United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-90/067
September 1990
EPA
Superfund
Record of Decision
Yellow Water Road, FL
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50272.101
REPORT DOCUMENTATION 11. REPORT NO. I 2. 3. Reclpient'o Acc..olon No.
PAGE EPA/ROD/R04-90/067
4. TIUe and SubdUe 5. Report Dote
SUPERFUND RECORD OF DECISION nC!/?A/90
Yellow Water Road, FL
6.
First Remedial Action
7. Aulhor(o) 8. Porfonning Organization RepL No.
8. Porfonning Orgainization Name and Address 10. Projecvra8l
, FQHM 272 (4.17)
(See ANSI.Z39.18)
See InstrucUons on Reverse
(Former1y NTlS-35)
Deportment of Commerce
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EPA/ROD/R04-90/067
Yellow Water Road, FL
First Remedial Action
Abstract (Continued)
ground water contamination will be addressed in a subsequent ROD. The primary
contaminants of concern affecting the soil and sediment are other organics including
PCBs.
The selected remedial action for this site includes excavating 3,560 cubic yards of
onsite contaminated soil and sediment with PCB concentrations greater than 10 mg/kg;
solidifying and stabilizing the soil and sediment, if a treatability study determines
the effectiveness of using solidification for organics; placing treated soil within
the old salvage operational area and covering the area with I-foot-thick soil cover;
conducting leachability studies of the treated mass; backfilling excavated areas with
clean soil and revegetating the site; implementing site access restrictions including
fencing; conducting ground water monitoring; and abandoning ground water wells within
the excavated area, if necessary. The estimated present worth cost for this remedial
action ranges from $1,119,000 to $1,448,200, (depending on the soil disposal method
used), which includes a total O&M cost of $62,600 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Onsite soil cleanup levels are based on the TSCA PCB
Spill Cleanup Policy for unrestricted sites. PCBs will be remediated to a level of
10 mg/kg with a minimum excavation depth of 10 inches, and excavated areas will be
covered with clean fill to reduce levels of PCBs to less than 1 mg/kg.
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,
Record of Decision
Operable Unit One
Declaration
SITE NAME AND LOCATION
Yellow water-Road Site
Baldwin, Duval County, Florida
STATEMENT OF BASIS AND PURPOSE
This deqision document presents the selected remedial action for
Operable Unit One at the Yellow Water Road Site in Baldwin,
Duval County, Florida, which was chosen in accordance with the
Comprehensive Environmental Response Compensation and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments
Reauthorization Act of 1986 (SARA), and, to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This decision is based on the
administrative record file for this site. The attached index
identifies the items that comprise the administrative record
upon which the selection of the remedial action is based.
The State of Florida, as represented by the Department of
Environmental Regulation (FDER), 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
imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE REMEDY
The remedy selected by EPA will be conducted in two separate
operable units. Operable Unit One addresses the source of the
contamination by excavating, stabilizing, and solidifying the
PCB contaminated soils. Operable Unit Two will address the
appropriate remediation for the ground water.
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The major components of the selected remedy for Operable Unit
One include:
o
a treatability study to verify the effectiveness of the
technology in solidifying/stabilizing PCBs contained in
Site so-ils;
o
t~e excavation of soils having PCB concentrations in
excess 0: 10 ppm with subsequent treatment by
stabilization/solidification;
o
placement of the treated soils in the former
operational area of the Site;
o
backfilling excavated areas with clean soils (less than
1 ppm PCB concentration);
o
placement of a vegetated one-foot thick soil cover over
the treated soil mass (monolith) and securement of the
monolith by a security fence;
o
provision of a vegetative cover over the remainder of
the Site and;
o
long-term management controls including operation and
maintenance of the monolith, vegetative cover and
fence.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate for this remedial action
and is cost-effective. This remedy satisfies the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element and
utilizes permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum extent
practicable.
Because this remedy will result in hazardous substances
remaining on-site above health-based levels, a review will be
conducted within five years after commencement of remedial
action to ensure that the remedy continues to provide adequate
protection of human health and the environment.
~fP 2 8 1990
. '
"1 .
Date
- - "-- ,
'Greer C. Tidwell
Regional Administrator
-
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Record of Decision
The Decision Summary
Yellow Water Road Site
Baldwin, Duval County, Florida
u.s.
Prepared by:
Environmental Protection
Region IV
Atlanta, Georgia
Agency
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1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
TABLE OF CONTENTS
Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1
1.1 Scope and Role of Operable Unit......................2
Site Name, Location and Description.......................2
Site History and Enforcement Activities...................6
Community Relations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9
Scope and Role of Response Action Within Site Strategy... .10
5.1 Soils/Sediments..................................... .10
5.2 Groundwater.......................................... 10
Summary of Site Characteristics.......................... .10
6 . 1 Sit e Ge 0 logy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 0
6.2 Site Hydrogeology. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11
6.3 Site Contamination...................................11
6.3.1 Volatile Organic Compounds................... .15
6.3.2 Base/Neutrals................................. 15
6.3.3 Polychlorinated Biphenyls (PCBs)............. .21
6.4 Surface Water and Sediments......................... .21
6.5 Air.................................................. 24
Summary of Site Risks.................................... .24
7.1 Identification of the Contaminants of Concern....... .24
7.2 Human Health Risks.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26
7.2.1 Exposure Assessment Summary.................. .26
7.2.2 Toxicity Assessment Summary.................. .26
7.2.3 Risk Characterization Summary................ .29
7.3 Environmental Risks.................................. 38
Remedial Action Goals and Objectives..................... .39
Description of Soil/Sediment Alternatives................ .41
9.1 Alternative 1 - No Action............................ 41
9.2 Alternative 2 - Excavation/Disposal/TSCA-Compliant
Land fill. . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
9.3 Alternative 3 - Excavation/Disposal/Incineration.... .44
9.4 Alternative 4 - Excavation/Solvent Wash/Extraction
D i s po sa 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
9.5 Alternative 5 - Excavation/Stabilization/
Solidification...................... .46
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10.0
11.0
12.0
Comparative Analysis of Soil/Sediment Alternatives...... .48
10.1 Overall Protection of Human Health and the
Environment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .48
Compliance With Applicable or Relevant and
Appropriate Requirements (ARARs)........... .49
- Long-term Effectiveness and Permanence....... .52
Reduction of Toxicity, Mobility, or Volume
Through Treatment.......................... .52
- Short-term Effectiveness......................53
Implementability..... ..... ~.................. .54
10.2
10.3
10.4
10.5
10.6
10.7
10.8
10.9
Cost. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .54
State Acceptance.. . . . . . . . . . . . . . . . . . . . . . . . . . . . .55
Communi ty Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . .55
Selected Remedy............................. . . . . . . . . . . . . .55
11.1 Operation and maintenance. . . . . . . . . . . . . . . . . . . . . . . . . .56
Statutory Determinations......... .... ................... .56
12.1 Protection of Human Health and the
12.2
12.2.1
12.2.2
12.2.3
12.2.4
12.2.5
12.2.6
12.3
12.4
12.5
12.6
Environment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .57
Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs)........... .57
Occupational Safety and Health Administration
( OS1-!A.) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57
Clean Water Act/Safe Drinking Water Act...... .57
National Pollutant Discharge Elimination
System (NPDES).............................. 57
Resource Conservation and Recovery Act
( RCRA) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58
Toxic Substance Control Act: (TSCA).......... .58
PCB Spill Cleanup Policy..... ................ .59
Cost Effectiveness............ ............... .59
Utilization of Permanent Solutions and
AlternativeTreatment or Resource Recovery
Technologies to the Maximum Extent
Practicable. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .59
Preference for Treatment as a Principal
Element. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .60
Documentation of Change...... ................ .60
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Figure 2.1
Figure 2.2
Figure 2.3
Figure 6.:
Figure 6.2
Figure 6.3
Figure 6.4
Figure 6.5
Figure 6.6
Figure 6.7
Figure 6.8
Figure 6.9
Figure 6.10 -
Figure 6.11 -
Figure 7.1
Figure 9.1
LIST OF FIGURES
~ey Site Map.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Site Plan........................................ 4
Ownership Plat Map...............................5
Geologic and Hydrogeologic Cross-Section
Locations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12
Geologic Cross-Section A-A'..................... .13
Geologic Cross-Section B-B'..................... .14
Soil Boring Location Map........................ .i6
Soil Sample TVOC Concentrations
(Ttlestern Areas) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Soil Sample TVOC Concentrations
(Eastern Areas) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18
Soil Sample Phthalate Concentrations
(Western Areas) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19
Soil Sample Phthalate Concentrations
(Eastern Areas) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20
Soil Sample PCB Concentrations
(Western Areas) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22
Soil Sample PCB Concentrations
(Eastern Areas) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23
Fixed-Media PCB Air Sample Locations............ .25
Soil Sample PCB Concentrations
(Western Areas) for Risk Characterization....... .30
Soil Excavation Area PCB Concentrations
Greater Than 10 ppm............................. .43
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Table 7-1
Table 7-2
Table 7-3
Table 7-4
Table 7-5
Table 7-6
Table 7-7
Table 7-8
Table 7-9
LIST OF TABLES
Preliminary Release Source Analysis.............. .27
Matrix of Potential Exposure Pathways............ .28
So.il Analysis
Sector 1 - Analysis for PCBs..................... .31
Soil Analysis
Sector 2 - Analysis for PCBs..................... 32
Soil Analysis
Sector 3 - Analysis for PCBs........ . . . . . . . . . . . . . .33
Soil Analysis
Mean Soil PCB Concentrations..................... .34
Soil Analysis
Additional Cancer Risk Due to PCB Exposure
Residential Scenario..... .... .................... .35
Assumptions Used to Estimate Exposure And Risk
From Contaminated Soils in a Residence........... .36
Soil Analysis
Additional Cancer Risk Due to PCB Exposure
Parkland Scenario................................. 37
LIST OF APPENDICES
Appendix A - Site Data
Appendix B - Responsiveness Summary
Appendix C - State Concurrence Memorandum
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Record of Decision
Summary of Remedial Alternative Selection
Operable Unit I
Yellow Water Road Site
- Baldwin, Duval County, Florida
1.0 Introduction
The U.S. EPA's involvement with the Yellow Water Road Site began
with a removal action initiated in November 1984. At the outset
of the removal, the Site contained electrical transformers,
liquids, and soils, contaminated to varying degrees with
polychlorinated biphenyls (PCBs). During the course of this
removal action, the transformers were drained, steam-cleaned and
stored on-site, the liquids were placed in secured, on-site
holding tanks, and contaminated soils were excavated and
stockpiled.
The Yellow Water Road Site was included on the National
Priorities List in June 1986. In March 1987, notice letters
were sent to the Potentially Responsible Parties (PRPs) who had
been identified for the Site. By May 1987, a group of the PRPs
had joined together and formed the Yellow Water Road Steering
Committee.
In May 1988, under EPA oversight, the Steering Committee
undertook additional removal activities at the Site, which were
completed in July 1988. The removal activities included the
off-site disposal of the transformers and the previously
stockpiled contaminated soils and the off-site incineration of
the PCB containing liquids.
Under a Consent Order dated September 24, 1987, a Remedial
Investigation/Feasibility Study (RI/FS) was performed by
Conestoga-Ro.ers & Associates on behalf of the Steering
Committee, again under EPA oversight. The resulting RI and FS
Reports were submitted in April and August 1990, respectively.
On August 28, 1990, EPA made the FS Report and
for Operable Unit One available to the public.
Plan addresses the residual soil contamination
on-site.
the Proposed Plan
This Proposed
remaining
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1.1
Scope and Role of Operable Unit
The Remedial Investigation (RI) identified the areas of soil
contamination to be remediated but was not of sufficient scope
to thoroughly define the extent of migration of PCBs in ground
water. Addition61 data is required to determine if migration of
PCB contaminated ground water is occurring and to further
evaluate treatment alternatives for the PCB contaminated ground
water. As a result, EPA has decided to implement cleanup of the
site in two operable units. The first operable unit, which is
addressed in this Record of Decision (ROD), will eliminate the
potential for direct exposure to the contaminated soils. The
investigative tasks of the second operable unit will include
installation of additional ground water monitoring wells,
additional surface and vadose zone soil and ground water
sampling, and further analysis of ground water technologies. A
Record of Decision will then be written to address potential
ground water contamination.
This ROD has been prepared to summarize the remedial alternative
selection process and to present the selected remedial
alternative for the first operable unit.
2.0 Site Name, Location and Description
The Yellow Water Road site is located off Yellow Water Road
(Florida State Road 217) approximately one mile south of
Baldwin, Duval County, Florida (see Figure 2.1).
The site encompasses approximately 14 acres of predominantly
vegetated land with limited topographical relief. Dense woods
that can be viewed as a natural resource are located on the
perimeter of the site's boundary. Surface elevations across the
site generally do not vary. more than one or two feet except for
a few shallow man-made drainage ditches (see Figure 2.2).
The. land adjacent to the site is used for many commercial
purposes. Property owned by Florida Power & Light Company is
located west of the site. Indian Head National Bank of Nashau
owns property situated northwest, west, south, and southeast of
the site. Property to the north is owned by Montgomery L.
Broward, and property to the northeast is owned by Fred B.
Miller, Jr. Some property to the east, across Yellow Water
Road, is subdivided into residential plots .bearing the name
Village Green Subdivision. Interstate 10 is positioned north of
the site, and Seaboard Coast Line Railroad owns property located
to the northwest (see Figure 2.3).
The immediate on-site population is presently estimated to
include five persons. An analysis of the population of the
Traffic Analysis Zone (TAZ) in which the site is located shows
an approximate.surrounding population of 350 persons. It is
estimated that the current population of this area will remain
relatively constant until the year 2010.
-2-
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ASSUMEO lU."S Of fORMER OPERAtiONal AREA
APPROXIMAIE lOCATION Of E XIS TlNG WAif R SUPP\f ...U l S
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Two residential buildings, consisting of a one-story family
dwelling occupied by the Hyman family and a house trailer
occupied by the Tyer, Jr. family, are located on the site. Also
located on-site are assorted multi-purpose outbuildings which
include storage~heds, a pump enclosure and a carport. The only
other permanent structure located on-site is a chain-link fence
surrounding the former operational area which covers
approximately three acres.
The dominant body of water nearest the site is the St. Johns
River. Ground water flows from east to west across the site.
There are no discharge areas on the site or immediately
downgradient from the site.
3.0 Site History and Enforcement Activities
Prior to commercial development of the Site, the property was
owned by Mr. Hardlee Spence, who used the land for dairy
farming. In the late 1940's, the land was purchased by Mr.
Robert C. Tyer for eventual commercial development.
Title to the property was transferred by Mr. Tyer to the present
owner, American Environmental Energy Corporation (AEEC) in
January 1982. In October 1981, AEEC had entered into a joint
venture with two other corporations, the American Electric
Corporation (AEC) and the American Environmental Protection
Corporation (AEPC) , with the intent of moving an incinerator to.
the Site and obtaining a permit under the Toxic Substances
Control Act (TSCA) to incinerate PCBs. The principal
individuals involved in this joint venture were Mr. Tyer and Mr.
Maxwell Cobb.
As part of this enterprise, beginning in 1981 or 1982, PCB
contaminated liquids and equipment were stored at the Site. The
incinerator permit was never obtained, and the PCB contaminated
materials continued to be stored on-site.
By October 1982, the joint venturers had parted ways, and AEEC
and Mr. Tyer sued AEC and Mr. Cobb and obtained a restraining
order preventing Mr. Cobb from entering onto the Site. After
barring Cobb and AEC's access to the Site, Tyer and AEEC
salvaged valuable metals such as copper from the transformer
carcasses, spilling PCB liquids and causing soil contamination
at the Site.
In 1982, a customer of AEC, Dickerson Asphalt Company, filed
suit against the Department of Defense (000) under the Federal
Tort Claims Act. The suit alleged that PCB liquids sent by 000
to ABC were sold to Dickerson through a third party as waste
oil. The lawsuit and the conditions noted by EPA TSCA
inspectors led EPA, in cooperation with the FBI, to begin a
criminal investigation of the operations of ABC and Mr. Cobb.
The investigation centered on a contract between ABC and 000 for
disposal of PCB contaminated liquids, equipment, and materials.
-6-
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--.--
I
At a criminal trial involving AEC's performance under the
contract with 000, the prosecution centered on 47 PCB
transformers. AEC had reported to 000 that they had disposed of
the transformers at TSCA approved facilities when they had
instead placed t~em at the Yellow Water Road Site. Although the
defendants were-acquitted by a jury on these charges in May
1984, guilty pleas were entered by Mr. Cobb and AEC's
vice-president, X~chael Hamm, on two unrelated criminal charges
uncovered durin~ the course of the investigation.
In the fall of 1984, Duval County cited Mr. Tyer, as president
of AEEC, for violations of local PCB storage ordinances. The
County ordered Tyer to remove all PCBs and PCB contaminated
items, to investigate the Site to determine the extent of
contamination, and to determine the cleanup and monitoring
activities whic~ were needed. Tyer informed the County that he
was financial:y unable to meet these demands, and EPA's
Emergency Response and Control Section was called in to respond.
