United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R04-92/103
June 1992
PB93-964015
$EPA Superfund
Record of Decision:
Yellow Water Road Dump, FL
-------
.I"
NOTICE
The appendices listed In 1he index that are not found in this document have been removed at 1he reQuest of
the issuing agency. They contain material which supplement. but adds no further applicable information to
the content of the document. All suppiemental material is, hoWeVer. contained In the administrative record
for this site.
-------
50272.101
REPORTDOCUMENTA~ON 11. REPORT NO. I ~ I. A8dpIenI'8 Acm88Ion No.
PAGE EPA/ROD/R04-92/103
4. 11tI8 MIl 8ubIItI8 . I. AIpart 0818
SUPERFUND RECORD OF DECISION 06/30/92 -
Yellow Water Road Dump, FL I.
Second Remedial Action - Final
7. AuIhor(8) .. PiIrfoIInkIg 0rpnIDII0n AIpL No.
I. I'IIrtIIIftng OIplnlJallon ..... MIl AddNM 10. ProjIctIT8IIIIWarII UnI1 No.
11. CoNNcI(C) or Gr8nt(G) No.
(C)
(0)
1~ 8poI8arIIIg 0rpIU8II0n ..... MIl AdIh88 11. Type of R8pIII16 PwIod eo-.!
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
11. ...... -..., No....
PB93-964015
11. Ab8bct (LImIt: 2IID WOId8)
The 14-acre Yellow Water Road site is a former storage area for PCB-contaminated
liquids and electrical equipment in Baldwin, Duval County, Florida. Dense woodlands
are located along the perimeter of the site, and surrounding land use is mixed
commercial and residential. The property, originally purchased in 1940 fo~ commercial
development, was later acquired by the American Environmental Energy Corporation
(AEEC). In 1981, AEEC entered into a joint venture with two other corporations with
the intent of moving an incinerator to the site to destroy PCBs and began onsite
storage of PCB-contaminated liquids and electrical equipment at the former operational
area in anticipation of upcoming onsite incineration operations. The proper permits
for the incinerator were never obtained. In 1982, PCB-contaminated oils were spilled
at the site during onsite salvage operations to remove valuable metal parts from
transformer carcasses. As a result of onsite PCB contamination, EPA conducted a
number of investigations that revealed PCB contamination in the soil and ground water.
In 1984, EPA conducted a removal action that included cleaning and storing 719
electrical transformers; securing 100,000 gallons of PCB liquids in onsite holding
(See Attached Page)
17. Doc:umInt An8Jy8I8 L DncrIptora
Record of Decision - Yellow Water Road Dump, FL
Second Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: Organics (PCB)
b. Identiller8lOpen-EncIecI Terma
c. COSA T1 FleldlGroup
18. Avlilabllity Statement 19. Security Cia.. (ThIs Report) 21. No. of Pages
None 74
20. Security Cia.. (Thla Pege) n PrIce
Non1=>
See ANSl-Z39.18 See In.rruclioM on RellfltM ...",
(Formetfy NTI~35)
Department of Commerce
-------
EPA/ROD/R04-92/l03
Yellow Water Road Dump, FL
Second Remedial Action - Final
Abstract (Continued)
tanks; and excavating and storing 3,000 cubic yards of PCB-contaminated soil onsite. In
1988, EPA directed a second removal action that included demolishing an onsite warehouse;
disposing of warehouse debris and stockpiling contaminated soil offsite; incinerating
78,854 gallons of PCB liquids offsite;. and disposing of 704 transformers and 18,690
po~nds of capacitors offsite. The remedy selected by EPA for this site has been
conducted in two separate operable units. A 1990 ROD addressed the source of the
contamination by excavating, stabilizing, and solidifying the PCB contaminated soil.
This ROD addresses the appropriate remediation for the contaminated ground water as OU2.
This is the second and final planned remedial action for this site. The primary
contaminant of concern affecting the ground 'water is PCB an organic.
The selected remedial action for this site includes constructing four additional ground
water monitoring wells downgradient of the former operational area; installing a security
fence; conducting long-term ground water monitoring; and implementing institutional
controls including deed and groun~ water use restrictions to .control exposure to
contaminated ground water. Downgradient monitoring will be performed quarterly for
2 years, after whichthe_grou~d water monit~ring frequency will be reevaluated if no PCB
contamination is detected. If PCB contamination is identified above MCLs in compliance
wells, additional contingent remedial activities would be implemented including
construction of ground water extraction wells; installation of a ground water filtration
system, with a granular activated carbon (GAC) treatment system, and a treated effluent
discharge system, which uses onsite infiltration ponds or drainage swales; and
transporting and disposing and/or treatment of the residual carbon and filtration waste
offsite. The estimated present worth cost for this remedial action is $4.07,620 for
initial implementation and $1,377,600 for full implementation of the contingent remedy.
O&M costs are not provided for this remedy. .
PERFORMANCE STANDARDS OR GOALS: The chemical-specific ground water clean-up goal is
based on SDWA MCLs for PCBs 0.5 ug/l. However, because of the technical impracticability
of using a treatment system to remove PCBs from ground water, a waiver of SDWA MCLs is
required for ground water located directly beneath and in proximity to the former
operational area. .
-------
.'
. "
-
. - : ~;. t.. ..
. "~',,:' ~~:
. '. :r:
..;.:2,
, -.
c.;',
''"" .
't :.
'''.or ..,
.'....... .
- -
. .
...,. ':'-:..:'" ',". -, t.,
,'.I< '- .;..- ....
,',f
,.::.. ;...
,< .
"
- .,'';-.''
.- -
..
Record of Decision for
Operable Unit Two
The Decision Summary
. . .a.._.
'1;.'
. "-..
....,
. ''''''''.ti
, -.
'-'1' .
, .'
- - - '.
.~. :.
'\: -,.:-
."~
..
, ..
~-:. .::-. '.:. ~.
. -.:....;:.:....
'..
""r ~',..
'. ..' ..............
\r .~
t.!~t
. .', . ~
. "
(:~'" ! . .'
. ....
~":'I ~~.~.. '..~.;Y,e,l:low ~Wa.ter.. .Road, ~Site' .
l,l:- " ,'".,:, C--.. ..~:. ""',l'. :.....':_,...'. '. ~ -" ""I . ~
Baldwin,
Duval
County ,.- 'Florida .
, ''''..... 1:. - ~ ,
.~.' " . .
.li. .
- .
'-:!fo# .'.
;":
"--1"'--
".~.C
;'~'; [
-. r
"
. ..- .-
.,' ,J.""':
\ ~. ;'P, ..~ ~
.'
. -
.. .
r .
~I* .
. .
- .
"
u.s.
Prepared by:
Environmental Protection
Region IV
Atlanta, Georgia
Agency
-
. -.
.. ....... ".
. 'ar~t'
... ..-
., ".
. .
.'
- .
"" -: ~
"~
"',...'
. ,
-------
RECORD OF DECISION
OPERABLE UNIT TWO (GROUND WATER)
DECLARATION
SITE NAME AND LOCATION
Yellow Water Road Site
Baldwin, Duval County, Florida
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
Operable Unit Two 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 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 has been conducted in two separate
operable units. Operable Unit One addressed 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.
The major components of the selected remedy for Operable Unit Two
include:
o
the implementation of a long-term ground water monitoring
program;
-------
-2-
o
the construction of four additional ground water
monitoring wells downgradient of .the source area, two
wells (one in the Upper Sand Unit ,and one in the Lower
Sand Unit) will be located 20 feet downgradient of"
monitoring cluster 7 and two ('one in 'the Upper Sand Unit
and one in the Lower Sand Unit) located 20 feet
downgradient of monitoring cluster. 8;
the implementation of institutional controls, which would
include deed restrictions, zoning controls, and water
supply well. permitting prohibitions; -,
o
o
the contingent construction of the appropriate number of
ground water extraction wells which will be determined
during remedial design. However, costs are currently
based on two extraction wells, one in the Upper Sand Unit
and one in the Lower Sand Unit, both located near the. .
western boundary of the former operational area of the
Site; . ' , ,
o
the contingent installation o~ a ground'water pumping -
system; .
o
.." ... c . . ..
the contingent installation of a ground water filtration
system;.
o
the contingent installation of a Granular Activated Carbon
(GAC) Treatment system;
o
the contingent installation of a treated effluent
discharge system;
o
the transportation and disposal of the GAC and filtration
waste to a TSCA-compliant landfill or incinerator, if
treatment is warranted; and
o
long-term management controls including operation and
maintenance of the ground water treatment system if
warranted.
Items 1 through 3 will be immediately implemented. The
implementation of items 4 through 10 of this alternative would be
contingent upon confirmation of PCBs at downgradient compliance
monitoring wells. Confirmatory sampling must occur within sixty
days of receipt of the original monitoring results that show'
elevated PCB concentrations. -
The initial total present worth cost for the selected remedy as
presented in the Feasibility Study is $376,754. If the
contingency is fully implemented, the total present worth cost
will be $1,346,725. After further consideration of comments
-------
-3-
received during the public comment period, two additional
monitoring wells were deemed necessary, thus increasing the total
present worth cost by $30,875, for a total present worth cost of
$407,629 for initial implementation and $1,377,600 for full
implementation, if warranted.
STATUTORY DETERM.IHATION
The selected remedy is protective of human health and the
environment, is cost effective, and it complies with Federal and
State requirements that are legally applicable or relevant and
appropriate to the remedial action or a waiver can be justified
for whatever Federal or State applicable or relevant and
appropriate requirement that will not be met. A waiver of the
Safe Drinking Water Act (SDWA) Maximum Contaminant Level (MCL)
for PCBs is required for the ground water located directly
beneath and in close proximity to the former operational area.
Justification for the waiver is the technical impracticability of
utilizing a pump and treat system to remove PCBs from the ground
water [40 C.F.R. 300.430(f)(1)(ii)(C)(3)]. This waiver applies
solely to the ground water beneath the source area and will
remain in effect until such time as active remedial measures may
provide some advantage in attaining the ARAR. This remedy
utilizes permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum extent practicable
for this site. However, because treatment of the principal
threats at the site was not found to be practicable, this remedy
does not satisfy the statutory preference for treatment as a
principal element.
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.
c:'-30-9z.
Date
~fl1~
f\Greer C. Tidwell
Regional Administrator
-------
.g
1 . 0 Site Name-, Location and Description. ..... .v ............. 1
2 . 0 Site History and Enforcement Activities ................. 5
3.0 Highlights of Community Participation. . . ............ ... .8
4 . 0 Scope and Role of Operable Unit ........................ .9
5 . 0 Summary of Site Characteristics .... ...... . . ." ............ 10
5 . 1 Geology ...... ... .................... . . ............. 10
5 . 2 Hydrogeology ...................... .'.'.' ...... . ....... 10
5 . 3 Sampling Results ........................ . ........ . . 14
6 . 0 Summary of Site Risks ..... ................ .............. 20
6 . 1 Overall Risk Characterization Summary .............. 20
6.1.1 Identification of the Contaminants of
Concern ..................................... 21
6.1.2 Fate and Transport Analysis ................. 21
6.2 Human Health Risks. . .-. .............................. 22
6.2.1 Exposure Assessment Summary ................. 22
6.2.2 Toxicity Assessment Summary ................. 22
6.2.3 Risk Characterization Summary ............... 24
6 . 3 Environmental Risks ................................ 24
7 . 0 Description of Ground Water Alternatives ................ 26
7 . 1 Alternative 1 - No Action ......... ................. 26
7.2 Alternative 2 - Institutional Controls and
Monitoring .............. ........... 27
7.3 Alternative 3 - Filtration/Carbon Adsorption
(GAC) .............................. 29
7 . 4 Alternative 4 - Filtration/UV Oxidation ............ 32
7.5 Alternative 5 - Contingent Filtration/Carbon
Adsorption ......................... 34
8.0 Comparative Analysis of Ground Water Alternatives ........ 37
8 . 1 Overall Protection of Human Health and the
Environment ....................................... 37
8.2 Compliance With Applicable or Relevant and
Appropriate Requirements (ARARs) .................. 39
8.3 Long-term Effectiveness and Permanence ............. 44
8.4 Reduction of Toxicity, Mobility, or Volume ......... 45
8 . 5 Short-term Effectiveness ................ ........... 45
8.6 Implementability ................................... 46
8.7 Cost ............................................... 47
8 . 8 State Acceptance ................................... 48
8 . 9 Community Acceptance .......................... ..... 48
9 . 0 Selected Remedy .......................................... 48
-------
-2-
10.0 Statutory Determinations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .55
10.1 Protection of Human Health and the
Envirorunent. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .56
10.2 Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs)............ ......56
10.3 Cost Effediiveness................................58
10.4 Utilization of Permanent Solutions and
Alternative Treatment Technologies (or Resource
Recovery Technologies) to the Maximum Extent
practicable...................................... .58
10.5
Element. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .59
Preference for Treatment as a Principal
11.0 Documentation of Significant Changes.....................59
-------
LIST OP PIGURES
Figure 1. 1
Figure 1. 2
- KeyS i te Map.........'........................... 2
- Site Plan....................................... 3
Figure 1.3
- Ownership' P la t Map.............................. 4
Figure 5.1.1 - Geologic and Hydrogeologic Cross-Section
Locations. . . . . . . . .". . . . . . . . . . . '. . . . . . . . . . . . . . . . . . .11
Figure 5.1.2 - Geologic Cross-Section
A-A I . . . . . . . . . . . . . . . . . . . . . 12
, . .
Figure 5.1.3 - Geologic Cross-Section
B-B' .- . . . . . . . . . . . . . . . . . . . . 13
Figure 5.3.1 ~ Monitoring Well
Lo~ations . . . . . . . . . . . . . . . . . . . . . . . 15
Figure 5.3.2 - Monitoring, Well PCB Concentrations..............18
Figure 5.3.3 - Monitoring Well PCB Concentrations from
Source Area and Downgradient Wells..............19
Figure 9.1
Figure 9.2
- Typical Extraction Well Pump Station............51
- Granular Activated Carbon Process...............52
-------
Table 5.3.1
Table 6.3.1
Table 8.1
Table 8.2.1
Table 8.7.1
Table 9.1
Appendix A
LIST OF TABLES
- Contamination Prevalence Summary.... ............17
- Endangered and/or Threatened Species
for Duval County, Florida..................... ..26
- Glossary of Evaluation Criteria.................38
- Applicable or Relevant and Appropriate
Requirements (ARARs)............................ 40
- Ground Water Remedial Alternative Cost
Compar isons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47
- Cost Analysis Summary for Alternative 5.........54
LIST OF APPENDICES
- Responsiveness Summary
-------
. ~..~.......
RECORD OF DECISION
Smnm"1ry of Remedia,l Alternative Selection ~ .
Operable Unit Two - Ground Water
Yellow Water Road Site
Baldwin, Duval Co~ty, Florida' ..: ..:.
.... - <..-..' --,.
..
1.0
Site Name. Location. and DescriDtioli~'
~..... .-..'!-. ..
. . .
.- '
. .
. . ...~ ..." ~
. .
