 1900 19,000 840 1000
SOd i Uti 35,000 96,000 9600 8200 16,000 16,000 6600 19,000 3 ~<;.~
Vanadiun
Zinc
3
200
19
3
23
33
66
33
~~
42
33
r = data rejected \ftJer OA/f;/:,
x = estimated value
() = local lab data
-------
Table 5 (cont.). -Gro\.nd Water Contaminants Identifed in New (EPA) I'bnitoring Wells.
Concentration in ~icra;1rams Per Liter ~ LQ/l) .
~
--
:, Cluster G ~
MW-20 I MW-2l
55' 10'
Tol uene 5.0 2.9x
Carbon Disulfide
C11orobenzene
Braoochloranethane 4.OX
Brcrro-
dichloranethane 3.7x
C-S Alkylbenzene
Sulfenamide
C-6 Alkvlphenol 910 910
Aluninun
Bariun
18
26
t
Cadmi un "
Calciun 2800 34,000
O1rani un 4 22
Cabal t I f
COpper 37
Iron 880 310
~
Lead l~~O I 12~~OO~
~anese
nesiun
Nickel
Potassi un 9200
Sodiun 12,000 13 , 000
Vanadi un
Zinc
14
26
t
-r . data rejected I.R1er OAI~
x = estbnated value
() = local lab data
-------
SECTION rv
ENFORC~ENr ANALYSIS
The PRPs (Waste Management, Inc. and the (lnitetential aqreement on the appropriate remedy.
WMI indicated that it did not believe that capping ot' ground water
remediation was necessary but did acknowledge that some level of
monitoring will be required.
It seems unlikely tnat WHI initially will aqree to a remedy which includes
ground water remediation and capping (proper closure of the landf ill) .
The Navy did not make a presentatlon at the meetino and appears to concur
with Golder and ~I.
EPA has determined that nroper landf.ill closure, around water remediation
and monitoring, and institutional controls is a propet' and defensible
remedial action for the Hi~s ~ Landfill site. Therefore, EPA need
not be flexible during negotiations. The pur~se of the ra'tedy is to
~itioate and minbnize human health risks anddamaae ~o the environment.
EPA's selected remedy is the most technoloaically feasible, cost-effective
alternative, which the Acency should suppOrt viqorously.
[)Jring the FS public carment period, Vlt!I contended that the only remedial
actions appropriate for the site were ground water monitoring and
institutional controls. WHI has indicated a belief that the existina
larrlfill cover will be sufficient if it is repaired. They have also
indicated that the only issue surrounding the site involves the health
threats which W!re elbninated when !TIunicipal water suppl ies were provided
to the Hippa Road residents. !he existing landfill cover is a thin,
intetmitteM layer of sand which affords no protection fran dermal exrosure.
The cleanup 8C8nerio offered by WHI ignores the degradation of a potential
water supp!!', ~ich 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 rronitoring. fbwever, like WHI, the Navy has indicated a
hel ief that around water recovery is not necessary due to the low
concentrations of contaminants, which will eventually enter into the
surface water t'egime.
-------
SECfION V
ALTERNATIVES COOSIDERED
PUBLIC ~-1Im ENVIIOIMENTAL OBJECfIVES
Public Health. The Hipps ~d Landfill has historically posed a public
health threat throl.Qh t'-'O routes of -exposure: consll'llption 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. AlthOl.gh there is currently no threat to
environmental resources, any landfill has unknown potential for further
releases. Leaching of additional contaminants fran the landfill may
prodoce a contaminant loading to the ground water which could harm the
environment once the grol.l1d water reaches the surface water environnent.
Since the ground water leaving the site discharges into an unnamed
tributary of the Ortega River, there is a potential for future enviromental
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 ~d 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 remediation (group C alternatives).
Several carDinations of group A, group B, and group C alternatives will
provide rElll8dial actions which canply with applicable enviromental
laws. OW .~le is a ClCJlt)ination of ground water recovery and treatment
(group A), ccntaiment/encapsulation (group B), and institutional controls
(group C). Gro\.rd water recovery and treatment will respond to issues
raised ~r the Clean Water Act (CWA), the Toxic Substances Control Act
(TSCA), and the ~source Conservation and Recovery Act (ReM). These
sane laws are also addressed by containment/encapsulation of the landfill
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).
-------
Althouah both PRPs have indicaterl a ~illinoness to neaotiate, the o~osoect
for agre~nt with waste Management, Inc. 1s poor. Negotiations wlll
beain during-the IQ) finalization process. A neaotiation period will be
allowed per the NCP, and EPA will be prepared to initiate remedial design
in the event that neootiations are unsuccessful.
~
_.
"
-------
Table 6.
RllDedial Technologies Considered for Remediating GrolZ1d
water Oontamination at the Hipps Road Landfill Site.
Gr:o':5 A Al te rna t i ves .
--
1. Ground Water Containment
a. Slurry Wall
b. Grout Curtain*
c. Sheet Piling
d. Surface Capping
e. Impervious Liners
f. H~raulic Barrier
2. Ground Water Treatment
a . Flocculation
b. Filtration
c. . Air Stripping
d. Steam Strippi~*
e. Spray Irrigation
f. Activated Carbon Adsorption
g. Resin Adsorption*
h. Reverse OEm:>sis*
i. OZonation* .
j . wet OXidation*
k. Biological Treatment*
3. Ground Water Recovery and Disposal
a. Punping
b. City Publicly Owned Treatment W:lrks
c. Surface Water Discharge
d. Ground Water Recharge
"
.\
(*) = I:enotes technologies which were eliminated during the preliminary
screening phase.
-------
~
_.
Table 7.
Remedial Techrologies Considered for Remediating the
Lardfill Material at the Hipps Road Landfill Site. Group B
Alternatives.
Soil Treatment, Storage, or Disposal Technologies
L Offsite Disposal
2. Onsite Extraction*
3. Onsite Stabilization/Solidification
4. Onsite Containment and Encapsulation
s. Onsite Incineration*
6 . Ve,:,ti~* .
.,
(*) = Denotes technologies which were eliminated in the initial screening
phase .
Table 8.
Technologies ~ich Address Other Factors Affecting Remediation
of the Hipps ~ Landfill Site. Group C Alternatives.
1. No Action Alternative
2. Mo-l~ and Pb'titoring
3. In8titutiooal Controls
-------
SCREENIN:; OF TECHOO[ŁX;IES
Potential t'8B8dial alternatives identifierl .for the HiDPs Poad Landfill
site were initially screened on the basis of technical feasibility, level
of. nrotection ~ovided to public health and cost-effectiveness. For
exanple, th"" "c"'~f grout curtains was el irrtinated durirq this phase
hecause a slurry wall will produce similar resul ts at a lower cost.
Similarly, reverse osmosis was elirrtina~edat this point because it requires
specialized operation and maintenance and because it is not cost-effective.
Another exanple is onsite incineration ~ich was elUninated because that
technoloay 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 site specific criteria. The second
phase review considered technical feasibility, the level of public health
and environnental protection provided, and on a relative cost-estimate
basis. The alternatives elUninated durinq this phase are listed in table
9.
The alternatives which were retainen after screening were then described
in detail with regard to engineerina considerations, equipnent needs,
operation and !"aintenance needs, monitoriOCf reouirements, health and
safety, pemittirg !:'eQUirements, schedulina projections, and cost estimates.
Alternatives shown in table 10 ~t the site specific needs and are feasible
for the Hipps ~ad landfill site"coocHtions.
i'
Technoloaies Eliminated
Several alternatives were el iminated in the prel Uninary screening phase and
in the detailed screeniOCf. '!he following is a list of remedial options
which were el iminated during the screening phases and the reasons for
el Unination.
Ground Water Technoloaies
Grout Curtains. The use of arout curtains was considered as a method for
containing contaminated ground water. However, slurry walls provide the
sane level of effectiveness for about one-third the cost.
Sheet Pilil11. '!his alternative was el iminated for the sane reasons as
the arout aa1:ain.
Steam StriJ:lldna. This alternative was considered as a 1'1ethod for treating
contamlnateag-rcund water: however, air stripping is equally effective
am less costly.
Resin Adsorption. Resin adsorption is potentially feasible as a treabnent
method for contaminated around water. Full scale applicability of this
technolorw for the contaminants found at the Hipps Road Landfill site has
not been proven. Carbon adsorption can produce sUnilar efficiencies at
.' :-.~.- &. ,-,v;.;:t ,-it .0, .
-------
Table 9. scree~ Out Technologies.
Screened 00l ~hnolog ies
Reason
~ WATER 1'5D TE:CHN:)LCGIES
GRaJND WATER CCNrAINMENl'
Grout Curtain
Lbnited Effectiveness
Sheet Piling
Lbnited Effectiveness
GR:XJND WATER TREA1MENI'
Activated Carbon Adsorption
[)::)as Not Rerove Vinyl
Chloride, Must be
Canbined with Other
Technologies
Onsite Biological Treatment
High Cost and
Limited Effectiveness
"
Spray Irrigation
Not Compatible with
Site Characteristics
GIOJND WATER DISPOSAL
Ground Water Recharge
Too High Ground Water
~Table and Low Recharge
Rate
SOIL 1'5D TECHOOLCGIES
TOtal Offsite Disposal
High Cost
High Cost
TOtal Onsite Stabilization/Solidification
-------
Table 10.
Remedial Technologies Retained for Detailed Evaluation
A. Ground Water Technologies (Group A)
.B.
1.
2.
Extraction, Air Stripping and Disposal
Extraction, Flocculation, Sedimentation, Filtration,
and Disposal
Extraction and Treatment at the PalW
Extraction, Air Stripping, Flocculation, Sedimentation,
Filtration, Carbon Adsorption, and Disposal
Extraction of Ground Water fran H~raulic Barrier
Wells Onsi te, Long Term Air Stripping, and Disposal to
the ortega River
Extraction of Ground", Water fran H~raulic Barrier
Wells, Treatment According to A-4, and Discharge to
the PC1IW
Installation of an Hanging Slurry Wall around the
Landfill, Surface Capping, Reverse Gradient Wells
within the Slurry Wall.
3.
4.
5.
6.
7.
Soils Technologies (Group B)
-.
1. Partial Solidification and Stabilization
2. Onsite Decontamination of Bulk Solids
3. Partial RenDval and Offsite Detoxification
4. Partial Solidification and Stabilization, O1site
Decontamination of Bulk Solids, Partial Retcval and
Offsite Detoxification, and Resource Recovery
5. COntainment and Encapsulation
C. Other Alternatives (Group C)
1. . It) Action
2. Landfill Closure and ~nitoring
3. Institutional Controls
-------
Reverse O!IDC8is. ReVerse osrTOsis systems are difficult to implement and
operate. A combination. of carbon adsorption and metal precipitation is
equally feasible with lower costs.
OZOnation. ....'DU6process requires that ozone be pr:oduced onsite. Because
the production of ozone is expensive and requires specialized opet"ations,
ozonation was eliminated. .
Wet Oxidation. Wet oxidation requires excessive aroounts of energy, which
make it unfeasible on a cost-effectiveness basis.
Activated Carbon Pdsorption (alone). The ground water contaminant found
to be rrost pervasive was vinyl chloride. Carbon adsorption cannot effec-
tively remove this contaminant.
Disposal of Treated GroU'1d Water via Recharge. Recharge t"ates of the
local soils are too low to utilize this alternative effectively. Lmple-
mentation would require very low pl.ltlping rates and a large m.mber of
wells, which is not cost-effective.
Spray Irrigation. '!he application of spray irrigation to the contaminants
foU'1d 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 TECHOOLOOIES
~site Extraction. Decontamination of the soils was not found feasible
due to the large degree of variation of the contaminants and their
distribution, which would require a cLmberscme washing process.
~site Incineration. The concentrations of contaminants foU'1d in the
soils are very small. Incineration would be costly when cc:rnpared 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. '!be levels of volatile organic catp)unds found in the soils are
low. '!he major threat is posed by the potential presence of containedzed
ca1IpOU'1ds. Vllnting would not address this concern.
Biological 'ft8atment. '!he l~ levels of contaminants fO'-l'\d at the Hipps
lO!d 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.
~ite Solidification and Stabilization. This technology produces
unnecessa~:''' .. ~ - ._-~...: --.' ." ~~~ =t::- are prohibitively high.
-------
Table II.
Summary of Evallwlion of Remedlall\lterlliltives.
Altern.t In
Technlc.1 Fee.lbillt,
Dwlronlent.1 18pect
Public He.lth Concenw
Inetltutl0n81 lequl~t.
A-I Ah Strlppln!!
eoet f".onfl""nce
LiP".1 . 50%
IInll CrMIt II... -
9.0\ to 12.20
"1,000 .el.
A-2 P1or~ol.tlon,
S~I..nt'.t lon,
end fllu.Uo"
Co!lt Con'ldtonee
LiPvel . ~%
""I t CoIIt bnse -
6."1) to 1.81)
1/1,000 11.1.
A- J T1-f!lIt.~nt et
V8!1tf!v.tf!r "lent
en"t ('.on' '''rocI'
LiPv.l . ~%
l/nlt Coat 1I:1f~e
6.~() to 8.911
"1,0110 .el.
A-4 ,I....cul"lo..,
s.d'w.et I..",
rlltrdt, AI r
Strl,,1 ...1
CIIrtIon eOI I't Ion
CoIIt Confld"ncf!
,,"I'I . ~I
'/It I t ".oet ""l1r,f!
1".70 to 11.110
. "1,000 11"1.
c.-. equl.-nt end procedurI'e
u.ed lor thle elternetlve. tXpert
technlcel pere_1 required to
.ape"l.. operet Ion. Cle....
ellectlvf!neee 8U.t be werl'led
'" effluftlt _Itorlns. Onl,
pI'MI"e woe rMucUOII8. tltte"
end PC" ere not r-..ed '" thle
operet Ion.
In eddltlon to epeclllcetlOll8
'or A-I ebowe, thle option
~e. he.., _Ul..
('- "'1ula-nt end pro-
~f!doree oe.d 'or thl.
.Itern.llvf!. PI.c.. ectuel
teek 0' r.-ovlnll or neulrel-
I zl"l ~onl-In8llon In htmll.
of eeconrt.ry perl,.
Tec'-Ior.l... 8nd ..,I.....t
u.ed In thle proc.... ere veil
proven. rpqu Ire. I'lIpf!rt
pen_I dot! to m_rou.
proc... .t.... 1I.le e"."..U..
provl"".. the hlKfwo.t r-v.I
.fllcleoc, 0' conI-I".....
Air etrlppln, .ol.tlle
or".. I c c""""""'. I rcJ8
,round illiteI' viII .ln18l-
"vene effect. to the
..U If er f rcJ8 VOCe. Doe.
not reeolwe the emrh-
.....t.l probl- 01 _t8l.
end I'CI cant_IMt Ion.
-r
"occal.Uon, eedl8e8ltd Ion
8nd flit nt Ion he..,
....1 viII .1,,1.1-
8dW!...e .ffect. to the
equlfer frcJ8 conUnued
_t.l. cOll\_I..-lon.
Tre.t8e8lt .t ....t....ter
pl..t ..11 .Inl.he 8dW!ne
effect. to lhe Aquifer frcJ8
vor.. end _tel cont-I-
,,81 Ion.
1-.1 o' VOCe, I'CIII, ....
he.., -t.l. viii .1,,1.1-
.11 811...... effect8 to the
equlfer.
".. rl." 01 e.poeure to
effluent 911pOr. 1rcJ8 the
proce.. .".t. for ta-e
vork I", OII8lte. ".. rl'"
01 e.poeure to ,n.III ...t.1'
Cont_IMt Ion clue to VOC8
I. .1I"lllc..tl, reduced.
"Inl..1 rl'" ..I.t. for
ta-e 1101111", on the
pl'oc.... ".. rI. of
e.,.ure to ,round ""81'
cont_IMt Ion clue to
_tal. I. .1I"lflcantl,
n61cecl.
"In"'l rl"'. ""I. ~I.l
lleUon ell.lnete. the rI.
o' h..l", ....It I-I
cont_Ill8t.lon reech the
""'1'1,1", ...I'el'.
""I. cOl8lllnet Ion of A-I
.... A-I.""', pI'MI"
hl8he.t dqree 0' ""lIc
he.lth protect Ion.
....t c-.I, vlth Cle.. AII' Al:t,'
pret nllt8e8lt .t"""l'II. ror
FOIV. Peder.' Vllter Qu.llt,
(:rlted., .... NPOf".S pldence.
S- .. A-I .bowe (..cept :1e..
AII' Al:t cCl8lpHence doe- ftOt 1IpPI,.)
....t .180 c-.I, vlt" oor ttend.l'II.
for heu~. ....te u-p.rt 0' ..'.1
.lurI... tr8ll8pOrt rul.. (I"'.) end .
QlI" to 01.,..1 o' OI8f :.11,
SUbUhecl end Solidified
_te.
, I
.1
Doe. not neecI to c-.I, v, ; . '18u..-.
Uute leplatlOll8, Sunar.i.. ,.
or crlt.rl..
S8e .. A-I .howe (e.c.,t 1I~.0 8U.t
C881f1, with oor t r_port
"""""., "'..rdode "'.t.
"'..1_, .... Tr-port
......
-------
T;lhl(' II (conL.).
Sumrn;lry of Evaluation of nem('dial AlLernalives.
Alt.m..t I...
Instltutl0R81 Requlr.-.nta
Trchnlcal '.R8lblllt,
r.n.1~tal I.,eet
Public Health Cbnc.rne
A-5 All' Strlppl~~ end
P01V 01 ache. II.
Q)at Oonflcl",.c.
...".1 + 501
..-... CoIIt ~.
9.11' to 10.17
'/1,000 lIel.
A~ PUll "':.at..... end
Rlvu Dlach..rll.
Q)et Oonfl~
. "'nl + 501
..-.It o..t R...
7.11(, to 16."",
111,000 lIa"
A-7 Slurry Veil,
Sur'.r. Clprln«,
IIfMI It~".r..-
Grlllll.nt "'"a
. a.et OonfltIPnc.
"'n I + 501
1)11 t CoIIt ""lIIe
10. }fJ 10 IJ.I"
111,000 .a"
~I ...ut,
SoIl.I ncatl.", end
ltebll'.atlOft
ODet Oon, I cftonc.
Ln.1 + 501
Unit OnItt RIInK. -
76.111 to 96."10
, "ton'
S- .. A-I
TKhnolOSl.. end equl...... U8ed
In thle proc.aa are ..II prov.n,
rpqulna .lIpt!rt ,.nomel clue to
n'-roua proc..a at..a. ,",I~
alt.rnetl". prowldpe thP hl~at
re80Yal ."lcIPftC, of
cont_l...h.
0-... f'qullJ8"lt ue"" for
cllpplns. Trlll...d I"'u_I
requlr.d for alurry VIlli
lnetalilit Ion.
0.-. eqlll,....t end proc-rea
...d '01' aoll e.cRYatlon, aolld-
I'lcation end atllhlillation.
CI.enup .ffect I........ -t be
".1'1.1... vlth lellCh t..t..
S- a. A-I
a--I of voo., PCII8, ...
he.", ..tala viiI .Inl.lze
all edw.,.. effecta to the
.".1'.
Oont.-I...ta In tr.. 18nII-
ftll -ire .t 0""', not
"'.tr~d.
Solldlflcation/.tahlll.8tlon
..III prowlde ~Iat Ion '01'
hP.., ..tal. cont.-Inlltlon.
[ffeeta on woe. ar. uneu-,
but thouKht to be .a'Klnal.
S- .. A-I
,",Ia cf8bhwt Ion 0' A-I
end A-l allMe, prowl"a
hlr,hPat 6.sree 0' public
health protect Ion.
Ie... the ..albllltl..
0' ....1 canteet ..lth
lend"" 88I.rlal. Oontrola
posalble 'liture cont-I_t
rel.a..a.
. 'I" 0' elqlO8Ure 10
...,rhr. "'rlnll .u-I-
end relet... act 1"lt I.. I.
hl~. A't., eolldlflcetlonl
.tahlllilitlon, the 1'1" 0'
..poeur. to cant'-Inat'"
.nll la I.. PUrther
cont -Inllt Ion 0' «rouncI
VIIter ..Ith r...., ..till.
..III ~ .Inl.lz~d. FUtur.
,.1.11... n' '1)I:a COt.ld be
po..lbI..
S- .. A-I
s- .. A-I ahow! (..cept II '0
...t c08pI, ..Ith IU1' Ua. ., ,rt
.t8l1ll1l""a, ""rndooa Va.'
ael!lliatlona,'" T'_POi, .....1".
"'.t c08pl, ..It" lIa.ar.to.,,I Ja.t.
..platlons end ROIA hrlli ~..
CUI"".... .
.. c.,l, vlt.. a" hll..rdou. Vllilt.
"1111.1_, [PA ItI1tA ~.IIPI pld..-
....., pille to dhpoe.1 0'
Ch88lcall, .tablll~d IIfMI .01Idl.l.d
_t., end pret r.et-...t r,uldlll1Ce
""11''' .,,1, to thl. alt.mllt I"..
-------
Table II «'ont.).
Summary 01 EvaJu;'Itfol1 uf Remedial Alternatives.
AII~m"I Iv~
Inatltutl0n81 lequlr88ent.
T~chnlc81 F~88Iblllt,
r.nwl~ul 1"8d
Public He.lth OonreFft8
8-1 111I1Ie Soli""
OPcont-ln"Ilon
".n"1 Confldrnr~
Lrv..1 . ~t
....11 ".ollt "'''II~ -
4J.'HJ to 11."10
"tnn .
8-) hFtlel lI_v.1
.nd Of '" It e
\)Ptnd flceUOfI
Collt eonll01
...." c.."t RA"It~ -
47."11 10 II.KO
"tol1
SI.II.r to 8-1 8bov~ 'or.
ellc.v8tlon, ~tc. \)PCont..l-
n8tlon e"ectlnRt"... I.
q...et loneble due to ~
neture 01 bulk eollde.
ec-n f!qulp8ent end pl'OCeduFe.
ue~d 'or eoll exc.v8tlon end
t ruck In\!. Cleenup e"ectlvene..
..et be verlf led with leech
teet..
H On8hIMI Inn 01 II-I, !;- .. 11-1, 8-1, .nd 8-) .bove.
8-1, III1d 8-)
CollI Cnnlldrncr
Lrvel . :>0%
""It OMt ""n«r -
74.91) ~ 1011.10
8/tOll ,
.., OIftt"I+nt end
. DIe....ul.t Ion
OKt ".onll~nce
LPnl . :>ot
IInl t "lIlIt ""1111(" -
"1.111' to 111.10
I'ton
c.--. equlp8Pnt IInd pl'OCeduFe.
ue~d 'nr 11011 ellcevetlon,
coni III.-nt, II11d rneapeul.t Ion.
TrlllnPd pt!uormrl required lor
IInu 11181811.lIon.
VIII produce ....t_ter
requlrllll tre.t_t.
(U8ete produced OI18lte
I. controll.ble.) UnprO„en
"'1 11001, ""e emr I rOI8eI1t.1
l8pert e.tb88tee dl'flcult.
II-III I. effect Ive --
of 8111\1811"8 the probl-
of conl88lnatlon .t the
.Ite. Cant 881 net Ion I.
r~ ~ deatrvpd.