In November 1984, at the outset of the initial removal action
conducted by EPA, the PCB contaminated materials stored at the
Site included 719 electrical transformers and a large amount of
PCB contaminated liquid. During this removal action, the
transformers were drained, steam cleaned, and stored on-site,
and approximately 100,000 gallons of PCB contaminated fluids
were drained to secured, on-site holding tanks. Approximately
3,000 cubic yards of soil contaminated with PCBs were also
excavated and stockpiled on a concrete pad.
EPA proposed to incinerate the PCB contaminated fluids and soil,
and, in January 1985, the City of Jacksonville conditionally
approved the incineration of this material, pending an amendment
to a city ordinance which prohibited the incineration of PCBs
within the city limits. However, the Baldwin community opposed
on-site incineration and, in February 1985, the Jacksonville
City Council rejected the incineration proposal.
In order to complete the removal action, EPA secured the Site by
covering the stockpiled Boil with a synthetic protective
covering and locking the gate. At that time, the responsibility
for overseeing the Site was temporarily transferred to the City
of Jacksonville Department of Health, Welfare, and
Bio-Environmental Services.
In March 1985 the Florida Department of Environmental Regulation
(FDER) issued a notice to the various principals of AEC and AEEC
based on the detection of trichloroethene contamination in four
drinking water wells located upgradient of the Site. This
notice advised them that the site was in violation of State law
and that a Contaminant Assessment Plan (CAP) and a Remedial
Action Plan (RAP) must be developed and implemented to address
the contamination of the site. Subsequent groundwater
assessments were conducted which indicated that the groundwater
contamination was limited to within the site boundaries.
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On April 15, 1985, EPA completed a Hazard Ranking System (HRS)
package for the Site. The aggregate HRS score derived for the
Site was 30.26. This score was based primarily on the ground
water exposure pathway.
On June 14, 1985, EPA Region IV issued an order under Section
106 of CERCLA to ~~. Tyer, compelling him to cease various
site-related activities. This order restricted the removal,
salvaging, cleaning or emptying of the transformers on-site
without proper notification to the officials listed in the
order.
The Yellow Water Road Site was proposed for the National
Priorities List (NPL) in Update 4 on September 18, 1985 (50 F.R.
37950), and the Site was placed on the NPL on June 10, 1986.
Ranked by its HRS score, the Site was listed 658th out of the
888 sites listed on the NPL in June 1986.
On September 5, 1986, demand letters were mailed to Robert C.
Tyer and Janice L. Tyer, as site owners and operators, as well
as to AEEC, as a site owner. Demand letters were also sent at
that time to the two generators of hazardous substances found at
the Site who were known to EPA at that time.
In October 1986, Region IV mailed information request letters to
approximately 90 additional parties. The information obtained
in response was compiled for EPA Region IV by the EPA National
Enforcement Investigation Center. They generated a volumetric
ranking of the PRPs. In March 1987, EPA sent notice and demand
letters to the 67 PRPs who had been identified.
By mid-1987, 53 of the 67 identified PRPs had joined together
and formed the Yellow Water Road Steering Committee (the
Steering Committee). Subsequently, EPA and the Steering
Committee entered into an Administrative Order by Consent dated
September 24, 1987, for the performance of an RIfFS at the Site.
On March 8, 1988, the United States filed suit against Mr. Cobb,
Mr. Tyer, AEC, and AEEC, in the United States District Court for
the Middle District of Florida, Jacksonville Division, Civil
Action No. 88-205-CIV-J14. By this action, EPA seeks to recover
its past costs associated with the Site and seeks a declaratory
judgment on liability for future costs. Approximately 50
generator PRPs have signed agreements tolling the statute of
limitations on the United States' cost recovery claims until
December 1990.
In May 1988, EPA and the Steering Committee entered into an
additional Administrative Order by Consent, under which the
Committee undertook an interim surface removal action at the
Site under EPA oversight. This removal action was completed in
July 1988. The removal activities included the demolition of an
on-site warehouse, disposal of the resulting debris and the
-8-
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previously stockpiled contaminated soil, off-site incineration
of 78,854 gallons of PCB containing liquids, disposal of 704
transformers, and disposal of 18,690 pounds of potential PCB
capacitors. The PCB contaminated soils were transported to
Chemical Waste ~anagement's permitted disposal facility located
in Emelle, Alabama. The PCB contaminated liquids were
transported by rail to SCA in Chicago, Illinois, for
incinerat.:.on.
RI/FS field activities were conducted at the Site from November
1988 to ~arch 1990. Soil and sediment samples were collected
and 18 groundwater monitoring wells were installed and sampled.
The resulting RI and FS Reports were submitted to EPA in April
and August 1990, respectively. The FS Report and the Proposed
Plan for Operable Unit One were made available to the public on
August 28, 1990, commencing the 30 day period for public
comment.
4.0 Community Relations
In accordance with CERCLA 113 and 117 requirements, a Community
Relations Plan (CRP) for the Yellow Water Site was developed.
This Community Relations Plan outlines citizen involvement and
the community's concern.
The most active period of community involvement with the Yellow
Water Road site occurred during 1984/1985 when EPA proposed to
bring a portable incinerator on-site to burn PCB-contaminated
materials stockpiled by EPA. Because of community opposition to
on-site incineration, EPA decided against incineration as a
viable alternative for remediating PCB contaminated soils
stockpiled within the former operational area of the site.
Media coverage for the site has been sporadic since 1984.
Minimal community involvement has occurred with regard to the
site since 1985.
An RI Fact Sheet for the Yellow Water Road site was issued to
the public in December of 1988. All site-related documents were
made available to the public in the information repository
located in the Baldwin City Hall and at the EPA Records Center
in Region IV. Following the release of the RI/FS Fact Sheet,
an availability session was held on Tuesday, May 29, 1990, from
7:00pm to 9:00pm at the Mamie Agnes Jones Elementary School. At
this meeting, EPA officials provided an update on site related
activities in addition to answering questions from concerned
Jacksonville citizens.
A public meeting was held on September 4, 1990 to present EPA's
preferred remedial alternatives for the soils/sediments at the
site. During the public meeting the community was informed of
the availability of a Technical Assistant Grant (TAG). The
-9-
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public was provided an opportunity for public comment on the
remedial alternatives from August 28, 1990 to September 27,
1990. A response to the comments received during the public
comment period is included in the Responsiveness Summary, which
can be found in~ppendix B of this Record of Decision.
This decision document presents the selected remedial action for
the Yellow Water Road site, in Baldwin, Duval County, Florida,
chosen in accordance with CERCLA, as amended by SARA and, to the
extent practicable, the National Contingency Plan. The decision
for this site is based on the administrative record.
5.0
Scope and Role of Response Action Within Site Strategy
5.1
Soils/Sediments
This ROD addresses the source of contamination at the Yellow
Water Road Site. PCB contaminated soils/sediments were found
above the Toxic Substance Control Act (TSCA) recommended level
of 10 ppm of PCBs in soils/sediments for an unrestricted area.
Consequently, PCBs in soils/sediments at the Yellow Water Road
Site pose the principal threat to human health and the
environment because of the risks associated with possible
ingestion or dermal contact. The cleanup objectives for this
ROD are to prevent current or future exposure to the
contaminated soils/sediments through treatment and containment,
thereby reducing the migration of existing contaminants.
5.2
Ground Water
The Remedial Objectives for contaminated ground water associated
with the Yellow Water Road Site will be addressed in a separate
Operable Unit and Record of Decision.
The scope and extent of ground water remediation will be based
on the results of additional ground water testing to be
conducted during October/November 1990, and data previously
collected during the RI. This data will serve as the basis for
determining remediation requirements for site contaminated
ground water.
6.0 Summary of Site Characterizations
6.1 Site Geology
The Yellow Water Road site is underlain by approximately 75 feet
of unconsolidated sand, silt, and clay. The overburden rests on
an approximately 20-foot-thick layer of coquina limestone and
calcareous sandstone. This unit is underlain by the Hawthorn
Formation, a thick sequence of silty clay, clayey sand, and
-10-
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sandy limestone. Four stratigraphic units were encountered
dur~ng the RI ranging from five to 35 feet in thickness.
The upper unit consists of light brown to brown fine silty sand
and f~ne sand. -Thin, discontinuous sandy clay and clay layers
are a~so present in this unit. The clay unit, from five to 15
feet thick, has a high plast~city and is inferred to be
continuous across the site. The hydrometer analyses performed
on this un~t sho~ that the clay contains from 25 to 47 percent
silt and very fine sand. The next unit consists of fine to
medium sand and silty sand with gravelly and shelly sand layers
being common. The lowermost unit encountered is made up of
poorly indurated medium to coarse coquina and brown, poorly
cemented fine to medium calcareous sandstone. Figures 6.1
through 6.3 il~ustrate geologic cross sections at the Site.
6.2 Site Hydrogeology
The Yellow Water Road Site is underlain by two major aquifer
systems, the shallow aquifer and the Floridan Aquifer systems.
Water from the shallow aquifer is considered of adequate quality
for domestic use. Although the iron content of the shallow
aquifer is higher than the lower Floridan Aquifer, it has a
lower hardness and chloride content. Recharge of the shallow
aquifer is chiefly by rainfall. The Floridan Aquifer is the
major source of ground water in northeast Florida. The Floridan
Aquifer is recharged through sinkholes and by downward leakage
from surface water bodies and the shallow aquifer where the
aquitard is thin or absent. Based on available information and
close examination, there are no sinkholes on or within the
vicinity of the Yellow Water Road site. Wells 40 to 150 feet in
depth within the Florida Aquifer supply water for stock,
domestic, and irrigation users. Small diameter wells in the
sand unit yield between 10 to 25 gallons per minute (gpm).
Wells in the limestone can yield as much as 80 gpm for two-inch
wells. Water yield from wells in the Floridan Aquifer vary
depending on depth, artesian pressure, and transmissivity.
However, wells two to six inches in diameter can yield as much
as 500 gpm.
6.3
Soil Contamination
The soil sampling phase was designed to establish horizontal and
vertical contaminant boundaries throughout the site. Sampling
stations for the soil borings were located on the nodes of a
lOO-foot square grid covering all cleared and unobstructed areas
of the site including the fenced former operational area. The
primary east-west baseline for the grid was established in a
main surface water swale running parallel to the site access
road. In order to further refine areal PCB contaminant
boundaries, additional surficial soil samples were collected in
March 1989, at locations off-set from established nodes. In
-11-
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FICUKE O. I
GEOLOGIC AND HYDROGEOLOGIC
CROSS-SECTION LOCATIONS
YELLOW WATER ROAD SITE
Baldwin, Florida
- ------------------
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100
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CEOIOGIC CROSSSECTlON A-A'
~ YELLOW WA TER ROAU SITE
Baldwin Florida
J
-------
addition, five soil samples were collected for volatile Organic
Compound (VOC) analysis during the January/February 1990
sampling event. Figure 6.4 illustrates the soil boring
locations for the site. The following subsections describe the
extent of contamination found in the surface soils at the site.
6.3.1
Volatile Organic Compounds (VOCs)
VOCs that were identified in investigative samples without
associated blank contamination at concentrations above the
Practical Quantitating Limit (PQL) included acetone, methylene
chloride and toluene. Quality Assurance (QA) analysis verified
that the presence of acetone and methylene chloride was due
primarily to equipment decontamination solvents and/or
laboratory contamination. Only 23 of the 105 investigative soil
samples analyzed were found to contain VOC concentrations
(without associated blank contamination) above the PQL. In most
cases for which VOCs, (other than acetone or methylene chloride)
were found, concentrations were estimated due to their presence
below PQLs. VOC concentrations in soils (excluding those for
methylene chloride and acetone) ranged from non-detected (NO) to
0.34 mg/kg for toluene.
Total VOC concentrations (less acetone) were calculated and are
shown on Figures 6.5 and 6.6 Results of the sampling program and
assessment of the detailed field and analytical Quality Control
(QC) data indicate that VOC soil contamination is not
significant at this Site. Soil sample VOC data are summarized
in Appendix A.
6.3.2
Base/Neutral Organic Compounds (B/Ns)
The predominant base/neutrals (B/NS) found in surficial soils
can generally be divided into two groups based on similarity of
structure, namely phthalate esters and Polynuclear Aromatic
Hydrocarbons (PAHs). Only 12 of the 96 investigative soil
samples analyzed for B/Ns contained phthalate esters (without
associated blank contamination) above the PQL. Phthalate esters
concentrations ranged from NO to 1.6 mg/kg. Phthalate esters
are ubiquitious in the environment, especially at concentrations
less than 1.0 mg/kg. Figures 6.7 and 6.8 illustrate the
distribution of total phthalate esters throughout the Site.
PAHs were found in areas of high PCB contamination and areas of
heavy traffic or surface water runoff sinks from heavily
travelled areas. Only three (3) of the ninety-six (96) .
investigative samples analyzed were found to contain detectable
PAH concentrations (unqualified due to associated blank
contamination), which ranged from NO to 4.1 mg/kg. The
locations of the PAH concentrations indicate that they are
likely to have come from automotive and/or heavy equipment oil
drippings resulting from movement of these vehicles around the
Site. Soil sample BIN data are summarized in Appendix A.
-15-
-------
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. I
FICUKE 6.4
SOIL BORING LOCA TlONS
YELLOW WATER ROAD SITE
Baldwin, Flodda
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FIC[JKE 6.5
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SOIL SAMPLE PHTHALATE CONCENTRA TlO~
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SOIL SAMPLE PHTHALATE CONCENTRA nONS
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6 . 3 . 3
Polychlorinated Biphenyls (PCBs)
All polychlorinated biphenyls (PCBs) found at concentrations
greater than 1.0 mg/kg at the site were located within, adjacent
to, or north and Nest of the former operationa~ area.
Fifty-eight (58~ of the 151 investigative soil samples analyzed
for PCBs had de~ectable concentrations of PCBs, ranging in
concentrations f~om the PQL to 660 mg/kg. Few sampling
locations contained PCB concentrations in excess of 1.0 mg/kg
and only 10 locations contained PCB concentrations in excess of
10.0 mg/kg. The presence of residual PCBs was mainly isolated
to areas of known PCB-handling operations. Figures 6.9 and 6.1Q
illustrate PCB concentrations in the western and eastern
portions of the site, respectively. Soil sample PCB data are
summarized in Appendix A.
6.4 Surface Water and Sediments
Surface water and sediment samples were collected in drainage
courses on-site and downgradient from the site, so that
potential pathways or receptors of surficial contaminant
migration could be identified. Because the site is
topographically very flat, the sample locations were selected
after a local storm event. Surface drainage at the site is
generally from south to north. Surface water and sediment
sampling locations are shown on Figure 6.6
Low-level VOC contamination was found in surface water and
sediment samples. Close analysis of the samples showed that
overland transport and deposition of site-related VOCs were not
significant at this site.
BIN extractable compounds were limited solely to
di-n-butylphthalate and bis(2-ethylhexyl)phthalate in sediments
and bis(2-ethylhexyl)phthalate, dimethyl phthalate,
butylbenzylphthalate, and diethylphthalate for surface waters.
Of the 20 investigative samples analyzed, two samples were found
to contain unqualified phthalate ester concentrations above the
PQL. The concentrations, all of which were found in surface
water samples, ranged from ND to 0.018 mg/L.
Sediment sample PCB concentrations ranged from ND to 60.5
mg/kg. For samples collected north of the former operational
area, a distinct trend was evident in which PCB concentrations
appeared to be inversely related to lateral distance from the
former operational area. The only apparent exception in
sediment PCB data was the occurrence of 8.9 mg/kg total PCBs at
-21-
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SOIL SAMPLE PCB CONCENTRA nONS
(WESTERN AREAS)
YELLOW WATER ROAD SlTt
Baldwin, norida
-------
a location 400 feet south of the former operational area's
southwest corner. PCB concentrations detected in surface water
were low and were limited to three locations, all of which were
associated with PCB-containing sediments. The presence of PCBs
in these sample~may be due to the presence of contaminated
particu~ates (al~ samples were unfiltered) and/or low-level
solubi~~za~~on 0: PCBs from underlying contaminated sediments.
6.5 Air
Air monitoring data obtained during the 1988 Surface Removal
Action indicated that airborne PCBs (both particulate and vapor
phase) were not problematic (all data were below detectable
levels) at this site. Prior to drilling and sampling
activities, an HNu photoionization detector (PID) was used to
determ~ne background air quality upwind of the Site. Instrument
readings were taken continuously at each drilling location. No
instrument readings above background levels were observed at any
time. In addition, PCBs were not detected during air monitoring
conducted in support of the RI Health and Safety Program.
Evaluation of these data supported by historical information
leads to the conclusion that airborne contaminant transport is
not a significant migration pathway at the Yellow Water Road
Site. (Figure 6.11).