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 1.1).' . :. "
The site encompasses approximately 14 acres of predominantly
vegetated land with limited topographical 'relief. ' 'IDense woods. ,. .
that can be viewed as a natural resource are located on.the .
perimeter of the sites boundary. Surface'elevations.across the'
site generally do not vary m0r.e than one or ,two 'feet,'except for. a
few shallow man-made drainage' ditches. '( see. .Figure :~. 2) . '
. ; ~. '.' : . . . .;.\'. .:', ,.. ';. .. ,
The land adjacent to the site is used for many commercial' . "',
purposes. Property owned by Florida Power & Light Company~s
located west of the site. Indian Head National Bank of Nashau
owns property situated northwest, west, sout~, 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 1.3).
. ~>... :.'. :~
""'. ..
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.
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 sheds, 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.
-------
tV
(
)
SITE
,..,
. "
10",.
"-4
YELLOW
KEY MAP
WATER ROAD SITE
Baldwin, Florida
eRA
21~tl- 70-19/05/89-9-0
-------
'r-j -- ~ \,,~-v~ ~ ~ '~ 1 i
"', ~ i ~ . ; . . ~. , . f
. I . h~a~~ '. .
! 0 L__- JiJ~." = ..:' ..... H, 1
-- }' 0 --- 3G . . . , . '.' Pji ~
I -~ e ,~
i --<~~ frt
I~Q . ~>;> " /IE
L_______.l--:_--~-------~_lL.. "
-------
\
'I
,
, \
i , ~:..,
~~~,~
~ :
f . I
II
~ //
~ 1/
t (r
;
HWY 90
-/
1
I
I I
I
::;/
-t;
ti BALDWIN
~I
~
c,;
I .
'. I
II
'8t....Ut. 11 '
I
/
I
. I FLORIDA
/ I POWER.. /
I / ~GHT eo /
/ 35
/
1
I /
INOIAN HEAl)
NAT,ONAA. lANK
~ NASHAiJ
F"ED 8
MLLER JA
'.110. v.t.,.
..... S1 t.
; N 01..-. HEAD \~\~
I NAilONAL BANK
I
I
I
I \
TWP 3S -RNG,23E \
V
I
I
I
1
1
!
\
\
J
" I
u
i
... I
>JI
0 I~
~
u
.. N
. i
~
,
(/)
n N
'~
'~
~
H
, I
'-jeTE 3ASEO ON 1ge4 ::UVAL :::VNT'f'
OWNERSHIP F>l..AT
NOT T:) SCAL.E
FIGURE 1.3
CRA
YELLOW WATER ROAD SITE
Baldwin, Florida
2158-70-' ~/05/8~-S-O
4
-------
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 tmmediately
downgradient from the site. '
-
2.0
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. ," ,.'V: " '-:, ..
. I~" .
Title to the prope~ty was transferred by Mr.Tyer ,tothe'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 Polychlorinated Biphenyls (PCBs). The principal
individuals involved in this join.t-venture were Mr. Tyer.,and Mr.
Maxwell Cobb. : " ',. ' .. ,
"
As part of this enterprise, beginning in 1981 0~'~982, PCB
contaminated liquids and equipment were stored at. the S,i~e. The
incinerator permit was never obtainedi and the PCB-contaminated
materials continued to be stored on-site'. .'
By October 1982, the joint venturers had parte~~ays, and AEEC
and Mr. Tyer sued AEC and Mr. Cobb, 'obtaining a'restraining order
in December 1982, preventing Mr. Cobb from entering the ;Site
boundaries. 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 (DOD) under the Federal Tort
Claims Act. The suit alleged that PCB liquids sent by DeD to AEC
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 AEC and Mr. Cobb. The investigation centered
on a contract between AEC and DOD for disposal of PCB
contaminated liquids, equipment, and materials.
At a criminal trial involving AEC's performance under the
contract with DOD, the prosecution centered on 47 PCB
transformers,. AEC had reported to DOD that they had disposed of
the transformers at TSCA approved facilities when they had
instead placed them 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,
5
-------
Michael Hamm, on two unrelated criminal charges uncovered during
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 which were
needed. Tyer informed the County that he was financially 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 soil 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 (BESD).
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 (TCE) 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 ground water
assessments were conducted which indicated that the ground water
contamination, which was due to the presence of PCBs and not TCE,
was limited to within the site boundaries.
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.
6
-------
On June 14, 1985, EPA Region IV issued an order under Section 106
of CERCLA to Mr. Tyer, ordering 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.
In March 1987, EPA sent notice and demand letters to 67
Potentially Responsible Parties (PRPS) identified as generators
of the PCB-contaminated materials found at the Site. By May "
1987, 53 of the 67 PRPs had joined together and formed the Yellow
Water Road Steering Committee (the Steering Committee). Later
that year, EPA and the YWR Steering Committee entered into an
Administrative Order by Consent (AOC) to conduct a Remedial
Investigation/ Feasibility Study (RI/FS).
In May 1988, EPA and the Stee~ing. Committee entered into an
additional Administrative Order by Consent, under which.the
Steering Committee undertook an interim surface removal action at
the Site underEPA oversight. This removal action was completed"
in July 1988. The removal activities included the qemolition of
an on-site warehouse, disposal of the resulting debris and the
previously stockpiled contaminated soil, off-site ~ncineration 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 Wa"ste Management's permitted disposal facility located
in EmelIe, Alabama. The PCB-contaminated liquids were
transported by rail to SCA in Chicago, Illinois, for
incineration. "
Conestoga-Rovers & Associates, acting on behalf of the Steering
Committee, performed the RI/FS field work, again under EPA
oversight. These field activities were conducted at the Site
from November 1988 to March 1990. Soil and sediment samples were
collected and 18 groundwater monitoring wells were installed and
sampled. The resulting RI and FS Reports were submitted and
approved by BPA in April and August 1990, respectively. Based on
these documents, BPA determined that additional data was needed
to fully evaluate the extent of ground water contam~nation; and
as a result, EPA separated the cleanup into two Operable Units,
one for soils and sediments and one for ground water. EPA
proposed a cleanup plan for Operable Unit One (OU1) (soils and
sediments) in August 1990 and selected the remedy in September
1990. The Steering Committee is presently performing the
Remedial Design for the remedy for OU1.
Concurrent with the release of the OU1 Record of Decision (ROD),
the Steering Committee began additional OU2 (ground water) field
7
-------
work. The additional OU2 field work was conducted in two
separate phases in January and October 1991. Activities included
installation and sampling of six (6) additional ground water
monitoring wells, sampling of surface and vadose zone soils, and
sampling of several existing monitoring wells. The resulting OU2
RI and FS Reports were submitted and approved by EPA in March and
April 1992, respectively. EPA released the proposed Plan for OU2
to the public on May 7, 1992, commencing the 30 day comment
period. Comments received from the public and the State have
been incorporated into the Responsiveness Summary, which is found
in Appendix A of this document.
3.0
Hiahliahts of Community Particioation
In accordance with CERCLA sections 113 and 117 requirements, a
Community Relations Plan (CRP) for the Yellow Water Site was
developed. This Community Relations Plan outlines citizen
i~volvement 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.
The public was provided an opportunity to comment on the remedial
alternatives for OU1 from August 28, 1990 to September 27, 1990.
In addition, a public meeting was held on September 4, 1990 in
Baldwin, Florida to present to the community EPA's preferred
alternative for OU1 source remediation. During the public
meeting, the community was informed of the availability of a
Technical Assistant Grant (TAG). A response to the comments
received during the public comment period is included in the
Responsiveness Summary, which can be found in Appendix B of the
OU1 Record of Decision.
8
-------
The OU2 RI/FS Reports and Proposed Plan for the Site were
released to the. public for comment in May 1992. These two
documents were made available to the public in both the "
administrative record and the information repository located in
the Baldwin Town Hall. A public comment period was held from May
7, 1992 through June 6, 1992. In addition, a public meeting was
held on May 18; 1992 to answer questions about problems at the
Site and the ground water remedial alternatives under
consideration. A response to each comment received during the
comment .period has been provided in the Responsiveness Summary,
.which is found in Appendix A of this Record of Decision.. .'
This decision document presents the selected ground water
remedial action for the Yellow Water Road Site, in Baldwin, Duval
County, Florida, chosen in e-cordance with CERCLA, as amended by
SARA, and, to the extent practicable, the National Contingency
Plan (NCP). The decision for this Site is based on the
administrative record.
4.0
SCODe and Role of Ooerable Unit
..' .
As with many Superfund sites, the problems at the Yellow Water
Road Site are complex. The initial Remedial Investigation (RI)
identified the areas of soil contamination to be remediated but
was ,not of sufficient scope to ,fully characterize the extent of
ground water contamination. Additional data was required to
determine if migration of PCB-contaminated ground water had
occurred and to further evaluate treatment alternatives for the
PCB-contaminated ground water. As a result, EPA decided to
implement cleanup of ~he site in two operable units. Operable
Unit One (OUl), which is addressed in the Record of Decision
(ROD) dated September 28, 1990, eliminates the potential for
direct exposure to the contaminated soils and sediments.
Operable Unit Two (OU2) addresses the potential for direct
consumption of contaminated ground water. .
The second OU remedy authorized by this ROD addresses the
contaminated ground water in the limestone unit (surficial
aquifer). The principal threat posed to human health and the
environment stems from the potential future ingestion of ground
water from source area wells by local residents. Also, there is
a threat of contaminant migration in both aquifers to areas
located off-site.
This is the second and final planned remedial action for this
site. The objectives for the re~edy are to prevent the near-term
and future exposure of human receptors to contaminated ground
water both on and off-Site, and to monitor ground water in a
manner that will verify the effectiveness of the selected rem~dy.
This ROD has been prepared to summarize the remedial alternative
selection process and to present the selected remedial
alternative, for the second operable unit.
9
-------
5.0
5.1
SmmnATy of Site Characteristics
Geology
The Yellow Water Road Site is underlain by approximately 75 feet
of unconsolidated sand, silt, and clay. These strata rest on an
approximately 20-foot-thick layer of coquina limestone and
calcareous sandstone. .~his unit is underlain by the Hawthorn
Formation, a thick sequence of silty clay, clayey sand, and
sandy limestone. Four stratigraphic units were encountered
during the RI. These units are detailed, sequentially, as
follows:
i) upper sand, .25 to 35 feet thick;
ii) clay, 5 to 15 feet thick;
iii) lower sand, 25 to 35 feet thick; and
iv)
limestone, 10 to 20 feet thick.
The upper sand consists of light brown to brown, fine, silty sand
and fine sand. Thin, discontinuous, sandy clay and clay layers
are also present in this unit. The clay unit, from five to 15
feet thick, has a high plasticity and is inferred to be
continuous across the site. Hydrometer analyses performed on
this unit show that the clay contains from 25 to 47 percent silt
and very fine sand. The lower sand consists of fine to medium
sand and silty sand with gravelly and shelly sand layers. The
lowermost unit encountered is a poorly indurated, medium to
coarse coquina and brown, poorly cemented, fine to medium
grained, calcareous sandstone. Figures 5.1.1 through 5.1.3
illustrate geologic cross sections at the Site.
5.2
Hydrogeology
The Yellow Water Road Site is underlain by two major aquifer
systems, the shallow aquifer and the Floridan aquifer systems.
These aquifers are separated by low permeability sections of the
Hawthorn Formation.
The shallow aquifer system consists of sands, limestone, and
shell beds. Water from the shallow aquifer is considered of
adequate quality for domestic use. Recharge of the shallow
aquifer is chiefly by rainfall. 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.
At the Yellow Water Road Site, the shallow aquifer system
consists of an upper sand and a lower sand and limestone unit
(identified in the RI Report as the upper and lower water table
units respectively). The upper water table unit is separated
from the lower water table unit by a clay layer. Most
10
-------
......
......
./
..- ,
-
, , -.J l~J -'1
1---
k ''l
' n '/
' ' \ ,----. -\ /
/ ~~"../'';;, /
1 '
.I
.It N5I. tIf'm5
~I
/
,
200ft
I
r
'-"'-~'~~
DOl!( -
o 100
I
"'~!~~
, ''''''...
DOI'I IIOOOS
/ .r'
P --/.;.:. J( :!-
- -------~--~:: ~:~~~ '.~~:::::::._~--~:=---
~-
, "
'" ",
~,.,,
-------
100
90
I!O
70
...1
U1
:::E 60
«
~ t---
W
tJ W 50
LL
?;
Z 4()
a
f=
«
> .~
W
.1
W
20
10
o
-10
A
um..
"'''''''
I I I
..~
SlL TY SAND
SAND
- - ---------- -
ClA Y
ClA ~Y SAND
SAND
-. ~~(~TCWE
SANDS TONE
250
WJENQ
WlI!
~}AN[) P,I,CIo, IN 11 RVAI
CRA
71~1! 10 7//04//19 9 0 (~ 7)
---~----
--- ----
----. ---
500
-
- - --.--
150
A'
um..
...
I I I
~~~
-------
100 -
90.
60-
70 --
~
-'
VI
:::I 60-
«
.--
"-' W
W w 50
lA.
Z
,;::.
Z 40
o
1=
«
> jO
~
w
20-
10
0-
-10 -
WlEMQ
'ltfU
B
Umc
NNN
I I I
;s;s~
. ----- -~------
SlL TY SAND
SAND
-- ~.
CLAY
j!?UC umc
1"1'1 fDCUO
~;s;s III
~ ~n
SLIGHTly.!
SlL "
SAND
SAND
- .. ClA Y
IN TF:RBE£?'!!l!
. _..--~-
.- -- ... ".+.-.- .---.----..------
SlL TY SAND
SAND
SlL TY SAND
---. ..- ----.. -'"
lIUES TONE
SAND
SAND PACK I/llrHVAl
CRA
21~8-10-27 /04/89"9-0 (X- j)
-. ". ---.-
SANOY lL T""
2~0
__h --'---'---..
SlIGHn. Y
SlL TY SAND
--'--.
U---_"h- h____n_.
CLAY
.------.- -----.
--- .
SlL TY SAND
~-
SAND
.::.:DA y
SfL TY SAND
..--'- -- .."- .-..
'.
lIUES TONE
UARL
~
1~0
--.. .----.--
!. "
~ '\ r
; " '.
~~~
I I I
.;s~
..-. . .--.---.... "..
SliGH n. Y
SlL TY SAND
-----.....
. _~LA ~--_., -;-
. ~. t
- ~.
SlL TY SAND' " .
SAND'
.- . - - ---....--
'-,
LIMESTONE
,-
.1 .
,
1000 - . "~O
DISTANCE- (IN FEET) -
"
- .-.-. --" .
.---....---..-
... --.. -0.- .. .---".. -.--.
B'
cum
'j "j ..
....
~
.0'. ._.. .-
SlL TY SAND
, .
UPPER SAND UNIT'
SAND
CLAY
-- - '. (;i.jfr=l!N!.r- --
".
... .... _0.___--
SlL TY.
CI A ~Y SAND
LOlleR SAND 'UNIT
. SAND
-.. .-----:-
. :
. ,
.-
SAND Y SlL T
UUESTONE
SANDSTONE
'. d'!
~ .". 1
LIMESTONE UNIT
,-
1.
I~ t'
17~ .
. ~; '.
. 71""1
n~o
l~()()
Figure 5.1.)
GEOLOGIC CROSS-SECTION B-B'
YELLOW WATER ROAD SITE
Baldwin, Rorida
-------
water-supply wells in the Yellow Water Road area are
approximately 80 to 150-feet deep and draw water from the lower
water table unit of the shallow aquifer system.