""
IIn", _t III. not r-ed
durl"8
-------
Tahle 11 (cont.).
..,
Summary of Evaluation of Remedial Alternatives.
Alternlltlft
1ft8t1tutl_1 '.I~.
~Ic.l re..lbility
fJ'Iwl.--..1 IlIp8Ct
Pllbllc ..lth OIIN:en18
C-l Clo,ure end
Monltl!rlnr.
C-1In,tltutlonRI
Control.
Plk_t of (own .terl.1 end
-Itorl... wll. III contlldered
C088Qn Pn«lnprrlnR prectlc..
ec-,n prlldlce.
No ftductlon In cnnt_l_t
t r8n8port . Incftue.
tunalf. Siowe wertlclIl
-".....t of Irnund ...ter
t hroul:" the lendlt 11.
110 reduc:t Ion In lround
...ter tr-port.
'Huce. thP chene. of
de,.1 ContllCt ..Ith
lendflll -.terl.l. AI.o
ftducft the pntIlllblllt,
of .011 Inpstlon by .
children.
'.-e. chence of cont.ct
with cont_hl8ted 8011 ...
lround ...ter.
'e.trlctlon on cIo8elltlr u.. 0'
0' ,round ...ter fr.,. the .urflcllli
..ulfer. Closure 01 prl"lIte willi.
~ 8OcIlflc8tlon. ""trlctlon on
~.tlc VIII! of ,rooM vnt.r Ir.,. t""
.urflclRI Iqulf.r. (l08ur. 01 prl"lIt.
...118. renclnc of lendlili.
-------
~
--
Table 12. Cost Est.imates for the petained Psrredial ~.l ternc.ti ves.
Cost, $1,000 Cost $1,000 Cost, Sl,COO
Constructia1 O&M Present Wort.~
Alternative Present Worth Present Worth(l) Total
GIa.N) wm;:R
&-1 Extrac:tiat Wells 355 0 355
&-2 Hydraulic Barrier Wells 213 0 213
0-1 Discharge to Ortaqa ltiver 252 0 252
0-2 Discharge to P01W 435 700 1135
A-1 Air Stripping 2,120 0 2,120
A-2 rloc:c:ulatiat, Sed. , rilt. 1,674 0 1,674
A-3 Treat::Dent at the P01W 736 700 1,436
A-4 Careinatiat of ~1 , A-2 3,920 0 3,920
plus carbcn Adsorptiat
A-5 ~'1'em Air Stripping " 1,219 8,363 9,582
and P01W Disposal (2)
~ ~'1'em TreatJnent and 1,467 13,159 14,626
ti ver Di5p:)sal (2)
Jr.7 Slurry Wall, cappinq, (2) 3,800 1,263 5, 063
and P.everse-Gradient Wells
SJILS
~
B-1 Part. SOlidificatiat , Sta. 13,535 54 13,589
B-2 a.alk SOlids Cec:a1taminatiat 8,697 54 8,751
B-3 Part. ~~fsite Detox. 8,453 54 8,507
B-4 cazcinatiat of B-1, B-2, , B-3 13,670 54 13,724
B-5 Ccntairm!mt , ~atiC21 9,268 672 9,94Q
GnU.AL
C-2 Closure Plan and l'a\itoring 530 530 1,060
C-3 Instit:ut1cnal Alternative 527 54 581
(1) ~ CCI8t8 - activities shaoring $0 value are indicated with capital costs. It is
asS\Dld that QUI for these activities last a'\l.y a'I8 year and is handled by the
c1eanJp ccntractor.
(2) Inc:11.l:!ed at the request of f'DD.
-------
Alternative 5 - Extraction of G~ound Water from Hvdraulic Barrier wells,
La Te~ Ai~ Stri i , and Dis sal to the pOTW. This alternative is
sUnilar to water Alternatlve 1, with the excePtion that the
qround water recovery system would be designed to cap~ure the 1eacHrQ
edae of the cont.sninant plume. The ~ecovery well system would be maintained
indefinitel~provide protection from the threat of future ~eleases by the
landfill to the ground water enviroment.Disposal of the ground water
would be to the nearby FG'IW ~ather ~;'.an' 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 Accordinq to Ground Water Alternative 4, and Discharae
to the Ortega River. This alternative \IIOuld use a ground water recovery
systEl't designed to capture the leading edqe of the contaminant plLme.
'D1e recovery well systan would be maintained irdef.initely to provide
protection from the threat of future releases by the larxifill to the
ground water enviromtent. Full treatment of the qround water \IIOuld be
imnlanented to insure that waters bei~ discharged to the Orteqa River
\IIOuld not adversely impact the surface water enviromtent.
Alternative 7 - Installation of a Hanaina Slu~ wall around the Landfill,
Surface Capplng, Reverse Gradlent wells within the Slurry wall, and
Discharae to 'the PO'lW. This alternative would use a hangina slurry wall
arourd the landf ill per imeter to ~revent leachate fran leaving the
site. A surface cap would he installed to reduce the infi! tration of
rain water, and to reduce the level of leachate generation. Since there
is no accessab1e fully confining unit in which the slurry wall can be
based and since the Remedial Investigation demonstrated a downward
canponent of ground water flow under the landfill, reverse gradient wells
\IIOuld be installed to prevent leachate fran migrating under the slurry
wall. Low levels of ground water contaminants are eXP!cted fram the
landfill so that discharqe to the FO'IW \IIOuld not adversely affect
municipal operations.
SOIL TECHOOI.CX;IES
Alternative 1 - Partial Solidification and Stabilization. Partial
solidification and stabilization would entail that the soil component of
the fill material would be excavated and combined with a solidifying
aqent to reduce the level of leachate emanating from the contaiminated
soils. This may Unorove the handl ing and ph}'sical characteristics of the
wastes, d--. .. the surface area of contaninated materials, ard 1 imi t
the solubility or detoxify the hazardous constituents of the wastes. The
Solidifying agent would entail using either a cement based process or
sane other (X)zzalanic process. Stabilhation would involve the use of
inorqanic chanicals which produce insoluble cat\fX)unds which are rot
. affected by changes in site specific conditions. However, the hazardous
constituents would remain within the monolithic block of material generated
during the process. . .
-------
Alternative 2 - Onsite Decontamination of Bulk Solids. The contents of
the landfill incl~a large auantity of metalic objects which cannot be
addressed -in .other alternatives which remediate the soils component of .
the fill material. 1his alternative would involve excavation of the fill
Material, transport to a decontamination area, and d~ntamination of
bulk solid~.witA.steam or solvents. The decontaminated solids would be
. replaced into the lamfill or disposed of at a local sanitary landfill,
and decontamination ~te streams would be treated in a temporary onsite
trea~ent system.
Alternative 3 - Partial Removal and Offsite Detoxification. This
alternative would ~ire excavatlnq the most hiqhly contaminated soils
fram the landfill, and offsite treatment by incineration for orgainics
or landfilling for mterials which cannot be incinerated. However, the
nearest facility to which the wastes may be transported for treatment or
disposal is approxn.ately 600 miles fram the site.
Alternative 4 - Partial Solidification and Stabilization, Onsite
Decontamination of Bulk Solids, Partial Removal andOffsite Detoxification,
and Resource Recovez:y. This alternative is a combination of Soil
1echnologles 1, 2, and 3, with the addition of resource recovery. Eesource
recovery loiOuld involve certification that decontaminated metals are free
of hazardous wastes and loiOuld then be presented for recycli~.
Alternative 5 - Containment and Encapsulation. 'this alternative ~uld
involve the excavation of the landfill contents ard sealirg the base of
the landfill with an impermeable liner. The landfill materials loiOuld be
re-se of this alternative is to
limit the leachability of toxic materials by constructirg a physical
barrier which separates the toxic materials fram the environment.
~
CYI'HER ALTERNATIVES
Al ternative I - No Action. The" No Action alternative implies that the
s 1 te p:>ses no threat to p\bl ic heal th, 'Nel fare, or the environnent and
that EPA will undertake no remedial response at the site. This alternative
was considered urder the mardates of the National Contirgency Plan,
however, the threats posed by the site and identifed in the Remedial
Investigation indicate that the No Action alternative is unacceptable.
Therefore, this alternative will not be addressed further.
Alternative 2 - Landfill Closure and Monitoring. !his alternative will
include the placement of a hiqh integrity cover over the landfill, closi~
the existing private wells in the area, and roonitoring the ground water for
further releases. This option will remove the DOtential for hllnan contact
with the landfill materials and insure that the nearby residents will not
consume contaminated qround water.
Alternative 3 - Institutional Controls. This alternative includes any
activity which would facilitate remedial action ard the protection of any
remedy implemented during the remedial action. This option may include,
-------
but is not.l~itedto, installation of a perimeter fence around ~~e site,
institution of a drilling ban within the affected area, relocation of
affected residents under the Federal Emergency Management _~ency, and
closure of existing monitoring 'Neils. Specific i~stitutional controls
would be i.d8Ae!fied under the remedial design !;)~se.
-------
SF.Cf!ON VI
COMMUNITY RELATIONS ACfIVITIES
In '1ay 1983, the first public meetina was held by concerned citizens who
live in the Hipps.~ Lardfill vicinity. The citi-zens formed an organi-
zation known as"the Jacksonville Heiahts Concerned Citizens ~ainst
Contaminated vater (JHCCACW). The orga~ization is riOW krioW1"\ as Jacksonville
Citizens ~ainst Contaminated Water (JCACW). The formation of the JCACW
was initiated in reaction to what was perceived as a lack of response to
contamination of private water supplies by the City of Jacksonville.
JCACW has been active in ensuing years. 'I\I.o mEmbers (S~kesperson YVonne
Wbodrnan and Secretary Gail Speicher) testified before the House of
Pepresentatives Envirorment, Energy, and Natural Resources Subcamtittee
of the COmmittee on Government Operations on June 22, 1983. Their
testimony dealt with the effects of ground water contanination and the
lack of responsibility assumed by the waste generators and aovernment
officials (See appendix A).
On July 9, 1983, YVonne Wbodman met with F.PA Administrator William
Ruckelshaus, along with 14 representatives fran other 9Jperfund sites.
The meeting was held to inform Mr. Rlckelshaus of the pervasive citizen
concerns surrounding -9Jperfund sites.
"'
The Hipps ~ad tandfill was finalized on the NPL in September 1984. That
same month, EPA obliqated funds for the RI/FS. In October 1984, the REM
I I contractor was tasked to perform the RI/FS.
Region IV has conducted extensive community relations activities at the
Hipps ~ad tandfill site. Q, NovEmber 13, 1984, EPA officials and their
contractors met informally with the Hipps Road residents. !he meeting
was held to qive the residents an opPOrtunity to present their concerns
and to allow EPA to explain what actions \oIOuld be conducted under the
RI/FS. One major concern raised by the citi~ns was a request that JCACW
leaders be informed whenever "outsiders" will be in the vicinity. !his
request stemned fran previous events in which urrnarked goverrment vehicles
Io.ere seen standing idly in the area. EPA subsequently informed the JCACW
leadership of any official EPA activity in the area.
~ May 23, 1985, EPA held an informal publ ic meeting with the Hipps R:>ad
area residents to present the final RI/FS work plan. The meeting was
preceded by th8 release of a Fact Sheet in April 1985 and by a press
release. Copi.. of the Wbrk Plan, Community Relations Plan, and auxiliary
docl.l'nents \\8r8 placed in the local information repos i tory at the Webb
Wisconnett Branch of the Jacksonville Public Library. CODies of the same
documents were provided directly to the JCACW officers.
Fran January 1985. throUJh September 1985, EPA conducted an irmtediate
ranoval response in which all area residents who were usin:;:J qround water
resources were connected to municioal water supplies. This eliminated
to"'''' f....=.r nf t""n"~; ~12~ exp:>sure to contaninated drinkinq water.
-------
'thro~ut.the RI/FS process, EPA frequently maintained contact .with
JCACW officers with telephone calls and onsite visits. Each final document
was proYided to the JCACW officers and the information repository.
#
Q1ce the
-------
SEcrION uI r
CCt-JSISTEOCY WITH ornER' ENVrRO~1ENTAL ~S
Envi~~nmenta1 laws which may he applicable or relevant to the remedial
act ivity are~- - ~
-- Safe Drinking Water Act (SI:WA)
-- Resource Conservation and recovery Act (ReRA)
-- Toxic Substances Control Act (TSCA)
-- State of Florida Administrative Gade Chapter 17-7 - Landfill Closurp.
(17-7 FAC)
-- 1980 EPA Water Quality Criteria
-- Pre-treatment GJidance for Dis{X>sal at the ro'IW
In 1983, the City of Jacksonville extended public water supply lines into
the Hipps ~ad area. Several res idents elected to connect to the ci ty
suppl ies at that time. In 1985, EPA conducted an emergency response
which pr-ovided all remaining Hipps ~ad Lardfill area residents with
municipal water supplies. Thereby, the local residents were provided
with safe drinking water per the SCWA.
Design and implementation of the landfill closure will be conducted in
accordance with S\btitle D of RCRA and Q\apter 17-7 FAC. 'this action
includes cappina the lardfi1l in accordance with RCRA requirements,
recovery of contClninated ground water, and long-tem ground water rronitoring.
These three r-eQUirements are inch.rled in the selected remedy.
Because of the potential uses for the surficial aquifer, ground water
recovery will be conducted until the ground water auality is in canpliance
with the standards established under the S[)JA. Contcminants which ar-e
not addressed under the SLWA will be removed until COttpl iance with the
1980 Water QJality Criteria Hunan Health Stardards is reached. MY
contcminants for which there are no standards will be removed to levels
which are mutually agreeable to EPA, Florida Department of Environmental
Requ1ation, and the City of Jacksonville Si~Envir-ormental Services
Division. 'these levels will be defined during the Remedial Design phase
of Remedial Implementation. Any state water quality standards which are
more stdngent than federal stardards will have precedence.
The recovered ground water will be discharged to the local FO'IW for
tr-eatment and disposal. Discussions regarding access to the POTW were
held in November 1985 with officials fram. the Jacksonville Public Works
Division. ']he City of Jacksonville indicated a willingness to accept the
ef~luent for treatment. Pretreaement standards are the operational
standards by which discharge to the POTW will be assessed. If the
contcminant levels are above the pretreaement standards, dilution of
the contcminated ground water will be accePtable. (Appendix C).
The implementation of institutional controls will reauire that the
existing local dr-illing ban enacted by the Jacksonville Sio-Environmental
Se~d"""" "~"';C:;t"\... (~~O) be continued. BESD officials have indicated a
wL..... ".. .---,:,nt this restriction.
-------
During the .field investigation, ground water samples indicated the presence
of PCB's in concentrations above the partitioning coefficient in water.
'!he presence of PCB can probably be attributed to the unfiltered water
samples in which PCBs adhered to the soils ~ fb,..Iever, concentrations
"detected ...-1everal orders of magnit1.de below . levels which ~uld invoke
TSCA regulations.
The Natural Resource Damage Assessment, conducted by the Fish & Wildlife
Service conclooed that no federal trustee resources have been impacted by
the site (Appendix D). There are no threatened wetlands, and the site
is above the SOO-year floodplain (Figure 7).
...
.\
-------
'Cj-O
u
"~i~~-7-=- -
i
- - -- -:=-- _~i~e.~T
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,~
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...
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: c:J
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it::
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. ~ 110'"
~,;"" " i!> ...",\
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~~~~ :'
-:\,0 !J...\ j
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,: '/' ,,)
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--
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,
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--'----, ..- '- /
-~~ -- /
II.__~.!'~
Figure 7.
Hipps ~ Landfill site flood potential map. Zcn!S designated
with the prefix "A" indicated areas of lOo-~ar flood levels
(dark shaded areas). Zones with the prefix "8" indicate areas
between the 100 and SOo-year floods (light shaded areas).
Zones with the prefix "c" are areas of minimal flooding.
National Flood Insurance Program Flood Insurance Rate Map
'120077-01C;(\ -
-------
SECTION VI II
RECCMMENDED ALTERNATIVE
SELECTED REMEDY
.,.
---.
The ~ecommended alte~ative is a combination of alternaties A-3, C-2, and
C-3 (Table 5-1, ~S Ferort). This canp~ises ground water ~covery and
treaement at the RJTW, p~oper landfill closu~e, and institutional controls.
The ground water :ecovery system would entail the installation of a
~ecovery well network and construction of a pipe line to access the POTW.
!he point of connection lies approximately 20,000 feet fram the site.
The recovery systsn will capture the existing Dltrne of around water
contamination to prevent the degradation of additional portions of the
aquifer. Once the clean-up aoals, as outlined in 'Section VII of this SUrrtnary
of Remedial Alternative Selection are attained, the recovery will be
discontinued and the around water monitorirq' phase will be initiated. If
monitorirg indicates further ~elease of contaminants to the around water,
the ~ecovery operation will be reinstituted. Each recovery well will .
have an individual pump so that future recovery operations (if necessary)
can be Unplemented to address' new ~elease conditions.
!he landfill cap will be constructed in a \'I\anner consistent with all
appl icable Federal, State, and local regulations. 'the cap will preclooe
physical contact with the landfill contents and will reduce the vertically
downward hydraul ic gradient caused by the ground water "mounding" due to
infiltration.
Institutional controls may inclooe, but are not limited to, fencing the
site, continuance of the local well drilling prohib~tion, land use
restrictions, arouting existing private wells, and public or PRP acauisition
of private lands. Property on which the landfill is located is residential
and two hanes are physically on the larofill. A third hane is imnediately
adjacent to the landfill. A total of seven' (7) residential lots will be
affected in part or in whole by implementation of this remedy.
Ground water MOnitoring will be conducted quarterly for the f.irst two
years. If no further releases are identified during that tUne, monitoring
will then occur ssni-annually. All analyses will consist of full priority
collutant scans. If the recovery systems need to be reactivated in the
future, the 8\Diequent ncnitoring 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
systsn. O&M will continue for 20 years after the final ground water
:ecovery operation. EPA will provide operation and maintenance costs for
one year after canpletion of the remedial action. After that time, the
State of ~lorida or its designee will assume responsibility for operation
and maintenance associated with thp. S;~A.
-------
ca;r-EF.F!rl'IVENESS
Section 40 CPR Part 300.68 (j) states:
'!he appt'*~tt extent of remedy shall be determined by the lead agency. s
selection of the rerredial alternative which the agency determines is cost-
effective (i.e. the lowest cost alternative that is technologically
feasible and reliable and whi~~ effectively mitigates and minLmizes damage
to and provides adequate protection of public health, \oIelfare, or the envir::mrnent.
The remedy selected for remediation of the Hipps Read tandfill site i.s
consistent with this requirement. All other feasible alternatives which
perform equal or superior to the selected remedy are more expensive. All
of the less costly alternatives presented in the Hipps Read Landfill
Feasibility Study are either not sufficient to fully ~iate the health
and environmental threats posed by this site or are not consistent with
applicable environmental laws. A sUtlnaryof feasible alternatives which
\oIere rejected is presented in table 13.
The selected remedy is estimated to cost between $3.9 million and $4.4
million .
"
-I
-------
Table 13. sumaary Table of Feasible Alternatives and Cost-Effectiveness Canparison.
Cost in Millions of Dollars. .
Remedial Alternative
. ...
.- -
A-l. Air Stri~~ing
I Reason for Non-Selecti~
I -
I
I
Less cost 'effective than treatment at
the POTW and failure to address all
round water contaminants
I Estimated
I Cost Range
I
\ 1. 6 to 3. 3
A-2. Flocculation
SedUnentation and
Fil tration
Equally cost-effective when compared
I to treatment at the PC1lW but fails to
address all round water contaminants
I 1. 3 to 1. 3
A-3 (RA-6). Ground Water
Treatment at the PO'IW
A-4 (RA-l). Canbination of
RA-l and A-2, ~lus
Carbon Adso tion
A-S. Air Stripping and'
Disposal at PC1lW
'n'le reccrmended alternative for ground
I water remediation
I
I
Addresses all ground water contaminants,
but is expensive canpared to treatrlent
at the PO'IW
1.3 to 1.9
I
I
I 3.1 to 4.0
I Less cost-effective than treatrrent at the I 9.0 to 10.6
POrw. and failure to address all grourd
water contaminants
A-6. Full Ground water
Treatment and Disposal
to the POlW
Less cost-effective than treatrrent at the
PC1lW and failure to address all grourd
water contaminants'
3 . 2 to 17. 3
A-7. Slurry Wall, Surface
Capping, and Reverse
Gradient Wells
8-1. Partial Solidification
and Stabilization
Expensive and not sufficJent alone
I
I Technically effective but expensive
canpared to capping and institutional
controls
4.1 to 6.9
I
I 8.4 to 15.0
4.1 to 12.7
B-2. Bulk Solids
Decontamination
B- 3. Part ial R81aval and
Off-Site D8taKification
8-4. Canbination of B-1, 8-2,
B- 3, and Resource
Recover
Must be used in conjunction with B-1 and
is not cost-effective canpared to capping
and institutional controls
Insufficient alone, must be used in
conjunction with 8-1. Not cost-effective
ccmpa.red to capping and institutional
controls
I .
I Fully addresses landfill contents but
expensive canpared to capping and
institutional controls
4.0 to 12.3
I
I 7.7 to 18.7
t)-~. containment and
Encapsulation
I Effectively addresses landfill problems,
but is expen~ive c::arpared to capping and
institutional controls
I 5 .5 to 14. 2
-------
Table 13 (cont.), Summary Table of Feasible Alternatives and Cost-Effectiveness
~rison. Cost in ~illions of D:>llars.
~
Remedial Alternative
-..
Estimated
Cost Rance
Reason for Non-Selection
C-2 CRA-2) Closure Plan and
/It:>nitoring
Insuffic~ent alone to address effects
POsed by the landfill al~~ough it is
cost~ffective
C-3 CRA-3) Institutional
Controls
! 1. 0 to 1. 5
I
I
I
I
I Alone, this option
any aspects of the
inex nsive
fails to remediate
site, although it is
j
I 0.6 to 1
I
RA-4. Canbination of
C-2 and C-3
RA-S. Canbination of A-4,
C-2, and C-3
RA-7. CatDination of A-3
and C-2
RA-8. CatDination of A-3
C-2, and C-3
RA-9. CatDination of A-4
and C-2
RA-IO. Canbination of A-6
and C-2
Cost~ffective but fails to address
t ground water contamination
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 ine nsive
Addresses all aspects of the site in the
ITDSt cost~ffective manner
Expensive carp.ared to RA-8 and fails to
inclu:!e cost of institutional controls
I
Expensive CCIIpared to ~8 and fails to
inclu:!e cost of institutional controls
1. 6 -to 2. 5
I
I
I 5.0 to 6.2
I
I
2.4 to 3.4
3.9 to 4.4
I
I 10.3 to l:,~
I
RA-ll. Canbination of A-3
and A-7
8.4 to 1",;
Addresses all aspects of the site, but
I is expensive CCIIIpared to RA-8
4.7 to 7.5
-------
SECTION IX
OPERATION AND MAIm'ENANCE
retreatment criteria are not exceeded and
to rn:x1itor flow rates. If the contaminant concentrations exceed the
t>retreatment criteria, the operator will adjust withdrawal to t>~ide
dilutants to the recovered ground water and readjust flow rates.
