United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
PB93-964008
EPA/ROD/R04-92/113
June 1992
&EPA Superfund
Record of Decision:
Whitehouse Waste Oil Pits
(Amendment), FL
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NOTICE
The appendices listed in the index that are not found in this document have been removed at the reQuest :)1
the issuing agency. They contain material which suppjement. but adds no fur1her apptic:abte information (0
the content of the document. All suppktmentai material is. however. contained in the administrative record
for this site.
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S0272-101
I REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/R04-92/113
ThIe 8nd SubtItI8
1 ~
3. A8c1pient'a Ac-.lon No.
SUPERFUND RECORD OF DECISION
Whitehouse Waste Oil Pits (Amendment), FL
First Remedial Action - Final
7. AuIhor(a)
5. A8part D8t8
06/16/92
a.
a. P8rtonnIng Orpnlzdon A8pI. No.
8. IWfomling Or;8lnlatlon ...... 8nd ~
10. ProJ8cllTaklWork UnI1 No.
11. ConIracl(C) or Grant(G) No.
(C)
(G)
1~ ~ Org8lllDtlon ...... 8nd AddN88
U.S. Environmental Protection
401 M. Street, S.W.
Washington, D.C. 20460
13. Type 01 Repor16 Period Covered
Agency
800/000
14.
15. Su~No'"
PB93-964008
1a. Ab8trac1 (UnlIt: 2110 -Ide)
The 7-acre Whitehouse Waste Oil Pits site was used by Allied Petroleum Products
(Allied) to dispose of acidic waste oil sludges from its oil reclamation process in
Whitehouse, Duval County, Florida. A cypress swamp system and residential area are
immediately adjacent to the site. The northeast tributary of McGirts Creek traverses
the north site boundary. The Floridian surficial aquifer underlies the site and is the
drinking water source for local residents. In Allied's reclamation process,
contaminants were removed from waste oil treatment with concentrated sulfuric acid,
which precipitated most Of the additives and sediment as well as a large portion of the
metals and other contaminants in the waste oil. The acid sludge produced in the first
step and clay used to decolorize the oil were dumped into the unlined pits at the site.
In 1976, following a 200,000-gallon waste oil spill that occurred during dike wall
reconstruction, a treatment system to drain the liquid portion of the pits was
constructed. In 1979, under the supervision of the state and city, the pits were
capped with clay and top soil. A 1985 ROD addressed source control as a containment
remedy consistin~ of a slurry wall construction, soil cap, and a ground water recovery
and treatment system; however, EPA has re-evaluated the' 1985 ROD selection and
(See Attached Page)
17. Document AnaJy8I8 ... De8c:rlplDl8
Record of Decision - Whitehouse Waste Oil Pits (Amendment), FL
First Remedial Action - Final
Contaminated Media: soil, sludge, gw, sw
Key Contaminants: VOCs (benzene, toluene, xylenes)
(arsenic, chromium, lead)
organics (PCBs, phenols), metals
b. IcI8ntlflel8l0pen0Encl8d T-
c. COSA TI R81d/Group
18. AVIII8bIIty SI8I8m8III
18. S8c:I81ty CI- (Th18 Report)
None
20. S8c:urIty Clue (this Page)
Nnnp
21. No. of Pagn
106
I
22. Price
See AI$Z3I:\a
See ".tructi- on ".-
(4-'"
(FOIftIIIIy NT19-35)
~tol Co_ce
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EPA/ROD/R04-92/113
Whitehouse Waste Oil Pits (Amendment), FL
~irst Remedial Action - Final
Abstract (Continued)
determined that the containment remedy failed to meet the requirements of SARA. As a
result, this ROD Amendment focuses on an alternative for treating Whitehouse wastes by
eliminating direct contact risk associated with pit soil/sludge wastes and preventing
contaminated ground water in the surficial aquifer from migrating laterally. The primary
contaminants of concern that affect the soil, sediment; surface water, and ground water
are VOCs, including benzene, toluene, and xylenes; organics, including PCBs and phenols;
and metals, including arsenic, chromium, and lead.
The amended remedial action for this site includes excavating and treating 56,930 cubic
yards of waste within seven waste pits. A treatment train consisting of soil washing,
biotreatment, and sOlidification/stabilization (S/S) technologies will be used to treat
the waste pits. Included in the clean-up activities are onsite deposition of washed
soils and S/S of contaminated fines and sludges; contaminated ground water recovery,
ground water analysis and treatment by onsite granular activated carbon (GAC) adsorption
and chemical precipitation units before discharge to McGirts Creek; installation and
maintenance of a 6-inch vegetative cover over the excavated area; and installation and
maintenance of a fence around the site during remedial activities. A pilot-scale
treatability study will be initiated to further develop the treatment train. If the
ground water treatment system is not capable of achieving the clean-up goals at the end
of any 5-year period, the following contingencies will appiy: containment measures to
prevent further migration of the ground water plume; consideration of a waiver of
chemical-specific ARARs for the aquifer; and institutional controls to restrict access to
;ertain portions of the aquifer and onsite and offsite well monitoring. The estimated
resent worth for this remedial action is $15,500,00 with O&M costs of $3,400,000
:alculated for a 30-year period.
PERFORMANCE STANDARDS OR GOALS: Soil clean-up levels are based on a direct contact
exposure pathway (risk-based). Chemical-specific goals for soils include PCBs 1 mg/kg;
phenols 47,467 mg/kg; benzene 0.4 mg/kg; toluene 2,000 mg/kgi arsenic 32 mg/kg;
hexavalent chromium 526 mg/kgi and lead 500 mg/kg. The ground water clean-up levels are
in accordance with the Florida Water Quality Standards. Chemical-specific goals for
ground water include phenols 10,000 ug/l (risk-based)i benzene 1 ug/l (ARAR-based)i
toluene 24 ug/l (ARAR-based)i.xylenes 50 ug/l (ARAR-based)i arsenic 50 ug/l (ARAR-based)i
chromium 100 ug/l (ARAR-based)i and lead 15 ug/l (ARAR-based). '
3
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AMENDED RECORD OF DECISION
Declaration
SITE NAME AND LOCATION
Whitehouse Waste Oil Pits
Duval County
Jacksonville, Florida
Site
STATEMENT OF BASIS AND PURPOSE
This Amended Record of Decision (AROD) presents the u.s.
Environmental Protection Agency's (EPA) selected Remedial Action
(RA) alternative for the Whitehouse Waste Oil Pits (Whitehouse)
Site. This AROD was developed in accordance with the
Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA) of 1980, as amended by the Superfund Amendments and
Reauthorization Act (SARA) of 1986, 42 U.S.C. 9601 et sea., and
to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP) (Section 105 of
CERCLA), Fed. Reg. 1990. This AROD documents the fundamental
changes to EPA's previous 1985 Record of Decisi~n (ROD). This
decision is based on the updated Whitehouse Site Administrative
Record file.
The Florida Department of Environmental Regulation's (FDER)
verbal concurrence on this AROD will be. followed by written
concurrence.
SITE ASSESSMENT
Actual or threatened releases of hazardous substances from the
Whitehouse Site, if not addressed by implementing the selected
remedy in this AROD, may present an imminent and substantial
endangerment to public health, welfare and/or the environment.
5
:~:.~
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AROD EXPLANATION
/I1A Y $"J
In the,11985 ROD, EPA selected a "containment" remedy consisting
of a slurry wall construction, soil cap and a groundwater
recovery and treatment system. Section 121(b) of SARA directs
EPA to develop clean-up alternatives for Superfund Sites that
provide treatment which permanently and significantly reduces the
mobility, toxicity and volume of hazardous substances. Pursuant
to this statutory mandate, EPA re-evaluated the 1985 ROD
selection and has determined that the "containment" remedy fails
to meet the requirements of SARA.
In 1990, EPA conducted a Treatability Study (TS) to examine a
treatment train consisting of Soil Washing, Biotreatment and
Solidification/Stabilization (S/S) as viable technologies for the
Whitehouse Site. TS results confirmed that this treatment train
would be an effective overall source control remedy and would be
consistent with SARA's goals of a more permanent remedy. This
treatment train was evaluated as Alternative 3 in EPA's 1991
Feasibility Study (FS) and was found to be the most effective
overall alternative for treating Whitehouse wastes. Based on
such finding, EPA has selected Alternative 3 as the remedy of
choice for the Whitehouse Site. Since Alternative 3 is
significantly different than the previously selected 1985 ROD
remedy, EPA is required to ammend the Record of Decision.