7.0 Summary of Site Risks
7.1 Identification of the Contaminants of Concern
In choosing the contaminants of concern, consideration is given
to factors such as, "any available site background data,
disposal history (and records, if available), types of remedial
actions being considered, on site and off site chemical analysis
data and site characterization data necessary for exposure
assessment" (Chapter 3, "Superfund Public Health Evaluation
Manual" EPA/540/1-86/060, OSWER Directive 9285.4-1, December
1989) .
PCB compounds were found to be the contaminants of concern for
all media (air, surface water and sediments, and soil). All
other contaminants discussed previously have been discounted as
contaminants of concern for various reasons (i.e. concentrations
of contaminants that are typical of the region that are not
site-related, that are of low prevalence/occurrence, or that are
laboratory analysis related). Overland PCB transport processes
are limited to surface water movement in and adjacent to the
site. Surface drainage at the Site is generally from south to
north. Due to the characteristic non-polar nature of most PCBs,
they are relatively insoluble in water but readily adsorbed to
most particulate matter. By analyzing the surface water and
sediment PCB data, it is apparent that the predominant mode of
overland PCB transport at Yellow Water Road is by sediment
transport in conjunction with surface water flow.
-24-
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SOIL SAMPLE PCB CONCENTRA no~
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7.2 Human Health Risks
7.2.1 Exposure Assessment Summary
Table 7.1 summarizes the potential release mechanisms and
potentials for release for the four primary media of concern at
the Site. Table 7-2 summarizes the potential human exposure
pathways which appear possible.
. I
A potential exposure pathway exists through the volatilization
of contaminated surface soil as transported through the air in
the form of vapors or suspended particulates and subsequently
inhaled by humans. While all liquids are volatile to some
extent, the vapor pressure of the indicator chemical (the PCB
group of compounds) is low; therefore, volatilization of
soil-bound PCBs and subsequent vapor inhalation by humans on or
near the site will be negligible as was confirmed by historical
and RI data. A limited potential for exposure does, however,
exist through the generation and subsequent inhalation of
contaminated airborne particulates, especially along the Site
access road. An opportunity for the generation of
PCB-contaminated particulates also exist along the rudimentary
tracked road leading out of the Site in the area of the western
access gates and back to the area where much of the transformer
storage had taken place. The surface soils in this area is
also, in some places, exposed directly to the atmosphere with no
overlying vegetation present for stabilization. However,
previous on-site air quality sampling showed no detectable
levels of PCBs on airborne soil particulates.
Dermal exposure to soil/sediments on-site and surface water
on and off site is presented above as a potential exposure
pathway. The source of contaminated surface waters are
contaminated surface soils and ponds that have become
contaminated resulting from leaching and surface runoff.
both
Ingestion, dermal contact, and inhalation are all human exposure
routes. Routes identified above as potentially complete
exposure pathways are considered in detail in the risk
characterization summary. They are:
1)
Inhalation of airborne soil particulates and direct
contact with contaminated soil; and
2 )
Ingestion of groundwater contaminated by site-related
compounds.
7.2.2 Toxicity Assessment Summary
Based on the occupational studies reviewed, toxicological
findings indicate that exposure to PCBs in high levels has
demonstrated the ability to cause dermatitis and chloracne but
-26-
-------
TABLE: --~
PR~ARY RElEASE SOL"RCE A."'AL'rSIS
Release Potmttal Release Release
,'dedi",m Release So",rce . Mechanum Time Frame Release Probabtl!ty,:t,mount.
Au' Contaminated Fug1hve Dust ChroNc low probabllltv ,ntnor
Surface Sod Volatilization ChroNc neglig1ble
5urface ~Vater Contarrunated Surface Runoff ChroNC negligIble
Surface Sod Groundwater Seepage ChroNc neglig1ble
Groundwater Surface Soils Site Leaching ChroNe high probability / maJOr
~tl Surface So1l Site Leaching ChroNe high probability / maJOr
~ote:
. nunor, maJOr: low, hip etc. refer to rompamoN or
release probabtlities and amounts at this SIte and do not attempt to quantify the release.
-27-
-------
TABl.E 7-2
MATRIX OF POTENTIAL EXPOSURE PATHWAYS
Trllnsporl Humll.. Number of r.,..,
Medium s..... Meduinl.m Expo.ure Pol..' Exposure Roule People Exposed C4I J.t1t414
Air ContamJnalied Volatilization On Site Inhalation 0 No
Surface Soil
Dust On Site Inhalation <10 Yes
Surface Water Contaminated Leaching Ponds Dennal 0 No
Surface Soil II Ponds Surface Runoff
I
tV Groundwater Surface Soil Leaching Private Wells Ingestion <10 Yt.'S
ex>
I
Soil Contaminated Direct Contact On Site Ingestion <10 Yt.'S
Surface Soil Dennal <10 Yes
Inhalation (see on Sit~ air)
-------
other clinical effects, including cancer, have not been
observed.
EPA classifies PCBs as a B2 carcinogen, or "Probable Human
Carcinogen," bas_ed on information from its Integrated Risk
Information System (IRIS). This classification indicates that
there exists evidence of carcinogenicity in animals and
"inadequate but suggestive evidence of cancer in humans by
ingestion and inhalation or dermal contact."
The liver is the primary target organ and site for metabolic
conversion and excretion. However, clinical studies have given
little evidence that hepatic dysfunctions occur in PCB-exposed
workers, even though their blood level of PCB may be high.
Excretion of metabolites is primarily in feces and secondarily
in urine.
7.2.3 Risk Characterization Summary
Potential human exposure to site-related contaminants (PCBs)
were evaluated by two main pathways. Potential points of human
exposure considered were inhalation or direct contact with
surface soils, and ingestion of contaminated ground water.
Exposure by inhalation and direct contact were included in the
residential and parkland scenarios used for soil exposure
assessment. Potential soil exposure was estimated using the
conservative assumptions of site development and exposure
scenarios in the absence of further remedial measures. The
target range for acce~tability of6risks to human health in this
assessment is 1 x 10- to 1 x 10- cumulative lifetime
excess cancer risk level.
Residential development of the on-site secure area was found to
pos~ an estimated additional lifetime cancer risk of 7.1 x
10- to potential future residents. Development of this area
into parklands wo~ld result in a potential additional cancer
risk of 1.1 x 10- for lifetime recreational users of this
area. Obviously, both of these risks are above the target risk
range used in this assessment.
One localized highly contaminated area west of the secured area
was c~lculated to have an additional lifetimeScancer risk of 2.2
x 10- for residential exposure and 3.4 x 10- for
parkland. While this is at the high end of the acceptable risk
range under the parkland scenario, removal of the area of gigh
contamination6would result in an average risk of 4.3 x 10-
and 6.6 x 10- for residential and parkland scenarios,
respectively. The risk characterization information is
summarized on Figure 7.1 and Tables 7-3 through 7-9.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
-29-
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TABLE ~-3
SOIL ANALYSIS
SECTOR 1 . ANALYSIS FOR PCBs
Soil Boring Sam~le PCB Cone.
Sample Depth (ft.) (mglkg)
SB-S3 0 - 1 36
5 B- T3 0 . 1 3:0
SB-R4 0 - 1 6.5
58-54 0-1 200
58- T4 0-1 5.6
SB-RS 0 - 1 0.280
Notes:
6 Samples AnIIp.ed.
.\fean: 93.06 milks.
See Figure 6.4.1 for soil boring locations.
-31-
-------
TABLE i-4
SOn. ANALYSIS
SECTOR 2 - ANALYSIS FOR PCBs
Soil 80""1 SlJmple PCB Cone. Soil 8ori"I Sample PCB Cane.
Sample Depth (ft.) (mglleg) Sample Depth (ft.) (mg/1cg)
SB-CO 0-1 0.72 SB-XX 0 - 1 0.74
sa-vo 0 -1 ND sa-xY 0-1 :0
sa-wo 0-1 ND SB-XZ 0 - 1 0.91
5 a-xo 0-1 ND SB-V3 0-1 128
58-Ul 0-1 8.1 SB-V3 0-1 1.2
58-VI 0-1 0.90 SB- W3 0 - 1 17
5B-Wl 0-1 2.2 SB-X3 0-1 8
5 B-X 1 0 -I 0.18 SB- Y3 0-1 13
SB-U2 0 -I 36BO) SB-Z3 0 - 1 0.5
SB-V2 0 -1 13 SB-V4 0 - 1 660
SB-W2 0 -1 0.32 SB-V4 0-1 4.8
SB-X2 0 -I 0.33 SB-W4 0-1 0.38
Sa-Y2 0 - 1 9.4 SB-X4 0 - 1 2.0
SB:Z2 0 -1 0.290 SB-Y4 0 -I 0.47
Notes:
28 Samples ~
Mean: 29.02 mgI1I8
See Figure 6.4.1 Cor soil boring locations.
If 27 samples are averaged, excluding the 660 mg/kg sample taken at SB-U4. the mean PCB
concentration is 5.66 mg/kg.
( 1 ) B Qualifier: PCBs detected in blank; results not corrected.
-32-
-------
'11\111.1-: 1- ')
SOil ANALYSIS
S~CTOR 3 - ANALYSIS FOR PCOs
SoU Boring SlJmp'~ PCB COliC. SoU Boring S"mp'~ PCB Cone. Soil Boring S"mp'~ PCB COlic..
SlImp'~ DqJth (ft.) (8,/1" SQmp'~ DqJth (ft.) (mgI1g) SlImp'~ Dryth (ft.) (8,/1"
SB-A2 0 - 1 NO SO-T) 0 - 1 0.420 SO-Rb 0 - I NO
SO-02 0 - 1 0.080 SO-N3 0 - 1 ND SO-56 0 I ND
SO-C2 0 - 1 NO SO-D3 0 - 1 ND SB- Tb 0-1 NO
SB-D2 0 - 1 NO SO-PJ 0 - 1 0.062 SO-Ub 0 - I 0.090
SB- E2 0-1 NO SD--Q3 0-1 2.0 S8-Vh 0 - I ND
SO-F2 {} - 1 NO SB- R3 0 - 1 2.0 SO-Wh 0 - I ND
SB-C2 0-1 0.13 SO-04 0 - 1 NO S8-Xb () 1 ND
SB-H2 0-1 NO SB-P4 0 - 1 0.13 S8-„b 0 - I ND
I SB-12 0 - 1 NO S8-Q4 0 - 1 0.064 S8-07 () - I ND
L...J
w 0-1 NO SD-05 0 - 1 0.034 S81? 0 - 1 ND
I SO-J2
50-1<1 0 - I NO SO-P5 0 - I NO SO -Q7 /) - I ND
SO-U 0 - 1 0 ()) 2 SO-55 0 - 1 0.220 SOlO U - I ND
SO-M2 0 - 1 ND SOoTS 0 - 1 0.340 SO-57 () I NO
SD-N2 0 - 1 0.062 SO-U5 0 - 1 O.2bO 58-'17 0 - 1 NO
S8-02 0-1 NO SO-V5 0 - 1 NO SO-U7 () - I NO
SO-P2 0 - I 0.051 SO-W5 0 - I NO SO- V7 0- I ND
SD--Q2 0 - I NO SIJ.- X5 0-1 O.b90 SB- W7 0 - 1 ND
5B-R2 0 - I 0.60 S8-„5 0-1 NO S8-X7 0 - 1 ND
SO-S2 0 - 1 1.6 SO-Ob 0 - 1 ND SO-08 U - I ND
SB- 1'2 0 - 1 1.6 S8-Pb 0 - 1 ND S8-1>8 0 - I ND
S8-S1 0 - 1 0.20 SO-Q6 0 - 1 0.430 SB-Q8 () - I ND
S8-R8 () - I NO
Notes:
M S.In\pll'~ AII..IIYIl'd
Ml'..I1I II!H IIIg/J...g
l,,'t, l'I~~lItl' h 4 I lor ,>olll,urlng 111\.111011'>
-------
"I'ABLE 7-6
SOIL ANALYSIS
MEAN SOIL PCB CONCENTRA llONS
Sector 1
Sector 2
Sector 2a.
Sector 3
~umber of
Samples Analyzed 6 28 27 64
~ean PCB
Concentration
(mg/kg) 93.06 29.02 5.66 0.28
Notes:
Sector 1
Sector 2
Sector 3
Area within secure (fenced) zone.
Area west of Sector 1 as shown in Figure 6.4.1.
All other on site areas (excluding Sector 1 and Sector 2).
. Mean value of all samples analyzed within Sector 2 with the exception of SB-U4
which was 660 mg/kg at 0 - 1 ft. depth. This mean value of 5.66 mg/kg is felt to
accurately reflect the extent of PCB contamination of the remaining soil within
this sector.
-34-
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-::.-\.8,-E --7
SOIL ANALYSIS
ADOmONAL CA.'JCER RISK DCE TO PCB EXPOSCRE
RESIDE.NTIAL SCE'{ ARlO
Sector 1 Sector 2 (1) Sector 2a(2J Sector 3
\fean PCB Cone.
img/kg) 93.06 29.02 ;.66 0.28
Y 0ung ChIld 8.07'( 10-;-
il-6yn) 2.68 x 10-4 8.37 x 10-; 163 '( 10"';
Older Child
1.25 x 104 3.91 x 10-5 763 x 10-0 ~
(6-18yrsJ 3.i:" '( 10-1
Adult
3.15 x 104 981 x 10-5 1.91 x 1(j5 ..
\ 18 yrs +) 9.46 X 10-1
Addi tional Lifetime
Cancer Risk 7.08 x 104 2.21 x 10-4 4.31 x 10-5 2.13 x 10-f!
\iotes:
1)
2)
M:ean of 2B samples used in calculation. as derived in Table 6.4.2.
M:ean of 27 samples used in calculation. as denved in Table 6.4.2.
Residential Scenano
Time Factor:
All age exposed to yard soil for 6 months of each year; 5 days per week wHhm
each 6-month exposure penod.
Child (1 ~):
Child (6-18):
Adult (18 yn +):
Soil -rntake" - meld:
(for days ~r")
Child (1~)
Child (6-18)
Adult (18 yn +)
Body Weight:
15 kg
40 kg
i'O kg
200
100
100
Dermal Inhale
20 0.21
14 0.32
15 0.81
Ingest
Lifetime:
70 years
-35-
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TABLE 7-8
ASSt1MPTIONS USED TO ESTIMA n: EXPOSURE AND
IUSJe: FROM CONT AMINA TED SOlLS IN A RESIDENCE
Y O""g"" a I fl~,.
Au"mptiorr Child Child Adult
1) Age Range (yean) 1to6 6 to 18 18 through ;-0
2) Body Weight (kg) 15 40 iO
3) Days Exposure Per Year (4) 130 130 130
4) Soil Exposure (mg/ day)
I nges tio " (1) 200 100 100
DermJlI (2)(3) 20 14 15
Inhalation (2)() 0.21 0.32 0.81
Total Soil Intake (mg/ day) 220.21 114.32 115.81
5) Absorption Rate (%) (3)
Oral 100 100 100
Skin 1.8 1.8 1.8
Inhale 7S 7S 7S
Notes:
(1)
(2)
(3)
(4)
Source: EPA Memorandum, January 27, 1989: Interim F"tnaJ Guidance for Soillngesdon Rates.
Represents quantity of soil containing the amount of chemical absorbed.
Source: Hawley, J.K. Risk Analysis, Vol. 5, No.4, 1985, Page 295, Medium "Intake", mg/day.
130 days represents exposure to soil for 6 months of the year; 5 days per week for this 6-month
period. From (3).
-36-
-------
~A3:"'~ ~-9
SOIL AN'AL YSIS
ADOmONAL CA.l'KER RISK DVE TO PCB EXPOSL'"RE
P ARK1.A.'ffi SCENARIO
Sector 1 Sector 2(1) Sector 2a(2) Sector 3
\1ean PCB Cone.
(mg/kg) 93.06 2902 566 0.:8
Young ChIld 5.37 x 10'-5 3.26)( 10-6
(1 - 6 yrs) 1.67 )( 10'-5 1.61 '( 10-7'
Older Child
(6 - 18 yrs) 2..51 x 10-5 7.82)( 10-6 1..53)( 10-6 7..55 )( 10-8
Adult
(18 yTs +) 2.94 x 10-5 9.15)( 10-6 1.79 )( 10~ 8.83)( 10-8
Additional Lifetime
Cancer Risk 1.~ x 10-4 3.37 x 10-5 6..57 x 10-6 3.25 )( 10-7
:'-Jotes:
1)
2)
Mean of 28 sample5 used in caJculat:1on. as derived in Table 6.4.2.
Mean of 27 sample5 used in caJculat:1on. as derived In Table 6.4.2.
Park L.md Scenario
Time Factor:
Child~ months of each year; 1 day per week within each 6-month exposure
period.
Adult~ months ot each year; 2 days per month w1thin each 6-month exposure
period.