Maintenance required after canpletion of grol.nd water recovery will
include bi-annual inspection of., the pl.ll1pS, lronitoring equipnent, and pipe
lines to insure that the ground water recovery system is in working 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 from the last recovery operation.
tNIDFILL CAPPING AND ~ITORING
<:nce 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
include keeping the vegetative cover intact, prevent deep root plants
fran encroaching on the cap, and keeping the landfill drainage system in
proper condition.
O&M for the cap will continue for 20 years from the final ground water
recovery cpratioo.
INSTI'lUrICJW. cxm'R)IS
The institutional controls include installation of a fence to restrict
access and protect the cap from encroachers. O&M will require bi-annual
inspection of the fence and repair as needed.
FUNDING
was\..!:.
'.... ~ ..V".LUes nas' instituted a !;)rogram for dealing with hazardous
::>....I:::i. 1nis program is designed ?"1 the CERCtA nOOel and is ~rated
-------
similarly. to .S~rf1ft1 through the Florida Department of Environmental
Regulation. '1he State of Florida has agreed to flJ'\d 10% of the cost for
implementing the selected remedial action.
'l11e relocat~ residents who are affected by the implementation of the
selected remedial action will be condu=ted by the federal governrent
under Federal Emergency Management Agency (FEMA), with acquired lands
be ing deeded by the federal government to the State of Florida. .
After the remedial action has been implemented, EPA will t>rovide O&M
costs for one ~ar. At the end of the first ~ar, the State of Florida
will assure the responsibility for O&M. A letter expressing concurrence
by the State of Florida is in Apt)endix E.
'these arrangements vill be negated should the PRPs agree to undertake the
RD/RA ot)erations as outlined in this docunent.
~
~
-------
SECrI~ X
PRQJEcr SCHEOOtE
The schad"'''' ~ the RD/RI phases of the Hipps ROad Landfill site
~iation are dependent on the success of enforcement negotiations.
the PRPs agree to undertake RD/RA, the schedule will be negotiated to
acex.mllodate EPA, FDER, and the PRPs.
If
If, however, negotiations with the PRPs is unsuccessful, EPA will follow
the schedule outlined below:
Schedule Landmark
Date for
Implementation
9/1/86
10/31/86
12/31/86
2/1/87
8/1/87
8/30/87
..
10/1/87
10/1/89
1.
Finalization of the ROD
2. Canplete Enforcement Negotiations
3. Award Superfurd State Contract (and
rAG) for Design
"
4.
Initiate Design
5. Canplete Design
6. Award/Prnend Superfurd State Contract
(and IAG) for Construction .
7.
Initiate Construction
8. Canplete Construction
-------
SEC!IOO XI
Ft!IURE AC!rOOS
...
Future ac~ 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 assesStent, 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
'IestiDDny" SutJnitted by
Yvame W:xxinan and Gail Spe icher
before the
House of Representatives
Environnent, Ehergy, and Natural Resources
SUbcxmnittee on Governnent ~rations
..
-------
.
'rESTI~ONY I'OR
BoeSB ,0' RDUSEN'l'A'l'IVES
UVIAONMEN1', ENERGY, AHD HA'l'ORAL RESOURas SUBCOMMIftD
.L
. "
QP ft&
. ~
CCM!Unss OH GOVERNMENT OP!RA'l'IONS
SeBMI'l'TED ON WEDNESDAY, JUNE 22, 1983
BY:
YVONNS WOODMAN .
GAIt. SPEICHER
SPOKESPERSONS FOR JAC~~U~Y~~~ HEIGHTS
CONCERNED CITIZENS AGAINST WATER"
CONTAMINATION
-------
Thank you, Congres~man Bennett, 'Eor the in t rod:Jct ion and h:,
_.r efforts in "our behalf. Without ~he support of yourself"
1
Senator Lawton Chile. of the Florida Senate, Mr. Don Gray, and
Lester Brown, we ~tanot be here today to address this
subcommittee.
Mr. Chairman ... Members of the Subcommittee on Environment,
it. "
Energy, and Natural Resources ... ladies and gentlemen: We are
vic:i.. of 9roundwater contamination. . Water ,.. the very
resources necessary to sustain lile, ~:h yours and mine, is
bein~, aDd in our cas.. has already be~n, destroyedJ
con:amina:ion is... ind.~d, a. life and death issu..
.
Groundwater
,
In'the next few minute., we~will summarize the effects
.,
rUftdwater contamination has had on re.ideD:. of the Hipps Road
'kre. in Jacksonville, Florida.
J
presentation, iDcluding physical evidence and dccuman:ation, as
Additionally we submit our entire
..
tes:imany to this subc:olllllli t.:.. . .
In the 1960'., the 0.1. Navy contracted with independent
.
. ,
vaste contractors for the 4i.po.i:ion of -trash- ,enerat.ed by NAS
. .
Jacksonville .and HAS Cecil ,1.1d.
A former landovaer, for the
purpos. of fil11DV lD a cyp~.88 8Wamp and hoping to cre.te'
.
-useable- land, 81%884 to a landfill contract with the disposal
.
companie..
Re.ident. were concerned with the problema that: would
. .
accompany :he 6.8 acre landfill.
, .
-1-
-------
At the beginning o~ the landfill dumping period, the
..i tatio.n regulation and supervisiOf'l shou td have bean assumed by'
;
-
the County Health Department. On' October 1, 1968, the City of
Ja~ksonville ana-8w„~l County 90ver.nments consolidated. At this
time, the two became one, meaninq the 'City Health Department
should have acquired ~he 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~. from NAS JacKsonville and
Cecil Field, that the lanc!f'ill vas supervised by the Sani tation
Division, and tW.t in 7 years we o.ould even build on it.
. .
blind laith, ve purchased the property, beinv drawn to the
ghborhood by the refresbinv rural lifestyle and pleasant
So in
a.ighbors. BOw!Ver, some people purchased property ift the area
never kno~inV about the lapd~ill. We dis~overed, that the Hipps
Road landfill was never totally completed.
It ".. to have a
layer of topsoil &Dc! foilag. OD the surface.
When we asked our
city councilman to investigate, be reported that tbe Sanitation
Division bad released it .. .atisfactorily completed.
payment ".. ..4. _4 thue v.. nothinV v. could de.
The final
. '
In the e.rl~ ~'70'., a pond borderin~ the landfill bad a
- .
thick foul-odore4 film on its surface, and fish and surrounding
vegetation died.
aesidents cal~ed city atticials.
After
evaluating tbe situation, the city ordered the.cleanup.
-2-
-------
,
oroxima~ely four barrels of a degreasing agen~ were dumped inca
;-:-nd.
f
HEALTH DEPARTMENT INVO~VEMENT
According to the Department of Health, Welfare and
.., ,
. Bio-Environmental Services report dated April 11, 1983, the
e
Public Sealth Division of the City of Jacksonville took the
8first- vater sample at 8903 Sipps Road on February 15, 1983, in
..
response to a ccullplaint of unusual taste and odor in well vater.
'.
Test results, no~ available, until March 18 shoved vinyl chloride
. .
and other solvents and degreas~rs" present. .
<~ually, the Carro~l ,lttmaA family noticed a strong
.odor and taste in their vater .following heavx rains in
J ,
September, 1979, and called the City Sultb Cep&rtment
to complain.
. . . ~
A first test (bacteriological aDalysis)
vas .conducted 10/15/79 and found to ~ satisfactory.
ODable to drink the vater due to strong petroleum odor
and taste, Pittmans had a water softener installed on
July 1, 1980.
Still the odor and taste vere prevalent.
The situatioa .ors.oed and they called the vater
softener co8pany.
Tha company stated that it wasn't' a
vater softener problem, but they 'should call the City
aealth Department;
In ~anuary, 1981, the Plorida
. .
-3-
-------
.
Oepartment of Health and Rehabilitativ~ Services r~n
.
two drinkin~ water chemical anllyses, the last of which
Pit~ans were told would be sen~ to Atlanta,
accompanied by certification of suspected imminent and
sUbstantial d~nqer documents.
Thp.y did not r~c~iv..
results until March 20 and there was no indication of
. Atlanta involvemedt:..
Tests indicated BCt.
At this
point, the Pittmans were told by Mr. Lanqford Cnow
re~ired) of the Health Cepartment that the Sealth
Cepartment had dene all the.!re. tasting they could do.
\.
Any further tasting would cost approximately $800 to
,.
$1,000 and would.ba.e to be done .at their own expense.
o "
Be urged them to drill a new wall instead, aince
o
further tasting would revaal the need for a new one
anyway.
Be a180 told tb.. not to make vave., tell no
one .about your vatar.problem, not fOur nei9hbora and
especially not the madia.
If they did ethey were
told), itvould cauae trouble and their property would
devalue. They were ne.er warned not to dr ink the
vater. ~1re4 of afODiain9 over wbat to de, the
P1t~. Cl88pl1ed 011 October 8, ~98l, at the coat of
$1,200. .i9b~eell IDOntha latar, April 20, 1983, they
. were told tbe new well was contaminated.)
Following tbe tasting of the Todd residence, a series of
00
vell ta.ts and mud .ample. from ponda were dene Csee Attachment
-4-
-------
Curing earl~ stages of testing, se~e~~l residents drilled
.
t their own expense ..after being led to bl!lieve that was
,nly alternat~V8. This' presented cahfusing and conflicting
:uation~ with which t~ JacKsonville Heights Conc~rned Citizens
~. to' deal.
We were told not to drinK the water,-but it was OK
bathe in it.
Also, only ten wells per' week could be tested
:ording to the Health Department.
This created confusion and
tbt since the situation wis declared an emergency by the Mayor.
litionally, we have since discovered, on the lame day, that one
abar of our Steerini Committe. was told by the~OER that the mud
~les taken from nei~hborhood ponds were completed and. showed
. another member was at the Bio-Environmental Division and .aw
..
! mud samp~es sitting untested in a,refrigerator.
tbat they were teo busy ta.. get to tb8ID.
The chamist
.
~ .~ ~~her contradiction seamed to be the lack of knowledge
.
:erad regarding health hazuda.
When .The Summary of VBO
sple. Taken' in the Hipp. Road Area. va. III&de available to
.,
lidents, v~ found there were approxi~te1y thirteen various
cin. including banzene, methylene chloride; tetracbloriethene,
1ylchloride and methyl isobutyl ketone.
By talking with
)4trt. aDe! re.earcbut data, we realiz84 our probl8111 was much
:e than just 0~taia1Dt potable drinking ~ater, a. official.
l1d have U8 belieft.
The quote mast readily usee! vas .pose. no
_diate. harm-.
By drinking a single glas. of water, one won't
.
a1 immediate effect, but what &boat long-term consumption?
-5-
-------
, .
.
~ abou~ exposure throuqh inhalation of fumes 3nd skin
. -
Q~sorption?
~ha~ about qenetic ef:e~s on future qener~tions?
. -
Obviously, ~88 can ~ell us how lonq the chemicals hav9
. leached into our water supply.
Some of the w~ll~ that proved to
OP. contaminated did no~ have the sam~ detec:able odor as others.
Mr. Fry was quoted as sayinq, -just because it comes up clean one
time, doesn't mean it w0.f,'~ come up contaminated the next time".
This implies that there are too many variab~~s to measure the
length of exposure.
'"
,.
NAVY AND CIn INVOLVEMENT
Perhaps the most fru~ratinf of allthe.e issues is the
apparent apathy ~f 0.5. Navy representative. towards our
situation. rirst there wa, a. ccmplete denial of~lnYOlv.ment of
the Navy ~
Next came an admission from a Navy spokesman of
knowledge qf dumpinf at the sit., but no records of contents
dumped are available.
Second, accordinf to minute. of the
Department of Health, Welfare aDd aio-Environmental Services, 011
-
April 8, 1983, . ...tinf w.. beld to dlscuas contaminated wells
012 Hipps Road.
It va. attended by Bill Roach, NAS Jax and Dave
Rogers,NAS Cecil F1e14.
Although the Navy met with the city and
state officials to discuss. ~he ,ipps Road situation, the Navy
-~ft.~."~lv chose not , to be represented at citizens meetings, even
-6-
. .
-------
.
-;ug'h inv i ted .
We hereby submit cvid~nca of waste 9~n~rated by
dVY.
"
I
Exhibit A is a five qallon can labeled ".methyl ethyl ketone"
...
with label indi~nq Naval Air Station Zip Code 32212.
A 1967
datOll! is 1p'l]ihl~.
Thj ~ w",~ 11I)(C::AI'Jllt~rl ; n
t.h'" nr."!!I;-n~. ~f
T')~ n r. r :, v '
and Lester Brown June 4, 1983, from the landfill behind the
. residence of Donald R. ~oodman, 9084 Hipps Road.
was approximately six inches below the sur~ace.
Depth of find
Exhibit 8 is offic!'al military docu.nts found on the dump
.ite on the same date.
..
",
Exhibit C is photographs of pieces of evidence and other
..
materials taken from the dump site by .residents befo~e
-completion of landfill-, ai~craft tires and .ections of airplane'
,?s protruding through the landfill surface, and other
photographs demon.tratift~ the era tor-like topography of the
" .
landfill; spar.e V8getati~n,. an4 8urfacing of va.te materials.
..
~h~ City of Jacksonville has displayed various attitudes
. .
regarding our .ituation.
One surprising.element va. the .fact
that our own city councilman has never responded in a positive
manner to calls ftOr participated in citizen's ..etings to which
be vas person&117 iavite4.
The commit88nt fro. the City of Jacksonville to meet our
immediate and long-term needs came with an emergency ordinance
pas.ed by city councillll8n on May 10,1983, (.e. Attachment 8).
We fe.l this ordinance .et,a precedent.
OtheJ: ci ti.. throughout
-7-
-------
"~e United .Statas shouldpa~~ similar' tcgist.J:ion, as it. i:;
.:oming more and. mo::e evident that it will bl! needed. It
?
provdes for illUDlldiate and long-term safe drinking water needs .1S
well as providi8,f "'#illS of recovery for costs andexpens
-------
.
t.h(!C'e hc1ve ~QI'\
C'eport.s of num(!C'ous' c:'1C' i.c1C L'C'obl-!ms,
~oss of
, -',ilibrium, na~"sC!a, headaches, "fat'ique, black outs, dizzines3,
. rlO~lycelnia, t\!pertens"ion, kidney in f
-------
three mont.h:i.
Resear~h on the toxic ~hemic~ls found in ar~~
.15 reveals abundant information o"n .all but: one -- 4 ~thyl 2
. -. f
cJenCc1none, t.he ch..ic41 Which measured at the highest.
. concan cra t ion of,-&J..1:8'"c!etected.
Recently, we did learn anot.her
ni\l:1e fo r
this toxic chemiC41 -- methyl isobutyl ketone, which
research shows destroys the enzyme system.
~,
CONCLCSION
.
w. have been devastated by effects of groundwater
contamination.
.The devaluation o~.property, disruption of lives,
and physical and emotional harms~blcome more apparent eacb day.
a bas run out.
One does~'t bave to hold a doctorate degree to
- ~aliz. that tbis nation is in the midst of a national crisis.
.1'
The irres~nsible misbaps of yesteryear are the tragedies of
-I
today. A~proxim&telY SOt of AD8ricans depend on groundwater to
survi"e.
Tbe ."idence is clear.
Groundwater contamination has
become a .cancer. of its own - destroying human li"e~ ...
.
physically, emotionally, and economically, not by an act of God,
but ra~her.by 8&D.
It's time ~ qait playing political football witb this
.
issue.
The.seriousness of groundwater contamination must be
recognized.
An immediate commitment from---gislator, and action
.must be initiated to stop i~~
Tbose who ganerata and regulate
-10-
-------
.araous w~s~e mus~ be forcea to Eoi.!OW thc"ugh with I:hcir
..aponsibilitie~. .
f
Priorities must be rearranged ':.0 Ineet I:his crisis. Doll.3rs
can and must be ~~avail~ble to provide the agencies with
manpOW'9r,
technology, equi~ment, ~nrl the me~ns to ~nforc'9 1~w3
regarding hapnazard toxic was~e dumping.
If laws are not.
presently effective, th~y must be changed to be SQ.
'1'
As concerned citizens, we have discovered many discrepancies
- t
and contradictions and have learned to recognize them readily.
It'. amazing how smart and pers8v,ring & person becomes when his
lit. and economic stability become endangered.
It's. ..d .legacy W8 leave to our children, ladies and
cr8ntluen" "'....-Wt .., -. k":1":- ...~~ ....-,..
-11-
-------
. ADDITIONAL CO~~NTS
'I
. Accord1n& to nor lcia Deparalent of Environmental l.egulat10n'. 1982-83 - Summary of
" Ca..' of C.OIIII4vat.. CoftU81D&t10".. 1" Florida tha.. ..... 65 ..corded dte. of
.. 1"0",",lI&t.. C011tDiaat1o... $a.." of tl1... ..... 1" Dwa1 eo""ty. No.. tha.. are .1,M.
norl4a =1dUq ..~t col1t81l2&t1011 .1t.. .. 1D41cat.d b1 data from the !P A
10nal GrOU114 vacar ...,p1y S.....,.y 1.. 1981 ....01 ...1081 ""lat1la o.,ank cII.1I1c:al. .uch
. .
1-~cII1o~t-, Ca=ac!I1oroatll1laM, ud 9i1lYl cII1ori4. -"* .t."ud 1Ja -cr (10)
.-
18UD1C1 ~tar -4_.1.. cue ..n8d &lao.t. 700,000 no~1c11aUl
1A 1)unJ. Co'tlq (JacUoariJJ,a) alOI1. ~ c1t7 baalth cIa,a~l1t ..t1ut.. th8~8 ara .
r.
f1f~ (50) . laDd!11la; 16-18 _loa j,ddt1f1ad by lo...t1o", ud oll1Y fou (4)
Ltl11D the c:1.,,'. .,...c .. ..u....ad. .......... laDd!11la 1Ja INft1 Cou." - only
'tb8 tnth 1.... ch.~. '. DO way of
alA u,t by tba d~ SA cb8 put teA (10) ,.an.
:Dowi~ .
,
--- ..u I'll ...", iadUiUT - 811Łtazi ..._...ud - ... oltC1al ... cop of .
noriU" 81&1 18 .-=-.11 porau.
.w U1a co tba SAc:~8&l1D1 aount. of
~
.'-
t188 ~bl .
ft8 l'r.~ - - acUtIII~ -uDI dIG.. wbo ODDf~ODt dI8 pubUc: .... co - 011. of
iAdiff- - .. "'S ~_c ... petta ,.",,1.1 ,.., foa: tD4a7'. "'....... , Uf-."la.
. " .40
A8 a dc~ia. t ..-.. ,.....Ch8 pri~ 18 too.' bilhl
IDt.~..C aDd fear 8%8 tWO fore..
u.t ,.uta ~
CWO-'Cep... .CU~ daa lack at f.cU.q aac:a"8%7 co 18111 =l1t~ol of pollut1011 even
ch~P cbGU&D~'IIDI".... _oka', 'aM 40=-I1U ~d.Dforc:a 08 fur....aDd, SA ~"I1C'.
AU088 tba. aat1011 uu1e&D8
8%8
U111t1D1' . . t1rec!
of
poUt1caJ.
8%8 .1~11ec!--- coat111DOU cI1ft...rcS for ~~. ==-~,;;t::: ~! ht.J1MD 11..a.
tat'" .t111
...u- 1Ja tb1l - aac:1OD. 118 c- yooa foa:.'" ""poR...u.'" co .,.ak.. .aad ,.ay tho
our c"c18DCT ~ fa11aA ~!'Oa
-de&! ..n-.
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APPENDIX 8
Respons iveness SUrmary
"
-.
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U.S. EPA REGION IV
HIPPS ROAD LANDFILL SITE
RESPONSIVENESS SUMMARY
DOCUMENT NO.:
"
. -. , :......... I
, I :
j,""-:" .":" : '.
,
. I. I..
. .1'/ .' \...,. ~
, . -...... . -
- '- '...J ."'.
. .',' :-......- 1-:..
... ""-' .....: '.... -
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TABLE OF CONTENTS
Executive Summary.....................:......... . . . . . . . . . . . . . . . . . . . . . . .
Comments and Responses
Deficiencies in Recommended Alternative................... .........
Inadequacies of Health Assessment.......................... ........
Excesses of Recommended Alternative... .,...........................
Insufficient Data to Show Connectlon Between Landfill and
Contamination[[[ .
(;nkno(,,'n Contaminants.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Quality of Public Involvement Process and Reports,.................
Spread of Contamin~tion Cnknown..........:...... .,..........,... ...
Re locat ion of Res idents. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Local -ater Runoff. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . , . . . . . . . . . . . . . . . ,
Ground-Io'ater Flo(,,'. . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . , . . . . . . . . . . . . . . . . .
(;se of Innovative Technology....... .',.,........."..........,....,.
(;se of Cost Criteria.........o'("""'" . . . . . . . ., . . . . . . . . . . . . . . . . . . .
Safety of ~ew ~'ells.... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Responsiveness to Risks of Landfill.......... ..........,..... ......
Capping Local Wells...............,................................
Inaccuracies in RI and FS.. . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . .
Department of the Savy's Recognition of Seed for Remedial Action...
RCRA App 1 icab i 1 i ty. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Air Stripping................................... ',\' . . . . . . . . . . . . . . . . .
JacKsonville waste Water Treatment Capability............. .... .....
Effectiveness of Ground-water Extraction Procedures.......... ......
Appendix 1 - Source of Comments.... . . . . . . . . .'. . . . . . . . . . . . . . . . . . . . . . . . . . .
Appendix: - \ames and Addresses of Commenters........ ............. ....
?~:t~
.:.
."
., ,
-.
36
~8
50
56
58
61
63
67
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EXECUTIVE SUMMARY
HIPPS ROAD RESPONSIVENESS SUMMARY
1.
!~7RODcc-:-rG~
The Public Comment Period on the Hipps Road Remedial Investigation/
Feasibility Study (~ay ;-28, 1986) began with a public meeting held on ~av ;
at the ~ebb ~esconnett Branch of the Jacksonville Public Library. .
Approximately ninety residents attended the meeting. which lasted from ; p.~.
to 10 p.m. During the Public Comment Period following the meeting, the C.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 responses to them comprise the first part of the
Respons~veness Summary. The second part is the official transcript of the
public meeting.
"
This Executive Summary lists .a11 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 connection between the landfill contents and the
contamination of local wells has not been sufficiently
established.
The r8881D1na areas of concern that received fewer comment letters
included:
.
Cnknown contaminants;
Quality of public involvement process
Spread of contamination unknown;
Relocation of residents;
Local water runoff;" .
Ground-water flow;
and reports;
.
.
.
.
.
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-
. Use of innovative technology;
. Vse of cost cri~eria;
. Safe~ 91 1i.., we Us;
. Responsiveness to risks of landfill;
. Capping local wells;
. Inaccuracies in the RI and FS;
. Depar~ment of the \avy's recog~ition of need for remedial
. RCRA applicability;
. Air stripping;
.. Jacksonville waste water treatment capability; and
. Efiec~iveness of ground-wa~er extraction procedures.
ac.ti.on;
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 commen~.
I I. ~IAJOR COSCERSS AND EPA RESPO~SES
"
A. INADEQUACY OF RECOMHE~DED PLAN
Comments in this category specifically criticized the recommended plan for:
.
the use of a clay cap, since the technology is not
sufficiently reliable;
-I
.