Ground-water flow in both the upper sand and the lower sand and
limestone unit of the shallow aquifer system is from east to
west. The horizontal hydraulic gradient ranges from 0.001 to
0.0006. The gradient decreases to the west toward a swampy area
on the west side of the Site. The ground-water velocity was
calculated as 4.6 ft/year within the upper sand and 4.7 ft/year
within the lower sand and limestone unit. There are no
ground-water discharge areas on the Site or immediately
downgradient from the Site.
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/ and recharge to this aquifer through the overlying Hawthorn
Formation is considered to be very low. Water yield from wells
in the Floridan Aquifer varies depending on depth/ artesian
pressure, and transmissivity. However/ wells two to six inches
in diameter can yield as much as 500 gpm.
5.3 Sampling Results
Twenty-eight monitoring wells have been installed at the Site in
both the upper sand and the lower sand and limestone unit to
determine the extent of PCB contamination (Figure 5.3.1
illustrates well locations). Seven ground-water monitoring well
nests (MW-1 - MW-7), comprised of three wells per nest, and
individual monitoring well, MW-8A, were installed during the
Operable Unit 1 (OU1) RI field work. Additional monitoring well
nests MW-9 and MW-10, consisting of two wells per nest, and
individual monitoring well MW-8B were constructed and developed
during the first phase of the Operable Unit 2 (OU2) field work.
The final monitoring well, MW-11A, was constructed during the
second and final phase of the OU2 field work.
Monitoring wells were constructed to depths that correspond with
the three stratigraphic units located at the Site. These are as
follows:
o Upper Sand Water Table Unit ("A" wells);
o Lower Sand Water Table Unit ("B" wells); and
o Limestone Unit ("C" wells).
Two rounds of ground water samples, Phases I and II, were
collected during the initial OU1 RI field work from well nests
14
-------
...
---
\J1
I."'" ~
... -6... .
"ONII uRlNG WI It I OCA liON
Figure 5.3.J
L LOCA TlONS
t.AONITORINGwmR ROAD 51.1£
YELLOW Baldwin, nOr/do
CRA I (P- u)
71 ~8 gO 1 ~/OI/gJ - 13-
-------
MW-1 to MW-6. A subsequent third and fourth round of samples,
Phases III and IV, were collected in February and March 1990,
respectively. Phase III and IV sampling was limited to
downgradient and source area wells. Another sampling event took
place during the first phase of OU2 RI field work in February
1991 in which selected existing and all newly installed
monitoring wells were sampled. The final OU2 sampling event
occurred in October 1991 and involved sampling of wells MW-6A,
MW-7A, and the newly installed MW-11A. These last two sampling
events were labeled the "Supplemental Groundwater Investigation
Sampling Rounds" in the OU2 RI/FS Reports.
During sampling phases I through IV, the samples were analyzed
for the complete Target Compound and Analyte Lists (TCL/TAL),
which includes analysis for volatile organic compounds,
base/neutrals (B/Ns), inorganic compounds and polychlorinated
biphenyls (PCBs). A summary of contaminant prevalence within the
ground water samples of Phases I, II, III, and IV is presented in
Table 5.3.1. Based on the results of the initial ground-water
sampling rounds, EPA was able to determine the following:
1. No significant ground water VOC contamination exists at
the Site;
2. No samples contained unqualified B/Ns above acceptable
limits (as determined from Phase I monitoring results),
thus B/Ns were omitted from subsequent monitoring;
3. No Inorganics were detected above acceptable levels (as
determined from Phase I monitoring results); therefore,
Inorganics were dismissed as chemicals of concern; and
4. PCBs were detected in the ground water during Phases I,
II, III and IV and represent the only chemical of concern
at the Site (Ground water PCB concentrations found during
all sampling rounds are shown in Figures 5.3.2 and 5.3.3).
The results of the Phase I through IV ground-water sampling
events prompted EPA to initiate the OU2 Supplemental Groundwater
Investigation in order to refine the vertical and areal limits of
the PCB plume thought to exist at the Site. The ground-water
samples obtained during this subsequent investigation were
analyzed solely for PCBs since it was determined that no other
chemicals posed a significant threat to ground water quality.
During the OU2 Supplemental Groundwater Investigation, it was
determined that PCB contamination of the Upper Water Table Unit
("A" wells) is confined to a small "source" area located within
Site boundaries. Monitoring data confirm that the Lower Water
Table Unit has been marginally impacted by PCBs in the source
area (contamination is limited to MW-6B and MW-7B). There is no
indication of contaminant migration in the Lower Water Table Unit
to areas adjacent to, or downgradient of, the source area. In
fact, of all the wells sampled, PCBs were detected above the
16
-------
.-
.......
Based on the number of occurrences of this analyte in investigative samples at concentrations above the practical quantitation limit
(PQl) without associated method blank contamination.
Mean calculated using only concentrations above I'QL.
MCL = Promulgated Maximum Contaminant Level
EP A IRIS Database 1/1/90.
PDWS = Promulgated Primary Drinking Water Standard .
from Horida Ground Water Guidance Concentrations, Horida Dcpar~ntof Environmental Regulation, February 1989.
NA = Not Available. .
Standard is based on total trihalomethancs
Ft.-dcral MCL for polychlorinated biphenyls is based on 0.5 IJg/ L total PCBs.
Table 5.3.1
CONTAMINANT PREVALENCE SUMMARY
GROUNDWATER SAMPLES
"PHASES I, II, III AND IV"
Compound
DdedionU'
Frequency
Melin Concentratiun
Detected (mgIL,
Anll'yte Concentrlltion ..
Rllnge (mglU
1,1,1- Trichloroethane
1,1-Dichloroethene
1,1-Dichloroethane
2-Butanone
Acetone
Aroclor-1248
Aroclor-1254
Aroclor-1260
Benzene
Carbon Disulfide
Chlorobenzene
Chloroform
Methylene Chloride
Tetrachloroethene
Toluene
Trichloroethene
1 of 61
1 of 61
1 of 61
2 of 61
13 of 61
11 of 74
3 of 74
11 of 74
1 of 61
1 of 61
2 of 61
17 of 61
4 of 61
80f61
1 of 61
1 of 61
ND - .00092 :
ND - .0037
ND - .0037
.019 - .043
ND-.19 .
ND - .0095 ':
ND - .0043
ND - .0053
ND - .016
ND - ..00053
NO- .0023
ND - .0038
NO - .016
NO- .001
NO - .0093 .
NO - .025
.0019
. .0016
.0054
.0008
.031
.0188
.0050
.0031
.0036
(1)
(2)
(3)
(4)
(5)
(6)
(7)
Feder'" Floridll
MCL (JJ PDWS (4'
(mglL) (mglU
0.2 0.2
.007 .007
NA(5) NA
NA NA
0.0005(7) NA
0.0005(7) NA
0.0005(7) NA
.005 .001
NA NA
0.4 NA
NA .1(6)
NA NA
0.005 .003
1.0 NA
.005 .003
-------
r'
" l. '.
1,..,
co
"""'-
{)
. \
. '
" ~.:
CRA
'/i7,M H'
FOH tllOWUP Of
TI11S ARE A, SH
FlGUH£ 2,1,9
.
.
..."
.0'"''
Ii
~'
\-~'~1
Ut H~ '8OUU'S
\
I
.
.
.~.
~~--::-::-
.'
~'.~~
----,
"'. .
......
IIOOOS
\' ~I.~
.""
~
"." b~ .
"ONI1 01<\"(; WI II I OC ~ liON
HOUND ONE PlU CONCENIH~nON (mg/l 'Ol~l PCB'.)
"(lINO fWO ~lU CONCIN'H~nON (mg/L rol~1 PC/f.)
I>f IlCil U A I II <;5 THAN IIIl 01" C flON 11..11
RUUN!J fliRtl Pl~ CONLlNlkAllON (mC)/l 101"1 PUt'S)
~OU'-W f01l1-l tJ(t:f (ONCtNlkAHON (rtlC)/1 101"1 PCtf.)
(ONl y ~(JlJ~U ANU UU'lft.jL.HAUHHI M(15)
~\)i-'P\~-"tNI"\ l.HO\JHI>W"IIH \NJ\".)"(~A"Uti <109'\ PC,,',) fl8MUAHY 11)9' WONllo.tlNG t >A'~1
IJtjlii [ff.UI '5
')IJI'I'I t loA' tllA.1 (~()utm'N'" I. lot IN''''' ') IIGAlle)N (mCiJ/1 pur a) DC 1001 R 19V1 "()NIIQt.tltl(~ I ""'4 r
"'UJ - 1111 {OW>Ou~.o "...... -"I '"0 tOIl ~r ..ul ~ 11(~ftU
ntt ...5~t"dIU Uf IIC~ .M' IS"" Isnw...no WAH''''
()..I( 10 ,.UILltHCI <» HU~"" isr"8lt!lttfOI'YartI'
( ool't)
'----1'~
( !.Juua../
~ LIlJit" 1
00'.
"'0 - NOr OI! IlcnlJ
1'111 U,t,IAltASI ION Ut I\LnotoIl"I~)
I', ()1 'y.'
I \ I Ii' ';0)
.
J
u
~r
'f' -.
'"
.
. :
11)11
100ft
....J
.
I-U
'" ~'.
~.~
.
.,
...,.
"'''''»
~~-
- . '- ,-
~-
~~ ----~- "-
"............. .~~ -~-...,....-
ooous
~,.- ,
;'
I
.;-
Figure 5.1.2
MUNITORING WELL PCB CONCENTRA nONS
YELLOW WATER ROAD SITE
Baldwin, Aorida
-------
,
/ - "'\.,
! ~ 10011 "'"
'. , , ~~-~A~~
]" , , " , '. , '';',A,-'" 'N
\J7' , , , '., -~~'~',,,, '" ,
'.\1 ~~~ ~;"~~:"c:::=:-, ,'" ':-:.";:,;..N
' """ ',.., 'M' '. .' ,. ---- / .,. '" " ( .. ,.".
.- ';;; "..' . . ~ -.. . .. :, " : ' -- , . 'I ~ "
"'L" IotW-211 :11..,..).. ~W"C lot':., '2,; '. ~ 4' '. /'" ''':'' .
'::'". . .~:"-:~--::--,. -- :::.:: ."m.. '.., ,::, ,: , ,: b~ 00 0 ~ ( ..
_. ~~!=----" 1;;:'-:'IotW-?Af \"':':1' '.n'r'"],. '. . ~..~--.-._'. ..>(.. 0 00., (
"'':'' '---,.:". ".. ,..,- ~:;;'1 ~ ~;;":. , " ' '0' . " }
'.,',..". ':wlii:e...,..6A' ':-" 0. \
'. """. 11..'1.. . ,':;;" .. " ,', 000' f" ,'11 lit'
' . -, ',:=, ", " :J 0 ;:, .
QW';;'~.'l'~r- ", -:"~~~;~-:;"'j' .'~.~ 0 ..' f'. " ./ff ' '
,-, ': :, --, "" '> " I
' ' "', , .~~, ,--.:.., - 'S:!'" "'-
"-.£ V""""""... 'r',,- '",,,,
I ,,~ ..
, .
/
k/
.,/
:y ') 3.'3
"""" ' ".. Fi.u re ..
"'-', " . " nONS
'\ ( "-,-- '-" CONC£NTRA LLS
I WEll PCB RADIENT WE
MONITORI~~A AND OO~2 TER ROAD Sl~
SOURCE A YELl.OW Baldwin, Flan
, '
'.
.-
"?
o
...) ,
f::~~ .
11...48 .
. . ".-4"
1I..4C. .'"
,II) I""'~
110,\ '.
.r"J
,./
l'
'0.
IUIII
1"8.:
..,
II. JB
. .11.' JA
.,.
f:~~
..,
o
..."...,.
. .
..
,~~.. ~~' "
'----'';::. =.0:: ::~~ :::: :::]:~ l'~' ~~
.,. ,-~, """.~ 'm, , .
au" PC8 CON . I[C nON LOIot' .
. '00"' ~ ~ rn.. ,~ ~ , ",. ~ .J, .' ,
''"'''I OIIlCIIU AII[ II CONCINIRATION (m~/ 10lAI PClf.) . ONIIOHING [\1£;',
,-, ., "'~A ,~, .
ROUND It. . ONCININA"ON liS) '.) IIHRuANr ON NI~"S
,-, ~ ~, ~~"' . , ern. "".." ,,"..
-" .u - - mo.".. ,". ~,."",,... .. .", .~"~,,
- ,~, ~ '"",",..". ~"",.".,,~, ",'" ",w'" .
~UPPl t '-41 N t/~:, ILNIU I'CU CO.. S II... IIUN (",~/,
,-,~, ,"'""., , ,..",,,," ,
. lA, (;HOU" 0
~I'I"I"IIII 810' .')1 18 1I<~A.h"
. ,-- - -, -:.::~:~ - :~Z,::...... .
..I" - h. 'SOCIAnu 1811~ .."IINC "'" , IS)
~~ ~o "<"18"" ''''''''0< 18 ,,1',1")'1.' t.
I;;
Ot,,!If
....,.
DO.."
OOODS
-'
"'I~
.!.au.
-------
accepted federal Maximum Contaminant Level (MCL) of 0.5 parts per
million (ppb) on a consistent basis in only four monitoring
wells, MW-6A, MW-6B, MW-7A and MW-7B. Figure 5.3.3 shows the PCB
conc~ntrations in these wells over all six ground-water
monitoring rounds.
Based on the non-detect sampling results from the newest well,
MW-11A, which is located 20 feet downgradient of MW-6A, it was
demonstrated that PCBs within the aquifer have not migrated
downgradient from MW-6A. consequently, this data, in conjunction
with the filtered/unfiltered PCB analyses from the first sampling
rounds, indicate that a continuous PCB plume is not present
between MW-6A and MW-7A. The monitoring data demonstrate that
PCB migration is being effectively attenuated, confining
ground-water contamination to the source area. .
6.0
6.1
SUDIIDarv of Site Risks
Overall Risk Assessment Snmm...ry
The assessment of the risk posed by the Yellow Water Road Site
was evaluated in a site specific risk assessment dated August
1990 (See Section 6.0 of the OUI RI Report and Section 2.3 of the
OUI and OU2 FS Reports). This assessment, which was compiled
prior to the 1989 guidance (EPA/540/1-89/002), examined the
amount, concentration, properties, and environmental fate and
transport of the PCBs found in the ground water at the Site, and
the populations and environments potentially at risk. The risks
associated with the Yellow Water Road site were calculated based
on current and future exposure scenarios. The numerical cancer
risk values are theoretical quantifications of the excess
lifetime cancer risk, that is, the increased probability of
contracting cancer as a result of exposure to site wastes,
compared to the probability if no exposure occurred. For
example, a 10-6 excess cancer risk represents an exposure that
could result in one extra cancer case per million people exposed.
The 10-6 risk level is considered the goal for remediation at
Superfund sites under the National Contingency Plan, 40 CFR
300.430(e) (2) (i) (A) (2).
Though there are currently no complete exposure pathways, the
predicted risk due to future ingestion of ground water (potential
on-site residence) was 3.1 x 10-3, which is unacceptable when
compared to the upper boundary of the risk range (i x 10-4).
However, ground water sampling indicates that the plume is
currently limited to the former operations area within the Yellow
Water Road property boundary. Also, the closest residential area
is approximately one half mile northwest of the site and is
hydrogeologically upgradient. Downgradient from the site there
are no residential wells within a 1.5 mile radius area which are
used to obtain water from the surficial or Floridan water bearing
zones. Ground water modeling projections indicate that
concentrations in the ground water will be below the limit of
20
-------
detection prior to' reaching any off-site discharge points or ,:
receptors. ,Overall, the Remedial Investigation revealed that the
Site!s ground water does not pose an imminent or future possible
threat to off-Site residents.