Alternative 3 will produce an effective solution to remediation
of contaminants present at the Whitehouse Site, and will require
only minimal removal of hazardous constituents off-site for
disposal in the form of GAC filters spent during groundwater
recovery and treatment. Also, Alternative 3 will meet all
Applicable, Relevant and Appropriate Requirements (ARARs).
AROD DESCRIPTION
The remedy selected in this AROD consists of, among other things,
treating the contaminant source, preventing contaminated
groundwater in the surficial aquifer from migrating laterally
,-
6
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contaminants
o
S/S of Biotreated contaminant fines and sludges
exceeding clean-up criteria
o
on-site deposition of washed soils and S/S of
contaminant fines and sludges
o
contaminated groundwater recovery, groundwater
analysis and treatment by on-site GAC adsorption
and chemical precipitation units to acceptable
levels; clean-up levels would be in accordance
with Florida Water Quality Standards Chapter
17-3.061.3(m) of the Florida Administrative Code
before discharge to McGirts Creek
o
Installation and maintenance of a 6 inch
vegetative cover over the excavated area.
o
Installation and maintenance of a fence around
the site during remedial activities
o
Institutional controls including deed
restrictions
The estimated present worth capital cost for the AROD remedy is
$15,500,000 with Operation and Maintenance (0 & M) costs of
$3,400,00 calculated for a period of 30 years.
STATUTORY DETERKINATIONS
This AROD is protective of human health and the environment,
complies with Federal and State ARARs directly associated with
this action, and is cost-effective. This AROD utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable. This AROD also satisfies the statutory
7
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off-site and preventing potential vertical migration downward
into the Floridan aquifer. The surficial aquifer is the source
of drinking water for local residents, and contamination presents
a threat to human health and the environment.
Soil contaminants of concern include organic compounds (Benzene,
Benzo(a)pyrene, Bis (2-Ethyl Hexyl) phthalate, Chlorobenzene, 1,4
Dichlorochlorobenzene, Di-N-Butyl phthalate, Methylene Chloride,
Polychlorinated Biphenyls (PCB) 1260, 2-Methylnaphthalene,
Naphthalene, Phenol, Tetrachloroethene, Toluene and
Trichloroethene) and inorganic compounds (Antimony, Arsenic,
Barium, Cadmium, Chromium, Copper, Lead and Nickel). Groundwater
contaminants of concern include organic compounds (Acetone,
Benzene, Benzo(a)pyrene, Bis (2-Ehtyl Hexyl) Phthalate, Carbon
Disulfide, Di-N-Butyl Phthalate, Ethylbenzene, Methyl Ethly
Ketone, 3/4 Methylphenol, Naphthalene, 2-Methylnaphthalene,
Phenol, Toluene, Trichloroethene and Xylene) and inorganic
compounds (Antimony, Arsenic, Barium, Cadmium, Chromium, Copper,
Lead, Manganese, Nickel, Selenium, Vanadium and Zinc). These
contaminants exceed both state and federal drinking water
standards in varying degrees.
1992 AROD REMEDY
Major components of the remedy contained in this AROD include:
o
excavation of contaminated waste pits
o
separation of construction debris, stumps, etc.
from contaminated soils and steam cleaning prior
to off-site disposal
o
volume reduction by Soil washing to free
contaminants from soils by suspension in
wash-water
o
Biotreatment to biologically degrade wash-water
8
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preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element.
Because the water table may limit the. depth of excavation, some
hazardous substances above heal~h-based levels may remain on-
site. The groundwater recovery and treatment system will address
any leachate from substances left behind. A review of the remedy
will be conduc~d at least every five years after commencement of
the RA to ensure that this remedy continues to provide adequate
protection of human health and the environment. Groundwater
contingencies are provided if treatment is found to be
ineffective at any five year interval. Contingencies include the
use of the groundwater recovery and treatment system to contain
the groundwater plume.
'-/~-92.
~/YJ~
t Greer C. Tidwell
Regional Administrator
DATE
9
:?-~....
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AMENDMENT TO THE RECORD OF DECISION
SUHMARY OF REMEDIAL ALTERNATIVE SELECTION
WHITEHOUSE WASTE OIL PITS SITE
DUVAL COUNTY, WHITEHOUSE, FLORIDA
Prepared by:
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia
11
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2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
1.0
TABLE OF CONTENTS
Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2
1
Site Location and Description... .... ......... ... ........
Site History................... . . . . . . . . . . . . . . . . . . . . . . . . .
2
Highlights of Community Participation .......... .........
6
Scope and Role of Amended Record of Decision
Within Site Strategy.................................. . .
7
Site Characterization.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6.1 Surface Drainage...................................
6 .2 Hydro-Geology......................................
Risk
7.1
7.2
7.3
7.4
7.5
8
8
8
Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Contaminants of Concern............................ 9
Exposure As ses sment ................................ 11
Toxicity Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 14
Risk Characterization .............................. 15
Environmental Evaluation ........................... 17
Description of ~ternative............................... 18
8.1 Alternative 1 - No Action...... .. .... . ..... . . . . . . .. 19
8.2 Alternative 2 - Slurry Wall, Surface and Groundwater
Recovery & Treatment ............... 20
8.3 Alternative 3 - Soil Wash, Biotreatment,
Solidification / Stabilization and
Groundwater Recovery & Treatment ... 20
8.4 Alternative 4 - Solidification / Stabilization and
Groundwater Recovery & Treatment ... 22
Comparative Analysis. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 22
9.1 Overall Protection of Human Health and Environment. 23
9.2 Applicable, Relevant and Appropriate Requirements
9.3
9.4
9.5
9.6
9.7
9.8
9.9
CampI iance ......................................... 23
Short-Term Effectiveness and Permanence ............ 23
Long-Term Effectiveness and Permanence ............. 24
Mobility, Toxicity or Volume Reduction ............. 24
Implementability ................................... 24
Cost Effectiveness.................................. 25
State Concurrence.................................. 25
Community Acceptance ............................... 25
12
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10.0
11.0
12.0
13
TABLE OF CONTENTS
(cont'd)
Amended Remedy
Selection. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 25
Clean-up Goals
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 32
Statutory- Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 32
12.1 Overall Protection of Human Health and Environment. 33
12.2 Applicable, Relevant and Appropriate Requirements
CampI iance ........................................ 33
Long/Short-Term Effectiveness & Permanence ........ 35
Cost Effectiveness................................ 36
Utilization of Permanent Solutions and Alternative
Treatment or Resource Recovery Technologies to the
Maximum Extent Practicable ........................ 36
Preference for Treatment as a Principal Element ... 37
Documentation of Significant Changes .............. 37
12.3
12.4
12.5
12.6
12.7
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FIGURES
Figure 1 - Site Location Map .. ... ....... ................ ....
3
Figure 2 - Site Map .........................................
4
Figure 3 - Conceptual Treatment Train Flow Diagram ..... ..... 26
APPENDICES
Appendix A - 1985 Record of Decision
Appendix B - Responsiveness SnmmO'iry
Appendix C - Tables 1 - 17
Table 1 - Contaminants of Concern
Table 2 - Exposure and Intake Assumptions:
Surface Soil & Exposed Wastes
Table 3 - Exposure and Intake Assumptions:
Surface Water
Table 4 - Exposure and Intake Assumptions:
Groundwater
Table 5 - Toxicologic Criteria values:
Cancer Health Effects
Table 6 - Toxicologic Criteria Values:
Non-Cancer Health Effects
Table 7 - Cancer Risks & Non-Cancer Hazard Indices:
Surface Soil
Table 8 - Cancer Risks & Non-Cancer Hazard Indices:
Exposed Waste
Table 9 - Cancer Risks & Non-Cancer Hazard Indices:
Surface Water
Table 10 - Cancer Risks & Non-Cancer Hazard Indices:
Shallow Groundwater
Table 11 - Cancer Risks & Non-Cancer Hazard Indices:
Shallow Groundwater
Table 12 - Non-Cancer Hazard Indices:
Deep Groundwater
Table 13 - Cancer Risks & Non-Cancer Hazard Indices:
Shallow Groundwater
Table 14 - Risks Associated with Combined
Exposure Pathways
Table 15 - Caparison of Surface Water Contaminants to
Standards
Table 16 - Glossary of Evaluation Criteria
Table 17 - Risk-Based and Standard-Based Clean-up Goals
Appendix D - Florida Department of Environmental Regulation
Concurrence Letter
14
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AMENDMENT TO THE RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
WHITEHOUSE WASTE OIL PITS SITE
DUVAL COUNTY, WHITEHOUSE, FLORIDA
1.0 INTRODUCTION
This Amended Record of Decision (AROD) presents the selected
remedial al~ernative for the Whitehouse Waste Oil Pits
(Whitehouse) Site. This AROD was chosen in accordance with the
Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA) of 1980, as amended by the Superfund Amendments and
Reauthorization Act (SARA) of 1986 and to the extent practicable,
the National Contingency Plan (NCP). This AROD is based on the
Whitehouse Waste Oil Pits Site Administrative Record.