Body Weight
Child 0-6):
Child (6-18):
Adult (18 yn +):
15 kg
40 kg
70 kg
5011 -Intake- - mg/ d:
(for days exposed)
Child (1~)
Child (6-18)
Adult (18 yn +)
Inge5t
Dermal
Inhale
200
100
100
20
14
15
0.21
0.32
0.81
Lifetime:
70 years
-37-
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7.3 Environmental Risks
The study area of concern for environmental risks includes the
surficial soils located within, and west of, the former
operational area, as well as the soils lining the north drainage
swale running p~rallel to the site access road. Sed~ent
contamination is also of concern in areas within and adjacent to
the former operational area. Guidance for completing this
assessment is provided in Chapter 6 of the document, "Risk
Assessment Guidance for Superfund, volume II, Environmental
Evaluation Manual" EPA/540/1-89/001, March 1989.
As discussed for human exposure in Section 6.2.1 of this ROD,
the same potential exposure pathways may be applied to animal
populations. These pathways include:
.inhalation of airborne soil particulates and direct
contact with contaminated soil;
consumption of lower trophic level species contaminated
by PCBs.
Investigations have shown that PCBs interfere with reproduction
in phytoplankters. Other observed effects in mammals and birds
include microsomal enzyme induction, porphyrogenic action, tumor
promotion, estrogenic activity, and immunosuppression. Other
adverse effects are possible since the PCBs are lipophilic, a
property, along with their stability, that leads to
bioaccumulation and the possibility of long-term effects that
have not been completely identified.
PCBs are lipophilic compounds and, therefore, tend to accumulate
in tissues of living organisms. In birds and mammals, PCBs may
be persistent with half-life ranges of weeks to years. In
addition, mammals and insects readily absorb PCBs directly
through the skin or cuticle. Consequently, PCBs may be
transported to higher trophic levels of a food web.
In the case of carnivorous species such as the cats, raptorial
birds, and snakes, exposure would likely be limited to '
inhalation of airborne soil particulates and direct contact with
contaminated soil or by consumption of another animal species
already exposed to, and contaminated with, PCBs. In the case of
the insectivores, such as many bird species, amphibians, and
insect species, exposure would likely be limited to consumption
of contaminated insects or inhalation of airborne soil
particulates and direct contact with contaminated soil.
Herbivorous species could be exposed to PCBs through consumption
of contaminated vegetation or through inhalation of airborne
soil particles and direct contact with contaminated soil.
-38-
-------
Based on the evaluation of ecological impacts resulting from the
presence of PCBs in the surficial soils and sediments, the
contamination at the Yellow Water Road Site will affect very
limited receptor populations or habitats. The contaminated
soils and sed~ents on site, therefore, pose a small overall
threat to terrestrial biological communities. A detailed
list~ng of al~ species (including, but not limited to,
endangered species) endemic the site can be found in the RI
Report.
8.0 Remedial Action Goals and Objectives
Remedial action goals for CERCLA sites are established under
CERCLA Section 121 (Clean-up Standards), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and
the National Contingency Plan (NCP), as codified in 40 C.F.R.
Part 300. The national goal of the remedy selection process is
to select remedies that are protective of human health and the
environment, maintain protection over time, and minimize
untreated waste.
The remediation goal for PCB contaminated soils at the Yellow
Water Road Site is 10 ppm PCBs. This cleanup goal was set after
consideration of the appropriate CERCLA guidance, the PCB Spill
Cleanup Policy, and the risk assessment performed by the PRPs.
The PCB Spill Cleanup Policy, published in 40 C.F.R. SS 761.120-
761.139, prescribes the level of cleanup required for PCB spills
occurring after May 4, 1987, and is therefore not directly
applicable. However, it is codified policy which represents a
substantial scientific and technical evaluation, and as such, it
has been considered in developing CERCLA guidance cleanup levels
and therefore has been considered in determining the cleanup
levels for this Site.
Under the definition set out in 40 C.F.R. S 761.123, the Yellow
Water Road Site would be considered a non-restricted access area
for application of the PCB Spill Cleanup Policy. Soils in such
a non-restricted access area must be decontaminated to 10 ppm
PCBs by weight, excavated to a minimum depth of 10 inches and
replaced with clean fill containing less than 1ppm of PCBs (40
C.F.R. S 761.125(c)(4)(v)).
Consistent with the PCB Spill Cleanup Policy, the appropriate
CERCLA guidance recognizes a range of .1 ppm to 10 ppm as
generally falling within the protective range for residential
areas. Reference documents include: Guidance on Remedial
Actions for Superfund Sites With PCB Contamination, OSWER
-39-
-------
Directive No. 9355.4-01 (August 15, 1990); Draft Guidelines for
Permit Applications and Demonstration Test Plans for PCB
Disposal by Non-Thermal Alternate Methods, Office of Toxic
Substances (August 21, 1986). The actual cleanup level selected
within this range is dependent upon the risk assessment.
The 10 ppm remediation goal for soil cleanup at this Site is
based upon the following risk assessment assumptions:
The parameters' include:
Child (1 to 6 years)
Time Factor: 5 days/week, 6 months/year, and
5 years/lifetime
Intake Factor:
Conversion Factor:
Slope for PCB:
220.21 mg soil/day/15kg
1x10-6
7.7 (mg/kg/day)-1
Child (6 to 18 years)
Time Factor: 5 days/week, 6 months/year, and
12 years/lifetime
Intake Factor:
Conversion Factor:
Slope for PCB:
114.32 mg soil/day/40kg
1x10-6
7.7 (mg/kg/day)-1
Adult (18 to 70 years)
Time Factor: 5 days/week, 6 months/year, and
52 years/lifetime
Intake Factor:
Conversion Factor:
Slope for PCB:
115.81 mg soil/day/70kg
1x10-6
7.7 (mg/kd/day)-1
Using the aforementioned assumptions, the lifetime risks due to
coniaminated soil goncentrations of 25 ppm and 10 ppm are 1.9 x
10- and 7.6 x 10- respectively. Subpart E of the National
Contingency Plan, as amended in 1990, 55 FR 8866 and 8848 (March
8, 19904' establisheg an acceptable cancer risk range of
1 x 10- to. 1 x 10- (40 CFR S 300.430(e)(2)(i)(A)(2))."
Accordingly, any subsequent remediation for Yellow Water Road
should employ the 10 ppm final concentration goal, thus reducing
the risk due to carcinogen exposure to within the acceptable
range.
The remedial action objectives for the site soils and sediments
are to:
-40-
-------
prevent the near-term and future exposure of human
receptors to contaminated soils and sediments on-site;
control contaminant migration due to surface drainage so
contaminant releases from the site do not exceed levels
of concern to human health and the environment; and
monitor the PCB concentrations in the soils and
sediments to verify the effectiveness of remedial
measures.
9.0 Description of Soil/Sediment Alternatives
The Feasibility Study report presents the results of a detailed
analysis conducted on five potential remedial action
alternatives for the Yellow Water Road Site, with A and B
alternatives presented for cleanup levels of 25 ppm and 10
Since the submission of the Feasibility Study and issuance
the proposed plan, EPA has determined that a cleanup level
ppm does not fall within an acceptable risk range.
Consequently, only the B alternatives are evaluated in this
Record of Decision.
ppm.
of
of 25
This section of the Record of Decision presents a summary of
each of the five alternatives that are described in the FS
report.
Alternative 1 - No Action
Alternative 2 - Excavation/Disposal-Landfill
Alternative 3 - Excavation/Disposal-Incineration
Alternative 4 - Excavation/Solvent Wash/Treatment/Disposal
Alternative 5 - Excavation/Solidification/Stabilization
9.1 Alternative 1 - No Action
The National Contingency Plan requires that the "no action"
alternative be considered at every site. Under the "no action"
alternative, EPA would take no further action at the site to
control the source of contamination. This alternative serves as
a baseline with which other alternatives can be compared. PCBs
are stable in the environment and only slow degradation would be
expected due to natural causes.
Residual PCB concentrations in site soils and sediments range
from below detection limit to 660 mg/kg. The corresponding
additional cancer risk associated wit2 these goncentrations is
above the guideline risk range of 10- to 10- in and
outside of the former operational area.
The No Action alternative would not prevent the potential
migration of PCBs off-site via sediment transport or leaching of
PCBs into the upper sand unit from the remaining limited area
-4l-
-------
of surficial contamination. Additionally, a volume of 3,560
cubic yards of PCB contaminated soil would not comply with the
applicable or relevant and appropriate requirements (ARARs)
pursuant to TSCA, since these soils would remain untreated
on-site. -
There are no costs associated with this alternative since it
requires noact~on to be implemented.
9.2
Alternative 2 - Excavation/Disposal - TSCA-Compliant
Landfill
This alternative would require the excavation, transportation,
and disposal of PCB-contaminated soils.
Specific remedial activities would include:
i)
the excavation of approximately 3,560 cubic yards of
soils having PCB concentrations greater than 10 ppm, to
a minimum depth of ten inches; (Figure 9.1).
ii)
the transportation and disposal of the excavated soils
at a TSCA-compliant landfill;
iii)
backfilling of the excavated areas with clean soil
(less than lppm PCB by weight) to a minimum depth of
ten inches;
iv)
regrading of the site to promote positive drainage; and
v)
planting and maintenance of a vegetative cover over the
site.
There are approximately 3,560 cubic yards of soil and sediment
with PCB concentrations at or above 10 ppm. Sediments with
concentrations greater than 10 ppm occur in the former
operational area and at the origin of the swale north of that
area.
This alternative would result in the removal and disposal of all
soils containing a 10 ppm or greater concentration of total PCBs
and would be considered a permanent remedy. Ground water wells
located in the excavation area will be abandoned in accordance
with EPA and FDER approved procedures. This alternative would
be effective in reducing the future residual risk associated
with exposure to the PCB-contaminated soils.
This alternative is both technically and administratively
feasible. The required equipment, labor and material are
readily available.
This alternative would meet clean-up criteria specified in the
TSCA Spill Policy for a "residential/commercial area".
Alternative 2 would meet the requirements of all action-specific
and location-specific ARARs, as applicable.
-42-
-------
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-------
The estimated timeframe to complete the excavation and material
handling portions of Alternative 2 is four to five weeks.
The estimated capital costs for this alternative range from
$2,490,875 to $3,578,875. No O&M costs are anticipated since
this alternative is considered a permanent remedy. The
estimated total cost ranges from $2,533,085 to $3,632,245.
9.3 Alternative 3 - Excavation/Disposal - Incineration
This alternative would require the excavation, transportation,
and destruction of PCB-contaminated soils at concentrations
exceeding 10 ppm at a TSCA-approved off-site incinerator.
Specific remedial activities would be similar to those discussed
for Alternative 2 with excavated soils being disposed of at a
TSCA-compliant off-site incinerator rather than a landfill.
Ground water wells located in the excavation area will be
abandoned in accordance with EPA and FDER procedures.
Approximately, 3,560 cubic yards of soil and sediment with PCB
concentrations at or above 10 ppm would be excavated and
disposed of with this alternative. The risks associated with
this alternative would be similar to that discussed for
Alternative 2.
The estimated time frame for implementation of this alternative
(excavation to destruction of contaminants) would be four to
five weeks. This alternative would be both technically and
administratively feasible. The requisite equipment, labor, and
materials are available. A TSCA approved incinerator is
required. Scheduling and coordination problems related to the
ready availability of PCB solid waste incineration capacity,
should be anticipated.
This alternative would meet the clean-up criteria established
for a "residential/commercial area" as defined by TSCA. This
alternative also incorporates treatment as a remedial
component. Alternative 3 meets all the requirements of all
action-specific and location-specific ARARs, as applicable.
The anticipated capital costs for this alternative would be
between $9,070,880 and $11,454,625. No O&M costs would be
incurred as this remedy is considered permanent. The estimated
total cost ranges from $9,164,390 to 11,564,635.
9.4 Alternative 4 - Excavation/Solvent
wash/Extraction/Disposal
This alternative would require the excavation and on-site
treatment of soils containing PCBs at concentrations above 10
-44-
-------
ppm. If deemed necessary by EPA and FDER, ground water wells
located in the excavation area will be abandoned in accordance
with EPA and FDER approved procedures. Treated soils would be
placed back into excavated areas. Specific remedial activities
would include:
ii)
iii)
iv)
v)
vi)
i)
treatability studies to verify the technology
with site soils;
the excavation of soils with PCB concentrations
greater than 10 ppm;
at or
the on-site treatment of the contaminated soils
a solvent washing/extraction process, the Basic
Extractive Sludge Treatment (BEST), to achieve a
residual PCB concentration in treated soils no
greater than 10 ppm;
using
disposal of PCB-contaminated solvent at an off-site
TSCA-compliant incinerator;
the placement of the treated soils back into the
excavated sections; and
provision of a vegetative cover over the entire Site.
There are approximately 3,560 cubic yards of soil and sediment
with PCB concentrations at or greater than 10 ppm. The only
sediments with PCB concentrations greater than 10 ppm occur
within the former operational area and at the origin of the
swale north of the former operational area.
The BEST process to be used produces the following three
effluent/waste streams:
1) treated soil (with residual triethylamine (TEA)
concentrations of approximately 200 ppm)
2) water stream (same TEA residual concentrations as for
soil) which will be treated on-site by activated carbon to
remove low level PCB residuals prior to discharge to the
northerly surface swale or, depending on volume, disposed of
at an off-site facility; and,
3) a PCB-containing oily waste stream which must be disposed
of in accordance with TSCA.
-45-
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TEA is reportedly 100 percent biodegradable in 11 hours at
concentrations of 200 ppm in water. TEA is not listed as a
compound of concern at these concentrations.
The anticipated time frame to complet1 this alternative would
be 28 to 30 wee~s, based on a 37.5 yd /day (12-hour day), 80
percent efficiency treatment rate plus site
mobilization/demobilization.
This alternative would result in the removal and treatment of
all soils which had PCB concentrations at, or greater than, 10
ppm. Soils would be treated to a PCB concentration below 10
ppm. This alternative would be effective in reducing the
future residual risk associated with exposure to the
PCB-contaminated soils. This alternative would be considered a
permanent remedy.
This alternative would be both technically and administratively
feasible. However, provision of necessary equipment and
technology is through a limited number of vendors, which may
cause scheduling and availability difficulties. This
technology also has a limited experience history.
This alternative complies with the clean-up criteria
established for a "residential/commercial area" as defined by
the PCB Spill Clean-up Policy. A bench and pilot scale
treatability study would be required by the single source
vendor to confirm that the technology is compatible with site
soils and is able to achieve the 10 ppm treatment criterion.
This alternative also utilizes an "innovative technology" and
incorporates treatment as a remedial component. This
alternative would meet the requirements of all action-specific
and location-specific ARARS, as applicable.
The estimated capital cost is $2,612,900. O&M costs of $44,210
are required to maintain the vegetative cover installed over
the site. The total cost is $2,748,000.
9.5 Alternative 5 - Excavation/Stabilization/Solidification
This alternative utilizes a solidification/stabilization
procedure which would stabilize the PCBs. Specific remedial
activities would include:
i)
a treatability study to verify the effectiveness of the
technology in solidifying/stabilizing PCBs contained in
site soils:
-46-
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ii)
iii)
iv)
vi)
vii)
viii)
ix)
the excavation of soils having PCB concentrations in
excess of lO ppm with subsequent treatment occurring in
a batch mixer;
pre-leaGhing analysis - Toxicity Characteristic
~eaching Procedure (TCLP);
treatment consisting of batch mixing contaminated soils
with water and site-specific designed and tested
admixtures to form a homogeneous matrix;
v)
placement and curing of the treated soils back within
the operational area;
backfilling excavated areas with clean soils (less than
1 ppm PCB concentration);
placement of a vegetated one-foot thick soil cover over
the treated soil mass (monolith) and securement of the
monolith a security fence;
provision of vegetative cover over the remainder of the
site and;
long-term management controls including operation and
maintenance of the monolith, vegetative cover and
fence.
There is an estimated 3,560 cubic yards of soil and sediment
with PCB concentrations at or above 10 ppm. Because this
material would not require off-site transportation or disposal,
all activities related to this alternative would pose minimal
threat to the community.
This alternative would result in the solidification and
stabilization of soils which had PCB concentrations greater
than 10 ppm. If deemed necessary by EPA and FDER, ground water
wells located in the evacation area will be abandoned in
accordance with EPA and FDER approved procedures. This
alternative would be effective in reducing the future residual
risk associated with exposure to the PCB-contaminated soils.
The anticipated timeframe to comP1ete this alternative would be
10 to 12 weeks, based on a 100 yd /day treatment rate plus
site mobilization/demobilization.
This alternative would be both technically and administratively
feasible. The requisite equipment, labor, and materials are
readily available.
-47-
-------
~his alternative would accomplish the clean-up criteria"
established for a "residential/commercial area" as defined by
TSCA. A TCLP test and/or other leaching test would be
performed to verify that the stabilized soil is effective in
fixing PCBs within the solidified monolith. In the event that
the results of ~he leachability test or other treatability
tests do not verify the technology's effectiveness, all soils
with PCB concentrations greater than or equal to 50 ppm will be
disposed in a manner consistent with the requirements of TSCA.