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
wha~ever remedy is selected will fully clean up the site according to the
dictates of ~b8 National Contingency Plan. Specific EPA responses were: if a
cap is used ii will be used along with other measures; it is not feasible to
excavate tbe 8011 to remove the contaminants; the solution will control
contaminatioa ~hr.ats to the ground water; and that soil contamination is
addressed in the B group of alternatives.
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-3-
B. EXCESSIVENESS OF RŁCm1~ESDATICSS
~!any COIIID.n~s from the Department of the ~avy and:
stressed th~. re~ommended plan ~as tOO extensiv~.
.ground-~ater extraction and restorat:on of the ground
standards is unnecessary.
~aste Control of Florida
In partic~lar,
water to dri~klng ~ater
EPA's response is that the ground .ater in this area is a potent:al
drinking water supply and extraction may be necessary ror 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. r~StrFICIE~L DATA TO SHOw COS~ECTrO~ BETWEE~ ~~DFILL A~D CONT~~ISATED ~ELLS
~aste Control of Florida provided several comments saying that the RI
procedures ~ere 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 ~hat it was a significant source. In
addition, while investigating other potential sources of contamination does
fall ~ithin the purview of the Superfund program. it is not within the scope
of the Hipps Road RIfFS.
D. HEALTH RISKS
Residents were also concerned that the health assessment minimized the
tr~e exposure risk and did not consider very sensitiv~ populations, other
potential pathways of exposure (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
contaminatiaa to safe levels. Third, the human body has its own complex
methods of riddinl itself of the major contaminants of concern. Furthermore,
there is not enouah information or scientific knowledge to evaluate many
synergistic .ffec~s and hypersensitivities.
The next section contains the written commen~s 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 l.~
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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 ~ill remain at risk.
Response:
During the Public ~eeting held for discussion of the Hipps Road Landfill.
Feasibility Study, a concerned citizen questioned EPA about the remedy being
proposed for this ~PL site. In response, the audience was told that EPA ~as
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-wat~r 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 ~ater supplies in actions conducted by both the City of
Jacksonville and the ~.s. EPA. If the landfill is covered by a protective
cap. the threat posed by contact with landfill contents will also be mitig3ted
by placing a barrier between the landfill and the public.
-I
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-) -
DEFICIENCIES IN RECOMMENDED ALTERNATIVE
*'"
Source of C~.....t
2
Commen t :
E?A has recommended [at the public meetingl the use of a clay cap to
contain the site. Clay caps ~ill not suffice as a permanent solution and
historically require large levels of funding for repairs and maintenance.
Resoonse:
EPA has not finalized any recommendations for remediating the Hipps Road
Landfill site; recommendations ~ill be presented to the EPA Regional
Administrator who will ultimately decide on the desirability of the proposed
remedy. The Feasibility Study has projected present worth costs for all
remedial alternatives which were found to be feasible for this site. Capping
the landfill was estimated to cost approximately 51.5 million to implement and
maintain for 30 years., along with ground-water monitoring. This is one of the
most cost effective measures available for this site. However, EPA does not
feel that a cap alone will provide adequate protection for human health and
the environment. therefore the cost of the final remedy will probably be much
higher. .
~
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-" -
DEFICIENCIES IN RECOMMENDED ALTERNATIVE
Source of Comment
2
Comment:
Given the geological (crater-like) condition of the site, a clay cap ~ill
a1so settle. crack, and leak.
Resoonse:
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 surf3ce. This would prevent settling. Any cap will
require continued maintenance to prevent dessication cracks and erosion. If
EPA were to select this option 3S part of the remedial response for the Hipps
Road Landfill site, provisions for maintaining the cap would be arranged prior
to final selection.
-I
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DEFICIENCIES IN RECOMMENDED ALTERNATIVE
#
Source of C_-_t 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 later in wildlife, money, proper~y, and the well-being of human
life.
Response:
Landfilling waste materials is, at best, a marginal technology. However,
the wastes. generated in this country are primarily disposed at landfills.
Technological advances have been made which improve the quality of landfilling
operat-ions, but further improvements are still necessary. Until the volume of
waste generated is reduced significantly. landfilling will probably continue
to remain the.primary feasible solution.for disposal of municipal wastes. If
EPA determines that the Hipps Road Landfill wi)l 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.
-'
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-3 -
,DEFICIENCIES IN RECOMMENDED ALTERNATIVE
. Source of ColIDIfen1:
2
Comment:
Csing a cap for the slow do~n of percolation in no way qualifies as
containment. In addition, lateral and vertical flow of the ground ~ater ~s
not restricted in any way, thus allowing continued contamination of :he ground
~ater.
Response:
The purpose of a cap is three fold:
1.
It does reduce the downward m:gration of wa1:er from
the surface through the fill material;
.,
8'
It significantly reduces the possibility of anyone on
the site contacting contaminants that might be exposed
1
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
~il1 continue, but there are mechanisms evaluated in the Feasibility Study
which are capable of dealing with this. If ŁPA chooses to cap the landfill,
these additional actions would necessarily be included.
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-:;-
DEFICIENCIES IN RECOMMENDED ALTERNATIVE
Source of CCJ1IIIL..uL
10
Commen~:
Several EPA al~ernatives (Alterna~ives C-2 and C-3 from ~he FS) ~ould
result in the use of a surface cap ~ithou~ any further containment or remov~l
effor~s. This would have little, if any, effec~ on con~rolling migra~ion from
~he si~e. Ground wa~er could easily move la~erally below ~he cap and pick ~p
con~aminan~s, spreading ~hem away from the si~e. CD~ [EPA's con~rac~ors for
~his project) expressed this same concern (FS, p. 2-20). This s~ep alone
provides inadequa~e pro~ec~ion and ~ould be ineffec~ive"
~one of ~he firs~ five preferred [remedial] op~ions address con~aminan~s
in soil. Ground-water extrac~ion (Al~ernat:ve A-4) would only remove water
soluble chemicals and would no~ remove chemicals presen~ in the soil. As a
resul~. chemicals would con~inue ~o leac~ in~o the ground water at a very slow
ra~e for years.
Response:
All remedial alternatives ~hat were found to be feasible were presen~ed in
Table 5-1 of the draft Feasibili~y Study. This ~able is a liSt of
al~ernatives which can be used to remediate ~he Hipps Road Landfill, and the
final remedy selected for ~his site may encompass any combination of ~he
alternatives presen~ed in Table 5-1. The al~ernativ~s which have ~he initial
letter "An address remediation of the ground-water contamination. Those
alternatives with the ini~ial letter "s" deal wi~h remedia~ion op~ions for the
landfill. Finally. the alternatives with a "c" designa~ion address "o~her"
considerations. EPA has never indica~ed tha~ consideration is being given to
implementing any "c" op~ion by itself, and no such remedy will be recommended.
The "first five preferred [remedial] options" include four options which
treat ground-wa~er contamination and the fifth op~ion (B-1) eliminates
leacha~e production. The compounds which en~er ~he ground water are wa~er
soluble, by definition, and would effectively be recovered" in a ground-water
recovery sc~io. Contamination in ~he soils is fully addressed by the group
"B" remedial alternatives.
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- 1,- -
...
DEFICIENCIES IN RECOMMENDED AL TE,RNA TIVE
...
Source of ~~nt
10
Comr.tent:
All three Group C Alternatives are inappropriate as cleanup alcernacives
because none addresses the problems of contamination at the sice. Alcernat:ve
C-l - no action - is clearly unacceptable. C-2 - landfill closure and
monitoring - calls for capping the site, meeting the Florida Depar:men: or
Environmental [Regulation] closure regulations, and not using the COntaminated
ground water as a drinking ~ater source (see FS, pp. 3-33 to 3-37). ~hile
these steps may be helpful. the site has already failed, leaking contaminants
into the community. A closure plan ~ill not address these problems and is
inappropriate for this situation. Alternative C-3 calls for using
"institutional" controls such as installing '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 iq the landfill will not migrate
(a completely false assumption - it already has). and that there will be
closure of the site. Again. nothing is stated1about cleanup either on- or
offsite. ~one of these alternatives should be considered and each should be
dropped from the report.
Response:
Alternative
remedial Option
300. 68'CF) (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
~ sufficient by themselves. and EPA has never indicated any inten~ion 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-2. combined with other remedial
actions, is . feasible alternative which complies with the mandates of the
Sational Coatta,ency Plan, under which Superfund operates. Therefore.
Alternative C-2 will also remain part of. the Feasibility Study.
Finally, EPi and its contractors never stated that these alternatives
~ould 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 would be eliminated.
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, .
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DEFICIENCIES IN RECOMMENDED AL TERNA TI VE
Sou~=e of Comment
1 - ~
01 ..
C.:::mment:
The ~ecommended plan [at the public meeting] does not add=ess 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-site ~orkers. In addition. both options were found to be prohibitively
expensive in the cost-effectiveness analysis. The National Contingency Plan,
under which "Superfund" is implemented, nquires that applicable technologies
be screened in terms of technical feasibility, -level of protection provided to
the public and environment. and relative cost ~ffectiveness. The two options
cited above can potentially present a risk to the public and are not cost
effective, and ~ere therefore eliminated from further consideration. The
remedy ~hich EPA selects ~ill satisfy all criteria mandated by the Sational
Contingen~y Plan.
~
.
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- -
DEFICIENCIES IN RECOMMENDED ALTERNATIVE
Source of C_--_Rf
2
Comment:
A remedial action at this site must be a permanent solution whi~h will not
require additional expenditures, and which includes a complete aqulfer
cleanup. A plan for remediating this site must address onsite containment ~nd
.restrict the lateral flow of ground water or remove contaminants.
Resconse:
Cnder the \ational Contingency Plan. remedial actions are" those
responses to releases that are consistent with a permanent remedy to prevent
or minimize 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 remedial' 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
~ith the ~ational Contingency Plan and the Comprehensive Environmental
Response. Compensation, and Liability Act (CERCLA). and in accordance with the
known site specific conditions.
.,
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-i3-
DEFICIENCIES IN RECOMMENDED ALTERNATIVE
Source of Commwftt
1 & 3
Comment:
The recommended plan [at :he ?ublic 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.
Resconse:
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 .contentswas not found to comply with
all mandates or the ~ational Contingency Plan. Therefore the selected remedy
will inherently have provisions for maintaining the integrity of the remedial
actl.on.
-I
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INADEQUACIES OF HEALTH ASSESSMENT
. Source of C:oiIiDent
'2
Commen,;:
The total health assessment ~ithin the Feasibilicy Study ~as used to
minimize the ~ exposure risk.
Response:
This comment is unjustified and unwarranted. The major source of concern
at the Hipps Road Landfill site ~as 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 :his site. These works were pro~uced with the utmost integrity
from legal, scientific. and technological perspectives. The findings may not
please public reviewers, but the veracity cannot be questioned.
.1
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- : 5 -
>.
INADEQUACIES O'F HEALTH ASSESSMENT
Source of C~ 2-
Comment:
EPA ~ assess past exposure [of the Hipps Road area residents to :he
contaminants] in order to prepare an assessment of potential future health
risks.
\0 assessment was performed to address the effects of the contaminants
found at Hipps Road on unborn children. newborn children, or the elderly.
Resoonse:
The main 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.
-.
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INADEQUACIES OF HEALTH ASSESSMENT
Source of Comment
2
Comment:
Citizens may con~inue ~o be exposed to contaminants ~hat may have pe~vaded
household items such as water heate~s or water softeners. So assessment of
this potential has been ~ade.
Resconse:
\0 assessment of this exposure route is warranted. Once the source of
contamination (ground water) is removed, the exposure ceases. Volatile
organic compounds will rapidly volatilize off or degrade. The length of ~ime
since the exposure has ceased has been too ~ong for VQC's to still pose any
significant threat.
-,
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-
. .
INADEQUACIES OF HEALTH ASSESSMENT
..
Source of Ca~--t
2
Comment:
During the public meeting, citizens were told that the body naturally
cleanses itself of the chemicals found during the Hipps Road landfill Remedial
Investigation. Research disputes th~s.
~o consideration was given to household uses, such as showering or ~ashing
dishes, or ~ater containing the compounds found at Hipps Road. Nor is there
any plan to address these Cl=cumstances.
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. w~ile this is not always true with exp~sures 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 ~ould 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 ~arrant concern about dermal exposure and absorption.
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- ~a-
.INADEQUACIES OF HEALTH ASSESSMENT
Source of COiIen~
2
Comment:
It appears that throughout ~he 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 ~ith
long term exposure. There ~as also no presentation of the (synergistic I
effects of various contaminants, although it is reasonable to assume that the
presence of any toxic chemicals in any combination increases the total heal~h
risk.
Response:
A health risk is determined and assessed by three factors; all of which
mus~ be present and "operating" in a dynamic fashion, over time. These
fac tors 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 voe's and
metals were ~ 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 path~ay for exposure was identified, it ~as eliminated by
the extension of the city wa~er lines.
Very ll~~l. is known about synergistic effects, especially since at least
60 separate C08pOunds were identified a~ this site. Science is unable to
assess synerI1.~ic effects of multiple substances and varying concentrations.
Research h.. .hewn synergism can result in additive and negative effects in
re~earch ;;t~inls. It's virtually impossible to extrapolate this to human
exposures -- especially those that are retrospective.
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-:~-
INADEQUACIES OF HEALTH ASSESSMENT
C'
Source of C~-,t
2
Comment:
Indicator compounds used in :he Feasibility Study are
corresponding :0 the mean concentrations found during the
Investigation. However, this precludes the consideration
caused by episodic high exposure levels.
assessed at levels
Remedial
of the effec:s
Resoonse:
Csing 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. Sone 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 ~hat is now 0011y an anecdotal issue.
.,
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~ ~
- .-
--
'INADEQUACIES OF HEALTH ASSESSMENT
Source of Cd~
2
Comment:
~o assessment was made to determine if the compounds found at Hipps Road
could cause people to develop sensitivities ~hich could be aggravated by
future exposure to trace levels of organic compounds or metals.
Resoonse:
CDC/ASTDR has determined that dn assessment of this nature cannot be
conducted. Such hypersensitivities have been found to develop from other
causative factors or agents, such as high occupational exposures. They have
not been found to develop from the consumption or use of water contaminated
with the relatively low concentrations of volatile organic compounds and
metals that were found at the Hipps Road.Landfill.
~
.,
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-::-
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of C6--_ftt
s
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)".
~e find no basis for this conclusion in the underlying reports. Indeed.
the statement is inconsistent ~ith both the "cleanup goals" at pages 1-27 to
1-28, and the 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 S 300.68(i)('l)1 Although there are
some exceptions outlined in 9 300.68(i)(3), none are applicable to the Hipps
Road Landfill. The surficial aquifer, within the site area, is a potential
drinking water source and as such, drinking water criteria are applicable.
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. -~~-
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of Co~ent
9
Comment:
The Remedial Investigation concludes that ground-water contamination will
discharge in nearby surface ~aters at levels that would be in compliance ~ith
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 provides 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.
~
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,~
--~-
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of Co~~
8
Comment:
The Remedial Investigation and Feasibility Study state that the
contamination of the ground ~ater at Hipps Road creates a hazard should that
~ater 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 ~ater
source, then there is no need to achieve or maintain drinking water standards
of purity in the ground ~ater.
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 vicinioy 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.
~
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-2--
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of C~~
8
Comment:
The Remedial Investigation concludes that ground-water contamination ~ill
discharge in nearby surface ~aters 3t levels that would be in compliance ~l:h
applicable state and federal regulatory standards. The municipal water s~pply
has been extended to the residents in the Hipps Road area. Accordingly,
extraction of ground water berore 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.
~
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-:3-
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of c_......~
C}
Commen'::
~any of the remedial alternatives proposed in the draft Feasibi~it) Study
are not appropriate because: (1) the ~ells where chemicals have been detected
are not used for human consumption; (2) public water is available to all ~ell
owners; and (3) the contamination found in ground ~ater 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 haz~dous waste site. For this
reason, EPA feels that all preferred alternatives listed in the Hipps Road
Landfill Feasibility Study are applicable and feasible.
-,
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-:6-
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of C~an~
8
Comment:
The implementation of a closure plan, providing for additional ear~h
cover, continued monitoring for an expected period of up to 30 years,
institutional controls to inhibit excavation, drilling, and the use of ~ells
in the contaminated zone, as well as relocation, if needed, of homes affec:ed
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 =isks ~o 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 ~ust be made clearly supports
this resolution.
Response:
The remedial action alternative described was discussed at the public
meeting held on ~ay 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 d~ta 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.
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- ' --
- .
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of C...
1A'
8"
Comment:
The cost associated .ith extraction and treatment are a significant
increment over other, more conservative, remedial actions. Table 5-2, whic~
summarizes the alternatives and costs for treatment at Hipps Road, indicates
cOSts ranging from 56.3 to 512 million for the variety of technologies
available to treat ground .ater. All of these options assume. no removal of
the ba$ic 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 4-3 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 projection. Table 4-1 seems to limit
the projected O&~ for ground-water treatment to one yea~, 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.
Resoonse:
The ground-water scenario portrayed above is an accurate description of
that .hich was used for cOSt estimating purpo~es. 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 additioD, several more detailed evaluations are being conducted in
order to addz... scenarios in which there are further releases of contaminants
to the ground V.~8r. These additional evaluations will address contingency
needs to re-8CC1vat8 ground-water recovery systems, if necessary after an
initial recov8ry action.
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-:3 -
EXCESSES OF RECOMMENDED ALTERNATIVE
Source of e
lift
9
Comment:
While a connection bet~een the Hipps Road Landfill and
adjacent wells has not been established, it is appropriate
remedial measures that ~ill ensure that public exposure to
minimized or eliminated.
contamination in
to consider
the landfill is
Our review suggests that the follo~ing remedial measures are appropriate:
1
1.
Conduct additional investigation and monitoring to identify all
sources of conta~in~~ion in :~e area and verify predictions
regarding contaminant levels in the ground water;
2.
. Seal all private wells which indicate contamination; connect tbe
property owners of sealed wells,into the municipal water system;
3.
Repair the existing cover of the landfill and maintain it as is
necessary to provide a physical barrier to accidental exposure
to contact with the landfill contents;
4.
Install a series of institutional controls. including fencing,
cautionary signs and deed restrictions, which would prevent
future use of the landfill site; ~
5.
Consider relocating persons residing on or within the landfill
boundaries.
Implementing these recommendations will protect human health and the
environment by removing direct exposure to contaminants via the surface of the
landfill. and by eliminating access to contaminated ground water. [These)
proposed measures will ensure that any future releases of contaminants from
the landfill can be handled in the most effective way.
Re!'iponse:
Taken .. . whole, the combination of alternatives outlined above, is not
sufficient. The existing cover for the landfill consists of a permeable sand
layer which is thin, discontinuous, and affords no protection from dermal
exposure. In addition. there is no protection of ground-water resources in
, the area. Additional investigation of potential sources of, ground-water
contamination in the area.a~e not within the scope of this remedial response;
site discovery is a separate action under CERCLA.
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-2'1 -
,EXCESSES OF RECOMMENDED AL TERNA TIVE
Source of Co~
9
Comment:
The Feasibility Study ident~:ied 11 different remedial action alterna:i,es
or combinations of those alterna:ives. Based on the ranking of these
alternatives. as well as discussions held during a public meeting on ~ay [7].
1986 in Jacksonville. Florida, it appears that EPA's preferred alternatives
are: (1) ground-water extrac:ion and treatment and/or discharge for a period
of one year; and (2) construction of a closure cover over the site. In
addition. SPA 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 Landfill
site. The proposal will be made when a Record of Decision (ROD) is submitted
to the Regional Administrator. The remedy serection is approved when the
Regional Administrator signs the ROD.
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 closeo 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 ~ver the landfill, there is ample
justification for this decision.
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- ;iJ-
. .
EXCESSES OF RECOMMENDED AL TERNA TI VE
Source of C~~~~
8
Comment:
There is no significant risk of surface ~ater contamination associated
~ith a failure to undertake extrac~ion and treatment of the ground ~ater a~
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
pr~dicts that contaminated ground ~ater is not expected to discharge into ~he
unnamed tributary of the Or~ega River near the site for at least seven years
~ith maximum concentrations entering the tributary within 25 years. The
maximum concentrations released into the surface waters are estimated to be
less thanO.i ug/l, 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
~aters 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 ug/l,
presently the most stringent water criteria."
It is important to note, of course, that surface~water in this area is not
used as a source of potable water, and any ingestion could be expected to be
occasional and not systematic.
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 h.alth threats posed by surface water contamination are minimal,
as are envlr0D88ntal 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. .
, .
"000. - .
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- 3:-
. -
EXCESSES OF RECOMMENDED AL TERNA TIVE
Sou~ce of Commen~
8
Commen'::
The Feasibility Study raises risk concerns in several categorles ot~er
than ground-~ater hazards. These can be summarized as minimal rlsks of
ingestion of. or dermal contact ~ith. contaminated soils or surface ~~ters.
This includes a concern that heavy rains or o~her accumulations of water ~ou~d
create "ponding" of surface waters containing hazardous levels of COntamlna:'.':s.
It is the \avy's position that these problems are significant if no
closure or monitoring is conducted--an option tha~ we do not suppor~. 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. -
1
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 contam~nants by vegetation offsite. See A-25, FS.
The Feasibility Study also expresses some concern that the contaminants
~ili migrate downward into the limestone aquifer, thereby endangering that
"more highly used" ground-water reserve. 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 ~hich the report refers is not the deep Florida[n] aquifer upon which so
much of Florida's ~ater 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 or clay.
The smaller limestone aquifer identified at Hipps Road is located at a
depth of more than 70 feet and is isolated from the shallow aquifer by a layer
of clay of ai.continuous sandy and plas~ic properties. This semi-confining
clay layer, at monitoring well 21, indicated a hydraulic conductivity of 5.7 x
10-5 ft/day (1.0 x 10-8 cm/sec); these ligures 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
to~ard the northeast. the djrection of the gradient in this area. As waters
move through the clay at this v~ry slow rate, they discharge into the
limestone aquifer, through which a volume of more rapidly moving waters are
passing. Thus the waters moving int~ ~he lim:~~.-' ,~~~ -~~ougri the
seml-confin~ng clay layer are subject to. significant dilution, as wftll as
attenuation of contaminants due to the adsorption of elements by the clay.
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-;--
The cop~aminant levels identified in the limestone aquifer do ~ot suggest
a greater overall risk in this aquifer. once local ~ells are c~ntr~i~ed and ~o
longer used tor drinking. The added cover material contemplated by the
closure plan w1Ulalso reduce the vertical ground-water movement thr~ugh the
landfill. ?qr4-26. FS.
Resoonse:
EPA concurs with the posl:ion 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 limest~ne unit
is misleading. Hydraulic conductivity is the rate at which a fluid will pass
through a medium. but other factors must be considered ~hen 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 typi~: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.
.,
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-.:.~-
EXCESSES OF RECOMMENDED AL TERNA TIVE
Source of Commen~
8
Comment:
The draft Feasibility Study recommends the installation of 20 extraction
wells with the withdrawal rate of 10 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 problema~ic 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 ~ould be to discharge the ,extracted ground water to a POTW
operated by the City of Jacksonville. However, the nearest POTW is over two
miles a~ay and is not connected to the Hipps Road site by sewer. This means
that over two 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
600 of its projected upgrade capacity. .