Section 121(b) of SARA directs EPA to develop remedial
alternatives for Superfund Sites that provide treatment which
permanently and significantly reduces the mobility, toxicity and
volume of hazardous substances. Pursuant to this statutory
mandate, EPA began re-evaluating the 1985 ROD selection and found
the "containment" remedy to be inadequate.
In 1990, EPA conducted a Treatability Study (TS) to examine a
treatment train consisting of Soil Washing, Biotreatment and
Solidification/Stabilization (S/S) as viable technologies for the
Whitehouse Site. This treatment train was evaluated as
Alternative 3 in EPA's 1991 Feasibility Study (FS) and was found
to be the most effective overall alternative for treating
Whitehouse wastes. Since Alternative 3 is significantly
different than the previously selected 1985 ROD remedy (Appendix
A), EPA is required to amend the Record of Decision (ROD).
-1-
15
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2.0
SITE LOCATION AND DESCRIPTION
The Whitehouse Site is located in the community of Whitehouse,
Duval County, Florida, approximately 10 miles west of
Jacksonville on U.S. Highway 90 (Figure 1). The site occupies
seven acres of upland area immediately adjacent to a cypress
swamp system and residential area. The northeast tributary of
McGirts Creek traverses the north site boundary.
3.0 SITE HISTORY
The Whitehouse Site was used by Allied Petroleum Products
(Allied), a waste oil re-refinery, for the disposal of acidic
waste oil sludges from its oil reclamation process. In the
reclamation process, contaminants were removed from waste oil by
treatment with concentrated sulfuric acid which precipitated most
of the additives and sediment as well as a large portion of the
metals and other contaminants in the waste oil.
The oil was then typically vacuum-distilled and finished by
decolorizing with clay. The acid sludge produced in the first
step and the clay used to finish the oil were then dumped into
the unlined pits at the site.
Between 1958 and 1968, Allied constructed and filled seven pits
at the site (Figure 2). In 1968, Allied filed for bankruptcy and
ceased re-refinery operations. In the 1970s, the City of
Jacksonville and others acquired portions of the site as a result
of the nonpayment of back taxes.
In 1968, Pit 7 ruptured, spilling its contents into McGirts
Creek. The Jacksonville Mosquito Control Branch, in an attempt
to control future spills from other pits, began building an oil
water separator. This project was never completed.
-2-
16
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1.500 3,000 FEET
1.000 METERS
SITE LOCATION MAP
WHITEHOUSE WASTE OIL PITS SITE
FIGURE 1
DUVAL COUNTY, FLORIDA
OASCO 9EMVCCS MCOWOMTED
OWG1HW-
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DROPSTRUCTURE
FLOW DIRECTION
TOE OF SLOPE
TREATMENT PLANT ABEA
WOODED AREA
EDGE OP DISTURBED ARK A
NORTHEAST TRIBUTARY OF
McGIRTS CREEK
SOUTH DITCH
<;RAYSON ST
TO McGIRTS CREEK
MACHELLE DR
ADOPTED FROM: UNA I. REPORT.
THE WIIITEIIOUSE OIL PITS, DUVAL C*. FLA
srre ASSESSMENT
BUREAU Or OPERATIONS, FDER. DEC. I MI
SITE CHARACTERISTICS MAI'
WHITKIIOUSi: WASTE OIL PITS SITE
DUVAL COUNTY, FLORIDA
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In 1976, following a 200,000 gallon waste oil spill which
occurred during dike wall reconstruction by the Jacksonville
Mosquito Control Branch, EPA's Region IV Emergency Response
Branch became involved at the site. With the City of
Jacksonville's assistance, EPA constructed a treatment system to
drain the liquid portion of the pits. Following the pit
draining, the City of Jacksonville attempted to stabilize the
pits with construction debris, automobile shredder waste, scrap
lumber, trees, wood chips, etc. The automobile shredder waste
layer was then covered with a Fullers Earth/Oil Sludge mixture.
The pits were then capped with Fullers Earth and local clay.
Surface water diversion ditches which included limestone
neutralization pits were constructed.
In 1979, under the supervision of the Florida Department of
Environmental Regulations (FDER), the City of Jacksonville capped
the pits with clay and topsoil. Diversion ditches were modified
following vandalism.
In 1982, the site was placed on the National Priorities List
(NPL). Following the NPL listing, EPA conducted a search for
Potentially Responsible Parties (PRPs). However, viable PRPs
were not located at that t~e due to the scarcity of site
operating records.
In 1983, FDER completed a "Remedial" Site Investigation (RI)
under a cooperative agreement with EPA. The RI characterized
site wastes and the extent of contamination.
In 1985, EPA conducted a FS which evaluated remedial alternatives
for the site. Based on the findings of the RI/FS, EPA signed a
Record of Decision in 1985 which selected a remedial alternative
consisting of Slurry Wall construction, Surface Capping, and
Surface and Groundwater Recovery and Treatment as the most
effective overall source control remedy.
-5-
19
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In 1988, EPA initiated Remedial Design (RD) activities. A
Preliminary Design Analysis of the RD was conducted under
contract with the U.S. Army Corps of Engineers. Subsequent to
the Design Analysis, activities were discontinued. Pursuant to
SARA, EPA re-evaluated the 1985 ROD "containment" selection in
search of alternatives that provide treatment which permanently
and significantly reduces the mobility, toxicity and volume of
hazardous substances.
In 1989, EPA renewed its search for PRPs and was able to identify
a group of PRPs.
In 1990, EPA conducted a Risk Assesment to provide an updated
assessment of risks to human health and the environment. In 1990
and 1991, General Notice Letters were issued to a number of PRPs.
In 1991, EPA conducted a TS to examine a treatment train
consisting of Soil Washing, Biotreatment and S/S as viable
technologies for the Whitehouse Site. EPA also conducted a FS to
evaluate present RA alternatives.
In July or August of 1992, EPA will issue Special Notice Letters
to PRPs.
4.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
Minimal community involvement has occurred since 1985, despite
EPA's efforts to keep the community informed of activities at the
site.
The Risk Assessment, TS and FS documents were released to the
public on January 3, 1992. The documents were added to the
Administrative Record (AR) and made available for public review
at the following locations:
o
EPA Region IV (Docket Room)
-6-
20
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o
Whitehouse Elementary School (Site Repository)
EPA published a notice in the Florida Times Union newspaper on
January 16, 1992 notifying the public of EPA's upcoming Proposed
Plan Public Meeting on the site, the availability of the
Administrative Record and the thirty day public comment period.
A public meeting was held at the Whitehouse Elementary School on
January 30, 1992. At this meeting representatives from FDER and
EPA answered questions and addressed community concerns.
Responses to comments received during the public comment period
are included in Appendix B (Responsiveness Summary).
A thirty (30) day public comment period was established from
January 29, 1992 to February 28, 1992. Upon request from several
Potentially Responsible Parties, the public comment period was
extended an additional 30 days, ending on March 29, 1992.
5.0
SCOPE AND ROLE OF AROD WITHIN SITE STRATEGY
The major goal of the remedy selected in this AROD is to treat as
much of the contaminant source as possible to prevent
contaminated groundwater in the surficial aquifer from migrating
laterally off-site and to prevent the potential of vertical
migration downward into the Floridan aquifer. The surficial
aquifer under the site is contaminated with heavy metals,
primarily lead, which exceed both State and Federal drinking
water standards. The surficial aquifer is the source of drinking
water for local residents and contamination presents a threat to
human health. The clean-up objectives for this AROD are to
prevent current or future exposure to the contaminated
groundwater.
-7-
21
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6.0
SITE CHARACTERIZATION
6.1
Surface Drainage
The Whitehouse Site is located in the McGirts Creek drainage
basin. Local surface drainage flows toward the northwest
tributary of McGirts Creek approximately 1,200 feet away. Past
berming and capping operations raised the site 5-7 feet. The
present elevation surface drainage flows toward the northeast
into the northeast tributary of McGirts Creek and southwest into
a man-made drinage ditch. The soil cap over Pits 1 and 7 are
presently deteriorating allowing waste oil sludges to reach the
surface.
6.2
HydrO-Geology
The Whitehouse Site is underlain by a shallow aquifer system
which flows southwest and a deeper Floridan aquifer system which
flows south. The total thickness of the shallow aquifer system
is approximately 500 feet. The total thickness of the Floridan
aquifer system is greater than 2,000 feet.