6.1.1
Identification of Contaminants of Concern
In choosing the contaminants of concern for ground water,
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/540/1-86/0FC, OSWER Directive 9285.,4-1, .
December 1989). ," , .
As indicated by the sampling results in Section 5.0, PCB
compounds were found to be the primary contaminant of concern for
ground water at the Site., All other contaminants ~iscussed
previously were discounted as contaminants of concern for various.
reasons .(i.e., concentrations,of'.contaminants that are similar to
area/regional background: concentr~tion and thus are not
considered site-related, concentrations that are 'of low
prevalence(occurrence, .or concentrations ~hat are laboratory
analysis, related) .'. . .
The Site's impacts on ground water were characterized using data
from Phase III and Phase IV ground water .samplingand analysis
results. Of the ground water data in the two phases; data
collected from Sectors 1 (area within the property fence) and 2
(area downgradientof Sector 1) were used to characterize the
Site's risks. The exposure point concentrations used in
characterizing the risks due to groundwater ingestion were 6.7
ug/L (Phase III: MW-6), 14 ug/L (Phase IV: MW-6), 3.8 ug/L (Phase
III: MW-7), 1.9 ug/L (Phase IV: MW-7), and 1.8 ug/L (Phase IV:
MW-8). See Figures 5.3.2 and 5.3.3.
6.1.2
Fate and Transport Analysis
Site soils that are contaminated with PCBs will be remediated,
thus removing the primary source for cross-medial PCB
transport/contamination. However, a discussion of the fate and
transport possibilities of site contaminants is useful in
understanding the current site, contaminant migration potential.
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
21.
-------
water flow. The sorptive nature of PCBs will hinder migration
into ground water. Thus concentrations resulting from soil
sources will not contribute to high PCB ground water
concentrations.
6.2
Human Health Risks
6.2.1
Exposure Assessment Summary
An Exposure Assessment is an estimation of the magnitude,
frequency, duration, and routes of exposure to humans. Exposure
to the PCB contaminated ground water beneath the Yellow Water
Road Superfund Site was evaluated based on current and future use
scenarios. Based on the OU2 RI results, the only source of
potential PCB exposure at the Site (including the adjacent
landowners) is the surficial and Floridan aquifers beneath the
site. Evaluation of all other media (soil, surface water, air)
was addressed in the September 1990 Record of Decision.
In the original Risk Assessment, potential human exposures to
Site-related contaminants (PCBs) by two main pathways were
evaluated. Potential points of exposure considered were
inhalation or direct contact with surface 80ils and ingestion of
contaminated ground water. The first exposure scenario was
addressed in the OUI ROD; therefore the following discussion will
focus 801ely on the ground water pathway.
Under current land use conditions, no exposure to humans is
occurring due to incomplete exposure pathways.
To address the future use scenario, conservative exposure
assumptions were developed by EPA. In conducting the exposure
assessment, the focus was on the health effects that could result
from ingestion of PCB-contaminated ground water by an adult
representing the highest potentially exposed receptor. The
assessment was limited to long term daily exposure, since the
Site's future plausible use is residential. The exposure
assumptions included the ingestion of two liters of water per
day, 365 days per year, for 70 years from a well currently
containing the contaminant concentration described earlier
herein. It is noteworthy to consider that as a result of
dissipation and natural attenuation mechanisms, PCB levels in
site wells have declined.
Considering both the present time and the future, the only
complete ground water exposure pathway for the Yellow Water Road
Site is the future residential ingestion scenario.
6.2.2
Toxicity Assessment Smmn.ary
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to
22
-------
chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking
water) can be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g., to account for the use of animal
data to predict effects on humans). These uncertainty factors
help to ensure that the RfDs will not underestimate the potential
for adverse noncarcinogenic effects to occur.
PCB exposure can result in mild reversible injuries to skin and
organ systems, while higher concentrations can result in
carcinogenesis. Noncarcinogenic toxicity includes irritations to
the skin, nose, and lungs, which was documented when workers were
exposed to PCBs. Developmentally, young children of women who
eat foods that contain high levels of PCBs, such as fish, before
and during their pregnancy, might have trouble learning. EPA has
not established an oral RfD nor inhalation RfD for any of the
PCBs.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day)"1,
are multiplied by the estimated intake of a potential carcinogen
in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The term "upper bound" reflects the conservative estimate
of the risks calculated from the CPFs. Use of this approach
makes underestimation of the actual cancer risks highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.
From a carcinogenic standpoint, there is adequate evidence for
the PCBs to be classified B2 "Probable Human Carcinogen". 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 EPA oral CPF for PCBs is 7.7 X 10'°. Numerous
studies support this finding. Based on the animal toxicological
studies, PCBs in the diet were found to induce liver tumors.
Occupational exposures have induced melanoma cancers as reported
when a small group of male exposed workers in a capacitor
manufacturing plant showed an excess of all cancers. Primarily,
the excess was manifested in the digestive system and the
lymphatic tissues.
23
-------
6.2.3
Risk Characterization Summary
Potential human exposure to site-related contaminants (PCBs) was
evaluated via the ground water ingestion pathway. Potential
ground water exposure was estimated as a future scenario using
the conservative assumptions of site development and exposures in
the absence of further remedial measures.
Excess lifetime cancer risks are determined by multiplying the
intake level by the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e. g., 1 X 10-6 or 1E-6). An excess lifetime cancer risk of 1 x
10-6 indicates that as a plausible upper bound, an individual has
a one in one million chance of developing cancer as a result of
site-related exposure to a carcinogen over a 70 year lifetime
under the specific exposure conditions at a site. The Agency
considers individual excess cancer risks in the range of 10-4 to
10-6 as protective; however, the 10-6 risk level is generally used
as the point of departure for setting cleanup levels at Superfund
sites. Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ) (or the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the
contaminant's reference dose). By adding the Hqs for all
contaminants within a medium or across all media to which a given
population may reasonably be exposed, the Hazard Index (HI) can
be generated. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
Residential development of the on-site secure area as well as
downgradient areas was found to pose unacceptable additional
lifetime cancer risks. For off-Site development, the risk due to
ingestion of ground water from MW-7 in Phases III and IV were 8.4
x 10-4 and 4.2 X 10-4 respectively. Similarly, Phase IV sampling
of MW-8 showed an overall risk of 4.0 x 10-4. Currently, the
downgradient wells do not exhibit PCB contamination. MW-6, which
was located in the on-site fenced area; revealed risks of 1.5 x
10-3 and 3.1 X 10-3 as calculated from Phases III and IV PCB
concentrations respectively.
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.
6.3
Environmental Risks
The Risk Assessment also surveyed and assessed the Site's effects
on the environment. The site area is composed of mixed
vegetation ranging from grassland and marshy areas to densely
treed regions. As previously outlined, PCBs are the primary
contaminant of concern for Yellow Water Road. Also, the ground
24
-------
water medium is .the only medium of concern in this ROD, as
previously stated.
Currently~ there have not been any detectable Site-associated
effects on biolife in the vicinity of the site. One primary
pathway for ground water exposure would involve discharges into
wetlands. Numerous wetland areas are present to the north (600
feet), west (2000 feet), and east (800 feet). Ground water
discharge to these wetlands occurs in the area. Ground water .:'
migration is to the west at a velocity of approximately 4.6 to
4.7 feet per year. PCB migration with ground water is estimated
to be a fraction of a foot per year thus migration of the low on-
Site concentrations to off-Site wetland areas would take 4,800
years. Such migration would be contingent upon the presence of a
substa~tial source in excess of all detected concentrations. .
.....
Future potential ground water associated exposure might involve
human exposure pathways that can also be applied to terrestrial
animal populations. Thus human activity must oc~ur in order to
make ground water available for consumption (Le., watering lawns
with contaminated ground water, filling bird baths, etc.). Due
to the lipophilic properties of PCBs, mammals and insects would
readily absorb PCBs directly through the skin or cuticle. Thus,
such a onsite residential-based apprQach predicts that PCB
bioaccum~lation would occur with appropriate human intervention.
. .
Generally, 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.
There are numerous endangered or threatened species associated
with the Site's county as seen in Table 6.3.1. However none of
these are currently believed to have habitats on-Site. There are
also no known critical habitats associated with the Site area.
Overall, there are no complete pathways for exposure of critical
species to site-related ground water sources.
25
-------
Table 6.3.1
Endanaered and/or Threatened Soecies for Duval County Florida
Mammals:
Florida Panther (Felis concolor)Endangered
Birds:
Bald Eagle (Haliaeetus leucocephalus)Endangered
Arctic Peregrine Falcon (Falco peregrinus)Threatened
Bachman's Warbler (Vermivora bachmanii)Endangered
Ivory-billed Woodpecker (Campephilus principalis)Endangered
Red-cockaded Woodpecker (Picoides borealis)Endangered
Reptiles:
Eastern Indigo Snake (Drymarchon corais)Threatened
7.0
DescriDtion of Ground Water Remedial Alternatives
The OU2 Feasibility Study report presents the results of a
detailed analysis conducted on five potential ground water
remedial action alternatives for the Yellow Water Road Site.
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 - Institutional Controls and Monitoring
Alternative 3 - Filtration/Carbon Adsorption (GAC)
Alternative 4 - Filtration/UV Oxidation
Alternative 5 - Contingent Filtration/Carbon
Adsorption (GAC)
7.1
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/monitor the migration of ground water contamination or to
restrict access to ground water contamination. This alternative
serves as a baseline with which other alternatives can be
compared. PCBs are stable in the environment and only slow
26
-------
degradation would be expected due to natural causes.
Additionally, PCBs naturally tend to sorb to soil particles with
limited mobility in a ground water environment.
Ground water PCB concentrations range from below detection limit
to 29.4 ug/L. The corresponding additional cancer risk
associated with these concentrations is above the guideline risk
range of 10'* to 10"6 within and in close proximity to the former
operational area. However, as discussed in Subsection 2.2.5.2 of
the FS Report, using the velocity calculated for aqueous PCBs
(considering adsorption and advection) of 3.3 x 10"^ ft/year, the
time required for PCBs to migrate to the nearest downgradient
receptor would be in excess of 100,000 years;
This alternative will not comply with the preference for
treatment pursuant to SARA; however, through natural processes,
such as dispersion and attenuation, it would eventually achieve
compliance with federal MCLs over a period of time that is in
excess of 1,000 years. This alternative will not prevent the
potential migration of PCBs off-site via sediment transport or
leaching of PCBs into the upper and lower water table units. In
fact, this alternative will allow for the continued risk of
exposure to contaminated ground water should someone install a
potable water supply well directly in the source area.
Since no action is required, this alternative is easily
implemented with no associated costs.
7.2 Alternative 2 - Institutional Controls and Monitoring
This alternative includes the implementation of institutional
controls and the initiation of a long-term ground water
monitoring program to prevent exposure of human health and the
environment to PCB-contaminated ground water. As with the no
action alternative, this alternative relies on natural
attenuation processes such as dispersion for the reduction of PCB
concentrations in the ground water. In addition, this
alternative involves the construction of two additional ground
water monitoring wells (MW-12A and MW-12B) downgradient of the
source area and the construction of a security fence encircling
all source wells to ensure restricted access to the public.
The three readily available methods that will be used for
restricting access to contaminated ground water are:
- deed restrictions;
zoning controls; and
- water supply well permitting prohibitions.
A deed restriction is a negotiated addendum to an existing deed
which, until removed, indicates that the ground water resource
27
-------
below the property is not considered safe for potable or other
uses. This notifies the existing property owner and any
subsequent owners of the ground water condition during the time
that the aquifer is not usable.
Currently, Duval County has indicated that zoning ordinances are
in effect in the vicinity of the Yellow Water Road site. These
ordinances restrict the development of housing and ground water
withdrawals by potent{al ground water users in the area using the
zoning controls. Additionally, there currently exists a formal
well permitting process for the installation of all potable water
wells within the jurisdiction of the City of Jacksonville's
Department of Health, Welfare, and Bio-Environmental Services
(BESD), in which the Yellow Water Road Site is located. Also,
the St. John's River Water Management District requires a well
permit under certain conditions: If the well is equal to or
greater than six inches in diameter, and if the well is to serve
more than one household. At present, there are no existing water
s.upply wells within one mile downgradient from the Site.
Further controls are in place to prevent the installation of
potable water wells in areas of known contamination. According
to Florida State Regulation 17-524-, as set out in the Florida
Administrative Code, Chapter 17-524, the installation of any
potable water well into contaminated aquifers is prohibited.
These institutional controls can be readily implemented and
coordinated through BESD and the St. John's River Water.
Management District. The imposition of institutional controls
would be through a Site custodian, deed restrictions, and either
of the two identified local agencies. These controls would have
to remain in effect until PCB ground water concentrations
declined to acceptable levels, which EPA estimates is in excess
of 1,000 years.
In addition to the institutional controls, this alternative
includes the initiation of a long-term ground water monitoring
program to monitor the PCB concentrations in the ground water
beneath and in close proximity to the Site. The ground water
monitoring program will consist of annual monitoring of source
area wells (Monitoring well nests MW-6, MW-7, and MW-8) and at
least one upgradient well (MW-IA). In addition, future point of
compliance (POC) wells (MW-9 cluster and the newly installed MW-
12 cluster) would be sampled quarterly. This monitoring
frequency will be maintained for a period of two years. After
this two-year period, EPA will evaluate the monitoring results,
possibly reducing the monitoring frequency to semi-annual. After
EPA's five-year review, if historical data indicates stable or
Non-Detect PCB concentrations, EPA will evaluate the use of an
even less frequent monitoring schedule (annual) for these POC
well nests. All collected ground water samples will be analyzed
for PCBs.
This alternative is administratively feasible. The required
equipment, labor and material are readily available. The
28
-------
estimated timeframe to complete theconstruction.of 'the
additional moni.toring wells is one .week.' . ,.
This alternative will not comply'with the treatment preference
stated in SARA, but would represent a remedy through which
eventual compliance with federal MCLs will be achieved over a
period of time in excess of 1,000 years. This alternative will
eventually be compliant with all existing chemical-specific
Applicable or Relevant and Appropriate Requirements (ARARs), as
detailed in Table 8.2.1, due to the natural processes (dispersion
and attenuation) that will serve to decrease ground water PCB
. concentrations with time. Al ternati ve ':2 will meet the .
requirements of all action-specific and location-specific ARARs,
.as. app~icable (See Table 8.2.1). . . - .
The anticipated capital costs for this alternative would 'be
$30,875, with a present worth long-term O&M cost of $345,870.
The estimated total cost would be $376,745. It is noted that for
purposes of comparability and practicality, capital and present
worth costs were based on the installation of two additional
monitoring wells. The actual number and placement .of any
additional wells to be instaJ.led. ,will be determined during
Remedial Design. If EPAdeterminesthat more than the two.wells
specified above will be needed, the cost will increase
accor~ingly. Also, the present worth costs were estimated for a
30-year period; monitoring would need to be maintained for in .
excess of 1,000 years to attain a 0.5 ppb cleanup level.::"'. .',"'.--
naturally.
, ~ ...... .