Since araaad water contains only low levels of contaminants and withdrawal
and treatmeDC of around water may not remove all of these contaminants, the
efficacy of around-water withdrawal and cleanup must be questioned. ~oreover.
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
~he potential for. future exposure is minimized.
Response:
An extensive study was conducted to develop a feasible ground-wate~
recovery scenario (Appendix C-Z. FS); the'scenario as outlined is realistic.
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-.;--
EXCESSES OF RECOMMENDED ALTERNATIVE
The remedial value of pro~ec:ing a po~en~ial ~a~er r~source is obvious. EPA
. is 'a~are ~~ery of curren~ ly con~amina~ed g;-ound ~a~er :Jould not
address ~hrea~s posed by poten~ial fu~ure releases. If ground-water recovery
~ere implemen~ed at the Hipps Road Landfill si~e. the design would include
moni~oring ~o detec~ future releases. 1f releases do occur. the recovery
system. ~hich ~ould remain ir. place. ~ould be reac~iva~ed.
Discharge ~o the Or~ega River system was no~ presen~ed as a pr~ferred
remedial op~ion. However. if i~ ~ere ~o be recommended. EPA would ensure :hat
violations of Class 3 wa~er Quali~y Cri~eria would not occur. EPA con~racto~s.
have already met ~i:h City of Jacksonville Public Works Officials. The
expanded capacity of the nearest POTW will be completed prior 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 ~o be feasible. This is fully discussed in the Hipps Road
Landfill Feasibility Study. . .
~
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-35-
EXCESSES OF RECOMMENDED AL TERNA TIVE
Source of Commen;'
9
Commen~:
The draf~ Feasibili~y Study iden~ified t~o alternatives to control surface
exposure a~ ~he landfill si~e. One alternative involves installation of a 101.0;
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 permeabili~y cover is not justified. while the predominant
t.;a~er flow direc~ion ~hrough the soils underlying the site is vertical, a low
permeabili~y cover over ~he landfill will not hydraulically isolate ~he unit
from the ground water flows. The site lies between areas of higher elevation
and is. therefore, as has been previously no~ed. a localized recharge zone.
In addition, some of ~he landfill con~ents are apparen~ly located within a
water table zone. Therefore, the installation of a low permeabili~y cover
will have 1i~t1e impact on ~he ground water exposure to the contents of the
landfill. These fac~ors sugges~ that surface ~ctivity is warranted ~o 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
al~ernative. The existing cover is a highly porous, 1005ely 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-~ 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 in~egri~y barrier between the landfill contents and nearby
residen~s and the surface environment, and 2Y to prevent additional
contaminants from reaching the surface environment through infiltration from
ra~nfall events. while a cap will reduce infiltration through unsaturated
soil, it I.o;ill not decrease lateral migration of ground wa~er 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
ra~es by reducing the ground-water mounding attributable ~o the landfill.
-------
-;0-
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of C.AIWh_..t
9"
Comment:
Seither the hydrogeologic fi~dings 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 wells.
ResDonse:
The Remedial Investigation did not presume that the landfill was the only
source of contamination. 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.
~
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- j. -
INSUFFICIENT DATA 'TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of. C0m8.n~
9
Comment:
The princ.ipal 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.
ReSDonse:
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 3 existing (USGS) background wells. A total
of 64 wells were sampled. Some of the background wells revealed the presence
of low levels of contaminants. This .as 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 downgradien~ was larger than the
suite present in background wells, and had a ~ore variable composition. EPA
does not question the fact that the Hipps Road Landfill has significantly
impacted ground-water resources within the area.
~
. .
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-35-
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
. LANDFILL AND CONTAMINATION
Source of C~~
9
Comment:
Given the poor correlation between landfill contaminants and contaminants
measured in the wells, the [Remedlal Investigation) should include an
investigation of other potential sources of contamination. However, no such
investlgation was conducted. There may be many sources of contamination of
the adjacent wells and the landfill may be only a minor contributor.
Resoonse:
The scope of the Hipps Road Landfill Remedial Investigation was to
investigate 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 th~ although the site is not-the sole"source of contamination, it
is indeed a significant source.
~
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- .....-
INSUFFICIENT DATA "TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of Comment
9
Comment:
The hydrogeologic da~a combined ~ith the loca~ion
significantly cont3minated samples at wells E~'-2 and
not demonstra~e that the [Hipps Road) landfill is the
contamination.
from which the
E~fIi-3 were obtained does.
sole source of
Response:
TIle hydrogeologic data indicate that thc" wells from clusters EMW-2 and
E~~-3 which are screened in the 50-60 foot zone are positioned to receive
contamina~ed ground-water flow from the Hipps Road Landfill. Although this
does not prove that the landfill is the. 501e source of con~amination. it does
demons~rate that the landfill is indeed a sour-ceo
.\
-------
--v.
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 ~US Corporation as part of the
[Remedial Investigationj Report. The electromagnetic surveys indicated :~o
hot spots, one southwest of the Hipps Road Landfill site immediately across
Hipps Road, and the other in the immediate area of wells E~-2 and E:~-3.
Resoonse:
SUS Corporation 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. ~o analytical data from cluster ~ells in that vicinity account for
these readings. However, clay zones which wer~ 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.
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-.1-
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of Comment
9
Comm~nt:
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. ~any 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-s~te locations were not also found in the landfill samples.
For example, E~N-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 ~ompound 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 uni~ at EMW-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 product 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
r~lease 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
concentratioD8 below detection limits). Finally, as stated in the Remedial
Investigattoa Report (p. 10-1), some of .the compounds found offsite may be
derived fraa.OCher 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.
-------
----
INSUFFICIENT DATA .TO SHOW CONNECTION BETWEEN
. LANDFI LL AND CONT AMINA TION
Source of Commen~
9
Commen~:
The analy~ical da~a from ~he ground-wa~er samples shows ~ha~ the~e is an
area of significant contamina~ion nor~heast of the site. This area includes
wells E~~-2 and E~-3. The analytical da~a obtained from samples at E~~-2 ar.d
E~~-3 indica~e the contamina~ion to be present within and throughout the
aquifer (sample depths 10 feet, 33 feet, and 80 feet) with higher compound
concentrations in the lower of the sand unit (53 to 63 fee~) and in the
limestone unit.
Response:
The analytical data from ground-water samples show that there is an
of significant con~amination nor~heas~ of the si~e. This area includes
clus~ers E~~-2, E~N-3, and E~N-6, at the .30-60 foo~ depths. There are
virtually no contaminan~s in ~he 10 and 80 fooi wells in the same well
clus~ers.
area
well
~
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--3-
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of C:..._aJu
9
Comment:
The [Remedial Investigation] =epor~ implies lateral flow from the landfil~
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 ar.d
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-i and 6-11, RI Report).
The report is not biased because arthough there are several (9) wells
northeast of the site, there are more wells (24) to the east, south, and north
of the site.
-1
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-...-
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of Ccmment
9
Comment:
A~ E~~-3 only one compound was iden~ified 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
iden~ified in the limes~one uni~, only one was also identified in the
landfill. These low correla~ions do no~ demons~ra~e tha~ the Landfill is no~
the source of organic contamination a~ these wells. However, the existenc;-Of
so many compounds a~ the wells which were not also found in the landfill
indicates the exis~ence of other sources of contamination.
Response:
EPA agrees that the Hipps
ground-wa~er con~amination in
is no doub~ that ~he landfill
Road Landfill is not the sole contribu~or of
the local area (RI report, p. 10-1), but ~here
is a major source of contamination.
.,
-~.- -- .-.-
.'
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-...,)-
INSUFFICIENT DATA' TO SHOW CONNECTION BETWEEN
LANDFILL AND. CONTAMINA TION
Source of Comment
9
Comment:
The [Remedial Investigation) ignored possible explanations for problemati~
samples. For example. ~he construction of the bore holes indi~ates 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 ~ith 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 ~emporary 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 3.300 ug/l), ~hich could account for the level of lead in the
private well. ~
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--C.
INSUFFICIENT DATA TO SHOW CONNECTION BETWEEN
LANDFILL AND CONTAMINATION
Source of Comment
9
Comment:
Only one sampling event occurred and the samples taken were
contrary to commonly accepted sampling procedures. This raises
as to the extent of which metal ions, particularly arsenic, are
present in solution at such high concentrations.
not fil:ered.
the question
actually
Response:
Several ground-water sampling locations used in the EPA investigation have
also been used before. ~ost significant were wells E~-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 ~ay 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 ~anual mandates
that the ground-water samples collected in hazardous waste site investigations
remain unfiltered.
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-.. ' -
INSU'FFICIENT 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-~ater samples. ~hile zinc, cyanide, mercury, cadmi~m,
lead and arsenic were identified in samples taken from bore holes drilled i~
the landfill, there is 00 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.
Resoonse:
The metal compounds (FeO. FeS, etc.) are not commonly determined for
samples sent to the CLP. and although pH.was determined for the borehole
ground-~ater samples. it is of little value i~ 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 ~he
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 lo~er 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.
Do~ngradient. 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.
-------
--3-
UNKNOWN CONTAMINANTS
Source of ~---A~
.7
Comment:
EPA's consultant indicated that most of the rusting and therefore release
of toxics to ground water has reached a peak. I argue with this because I
still can locate cans (with ~.S.~. ~), medicine vials, hypodermic needles and
such that appear in excellent condition. Based on this it is anyone's guess
when some unknown contalner may rupture in the landfill and release
contc1mlnants.
Response:
The scenario is a valid concern which EPA has realized and must be
addressed in the. selection of any remedial action. The remedy selected by EPA
will address this issue.
.,
-------
-':'3-
UNKNOWN CONTAMINANTS
. Source of C.ov--..f--
10
Comment:
The contents of the landfill ~ere not clearly established in the Remedial
Investigation report (FS, p. 3-1i). This makes it difficult to properly
evaluate the effectiveness of a cleanup alternative because you do not kno~
all the chemicals you are trying to clean up. while it is not practical to
expect to kno~ lOO~ of the landfill contents, enough must be known to feel
that you have got the "worst actors".
Response:
The borehole 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 si~e were sampled. and there is no
reason not to believe that the "~orst actors" have been identified.
1
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.
-.
-------
- -
. QUALITY OF PUBLIC INVOLVEMENT PROCESS AND REPORTS'
Source of Comme~
.,
..
Commen~:
EPA has chosen to ignore the real concerns of the public.
Resoonse:
~i~hin the jurisdic~ion of the EPA, under ~he requirements of ~he
Comprehensive Environmen~al Response. Compensation, and Liabili~y Ac~ (CSRC~A;
and ~he \a~ional Contingency Plan (SCP) , EPA has addressed ~he public health
and environmen~al concerns surrounding ~he Hipps Road Landfill site. Early in
~his projec~, through many forms of communication ~ith ~he Hipps Road area
residents, EPA de~crmined that ~he =esidcn~=.1 concerns appeared to focus on a
desire for more complete information about actions taken at the site,
enforcement actions agains~ potentially responsible parties, health issues,
ground-water contamina~ion. and deprec~ation.of property values.
EPA has responded to these concerns as follows:
1. Desire for more complete information about actions taken a~ ~he si~e.
From the beginning of this project, the JCACW president and spokesperson were
contacted by the Regional Superfund Community Relations Coordinator and
assured that the appropria~e regional technical, legal, and public affairs
personnel would be in contact with them throughout ~he project. An invitation
was extended to call or come to the regional offic~ at any time for
information on this project. Routine calls. meetings, fact sheets, and news
. releases have been ini~iated by EPA during the course of this project. This
information flo~ included the citizens of ~ipps Road as well as local and
s~atc 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 al~ernatives 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 tbe po~entially responsible parties and has been available to answer
questions bJ Che ci~izens both by telephone and at the public meetings.
3. Health issues. As part of EPA's extensive Remedial Investigation
and Feasibility Study, the EPA contrac~ors have developed a comprehensive
Public Heal~h Assessment. The Centers for Disease Control ASTOR office has
been involved since the inception of this project. ASTOR has reviewed all
data generated from the ijipps Road Landfill and have made their findings
available. In addition, EPA and the City of Jacksonville have connected ~ll
'.--- .._;-: :~'::::::-';..'.:.:~r. supplies with the municipal water supply
~,,, - _:.. . .." =smove the major exposure path~ay.
-------
-51-
.QUALITY OF PUBLIC INVOLVEMENT PROCESS AND REPORTS
~. Groundwa~er Con~3mina:ion. The findings of the si~e inves:i~a:ion
indica~ed con:aminatlon of nearby ground-water resources. The data has been
made available :0 the citizens through the informa~ion repository and by
directly providing reports to the concerned citizens group, Jacksonville
Citizens Against Contaminated Water.
5. Depreciation of proper~v values. The deprecia~ion 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. Priva~e parties whose property has depreciated in
value may pursue a cause of action for damages against parties liable for the
depreciation.
~
..
-------
-5:-
. QUALITY OF. PUBLIC INVOLVEMENT PROCESS AND REPORTS
Source of ~.b.._.~~
2 5& J. 9
Comment:
The public was allocated a very short time for review of the Fe~sibi~ity
Study and to submit comments.
Response:
The ~ational Contingency Plan. under Io;hich "Superfund" is implemented,
mandates that ft... feasibility studies that outline alternative remedial
measures must be provided to the public for review and comment for a period of
not less than Zl 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 provide~ to a local citizen's group
(Jacksonville Citizens Against Contaminated Water) for review 17 days prior to
the public meeting. Twenty-one days were allotted after the public meeting
for submission of comments. Under the ~CP. EPA could have extended the public
comment period if such a request had been made. The public comment period Io;as
conducted in accordance with the manner mandated in the National Contingency
Plan.
-\
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-33-
QUALITY OF PUBLIC INVOLVEMENT PROCESS AND REPORTS
Source of Co~t
2
C::Jmment:
The goals of a Remedial Investigation and Feasibility Study are to: 1)
identify the source of contami~ation; 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
goals.
Response:
EPA has met these goals. The landfill has been identified as a major
source of contamination (p. 10-1 RI Report). ~either surface water nor
sediments in the area were shown to be contami~ated by the site (p. 10-2 RI
Report). however. the extent of ground-wa~er 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).
-I
-------
-,)..-
. QUALITY OF PUBLIC INVOLVEMENT PROCESS AND REPORTS
Source of G3~Dent
3
Comment::
At: t:he Public ~eet:ing. the representat:ive from CDC [ASTDR) ~as
non-committal and unprepared. The manner in which he talked do~n to the
public ~as unexcusable.
Resconse:
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 ~ater 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 consult:ant. ~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.
~
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-55-
QUALITY OF PUBLIC INVOLVEMENT PROCESS AND REPORTS
Source of C",.~-_I\t
1
Comment:
I have found numerous contradictions and inconsistencies ~hich cloud the
entire [Remedial Investigation/Feasibility Study] study. ~y comments come
from only a small review time on my par~ and I feel that many more questions
could be addressed. As an engineer I understand the positio~ that EPA must
try and ful:::l. it is an extremely difficult and complex one to say the least.
Re!';oonse:
Several of the inconsistencies mentioned previously have been answered.
It is likely that many of the inconsistencies appear to be such because of the
limited revie~ time. However, it is gratifying that the commentator
appreciates the EPA position as a difficult and complex one.
~
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-; 0-
SPREAD OF CONTAMINATION UNK~OWN
Source of ComlWnt
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 Survey (CSGS), identified as E~-2, E~N-3 and E~~-6 (FS, p. 2-~)
and estimated to be approxlmately 1000 feet northeast of the site eFS, p.
A-2). This is the extent of ~hat is known about off-site migration. CDM
[EPA's contractor for this project] actually assumes that this is the furthest
contaminants have travelled CFS, p. A-2). Yet there is no reason to think
this is the case without additional testin;.'
ResDonse:
Taking the range of site conditions into consideration (lithology,
contaminants, and hydraulic conditions) the greatest distance, predicted by
modeling, that the ground water 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 wells within 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 tQ "close in on" the
contamination by progressively approaching the landfill, rather than by
drilling directly into areas of high contamination.
-------
- J . ~
. SPREAD OF CONTAMINATION UNKNOWN
Source of Comm~~
10
Comment:
Deeper wells are needed to better evaluate how deep the contamination has
spread. Since COM [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 water supply for the City of JacKsonville.
~one 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 contamination in either the upper ground.water table or the deeper
limestone aquifer.
ResDonse:
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.
-------
- 53-
RELOCA TION OF RESIDENTS
Source of Comment
~ - -
.. ~ I
Comment:
Based on EPA's aim "Biggest Bang for the Bucks" comments [at ~he public
meetingJ, 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 ~hile a more
per~anent solution to the contamination problem be thoroughly researched.
During the meeting it ~as 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 institutional controls app~ars to be adequate measures to remedy the
landfill. Therefore. before further exorbitant amounts of monies are spent
for design. 2tC., I .ould recommend the immediate removal of residents in and
around the landfill and a temporary cap be pl.ced until a future more
equitable solution can be reached. If you cannot eliminate the source, keep
everyone away from the problem.
Resconse:
To date, EPA has expended funds to accomplish three primary goals. The
first was to prov: :~ safe drinking water to the public. The second was to
identify those par~ies pot~ntially responsible for ibe conditions found
surrounding the Hipps Road Landfill. The third was to develop a data base on
~hich 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. ~nder the mandates of the
~ational Contingency Plan. an emergency removal action is restricted to
approximately $1.000.000.00 in funding and 6 months in implementation. (~O
CrR 300.63(63)). Such action as suggested above would likely exceed this
limitation. .
-------
-;J-
RELOCATION OF RESIDENTS
Source of CQ888At
3 .s. L.
Comment:
The Feasibility Study did not specify which residents would be relocated
in order to implement a remedy at ~his site. I recommend that these people be
contacted.
ResDonse:
The Hipps Road area residents ~hose 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 ~hich EPA has already ~ejected. When design
specifications are known, discussions wtth the affected property owners will
be conducted in order to reach a fair solution~
~
-------
- ~
-~IJ-
RELOCA TION OF RESIDENTS
Source of Comment
10
Comment:
The ~leanup goals are misleading, poorly stated and do not address clean~p
of the site. Instead. they address the removal of risk. ~hile this is
impor~ant. 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
now, 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 wants or expects Łrom-a Superfund cleanup effort.
Protection and cleanup of the environment an~ 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.
-------
-.; >
LOCAL WA'TER RUNOFF
SO:lrce
of CoillllNm
6
C:Jmme~::
we are about across the road from the Hipps Road landfill on Exline R~ad.
we have a city drain ditch in front of our property .hich takes care of r~n
:Jff .ater from Hipps Road and the landfill area. we are concerned of ho. ~a~y
contaminants .e may be getting from the soil during long periods of rain ~hen
the .ater 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.
~
~
-------
-6:-
LOCAL WATER RUNOFF
Source of C0888ft~
7
Comment:
A contradiction arises from consul~ant and EPA comments concerning :hel=
opinion that contaminants only leave the area by ~ay of shallow surf3ce
waters. They justified their opinion by stating that rain water ~ercolated
rapidly, producing little or no runoff. Earlier during the consultan:'s
comments it was brought out that a monitoring well southwest of the si:e cou:d
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 tha~ 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.
.1
-------
_J
GROUND-WATER FLOW
Source of Comment
9
Comment:
~nder natural gradients, seepage from the landfill would enter the
limestone upgradient of these ~ells and flow through the limestone at the ~ell
locations [E~~-2 and E~~-31 to~ard 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 ~ells trom either the limestone unit or from the
landfill. The natural gradients do provide a flow pathway vertically down~ard
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 1983 ground-water level data in all monitoring levels).
Such pumping would increase the downward vertical gradient in the vicinity of
the wells and further prohibit upward flow from the limestone unit.
Resoonse:
~
The site investigation revealed both horizontal and vertical components of
ground water flow. The hydrogeologic and modeling data presented in the
Remedial Inve~tigation Report show that instead of flowing into the limestone
unit in the area of wells E~~-2, EMW-3, and E~N-6t 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.
-------
-o~-
GROUND-WATER FLOW
Source of C~~n~
9
Commer.t:
The (Remedial Investigation] report implies much more lateral flow i~ the
sand unit part of the aquifer system than is supported by the infiltrat~on
rates, potentiometric data and hydraulic conductivity -- hydrogeologic model
-- in the (Remedial InvestlgationJ 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 Report are uniformly
supported by data.
~
-------
-~)-
. .
GROUND-WATER FLOW
Source of C8888A~
9
Comment:
The lateral component of flo~ in the entire system is radially out~ard (to
the north, east, and south) from the site area to~ard the Ortega River system.
Resconse:
The lateral component or ground-water flow in each of the zones of the
surficial aquifer is predominately to~ard the northeast and east from the
site. The Field Investigation indicated no lateral flow to the south.
4
-------
.00.
CROUND-WATER FLOW
Source of Ca8888C
9
Comment:
From the area of the site, ground-water flow is primarily vertically
do~n~ard 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 lpp. 6-8 and 6-9, RI Report). The data show, and the Remedial
Inves:igation Report clearly states that the contaminants are most likely to
move in the lower water table zone. ~hich is. above the semi-confining layer
and well above the limestone unit (p. 6-20, RI Report).
~
-------
-""" . -
~ '
USE OF INNOVATIVE TECHNOLOGY
Source of Co~
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 Sucerfund Strate~y
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.
~
-------
- ~ 3.
USE OF INNOVATIVE TECHNOLOGY
Source of Cd1IIi.....t
10
Comment:
CC~ considered a small ~umber of technologies capable of addressir.g the
contamination at the site. Several ~hich would be effective ~ere elimir.ated
in the initial screening stage, based on cost alone (reverse osmosis, ~et air
oxidation, ozonation, resin adsorption). ~hile cost is a factor to consider,.
several of these methods could be very effective while posing less risks :han
the more preferred alternatives such as air stripping.
Furthermore, more innovative technologies are now available which were not
considered at all. ~ethods such as biological treatment as developed by
Groundwater Decontamination Systems or De:o~ 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 remove
many contaminants present in the soil. .CombiFing 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 an1)
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 Strate2Y (OTA-ITE-253. April 1985).
Response:
The initial screening of alternatives in a Feasipility 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 di8posed of at a landfill approved to accept hazardous waste,
thereby incazriDa additional costs.
-------
-,,9-
USE OF COST CRITERIA
Source of Comment
2
Commen,;:
Some technologies which would effectively clean up the site ~ere
eliminated primarily on the basis of cost. Eliminating a ~echnology 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 a "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
~ational Contingency Plan (~CP) to select the1most 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 ~CP. 40 CFR 9 300.68(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 and/or 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. ~o CFR 9 300.oS(e»
-------
,-
SAFETY OF NEW WELLS
Source of ~~"'II~
8
Comment:
It is clear from the study data that the most significant problem
appearing at the site is the contamination of ground ~ater under the si:e, ar.c
in a plume area extending approxlmately 1000 feet to the northeast 0: 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 fed from a
contaminated aquifer ~as eliminated.
It is both COSt effective, and in the best interests of the public
and welfare, 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 from contamination.
health
the
without
Resconse:
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.
-I
-------
_. -
RESPONSIVENESS TO RISKS OF LANDFILL
Source
of C~~
8
Comment:
The cleanup objectives on pages 1.27 and 1.28 more correctly state the
heart of the decision made by the EPA.