The shallow aquifer system is comprised of un-differentiated
Holocene and Pleistocene age sediments deposited during the
formation of marine terraces and beach ridges. Holocene and
Pleistocene deposits primarily consist of fine to medium grained
loose quartz sands, iron oxides and sandy clay beds containing
mollusk shell material. Underlying Pliocene and upper Miocene
deposits consist of sand, shell, sandy clay and limestone. A
limestone deposit at a depth of approximately 112 to 140 feet is
the major water-yielding zone. Most private wells obtain water
from this system. Middle to lower Miocene deposits consist of
sand, sandy silt, clayey sand, clay and sandy limestone, all of
which contain moderate to large amounts of phosphate sand,
granules and pebbles.
-8-
22
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The Floridan aquifer system is comprised of limestone deposits.
7.0
RISK ASSESSMENT
CERCLA as amended by SARA establishes a national program for
responding to releases of hazardous substances into the
environment. The NCP, which is the regulation that implements
CERCLA, establishes the overall approach for determining
appropriate remedial actions at Superfund sites. The overall
mandate of the Superfund program is to protect human health and
the environment from current and future threats posed by
uncontrolled hazardous substance releases.
As part of EPA's re-evaluation of the 1985 ROD and in order to
assess current and future exposure risks for the Whitehouse Site,
a Risk Assessment was conducted as part of the RI/FS process.
This section summarizes the exposure risks associated with the
site's environmental media.
7.1 Contaminants of Concern
Sampling data from the site's media (soils, sediments, surface
water and groundwater) were examined and compiled to produce a
list of all contaminants. This list was reduced according to the
Risk Assessment Guidance for Superfund: Volume 1; Human Health
Evaluation Manual (RAGS: EPA/540/1-89/002) methodologies (grouped
by chemical class and screened using frequency of detection in
each media, essential nutrient information, anthropogenic
comparison, association with site activities, background
comparison, and a.concentration-toxicity screen). The resulting
list of contaminants, deemed "chemicals of concern", include
contaminants that are the most toxic and represents 99 percent of
the risk thus being carried into the risk calculation procedure.
EPA's Risk Assessment also took into consideration sampling data
from exposed wastes. "Exposed wastes" by definition are areas of
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waste seepage or boils which are located primarily at the
northeastern end of the site. The media along with the
contaminants of concern are listed in Appendix C: Table 1.
Hazardous substances detected at the site can be placed into two
broad categories (carcinogens and non-carcinogens). The
carcinogens associated with the site are not numerous. Soil
localized carcinogens include 1,4-Dichlorobenzene, Methylene
Chloride, 1,1,2,2-Tetrachloroethane, and Tetrachloroethene.
There are no surface water carcinogens. PCB 1260 was the only
carcinogen in the exposed wastes. Trichloroethene and
Isophorone, also carcinogens, were localized to surficial
groundwater while no carcinogens were found in deeper
groundwater.
The noncarcinogens associated with the site include
Chlorobenzene, 1,4-Dichlorobenzene, Methylene Chloride,
Naphthalene, Tetrachloroethene, Toluene, 1, 1, I-Trichloroethane,
Acetone, and Methylisobutyl Ketone in soils. The surface water
noncarcinogens were Carbon Disulfide and Manganese. Exposed
wastes contained non-carcinogens Antimony, Barium, Copper, Lead,
2-Methylnaphthalene, 3,4-Methylphenol, Naphthalene, and Zinc.
Shallow groundwater contained non-carcinogens Carbon Disulfide,
Acetone, Toluene, Xylene, Antimony, Barium, Chromium, Copper,
Manganese, Nickel, Selenium, Vanadium, Zinc, 3,4-Methylphenol,
and Naphthalene. Deep groundwater noncarcinogenic contaminants
include Antimony, Barium, Chromium, Copper, Manganese, Nickel,
Zinc, 1,4-Dichlorobenzene, and Naphthalene.
The exposure concentrations developed based on the range of
contaminant concentrations are called the "Reasonable Maximum
Exposure"
7.2.
(RME) .
RME determination will be discussed in Section
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7.2 Exposure Assessment
The exposure assessment characterizes potential routes or
pathways of exposure for contaminants of concern to reach
receptors. The exposure pathways used in risk prediction
encompass current and future scenarios which include:
Current:
Future:
1)
Ingestion and dermal absorption of soils and
exposed wastes
dermal absorption of contaminants in surface water
ingestion of vegetables grown in contaminated soils
2)
3)
1)
2)
3)
Ingestion and dermal contact with soils
ingestion of vegetables grown in contaminated soils
inhalation of volatiles while irrigating vegetable
crops
ingestion of vegetables contaminated by groundwater
ingestion of groundwater
inhalation of volatiles during showering
dermal absorption of contaminants while showering
exposure to contaminants released from landfill
waste
4)
5)
6)
7)
8)
The populations to be examined include nearby residents and
trespassers as well as future residents.
The exposure point concentrations for each contaminant in each
medium were calculated using the 95% upper confidence Ibmit on
the arithmetic average.. This value is deduced by comparing the
95% upper confidence limit of the arithmetic average to the
maximum concentration and the lower of the two is selected. This
will be the RME concentration to be carried into the Risk
25
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Assessment.
The RMEs for the contaminants per media are listed
in Appendix C: Table 1.
Modelling was used to predict exposure concentrations for
groundwater to air mass discharge rates. First the air
columetric flow rate was determined to be 133 m3/sec which was
then used to calculate the concentration in air (as described in
the Superfund Exposure Assessment Manual: EPA/540/1-88/001).
Root uptake factors which were used to predict vegetable uptake
of contaminants from soil were calculated using the method from
Baes et al., (1984). Ground water contaminant concentration used
in irrigating homegrown vegetables involved a simple conversion
based on the total predicted amount of irrigation water used per
land area (3100 1/m2). This water amount was then factored with
the contaminant concentration in ground-water and corrected for
the amount of water that would actually reach the root zone (top
20 cms). EPA's Uptake Biokinetic Model was used to predict blood
lead levels (in various age groups) from lead concentrations in
various media.
A model was also used as a tool to predict future increases in
groundwater contamination from pit waste. The first step in this
two part model involved the use of a dilution equation to predict
chemical concentrations in the infiltrate that upon reaching
groundwater might result concentrations which exceed acceptable
health-based or ARAR-based groundwater limits. Total rainfall
was 51.47 inches/year (NOAA 3D-year average), evapotranspiration
was 41.41 inches/year (thornthwaite potential-based), runoff was
o inches/year, and infiltration was 9.96 inches/year. Chronic
daily intakes were calculated using the methods specified in
RAGS. All pathways were developed for ages D through 75 years.
If assumptions differed from that of the guidance manual (i.e.,
values drawn from other agency developed documents), such values
are listed in Appendix C: Tables 2 through 4.
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Present and future soil ingestion scenario assumptions (Appendix
C: Table 2) which include standard ingestion values of 100 and
200 mg/day for children and adults respectively. Soil exposure
frequencies ranged from 180 to 365 days/year which corresponded
to age ranges 0-1 to 18-75. Ingestion absorption factors were
applied at 50% for semivolatiles and metals while 100% was used
for volatile organics. Dermal absorption factors of 1.2%, 5%,
and 1% for semivolatile organics, volatile organics, and metals
respectively were used. Skin surface areas ranged from 1700 to
2000 cm2/event according to the age groups employed (0-1 through
18-75).
The exposure parameters used in surface water exposure are listed
in Appendix C: Table 3. This route focused on age groups 7-11
and 12-17. The duration of dermal exposure ranged from 5 years
(ages 7-11) to 6 years (ages 12-17) while the frequency of
exposure ranged from 52 days/year (ages 7-11) to 10 days/year
(age 12-17). Skin surface areas of 3800 cm2 and 5900 cm2 were
used for ages 7-11 and 12-17 respectively.
The exposure assumptions for groundwater ingestion are listed in
Appendix C: Table 4. Ingestion volumes of 1 liter for age groups
up to 11 years were used while 2 liters were utilized for the 12
to 75 age groups. Ingestion exposure frequencies were 365
days/year. In the inhalation route (during irrigation) the 0-1
age group was not examined. Inhalation frequencies of exposures
of 122 days/year were used in all remaining age instances.
Inhalation rates ranged from 0.83 m3/hr (ages 2-6) to 2.50 m3/hr
(ages 18-'5). In both ingestion and in inhalation, absorption
factors of 1 were' used.