.. ... ~
7.3
Alternative 3 -.Piltration/Carbon Adsorption' (GAc)
Maior Components of Remedial Alternative:
This alternative utilizes a ground water extraction system with
extracted ground water being treated by filtration and granular
activated carbon (GAC). It is estimated that a filtration system
would remove 70-90 percent of the suspended solids from the
extracted ground water. The removal of PCBs will occur in a
parallel fashion with removal of suspended solids and sediments.
Any remaining adsorbed PCBs and the low fraction of dissolved
PCBs will be removed through the final polishing by a GAC.
The major components of this alternative include:
a)
the implementation of institutional controls as
described under Alternative 2:
the construction of two additional ground water
monitoring wells (MW-12A and MW-12B) downgradient of
the former operational area:
b)
29
-------
c)
the installation of a security fence around all source
area wells (Monitoring well nests MW-6, MW-7, and
MW-8);
d)
the design and construction of ground water extraction
wells in both the Upper and Lower Sand Units, located
near the western boundary of the former operational
area of the Site;
e) the installation of a ground water pumping system;
f) the installation of a ground water filtration system;
g) the installation of a GAC treatment system;
h) the installation of a treated effluent discharge
system;
i)
the transportation and disposal of the GAC and
filtration waste to a TSCA-compliant landfill or
incinerator on an as-required basis; and
the implementation of a long-term ground water
monitoring program, as described under Alternative 2,
- to verify the effectiveness of the selected remedy.
Manaaement of Residuals:
j )
The residual filtrate and GAC waste generated from the treatment
system will be transported for disposal to a TSCA-compliant
landfill or incinerator on an as-required basis. A comprehensive
off-Site Emergency Contingency Plan (as part of a properly
enforced Site Health and Safety Plan) will address the potential
risks associated with the accidental release of these wastes
during off-Site transportation.
If treated ground water were discharged off-Site in this
alternative, state and federal laws require that a National
Pollutant Discharge Elimination System (NPDES) permit be acquired
to ensure discharged effluent meets all necessary criteria.
Consequently, effluent samples would need to be collected on a
monthly basis for the duration of the treatment program. It is
noted that, under the NPDES program, monitoring would not be
limited to the Site-specific chemicals of concern, but would
include additional parameters unrelated to the Site's history,
which are found on EPA's Target Compound and Analyte (TCL/TAL)
lists.
An alternative method of effluent discharge would be through an
infiltration pond located on-Site to collect treated ground
water. Specific permitting requirements exist for construction
and maintenance of an infiltration pond; however, the treated
effluent must meet only the substantive requirements of an NPDES
permit for the Site-specific chemicals of concern.
30
-------
Should the treated effluent be discharged directly to existing
drainage swales/ a sediment sampling program would be undertaken
to monitor PCB concentrations which may accumulate over time in
the environmental media. Since treated ground water would be
discharged to the main drainage swale running parallel to the
Site access road (and considered on-Site discharge), sediment
samples would be collected on an annual basis for the duration of
site remediation activities and monitored to ensure total PCB
concentrations did not exceed a level of 50 ppb. In the event
that sediment PCB concentrations exceed 50 ppb/ these materials
would be removed and/ dependent on conditions existing at that
time/ new or alternative methods for treated effluent discharge
would be evaluated by EPA.
The actual method for discharge of the treated effluent will be
evaluated and selected during the Remedial Design.
Summary of Remedial Alternative Evaluation;
This alternative is a demonstrated technology for the removal of
PCBs from ground water. It can be relatively expensive if the
GAC is regularly "spent/" that is,, the carbon has reached the
breakthrough point where the PCBs no longer adsorb to the surface
of the GAC. The use of a filtration system prior to passing
through the GAC system will increase the life of the system and
will reduce the amount of exhausted carbon that would require
off-Site disposal.
The estimated time frame for implementation of this alternative
(construction of treatment system) is eight to twelve weeks.
This alternative is both technically and administratively
feasible. The requisite equipment/ labor/ and materials are
readily available.
This alternative will eventually lead to compliance with
chemical-specific ARARs (federal MCL for PCBs is 0.5 ppb);
however/ due to the high affinity of PCBs for the Site geologic
media and the demonstrated low mobility of PCBs, these ARARs will
not be achieved in the foreseeable future. Alternative 3 will
meet the requirements of all action-specific and
location-specific ARARs (See Table 8.2.1), as applicable, and
will incorporate treatment as a remedial component pursuant to
SARA. This alternative protects human health and the environment
by implementing institutional controls and ground water
monitoring.
The anticipated capital cost for this alternative as presented in
the Feasibility Study is $425,750, with a present worth long-term
O&M cost of $920,975. The estimated total cost is $1,346,725.
It is noted that for purposes of comparability and practicality,
capital and present worth costs were based on two additional
monitoring wells and two extraction wells. The actual number and
placement of any additional well installations will be determined
during Remedial Design. If EPA determines that more than the
31
-------
four wells specified above will be needed, the cost will increase
accordingly. Also, the present worth costs were estimated for a
30-year period; treatment will need to be maintained for in
excess of 1,000 years to attain a 0.5 ppb cleanup level.
7.4 Alternative 4 - Filtration/UV Oxidation
Major Components of Remedial Alternative;
This alternative processes the extracted ground water through a
filtration system and a Ultra-violet (UV) Oxidation system where
the PCBs would be dechlorinated using a strong oxidizer and a UV
light. As with Alternative 3, the filtration system would remove
70-90 percent of the suspended solids in the extracted ground
water and the adsorbed PCBs in ground water prior to treatment by
the UV Oxidation system. Any remaining adsorbed PCBs and the low
fraction of dissolved PCBs will be removed through the final
polishing by UV Oxidation. As with Alternative 3, this
alternative will require in excess of 1,000 years of operation to
attain the 0.5 ppb federal MCL, the cleanup level established for
the Site.
The major components of this alternative include:
a) the implementation of institutional controls as
described under Alternative 2;
b) the construction of two additional ground water
monitoring wells (MW-12A and MW-12B) downgradient of
the former operational area;
c) the installation of a security fence around all source
area wells (Monitoring well nests MW-6, MW-7, and
MW-8);
d) the design and construction of ground water extraction
wells in both the Upper and Lower Sand Units, located
near the western boundary of the former operational
area of the Site;
e) the installation of a ground water pumping system;
f) the installation of a ground water filtration system;
g) the installation of a UV Oxidation treatment system;
h) the installation of a treated effluent discharge
system;
i) the transportation and disposal of the filtration waste
to a TSCA-compliant facility on an as-required basis;
and
32
-------
j) the implementation of a long-term ground water
monitoring program, as described under Alternative 1,
to verify the effectiveness of the selected remedy.
~i
Management of Residuals;
The residual filtrate generated from the treatment system will be
transported for disposal to a TSCA-compliant facility on an as-
required basis. A comprehensive off-Site Emergency Contingency
Plan (as part of a properly enforced Site Health and Safety Plan)
will address the potential risks associated with the accidental
release of these wastes during off-Site transportation.
This alternative will require proper disposal of treated ground
water as described for Alternative 3 in Section 7.3, Management
of Residuals. If the treated effluent is discharged off-Site, an
NPOES permit will be required. If the effluent is discharged on-
Site to an infiltration pond or the existing drainage swale, only
the substantive requirements of such a permit will have to be
met. In addition, this alternative would require a sediment
sampling program, as outlined for Alternative 3 in Section 7.3,
should the treated effluent be discharged to the existing
drainage swale. The actual method for discharge of the treated
effluent will be evaluated and selected during the Remedial
Design. l ; .
. •• •:.' >'•'•'
Summary of Remedial Alternative Evaluationt
This alternative is a demonstrated technology for the removal of
PCBs from ground water. A high suspended solid content in the
ground water will lower the efficiency of the UV Oxidation
treatment system to remove PCBs. Thus, it is necessary to use a
settling tank/filtration system prior to passing the ground water
through the UV Oxidation treatment system.
The estimated time frame to complete construction of this
alternative would be eight to twelve weeks. This alternative is
both technically and administratively feasible. The requisite
equipment, labor, and materials are readily available.
In obtaining ARARs, this alternative is identical to Alternative
3 in that it will eventually lead to compliance with chemical-
specific ARARs (federal MCL for PCBs is 0.5 ppb); however, due to
the high affinity of PCBs for the Site geologic media and the
demonstrated low mobility of PCBs, these ARARs will not be
achieved in the foreseeable future. Alternative 4 will meet the
requirements of all action-specific and location-specific ARARs
(See Table 8.2.1), as applicable, and will incorporate treatment
as a remedial component pursuant to SARA. This alternative
protects human health and the environment by implementing
institutional controls and ground water monitoring.
The anticipated capital costs for this alternative would be
$588,575, with a present worth long-term O&M cost of $1,054,996.
The estimated total cost would be $1,643,571. It is noted that
for purposes of comparability and practicality, capital and
33
-------
present worth costs were based on two additional monitoring wells
and two extraction wells. The actual number and placement of any
additional well installations will be determined during Remedial
Design. If EPA determines that more than the four wells
specified above will be needed, the cost will increase
accordingly. Also, the present worth costs were estimated for a
30-year period; treatment will need to be maintained for in
excess of 1,000 years ,to attain a 0.5 ppb cleanup level.
7.5 Alternative 5 - Contingent Filtration/Carbon Adsorption
(GAC)
Malor Components of Remedial Alternative;
This alternative utilizes institutional controls, long-term
monitoring and construction of a ground water extraction system
if PCBs at specified point of compliance (POC) wells are
confirmed to exceed the federal MCL of 0.5 ppb. This alternative
is identical to Alternative 3 with the exception of the
contingency imposed on implementation of the treatment system.
It is estimated that a filtration system would remove 70-90
percent of the suspended solids from the extracted ground water.
The removal of PCBs would occur in a parallel fashion with
removal of suspended solids and sediments. Any remaining
adsorbed PCBs and the low fraction of dissolved PCBs would be
removed through the final polishing by a GAC.
Initially, and perhaps ultimately, remedial activities for this
alternative will include:
a) the imposition of institutional controls as described
under Alternative 2;
b) the construction of two additional ground water
monitoring wells (MW-12A and MW-12B) downgradient of
the former operational area;
c) the installation of a security fence around all source
area wells (Monitoring well nests MW-6, MW-7, and
MW-8); and
d) the implementation of a long-term ground water
monitoring program, as described in Alternative 2, to
verify the effectiveness of the selected remedy.
If Alternative 5 were fully implemented, the additional remedial
activities would include:
e) the design and construction of ground water extraction
wells in both the Upper and Lower Sand Units, located
near the western boundary of the former operational
area of the Site;
34
-------
f)
g)
the installation of a ground water pumping system;-
the installation of a ground water filtration system;
h)
the installation of a GAC treatment system;
the installation of a treated effluent discharge
system; and
i)
j)
the transportation and disposal of the GAC and
filtration waste to a TSCA-compliant landfill or
incinerator on an as-required basis.,
..
The implementation of items e) through j) of this alternative,
would be contingent upon confirmation of PCBs at downgradient
compliance monitoring wells. These point of compliance (POC)
wells (MW-9A,' 9B, and the newly installed wells, HW-12A and MW-,
12B) will be sampled quarterly for PCBs. ' Confirmatory sampling
must occur within sixty days of receipt of the original
monitoring results that show elevated PCB concentra"tions.,
The monitoring frequency for thes~POC wells will'be maintained
for a period of two years. At the end of the two-year period, if
historical data from the source area wells indicate PCB "
concentrations are stable or declining with time, EPA will
consider a less frequent POC monitoringsChedule~(Semi-annual).
After EPA's five-year review, and again if PCB concentrations in
source area wells continue to be stable or decline,. the
monitoring frequency may be altered by EPA to allow only annual
monitoring of P~C wells. All collected ground water samples will
be analyzed for PCBs.' For evaluation and costing purposes only,
it has been assumed that two additional monitoring wells will be
installed under item b). The exact number and location will be
evaluated and selected in the Remedial Design and the costs
adjusted accordingly.
The long-term ground water monitoring program described under
item d) will be identical to that described under Alternative 2,
Section 7.2, consisting of annual monitoring of source area wells
(Monitoring well nests MW-6, MW-7, and MW-8) and at least one
upgradient well (HW-IA). All collected ground water samples will
be analyzed for PCBs.
Manaaement of Residuals:
If fully implemented, the residual filtrate and GAC waste
generated from the treatment system would be transported for
disposal to a TSCA-compliant landfill or incinerator on an as-
required basis. A comprehensive off-Site Emergency Contingency
Plan (as part of a properly enforced Site Health and Safety Plan)
would address the potential risks associated with the accidental
' release of these wastes during off-Site transportation.
35
-------
If fully implemented, this alternative would require proper
disposal of treated ground water as described for Alternative 3
in Section 7.3, Management of Residuals. If the treated effluent
is discharged off-Site, an NPDES permit would be required. If
the effluent is discharged on-Site to an infiltration pond or the
existing drainage swales, only the substantive requirements of
such a permit would have to be met. In addition, this
alternative would require a sediment sampling program, as
outlined for Alternative 3 in Section 7.3, should the treated
effluent be discharged to the existing drainage swales. The
actual method for discharge of the treated effluent would be
evaluated and selected during the Remedial Design, if warranted.
Summary of Remedial Alternative Evaluation;
This alternative, if fully implemented, is a demonstrated
technology for the removal of PCBs from ground water. It can be
relatively expensive if the GAC is regularly "spent", that is,
the carbon has reached the breakthrough point where the PCBs no
longer adsorb to the surface of the GAC. The use of a filtration
system prior to passing through the GAC system will increase the
life of the system and will reduce the amount of exhausted carbon
that would require off-Site disposal.
The estimated time frame for implementation of the first phase of
this remedy (construction of monitoring system) is one week. If
phase two is to be initiated, an additional seven to eleven weeks
would be required for construction of the ground water treatment
system. This alternative is both technically and
administratively feasible. The requisite equipment, labor, and
materials are readily available.
This alternative will eventually lead to compliance with
chemical-specific ARARs (federal MCL for PCBs is 0.5 ppb);
however, due to the high affinity of PCBs for the Site geologic
media and the demonstrated low mobility of PCBs, these ARARs will
not be achieved in the foreseeable future. It is noted that
initiation of phase two of this remedy, the active ground water
treatment, would only have a marginal effect on cleanup of the
Surficial Aquifer System and, as described under Alternative 3,
would take in excess of 1,000 years of operation to eventually
achieve cleanup goals. Under this scenario, the initiation of
the treatment system would be for containment purposes only.
Alternative 5 meets the requirements of all action-specific and
location-specific ARARs (See Table 8.2.1), as applicable, and, if
fully implemented, would incorporate treatment as a remedial
component pursuant to SARA. This alternative protects human
health and the environment by implementing institutional controls
and ground water monitoring.
The initial, and perhaps only, anticipated capital costs for this
alternative would be $30,875, with a present worth long-term O&M
cost of $345,870. The initial estimated total cost would be
36
-------
$376,745. If the alternative were fully implemented/ the
additional capitol costs and 0 & M costs would be $394,875 and
$575,105, respectively. It is noted that for purposes of
comparability and practicality, capital and present worth costs
were based on two additional monitoring wells and two extraction
wells. The actual number and placement of any additional wells
to be installed will be determined during Remedial Design. If
EPA determines that more than the four wells specified above are
necessary, the cost will increase accordingly. Also, the present
worth costs were estimated for a 30-year period; treatment would
need to be maintained for in excess of 1,000 years to attain a
0.5 ppb cleanup level.