[:0) 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 [sicl 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). 1
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 prese~ted 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 cond~tions, and the potential risks
that may arise from existing conditions (i.e., an heterogeneous landfill).
-------
. -
CAPPING LOCAL WELLS
Source of C4~_n~
6
Comment:
The [Duval County] Health Department tells us all wells on Exline Road are
OK. ~ith the exception of a 10t of iron. why will all wells in this area have
to be capped? Instead. why not keep all wells safe by moving the landfill:
FtesDonse:
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 0=
potentially affected by contamination from the landfill would be capped. It
is unlikely that many wells on Exline, whi~r. is mostly considered upgradient
of the site. would be affected.
~
-.
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- . ;,-
INACCURACIES IN RI AND FS
'Source of Commen~
7
Comment:
Several items disturb me, in both the Remedial Investigation/Feasibil:ty
Study and the Feasibility Study summary. If such thoroughness ~as observed ~~
such studies why does the fourth paragraph of the summary say that :hree homes.
exist just outside the landfill, when in fact my home and one other are
located direc:ly 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. ~olan, and w.H. Gore. There are two homes located
between the landfill and Hipps Road...".
-------
- . ...-
DEPARTMENT OF THE NAVY'S RECOGNITION OF NEED FOR REMEDIAL ACTION
Source of C _a~
8
eommen~:
The Depar~men~ of the ~avy recognizes and Supports the
a~ Hipps Road which will eff~ctively mitiga~e and minimize
provide adequa~e pro~ec~ion of the public health, welfare,
40 eFR 300.68(c).
Resconse:
\0 comment necessary.
-I
need to :ake action
damage to, and
and environmeno;.
-------
- . )-
RCRA APPLICABILITY
Source of Comment
8
Comment:
The Feasibility Study. at page ~-li, attempts to summarize the
insti:utional requirements ~hich could apply to the proposed closure. while
~e 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. ~O CFR 264) and the EPA RCRA Design
GUidelines would apply. This site ~as not active after 1970 and received no
~aste 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 -receiv~dwaste after November 19,
1980. does not preclude the Agency's considera~ion 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." (See 50 Federal Re~ister 47917, Section
II " -.
III,Revisions to Subpart F, November 20, 1985.)
-------
<6-
AIR STRIPPING
Source of ~--_nt
2 & 10
Comment:
The air s~ripping procedure poses an unnecessary threa~ and possibly
dangerous Tisks to nearby residents. The top preferred alternative incl~des
using air stripping to remove chemicals from ex~racted ground water. This
process ~ill put chemicals into the air where they .ill be dispersed into the
community. This procedure unnecessarily transfers the risks from the 6~ound
~ater that nobody drinks to the air tha~ everybody brea~hes. 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
alterna~ives. Carbon adsorption can achieve the same resul~, perhaps even
removing more chemicals without exposing anyone. Air stripping should no~ be
used under any circumstances.
To emphasize the importance of this, let~me share an experience from Love
Canal. During the cleanup there, residen~s es~ablished a "ho~ 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 onsi~e, 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 qf 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 CeC/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 actiOD at this site, and EPA a~rees with this decision.
-------
. I : -
. JACKSONVillE WASTE WATER TREATMENT CAPABILITY
Source of Cudmh...t
..
i
Cc:r.men~:
In :he
~he ground
This ..auld
same plan~
expansion.
Remedial Investigation/Feasibility S~udy one me~hod or dispoS31 of
..a~er is disposal in the Privately Owned Treatmen~ ~orks (PCi7,,).
be the City I s southwest \o,iaste water Treatment Plant (wwTP) 7his
is currently hydraulic1y overloaded and is only recently begin~ing
It appears that little or no thought was put into this concept.
Resconse:
In Sovember 1985, EPA's contractor 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 PO~. At that time, the EPA
contractor was informed that the Southwest wVTP is being expanded to provide
the necessary capacity. The increased capacit1 will be available before the
implementation of a remedial action. Therefore, the option to dispose of
contaminated ground water at the POTW is feasible, and that option ..ill remain
as part of the Feasibility Study.
~
-------
-~3-
.EFFECTIVENESS OF GROUND-WATER EXTRACTION PROCEDURES
Source of Comment
10
Comment:
CD~f [EPA's contractors ror this projec~] proposed a single grou~d-.~ter
extraction procedure using 20 extraction ~ells pumping 20 gallons per mi~4te
eFS. p. 3-2) to be used ~ith all Group A alternatives. This procedure
(developed as a computer model) est~mates that 95~ of the contaminated grour.d
~ater would be recovered after one year of continuous pumping eFS, p. )-2).
Several important factors ~ere not considered in this estimation: the
influence that surface capping ~ill have on water table levels, the lack of
containment system to keep contaminated ~astes within a limited area, the
limited ability to remove soil contaminants, and the selective removal of only
water-soluble 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
ans~ers of sufficient accuracy and detail to guide in the decision making
process for whatever decision needs to be made. In this case, a ground-~ater
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 ~he worst possible
contamination scenario, as previously defined by the model, 95~ of the
contamination will be removed ~ith this extraction well system within a year.
The role of ground-~ater 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
~ell system is in operation, exactly 95~ of the contamination may be removed
in less than on. year. Because of the many unknowns and uncertainties ~ith
respect to the around-water system, it may be more than a year before 95~ of
the contamiDa~10u is removed. Continued 'monitoring of ground-water quality in
the area will be necessary in order to evaluate the impact or the extraction
~e 11 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 ~ells, ground-water flow at Hipps Road is influenced primarily by
the regional hydrologic c~nditions. Capping the landfill, affecting a
relatively small area, will have a very small impact on water levels. With
extraction wells. !round-water flow at Hipps Road will be dominated by well
'...nBge and capping the landfill will have essentially no effect on ~ater
levels at the site. .
-------
-~9-
. EFFECTIVENESS OF GROUND-WATER EXTRACTION PROCEDURES
With re~ to a containment 5YStem. the extraction ~ell system itself
creates a hydraulic barrier in the aquifer. This barrier prevents the
contaminants from leaving the area. ~hile pumpage draws the contaminants into
the wells. Therefore. a physical containment system is not necessary.
with regard to removing soil contaminants. the extraction ~ell analysis
addressad only ground-water ~ontamination. The percent removal calculations
are based only on contamination of ground ~ater. 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 ~as not used because two-phase (fluid) flow is not
evident at the site. Only contaminants dissolved in ground water were
discovered in the monitor ~ells during the remedial 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 analysi~ 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.
-I
-------
Source ::
- 3C-
APPENDIX 1
SOURCE OF COMMENTS
1
Source
Petition form letter received from more :han 1~O individuaLs in
response to the initial remedial actions considera:ions stated bv
EPA at ~he ~ay i. 1986 Public ~eeting .
2
Jacksonville Concerned Citizens Against Contaminated water, signe~
by Alvin Speicher, Presiden~
J
Yvonne & Donald woodman, Hipps Road area residen~s
4
Ike ~olan, Hipps Road area reside~t
Gloria Strat~on, Hipps Road area resident
3
Paul & Jean O~~, Hipps Road area residen~s
6
i
.1
Henry Vorpe, Hipps Road area resident
8
Depar~ment of the Savy, submit~~d by D. R. Spell, Environmental
Branch Head
9
waste Con~rol of Florida, prepared by Golder Associates,
consultants; submitted by Charles H. Tisdale, Jr.
10
Citizens' Clearinghouse for Hazardous Was~es,
ac.ven U. Lester, Science Director; submit~ed
Hipps Road area resident
Inc., prepared by
by Yvo~e woodman,
-------
-5 :-
APPENDIX 2
NAMES AND ADDRESSES OF COMMENTERS
SA~IŁ
ADDRESS
DATE ~E71:.R
wAS ~ECEIrt:D
Henry \'orpe
9110 Hipps Road
Jacksonville, FL
5/22
32222
~ary Beth Woodman*
9084 Hipps Road
Jacksonville, FL
5/22
32222
Steven Woodman":
9084 Hipps Roac.
Jacksonville, FL
5/22
32222
Ronald Gagne':
4545 Cambr~dge Road
Jacksonville, FL- 32210
5/23
Paul & Jean O~t
7180 Exline Road
Jacksonville, FL
5/23
32222
Kenneth Stevens'"
6769 Lauriana Place
Jacksonville, FL 32216
5/23
Dona ld woodson''''
P.O. Box 7842
Jacksonville, FL
-\
32238
5/23
~ar jorie Gagne'':
4545 Cambridge Road
Jacksonville. ~L 32210
3/23
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 wood88a*
P.O. Box 7842
Jacksonville, FL
3/23
32238
Sheryl K. Baker'"
498 Eldridge Gelly Stree~
Orange Park, FL 32073
5/27
..
= Submitted Form Letter -
-------
- ~
- ~ -
:-.lA.'IE
ADDRESS
DA IE :'Z7T::~
~A5 RE::E:':ED
Les~er D. Sen~er*
159 ~achelle Drive
Jacksonville, FL 32220
- .,-
:J! -'
Joyce w'arrick*
5..30 \"orde Drive
Jacksonville. FL
5/2;
322~4
Arnold E. ~orris*
5150 Pennant Cour~
Jacksonville, FL 32:44
- ,'''-
:J / ...,
Mrs. Leroy Alline Starling*
5108 Colonial Av.eneue
Jacksonville, FL 32210
5/27
Ron Stevens'"
300 Glenlyon Dri~e
Orange ParR, FL 32073
5/27
S . w. Hyman"
858 Crest Drive Eas~
Jacksonville, FL 32221
5/27
Mrs. G. PoppaLordo*
5952 Black~horn Road
Jacksonville, FL 3224~
5/27
Earl ~!. Henry, Jr.:
8933 Hipps Road
Jacksonville, FL
-.
5/27
32222
Thomas Bus ler"
5400 Collins Road
Lot 112
J acksonv ill e, FL
5/27
32244
Ray Sne llgrove"
413 Ameca Avenue
Orange Park, FL
5/27
32073
Jimmy Tenney*
8929 Hipps Road
Jacksonville, FL
5/27
32222
Terrance JohD8oD*
8925 Hipps Road
JacKsonville, FL
5/27
3222
* ~ Submi:t~d Form Letter
-------
-83-
~A!'fE .
A:JDRESS
DATE LE7TER
\o,'AS RECE rVED
James E. Johnson*
8925 Hipps Road
Jacksonville, FL
3::22
5/27
Edtoiard Hall",
5017 Palmer Street
Jacksonville, FL 32210
5/27
Betty Burnett"~
8931 Hipps Road
Jacksonville, FL
32222
5/27
~. Benton"~
5909 11lth Street
Jacksonville, FL
32244
5/27
Connie & Tracy Patillo'~
7040 Exline .Road
Jacksonville, FL' 32222
3/27
wallace A. Witherbee*
6863 ~iss ~uffet Lane s.
Jacksonvl11e, FL 32210
3/27
William Gann'"
3957 Baimer Drive
Jacksonville, FL
32210
5/27
Peggy Cox'"
7030 Knotts Drive
Jacksonville, FL
~
32210
5/27
william ~. SZimore*
8941 Hipps Road
Jacksonville, FL 32224
3/27
David w'. Strunk
5858 I11th Street
Jacksonville, FL
32144
3/27
John R. Young'"
7514 Strato Road
Jacksonville. FL
32110
5/27
Doyle Hall*
8164 Crosswind Road
Jacksonville, FL 32244
5/27
" = Submitted Form Letter
-------
-3';'-
SAM!
ADDRESS
DA 1':; LET:'ER
\o.'..\S RECE:VED
C. E. Fr:mks'"
303 ~!urray Drive
Jacksonville, FL
- ',-
J, _1
32205
C. D. Hens ley'"
~306 Harlow Boulevard
Jacksonville, FL 32210
5/2:-
\.i.G. Dickinson":
6623 Aline Road
Jacksonville, FL
3/2i
32244
John O. ~!esmer:':
8933 Hipps Road
Jacksonville, FL
3/27
32222
Susan ~!arynowski*
:921 ~E 13th Street
Gainesvill~. FL. 32609
5/27
Clyde A. Brown":
1
3936 110th Street
Jacksonville, FL
5/27
32244
Leroy Starling"
3108 Colonical Avenue
Jacksonville, FL 32~10
3/27
Everett L. Stratton*
7183 Exline Road "8
Jacksonville, FL 32222
5/2i
James "", Cox,:
7030 Knotts Drive
Jacksonville.. FL
5/27
32210
Gloria P. Stratton*
7183 Exline Road #8
Jacksonville, FL 32222
3/27
Tony \.i. Poppalardo*
5952 Blackthorn Road
Jacksonville, Fl 32244
3/27
Roland Cuevoa*
1505 LaVilla Drive N.
Jacksonville, FL 32221
5/27
,', = Submitted Form Letter
-------
-55-
NAM!
ADDRESS
DATE LE77:::~
""AS REC:: n'::D
Danny \el.;ton'"
5373 Oaklane Drive
Jacksonville, FL 322~~
-,., -
:J.' ..I
David L. Phelps'"
8103 Poe Court
Jacksonville, FL
321':'4
5/27
Dorothy Johnson*
8925 Hipps Road
JacKsonville, FL
32222
5/Zi
John Hen
"+
Route 4 Box 6
Hawthorn, FL
32640
5/27
Delmer L. ~attison*
4841 Homecrest Circle
Jacksonvilie, FL. 32244
5/27
Pegg>' Beav iss""
71i1 Bunion Drive
Jacksonville, FL
32222
5/2i
R. Hisoire*
Box 1137
Jacksonville, FL
32239
5/27
Kathy Henderson'"
4224 ~v 30 Terrace
Gainesville, FL 32605 4
5/2i
Donald C. Steele*
491 Clermont Avenue S.
Orange Park, F~ 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
~Irs. Lyle Manu*
6224 Sauterne Drive
Jacksonville, FL 32244
5/27
.:~
= Submitted Form Letter
= Incomplete Address on Comment
+
-------
-56-
:-JANe
ADDRESS
DA T:: LETTER
\o;'.\S RE:CE I\'ED
~r. ~ ~rs. Larry Ba~~on*
3/2i
Gary J. Cour~'"
Gloria Strat':on
Ike Solan
Scott ~!. ~Iotel":
Submitted by Che~ Tisdale
on behalf of waste ~1gm~.
Inc.
o . R. Spe 11, PE
Jacksonville Citizens
Aga~ns~ Contaminate water
Yvone woodman &
Donald woodman
Submi~ted by Yvonne Woodman
& Donald Wo:~tft - from
Steven V. L.s~.r
Annette ~. ~axey*
33:2 Appleton Street
Jacksonville, FL 31210
i656 Arble Drive
Jacksonville, FL
5/2i
32211
i183 Exline Road #B
Jacksonville, FL 32222
5/27
il~5 Exline Road
Jacksonville, FL
5/27
32222
3434 Blanding Boulevard
Apartmen~ -#190
Jacksonville, FL 32210
1
5/28
King & Spalding
2500 Trust Company Tower
Atlanta, GA 30303
5/29
pm 5/28
Depar~men~ of the Navy
Southern Division
Naval Facili~ies Engineering
Command
2155 Eagle Dr., PO Box 10068
Charleston, SC 29411-0068
5/30
pm 5/28
PO Box 7842
Jacksonville, FL
32238
5;30
pm 5/28
PO Box 7842
Jacksonville, FL
32238
5/30
pm 5/28
Citizens Clearinghouse for
Hazardous Was~e
PO Box 926
Arling~on. VA 22216
5;30
pm 5/28
1601 Dunn Avenue 07A
Jacksonville, FL 32218
5/30
pm 5/28
.. = Submitted Form Letter
pm = Postmarked
-------
-3i-
NAME
ADDRESS
DATE LEITER
~'AS RECE I\"E:J
Linda Coffman'"
6232 Sau~erne Drive
Jacksonville, FL 32210
5130
pm 5/28
Kris~in A. Case*
4246 Hall Boree Road
~iddleburg. FL 32068
5130
pm 5/28
Chris Cummins"
~336 San Juan Avenue
Jacksonville, FL 32210
5/20
pm 5/28
~rs. Charles F. Anderson*
i408 Burlingame. Drive S.
Jacksonville, FL 32211
5/30
pm 5/28
Gerry E. Suits#
4500 Ramona.Street
Jacksonvi 11.e. FL, 32205
220 ~yra Street
~eptune Beach, FL
5/30
pm 5/28
~argaret E.~. Sullivan*
32233
5/30
pm 5/28
Richard E. Coffman*
7236 Blanding Boulevard #116
Jacksonville, FL 32244
5/30
pm 5/28
Doris ~. Gates'.
5885 Edenfiled Road #72~
Jacksonville, FL 32211
5130
pm 5/28
~rs. Lori Buck":
4216 Old ~ill Cove Terrace W
Jacksonville, FL 32211
5/30
pm 5/28
Karen ~ard*
102 SE 22nd Street
Delray Beach, FL 33444
5130
pm 5/28
Jeanette A. Todd*
8903 Hipps Road
Jacksonville. FL
32222
5/30
pm 5/28
Betty J. DidttDson*
6623 Aline Road
Jacksonville, FL
32244
3130
pm 5/28
~ary P. Nettles*
3915 Riverside Avenue
Jacksonville, FL 32205
5130
pm 5/28
,'. = Subm'itted Form Letter
pm = Pos~marked
-------
-65-
~~a:
ADDRESS
DA 7:: ~Z:-:-ER
wAS RECEIVED
Linda C. Jenkins*
Claude Oglesley*
~r. & ~rs. Carroll Pi~tman*
Ken Taylor':
~ichael H. Daniel*
John C. Levigs":
An~hony S. Fiore*
(plus a cover le~~er)
Alena Ellie':
Bonnie D. Perea*
Burna Perea':
Janie Fiore':
Dona GoIns.
8280 Honeysuckle Lane
Jacksonville, FL 32244
3/30
pm 3,'28
9280 Hipps Road
Jacksonville, FL
32222
3/30
pm 3/28
9066 Hipps Road
Jacksonville, FL
32222
3130
pm 3/28
6062 Seaboard Avenue
Jacksonville, FL 32210
5130
pm 5/28
1~19 B. Dancy S~reet
Jacksonville, FL . 32205
5/30
pm 5/28
11631 For~ Caroline Road
Jacksonville, FL 32226
5130
pm 5/28
4421 San Clerc Road
Jacksonville, FL 32217
5/30
pm 3/28
1300 Eas~ Cornwallis Road
Durham, NC 27713 4
5130
pm 5/28
1011 E. 33rd Avenue
Tampa. FL 336Q3
5/30
pm 5/28
1011 E. 33rd Avenue
Tampa, FL 33603
5130
pm 3/28
4421 San Clerc Road
Jacksonville, FL 32217
5/30
pm 5/28
917 Jones Circle
Durham, NC 27703
5130
pm 5/28
.. = Submitted Form Let~er
pm = Pos~marked
-------
-59-
NA.'iE
ADDRESS
DATE LE:7::R
\0,':\5 RECEIVED
Janie L. Hansely*
8 i i'3 Hipps Road
Jacksonville, FL
32222
5/30
pm 5/28
~eal D. Thomsen*
132 ~cDowell Avenue
. GA 31320 +
5130
pm 3/28
132 ~cDowell Avenue
. GA 31320 +
3130
pm 3/28
Jewe 11 Thomsen":
Janie P. Hansley*
8912 Hipps Road
Jacksonville, FL
32222
3130
pm 5/28
Edward Jaques":
1108 Blazing Ridge
Lawrenceville, GA30245
5/30
pm 5/28
Holly B. Jaques*
1108 Blazing Ridge
Lawrenceville, GA
30245
5130
pm 5/28
~argare~ Oglesley*
9208 Hipps Road
Jacksonville, FL
32222
5/30
pm 3/28
Al Speicher":
9040 Hipps Road
Jacksonville, FL
.,
32222
5/30
pm 5/28
Gail P. Speicher*
9040 Hipps Road
Jacksonville, FL
32222
5/30
pm 3/28
Carol Su~kowreik*
1649 Landing Lane
Nep~une Beach, FL
32233
5/30
pm 5/28
~r. & ~rs. W.R. Henderson*
1816 Kings way
Nep~une Beach, FL
32233
5/30
pm 5/28.
~illiam R. H8Dderson*
1816 Kings Way
Nep~une Beach, FL
32233
3/30
pm 5/28
.. = Submit~ed Form Le~~er
pm = Pos~marked
+ = Incomp1e~e Address on Commen~
-------
-10-
NA.'iE
ADDRESS
DATE LE'I-:-ER
I."AS RECEIVEJ
SCOtt Pinette"
22':' Oak Street
\eptune Beach, FL
32233
3,'30
pm 3/28
Judith D. ~Iozo'"
l20 \orth Street
Septune Beach, FL
32233
3130
pm 3/28
Thomas K. Burke*
2016 Strand
Septune Beach, FL
32233
3130 .
pm 3/28
Cecilia Vosper"
110 ~alnut Street
~eptune Beach, FL
32233
5130
pm 5/28
B. Galhon"
6265 ~errill Road
JacksonviIle, FL 32233
5/30
pm 5/28
". . H. Boky. Jr. ,.
1
1461 Hopkins Creek Lane
~eptune Beach, FL 32233
5130
pm 5/28
~ar ie Lynch'"
1462 Hopkins Greek Lane
~eptune Beach, FL 32;33
5130
pm 5/28
~elissa G. Koralakes*
1618 Landing Lane
Neptune Beach, FL
322.13
5130
pm 5/28
Laurina Vorndra"
1648 Landing Lane
Neptune Beach,. FL
32233
5130
pm 5/28
Kim Harey"
1454 Hopkins Creek Lane
Neptune Beach, FL 32233
5130
pm 5/28
Dianne ~arkin*
1519 Hopkins Greek Lane
Neptune Beach, FL 32233
5130
pm 5/28
Oscar L. H-..risk*
1627 Hopkirts Greek Lane
Neptune Beach, FL 32233
5130
pm 5/28
.. = Submitted Form Letter
pm = Postmarked
-------
.
. -9:-
S A.'1E
ADDRESS
DATE ~=:TT::R
1,0,',1.5 RECEII;=:D
J. Car lson':
E, Pife>':
~1artha James":
Janet W. ~ontgomery*
Gregory J. Streeter*
Bernie L. Brewer*
Particia B. Oarnswarth*
Douglas J. Jaegar*
Gary Gene Kirkland*
Paul R. Coombs'':
Larry Phillips*
~1aria A. Dill.
~~C9 Indian woods Drive
\eptune Beach, FL 32233
5/30
pm 5/28
130~ Forest ~arsh Drive
~eptune Beach, FL 32233
1440 Bucknoll Cove
~eptune Beach. FL
1~24 Bucknoll Cove
Septune Beach, FL
42i 6th Street N.
Jacksonville, FL
1
1435 Bucknoll Cove
Septune Beach, FL
5/30
pm 512 8
32233
5130
pm 5/28
32233
5/30
pm 5/28
32240
5/20
pm 5/28
32233
5130
pm 5/28
1419 Forest ~arsh Drive
Neptune Beach. FL 32233,
5130
pm 5/28
1731 Indian woods Road
Septune Beach. FL 32233 -.