Vegetable ingestion scenarios were not carried through the Risk
Assessment because the contaminant concentrations predicted to be
available in soils for uptake by root crops, leafy crops, and
non-leafy crops did not exceed background concentrations.
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7.3
Toxicity Assessment
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)-l
are multiplied by the estimated intake of a potential carcinogen,
to provide an upper-bound estimate of the excess lifetime cancer
risks associated with exposure at that intake level. The term
"upper bound" reflects the conservative estimate of the risks
calculated from the CPF. Use of this approach makes
under-estimation of the actual cancer risk 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.
References doses (RfDs) have been developed by EPA for predicting
the potential for adverse health effects from exposure to
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 that are thought to be without adverse affects.
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 ensure that the RfDs will not underestimate the potential
for adverse noncarcinogenic effects to occur.
The CPFs and RfDs for the contaminants of concern are listed in
Appendix C: Tables 5 and 6 respectively.
Both sets of numbers
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were extracted from either Integrated Risk Information System
(IRIS) or Health Effects Assessment Summary Tables (HEAST).
Toxicity information for each chemical of concern are also listed
in Appendix C: Tables 5 and 6. Overall, the target organs that
exhibit increased cancers include the liver by oral route and the
lungs which are the inhalation route's primary target organ. The
target organs/systems that might possibly be affected by the
site's noncarcinogens are diverse. These range from the liver
and kidney to skin, muscle, central nervous system (CNS), and
blood. The liver and kid~eys are primarily affected by the
site's organic volatile constituents such as Methylene Chloride,
Acetone, 1,2-Dichloroethene, 4-Methyl-2-pentanone,
Tetrachloroethene, and Chlorobenzene.
Note that fetotoxicity can be a problematic consequence of
exposure to either Phenol or Carbon Disulfide. Inhalation
toxicities range from simple irritation in the upper respiratory
tract (Xylenes and Toluene) to liver, kidney, CNS, and cardiac'
affects (1,4-Dichlorobenzene, 4-Methyl-2-pentanone, Manganese,
and Cobalt).
7.4
Risk Characterization
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., 1X10-6 or 1E-6). An excess lifetime cancer risk of 1X10-6
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
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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.
The chemical specific risk quantification results and hazard
indices per media are listed in Appendix C: Tables 7 through 13.
When combined (per media and across pathways) the resulting
carcinogenic risk for all current scenarios is 3.5X10-5 which
falls within EPA's acceptable risk range (10-4 through 10-6). The
total risk for the future scenario is 2.0X10-6 which is also
acceptable. The hazard indices for the current scenarios total
0.16 while the total for the future scenarios equals 16.9 both of
which are unacceptable (>1). This summary information is located
in Appendix C: Table 14. Lastly, it is noted that the hazard
index for the 0-1 years age group was slightly higher than the
2-6 years group. While risk managers should be aware of this
fact, it is important to know that said pathway is extremely
conservative thus the 2-6 group's values are probably more
realistic while also providing a suitable cleanup level that
would be protective of all age groups reported herein.
As predicted by the Uptake Biokinetic Model, lead levels in
groundwater and exposed wastes are unacceptable. Said model is
used in the absence of chronic toxicity values (RfDs) to predict
blood lead levels in sensitive age group populations. The
concentrations per media applied in this application included
0.33 ug/day (from surface soils), 56 ug/day (from exposed
wastes), 8.1 ug/day (from vegetables), and 306 ug/day (from
ground-water). Said model predicted blood lead levels ranging
from 127 ug/dl (ingestion of shallow drinking water) to 23.2
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ug/dl (incidental ingestion of exposed wastes). Predicted levels
that fall outside the acceptable range of 10 ug/dl are suggested
to be associated with neurological effects and nervous system
damage in children.
7.5
Environmental Evaluation
An environmental evaluation was performed as part of the Risk
Assessment. This evaluation procedure included: 1) a review of
the chemical concentrations in various media to establish the
presence, concentration, and spacial variability of specific
toxic chemicals, 2) an ecological survey to establish current
impacts to flora/fauna, and 3) toxicity comparisons to establish
a link between toxicity of the wastes and adverse ecological
effects.
The Ecological system of primary concern is the McGirts Creek
tributary which is located two-hundred feet north of the site. A
cypress swamp tributary system surrounds the site and empties
into this creek. This system was reportedly impacted according
to past sampling and observation primarily from releases along
the northeast branch tributary. In 1980, samples demonstrated
that Chromium, Lead, Zinc, Iron, and Cadmium were present in
waters around the site's tributary ditch system. No macro-
invertebrate populations could be located 100 yards downstream of
the oil pits in the northeast tributary. Also during that year,
FDER conducted a biological survey downstream in McGirts Creek
which revealed that the system was under stress. In 1982
inspectors noted dense vegetation and the presence of small fish
. along the stream bank which indicated that the system was
improving.
During EPA's 1990 site investigation, EPA observed that the
stream adjacent to the site was half dry with a brownish tinge.
No fish or amphibians were observed. No stressed vegetation was
observed. Sediment samples were devoid of contaminants while
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surface water samples indicated the presence of Aluminum, Barium,
Lead, Manganese, Zinc, and Carbon Disulfide.
Appendix C: Table 15 qualitatively compares various ARARs
(including State of Florida Surface Water Quality
Classifications) to the sampled concentrations. Note that
Aluminum, Manganese, Zinc and Carbon Disulfide exceed listed
ARARs .
Threatened and endangered species localized to the entire state
of Florida include the Florida Panther, Bald Eagle, Bachman's
Warbler, Ivory-billed Woodpecker, Red-cockaded Woodpecker,
American Alligator, and the Eastern Indigo Snake. Duval county
is a critical habitat for the Florida Manatee. Though none of
these species have been observed at the site, the possibility for
such an association on or near the site remains possible.
8.0 AROD ALTERNATIVES CONSIDERED
Remedial Alternative Development
The 1985 ROD remedy was based on an estimated contamination area
volume of 127,000 cubic yards. This estimate is based on the
entire site (pits and surrounding area). The 1985 ROD remedy has
been re-evaluated in the FS and this AROD as Alternative 2.
Alternative 2 uses the same volume estimate found in the 1985
ROD.
As part of EPA's 1991 FS, waste volumes estimates were
re-calculated to establish a basis for comparison of remedial
Alternatives 3 and 4 in the treatment of only the pit wastes. TS
field trenching data (Ebasco 1990) in conjunction with previous
investigation survey maps were used in the pit waste
calculations. Calculations assumed straight wall pits. The
earth cap was not part of this estimate. The FS concluded that
approximately 56,660 total cubic yards of waste exists within the
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seven
yards
and 4
pits. To allow for imprecise excavation, 56,930 cubic
of pit waste would require remediation. FS alternatives 3
are based on this estimate.
The FS also includes cost estimate break-down tables on present
worth Capital and Operation and Maintenance (O&M) costs for
alternatives 1-4. O&M costs were calculated for a period of 30
years although the RA is not expected to take that long.
Remedial Alternatives
The following remedial alternatives were evaluated in the 1991 FS
and this AROD:
o
Alternative 1 - No Action
o
Alternative 2 - Slurry Wall, Surface Cap and
Groundwater Recovery & Treatment (1985 ROD)
o
Alternative 3 - Soil washing, Biotreatment, s/S and
Groundwater Recovery & Treatment
o
Alternative 4 - S/S and Groundwater Recovery &
Treatment
8.1 AI ternati ve 1 - No Action
The No Action
the NCP to be
It provides a
alternative is required by Section 300.430(e) of
considered in the detailed analysis of this AROD.
baseline for comparison of other alternatives.
Under Alternative 1, no source control remedial measures would be
undertaken at the site and no further effort would be made to
restrict potential human exposure to contaminants. Given the
nature of the contaminant source, natural soil flushing is not
expected to reduce soil contamination to below clean-up criteria.
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The present worth cost estimate for Alternative 1 is as follows:
Capital:
(O&M):
$
$
62,000
o
62,000
8.2 Alternative 2 - Slurry Wall, Surface Cap and
Groundwater Recovery & Treatment (1985 ROD)
Under Alternative 2, a slurry wall would be constructed around
the entire site. The slurry wall would be keyed into the
aquitard. The area within the slurry wall would be capped to
control drainage and to eliminate direct exposure of the soil /
sludge wastes.
Groundwater extraction wells would be installed around the site.
Groundwater would be recovered from these wells and treated prior
to discharge to an on-site drainage ditch which flows into the
northeast tributary of McGirts Creek.