A detailed comparative analysis was performed on the five (5)
ground water remedial alternatives developed during the FS and
the modifications submitted during the public comment period
using the nine evaluation criteria set forth in the NCP. The
advantages and disadvantages of each alternative were compared to
identify the alternative with the best balance among these nine
criteria. A glossary of the .evaluation criteria is provided in
Table 8.1. According to the NCP, the first 2 criteria are
labeled "Threshold Criteria", relating to statutory requirements
that each alternative must satisfy in order to be eligible for
selection. The next 5 criteria are labeled "Primary Balancing
Criteria", which are technical criteria upon which the detailed
analysis is primarily based. The final 2 criteria are known as
"Modifying Criteria", assessing the public's and State agency's
acceptance of the alternative. Based on these final 2 criteria,
EPA may modify aspects of the specific alternative.
A summary of the relative performance of each alternative with
respect to the nine evaluation criteria is provided in the
following subsections. A comparison is made between each of the
alternatives for achievement of a specific criterion.
8.1 Overall Protection of Human Health and the Environment
This criterion addresses whether each alternative provides
adequate protection of human health and the environment and
describes how risks are eliminated, reduced, or controlled,
through treatment, engineering controls, and/or institutional
controls.
PCBs, which have the consistency of heavy oil to wax at room
temperature, are bound to geologic matter at the Site in a
separate phase from the ground water and can most likely not be
extracted from the aquifer in significant quantities at this
time. It is for this reason that it is most likely technically
infeasible to remove PCB contamination to levels that are
protective of human health and the environment in the foreseeable
37
-------
Table 8.1
GLOSSARY OF EVALUATION CRITERIA
THRESHOLD CRITERIA:
OVerall Protection of Human Health and the
addresses whether or not a remedy provides
and describes how risks posed through each
eliminated, reduced, or controlled through
controls or institutional controls.
Environment -
adequate protection
pathway are
treatment, engineering
Coamliance with
meet all of the
requirements of
and/or provides
ARABs - addresses whether or not a remedy will
applicable or relevant and appropriate
other federal and state environmental statutes
grounds for invoking a waiver.
PRIMARY BALANCING CRITERIA:
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.
ImDlementability - 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.
MODIFYING CRITERIA:
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 and the public comment
period.
38
-------
future. None of the remedies evaluated will in all probability
eliminate the risks due to PCBs in the ground water.
All of the alternatives, with the exception of the "No Action"
alternative, would provide protection of human health and the
environment by restricting exposure to contaminated ground water
through institutional controls and a ground water monitoring
program. These controls would have to remain in effect until PCB
ground water concentrations declined to acceptable levels.
Alternatives 3, 4 and 5 will prevent the migration of PCB-
contaminated ground water away from the source area, yet their
active operation will produce contaminated waste by-products that
will require staging,, transport and disposal, or treatment.
While Alternatives 3, 4 and 5 employ treatment as a remedial
component, the affinity of PCBs for solid material coupled with
the hydrogeologic characteristics of the Site renders treatment
for complete FCB removal ineffective. The extraction/treatment
systems would be utilized as a means by which the PCB-
contaminated ground water can be contained. Remediation of the
ground water to acceptable health based levels would not be
achieved in the foreseeable future (less than 1,000 years).
•* "* ' . t -
The No Action alternative fails to provide any controls to
restrict exposure to the contaminated ground water. Alternatives
2, 3, 4, and 5 rely on institutional controls and monitoring for
protection of human health and the environment until contaminant
levels naturally dissipate to levels below the MCL.
Thus, all factors considered, Alternatives 2, 3, 4 and 5 are
equally protective and slightly better than Alternative 1 since
they each have access restrictions and monitoring components.
8.2 Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
This criterion addresses whether or not an alternative will meet
all ARARs of other federal and state environmental statutes or
provide a basis for invoking a waiver. Each alternative was
evaluated for compliance with ARARs, including chemical-specific,
action-specific, and location-specific ARARs. These ARARs are
presented in Table 8.2.1. ARARs are broken down in the table
into federal and state regulations.
Because of the infeasibility of removing sufficient amounts of
PCBs from the aquifer for treatment, none of the alternatives are
estimated to comply with the Safe Drinking Water Act (SDWA), 40
C.F.R. Part 141, Primary Drinking Water Standards for PCBs, for
the ground water located directly beneath the source area (former
operational area) within the foreseeable future. The Maximum
Contaminant Level (MCL) set for PCBs, which is 0.5 ug/L or ppb,
will most likely not be attained beneath the source area by any
39
-------
Table 8.2.1
Page t of 4
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARAKs)
YELLOW WATER ROAD SITE
BALDWIN, FLORIDA
LQW 0' Regu'Qtion
lUfnmce
Ambient 0' CMmlcll'
Spedfic ARAR
Pnform"nu, Design 0' Action
Specific ARAR
Loclltlon
Specific ARAR
FEDERAL
42 use 9601 et. seq. Applicable, ~Ievant and Applicable, relevant and appropriate N/A
appropriate requirements requirements of 40 CFR 300.68 (NCP)
under Section 121 of SARA
2. RCRA 42 use 6901 et. seq. N/ A (1) Relevant and appropriate for on-site
-I'-- landfill, waste pile or surface
a im~ndment
3. RCRA Land Disposal 40 CFR 268 N/A . Restrictions on Land Disposal for
Restrictions (LDRs) PCB soils greater than 50 ppm
4. Toxic Substances 15 use 2605 N/A Applicable to transport and disposal
Control Act (TSCA> of PCB wastes greater than 50 ppm
5. Spills Cleanup 40 CFR 761 Applicable to remove soils Applicable to transportation and
Policy (under TSCA) Subpart D, G, K with PCB concentrations disposal of PCB wastes
greater than 10 ppm
6. Clean Air Act N/A Applicable to air emissions from any
on-site treatment alternatives
7. Safe Drinking Water Regulates drinking water Applicable to groundwater MCLs and
Act supplil.'S using MCLs water which may be consumed after
any treatment alternative
1. CERCLA/SARA
N/A
N/A
N/A
N/A
N/A
N/A
-------
Law or Regulation'
8. Worker Safety and
Health Protection
9. Clean Water Act
~ 10. Clean Water Act
~
11. Hazardous Materials
Regulations
12. Endangered Species Act
13. National Historic
Preservation Act
STATE OF FWRIDA
Rorida (FLA> Solid and
Hazardous Waste
Management Act
FLA Hazardous Waste
Rules
Table 8.2.1
APPUCABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
YELLOW WATER ROAD SITE
BALDWIN, FLORIDA
Rqemlu
Occupational Safety
and Health
Admlmstnl.tion (OSHA)
33 use 1251 et. seq.
33 use 1344 404B
. 49 CFR 170 to 179
50 CFR 402
16 use 470
17-730 F.A.C.
Ambient 0' Chemlall
Specific ARAR
N/A
N/A.
.. -
N/A
N/A
N/A
..
N/A
N/A
N/A
Performanu, Design 0' Action
Specific ARAR
Worker safety during remedial
constnaction ..
Applicable to discharges into
navigable waters or any work
perfonned in or affects the quality of
any navigable w~ters
Applicable to the discharge of
degraded or fill materials into
navigable waters
Appl.icable to transportation of
hazardous materials
-
N/ k.
N/A
. '.. . "I
. Applicable to transportation and
disposal of hazardous waste
. Applicable to transportation and
disposal of hazardous waste
Page 2 of 4
Loclltlon
Specific ARAR
N/A
NiA'
N/A
N/A
Applicable to pussible
ncgalive impact to
endangered spt.ocies
Applicable to possible
eUt-octs of undertakings on
historic sites and structures
N/A
N/A
-------
Table 8.2.1
Page 3 of 4
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (AKARa)
YELLOW WATER ROAD SITE
BALDWIN, FLORIDA
Ambient or Chntlad Performance, Design or Action Location
Law or Regulation Rlfrmact Specific ARAR Specific ARAR Specific ARAR
F1.A Air and Water N/A Applicable to alternatives that N/A
Pollution Control Act dispose of waste to waters of the State
F1.A Water Quality 17-3, Part IV N/A Groundwater quality standards N/A
Standards
F1.A Storm water N/A Applicable to any swale design N/A
~, Discharge Regulations 17-25
N
F1.A Ambient Air FOER 17-2 N/A Applicable to air emissions from N/A
Quality Standards treatment systems
F1.A Drinking Water FDER 17-550 Regulates drinking water Applicable to groundwater MCLs, and N/A
Standards supplies using MCLs effluent from treatment systems
F1.A Underground FOER 17-28 N/A Applicable to any treatment effluent N/A
Injection Control discharged back into the aquifer.
Permit required.
LOCAL AUTHORITIES
City of Jacksonville Ordinance Applicable to alternatives which use
Department of Health, 82-372-185 indneration or the purchase of
Welfare & 82-549-224 property.
Bio-Envirunmental
Services
-------
Law 0' Regulatloll
Rules regarding PCB
Storage and Disposal
Note:
(1) N/ A - notapplicable.
.f:'-
W
Table 8.2.1
Page 4 of 4
APPUCABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
YELLOW WATER ROAD SITE
BALDWIN, FLORIDA,
~
Amblmt or Chemic,,'
Specific ARAR ' .
II
. '. ..
N/A
:. ....
"'" t':
"
',. to
. f",1
'r.
:, " ::' '"
:"1,'
. : I .
: f ..
.:: I' ..
. : ;.' .
j~' ~
"
, ,
, , Pnformallce, Design or Actloll '
, , Specific ARAR
Locatioll
Spulflc ARAR
, ,
'Relevant to groundwater treatment
alternative,discharges. > ;"
N/A'
~
:'
. ,
"
, "
, I'
"
-,
(
.\ . ..
.f . ..
, "
,t.
-------
of the alternatives within a reasonable timeframe (less than
1,000 years).
EPA waives the requirements of 40 C.F.R. Part 141 for the ground
water located beneath and in close proximity to the source area
according to 40 C.F.R. 300.430(f)(1)(ii)(C)(3). This waiver
applies solely to the ground water beneath the source area and
will remain in effect until such time as active remedial measures
provide some advantage to attaining the ARAR. Justification for
the waiver is based on the fact that attainment of the MCL is
technically impracticable for several reasons, including: (1)
the sorptive nature of PCBs to geologic matter; (2) the limited
area of ground water contamination that exists; (3) the lack of
evidence supporting continued contaminant migration; and (4) the
trend towards naturally decreasing PCB concentrations in the
ground water. The benefit gained from immediate implementation
of a pump and treat system for removal of PCBs from the ground
water would be marginal at best due to the affinity for PCBs to
Site geologic matter.
Alternatives 2, 3, 4 and 5 will attain their respective federal
and state ARARs due to the implementation of institutional
controls and restricted Site access. Both measures will ensure
that there is no potential for future exposure to ground water
containing PCB concentrations in excess of federal and state
ARARs promulgated under the SDWA and Florida Drinking Water
Standards, respectively. Alternatives 3, 4 and 5 ranked higher
than the other two since they all have a treatment component
pursuant to SARA.
8.3
Long-Term Effectiveness and Permanence
Long-term effectiveness and permanence refers to the ability of
an alternative to maintain reliable protection of human health
and the environment over time, once cleanup levels have been met.
Alternatives 3, 4 and 5 provide greater long-term effectiveness
and permanence than the other two alternatives; however, the
affinity of PCBs to naturally occurring solids predisposes any
ground water extraction and treatment system to be only
marginally successful. There would be some PCBs extracted with
the filtered suspended solids; however, the effectiveness of
these alternatives for ground water containment relative to
natural processes would be marginal at best. In fact, as
presented in the FS Report, contaminant migration models indicate
that it would take approximately 1,000 years for the edge of a
0.5 ppb PCB plume to be observed only 40 feet from the Site
source area.
Alternative 2 is more effective than Alternative 1 in the long-
term due to the enforcement of institutional controls and the
implementation of an active monitoring system. The No Action
alternative was the least effective in achieving the long-term
44
-------
effectiveness and permanence criterion. .No Action leaves the
potential risk associated with the site ground water in an
unaltered state.
8.4
Reduction of Toxicity, Mobility, or Volume
This is the anticipated performance of the treatment technologies
an alternative may employ. The degree of reduction of toxicity,
mobility or volume through treatment varies depending on the
methods of ground water extraction and treatment employed.
As discussed previously, some PCBs would be extracted using a
pump and treat system. Alternatives 3, 4 and 5 offer active
reduction in mobility of PCB-contaminated ground water, resulting
in a higher ranking than Alternatives 1 and 2 for this criterion.
Alternatives 3, 4 and 5 utilize filtration and final "polishing"
as the treatment process for extracted ground water. Carbon
Adsorption (GAC) is the final polishing system used in
Alternatives 3 and 5, and UV Oxidation is utilized in Alternative
. 4. Alternatives 3, 4 and 5 woul~.reduce the mobility of the PCBs
by inducing inward or negative flow in the vicinity of the
contamination, preventing the spread of contaminated ground water
off-Site. However, again the effectiveness of Alternatives 3, 4
and 5 relative to Alternatives 1 and 2 is marginal due to the
chemistry of PCBs and the effectiveness of natural attenuation
mechanisms.
Alternatives 1 and 2 are considered equivalent since there would
be no active reduction in toxicity, mobility or volume of on-Site
PCBs in ground water with these alternatives. .
Reduction in toxicity and volume is at best marginal for
Alternatives 3, 4 and 5 when compared to Alternatives 1 and 2.
8.5
Short-Term Effectiveness
This criterion refers to the period of time needed to completely
achieve protection and any adverse impacts on human health and
the environment that may be posed during the construction and
impl~entation period until cleanup objectives are achieved. The
following factors were used to evaluate the short-term
effectiveness of each alternative: protection of the community
during remedial actions, protection of workers during remedial
actions, environmental impacts from implementation of
alternatives, and the time until- remedial action objectives are
met.
With respect to protection of the community, the No Action
alternative rates most favorably for this criterion since no
construction activities would occur. However, it is least
effective in reference to the time in which the remedy would
45
-------
achieve protection. Alternative 2 ranked second best only
because of the potential inconvenience imposition of
institutional controls may cause area residents.
The construction activities for Alternatives 3, 4 and possibly 5
would pose a minimal risk to the surrounding community; however,
the ground water treatment systems utilized in Alternatives 3, 4
and possibly 5 will produce contaminated waste by-products that
will require staging, 'transport and disposal, or treatment.
Handling of these waste by-products may pose an additional risk
to the community of off-Site transportation and potential
spillage.
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 waste by-products 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.
Alternative 3 was the least effective alternative since it would
generate the most amount of waste by-product that would require
additional remediation.
8.6
Implementability
This is the technical and administrative feasibility of an
alternative, including the availability of goods and services
needed to implement the solution.
All the alternatives are both technically and administratively
feasible; however, Alternative 1 (No Action) would require the
least amount of effort and, therefore, is most effective for this
criterion. This is followed by Alternative 2 which would only
require some administrative requirements and implementation of
monitoring. Alternative 5 would be easier to implement than
Alternatives 3 and 4 since initially (and perhaps ultimately)
only monitoring and institutional controls would be required.
Alternatives 3 and 4 would be considered the least implementable
due to the necessary extraction and treatment equipment required;
although Alternative 3 is slightly more effective than
Alternative 4 since the GAC treatment system may be amenable to
assembly of pre-constructed and sized components.