Alternative 5 would meet the requirements of all action-
specific and location-specific ARARs.
Operation and Maintenance activities would involve a
semi-annual inspection and maintenance of the monolith
cover and appropriate confirmatory sampling during the
year and" annual inspections and maintenance thereafter
years.
The estimated capital cost of this alternative ranges from
$976,480 to $1,293,980. Operation and Maintenance cost
associated with this task is estimated at $62,600. The total
estimated cost would be $1,119,000 to 1,448,200.
and soil
first
for 30
10.0
Comparative Analysis of Soil/Sediment Alternatives
Nine evaluation criteria are used in comparing the
alternatives. Each of the following subsections is entitled
according to these criteria and the alternatives are discussed
therein. A glossary of the evaluation criteria is provided on
Page 61 of this ROD.
10.1
Overall Protection of Human Health and the Environment
The no action alternative provided no additional protection to .
either human health or the environment. This alternative does
not reduce the on-site PCB concentrations through any remedial
action. The PCB concentrations within the soils and sediments
would remain above acceptable levels for an indefinite period
of time. In addition, this alternative would allow for surface
migration of PCBs. This alternative, therefore, was judged to
be the least protective.
Alternatives 2, 3, 4, and 5 were equally considered the most
protective since they would all achieve unrestricted access
-48-
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areas for the site. Each alternative removed or remediated PCB
soil concentrations to 10 ppm or below. However, alternatives
2, 3 and 4 require the off-site transport and
disposal/treatment of hazardous waste. Alternative 5, while
considered prot~ctive, would require long-term monitoring to
ensure that degradation of the solidified monolith did not
occur.
10.2 Compliance With Applicable or Relevant and Appropriate
Requirements
The primary ARARs for source control alternatives addressing
PCB contamination derive from the Toxic Substances Control Act
(TSCA) . ~he ~SCA PCB regulations of importance to Superfund
actions are found in 40 C.F.R. ~~ 761.60 - 761.79, Subpart D:
Storage and Disposal. TSCA requirements do not apply to the
disposal of PCBs at concentrations less than 50 ppm; however,
PCBs cannot be diluted to escape TSCA requirements.
Under this standard, the requirements of 40 C.F.R. Subpart D
are legally applicable to the Yellow Water Road Site. Three
areas have been identified with PCB concentrations above 50
ppm; the remaining seven areas to be remediated are below 50
ppm. According to the regulations promulgated under TSCA,
soils contaminated with PCBs at concentrations greater than or
equal to 50 ppm may be disposed of in an incinerator, treated
by an equivalent method, or disposed of in a chemical waste
landfill. 40 C.F.R. ~ 761.60(a)(4) and (e).
Alternatives 2 and 3 meet the requirements of TSCA, since they
involve, respectively, incineration and landfilling at TSCA
compliant off-site disposal facilities.
Aside from incinerat~ ~ or disposal in a chemical waste
landfill, there are additional methods available for disposal
of PCBs which were evaluated for use at the Yellow Water Road
site. Alternatives 4 and 5 involve the use of technologies
which can achieve substantial reductions in PCB toxicity,
mobility or volume but which are not equivalent in performance
to incineration.
The use of such alternative technologies is addressed in EPA's
Guidance on Remedial Actions for Superfund Sites With PCB
Contamination, OSWER Directive Number 9355.4-01 (August 15,
1990), and Draft Guidelines for Permit Applications and
Demonstration Test Plans for PCB Disposal by Non-Thermal
Alternate ~ethods, Office of Toxic Substances (August 21,
-49-
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1986). Under these guidances, when a remedial action
alternative for a Superfund site involves the use of a
technology that can achieve substantial reductions, but
residual concentrations in a waste to which TSCA applies will
still exceed 2 ppm, the substantive requirements for a chemical
waste landfill 5hould be met for on-site waste disposal. This
will not be considered equivalent to incineration but will be
treated as closure of an existing landfill, consistent with
TSCA chemical wa?te landfill requirements.
Not all of the requirements applicable to a TSCA chemical waste
landfill are met by either Alternative 4 or Alternative 5.
However, under the waiver provisions of 40 C.F.R. S 761.75(c),
certain of the long term management controls otherwise
applicable to a TSCA chemical waste landfill may be waived, as
long as operation of the landfill without the controls will not
present an unreasonable risk of injury to health or the
environment. For Alternatives 4 and 5, such a TSCA waiver may
be justified based on the concentration of PCBs remaining
on-site and other site-specific factors, including compensating
components of the long term management controls to be
implemented.
With respect to the concentration of PCBs remaining on-site,
the remediation plan for the Yellow Water Road Site provides
for PCBs to be remediated to 10 ppm or less. This is
consistent both with the EPA Draft Guidelines noted above and
with the PCB Spill Policy set out in 40 C.F.R. Subpart F, SS
761.120 - 761.135, which is discussed below.
The following requirements of 40 C.F.R. S 761.75, otherwise
applicable to TSCA chemical waste landfills, are not met by
Alternatives 4 and 5:
Soil requirements, under 40 C.F.R. S 761.75(b)(1)
Synthetic liner requirements, under 40 CFR S 761.75(b)(2)
Hydrologic conditions, under 40 CFR S 761.75(b)(3)
Leachate collection system, under 40 C.F.R. S 761.75(b)(7)
The following controls, which provide the justification for a
waiver, will be implemented in Alternative 5:
Solidification/stabilization of soils with PCB
concentrations of 10 ppm or greater;
-50-
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Performance of treatability studies to verify the
effectiveness of the technology in solidifying/stabilizing
PCBs contained in site soils;
Performance of leachability testing on the solidified mass,
using the Toxicity Characteristic Leaching Procedure (TCLP),
to determine if c:ean up levels that are protective of
grour.dwater would be achieved;
Placement of the stabilized/solidified material in an
enclosed, :enced area with a designed vegetative cover
installed atop the monolith;
Implementation of long term controls, which will include
inspection and maintenance of the solidified monolith,
vegetative cover, and fence and appropriate surface water
and groundwater sampling, as determined in the Remedial
Design and presented in the Operation and Maintenance Plan
for the Site.
Based on these site-specific controls and the concentrations of
PCBs remaining in the soils, the requirements of 40 C.F.R.
S 761.75(b) related to soils, synthetic liners, hydrologic
conditions, and leachate collection systems will be waived for
Alternative 5. Alternative 5 will meet the TSCA ARARs, as
modified by this waiver.
Likewise, Alternative 4 would not comply with the TSCA ARARs,
as presented above. Therefore, if selected, it would also
require a TSCA waiver.
The "No Action" Alternative does not meet the TSCA ARARs, since
it leaves in place the existing PCB contamination in excess of
50 ppm, without providing for further disposal or treatment by
any method.
Although not an ARAR, the PCB Spill Cleanup Policy set out in
40 CFR Subpart F, SS 761.120 - 761.135, is an important factor
To Be Considered (TBC). In this ROD, the PCB Spill Policy was
used as guidance in the development of cleanup goals and the
evaluation of alternatives involving little or no long-term
management control. Each of the alternatives other than the
"No Action" Alternative (Alternative 1) meets the cleanup goals
set with reference to the PCB Spill Policy.
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10.3 Long-term Effectiveness and Permanence
The no action alternative was the least effective in achieving
the long-term effectiveness and permanence criterion. No
action leaves the potential risk associated with the site soils
in an unaltered -state.
Alternatives 3 and 4 are considered the most effective from the
perspective of this evaluation criterion since the greatest
volume of PCB-contaminated soil would be permanently removed or
treated. However, Alternative 4 is deemed somewhat less
reliable since it is an innovative technology.
Alternative 5 is considered the next most effective in the
long-term perspective. This alternative would require the
solidification and stabilization of soils which had PCB
concentrations greater than 10 ppm and consequently, would
reduce PCB surficial soil concentrations at the site to less
than 10 ppm. However, this alternative would result in an
on-site stabilized soil monolith which would require long term
monitoring and maintenance to demonstrate its continuing
reliability.
10.4 Reduction of Toxicity, MObility, or Volume
The no action alternative is the least effective in this
evaluation criterion. The no action alternative would result
in no reduction of toxicity, mobility or volume of the PCBs at
the site.
Alternatives 3, 4 and 5 were considered the most effective in
this evaluation criteria since all contaminated soils above the
concentration level of 10 ppm would realize a reduction in
either volume, mobility or toxicity.
Alternative 5 would successfully reduce the mobility of PCBs by
solidifying the soils into a solid homogeneous matrix. The
toxicity of the PCBs may be reduced by chemical reaction with
pozzolanic material. The draft USEPA document entitled "Draft
Guidance on Selecting Remedies for Superfund Sites with PCB
Contamination", September, 1989, indicates that the chemical
reaction of some types of pozzolanic material with PCBs tends
to dechlorinate the PCBs, rendering them non-toxic. Provision
of a vegetated cover over the Site would reduce the mobility of
residual PCBs with concentration of less than 10 ppm in
untreated soils; however, this alternative would not result in
a net reduction in waste volume.
-52-
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Alternative 2 would be considered the next most effective since
the materials would only be removed to another "site." This
alternative wou~d not result in a reduction of volume, mobility
or toxicity.
10.5 Short-term Effectiveness
The No Act~on alternative rates most favorably for this
criterion in respect to adverse impacts on human health and the
environment that may result during the construction and
implementation period since no construction activities would
occur. However, it is least effective in reference to the time
in which the remedy would achieve protection.
Alternatives 4 and 5 are the most effective alternatives.
Soils would be treated on-site, which alleviates the
possibility of off-site accidents or contaminant release.
The construction activities for Alternative 5 would pose a
minimal risk to the surrounding community. The implementation
of a detailed remedial health and safety plan would minimize
contaminant migration off-site due to the movement of
construction equipment and trucks.
In each alternative, the protection of site personnel would be
afforded by the use of appropriate safety equipment to be worn
at all times while working in contaminated areas. A properly
implemented health and safety program would also provide for
additional protection of personnel.
Adverse impact to the environment would be negligible for each
alternative. Environmental impact, if any, would arise from
dust particulate emissions at the site and any accidental
releases during transportation of the soils to the
TSCA-compliant landfill. A properly implemented health and
safety program would address air monitoring requirements on
site and an off-site Emergency Contingency plan would address
any off-site release procedures.
Alternatives 2 and 3 were the least effective alternatives
since they involved the greatest volume of soils requiring
excavation and disposal off site, creating the greatest
potential for off-site incidents and potential contaminant
release.
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10.6 Lmplementability
The no action alternative is easily implemented since no action
is required. This alternative was therefore ranked most
implementable.
Alternative 2 is considered the most effective alternative
under this criterion. Excavation and off-site disposal at a
permitted landfill is a technology which has been used for a
large number of hazardous waste remedial projects, is well
known, and is simple to implement.
Alternative 3 was ranked next most effective. While the
on-site activities required under this alternative are
identical to Alternative 2, problems are often encountered
trying to procure, schedule, and coordinate off-site solid
waste incineration facilities. Delays of several months on
incineration projects are not uncommon.
Alternative 5 was considered the next most easily implemented.
Although the technology is relatively well known, additional
care and expertise must be used when mixing and processing the
soils and solidification admixtures to achieve desired results.
Alternative 4 was considered the most difficult to implement
since these alternatives involve a complex treatment process
which has not been used to date on a significant number of
similar applications. The fact that the technology is
proprietary may also cause problems and delays in availability,
scheduling, and maintenance.
10.7 Cost
The following alternatives were assessed on a total cost basis
using the estimated capital cost to perform the remedial work
and the present worth cost for operation and maintenance costs,
using a five percent discounted rate over a 30-year period.
Alternative 1
Alternative 2
Alternative 3
Alternative 4
Alternative 5
$0
$2,533,084 -
$9,164,390 -
$2,748,000
$1,119,000 -
3,632,245
11,564,635
1,448,200
Alternative 3 (incineration) is the most expensive remediation
alternative at a range of $9.1 million to 11.5 million. The
cost for Alternatives 2, 4, and 5 are substantially less than
-54-
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-~- -- ~-~- "_. ~ -"--
the cost for Alternative 3 and offer a compatible degree of
protection. Alternative 1 is the least costly and provides the
least amount of protection.
10.8
State Acceptance
The State of Florida has concurred on the selection of this
remedy.
10.9
Community Acceptance
Based on comments made by citizens at the public meeting held
on September 4, 1990, and those received during the public
comment period, the Agency perceives that the community
believes t~e overall selected remedy of
solidification/stabilization of soils/sedLrnents to 10ppm will
effectively protect human health and the environment.
11.0 Selected Remedy
Based upon consideration of the requirements of CERCLA, the
detailed analysis of the remedial alternatives, and public
comments, EPA has determined that Alternative 5 is the most
appropriate remedy for the Yellow Water Road Site in Baldwin,
Duval County, Florida. EPA's selected remedy is protective of
human health and the environment at the Yellow Water Road site.
During the Remedial Design, a treatability study will be
conducted in order to optLrnize admixtures for the treatment
process. Leachability studies of the stabilized mix will also
be conducted.
Upon completion of the Remedial Design, approxLrnately 3,560
cubic yards of PCB contaminated soils/sedLrnents exceeding 10
ppm will be excavated and batch treated by solidification and
stabilization methods to the established clean-up levels of PCB
in a TCLP leachate test. At selected intervals during
excavation, soil samples will be collected and analyzed to
determine the limits of excavation. Excavation of all soils,
including sediments and soils in the vadose zone, will continue
until the clean-up goal of 10 ppm of PCBs in soils/sediment is
achieved.
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The stabilized and solidified soil/sediment will be placed back
into the former operational area, covered with a vegetated
one-foot thick soil cover and secured by fence. The excavated
areas will be backfilled with clean fill (soils containing less
than 1 ppm of PCBs). The remainder of the site will be
vegetated.
This recommended alternative meets the requirements of the
National Oil. and. Hazardous Substances Contingency Plan (NCP),
40 CFR 300.68 (j), and the Superfund Amendments and
Reauthorization Act of 1986 (SARA). This alternative.
permanently and significantly reduces the mobility of hazardous
contaminants in the soil and sediments, in and outside of the
former operational area. Solidification/stabilization is a
widely used treatment that permanently immobilizes contaminants
in a cement-like'matrix. Such treatment of PCB contaminated
soils/sediments will effectively prevent their posing a threat
through direct contact or by leaching to the groundwater.
The duration of the soil treatment is estimated at six months.
The total present worth cost of this alternative is
approximately $1.5 million.
11.1
Operation and Maintenance
Operation and Maintenance activities will include semi-annual
inspections of the monolith, soil cover and appropriate
confirmatory sampling during the first year and annual
inspections thereafter for the next 30 years. Long-term
operation and maintenance requirements are expected for the
recommended alternative for this operable unit. Monitoring
will determine the effectiveness of the alternative at reducing
migration of PCBs in the groundwater. An Operation and
Maintenance Plan will be developed during the Remedial
Design/Remedial Action tasks.
12.0
Statutory Determinations
The U.S. EPA and FDER believe that this remedy will satisfy the
statutory requirements of providing protection of human health
and the environment, attaining applicable or relevant and
appropriate requirements or other environmental statutes, will
be cost effective, and will utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Finally
-56-
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implementation of the remedy will comply with CERCLA Section
121 (b) (1) preference for treatment.
12.1
Protection of Human Health and the Environment
The selected remedy of solidification/stabilization of the
soils is protective of human health and the environment by
eliminating the Bource of contamination and direct threat
through dermal contact with surface soils. The source of
contamination will be excavated, solidified and returned to the
respective excavated areas.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
Section 121 (d) (2) (A) of CERCLA incorporates into the law the
CERCLA Compliance Policy, which specifies that Superfund
remedial actions must meet any Federal standards, requirements,
criteria, or limitations that are determined to be legally
applicable or relevant and appropriate requirements (ARARs).
Also included is the provision that State ARARs must be met if
they are more stringent than Federal requirements. The
recommended alternative was found to meet or exceed the
following ARARs, as discussed below.
12.2
12.2.1
Occupational Safety and Health Administration
OSHA)
A health and safety plan will be developed during the remedial
design which will be followed during field activities to assure
that regulations of OSHA are followed.
12.2.2
Clean Water Act/Safe Drinking Water Act
Additional groundwater studies will be conducted during as part
of Operable Unit Two. A feasibility study to determine the
appropriate clean-up alternative will include measures to
ensure compliance with the Safe Drinking Water Act, and the
proposed MCL of 0.5 ug/l for PCB in groundwater.
12.2.3
National Pollutant Discharge Elimination System
(NPDES)
The chosen alternative does not include any discharges,
therefore this requirement does not apply.