The present worth cost estimate for Alternative 2 is as follows:
Capital:
O&M:
$
$
5,300,000
6,200,000
11,500,000
8.3 Alternative 3 - Soil Washing, Biotreatment, S/s and
Groundwater Recovery & Treatment
Under Alternative 3, all seven pits would be subject to
excavation. Pit soil/sludge wastes would be excavated to varying
depths according to the confines of each pit. Excavation depths
would be limited by the groundwater table at the time of
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excavation. Excavation would be performed during a seasonal low
water table period to maximize excavation depths.
Excavated soil/sludge wastes would then be screened to remove
coarse material (construction debris, stumps, etc.). Coarse
material would be steam cleaned prior to off-site disposal.
Screened soil/sludge wastes would then be slurried with water
and/or surfactants in a soil washing unit to suspend contaminant
fines in the wash-water. The coarse soil (> 200 mesh) would be
. I
separated from the wash-water and suspended fines « 200 mesh).
Screened coarse soils below clean-up goals would be placed back
on-site into the excavated area. Screened coarse soils above
clean-up goals would be subject to S/S prior to backfilling
on-site.
Suspended contaminant fines « 200 mesh) would then be subjected
to biotreatment to remove contaminants from the waste stream
through microbial degradation.
Biotreated effluent would then be treated prior to discharge to
an on-site drainage ditch.
S/S would then be used to treat contaminant fines which
biotreatment could not adequately treat.
Groundwater extraction wells would be installed
Groundwater would be recovered from these wells
to discharge to an on-site drainage ditch which
northeast tributary of McGirts Creek.
around the site.
and treated prior
flows into the
The present worth cost estimate for Alternative 3 is as follows:
Capital:
O&M:
$
$
15,500,000
3.400.000
18,900,000
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8.4
Alternative 4 - S/S and Groundwater Recovery &
Treatment
All seven pits would be subject to excavation. Pit soil/sludge
wastes would be excavated to varying depths according to the
confines of each pit. Excavation depths would be limited by the
groundwater table at the time of excavation. Excavation would be
performed during a seasonal low water table period to maximize
excavation depths.
Excavated soil/sludge wastes would then be screened to remove
coarse material (construction debris, stumps, etc.). Coarse
material would be steam cleaned prior to off-site disposal.
Screened soil/sludge wastes would then be S/S and placed back
on-site into the excavated area.
Groundwater extraction wells would be installed around the site.
Groundwater would be recovered from these wells and treated prior
to discharge to an on-site drainage ditch.
The present worth cost estimate for Alternative 4 is as follows:
Capital:
O&M:
$
$
20,900,000
3,400,000
24,300,000
9.0 COMPARATIVE ANALYSIS
This section provides the basis for determining which alternative
(i) meets the threshold criteria for overall protection of human
health and the environment and has compliance with ARARs (ii)
provides the "best balance" between effectiveness and reduction
of mobility, toxicity or volume through treatment,
implementability and cost (iii) has state and community
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acceptance. A glossary of the evaluation criteria is provided in
Appendix C: Table 16.
9.1 Overall Protection of Human Health and Environment
Alternative 1 would not be protective of human health and the
environment because it would not reduce the level of risk.
Exposure pathways would not be removed nor would contaminant
migration be eliminated. Therefore, Alternative 1 will not be
considered further in this comparative analysis as a remedial
alternative option.
Alternatives 2, 3 and 4 would be protective of human health and
the environment. Alternatives 2, 3 and 4 would reduce the level
of risk via removal of the direct contact exposure pathway and
the groundwater ingestion pathway. Alternatives 3 and 4 would
reduce contaminant migration.
9.2
ARAR Compliance
Alternatives 2, 3 and 4 would effectively meet all respective
ARARs. However, Alternatives 3 and 4 might require treatability
variances if SIS admixture formulations do not meet TCLP
standards.
9.3
Short-Term Effectiveness and Permanence
Alternatives 2, 3 and 4 would achieve short-term effectiveness
and permanence. Alternative 2 would remove the direct contact
exposure pathway via surface capping. Alternatives 3 and 4 would
remove the direct contact exposure pathway via' excavation and
treatment of pit wastes. Alternatives 2, 3 and 4 would also
remove the groundwater ingestion exposure pathway via groundwater
recovery and treatment.
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9.4
Long-Term Effectiveness and Permanence
Alternatives 2, 3 and 4 would achieve long-term effectiveness and
permanence. Alternative 2 would remove the direct contact
exposure pathway via a long-term containment system consisting of
slurry wall construction and surface capping but would leave the
contaminant source in place. Alternatives 3 and 4 would remove
direct contact exposure via excavation and treatment of pit
wastes. Alternatives 2, 3 and 4 would also remove the
groundwater ingestion exposure pathway via long-term monitoring
of groundwater recovery and treatment.
9.5
Mobility, Toxicity and Volume (KTV) Reduction
Alternatives 2, 3 and 4 would reduce MTV in varying degrees.
Alternative 2 would reduce Mobility via slurry wall construction,
Toxicity via groundwater recovery and treatment but would not
reduce Volume. Alternatives 3 and 4 would reduce Mobility via
treatment of pit wastes, Toxicity via treatment of pit wastes and
groundwater recovery and treatment and Volume via treatment of
pit wastes although some volume increase would occur as a result
of stabilization activities.
9.6
Lmplementability
Alternatives 2, 3 and 4 would be technically and administratively
feasible to implement in varying degrees. Alternative 2 would be
technically and administratively feasible to implement because
slurry wall construction and surface capping are proven
technologies. Alternative 3 would require technical design
considerations due to the intricacies of the treatment train but
it is administratively feasible. While proven technologies on
other sites, these technologies are still undergoing evaluation
on site-specific wastes. TS results are favorable on Whitehouse
wastes but will need further studies in the RD to fine tune the
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technology train. Alternative 4 would be.technically and
administratively feasible. S/S is a proven technology.
9.7
Cost Effectiveness
Alternatives 2,. 3 and 4 would be cost effective in varying
degrees. Alternative 2 would be cost effective with Capital, and
O&M costs totaling $11,500,000. Alternative 3 would be more
costly with Capital and O&M costs totaling $18,900,000.
Alternative 4 would be the most costly with Capital and O&M costs
totaling $24,300,000.
9.8
State Concurrence
FDER concurs with Alternative 3 because it offers maximum
protection of human health and the environment by treatment of
pit soil/waste sludges through Soil Washing, Biotreatment, SIS
and Goundwater Rcovery and Treatment.
9.9
Community Acceptance
While Alternatives 2, 3 and 4 offer protection of contamination
to the Whitehouse community via groundwater recovery and
treatment, Alternatives 3 and 4 offer maximum protection by
treatment of pit soil/waste sludges. Based on comments made by
citizens at the public meeting held on January 30, 1992 and those
received during the public comment period, EPA perceives that the
community believes Alternative 3 would offer adequate protection
to human health and the environment.
10.0 AMENDED REDDY SELECTION
Alternative 3 is the 1991 AROD selected remedial alternative.
The Soil Washing, Bioremediation, S/S and Groundwater Recovery
and Treatment (Figure 3) technology train are described in
further detail below:
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39
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ST
M
EXCAVATION DEBRIS OVERSIZE DECONTAMINATION
REMOVAL AND DISPOSAL
UNDERSIZE
SAND SOIL WASH (VOCs;
BACKFILL SYSTEM
SAND FINES
(METALS) (IN SUSPENSION)
,
ABILIZED LleUI D/SOLIDS (VOCs) VOC
A TERlAL TREATMENT - OFF-GAS
SYSTEM " TREATMENT
-
ST ABILIZA TJON {Jt.TIERFLOW GRAVITY
- THICKENING -
(METALS)
OVERFLOW
WATER
TREATMENT
DISCHARGE TO POTW
ONSITE SURFACE WATER DISCHARGE
FIGURE 3
BIOREMEDIATION CONCEPTUAL PROCESS
FLOW DIAGRAM
WHITEHOUSE WASTE OIL PITS SITE
TREATABILITY STUDY
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ARCSIV\WHITEHOU\13-4934\TS
40
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All seven pits will be subject to excavation and treatment.
Estimated pit depths range from 6 to 14 feet. The purpose of
treatment is to eliminate the direct contact risk associated with
exposed pit soil/sludge wastes which occurs through soil cover
erosion. Treatment also reduces the leachability of waste
contaminants to the groundwater thus reducing the Groundwater
Recovery and Treatment time.
Clean-up levels have been established (Table 17). The entire
contents of each pit exceeding soil clean-up levels will be
excavated. Residual soils below the pit contents which are
contaminated above clean-up levels will be excavated. Excavated
soil/sludge wastes will be treated to clean-up levels prior to
placement back into the excavated area. Groundwater will be
recovered and treated to clean-up levels prior to discharge to an
on-site drainage ditch. Further sampling in the RD will
determine whether Pit 6 will be excavated due to low
contamination levels. Excavated pits will be sampled during RA
activities for quality control.