46
-------
8.7
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. Table
8.7.1 details the capital and 0 & M costs for the 5 ground water
remedial alternatives. It is noted that for Alternatives 2
through 5, cost estimates were also based on the installation of
two additional monitoring wells and ~ extraction wells,
although additional wells may be required, as determined during
Remedial Design. Also, it is noted,'that for Alternatives ,3
through 5, cost estimates were based on a 30-year period, yet
treatment would be required for a period in excess of 1,000
years.
Table 8.7.1
Ground water Remedial'Alternative CostCompariSODS
AL'l'BRRM'IVB f
'1'O'lAL ,PRESBN'l'
WORTH COST
Alternative ,1 '
$0-, ,
Alternative 3
$376,745
$1,346,725
Alternative 2
Alternative 4
$1,643;571 '
$376,745
$1,346,725
Alternative 5
(Fully Implemented)
Alternative 4 (Filtration/UV Oxidation) is the most expensive
ground water remedial alternative at $1.6 million. The cost for
Alternatives 3 and 5 (if fully implemented) are slightly less
than the cost for Alternative 4 and offer a comparable degree of
protection. Alternatives 2 and 5 (initially) are substantially
less expensive than Alternatives 3 and 4, yet provide a
comparable degree of protection because of the ma~ginal benefit
gained from actively remediating PCBs in ground water.
Alternative 1 is the least costly and provides the least amount
of protection.
47
-------
8.8
State Acceptance
This indicates whether, based on review of the RI Report, FS
Report, and Proposed Plan, the U.S. EPA and FDER agree on the
preferred alternative. EPA and FDER are in agreement on the
selected alternative.
8.9
Community Acceptance
This indicates the public's support of a given alternative. This
criterion is addressed in the Responsiveness Summary, Appendix A
of this document.
Based on comments made by citizens and government officials at
the public meeting held on May 18, 1990, and those received
during the public comment period, the Agency perceives that the
community believes that the overall selected remedy of Contingent
Filtration/Carbon Adsorption (GAC) for contaminated ground water
will effectively protect human health and the environment.
9.0
Selected Remedv
Based upon consideration of the requirements of CERCLA,the
detailed analysis of the remedial alternatives and public
comments, EPA has selected Alternative 5 as the appropriate
remedial alternative for ground water at the Yellow Water Road
Site. Alternative 5 provides short and long-term protection of
human health and the environment from potential threats
associated with direct contact (ingestion) of the PCB-
contaminated ground water, and provides for immediate initiation
of active restoration/containment should the contaminated ground
water migrate outside of the former operational area.
Initially, and perhaps ultimately, remedial activities for
Alternative 5, as modified by the incorporation of comments
received from the governing state agency, include the following:
a)
the imposition of institutional controls as described
under Alternative 2, Section 7.2i
b)
the construction of four additional ground water
monitoring wells downgradient of the former operational
area, two wells (MW-13A and 13B) will be located 20
feet downgradient of MW-7 and two wells (MW-12A and
12B) located 20 feet downgradient of MW-8i
c)
the installation of a security fence around all source
area wells (Monitoring well nests MW-6, MW-7, and
MW-8)i and
d)
the implementation of a long-term ground water
monitoring program, as described in Alternative 2 and
48
-------
.
modified below, to verify the effectiveness of the
selected remedy. "
!f Alt3rnative 5 were fully implemented, the additional remedial
activities would include: '
f)
,g)
h)
i)
e)
the design and construction of ground water extraction
wells in both the Upper and Lower Sand Units, located
near the western boundary of the former operational
,area 'of the Site;
- ,
. .' .
the ,installation of 'a ground water 'pumping system;
the installation ofa ground wat~r fi~~ration system;
the installation of a GAC treatment system;
'the installation of a treated effluent disch~rge
system; and
the transportation and disposal of, the GACand
filtration waste to a TSCA-compliant landfill or -
incinerator, on an as-reqUired, bas.i~.:.'
The implementation of items e) through j) of'this alternative
would be contingent upon confirmation'of PCBs' at downgradient
compliance monitoring wells. These point of compliance (POC)
wells (MW-10A, lOB, and the four newly installed wells, MW-12 A,
12B, 13A, and 13B)- :will be sampled quarterly for PCBs. '
Confirmatory sampling must occur within sixty days of receipt of
the original monitoring results that show PCB concentrations at
or above the 0.5 ppb MCL. ' ' -
, j)
The monitoring frequency for these P~C wells will be maintained
for a period of two years. At the end of the two-year period, if
historical data from the source area wells indicate PCB
concentrations are stable or declining with time, EPA will
consider a less frequent POC monitoring schedule (semi-annual).
After EPA's five-year review, and again if PCB concentrations in
source area wells continue to be stable or decline, the
monitoring frequency may be altered by EPA to allow only annual
monitoring of P~C wells. All collected ground water samples will
be analyzed for PCBs.
The long-term ground water monitoring program described under
item d) will consist of quarterly monitoring of source area wells
(Monitoring well nests MW-6, MW-7, MW-8,- MW-11) and at least one
upgradient well nest (MW-l). The monitoring frequency for these
source area wells will be maintained for a period of two,years.
At the end of the two-year period, if historical data indicate
PCB concentrations are stable or declining with time, EPA will
consi~er a less frequent source area monitoring schedule (semi-
annual). 'After EPA's five-year review, and again if PCB
concentrations in source area wells continue to be stable or
49
-------
decline, the monitoring frequency may be altered by EPA to allow
only annual monitoring of source area wells. All collected
ground water samples will be analyzed for PCBs.
Due to the sorptive nature of PCBs, the geologic characteristics
of the Site, the anticipated decrease in ground water PCB
concentrations over time, the limited area of ground water
contamination, and the lack of evidence supporting the concept of
continued PCB-migration within the aquifer, EPA determined that
the benefit of immediately implementing a conventional ground
water pump and treat system at the Site would be marginal at best
in comparison to the results obtained from the naturally
occurring attenuation mechanisms such as dispersion.
At this time, implementation of a conventional pump and treat
system would be for containment purposes only, due to the current
technical impracticability of removing PCBs from ground water.
As part of the remedy, should PCBs be confirmed in any of the
designated Point of Compliance (POC) wells at or above the SDWA
MCL of 0.5 ppb, a pump and treat system would be designed and
implemented to ensure protection of human health and environment
by eliminating the threat of PCB migration in the ground water.
"Treatment" of the contaminated ground water would be
accomplished by passing it through a treatment process similar to
that shown in figures 9.1 and 9.2 and would extend beyond the
points of compliance at the operational area boundaries, actively
containing the contaminated ground water within Site boundaries.
After being passed through a filtration system for removal of the
suspended solids and adsorbed PCBs, the ground water would be
passed through a series of carbon adsorption units, which contain
granular activated carbon (GAC) and operate in a downward series
mode, for removal of the remaining contaminants. Treated ground
water would either be discharged to on-Site infiltration ponds or
drainage swales, or to off-Site receptors. Should off-Site
discharge be the chosen option, an NPDES permit would be
required.
Referring to Table 5.3.1, the Site-related contaminant of concern
has a Maximum Contaminant Level (MCL) as promulgated under the
Safe Drinking Water Act (40 C.F.R. 141,143). The MCL for PCBs is
0.5 ppb and will be used as the remediation level for the
contaminant at and beyond the points of compliance to the Site
boundaries. Pumping and treating would be utilized to contain
the contamination, and therefore, would continue until the
remediation level for PCBs (0.5 ppb) is achieved.
Initial construction activities for the implementation of the
ground water monitoring program are estimated to be completed in
one week. If the treatment phase is warranted, an additional 8
to 11 weeks will be required to complete the construction
activities.
For purposes of comparability and practicality, capital and
present worth costs were based on the installation of two
50
-------
- -,r
r.CCESS HA T01 FOR
. -":..- 1. - RISER PIPE RDtCVAL
---
-.
PREF ABRICA 'Tm
F1BERGl.ASS SHELT'£R
:!'1.! '.:ir~'
- CCNCREn: PAD----
II
:F~~r
CPa. BCREHCt.£
LEVU CQN1Ra.
ElEC1ROOES
Figure 9.1
CRA
TYPICAL EXlRAC110N WELL PUMP STA1l0N
YELLOW WA"fER ROAD SITE
Baldwin, Ronoa
2158-90-06/04/91-13-0
51
-------
i SPENT CAC - DISPOSE
, Of' AS HAZARDOUS WArn")
i
( DISPOSABLE !
-l CAC SYSTEM)
-
~EA TE;:)
JISCHARGE
::NTAMINATEJ
:;ROUNDNA TER
-( .~~~~~N J
,
SLUDGE DISPOSAL
PARAL1.EL MODE DIAGRAM:
VACUUM
BREAK
-
DISPOSABLE
GAC
UNIT
DISPOSABLE
GAC
UNIT
INFLUENT
EFFLUENT
NOTE: (1) SPENT GAC 'MLL. BE DISPOSED OF AT AN APPRO~
FAOUTY IN ACCORDANCE ""'11; PREVAIUNG LOCAL. STATE
-AND FEDERAl REGULATIONS.
SOURCE:
JSEP A HANDBOOK: REMEDIAL ACTION AT WASTE
JISPOSAL SITES. OCTOBER 19B5
Figure 9.2
CRA
GRANULAR ACTIVATED CARBON PROCESS
YELLOW WATER ROAD SITE
Baldwin, Aorida
2158-90-17/01/92-13-1
52
-------
additional .onito~ing wells and two extraction wells. Table 9.1
details the cost analysis summary for Alternative 5 as presented
in the Feasibility.Study. After further consideration of.
comments received during the public comment period, two
additional monitoring wells were deemed necessary, thus
increasing the total present worth cost by $30,875, for a total
present worth cost of $1,377,600. It is noted, that if EPA
determines during remedial design that more than the four
m~nitoring or two extraction wells specified above are necessary,
the cost of the remedy will increase accordingly. Also, the
present worth costs were estimated for a 3D-year period;
treatment, if implemented, would need to be maintained for in .
excess of 1,000 years to attain a 0.5 ppb cleanup level.
Long-term ground water operation and maintenance activities will
include quarterly monitoring for a minimum of two years. At that
time EPA will evaluate the feasibility of using a less frequent
monitoring schedule for the duration of the long-term ground
water monitoring program. Long-term operation and maintenance
requirements are expected for the recommended alternative for
this operable unit. Monitoring will determine the effectiveness
of natural processes and the i.mplemented contingent pump and
treat system at reducing migration of PCBs in the ground water
and potentially remediate ground water to meet the MCL. An
0peration and Maintenance Plan will be developed during the
Remedial Design/Remedial Action tasks. .
Due to the strong binding nature of PCBs, it is technically
impossible at this time to develop an alternative which will.
remove PCBs from the ground water to levels EPA deems acceptable
in a reasonable amount of time. The selected contingent ground
water extraction system would remove some of the PCSs in the
aquifer; however, complete removal to health-based levels would
not occur within the foreseeable future.
Desian Considerations
To insure that the design of the system, if warranted by
confirmation of PCB migration at the Site, is optimized,
modifications may be considered prior to invoking contingency
measures. Any or all of the below may be employed:
a)
at individual wells where cleanup goals have been
attained, pumping may be discontinued;
al ternative pumping at wells to eliminate s.tagnation
points;
b)
c)
pulse pumping to allow aquifer equilibration and to
allow adsorbed contaminants to partition into
ground water~ and
53
'-,
-------
Table 9.1
COST ANALYSIS SUMMARY
ALTERNATIVEs
CONTING~" FILTRATION/GAC
YELLOW WATER ROAD SITE, BALDWL'J, FLORIDA
Estimated Estimaud
O&M Capital Total
Item Dncripticm Costs Cost Cost
Summariud Costs
Phase I - Monitoring Wells
1. Direct Capital and Contingency Costs $ 0 S 23,750 $ 23,750
2. Indirect Capital Costs 0 7,125 7,125
3. Operation and Maintenance Costs 345,870 0 345,870
Subtotal: Phase I Costs S 345,870 S 30,875 S 376,745
Phase n - Contingent Groundwater Treatment
1. Direct Capital and Contingency Costs 0 303,750 303,750
2. Indirect Capital Costs 0 91,125 91,125
3. Operation and Maintenance Costs 575,105 0 575,105
Subtotal: Phase n Costs $ 575,105 $ 394,875 $ 969,980
TOTAL COST S 920,975 $ 425,750 $ 1,346,725
54
-------
d)
installation of additional extraction wells to
facilitate or accelerate cleanup of .the contaminant.
plume.
e)
an innovative ground water recovery system to enhance the
recovery of PCB ground water.
Continaencv Measures
Due to the hydrogeological characteristics of the Site and the
chemical nature of PCBs, it has been determined that the portion
of the surficial aquifer beneath the former operational area and
the surrounding acreage incorporating the Site can not be
restored through known conventional means to its beneficial use
in the foreseeable future. Thus, all of the following measures
involving long-term management may occur, .for an indefinite
period of time, as a modification to the selected remedy and/or
the contingent treatment system:
a)
engineering controls such as physical barriers, or
long-term gradient control provided by low level pumping,
as containment measures; .a~d .
-
. .
periodic reevaluation of remedial technologies,
innovative technologies, for restoration of
PCB-contaminated ground water.
The decision to invoke any or all of these measures may be made
during periodic review of the remedial action, which will occur
in accordance with CERCLA Section 121 (C), 42 U.S.C. 9621 (c),
which specifies that ~ formal review be conducted at least every
five years for sites with contaminants remaining above health- .
based levels. Additionally, reevaluation of possible ground
water remedial technologies will occur prior to implementation of
the contingent pump and treat system. If any or all of these
measures are determined to be appropriate, an Explanation of
Significant Difference (ESD) or a ROD Amendment will be issued to
document these measures and inform the.public.
b)
including
10.0
Statutory Determinations
Under its legal authority, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, Section 121 of CERCLA establishes several other
statutory requirements and preferences. These specify that when
complete, the selected remedial action for this Site must comply
with applicable or relevant and appropriate environmental
standards established under federal and state environmental laws
unless a statutory waiver is justified. The selected remedy must
also be cost effective and utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies' to the maximum extent practicable. Finally, the
55
-------
statute includes preference for remedies that employ treatments
that permanently and significantly reduce the toxicity, mobility
or volume of hazardous wastes as their principle element. The
following sections discuss how the selected remedy for this Site
meets these statutory requirements.
10.1
Protection of Human Health and the Environment
The selected remedy of contingent filtration/carbon adsorption of
the ground water protects human health and the environment
through the imposition of institutional controls and ground water
monitoring. Restricted access to both the Site and the ground
water below eliminates the threat of direct contact (ingestion)
of the PCB-contaminated ground water to current and future
landowners in the vicinity of the Site. Should PCB migration
begin to occur, the contingent pump and treat system will be
immediately implemented, eliminating the potential ingestion
threats to downgradient receptors.
Implementation of Alternative 5 will not pose any unacceptable
short-term risks or cross-media impacts to the Site, the workers, .
or the community that cannot be readily controlled. Should the
contingent treatment system be implemented, potential risks
associated with transportation of waste by-products and discharge
of treated ground water off-Site will be minimized by following
the respective Health & Safety and Discharge Permit Plans.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARABs)
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 and state 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.