5/30
pm 5/28
1811 Indian Woods Road
Neptune Beach, FL 32233
224 Oak Street
Neptune Beach, FL
1512 Big Tree Road
Neptune Beach. FL
1501 Big Tree Road
Neptune Beach, FL
5/30
pm 5/28
32233
5/30
pm 5/28
32233
5/30
pm 5/28
32233
5130
pm 5/28
.. = Submitted Form Letter
pm = Postmarked
-------
.,:-
NA. '1!
ADDRESS
;)ATE LEl: :.R
""AS RECr:IV;:O
Renee Albert'"
Tom Rady*
Lucille YounS'"
Linda white'"
Ken Kirton*
P. Bailey""
Alfred W. Shepherd'"
C. \0,'. Johnston'-'
Colton L. Pusler*
919 Septune Circle
Sepcune Beach, FL
1314 Big Tree Road
Septune Beach, FL
1401 Kings Road
\epcune Beach. FL
1~06 Big Tree Road
Septune Beach, FL
3:233
5130
pm 5/28
32233
5/30
pm 5/28
32233
5;30
pm 5/28
32233
5/30
pm 3/28
1504 Big Tree Road
Sepcune Beach, Ft32233
1603 Arrowhead
Septune Beach, FL
1510 windward Lane
Neptune Beach, FL
1643 Leeward Lane
Neptune Beach, FL
1528 Leeward Lane
Septune Beach, fL
5130
pm 3/28
32233
5/30
pm 5/28
32233
5/30
pm 5/28
32233
5/30
pm 5/28
32233
3/30
pm 5/28
- = Submitted Form Letter
pm = Postmarked
-------
-~~-
~A.'1E'
ADDRESS
DATI: LE77::~
WAS i\ECEI\"EJ
Brenda & Ar~ Zipperer~
8389 Hilma Road
Jacksonville, FL
32 2 44
61Z
pm 5130
C 1 if~on A. Todd"t
8903 Hipps Road
Jacksonville, FL
32222
6/2
pm 512 9
Rose A. Con~reras*
7627 Indian Lakes Drive #2
Jacksonville, FL 32210
6/2
pm 5/29
John R. Smi~h"t
6054 Toyo~a Drive
Jacksonville, FL
32244
6/2
pm 5/29
Frank Smi~h*
6301 Roosevel~ +
6/2
pm 5/29
Allen Himes't
8314 Dandy Avenue 1
Jacksonville, FL 32211
6/2
pm 5/29
D ina Pork"t +
6/2
pm 5/29
Earnest L. Walker*
371 Spruce S~reet +
~
6/2
pm 5/29
Gerald G. Hill*
8936 Hipps Road
Jacksonville, FL
32222
6/2
pm 5/29
Daniel J. Hurs~"t
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
~t. E. Ke lly*
7135 Shindler Drive
Jacksonville, FL 32244
6/2
pm 5/29
.. = Submitted Form Letter
pm = Postmarked
+ = Incomplete Address on Commen~
-------
-~..-
~A.'ii
ADDRESS
DATE :'ET'!'ER
~AS RECSrVED
Allen ~. ~iller*
Henry B. Bo~den, Jr.*
Jerome Rivers'"
'J.L. Budgets""
'J ill iam Durham"
Angela D. &
Richard T. Evernder*
Robert Gidcumb""
Ernest O. Thomas*
Fredrick ~. Hughes""
Donna Carter'"
IC R. Beals*
Robert E. A1-I..
Allen G. Appler
2103 Figaso Lane
Jacksonville, FL
6/2
pm 5/29
;;04 Hare Avenue +
6/2
pm 5/29
~662 Roanoke Boulevard
6/2
pm 5/29
3019 Roselle S:reet
Jacksonville, FL 32205
6/2
pm 5/29
6606 Kincack Drive +
6/2
pm 5/29
8350 Sunflower Court #9 +
6/2
pm 5/29
4352 Vicksburg Avenue
Jacksonville, FL 32210
6/2
pm 5/29
2534 Lancites
Jacksonville, FL
-.
6/2
pm 5/29
P.O. Box 7006 .
Jacksonville, FL
32238
6/2
pm 5/29
6477 Cooper Lane
Jacksonville, FL
32210
6/2
pm 5/29
6455 San Juan Avenue #9
Jacksonville, FL
6/2
pm :5 / 29"
4i54 Burgundy Road
Jacksonville, FL 32210
6/2
pm 5/29
1155 Hamlet Lane E.
Neptune Beach, FL 32233
6/2
* = Submitted Form Letter
pm = Postmarked
+ = Incomplete Address tJu
-------
-95 -
SA~E
ADDRESS
DATE :'E:7T=:R
\o,'AS RECE I\"::D
Jacquiline ~. Pooler*
1323 Leeward Lane
\eptune Beach. FL
. I')
0,.
32211
pm 5 no
Lauric Sorg":
11~9 Hamlet Lane
\eptune Beach. FL
32211
6/2
pm 5/30
Allen G. Applar*
1133 Hamlet Lane E.
Neptune Beach. FL 32211
6/2
pm 5/30
Clare A. ~cCruz*
li08 Hamlet Lane N.
~eptune Beach. FL 32211
6/2
pm 5130
~enelzo G. Shealy*
1828 Hamlet.Lane N.
Neptune Beach. FL' 32211
6/2
pm 3/30
william Daly":
1836 Hamlet Lane
~eptune Beach, FL
32211
6/2
pm 5/30
P. A. Robar":
1110 Hamlet Court
~eptune Beach. FL
32211
6'')
1 .
pm 313 0
Susan L. Zelt~ay*
1121 Hamlet Court
~eptune Beach, FL
32231
6/2
pm 313 0
Gl~'nn ~'ilson'"
1128 Hamlet Court
~eptune Beach, FL
32233
6/2
pm 313 0
~Iary Ed~ards':'
1140 Hamlet Court
Neptune Beach, FL
32233
6/2
pm 3130
Bob ~Iarshburn*
1143 Hamlet Court
Neptune Beach. FL
32233
6/2
pm 3/30
Charles H. TbD8p8on*
1150 Hamlet Lane E.
Septune Beach, FL 32233
6/2
pm 5130
O~en Joll1*
5114 Benning Road
Jacksonville, FL
32205
613
pm 313 1
Gloria Jean Jolly*
5114 Benning Road
, 'Jacksonville. FL
32205
6/3
pm 513 1
.. = Submitted .Form Letter
pm = Postmark.ed
-------
APP!M)IX C
City of Jacksonvill~
Division of Public WOrks
~ition Letter
RegardiB;;J the Availability
of the
Local Publ icl y Omed Treatment WOrks
for
Disposal of RecoYered Gran! Water
fran the .1
Hipps !bad Lamfill Site
-------
,-
July 31. 1986
~ ~
J.. ~
. , q.. s
i 0' ~ (~r~ r~lHaf? IV;~;SONV\\.~~ ~ ~
I I. r~---'-'- - III i
.) .,... O~~ ;
~ , r J \.] O.l L '" ~ L I:
. n h-r-:-"'-" -.- - - U j
iJ .J I":: L:9 L.::: U u LS L-.
:'r'''" . ~::~:c~ :":
DEPART~tE~T OF PUBLIC WORKS
Water Services Division
~s. Kristina L. Teepen
Remedial Project Manager
Emergency & Remedial Response Branch
U. S. Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30365
I.!L:.:::'.~, :.~..
Re:
Hipps.Road Landfill ~PL Site - Availability
of the Southwest Waste Water Treatment Plant
for Disposal of Recovered Ground Water
Dear Ms. Teepen:
The Water Services Division of the Department of Public Works has reviewed
your letter of July 29, 1986 and we are agreeable to working with EPA. DER,
or its contractors in the treatment and disposal of water from the Hipps
1
Road site. However. we are aware that the acceptance of this water may have
major impacts on our operating permits and a thorough review of all the
permitting and liability consequences must be made before approval to con-
nect is given. We are also concerned that the public may perceive our POTW
as a hazardous waste facility -- this perception cannot be allowed and we
would expect a strong commitment from EPA to educate the public about the
entire operation at Hipps Road.
~
There is no doubt that the caution you will detect on the part of the City
will be disproportionate to any possible environmental risk in treating
this effluent. However. we pride ourselves in our compliance and will
under no circumstance tolerate any action that risks compliance with our
pretreatment standards or operation permits. We are agreeable to working
with'EP~ because we see our POTW as the only viable solution likely to be
acceptable to the public.
Again. let me restate our willingness to work with EPA but only following
thorough r.~1ev of the constituents and the effect on our permit.
Very truly ,ours.
~i.1(t.~ ~
Allan E. Williams, P.E.
Deputy Director (Water and
Sewer)
. '
AEW/jh
I118III
-'-l1li
't II I'
cc: Scott D.' Kelly
Patrick T. Karney
Ron Leins - FDER
AREA CODE 904/633-3052/ 220 E. BAY STREET / JACKSONVILLE. FLORIDA 32202-3493
EOUAL OPPORTUNITY EMPl.OYER
-------
APPDIDIX D
D!part:ment of the Interior
Fish and Wildlife serVice
Natural Resource Dnage Assessnent
ReI ease ftaft Cl aims
-,
-------
~'
'-~"
../ - -~'
...- ,"~-- -~ '\..~...
~ ~~~ :1
-,._~J,
'~"
.~:,-,
l."nited States Department of the'lnterior
OFFICE. OF THE SECRE.TAR Y
WASHI~GTO~. D.C, 2024<)
'JU;, :2 5 i986
ERS4/1S19
~'r. Gene Lucero, Director
Environmental Protection Agency
Office of Waste Programs Enforcement
401 \1 Street, SW (Room S362]\;) \"H ~~'
Washington, D.C. 20460
Dear \lr. Lucero:
The De~6it~ent of the Inte:-lor has reevaluated the Hipps Road Landfm site,
Jacksonville Heights, Duval County, FL, because of new information made avai1a~l'! ~y
EPA, 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 Landfm provides habitat suitable for migratory birds,
and the Ortega River/St. Johns River system contaij1s s~veral 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 stewardship have been impacted
by materials fro~ this site.
.o\ccordingly, we are prepared to grand a release from c,laims for damages to natural
resources under our trusteeship from the Hipps Road Landfill.
3:':'1ce:'e:y, .1
/' /..,. / {
./~ ~"-- -' f--/
flruce Blancha:;d:Director
- Office of Environmental Project Review
cc:
j.!teve Klein/EP A
[iTIf?i: .R R E / r:'; ~
- --.I'..~
n. ...!-01?0;: {7D ....
U~ :.:.u...J..:- ,.--L~- : ' I
; ~ " ' I
~n ..;JL On 10Q~ II!
I oJ .J'.J..J ':
, " -"""'.~---.- ",
~J1";~~U UIC,IL
.':', ~:~~;:'~:.~~CL.~~ .:- -,
-------
APPENDIX E
State of Florida.
Department of awironnental Regwation
Letter of Concurrance
for the
Selected Remedy
-I
-------
STATE OF FLORIDA
,- '.
I ' .
".. .. " '-/
~ ~', .
DEPARTMENT OF ENVIRONMENTAL REGULATION
TWI'" TOWEI'IS O;:;:'CE BUII..DINQ
2600 BI..~; 1'1 STONE ~OAO
T"'I..I..A"''''SSEE. FI..:)RI::J4 nJ01,a~41
~:-.
,"ot~!!~"
~~~\.
... ~'!:...\
!I~~' '\~,
,\\~~.~.~j
. r!1~V....'
, ~'f 0# F\oI~.
A1:rg11st 15, 1986
BOB GR4......M
GOvERNOR
VICTORI~ J. TSCHINI(EI..
SECRET...RY
Mr. Jack Ravan
Regional Administrator
United States Environmental
?rotection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Jack:
The Florida Department of Environmental Regulation agrees Nith
and commits to the recommended remedial alternative, designated
RA-8, proposed in the final draft feasibility study for the Hi?ps
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 plu~e and eliminate all
?athNays for human exposure.
The state will also accept its responsibility to provide 10
percent of the $3.1 million cost for the project through tne
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
~. ())aJkv
Tschinkel
VJT/os
-------
APPENDIX F
E~ Position Statement
Reqardi~ 1
Relocation Policies
for
Affected Property O«ters
-,
-------
-. '.
. ;
,,'ij-:"
I . - .
- --......
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 quest~ons 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 8...where the President determines that,
alone or in combination with other measures, such relocation
is more cost-effective than and environmentally preferable
to the tran8portation, storage, treatment, destruction,
or secure di8position offsite of hazardous substances, or
may otherwi8e 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. 8ite would
be too costly and dangerous, EPA selected a cost-efficient
and technologically feasible remedy which calls for properly'
,- .
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- 2 -
closing the landfill with an adequat~ cap, and
groundwa~er ~mediation. The selected remedy meets
the reaurFements 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. lEMA'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.
~
S. 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 80nies. EPA has advanced the argument that it
has st.~utory authority to enter such property for purposes
of con.~ructino the remedy or staging fo~ construction.
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 Speich~r
(located at 9040 Hipps Rd.) and Mr. Strange (Exline Rd.).
Based on their previous comments, it is likely they will
~~-~-- .~ ~A ~.lncated. Presently, EPA has no legal authority
to ~~~ ~n" of Mr. Speicher or Mr. Strange. Further,
EPA's policy is that neither Mr. Speicher nor Mr. Stronge
will be reimbursed by the Agency if part of their property
is needed on a temporary or permanent basis. "In the event
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- 3 -
EPA does seek access to their respective properties, Mr.
speicher and/or Mr. Strange may initiate a lawsuit which
may impe4&-~e implementation of the remedy.
6. Must permanent relocation be approved oy 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.
~
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APPmDIX G
D!partnent of Heal th and Rurwu1 Services
Agency for 'Ibxic &lbstance and Disease Registry
Public Health Evaluation
for
Hipps Road Landfill Site
-------
('~
.~
D,t.
From
Subject
To
DEP~RT\1E~T OF HEALTH & Hl;\1A.'" SERVICES
~ -
- - . -- 6 .. "'-
.. -. . - -
A.;j'i' -:. .,. - ~. : ~ - :: : . - -
arc C) :-=~;~ = -; :: .
. MAY f 6 1986
Memorandum
#
"-.
Acting Director
Office of Health Assessment
Health Assessment: Hipps Road Landfill SI-86-046
Jacksonville, Florida
Mr. Chuck Pietrosevicz
Public Health Advisor
EPA Region IV
EXECU'I'IV! StOOfAq
The Hipps Road Landfill Remedial is a former landfill that ceased opera-
tion in 1970 and vas subsequently co~ered vith local soil of inadequate
quality for a proper cap. A January 1985 emergency response action
(providing an alternate, permanent vater Supply) appears to have addressed
the only opportunity for the site to pre.ent a potential public health
threat. The site should be properly closed and proper groundvater moni-
toring institutsd.
STAT~NT 0' PROBLq
The Environmental Protection "enc7 (EPA) requested the Agency for Toxic
Substances and Disea.e Registry (ATSDR) to reviev and comment on the
heelth end ri.t e..e'..ent. the Pee.ibi1ity Study (PS). end the edequecy
of the proposed remedial alternative. for the protection of public health.
~
The Hipp. load Landfill 1. located at the .outh.a.tern corner of the
inter.ecctoa of H1pp. and !zline Road. vest of downtown Jacksonville,
Florida. ~ landf1l1 Occupie. approximately 7 acre. in vhat va. once a
cyprus .W88p. It 1. presently a relatively flat area sparsely covered
with gras., bru.h, and pine trees. '111 material is reported to be buried
~n the site to a depth of 25 feet.
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Page 2 - Hr. Chuck Pietrosewicz .
The facility, operated by Waste Control of Florida, Inc., ceased opera-
tions 1~~ at which time the fill was cov~red 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.
EPA, throush an emersency response
nected the remainins residences to
The area surround inS the Hipps Road Site is residential and. until re-
cently, these residences depended exclusively on private vells for vater
supply. After several vells, reportedly tested in April 1983, vere found
to be contaminated vith volatile orsanic compounds, those residences vere
siven bottled vater and city funds vere appropriated to extend the city
vater system to include this area. City funds vere not provided to the
individuals to connect to the extendtd lines, thus, only those who vishe~
and had ~he funds could connect to the ciiy system. Durins January 1985,
~
action based upon ATSDR advice, con-
the city supply.
DOCUMENTS REVIEWED
1. Request for Assistance, Chuck Pietrosevicz, ATSDR, to Chief, Field
.1
2.
Services, ATSDR, Karch 14, 1986.
"Remedial Investisation Report for Hipps Road Landfill Site,
Jacksonville, Florida," February lO~ 1986.
"Hipps Road Landfill, Faasibility Study, Draft Report," February 24,
1986.
3.
.4.
"Site ADalysi., Hipps Road Landfill, Duvel County, Florida," by
8ioaecic. Corporation, Warrenton, Virsinia, June 1985.
ATS. .iC. fUe..
5.
.
CONTAMINANTS AND PATHVAYS
Table 1 presents the maximum concentrations for numerious chemical spe-
cies reportedly found in various samplins locations on and around the
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Page 3.- Mr. Chuck Pietrosewic:
Hipps Road Landfill. Based upon ~he da~a provided for chemical concen-
tration ~ .urface soil and groundwater. and the fact that the groundwater
is no longer being consumed in the .area of the site, ~here 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 vater supply has addressed the only documented
pathway for potential significant human exposure for this site. Any
remedial action vhich vould excavate the vaste or treat the groundvater
would provide a nev potential pathvay fo~ exposure.
The method by vhich the data vas presented in the reviev documents makes.
it difficult to fully evaluate the .ite. ,There doe. not appear to be any
clear pre.entation of the data from the private vell. on vhich the initial
remedial action va. ba.ed. In addition, there appears to be some incon-
.sistencie. in the Remedial Inve.tigation (11). For example, in Table 3-4,
the concentration of zinc in borehole 88-15 i. reported a. 1,400 ug/l.
vhile in Table 9-1, it i. reported a. 33,000 ua/~,
In order to interpret the groundvater cQndition in the vicinity of the
site, it vould have been u.eful to have .ampled the same vells on more
than one occa.ion. This vould demon.trate that the contamination vas
actually pre.ent in the vater and .hov if the concentration of the
contaminacion va. chanaina vith t1me,
From the "ca provided, there appears to be one private vell, one off-site
monitortBa ..11, and .everal on-site boreholes vith substantial organic
contamination, and one on-site borehole vith hiah metal concentrations.
. .
The privatevell contamination is vith methylene chloride vhich i5 ubiqui-
tous in laboratories a.nd notorious as a contaminant in the analytical
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Page 4 - Hr. Chuck Pietrosevicz'
proce... The reported 5.700 ug/l appears to b~ somevhat higher than might
be ezpecced from laboratory contamination. Rovever. it is also more than
tvo orders of magnitude greater than any of the other vater samples fro~
the site.
Therefore, it vould be difficult to consider the site to be the
source of this compound if it is, in fact, present in the groundvater of
the private vell. The reported methylene chloride in this vell is also
called into question because the monitoring well. in the immediate vicin-
ity report none of this compound. The other private well data reported
show low concentrations of toluene below any level for public health
concern for consumption of the water.
There appear. to be little relation.hip between the materials reportedly
found in the soil and the Iroundwat~r from the bore hOle. on the site.
Specifically, polychlorinated biphenyl. (PCB.) were reported in the
1
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 sample. from these bore holes show no PCBs even though they
were analyzed by priority pollutant p~ocedure.. This situation in vhich
the materials were reported either to be present.in the soil and not the
groundwater, or vice versa, appears to call into question the analytical
results.
Another result that call. into que.tion the validity of the analytical
results i. that of aluminum. In many of the sample. from the bore holes.
the temporary vell., and both series of monitoring wells, the aluminum
concentraciaD 1. reported to be in the thousands of ug/l, some even tens
and hUD~ of thouaand. of ug/l, while the maximum reported value for
the pri..e. ..11. i. 280 ppb, with most of the reported values being
reported a. le.. than the detection limit of 200 ppb. It seems difficult
to explain this wide difference in concentration with at least some of the
.~. . .. - -. - .
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Page 5. - Hr. Chuck Pietrosevie:
mon1torinl vells and ~rivate wells in close pro~imity to each other and
v1thdrav1ns from the same aquifer. While this is not the only difference
in results from adjacent vells, it is the most glaring example.
It appears that, at least in the off-site private vells, there 1s no
substantial indication that the landfill is the source of general conta~i.
nation. While the dovngradient vells Pi-6, Pi-7, Pi-8, Pi-9, and the
on-site vell PV-lO shov contamination, there is no consistency in the
contaminant; PW-6 has l,2-dichloroethane, Pi-7 has methyl ethyl ketone,
Pi-a has methylene chloride, Pi-9 ha. lead, and PW-l0 ha. the maximum
reported concentration (24 ug/l) of toluene. In the other private vells
toluene va. le.. than 10 ug/l.
One of the fev con.i.tencie. in the data ~. the reported concentration of
vinyl chloride in the three manitorina vell., EMi-6 (32 ug/l 50'), EMW-2
(28 ug/l 55'), and EMi-3 (31 ug/l 60'), vhich appear to be in the general
d1rect1on of the predicted groundvater flow, i.e., in a northeasterly
direction as vell a. into the aquifer. Thi. uniformity of concentration
vould, alons v1th the general lack of precur.or chemical., indicate that
the vinyl chloride had been produced by biodegradation es.entially on the
.ite and that further rapid increa.e in,concentration i. not occurring.
In order for thia aicuation to occur, i.e., ea.entially complete degrada-
tion of the precuraor chemicals, it would require very alov miaration from
the .ource of the contamination to the neare.t monitoring vell. Since it
haa been nearly 15 yeara since the landfill cea.ed operation, there has
been 88pŁ8 eta. to develop an environment for biodegradation. Thus, the
occurreaee of aubatantial biodegradation vould not be surprising. In
fact, the concentration of the one possible precursor, trans-l,l-dichloro-
ethene, also a biodegradation product, is not constant in these three
vells, but is higher in the more distant vells, EMW-2 (27 ug/l 55') and
EMW-3 (24 ugil 60'), t~,n in the nearby vell EMW-6 (6 ua/l 50"). Since
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Page 6.- Hr. Chuck Pie~rosevicz
there are no repor~ed precursor compounds for the dichloroethene in the
groundV8,~..1ra.ples from these veils, this inv~rse gradient from the
landfill could indicate that the concentration of precursor chemicals in
~he landfill has diminished significantly since the vater at the more
distant vells 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 .ub.~antial variation in concen~ra~ion of o~her chemi-
cal species 8mona ~hese three vells canno~ be explained by the assumption
that they all came from the same source. . Hovever , vith only one set of
data to evaluate, any conclusions abou~ vhat may be occurrina in the
aroundvater is pure conjecture.
COMMENTS
The feasibility study on pase 2-12, atate~ that aite-apecific da~a for
aoil aamplea show that contaminant. auch a. toluene and methylene chloride
are found ln levels capable of produclns a leachate with concentrations
esceedlna the cleanup aoal.. The data cited we~e not provided for reviev;
hovever, the data available for revie. (remedlal investiaation) did not
appear to support this clatm.
~
The use of data for. a compound like n-nitroaodiphenylamine as an indicator
compound for thia aite doe. not appear to be valid. It vas reportedly
found in t.o on-.ite .ell.; however, becau.e of analytical limitations it
could not be dl.ttDaui.hed from dlphenylamlne. If this compound is to be
used a. aD indicator of contamlnation for this .1te, then it i. necessary
for its pce8ence to be documented by additional analytical vork 10 that
identiflcac10a 18 poaitive. . Without this effort, the potential presence
of thia eV8~und .hould not be used in the .ite evaluation.