The RA will be performed during a low water table period to
maximize excavation depths. At the point where dewatering is
required to continue excavation as a result of groundwater table
influence, the excavation will cease. If the groundwater table
allows the entire excavation of all seven pits, the estimated
volume of wastes to be excavated will be 56,930 cubic yards.
Excavated wastes will be screened to remove coarse debris
(construction materials, stumps, etc.) from soils. Coarse debris
not amenable to treatment (Biotreatment or 5/5) will be steam
cleaned prior to disposal. It is anticipated that such debris
will be disposed off-site.
Screened .soils will then be slurried with water and/or
surfactants in a soil washing unit to suspend contaminant fines
in the wash-water. Coarse soils (> 200 mesh) will be separated
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from the wash-water and suspended contaminant fines « 200 mesh).
Screened coarse soils below clean-up levels will be placed back
on-site into the excavated area. Screened coarse soils above
clean-up levels will be subject to further soil washing and/or
S/S prior to backfilling on-site. The purpose of soil washing is
to reduce the volume of wastes requiring biotreatment.
Soil wash water and suspended contaminant fines will then be
biotreated to remove organic contaminants from the waste stream
through microbial degradation. The best demonstrated
biotreatment process for this site is a slurry-phase bioreactor.
Biotreated effluent below Florida surface water discharge
standards (Florida Water Quality Standards, Chapter 17-302) will
be discharged to an on-site drainage ditch. Biotreated effluent
above surface water discharge standards will be subject to
further biotreatment and/or treatment by the on-site groundwater
treatment system prior to discharge to an on-site drainage ditch.
The purpose of biotreatment is to reduce the volume of wastes
requiring S/S.
The groundwater treatment system will be designed to reduce
contaminants to below Florida surface water discharge standards.
The groundwater treatment system will also be designed with
sufficient capacity to accept Biotreated effluent without
modification. The groundwater treatment system will consist of
GAC adsorption and chemical precipitation units. The GAC
adsorption unit will be used to remove organic contaminants while
the chemical precipitation unit will be used to remove metals and
suspended solids.
S/s will then be used to bind contaminant fines (ie. heavy
metals) which biotreatment could not adequately treat. The S/S
monolith will be placed back into the excavated area. The
purpose of S/S is to retard migration of contaminants by binding
them in a stabilized matrix. Stabilization reagents might
include cement, pozzolans, organophylic clays, asphalt/bitumen
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and therrnoplacizers. TS results reveal that stabilized products
met specified strength parameters for Whitehouse wastes. S/S
formulations will be optimized in the RD to achieve the best TCLP
results.
A pilot-scale TS will be performed to further develop this
treatment train. A conceptual model of the treatment train is
included (Figure 3).
During remedial activities, provisions will be made to ensure
that McGirts Creek is protected from surface water runoff. A 6
inch vegetative cover will be placed over the excavated area
after remediation.
The EPA's Emergency Response Group is presently reviewing the
possibility of placing a fence around the site. Site fencing
will eliminate the possibility of direct contact to exposed
wastes by tresspassers. Any fencing placed on the site prior to
the RA may need modification during RA activities.
One goal of the RA is to restore the groundwater to its
beneficial use as a drinking water aquifer. Based on information
obtained during the RI and the analysis of all FS remedial
alternatives, EPA believes that the groundwater portion of the
1985 ROD selected remedy will be able to achieve present clean-up
goals with the exception of some heavy metals. Both GAC
adsorption and chemical precipitation units wil.l be used in the
groundwater treatment system.
It is estimated that the groundwater recovery and treatment
system will need to be operated for a period of 23 years in five
(5) year intervals. The effectiveness of the treatment system
will be carefully monitored on a regular basis and modified as
'warranted by performance data collected during operation.
Modifications may include any or all of the following:
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groundwater pumping may be discontinued at individual
wells where clean-up levels have been obtained with
continued monitoring
alternate wells may be pumped to eliminate
stagnation
wells may be pulse pumped to allow aquifer
equilibration and encourage adsorbed contaminants to
partition into groundwater
additional recovery wells may be installed to
facilitate or accelerate contaminant plume clean-up
Based on performance data, at the end of 5 years, if it is
determined that the treatment system is adequately reducing
contaminant levels toward the clean-up goals, the system will
continue for consecutive five (5) year periods. The
effectiveness of the treatment system in each 5 year period will
be determined in the same manner as the first 5 year period.
The selected remedy's ability to achieve this clean-up goal
cannot be fully determined until the groundwater recovery and
treatment system has been implemented and the groundwater plume
response monitored. Groundwater contamination may be especially
persistent in the immediate vicinity of the pits, therefore, the
effectiveness of the treatment system will need monitoring over
time.
In the event that the groundwater portion of the selected remedy
cannot meet all or a portion of the clean-up goals, the
contingency measures described in this section may replace the
groundwater portion of the selected remedy. Such contingency
measures will at a minimum, prevent further migration of the
groundwater plume and include a combination of containment and
institutional controls. The contingency measures are considered
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to be protective of human health and the environment and are
technically practicable.
Based on performance data, at the end of any 5 year period, if it
is determined that the treatment system is not capable of
adequately achieving all or a portion of clean-up goals, one or
more of the following contingency measures involving long-term
management may occur for an indefinite period of time:
containment measures would be implemented involving
enginee~ing controls such as physical barriers or
long-term gradient control through low level pumping
consideration may be given to a waiver of chemical-
specific ARARs for the aquifer based on the technical
impracticability of achieving further contaminant
reduction
institutional controls would be implemented and
maintained to restrict access to those portions of
the aquifer which remain above clean-up goals
on-site and off-site wells would be continually
monitored to ensure non-migration of contaminants
~ternative 3 will meet or exceed all ARARs. The bench-scale TS
suggested further modification of S/S reagent admixtures to
prevent leaching of Cadmium, Chromium and Lead. A pilot-scale TS
will be necessary as part of the RD to evaluate the ability of
the modified admixtures in reaching effective TCLP levels.
The decision to invoke any or all of these contingency measures
will be in accordance with CERCLA Section 121 (c).
In addition, as part of the RD, the northeast tributary of
McGirts Creek will be further sampled. Tributary sampling
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performed as part of the the TS/Risk Assessment revealed a
decrease in contaminants from previous sampling data collected.
Additional sampling will be performed to verify these findings.
11.0 Clean-up Goals
A range of organic and inorganic contaminants exist in varying
concentrations in pit soil/sludge wastes. Past releases of these
contaminants have presented and continue to present an imminent
and substantial endangerment to public health and the
environment. As a result, clean-up levels have been established
for soils (pit soil/sludge wastes) and groundwater.
Soil clean-up levels established in the Risk Assessment were
based on groundwater protection modelling. This modelling was
found to be overly conservative therefore, new soil clean-up
levels were established based on a direct contact exposure
pathway. These clean-up levels are applied to depth to reduce
contaminants available for migration to groundwater thereby
reducing the Groundwater Recovery and Treatment process time.
Whitehouse clean-up levels are listed in Appendix C: Table 17.
Groundwater clean-up levels established in the Risk Assessment
were based on human health risks (Risk-based) and ARARs (ARAR-
based) .
12 . 0 STATUTORY REQUIREMENTS
EPA has determined and FDER concurs that the selected remedy will
satisfy statutory requirements of Section 121 of CERCLA in that
it:
o
provides protection of human health and the
environment
o
utilizes permanent solutions and alternative
treatment or resource recovery technologies to the
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maximum extent possible
o
meets ARARs
o
is cost effective
Sections 11.1 thru 11.6 below summarize the statutory
requirements for this site.
12.1 Overall Protection of Human Health and Environment
Remedial Acrtions performed under CERCLA must be protective
of human health and the environment. The selected remedy
would meet this requirement due to contaminant reduction in
all media and the removal of exposure pathways.
12.2 Applicable, Relevent and Appropriate Requirements
Compliance
Remedial Actions performed under CERCLA must comply with
all ARARs. All alternatives ~onsidered for the Whitehouse
Site were evaluated on the basis of ARAR compliance. The
selected remedy would meet or exceed all ARARs. A pilot-
scale TS may be necessary as part of the RD to evaluate
the ability of modified admixtures in reaching effective
TCLP levels if Whitehouse wastes are found to be RCRA
characteristic wastes (D004 - D017).