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12.2.4
Resource Conservation and Recovery Act (RCRA)
The requirements of the Resource Conservation and Recovery Act
(RCRA) are applicable to RCRA characteristic or listed
hazardous waste~ (40 C.F.R. Part 261) which were disposed at a
site' after November 19, 1980. RCRA requirements include
minimum technology standards, monitoring requirements, and
storage and disposal prohibitions. RCRA also establishes
prohibitions-on land disposal of various hazardous wastes.
However, these regulations only apply to waste that is
considered hazardous under RCRA, i.e., listed in 40 C.F.R.
~26l.3 or characteristic as, described in 40 C.F.R. ~261.2.
PCBs alone are not a listed or characteristic RCRA hazardous
waste; however, if the PCBs are mixed with a RCRA hazardous
waste they may be subject to land disposal restrictions.
The PCBs associated with this site are not mixed with any RCRA
hazardous waste and therefore are not subject to RCRA
regulation or the Land Disposal Restrictions.
12.2.5
Toxic Substances Control Act (TSCA)
The TSCA PCB regulations applicable to this Site are found in
40 CFR Subpart D, ~~ 761.60 - 761.79. These regulations
specify treatment and disposal requirements for PCBs based on
their forms and concentrations.
For the purposes of determining compliance with TSCA, the
selected alternative is treated as closure of a landfill,
consistent with TSCA chemical waste landfill requirements. The
selected alternative satisfies the requirements of the
applicable TSCA regulations, found in 40 C.F.R. ~~ 761.60 and
761.75, as modified by the following findings and waiver of
requirements by the Regional Administrator.
Pursuant to 40 C.F.R. 761.75(c)(4), the Regional Administrator
hereby finds that the selected alternative will not present an
unreasonable risk of injury to health or the environment from
PCBs if it is implemented without meeting the requirements of
40 C.F.R. ~ 761.75(b)(1), (2), (3), and (7), and that the
requirements of 40 C.F.R. ~ 761.75(b)(1), (2), (3), and (7) are
not necessary to protect against such a risk.
The selected alternative meets the TSCA ARARS, as modified by
the Regional Administrator's findings and waiver~
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12.2.6
PCB Spill Cleanup Policy
The PCB Spill Cleanup Policy under TSCA is not an ARAR for
Superfund response actions; however, as a codified policy
representing substantial scientific and technical evaluation it
has been considered in developing the guidance cleanup levels
considered for this site. For non-restricted access areas, as
defined in 40 C.~.R. ~761.123, this policy requires that soils
be remediated ta 10 ppm PCBs, provided that the minimum depth
of excavation is 10 inches (40 C.F.R. ~761.125).
12.3
Cost Effectiveness
This alternative affords a higher degree of overall
effectiveness in not ~~ly protecting the public against direct
exposure but in remov~g the threat of a future release of
contaminants. The es~imated ca;ital cost of this alternative
is $1.12 - $1.45 million (including operation and
maintenance) .
The selected remedy affords overall effectiveness proportional
to its cost such that the remedy represents a reasonable value
for the money. When the relationship between cost and overall
effectiveness of the selected remedy is viewed in light of the
relationship between cost and overall effectiveness afforded by
the other alternatives, the selected remedy appears to be
cost-effective.
12.4
Utilization of Permanent Solutions and Alternative
Treatment Technology or Resource Recovery Technologies
to the Maximum Extent Practicable
The U.S. EPA believes this remedy is the most appropriate
cleanup solution for initiating an appropriate operable unit at
the Yellow Water Road site and provides the best balance among
the evaluation criteria for remedial alternatives evaluated.
This remedy provides effective protection in both the short-
and long-term to potential human and environmental receptors,
is readily Dmplemented, is cost effective, and is consistent
with future response actions that will be undertaken at the
site.
Solidification/stabilization of the contaminated PCB soils
represents a permanent solution (through treatment) which will
effectively reduce and/or eliminate mobility of hazardous
wastes into the environment.
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12.5
Preference for Treatment as a Principal Element
Soils contaminated with PCBs are the principal threat at the
site. This alternative (Solidification/Stabilization) would
successfully reduce the mobility of PCBs by solidifying
contaminated soris into a solid homogeneous matrix. Provision
of a vegetative cover over the site would further reduce the
mobility of residual PCBs in untreated soils.
The toxicity and volume of the PCBs may be reduced by chemical
reaction with pozzuolanic material. As previously discussed,
past research indicates that the chemical reaction of some
types of pozzolanic material with PCBs tends to dechlorinate
the PCBs, rendering them non-toxic.
Solidification/Stabilization is a treatment process which has
been demonstrated as effectively in reducing the mobility of
PCBs in the environment. Therefore, the statutory preference
for remedies that employ treatment as a principal element is
satisfied.
12.6
Documentation of Change
Based upon the requirements of CERCLA section 117(b), EPA has
determined that a change has been made in the "Summary Of The
Remedial Alternatives For Soils/Sediments" presented in the
Proposed Plan. In the Proposed Plan, EPA presented to the
public five alternatives for both clean up levels of 25 ppm and
10 ppm. However, since the issuance of the Proposed Plan, EPA
has made a determination that 25 ppm is not within an
acceptable risk range. Therefore alternatives which involved a
clean up level of 25 ppm were not evaluated in this Record of
Decision. In addition operation and maintenance costs for
alternative 5 were not included in the Proposed Plan. These
costs have been included in the Record of Decision.
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GLOSSARY OF &VALUATION CRITERIA
Overall Protection of Human Health and Environment - addresses
whether or not a remedy provides adequate protection and
describes how risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engineering controls
or institutional. controls.
Compliance with
meet all of the
requirements of
and/or provides
ARARs - addresses whether or not a remedy will
applicable or relevant and appropriate
other Federal and State environmental statutes
grounds for invoking a waiver.
Lona-Term Effectiveness and Permanence - refers to the
magnitude of residual risk and the ability of a remedy to
maintain reliable protection of human health and the environment
over time once cleanup goals have been met.
Reduction of Toxicity. Mobility. or Volume Throuah Treatment -
addresses the anticipated performance of the treatment
technologies that may be employed in a remedy.
Short-Term Effectiveness - refers to the speed with which the
remedy achieves protection, as well as the remedy's potential to
create adverse impacts on human health and the environment that
may result during the construction and implementation period.
Implementability - is the technical and administrative
feasibility of a remedy, including the availability of materials
and services needed to implement the chosen solution.
Cost - includes capital and operation and maintenance costs.
State Acceptance - indicates whether the State concurs with,
opposes, or has no comment on the Proposed Plan.
Community Acceptance - the Responsiveness Summary in the
appendix of the Record of Decision reviews the public comments
received from the Proposed Plan public meeting.
-61-
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APPENDIX A
RI Soil Sampling Data
-------
NOTES AND DEFINITIONS
. - Est. result less than 5 times detection limit
A - Analytical and/ or post-digestion spike
B . - Detected in blank, result not corrected
C . Confirmed on second column
D . Sample diluted for this analyte
E - Estimated result - see report narrative
G . Exceeds calibration range
J - Detected at less than detection wnit
N A - Not analyzed
- NC - Not calculated
ND - Not detected at specified detection limit
N R . Analyte not requested
N S Not spiked
N / A - Not available
P . Previously confirmed
Q - Outside control limits
R - Detected in blank, result corrected
S . IJetermined by Method of Standard Addition
U - Unconfirmed. 2nd column not requested
X Not confirmed by analysis on 2nd column
w
QUAUFIERS INTRODUCED BY CRA
K
. ~ Positive results are estimated (biased low) due to 't iolation of
;...
:" presaibed holding time criteria
. Negative results are estimated (biased low) due to violation of
prescribed holding time criteria
. Positive results are estimated due to outlying surrogate spike
recoveries
. Negative results are estimated due to outlying surrogate spike
recoveries
- The associated PQL is estimated due to low MS/MSD recoveries
. indicating a low bias in results
. .
y
M
z
-------
SOIL SAMPLE SUMMARY «UNITS = m~&~
PIIASE I RIJFS
YELLOW WATER ROAU SITE
SAMPLE 10:
U>CATION:
COMMENTS:
UA TE COLLECTED:
SO-GN-02a
~ 0-1 fool
1- .
SO-GN-02b
02 1-2 feel
SO-JA-C2a
C2 0-1 fool
SO-JA-C2b
C2 1-2 feel
12/14/88
12/ 14/88
12/15/88
12/15/88.
VOCS , I
Melhylene Chloride .oo3J 01 .0046 80
Acelone .00) BI .031 80
BINs
Di. n-bulylphlhalale .280 8 .380 80 .700 80
HIS( 2 -elhylhex yl )phlhalale .320 80 .110 I
Pyrene .0911
IJenzo(a)anlhracene .094 J
Chrysene .140 I
Den zo(b )fluor anlhene 3101
Denzo(k)fluoranlhrne .150 J
Denzo(a)pyrene .140 J
reos NO NO
Arndor-1260 .(8)C
-------
5011. SAMI'LE SUMMARY tUNITS = m~g)
PIIASE I RIIFS
- .
YELLOW WATER ROAn SITE
SAMPLE In:
U>CATlON:
n )MMENTS:
VA TE COLLECTED:
SB.GN-G2a
.; Q ().1 '001
SD-CN-G2b
G2 1-2 'eel
SB-CN-U2a
112 0-1 '001
S8-GN-12a
12 0- I 'oot
12/14/88
12/14/88
12/14/88
12/12/88
VOCS
Melhylent> Chloridt> .ooJ7BJ .0021 BJ .0015 BJ
Acelone 58 4-88 .0718
2-but"none .0061 J
DINs
Ui-n-butylphlhalale .370- .340- .600-8
Ois( 2 -ethylhex yl)phlhalale .300 -0 .190 81 .290-
:a
I'CUs NO NO NO
Ar()("lor-1260 .1JOC
-------
SOIL SAMI'LE SUMMARY «UNITS = mglkgt
PIIASE I RI/FS
YELLOW WATER ROAO SITE
SAMI'LE 11>:
toe A TION:
(( )MMENTS:
UA TE COLLECTED:
58-GN-Ua
U 0-1 fool
12/14/88
58 GN-1.21
11 0- 1 1001
Dup. of S8-GN-l2a
12/14/88
S8-GN-l.2b
L2 1-2 If't'l
12/16/88
S8-GN-Um
l2 1 -2 ff't'l
Oup- of S8-GN-l2b
12/14/88
vocs
Ml'lhylene Chloride .OOJ3 81 .0048 .8
An'lone 28 1.18
BINs
I>. nhulylphlhalale 138 .150 8
11.')(2 elhylhellyUphlhalale .14081
I'CU, NO ND
Awdur-l260 .OJ2C -029C
- .
-------
SOli. SAMPLE SUMMARY (UNITS = n'glkgJ
PIIASE I RIIFS
YELLOW WATER ROAI> SITE
SAMPLE 10:
IJ)CATION:
('( )MMENTS:
UA TE COLLECTED:
SO-JA-NJa
. 'i: .:- CH '001
12/15/88
S8-'A-NJI
NJ 0-1 1001
Dup- 01 SO-'A-NJa
12/15/88
VOCS
Melhylene Chloride .0034 8' .cnJ5 0'
AO!lone 2.5 B 2.60
BINs
Oi-n-bulylphlhalale .340 -0 .33O-B
nis(2 -elhylhexyl)phlhalale .QJ9 BJ
PCBs
NO
NO
J.
-------
SOl L SAMPLE SUMMAR V .UNITS = mglkg8
rllASE I Rill'S
YELLOW WATER ROAn SIT':
Si\MI)LE 10: SO'JA-03a' SBJA03a SB-IA-03a SO-IA-03b
U)CATION: ()] ().I Inul 03 0-1 1001 OJ 0-1 loul 03 1.2 lee I
('( )MMtNTS: M.;alrix Spike Malrix Spike Duplicale
I>A TE COLLECTEO: 12/15/88 12/15/88 12/15/88 12/15/88
vocs
Ml'Ihylene Chloride .0043 -0
A('elone .820 0
I.I-dlchloroelhene 100"" IIO~
Trichloroelhene 84 "" 84~
Uenzene 93"" 94~
Tnhwne 92~ 95~
Chlorobenzene 88~ 91~
DINs
Di - nbulylphlh.;al.;ale .340 -0
1.4 -dichlnrobenlene 72"" 74~
N - nilrosodi - n - pmpyl.;amine 73"" 75~
1.2.4 -Irichlorobenzene 78~ 85~
A(:enaphlhene 76~ 80~
2.4 dinilrololuene 77~ 87~
Pyrene 97,," 1CJ7~
rCDs NO NO
Arodor-1254 89~ 77~
-------
S( m. SAMI'I.E SUMMAR Y CUNITS = mg/l(gt
rllASE I RIIFS .
YELLOW WATER ROAI> SITE
SAMI'I.E II>:
I.OCATION:
n )MMENTS:
OATE COLLECTEO:
S8-IA-07".
at ()'1 '001
S8.JA-r7a
r7 0-1 '001
SB-tA-Q7a
Ql 0-1 '001
SB-tA-R7a
R7 0-1 '001
12/05/88
12/ffi/88
12/ffi/88
12/00/88
VOCS
Melhylene Chloride .01 .0 .0083 .0 II .0016 0' .013 0
An~l()ne .8900 .019.0 1.60 3.28
BINs
NO
NO
NO
NO
rCBs
NO
NO
NO
NO
-------
SOIL SAMPLE SUMMAR Y (UNITS = mglk~.
PIIASE I RI/FS
YELLOW WATER ROAD SITE
SAMPl.E 11):
lOCATION:
('()MMENTS:
UA Tli COLLECfEI>:
SB-,A-PJa
PJ 0-1 foot
SO-JA-PJb
PJ 1-2 fet't
SO IA-QJa
QJ 0-1 fool
SO-IA-QJb
Q3 1-2 f(''et
12/09/88
12/{P}/88
12/(IJ/88
l2/m/88
VOCS
Melhylene Chloride .0016 01 .0048 -0 .0019 OJ .0025 0'
An'lone 6.8 15 3.4 2.1
BINs
Oimclhylphlhalale .m7B'
Oielhylphlhalale .350 - B
O. n-bulylphlhalale .260 - 1.2 -0
Dis( 2 -elhylhe)( yl)phlhalale . I 50 BI .480 BI
I'CRs NO NO
Aruduf-1260 .062C 2C
-------
SOli. SAMrLE SUMMAR\' «UNITS = mglkg'
PIlASli I RI/FS .
YELLOW WA1'I:R ROAO SITE
SAMI'I.E IU:
U)CATION:
('( )MMENTS:
IJA TE COLLECTED:
S8-JA-08a
. 0-1 fool
SD-IA-rSa
1'8 0- 1 fool
SD-IA-Q8a
Q8 0-1 fool
SD-JA-RSa
R8 0-1 fool
12/
-------
S( nI. SAMPU: SUMMAR Y (UNITS = mglllgl
""ASE I Rl/fS
YI:U.OW WATER ROAD SITE
SAMI'I.E II>: SO-JA-Q4a SIJ-IA-Q4b SIJCA-R4a
lOCATION: Ot 6-1 foot Q4 12 ft.'t't R4 II-I 'out
( "( )MM I:NTS:
DA TI: COLLECTED: 12/01/88 12/{ti/88 1/23/m
V()('S
Mt'thylene Chloride .0025 OJ 0046-0 004 IV
An>tone 2.4 22 .026 IV
T l'trat'hloroethane .002 IV
DINs
[)I n butylphthalate .70 .470 -0
Als( 2 -e.hylhe xVi )phthalate , 150 OJ .390 -8
I'yrl'ne
Chrysene
Rcnzo(b)fluoranthene
Benzo(k)fluoranthene
PCBs NO
Arnclor-1260 ,064C 6.5
-------
SOIL SAMPLE SUMMARY «UNITS;: mglkgt
PtiASE I RI/FS
YELLOW WATER ROAD SITE
SAMI'LE ID:
LOCATION:
COMMENTS:
DATE COLLECTED:
S8-'A-R6a
.. 0-1 foot
12/(1)/88
SB-'A-R6a
R6 0-1 foot
Mdtrix Spike
l2/ffi/88
SB-'A-R6a
R6 0-1 fuot
Matrix Spike Ouplicate
l2/ffi/88
I
VOCS
Methylene Chloride .0017 8'
Al't~tone 5.48
I,I-dichloroethene NDZ 49 QC% 49 QC%
Trichloroelhene 90% 93%
Benzene 83% 83%
Toluene 100% 110%
Chlombenzene 120% 120%
BINs
Oi -n-butylphlhalalc .092'
1,4 -dichlorobenzene 59% 62%
N - nit roso-di- n- propylamine 64% 69%
1,2,4 -Irichlorobenzene 62% 65%
Acenaphlhene 56% 58%
2,4-Dinilrololuene 61... 61%
Pyrene 54% 54%
I
PCBs ND
Arodor-l254 73... -. 92%
--
. ;
.,
-------
SOli. SAMI'U: SUMMARY «UNITS = mglkgl
PIIASE I RlifS
YELLOW W A TEN ROAIJ SITE
SAMPLE IIJ:
U)CATlON:
('( )MMENTS:
I)A 1'E COLLECTED:
SU-CA-Sla
81 .... 1001 .