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Pale 7 - Hr. Chuck Pietrosewic:
CONCLUSIORS AND RECOMMLNDATIONS
The alri~~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 presentinl a public health threat, or that it likely will in the
future. Since there is no demonstrated pathway for human e~posure to the
chemical. a.sociated with the site, most of the proposed remedial action
would be counterproductive for protection of public health because, with
the e~ception of cappinl the site, they all propose some effort to remove
and treat the contaminated vater and soil. Even thoulh the.e media appear
to be, in aeneral, only .lilhtly contaminated, this activity could contam-
inate the air or surface loil at levels treater than currently present,
thereby ezpOlina the local population unnecessarily.
Since the site reportedly vas not properly closed, proper closure and
monitorinl of the site should be provided.
M~~-:s-?
Jeffr~y A. Lybarler, H.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 OF~-S:~E
HOL.E HOL.E GROUND SURFACE SURF~C:E
WATER SOIL.. WATER SOIL. WATER
ug/l mg/kg ug/l mg/kg mg/kg
.,..5enic: 2=0 18
barlum 110
be,..yllium 19
c:admium 61) 1. ~
c:ob.lt 4~
c:h,..omium 111)0 1.2 3~
c:opp.r 1:00 51
le.d 5:00 18 =9
!nerc:u,..y 18 0.10
nic:kel 370 14 =9
selenium :7
",.n.dium 1100
::inc: 11000 33 :200
.c:etone 800 PRESENT
C-~ alkylbenzene 10
C-4 alkylben:ene 20
C-~ alkylben:amide 10
ben:ene 408 O.OO~ 8
c:arbon disulfide 18 0.001 8.9
c:hloroben:ene 297 Q.ll 4.7
c:hrysene PRESENT
1.:2-diC:hloroben:ene 39.3
1~4-diC:hloroben:ene 11 0.14
1.1-dic:hloro.thane . 1 ~.3
trans-1.2-diC:hloroetnene 33
.ndrin leetone PRESENT
l:thylben:ene 162 0.011 68
r' thy I ethe,. 7
ethylhe~anoic: ac:id 20
ben:o(a>anthrac:ene PRESENT
diben:o(a.n)anthrac:ene PRESENT
Sen:o(ghi)pe,.ylene PRESENT
ben:O(a>p~,.ene -I PRESENT
indeno(l. .3-C:d)py,.ene PRESENT
methylene c:hloride 4.8
methyl etnyl ketone 0.003 9.7
methyl isobutyl ketone ......
~J..
metho)(yC:hlo,. . PRESENT
1,2-diphenylnyd,.azine
lazoben:8ne 1.0
metnylnonanediol 70
methtlPentanediol 20
n.Ph halene 96 0.4:5 20
N-nitrosodi~nenYl.mine 7.6
Idipheny amine 16
o~~bisethO)(Y.~han. lOr)
PC -1:42 36
PCS-1:260 :8
PC8-12:;4 1.8
phenol 34 13
methtlPnenol :;.7
2-me nylphenol 46
4-methYI~henol PRESENT
2.4-dime hrlPhenol 13
bis(2-ethr he)(Yl)~ntnalate 96
di-n-buty phthala e 39 PRESENT
~,..op.nol 40
etrahyd,.ofu,.an 1 1
toluene 49 68 PRESENT
tric:hloroetnene ., PRESENT
-.,) ~w.~y~gneptanone 70
'.IIY. ~ii.a.ur4de 73
xylenes (total) =:0 0.:2 93
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APPENDIX B .
1
RESPONSIVENESS SUMMARY
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1.0
2.0
3.0
4.0
5.0
RESPONSIVENESS SUMMARY
HIPPS. ROAD LANDFILL SUPERFUND SITE
TABLE OF CONTENTS'
INTRODUCTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
OVERVIEW. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERN...............2
SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED
DURING THE PUBLIC COMMENT PERIOD AND EPA'S RESPONSES..........3
4 . 1 Heal th I s sues. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
4.2 Technical Issues......................................... 5
4.3 Water Treatment Issues................................... 6
4.4 Well Permitting/well Construction Issues.................7
4.5 Ground-water Treatment System............................9
REMAINING
CONCERNS. . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . . . . . . . . 10
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RESPONSIVENESS SUJlMARY
1.0
IR'l'RODUC'nOR
The U.S. Environmental Protection Agency (EPA} established a public
comment period from July 1, 1990 through August 31, 1990 for
interested parties to comment on EPA's Amended Proposed Remedial
Action Plan (PRAP) for the Hipps Road Landfill Site. (The citizens
in Jacksonville requested and were granted a 30 day extension to the
initial comment period.) The comment period followed a public
meeting on July 11, 1990, conducted by EPA, held at the Auditorium of
the Jacksonville Public Library, Webb Wisconnett Branch in
Jacksonville, Florida. The meeting presented the results of the
studies undertaken and the modified preferred remedial alternative
for the site. .
A responsiveness summary is required by Superfund policy to provide a
summary of citizen comments and concerns about the site, as raised
during the public comment period, and the responses to those
concerns. All comments summarized in this document have been
factored into the Agency decision of the alternative for cleanup of
the ground water at the Hipps Road Landfill Site.
This responsiveness summary for the Hipps1Road Landfill Site is
divided into the following sections.
2.0
OVERVIEW
This section discusses the recommended alternative for remedial
action and the public reaction to this alternative.
3.0
BACKGROUND ON COHKOHITY IHVOLVEMBHT
~
This section provides a brief history of community interest and
concerns regarding the Hipps Road Landfill Site.
4.0
SUHMARY OP MAJOR QUESTIONS AHD COMKBH'rS RECBIVED
AHD AGENCY RESPONSB
This section presents both oral and written comments submitted during
the public comment period, and provides the responses to these
comments.
5.0
REXAINIlfG CONCBRNS
This section discusses community concerns that EPA should be aware of
in design and implementation of the' remedial alternative for the
site. .
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2.0
OvBltVIBW
The proposed plan to modify the preferred alternative for
ground-water recovery was presented to the public in a fact sheet
re~eased on June 30, 1990 and at a public meeting held on July 11,
1990. The modified recommended alternative addresses the
ground-water contamination by extraction, air stripping and disposal
on-site instead of extraction and disposal at the Publicly Owned
Treatment Works (POTW). The major. components of the recommended
alternative include:
A system of recovery wells installed to capture the
contaminated water.
Recovery monitoring system to determine water levels inside
and outside of the capture zone to evaluate the hydraulic
performance of the system.
An off-site monitoring system consisting of monitoring wells
located in the vicinity of the off-site ground-water
recovery operation. During the ground-water recovery
operation, these wells will be sampled quarterly for
volatile organic compounds to determine the effectiveness of
the ~ecovery system. .
Recovered ground water will be ~outed via a pipeline to the
closed landfill site. Volatile organic contaminants (VOCS)
will be removed by air stripping on the site. Discharged
water will meet the MCLs.
The community, in general, is concerned about the potential for
contaminant release from the air stripping system. The Record of
Decision Amendment and this Responsiveness S~ary addresses the
concern in detail.
3.0
BACXGROURD ON COMMOlfI'l'Y INVOLVEMENT AND' CONCBRN
The Jacksonville community has been aware of the contamination
problem at the Hipps Road Landfill Site for several years. EPA
prepared a Record of Decision (ROD) on September 3, 1986. In
September 1988, a fact sheet was published to inform the public of
planned remedial design activities.
A public meeting was held by EPA on April 5, 1989 to present a
schedule for implementation of remedial design activities at the
site. The meeting also served to inform citizens of the Partial
Consent Decree entered by the Federal District Court in Jacksonville
on January 25, 1989.
-2-
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EPA conducted a public information meeting on August 15, 1989 to
present the'de.ign for the landfill closure to interested citizens.
and local officials and to provide an opportunity for further
discussion of concerns raised by citizens during the previous April
5, 19.89 meeting. EPA conducted another public'meeting on July 11,
19.90. At the meeting, EPA, in consultation with FDER, announced to
citizens that the Agency was considering modifying the proposed
alternative for ground-water recovery based on new information
affecting the cost effectiveness of two alternatives. A 30 day
public comment period was initiated and was extended 30 days at the
request of citizens. The comment period ended on August 31, 1990.
Ground-water Contamination Concerns: Property owners were
concerned with the contaminants to be emitted from the air
stripping system. The citizens were also concerned that private
wells were still being drilled in the area.
4.0
SUMMARY OP MAJOR OUESTIONS AND COMMENTS RECEIVED DURING THE
PUBLIC COMMENT PERIOD AND EPA'S RESPONSES.
4.1
Health Issues
1. The airborne chemicals produced as a result of the proposed
recovery system are going to be very danqerous for me and my family
to be breathing. Please halt all plans to install the proposed
recovery system until it can be determined, without any doubts, that
it will be safe for all residents living in the direct vicinity of
the site.
EPA ResDonse: In order to better define the air impacts associated
with the operation of the ground-water recovery and treatment system,
a detailed analysis of the system was conducted. The analysis
assumed that the recovery effort was divided into three time
intervals. Each interval would last roughly six months and would
approximate the time required to recover one-third of the volume of
the plume (one-third of the pore volume). Using the information from
the capture zone analysis prepared as part of the system design,
average concentrations for specific contaminants were calculated for
each time interval. Using these concentrations, the flow rate
through the strippers, and assuming continuous operation, the
pounds/day released into the air was calculated for each
contaminant. The total emission rate per day was calculated for
comparison w1~ the guidelines presented in the EPA guidance document
titled Control of Air Emissions from SUDerfund Air StriDDers at
SUDer fund Groundwater Sites (OSWER Directive 9355.0-28). This
guidance document says that control of air emissions from Superfund
air strippers should be considered when the actual emission rate
exceeds 15 #/day and the release is in an ozone non-attainment area.
(The Hipps Road Landfill Site is located in a non-attainment area.)
The emission rate from this air stripping system is calculated to
range from 0.013 #/day during interval one to a system maximum of
0.048 #/day in interval two.
-,J-
-------
It drops off to 0.04 t/day in int~rval three. Monitoringduring
operation w~ll confir.m the actual emission rate. Clearly the.
emiss.ion rate anticipated from the air stripping system is much below
the criteria for considering controls established for the Superfund
Program.
An air pollution model was then used to predict the concentration at
the nearest residence. Certain conservative assumptions were used
for the air model - the wind was as.sumed to blow the contaminants
toward the residence 100% of the time and meteorological conditions
contributed only minimally to dispersion. The resulting
concentrations were compared with the guidelines provided in the
Florida Department of Environmental Regulation interoffice memorandum
titled Final Air StriDDer Review Procedures: October 20. 1987.
Finally, the concentrations at the nearest residence were compared to
those concentrations that might be expected to contribute one excess
cancer in a population of 1,000,000 individuals if they were all.
exposed to this concentration continuously for a period of 70 years.
The predicted concentrations of contaminants at the nearest residence
to the Hipps Road Landfill are well below both FDER standards for
acceptable ambient concentrations and EPA guidelines for cancer risk
associated with exposure (to contaminants) for a lifetime.
2. What impact might the air emissions from the air stripper have on
an asthmatic or sensitive individual living next to the site?
EPA ReSDonse: An air impact model was used to predict the
concentration of air emissions from the air stripping system at the
nearest residence. The concentrations were compared to those
concentrations that might be expected to contribute one excess cancer
in a population of one million individuals if they were all exposed
to this concentration continuously for a period of 70 years. The
results of this analysis showed that concentrations at the nearest
residence to the landfill were well below both the State of Florida
standards for acceptable ambient concentrations and EPA guidelines
for cancer risk associated with exposure (to contaminants) for a
lifetime. How the sensitive individual might be effected cannot be
projected from the cancer risk. However, concentrations that result
in an "acceptable" cancer risk (one in one million) are generally
much lower than the concentrations that would be "acceptable" if we
were considering only a chemical's non carcinogenic effects and not
its cancer potency. In addition, an examination of the toxic effects
of both vinyl chloride and benzene indicates that neither chemical
targets the pulmonary system. Therefore, we have no data to indicate
that air emissions will have any adverse impact on an asthmatic or
sensitive person living near the site.
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3. Why take the risk of discharging any chemicals into the
neighborhood at all? Has anyone looked into the technology and the
cost effec~iV8ness of adding a carbon. filter to th~ air stripping to
eliminate all of the contaminants? .
EPA Res~onsel The technology for polishing ~ir emissions with carbon
treatment systems is one with a track record. However, for the low
contaminant concentration in the emissions for the Hipps Road
Landfill Site, the carbon treatment system performance would be
questionable. The suppliers for such a filter treatment provided a
cost estimate of between $40,000 to $280,000 for a two year operating
life.
It should be noted that an analysis of adding a carbon filter to the
air stripping system was not done previously in this case because the
concentration of the contaminants projected to be released falls
orders of magnitudes below the level that normally triggers its
consideration under national guidelines.
4. EPA always seems to place a priority on an economic remedy before
it considers the public health.
EPA ResDonse: The first priority the Agency considers when selecting
a remedial alternative is the protection10f human health. However,
Congress clearly spells out in the (CERLA) law that remedies which
are equally protective of health and the environment also must be
compared for cost effectiveness.
c,
4.2
Technical Issues
5. Is. it true that EPA has no measurable limi~s for vinyl chloride
(a site-related contaminant) because it is so dangerous?
EPA ResDonse: There is a National Prim~ry Drinking Water Standard
for vinyl chloride. Vinyl chloride is also a carcinogen. Under the
above standard the Maximum Contaminant Level or the HCL must be
attained when remediating the ground water. The HCL (the federal
standard) for vinyl chloride is two parts per billion. The State of
Florida standard is one part per billion.
6. How would BPA respond to statements attributed to Mr. Benjamim
Ross who claima that samples being collected now are not being
analyzed for the right chemicals?
EPA ResDonse: The testing conducted at this site, or any Superfund
site, is not limited to only those chemicals for which there exists a
standard. The analytical methods and equipment used can - and have -
. detected other contaminants than those commonly associated with the
site. While the equipment is not always able to specifically
~dentify the contaminant, ~t qoes report useful information about
them.
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The analytical data8heets list those as miscellaneous compounds.
When detec~ed at this site, their total concentrations have not been
high enough to warrant-further investigation.
7. I under8tand that the remedy will capture vinyl chloride, but
that dichloroethylene was present in the dump as well. Are plans
being made to remove dichloroethylene as well?
EPA ReSDonse: Yes, there is dichloroethylene at the Hipps Road
Landfill. This contaminant is found in the same locations as the
vinyl chloride. Also detected with the vinyl chloride is 1,2
dichloroethylene which is not as toxic as vinyl chloride. The air
stripping process will remove the dichloroethylene as well as the
vinyl chloride. The area that has been identified as the plume of
contaminated ground water is the area that also has the
dichloroethylene contamination. However, it should be noted that the
dichloroethylene levels detected are already below the levels that
are protective of human health.
8. Is there is a possibility that some of the vinyl chloride could
go into the Ortega River?
EPA ReSDonse: The site-related contaminants, if left untreated and
not removed from the ground water, would1eventually go into the
Ortega River.
One of the goals of the remedial investigation for the site was to
project what kind of concentrations might result in the Ortega River
if these contaminants were to move unimpeded -toward the waterway.
The study took into account rate of ground-water flow and amount of
dispersion. The results indicated that there „ould be no adverse
impact on the aquatic life in the river. The study further
concluded, that at the levels the contaminants were detected, the
public health would not be at risk.
9.
Why do the trees appear to be dying on the site?
EPA ReSDonse: There is no reason to believe that contamination is
the cause of trees dying on the site. When a major construction
project is undertaken, the water flow in the area can be
significantly altered. The construction process may disturb and even
kill roots and vegetation.
4.3
Water Treatment Issues -
10. Is the reason the City of Jacksonville refuses to except the
recovered ground water is because EPA cannot guarantee the
concentrations of contamination that would be sent to them?
EPA Attornev ReSDonse: We have been in discussion with the City of
Jacksonville for some time concerning taking contaminated ~~tc=~ from
a Superfund site.
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This is also an issue in other Superfund sites where the remedies
that were selected in records of decision called for" treatment and
disposal at municipal treatment plants. The City of Jacksonville in
our discussions had never refused to take the water. However, city
officials have expressed concerns regarding whether or not the city
would be assuming liability by accepting discharge from the Hipps
Road Landfill Site. In addition, the city was concerned that the
treatment plant (POTW) might violate its NPDES permit. There was
never a decision made or a conclusion reached that they would not
take the water. Because of escalating POTW costs, the remedy
selected in the 1986 Record of Decision could now cost $3.9 to $4.4
million. The on-site treatment, while equally protective of human
health and the environment, is estimated at $1.2 million (February,
1990 estimate) and is, therefore less expensive.
11. The contaminated ground water has already been determined to be
too toxic to go through the Jacksonville sewage system.
EPA ResDonse: In an effort to evaluate the toxicity of the ground
water, EPA conducted toxicity tests the week of February 14 - 19,
1990, on water collected from wells TMW-7I and TMW-7S in an area
northeast of the Hipps Road Landfill Site. These wells appear to be
in the most contaminated portion of the plume for volatile organics.
They were selected in an effort to generate the worst case
situation. ~ased on EPA's review of the toxicity test results, it is
felt that the results show that discharge to the POTW would not
contribute to toxicity to the POTW's waste stream influent. (ref:EPA
corresDondence to Wastewater Division. Jacksonville Public Utilities
DeDartment. ADril 17. 1990. RE: Groundwater Toxicitv Evaluation.
HiDDS Road Landfill Site. The study further concluded that at the
levels the contaminants were detected, the public health would not be
at risk.
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4.4
Well Per.mittina/Well Construction Issues
12. Administrative record documents indicate that test results from
well depths of 50 to 60 feet were disallowed or thrown out. Why was
this done? Also, is there a current document or model that
incorporates these earlier results in its findings/conclusions?
EPA ResDonsea No, earlier results were not incorporated. The reason
is that of a~ the wells that were constructed in the past, an
evaluation of the quality of the well in terms of its ability to
provide unbiased results was made. Based on that evaluation, wells
that had been installed by the EPA back in 1985, 1986 were the only
wells that were considered unbiased for producing quality results.
We installed what what we considered high quality wells, to as good a
standard as there is in the industry now to basically replace all of
the wells that have been used previously. That is essentially the
reason the earlier data from the previously constructed wells weren't
used. To answer the question concerning earlier sampling analyses
being thrown out of current studies, we should state that the results
weren't really thrown out. . .
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Earlier results are"'not in current reports primarily because we're
looking for-the current location of the plume. To have data from six
or seven years ago would not be helpful for coming up with the
design.
13. Are there plans to construct wells northeast of the site to
determine where the contamination plume is at the present time?
EPA Resoonse: From the data collected from the existing well network'
we have determined where the plume of contaminated ground water is at
the present time. From the proposed recovery system monitoring wells
and the recovery well network, we can further confirm the location of
the contamination plume.
14. What information did the newer wells, the wells constructed
according to your specifications yield that was different from the
previous results?
EPA Response: The newer wells were designed and constructed
specifically for environmental monitoring. In this way the
possibility of causing bias in the sample analytical results is
min~ized. The results of sample analyslsfrom the newer wells were
consistent with earlier sample results. This tended to confirm and
better detail our previous understanding'of the nature and extent of
contamination. In this way we also have independent support of the
data from earlier and less ideally constructed wells. Thus we can
more confidently factor earlier sampling results into our remedy
decision-making process.
15.
How deep is the deepest well that is cont~inated1
EPA ReSDonse:
Approximately 57 to 60 feet.
16. Why is the City of Jacksonville still allowing permits for wells
to be dug? Who is responsible for well permitting in Jacksonville?
EPA Response: The EPA has had discussions with Jacksonville
Bio-Environmental Services regarding the well permit program. The
City recoqnizes that it needs improved regulations to be able to
better control installation of wells in contaminated areas. The.
Agency has a180 referred the City to Dade County officials, who have
been dealing wdth this type of problem for several years.
Well permits are handled through the City of Jacksonville's
Department of Health, Welfare, and Bio-Environmental Services.
address is:
Their
421 W. Church Street
Jacksonville, Florida 32202-4111
(904) 630-3666
Mi. Gary V. Weise - Manager
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17. How will the pumping of large volumes of contaminated water
effect the n~ighborin9 wells? .
EPA ReSDonsea The area in which we are going to be pumping will
cause some drawdown right around the wells that we pump. We did a .
pumping test, and as part of the test, we pumped a test well at about
60 gallons per minute. The drawdown from the ~est was minimal. The
extraction wells we are installing will pump at about 40 gallons per
minute, so the effect of pumping will be somewhat less. In the
immediate vicinity there will be drawdown. There is not anyone using
wells in the area of contamination. In a radius of 50 feet to 100
feet away from a particular well, the drawdown will be essentially
minimal~ it will be on the order of a foot or a couple of feet.
4.5
18.
Ground-water Treatment System
How long will the air stripper be operated?
EPA ReSDonse: The air stripper will be operated until the cleanup
goals in the aquifer are met. The process could take one to three
years.
19. How often will testing of contaminan~s be be done on the
ground-water treatment system?
EPA ReDresentative ReSDonse: The first phase of the system is a
treatability study, which is a period of time when the system is
tested for effectiveness. During the study, the ratios of air to
water are adjusted to insure that the system is performing properly.
During that time, testing will be quite regular, probably at least on
a daily basis if not more often. As the performance of the system is
at the level it should be, the testing will be done quarterly. The
water that will be discharged from the treatment system will meet
drinking water standards.
20. Will institutional controls associated with the remedial action
include an investigation of residents not hooked up to city water
within the area of the ground-water contamination plume?
EPA ReDresentative ResDonse: A review of the location of the City
water lines relative to the area of off-site contamination has been
conducted (AUgu8t, 1990). The review lead to the conclusion that all
residences within the area of off-site contamination are currently
. connected to the municipal water supply.
21.
What effect will a rainy season have on recovery efforts?
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EPA ReDresentative Res90nse: A r~iny season will likely dilute the
contaminant plume somewhat and extend recovery efforts. The size of
the recoverY 8Y8tem and the corresponding treatment system are
believed adequate to accommodate a wetter than normal season. It
should have no 8iqnificant effect on the stormwater retention basin's
ability to handle the quantities of water ne~essary.
5.0
Remainina
Concerns
The community's concerns surrounding the Hipps Road Landfill Site
will be addressed in the following areas: community relations
support throughout the Remedial Design/Remedial Action, and
incorporation of comments/suggestions in the Remedial Design.
Community relations should consist of making available final
documents (i.e. Remedial Action Progress Reports, monitoring data,
etc.) in a t~ely manner to the local repository. Also, issuance of
fact sheets to those on the mailing list will further provide the
community with project progress and a schedule of events. The
community will be made aware of any principal desiqn changes made
during the project design. If at any time during the Remedial Action
new information is revealed that could affect the implementation of
the remedy or if the remedy fails to achieve the necessary design
criteria, the Record of Decision may be revised to incorporate new
technology that will attain the necessarx performance criteria.
Community relations activities will remain an active aspect of the
Remedial Action phase of this project.
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