10.2
ARARs for treating or managing PCB-contaminated material derive
primarily from the Toxic Substances Control Act (TSCA) PCB
regulations. The TSCA regulations of importance to Superfund
actions are found in 40 CFR Section 761.60 - 761.79, Subpart D;
Storage and Disposal. They specify treatment and disposal
requirements for PCBs based on their form and concentration.
TSCA does not however address liquid PCBs at concentrations less
than 50 ppm, and therefore, does not apply to the ground water at
the Yellow Water Road Site. The highest concentration detected
in the ground water was 29.4 ppb from well cluster 6. Where PCBs
affect groundwater, the Safe Drinking Water Act (SDWA) provides
potential ARARs for establishing cleanup goals, i.e., Maximum
Contaminant Levels (MCLS).
56
-------
The recommended alternative.was found to:meet or exceed the
following ARARs selected from Table 8.2.1, as discussed below, or
a waiver has been justified. "'..' n_'.
Chemical-Soecific ARABs:
o
Safe Drinking Water Act MCLs (40 CFRPar~ 141 and 143),
a waiver is required for the ground water .located
directly beneath and in close .prox~ity,to.the source
area based on the technical ~practicability of
achieving the MCL in the foreseeable future.
. _....i'-;.,'.' ;~..'";._.,~."~~.... :...--1,. '. ~
. Florida (FLA) Drinking Water Standards (FDER 17-550),.
'1
o
Location-Specific
ARARs :
o' . Endangered Species Act (50 CFR 402), which requires
that federal agencies ensure that their actions do not
jeopardize the continued existence of' ,a' threatened or
endangered species .. . .. " .. .~
. ::.~_::'. :. JlY. ';.' :
L -...1 .
Action-Soecific ARARB:
~'. ....
", . ..'
o
CERCLA/SARA (42 USC 9601 et. seq.), defines ARARs under
,40 CFR.300.68.(NCP>'. " .' ;...., .,':' ';', d.
. ~ ;': (.' ':: .
o
Clean ,water Act (40 CFR Part 122).
, "
;".';'; .
..' ..
.. r-o.. " .
o
'Toxic Substances Control Act (TSCA) (15 usc 2605),.
which applies to transport and disposal of PCB wastes
greater than 50 ppm, such as waste by-products from
treatment systems.
o
Spill Cleanup Policy (TSCA, 40 CFR 761, Subpart D, G,
K), which applies to transportation and disposal of PCB
wastes.
o
Clean Air Act, which applies to air emissions from any
on-site treatment alternatives.
o
Worker Safety and Health Protection (OSHA)
Hazardous Materials Regulations (49 CFR 170 to 179),
which applies to transportation of hazardous materials
or waste by-products.
o
o
FLA Solid and Hazardous Waste Manageme~t Act, which
applies to the transportation and disposal of hazardous
waste.
o
FLA Hazardous Waste Rules (17-730 F.A.C.)
57
-------
o
FLA Water Quality Standards (17-3, Part IV)
FLA Stormwater Discharge Regulations (17-25)
o
o
FLA Drinking Water Standards (FDER 17-550), which
applies to effluent from treatment systems.
City of Jack~onville, Rules Regarding PCB Storage and
Disposal, which applies to ground water treatment
alternative discharges.
o
Other Criteria To Be Considered:
An agreement shall be reached in the future between EPA and
the State and Local Authorities to prohibit construction of
water supply wells on and in the vicinity of the Site. This
will prevent direct contact or ingestion of contaminated
ground water. .
Additionally, the chosen alternative may include effluent
discharge off-Site, and therefore, the requirements of an
NPDES permit may apply. .
10.3
Coat Effectiveness
This alternative affords a higher degree of overall effectiveness
in not only protecting the public against direct exposure but in
removing the threat of a future release of contaminants. The
estimated capital cost of this alternative, if fully implemented,
is $1.3 million (including operation and maintenance). Initial,
and perhaps ultimate, present worth costs total $350,000.
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.
10.4
Utilization of Permanent Solutions and Alternative
Treatment Technologies (or Resource Recovery Technologies)
to the Maximum Extent Practicable.
u.S. EPA has determined that this remedy is the most appropriate
cleanup solution for remediating the ground water at the Yellow
Water Road Site and that it provides the best balance among the
evaluation criteria for remedial alternatives evaluated. This
remedy provides effective protection in both the short and
58
-------
long-term to potential human and environmental receptors, is
readily implemented, and is cost effective.
•»
10.5 Preference for Treatment as a Principal Element
By monitoring Site contamination and restricting access to
contaminated ground water, the selected remedy addresses the
threat of future direct contact with, or ingestion of, PCB-
contaminated ground water. Should PCB migration be observed, the
contingent pump and treat system will be implemented to contain
the contamination as well as to remove it for treatment.
However, because treatment was not found to be practicable as a
means for reducing PCB concentrations to health-based levels,
this remedy does not satisfy the statutory preference for
treatment as a principal element. The hydrogeologic
characteristics of the Site coupled with the chemistry of PCBs
preclude selecting a remedy in which reduction of PCBs to
acceptable levels could be achieved in the foreseeable future.
Implementation of the contingent pump and treat system would be
undertaken solely as a means by which ground water contamination
can be contained.
Because wastes will remain in the ground water above health-based
levels, EPA will review the Site at least every five years. If,
at the time of review, a new technology for treatment of PCBs in
the groundwater is available and treatment is warranted, its
implementability will be assessed at that time.
11.0 Documentation of Significant Changes
The Proposed Plan for the Yellow Water Road Site was released to
the public on May 8, 1992. The Proposed Plan identified
Alternative 5, Contingent Filtration/Carbon Adsorption (GAC), as
the preferred alternative for ground water remediation. EPA
reviewed all written and verbal comments submitted during the
public comment period. Upon review of these comments, it was
determined that no significant changes to the remedy, as
originally identified in the Proposed Plan, were necessary.
59
\
-------
APPENDIX A
Responsiveness Sn_Ary
-------
RESPONSIVENESS SUMMARY
The U.S. Environmental Protection Agency (EPA) established a public
comment period from May 8, 1992 through June 7, 1992 for interested
parties to comment on EPA's Proposed Remedial Action Plan (PRAP) for
Operable Unit Two'for the Yellow Water Road site. During the comment
period, EPA conducted a public meeting on May 18, 1992 at the Mamie
Agnes Jones Elementary School in Jacksonville, Florida. The meeting
presented the results of the studies undertaken and the preferred
remedial alternative for Operable Unit Two (ground water). During the
public meeting the community was informed of the availability 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 ra=~ed
during the public comment period, and the responses to those c.,.nments
and concerns. All comments summarized in this document have been
factored into the final decision on the preferred alternative for
Operable Unit Two at the Yellow Water Road Site. '
This responsiveness summary for the Yellow Water Road Site is divided
into the following sections. " '
I.
Overview: This section discusses the recommended alternative
for remedial 'action for Operable Unit Two and the public'
reaction to this alternative.
II.
Backaround on Community Involvement and Concerns: This
section provides a brief history of community interest and
concerns regarding the Yellow Water Road Site.'
III.
Summary of Maior Questions and Comments Received Durina the
Public Comment Period and FDER's or EPA's ReSDonses: This
section presents both oral and written comme~ts submitted
during the public comment period, and provides the responses
to these comments.
IV.
Remainina Concerns: This section discusses community
concerns that EPA should be aware of in design and
implementation of the remedial alternative for Operable
Two at the Site. '
Unit
1.
Overview
The recommended alternative addresses the ground water contamination
by restricting access to the contaminated ground water through
imposition of various institutional controls and long-term ground
water monitoring. The major components of the selected remedy for
Operable Unit ,Two include:
-------
-2-
o
the implementation of a long-term ground water monitoring
program;
o
the construction of four additional ground water monitoring
wells downgradient of the source area;
o
the implementation of institutional controls, which would
include deed restrictions, zoning controls, and water supply
well permitting prohibitions;
o
the contingent construction of ground water extraction wells,
in both the Upper Sand Unit and Lower Sand Units, located
near the western boundary of the former operational area of
the Site;
o
the contingent installation of a ground water pumping system;
the contingent installation of a ground water filtration
system;
o
o
the contingent installation of a Granular Activated Carbon
(GAC) Treatment system;
the contingent installation of a treated effluent discharge
system;
o
o
the transportation and disposal of the GAC and filtration
waste to a TSCA-compliant landfill or incinerator, if
treatment is warranted; and
o
long-term management controls including operation and
maintenance of the ground water treatment system if
warranted.
Items 1 through 3 will be immediately implemented. The implementation
of items 4 through 10 of this alternative would be contingent upon
confirmation of PCBs at downgradient compliance monitoring wells.
Confirmatory sampling must occur within sixty days of receipt of the
original monitoring results that show elevated PCB concentrations.
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.
The community, in general, has no objections to the selection of the
recommended alternative.
-------
-3-
II.
Backaround on Communi tv Involvement and Concern
In accordance with CERCLA sections 113 and 117 requirements, a'
Community Relations Plan (CRP) for the Yellow Water Site was finalized
in September 1990 and later revised to include the Operable Unit Two
activities. This Community Relations Plan outlines citizen
involvement and the community's concern.
. ... \0
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 asa 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 th~ si~e since 1985.
An RI Fact Sheet for the Yellow Water Road s~te was issued to the
public in December of 1988. The OP1 Administrative Record was made
. available to the public in the ,information repository located in the
Baldwin City Hall and at the EPA Records Center in Region IV.', ,
Pollowing the release of the OUI RI/PS 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... '
The public was provided an opportunity for public ,comment on the
remedial alternatives for OUI from August 28, 1990 to September 27,
1990. In addition, a public meeting was held on September 4, 1990 in
Baldwin, Florida, to present to 'the community EPA's preferred
alternative for OUI source remediation. During the public meeting,
the community was informed of the availability of a Technical
Assistant Grant (TAG). A response to the comments received during the
public comment period is included in the Responsiveness Summary, which
can be found in Appendix B of the OUI Record of Decision.
The OU2 RI/FS Reports and Proposed Plan were released to the public
for comment in May 1992. These documents were made available to the
public in both the administrative record and the information
repository located in the Baldwin Town Hall. A public comment period
was held from May 7, 1992 through June 6, 1992. In addition, a public
meeting was held on May 18, 1992 to answer questions about problems at
the Site and the ground water remedial alternatives under
consideration.
. ...'
Only a limited number of community members attended the public
meeting. Most of the attendees were city and local government
-------
-4-
officials who expressed little concern about the selected remedial
alternative. Most comments made during the meeting were about the
specifics of the alternative, requesting detailed information about
the construction and operation and maintenance of the alternative.
The main concern expressed by the community residents concerned the
quality of their drinkin~ water supply wells. It was explained that
their domestic wells were all located upgradient of the source of
contamination and that sample results from their wells showed no
detectable contaminant levels.
The following section highlights and addresses the issues of concern.
A response to each comment received during the comment period has been
provided below.
III. Summary of Maior Ouestions and Comments Received Durina the
Public Comment Period and Public Meetina
1.) One commenter inquired about the Technical Assistance Grants
(TAG) which EPA can provide to a local community group for the pUrPOse
of providing technical aid in interpreting the site-related superfund
documents. The commenter was concerned with the amount of tLme it
would take to apply for and receive such a grant.
EPA Community Relations Coordinator Response: The Technical
Assistance Grant is a $50,000 grant available to one community group
per Superfund site for the sole purpose of hiring an objective
technical advisor to interpret or explain EPA's documents and site-
related data to the community. The TAG application process was
designed to take a maxLmum of four months from application to receipt
of the grant~ however, it is currently taking six to nine months to
complete the process. EPA Region IV is working to shorten this period
by making personnel available to aid the community group in filling
out and submitting the necessary application. In Region IV, there is
a toll-free number (1-800-435-9234) which the interested group can
call and request information about community involvement or assistance
with the TAG applications.
2.) A commenter asked to what level current engineering technology
can treat ground water contaminated with Polychlorinated Biphenyls
( PCBs) .
EPA Response: The technical impracticability of using pump and treat
to remediate ground water contaminated with PCBs has little to do with
the treatment process itself, but rather with the amount of time
required to achieve the established cleanup goals (federal MCL of 0.5
ppb). It is tLme not concentration that is the key factor in ground
water remediation at the Yellow Water Road site. Due to the affinity
of PCBs for soil and solid material, it is very difficult to "pull"
the PCB contamination from the aquifer material. For every pore
-------
- ,
-5-
volume of ground water extracted from the aquifer during pump and
treat, only a small fraction of PCBs is extracted from. the aquifer
material.
. .
-Eventually, the health-based standards will be achieved, but the
time frame is in excess of 1,000 years.
3.) A commenter inquired about the proposed remedy at the Site. The
commenter questioned whether bioremediation might be feasible in light
of the cost effectiveness it may afford. .
EPA/PRP ReSDonse:' During the Feasibility Study, EPA evaluated in-situ
bioremediation as a possible remedial alternative. It was dismissed
from final consideration based on the fact that no one has fully
developed the technology for PCB remediation in-situ. In fact, there
have been no pilot or bench scale studies of this techriology performed
on sites with PCB-contaminated qround water. One of the biqqest
problems with bioremediation of PCBs is that they are relatively
recalcitrant and therefore, not susceptible to the degrading
biological processes.
- . -
4.) The PRPs raised several qUestions about the specifics of the
long-term ground water monitoring program:
- c.
a.
b.
Where will. the Point of Compliance (POC) wells be located?
What will be the frequency of monitoring for the P~C and
source wells? - - ... --
Which PCB-concentration standard will be used to trigqer the
contingency?
. -.
EPA ReSDonse: The questions posed by the PRPs are answered within the
text of the Record of Decision; however, separate responses are
provided below:
a.
The Point of Compliance wells will include the wells of
existing monitoring clusters MW-9 and MW-10, in addition to
those of the "to-be-installed" clusters, MW-12 and MW-13.
The wells in cluster MW-10 are located approximately 30 feet
downgradierit of the known source area and the new wells of
clusters MW-12 and MW-13 will be located an equal distance
downgradient of the existing monitoring clusters MW-8 and MW-
.7, respectively. All P~C wells are located a safe distance
from the source boundary and within the known flowpath.
The monitoring frequency for the P~C wells will be
quarterly for a period of two years. At the end of the
two-year period, if historical data from the source area
wells indicate PCB concentrations are stable or declining
with time, EPA will consider a less frequent P~C
monitoring schedule (semi-annual). After EPA's five-year
review, and again if. PCB concentrations in source area
b.
-"
-------
-6-
wells continue to be stable or decline, the monitoring
frequency may be altered by EPA to allow annual monitoring
of POC wells.
The long-term monitoring of the source area wells will
consist of quarterly monitoring. This monitoring
frequency will be maintained for a period of two years.
After this two-year period, EPA will evaluate the
monitoring results, possibly reducing the monitoring
frequency to semi-annual. After EPA's five-year review,
if historical data indicates stable or Non-Detect PCB
concentrations, EPA will evaluate the use of an even less
frequent monitoring schedule (annual) for these well
nests. All collected ground water samples will be
analyzed for PCBs.
c. The Federal MCL of 0.5 ppb will be used as the ground
water remediation level for the Site. Implementation of
the contingent remedy will be triggered by two consecutive
sampling results, within a sixty-day period, which reveal
PCB concentrations at or above the federal MCL.
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.
Community relations will consist of making available final
documents (e.g., Remedial Design Work Plan and Remedial Design
Reports) 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.
------- |