58CA-Tla
1'1 0- 1 foul
1/-0/89
1/27/89
.
VOCS
BINs
PCBs
Aroclor-1260 .200 ND
A roclor-l254 NO .420
-------
SOIL SAMPLE SUMMARY (UNITS. mglkg)
PHASE 1 RIIFS .
YELLOW WATER ROAD SITE
SAMPLE ID:
LOCATION:
COMMENTS:
i . DATI! COLLECTED:
5B-jA-52c
&2 2-3 feet
CLP
12/19/88
5B-jA-52c
52 2-3 feet
CLP - Rerun (allall89)
12/19/88
5B-JA-T2a
1'2 6-1 foot
CLP
12/19/88
5B-JA-T2a
1'2 6-1 foot
CLP - Rerun (OJ/M/89)
12/19/88 .
vocs I
Methylene Chloride .0128
Acetone 5.581:
BIN.
Oi-n-butvlohthalate
.230 8J
PCB. NO NO
Arodor-1260 1.68 1.1
I .
-------
SOIL SAMPLE SUMMARY (UNITS", nWks-
PIIASE 1.RIfFS
YELLOW WAThR ROAD SITE
SAMPLE 10:
tOCA nON:
COMMENTS:
DA TE COLLECTED:
SB-JA-S5iI
&I 0-1 foot .
a.P
12/19/88
S6-jA-S5iI
55 0-1 foot
CLP - Rerun (01 /OS/tJ})
12/19/88
SB-JA-SSiI
55 0-1 foot
CLP - Rerun (01/05/tJ})
12/19/88
SB-jA-SSb
55 1-2 feet
CLI'
12/19/88
S6-JA-SSb
55 1-1-
CLP - Iteun fIl/m/f'»)
12/19/88
vocs , ,
Methv&ene Chloride .0108
Acetone .0458
T (II uene
BIN.
Oi-n-bulvlphthalale .190 OJ
Bls(2 -elh vi hex vi )phthalille
PCB. ND NO
Arndor-1260 .2200 .(8) J .500
I
-------
SOIL SAMPLE SUMMARY tUNITS - mglkg)
PHASE I RI/FS
YELLOW WATER ROAD SITE
SAMPLE 10:
LOCA 110N:
COMMENTS:
DA TE COLLEcrEO:
~jA ~b
1'2 1-2 feet
CLP
12/20/88
S8-jA-T2b
1'2 1-2 feet
CLP - Rerun
12/20/88
S8-jA-T2c
1'2 2-3 feet
CLP
12/20/88
S8-JA-TIc
1'2 2-3 feet
CLP. Rerun (02/02/89)
12/20/88 >
VOCS .
Methvlene Chloride
Aretone
BIN.
Oi-n-butvIDhthalate
j
PCB. >ND
A roclor-1260 1.2 B 1.2 .670
I I
-------
SOli. SAMPI.E SUMMARY CUNITS = mg/kgl
PIIASI: I Rill'S
YELLOW WATI:R ROAn SITE
SAMPI.E Ir>:
U >C A TION:
C<)MMENTS:
UA n COLLECTED:
SB-)A-T4a
.... 6-1 loot
CLf
12/20/88
SIJ-)A-Ha
T4 n-I loot
CU' - Malrix Spike
12/20/88
SH-)A-Ha
1"4 H- 1 'uol
CLP Malrlx Spike Dup.
12/20/88
SH-)A-Hb
T4 12 h_'t't
0.1)
12 !20/88
58-lA-He
T4 2-3 'eel
Clr
12/~/88
I
VOCS
Melhylene Chloride .006 8
Acelone 3 BE
1,4 - Dichlorobenzene NDZ 69'%, 27'%,
1,2,4 - Triehlorobenzcne NDZ 72'%, 23'%,
Al"enaphlhene NDZ 71 '%, 19'%,
N -- ni'rosodi - n - propylaminc NDZ 78 '%, 38%
1,1- Diehloroel hene 98% 96 '%,
Triehloroclhene 91% 92%
8cnzene 97'%, 97'%,
Toluene 103'%, 1 01 '%,
Chlorobcnzene 97% 96%
BINs
Di-n-bulylphlhalale .190)
1,4- Dichlorobenzene 69% 27%
N - nilroso-di-n - propylamine 78 '%, 38%
1,2,4-Triehlorobenzene 72% 23 '%,
Aeenaphlhene 71 '%, 19%
2,4 - Dinitrotoluene 78'%, 47'%,
Pyrene 76% 36 '%,
NO
J
r'.'
A md.., 1260
56
,I
ND
I
-------
SOIL SAMPLE SUMMARY CUNrrS = mslks)
PIIASE I RIIFS .
YELLOW WATER ROAD SITE
SAMPLE 10:
LOCA 110N:
COMMENTS:
DA TE COLLECJ'ED:
~JA-T5c
1'1 2-3 feet
CLP
12/16/111
~JA- T5c
TS 2-3 feet
ClP - Rerun C02/02/fIJ)
12/16/88
vocs
,
BIN.
PCB.
NO
NO
:..
-------
SOIL SAMPLE SUMMARY (UNITS - mslkg)
PHASE I RIIFS
YELLOW WATER ROAD SITE
SAMPLE ID:
LOCA 110N:
COMMENTS:
VA TIi COLLECTED:
SB-)A-U2a
VI 0-1 foot
CLP
12/16/88
S8-)A-U2a
U2 0-1 foot
CLP - Rerun 02/30/88)
12/16/88
S8-JA-U2b
U2 1-2 feet
CLP
12/16/88
SB-JA-U2c
U2 2-3 feet
CLP
12/16/88
vocs .
Methvlene Chloride .010B
Acetone .oos B)
BIN.
ND
PCB. ND NO
Aruclor-1260 368 32
.
-------
SOIL SAMPLE SUMMARY «UNITS = a'Afks)
PIIASE I,RIIFS
YELLOW WATIiR ROAD SITE
SAMPLE 10:
LOCA 110N:
COMMENTS:
DATE COLLECJB):
S&-,A-UJI» .
lQ 1-2 feet
a.P
12/16/88
S8-,A-UJm
U3 1-2 fftt
CLP - [)up.- S8-JA-UJl»
12/16/88
S&-JA-U3c
U3 2-3 fftt
CLP
12/19/88
S8-JA-U3c
U3 2-3 feet
CLP - Rerun «02/02/fIJ)
12/19/88
vocs '
,I
,
BIN.
PCB.
NO
NO
ND
ND
-------
SOli. SAMPLE SUMMAR Y «UNITS = IfIglkgt
PIIASE I RIIFS
YEI.LOW WATER ROAn SITE
SAMPLE In:
LOCATION:
c{>MMENTS:
DA TE COLLECfED:
SB-JA-U4b.
U4 1-2 feel
Clr
'l/16/88
SD,A.U4m
U4 1-2 feel
ClP - Dup.- SB-'A.U4b
12/16/88
SB-IA-U4c
U4 2-3 feel
ClP
12/20/88
SB'IA-U4c
U4 2-3 feel
ClP - RmJn
12/20/88
I
VOCS
Ml'lhylene Chloride
Acelone
BINs
Dls( 2 -elhylhex yl)phlhalale
Di-n-bulylphlhalale
PCUs
Arodor.1260 1.6 2.4 56B 63
-
-------
. S()II. SAMPLE SUMMA.IY fUNnS = m'~g.
PIIASE 1 RIII:S
YELLOW WATER ROAn SITE
SAM.'U: II): SO.,A.S6a SD-'A-T6a SO-JA-U6a Sn-'A-U6b
U)('AT'ON: 56 6-1 '001. T6 G-I '001 U6 0- 1 '001 U6 1- 2 'et.>t
('OMMENTS: . ,
UATE COlLECTEI>: 12/al/BB 12/(11/88 12/(11/88 12/Ul/88 .
VOCS ' ,
Mt'lhylcne Chloride .0025 8' .004 - 8 .0083 -0
An'IoRe .38 2.90 : 3.98
BINs
Di-n-bulylphlhalale 1qo OJ .530 -0 .4 -0
nisU -('Ihylhex yl)phlhalale ,180 0' .260 -0 .510 -0
PCBs NO NO NO
Arudor-1260 .09C
~
-------
SOIL SAMPLE SUMMARY (UNITS:: II1fVkst
PHASE I RIIFS
YELLOW WATER ROAD SITE
SAMPLE 10:
LOCA llON:
COMMENTS:
DA TE COLLECTED:
S8-JA-U5c
La 2-3 feet
a..P
12/20/88
5S-JA-U5c
US 2-3 feet
CLP - Rerun (02/02/89)
12/20/88
SB-'A-VSiI
VS 0-1 foot
CLP
12/01/88
vocs , ,
Methylene a.loide .003 BJ
Acetone 1.6 BE
Toluene
BIN.
~-n-~tyl~Uhalate .150 BJ
Dis(2 -eth ylhex vi )phlh.a.te
PCB. ND ND
ArocJor-1260 .170 BI
I
-------
SOIL SAMPLI! SUMMARY (UNITS. mglkg)
PHASI! I RI/FS
Yl!LLOW WATER ROAD SITE
SAMPLE ID:
LOCATION:
COMMENTS:
DATI! COLLEcrED:
S8-JA-U4n
1M 2-3 feet
a.p - Dup.-S8-JA-U4c
12/20/88
S8-JA-U4n
U4 2-3 feet
CLP - Renan (00/00/89)
12/20/88
S8-JA-V4,.
V4 G-Ifoot
CLP
12/01/88
S8-JA-V4b
V4 1-2 feet
CW
12/01/88
vocs
Methylene Chloride .002 BJ
Acetone 5BE
t:.
- ~ ~-
- ,
BIN.
Bis(2-ethylhexyl)phthalate 1.6
Di-n-butylphthalate .240 BJ
:
._~. . ~
PCB. ..
Arodor-l254 " 4.8
Aroclor-1260 56B 60 .190
..
. ;
-------
S( HI. SAMl'n SUMMAR „ CUNnS = m~gt
rllASE I RllfS
YELI.OW WAfER nOAl) SITE
12/02/88
SOJA-V61
Vb 0-1 foot
Dup of SO-JA-V6a
12/CJl/88
SO,'A-W6a
W6 0- 1 foot
CLP
12/01/88
SO-'A-X6a
X6 0- 1 'unt
SAM.'n ID:
I ()CATION:
('( )MMINTS:
DATE COLLECTED:
SO-'A-V6a
V6 O-I'oot
11/29/88
SO-'A- Y6.
Y6 6-1 fool
CLP
12/01/88
VOCS .
Mt'lhvlent' Chloride .0017 OJ .0029 0' .003 OJ .0037 80 .002 OJ
An'lune 5.20 5.2 0 20E 120 6.60E
OINs
\). nbuIv'phlh,,',,'e .350 80 .380 -0 .410 -0 .230 8'
IIi sC 2 c.' I hy 111(' II V Itphlh" I..Ie .690 0 .250 8 .110 J .1700'
1'('05 NO NO NO NO NO
-------
SOli. SAMI'LE SUMMARY (UNITS", mglkgt ,
PIIASE I Rl/fS .
YELLOW WATER ROAn SITE
SAMI'tE In:
I.OCATION:
('( )MMENrS:
UA TE COLLECTEI>:
SO-JA-W5a
'" 6-1 1001
CLP
12/01/88
SB-IA-W51
W5 0-1 fool
CLP - Oup.- SO-JA-W5a
12101/88
SO'IA-XSa
X5 0-1 foul
SB.IA-X5b
X5 1-21('(>1
SB-CA-YSa
n 6-11001
11/29/88
not specified
1/71189
vocs
Melhylene Chluride .004 01 .003 OJ .0064 .0
ACt~Iune I.IOE 150E 14 0
BINs
Hi- n-bulylphlhalale .140 01 _200 OJ
Ihs( 2 -elhvlhex yl)phlhalale .170 OJ
.
PCBs NO NO NO NO
Aruclor-1260 .690C
.
-------
SOIL SAMPLI! SUMMARY (UNITS - m&Jkg)
PHASI! I RUFS
Yl!LLOW WAnR ROAD SITE
SAMPLE ID:
LOCA 110N:
COMMENTS:
DA TE COLLECTED:
SB-CA-xXa
XX 0-1 fOot
SB-CA-XXb
XX 1-2 feet
SB-CA-XYa
XV 0-1 foot
SB-CA-XYb
XV 1-2 feet
1/"0/89
1/27/89
1/27/89
1/27/89
VOCS '
Methvlene ChIoride .OO5 .002 JM .0041
Acetone .014J .048 1M .001 1M .0741
ChIoroIonn .0)1 1
BIN.
Di-n-butylphthalate .590 -0 .580 -0 .920-0 .470-0
Oix(2 -dhvlhexvl)phthalate .290 -0 .096 01 .120 01 .130 81
PCB. ND ND
Amclor-1260 .740 20
I
I
-------
SOIL SAMPLE SUMMARY (UNITS = mg!ks)
PIIASE I RIIFS
YELLOW WATER ROAD SITE
SAMPLE ID:
lOCA 110N:
COMMENTS:
DA 1'£ COLLECI'ED:
SB-JA-W3a
M .. foot
11/)0/88
SS-)A-WJb
W3 1-2 feet
SB-)A-X3a
X3 6-1 foot
SS-)A-XJb
X3 1-2 feet
11/30/88
11/29/88
nol spedfied
vocs ,
Methylene Chloride .OM6-8 .011 88
Acetone .00'19 81 6.38
4-methyl-2-oenlanone .0035 J
BIN.
Di-n-butvlDhlhalate .2)0-8 .240 88
Ois<2-elhvlhexyl)ohthalate .160 01 .140 OJ
. ..~ -- ""'-
J
PCB. ND
ArocIor-1248 . 6C
Arodor-1260 IIC BC .046C
I
-------
SOIL SAMPLE SUMMARY fUNITS:: mglkgt
PHASE I RI/FS
YELLOW WATER ROAD SITE
SAMI'LE 10:
I.OCATION:
O)MMENfS:
I)A TE COLLECTED:
SB-)A-W4a
W4 0-11001
S8.'A-W"b
W4 1-2 fl't"1
SB-'A-X4a
X4 0-1 fool
SB-'A-X4b
X4 1-2 feel
S8-CA-Y4a
Y4 ().llool
11/30/88
l' /30188
l' 129/88
not specified
1 IV 1M
VOCS
Melhylene Chloride .002 01 .0062 80
ACt'lone 3.20 41 0
iO/Ns
Di - n-bu I ylphlhalale .440 80 .230 80
8is( 2 -el hylhel( vi )phl halale .24080 .130 8'
PCBs NO NO
.A rodor -1260 .J80C 2C .470
-------
SOIL SAMPLE SUMMAltV (UNITS = mglU
rtlAS~ I RI/I:S
VEI.LOW W A'fER ROAn SITE
SAMPLE 10:
LOCATION:
COMMENTS:
nA TE COLLECTED:
SOW-JA-1 1120
SOW-'A-2 1120
SOW-'A-3 1120
50W-IA-4 1120
SOW-JA-6 H20
12/Cli/88
12/(1)/88
12/(ti/88
12/00/88
12/15/88
VOCS
Me'hylcne Chloride _00151
Arelone .027 -0057 J
Chloroform _0055 .0024 -
Ommodichlommelhane .0012 -
Dibmmochloromelhane .(10031 1
Tolucne .tm23 1 .{D)22 1 .(1002 1
Tolal Xylencs JIOO7 1 .fXn)3 1 mos,
-
BINs
Di-n-bulylphlhalale .0024 01 .0024 OIM .0037 -0 .0035 -0 .0033 -0
Oulvlbenzylphlhalale .0012 I .0014 1M .0083
Ois(2 -elhylhex yl )phlha la Ie .0016 01 .0034 -OW .0022 01 .0023 01 .001681
Di-n-oclyl phlhalale .0015' .0026-
J
PCBs ND ND ND ND
Aroclor-1260 .00058 C
! 1
-------
S()I L SAMPLE SUMMAR Y .UNITS ::: mg/kg.
PUASE I RllfS
YELLOW WATER ROAn SITE
SAMrLE 10:
tOCATION:
COMMENTS:
I)A TE COLLECTED:
MW-40 U20
MW -50 ..20
M W -()() 1120
MW-70 H20
MW-80 H2O
11/16/88
11/16/88
11/16/88
11/16/88
11/16/88
.
VOCS
Melhylene Chloride .00 17 .
Acelone .0018 .8
Toluene .00071 I
BINs NO
Dis(2 -chloroelhoxv )melh-.ne .Ot4
2. melhvlnaphlhalene .OJ3
2,6-dinilrololuene .036
Phenanthrene .Oto
Anlhracene .039
Ruoranlhene .Ot2
PCBs
NO
NO
-------
SOIL SAMPLE SUMMARY (UNITS = mg/llgt
PHASE 1 RIIFS .
YELLOW WATER ROAD SITE
SAMltl.E 10: Ultra-rure Waler Organic-Free Waler . DI Waler Isopropanol
I.OCA.TION:
U)MMENTS:
UA TE COLLEcrED: 12'.'. nol specified 001 specified nol specified
VOCS , I
Acelone .0004 - .051 8 .011 -8 9.2
Chloroform .0093 "
8romodichloromethane .0016
()ibromochlorornelhane .fXXM J
Toluene .fr02 J .0012 ,
Tolal Xylenes .fXXM ,
Melhylene Chloride .000 -8 .0036 -8 .110.
2-bulanone 19
1,1, 1-lrichloroelhane 13
Trichloroelhene .410 -
4-melhyl-2-penlanone 2.9'
BINs
PCBs
,
-------
SOIL SAMPLE SUMMARY fUNITS . m~S)
PHASE I RIIFS
YELWW WATER ROAD SITE
SAMPLE 10:
I.OC A TION:
COMMENTS:
OA TE COLLECTED:
T8-1
T8-2
T8-J
T8-4
T8-5
«it; (DupUcilte)
12/13/88
CLP
1/19/88
not specified
CLP
12/13/88
a.r
12/13/88
I
VOCS
Methylene Chloride .0005 8' .001 8' .0014 BI .(0)9 BI an Bj 7"
Acetone .0108 .0025 OJ an 8'
BINs
PCBs
.
-------
SOIL SAMPLE SUMMARY (UNITS - mBfks .
PHASE 01 RVFS .
YELLOW WATER ROAD sm.
SAMPLE ID:
LOCATION:
COMMENTS:
OATH COLLBCI1!D:
WIR9O-AJ~
U5~1 foot
2/Ul/90
~20290-AJ-024
US 6-1 foot
DUPUCA TE
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APPENDIX B
Responsiveness Summary
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RESPONSIVENESS SUMMARY
The U.S. Environmental Protection Agency (EPA) established a public
comment period from August 28, 1990 through September 27, 1990 for
interested parties to comment on EPA's Proposed Remedial Action Plan
(PRAP) for Operable-Unit One for the Yellow Water Road site. During,
the comment period, EPA conducted a public meeting on September 4,
1990 at the Mamie Agnes Jones Elementary in Jacksonville, Florida.
The meeting presented the results of the studies undertaken and the
preferred remedial alternative-for Operable Unit One (soils/
sediments). During the public meeting the community was informed of
the availibility of a Technical Assistance Grant (TAG).
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 comments
and concerns. All comments summarized in this document have been
factored into the final decision on the preferred alternative for
Operable Unit One at the Yellow Water Road site.
This responsiveness summary for the Yellow Water Road site is divided
into the following sections. .
II.
III.
IV.
I.
. .
I.
Overview: This section discusses the recommended
alternative for remedial action for Operable Unit One and
the public reaction to this alternative.
Backaround on Communitv Involvement and Concerns: This
section provides a brief history of community interest ~nd
concerns regarding the Yellow Water Road site.
Summarv of Maior Ouestions and Comments Received Durina the
Public Comment Period and FDER's or EPA's Responses: This
section presents both oral and written comments submitted
during the public comment period, and provides the responses
to these comments.
Remainina Concerns: This section discusses community
concerns that EPA should be aware of in design and
implementation of the remedial alternative for Operable
One at the site.
Unit
Overview
The recommended alternative addresses the source of the contamination
by excavating, stabilizing and solidifying the PCB contaminated
soils. The major components of the recommended alternative include:
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a treatability study to verify the effectiveness of the
technology in solidifying/stabilizing PCBs contained in Site
soils;
the excav~ion of soils having PCB concentrations in excess
of 10 ppm with subsequent treatment by stabilization/
solidification;
placement 6f the treated soils in the former operational
area of the Site;
backfilling excavated areas with clean soils (less than 1
ppm PCB concentration);
placement of a vegetated one-foot thick soil cover over the
treated soil mass (monolith) and securement of the monolith
by a security fence;
provision of a vegetative cover over the remainder of the
Site; and
long-term management controls including operation and
maintenance of the monolith, vegetative cover and fence.
The community, in general, has no objections to the selection of the
recommended alternative.
II.
Backqround on Community Involvement and Concern
In accordance with CERCLA 113 and 117 requirements, a Community
Relations Plan (CRP) for the Yellow Water Site was finalized in
September 1990. This Community Relations Plan outlines citizen
involvement and the community's concern.
The most active period of community involvement with the Yellow Water
Road site occurred during 1984/1985 when EPA proposed to bring a
portable incinerator on-site to burn PCB-contaminated materials
stockpiled by EPA. Because of community opposition to on-site
incineration, EPA decided against incineration as a viable
alternative for remediating PCB contaminated soils stockpiled within
the former operational area of the site.
Media coverage for the site has been sporadic since 1985. Minimal
community involvement has occurred with regard to the site since
1985.
An RI Fact Sheet for the Yellow Water Road site was issued to the
public in December of 1988. All site-related documents were made
available to the public in both an administrative record and an
information repository located in the Baldwin City Hall and at the
EPA Records Center in Region IV. Following the release of the RI/FS
Fact Sheet, an availability session was held on Tuesday, May 29,
1990, from 7:00pm to 9:00pm at the Mamie Agnes Jones Elementary
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school. At this meeting, EPA officials provided an update on site
related activities, in addition to answering questions from concerned
Jacksonville citizens. '
The key issues and concerns of the Jacksonvi~le community identified
at the public meeting on September 4, 1990 and through written
comments received were:
Justification for the selected remedy: Citizens expressed
concern over the selection of Stabilization/Solidification as a
remedy for PCB contaminated soi1s at the site.
Inteerity of the selected remedy a The public was concerned about
the effectiveness of treatability studies in ensuring integrity
of a selected remedy, specifically stabilization/solidification.
III. SummarY of Maior Ouestions and Comments Received Curine the
Public Comment Period and EPA's Responses
1.) One commenter asked how many potentially responsible parties has
the ~PK ever collected from at Superfund sites (especially regarding
the Yell.ow Water Road site). .. . . .
EPA Attorney Response: EPA responded by statirig that presently work
at the Yellow Water Road site has been conducted by the PRPs, and EPA
,will negotiate with the PRPs to conduct design and cleanup of the
Site.
2.) A commenter asked what happens if the PRPs do not conduct design
and cleanup at the Site.
EPA Attorney Response: Superfund money will
will attempt to recover costs from PRPs. It
however, to try to obtain agreement with the
the Site.
be used, then the EPA
is EPA's intention,
PRPs to do cleanup at
3.) A commenter inquired about the proposed remedy at the site.
commenter was more accepting of off-site disposal rather than the
proposed on-site stabilization/solidification. .
EPA R~sponse: BPA evaluated nine criteria when selecting a remedy.
for remediation of soil and sediments at the Yellow Water Road site.
EPA feels that there is an increase in the risk to human health and
the environment by excavating and transporting soils to an off-site
facility.
The
4.) Another commenter asked why the s01ls could not be transported
if the PCB oils were originally drained and transported to Chicago.
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EPA Response: EPA is trying to minimize the risk associated with
remediating the site. Also, off-site disposal facilities may not
have the ability or capacity to take the contaminated soils from the
Yellow Water Road site. On-site treatment by
stabilization/solidification is an effective treatment technology for
remediating PCBs at Superfund sites.
5.) A commenter ask~d if all of the nine evaluation criteria are
equally weighed when choosing an alternative.
EPA Response: All nine criteria are considered when evaluating an
alternative. However, the number one criterion in looking at
alternatives is protection of public health and the environment. For
an alternative to be considered further, it must first be protective
of human health and meet Federal and State requirements.
6.) A commenter asked if Stabilization/Solidification has been used
at other Superfund sites.
EPA Response: Yes. One site in which this remedy was implemented is
the Pepper's Steel and Alloys site, located in Dade County, Florida.
7.) A commenter asked how long ago the Pepper's Steel site was
remediated by stabilization/solidification.
EPA Response: Remedial action construction was completed in the
Spring of 1989. The site is currently being monitored for long-term
effectiveness and integrity. For more information concerning the
Pepper's Steel site contact:
Dade County Department of Environmental
13th Floor
111 Northwest First Street
Metro-Dade Center
Miami, Florida 33128
(305) 375-3321
Resources Management (DERM)
Mrs. Diane Scott, Remedial Project Manager
U.S. Environmental Protection Agency
345 Courtland Street, HE
Atlanta, Georgia 30365
8.) During discussions regarding the stabilization/solidification
treatability studies, a commenter asked how long does treatability
testing occur and is there going to be a significant delay in the
project.
EPA Response: The treatability study is not considered a delay. It
is conducted during the remedial design phase of the project.
9.) A commenter asked if treatability studies are conducted on each
site, and does the EPA project how long it will take for leaching to
occur on stabilization/solidification sites.
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EPA ResDonser Treatability studies are a standard practice for sites
such as Yellow Water Road and Pepper's Steel where stabilization/
solidification remedies are selected. A treatability study is
conducted in order to oPtimize a mix for stabilizing and solidifying
the contaminants. ~he determination of whether leaching 'will Occur
is part of the treatability study; however, at this time, an actual
time frame in which leaching may OCcur (if at all) cannot be
determined.
10.) A commenter asked that if there is a failure in the
treatability study, would the ROD need to be amended, and if so, does
this cause a delay in the schedule.
EPA ResDonse: If, indeed, the remedy does not meet the criteria of
,being protective of public health and the environment as defined in
the ROD, then the ROD would have to be amended and this could delay
the cleanup schedule. But based on the information we presently
have, the EPA believes that the remedy will work and we have enough
information to proceed with the treatability study.
11.) , A-commenter asked how long the Yellow Water Road site will be
monitored.
EPA ResDonse: Upon completion of the remedial action phase of the
project, operation and maintenance begins on the site. Operation and
maintenance activities will involve a semi-annual inspection and
maintenance of the monolith and soil cover and confirmatory sampling.
Upon completion of O&M, sites are usually assessed every five years
to ensure integrity of the design and construction. Assessment
con~inues until the EPA feels that there is adequate data to prove
that the remedy is protective of human health and the environment on
a long-term basis.
12.) A commenter asked if it is more economically feasible to
transport materials from the Yellow Water Road site and other
Superfund sites to one site in the country and monitor contaminants
at that one site, instead of having several stabilization/
solidification sites across the country.
EPA Response: Stabilization and solidification is considered a
pe~anent remedy. The monitoring associated with this particular
rem~dy is limited in comparison to other remedies. With
stabilization/sOlidification, there is not an extensive amount of O&M
or monitoring associated with it as compared to other remedies. In
addition, as stated earlier, excavation necessary to transport
contaminated soils would increase potential risks to health and the
environment at those sites. ,
13.) A commenter stated that while solidification is a viable
short-term solution, over time there is a concern that leaching from
the solidified material may occur, and that it is not the same as
removing the contaminants and restoring the property to its original
°ondi tion.
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EPA Toxicoloaist Response: The goal of the Superfund program is not
to restore the property to its original condition. The primary goal
of the program is to protect human health and the environment. It is
not feasible to remove absolutely all PCBs from the site, and there
are levels of PCBs that are not harmful to human health and the
environment.
14.) A commenter inquired about where the nearest TSCA compliant
landfill is located_in reference to the site.
EPA Response: An approved TSCA compliant hazardous waste landfill is
located in EmelIe, Alabama. However, pressure has been placed on the
various states throughout the country to develop their own approved
hazardous waste landfills to decrease the transporting of wastes to
other landfills such as the one in EmelIe, Alabama.
15.) A commenter asked that if the
extraction disposal alternative was
be incinerated. Would they be sent
oils were incinerated?
excavation/solvent wash/
chosen, where would the solvents
to Chicago where the site's PCB
EPA Response: Before the EPA proceeds with any remedy, a plan is
developed and proposed. Details such as this one are addressed
during a treatability study. At this phase of the project, details
such as this one have not been addressed.
16.) A commenter asked if the mass contribution that is used in
solidification is equivalent to cement.
EPA Response: Yes, cement or some type of bonding material is used.
There are several technologies for solidifying and stabilizing
wastes. A cement-like material is, however, commonly used. Once
again, these types of details are addressed through treatability
studies and the remedial design phase of the project.
17.) Another Commenter asked if a material less porous than cement
could be used, for instance, a glass-like matrix.
EPA Response: What the Commenter is referring to is known as in-situ
vitrification, which solidifies materials in a glass-like matrix.
However, this technology has not been proven as an acceptable
technolcgy for PCBs.
IS.} One commenter questioned the source of some unknown chemicals
that were identified in low concentrations in one sampling incident
and asked if those tests were redone to check the previous findings.
EPA Response: The EPA did retest, taking four samples on four
different occasions. Certain other chemicals did show up in one
sampling incident, but not in subsequent samplings. Therefore, we
attributed the presence of those chemicals to improper decon-
tamination of equipment and/or possibly laboratory contamination.
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19.) A commenter asked if any drinking water wells in the area have
been contaminated with PCBs from the Yellow Water Road site.
EPA Responsez The sampling that occurred in both 1988 and 1989
indicated that no contamination was present in the drinking water
wells located at or near the Yellow Water Road site.
20.) A commenter asked whether or not soil that had been previously
excavated from the gite and placed on a concrete pad was covered.
EPA Response: Those soils were removed and transported to EmelIe,
Alabama for disposal by the PRPs under EPA guidance in 1988
21.) A commenter wanted to know what chlorinated benzene isomers
were discovered in a portion of the site that was believed to be
possibly contaminated.
EPA Responsez These benzene isomers were only found in areas where
high PCB concentrations were found; therefore, their presence appears
to be consistent with the generation of PCBs.
22.) A city representative posed several questions as to the overall
effectiveness of implementing the preferred Alternative 5 in
comparison to Alternative 4. The concerns were: ...
a. Alternative 5 is questionable as to compliance with ARARs.
b. Alternative 5 may not provide a long-term solution
considering the fact that it has not been proven that
leachate will not exceed drinking water standards.
c. Alternative 5 may create a contaminated dust from the
solidification process.
d. Alternative 5 requires an extensive treatability study,
which is one reason that Alternative 4 was not selected.
EPA Response: a.) In the Agency's review of Alternative 5, there
appears to be no violation of State or Federal environmental laws.
b.) Alternative 5 is considered a permanent remedy because
contaminants will no longer be mobile and contaminants should
therefore no~ leach into groundwater once the remedy is implemented.
c.) It is imperative that dust control be addressed when selecting a
remedial alternative such as stabilization/ solidification;
therefore, dust control will be addressed in the Remedial Design
phase of th~ project. c.) The method of solvent wash extraction
presented in Alternative 4 has not been previously implemented on a
large scale such as a Superfund site. Much research would have to be
conducted to see if, indeed, we could implement it on a large scale.
Therefore, EPA had some reservations about selecting a remedy for
this particular site that had not been proven at another Superfund
site. EPA felt that the better approach was to proceed with a
technology that has been previously used on PCB contaminated soils.
EPA has a higher confidence level with the stabilization/
solidification process (Alternative 5) than we do with the solvent
extraction process.
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,-
I .
The Yellow Water Road PRP Steering Committee commented by stating
that they support a landfill remedy, that is, excavating PCB
contaminated soils and diSposing in a TSCA compliant landfill. They
did state, however, that they do not oppose EPA's selection of
stabilization/solidification (Altenative 5) as a remedy for the site.
IV.
Remaining Concerns
The community's concerns surrounding the Yellow Water Road site will
be addressed in the following areas: community relations support
throughout Remedial Design/Remedial Action and incorporation of
comments/suggestions from the community into the Remedial Design.
Community relations will consist of making available final documents
(i.e., Remedial Design Work Plan, Remedial Design Reports, etc.) in a
timely manner to the local information repository for the site. EPA
will also issue fact sheets to those on the mailing list to provide
further information on progress of the project and schedules for
future activities at the site. EPA will inform the community of any
principal design changes made during the project design. If, at any
time during the Remedial Design or 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 with an opportunity for public comment to
incorporate new technology that will attain the necessary cleanup
objectives and goals.
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APPENDIX C
State Concurrence Memorandum
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-
- RISK ASSESSMENT CERTIFICATION
The Region IV risk assessment staff has reviewed the PRP-
generated risk assessment for the Yellow Water Road NPL Site,
Baldwin, FL for compliance with current Agency health risk
guidance and policy. Comments were conveyed to the Potential
Responsible Parties (PRP) through the Remedial Project Manager
and appropriate changes/corrections have been incorporated into a
revised risk assessment document. In accordance with the
requirement of OSWER Directive No. 9835.15 (8/28/90), it has been
determined that the final risk assessment as summarized in this
Record of Decision conservatively conveys the upperbound cancer
and the systemic toxicity risks posed through all reasonably
likely current and future exposure scenarios by contaminants
identified at this site. Therefore, it is acceptable to the
Agency.
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ELMER W. AKIN
HEALTH ASSESSMENT
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