FEDERAL REQUIREMENTS
Resource Conservation and Recovery Act (RCRA)
40 Code of Federal Regulations (C.F.R.) Part 261, Land Ban - The
RCRA Land Disposal Restrictions (LDRS) re-enacted in the 1984
Hazardous and Solid Waste Amendments (HSWA) require that RCRA
hazardous wastes be treated to Best Demonstrated Achievable
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Technology (BDAT) standards prior to placement into the land. At
present, not enough information exists to make a determination on
whether Whitehouse wastes are RCRA listed wastes. If Whitehouse
wastes are found to be RCRA listed wastes (D004 - D017), LDRs
will directly apply.
Clean Water Act (CWA) / Safe Drinking Water Act (SDWA)
EPA's determination of appropriate groundwater clean-up criteria
involved an evaluation of contaminant concentrations relative to
available Risk-based standards. Such limits, including ARAR-
based Maximum Concentration Limits (MCLs) and Maximum
Concentration Limit Goals (MCLGs), and Section 304 of the CWA
used as prescribed in Section 121(d)(2)(b)(i) of CERCLA also
defined in the SDWA.
Federal Clean Air Act (CAA)
The CAA identifies and regulates pollutants that could be
released during earth-moving activities associated with the
excavation of on-site soils. Section 112 of the CAA identifies
substances regulated under the Federal National Emission
Standards for Hazardous Pollutants for which there are no
applicable Ambient Air Quality Standards (AAQS).
considered an ARAR.
The CAA is
Endanqered Species Act (ESA)
The selected remedy is believed to be protective of species
listed as endangered or threatened under the ESA. Requirements
of the Interagency Section 7 Consultation Process, 50 CFR Part
402 will be met. The U.S. Department of Interior (001) and the
U.S. Fish and Wildlife Service will be consulted during the RD to
ensure that endangered or threatened species are not adversely
impacted by implementation of this remedy. There is currently no
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information to indicate that the site is visited by or contains
such species.
National Historical Preservation Act (NHPA)
The NHPA requires that action be taken to preserve or recover
historical or archaeological data which might be destroyed as a
result of site activities. No information exists to indicate
that the Whitehouse Site has any historic or archaeological
significance.
Federal OccuDationai Safety and Health Administration Act
(OSHA)
The selected remedial contractor would develop and implement a
health and safety program for its workers. All on-site workers
would meet the minimum training and medical monitoring
requirements outlined in 40 CFR 1910.
STATE REQUIREHENTS
Florida Administrative Code Chapter 1"1-3
Water quality standards for surface water and groundwater
affected by leachate and storm runoff from the site would be met.
Florida Administrative Code ChaDter 1"1-6
Effluent limitations and operating requirements for surface water
discharge would be met.
12.3 Long/Short Te~ Effectiveness & Permanence
Alternative 3 would be the most appropriate clean-up solution for
the Whitehouse Site and would provide the best balance in
remedial alternative evaluation criteria. This remedy would
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49
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provide long/short-term effectiveness in the protection of
potential human health and environmental receptors.
Soil washing, biotreatment and S/S represents a permanent
solution (through treatment) which effectively reduces and/or
eliminates mobility, toxicity and volume of hazardous wastes and
substances from the environment.
12.4
Cost Effectiveness
Cost effectiveness is determined by comparing the costs of all
alternatives being considered with their overall effectiveness to
determine whether the costs are proportional to tha effectiveness
achieved. Overall effectiveness for the purpose of this
determination includes long/short-term effectiveness, permanence
and mobility, toxicity and volume reduction.
The present worth cost estimate for Alternative 3 is as follows:
Present Worth:
O&M:
$ 15,500,000
$ 3,400,000
$ 18,900,000
The selected remedy affords overall effectiveness proportional to
its cost such that the remedy represents value for the money.
When the relationship between the cost and overall effectiveness
of the selected remedy is viewed in light of other remedies, the
selected remedy would be the most cost effective.
12.5
Utilization of Permanent Solutions and Alternative
Treatment or Resource Recovery Technologies to the ~~yimum
Extent Practicable
The objectives for this AROD are to treat pit
and prevent current or future exposure to the
groundwater in the surficial aquifar, through
soil/sludge wastes
contaminated
treatment and
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50
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containment, and to reduce the migration of contaminants.
Recovery and treatment of contaminants in the surficial aquifer
would achieve significant reduction in contamination at the
Whitehouse Site. The EPA will continue to evaluate long-term
effectiveness and permanence as part of the RA.
12.6
Preference for Treatment as a Principal Element
Bench-scale TS results indicate that Alternative 3 would
effectively treat Whitehouse soils contamination.
Soil Washing and Biotreatment have been demonstrated to
effectively reduce petroleum hydrocarbon contamination at other
Superfund sites. S/S is a widely used means for effectively
reducing metals contamination. Groundwater Recovery and
Treatment systems have been widely used in the treatment of
9roundwater and the containment of groundwater plumes.
Therefore, the statutory preference for remedies that employ
treatment as a principal element is satisfied.
12.7
Documentation of Significant Changes
The Proposed Plan for the Whitehouse Site was released for public
comment on January 3, 1991. The proposed Plan identified
Alternative 3 as the preferred remedial alternative for the
Whitehouse Site.
Based upon the requirements of CERCLA Section 117(b), EPA has
determined that a significant change has been made to the Risk
Assessment from the time of the Proposed Plan public comment
period. This change is an Addendum to the Risk Assessment in the
Administrative Record. The Addendum provides a basis for
remediation clean-up levels.
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51
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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 it was
originally identified in the Proposed Plan, were necessary.
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52
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APPENDIX A
1985 RECORD OF DECISION
53
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. - UNITED STATES ENVIRON..ENTAL PROTECTION AGENCylOther:
on[ AfAy 29 1985 -
)
IU8J[CT
Whitehouse Waste Oil Pits - Selection of Remedy, Authorization
for Design of Remedy
~..
Superfund Coordinator
TO
Thomas W. Devine
Director, wi5
Jack E. Ravan
Re~ional Administrator
The attached Record of Decision (ROD), when signed by you, viII
constitute the Agency's official selection of a remedy for the
Whitehouse Waste Oil Pits Site. The reco..ended alternative
(C-l) includes:
- Construction of a slurry .al1 around the entire site;
- Recovery and treatment of contaminated groundwater;
- Removal of contaminated sediments from the northeast
tributary of McGirts Creek, and
- Surface cap entire site.
This aemorandum will authorize us to obligate $600,000 to the
Corps of Engineers (COE) for des ion of this reaedy. We also
expect to have t~ge the eventual construction of the
remad¥. The State of Florida agrees with this course of action.
I recommend that you approve this memorandum to obligate desi~n
money to the COE, and also the attached ROD officially selecting
alternative C-l as the remedy for the Whitehouse Waste 011 Pits.
~~
r A~ Sml h
~!WD
¥
'>«(0
6~~ '"
«'v ,,2/-
V
Concur:
Approve:
~~1~-
Disapprove:
Date:
/1(7
ro
r /
/f'j7}-
f:. ,.. l:i~~ ca... S.H)
54
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0(;0002
RECORD OF DECISION
Remedial Alternative Selection
Documents Reviewed
I am basing my decision on the following documents describing the
analysis of the cost-effectiveness and feasibility of remedial
alternatives for the Whitehouse Waste Oil Pits Site:
- Remedial Action Master Plan, Whitehouse Site - Ecology'
Environment, Inc.
- Remedial Investigations: Phase I - .FDER/USGS, Phase II -
Ecology' Environment, Inc. (Appendix 1 & 2)
- Focused Feasibility Study, Whitehouse Waste Oil Pits Site,
Ecology & Environment, Inc. January 1985. (Appendix 3)
- Responsiveness Summary and Recommendations
- Summary of Remedial Alternative Selection
- State's position statement and 0&" commitment
Description of Selected Alternative
After a thorough review of all options, I have determined that
alternative (Cl) as detailed in the Feasibility Study and outlined
below is the appropriate remedy for this site. Alternative (Cl) -
containment of the wastes - includes:
- Construction of a slurry wall around the entire site,
keyed into the aquitard, isolating the waste~
- Recovery and treatment of contaminated groundwater within
the walled area, thus contributing to waste isolation
- Removal of contaminated sediments from the northeast
tributory of McGirts Creek and placing within the isolation
ar.a, and .
- Surface cap entire site to reduce the inflow' of water
into the walled area.
Declarations
Consistent with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), and the National
Contingency Plan (40 CrR Part 300), I have determined that the
55
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000003
-2-
on-site containment alternative (C-l) at the Whitehouse Waste
uil Pits Sit« is a cost-effective remedy and provides adequate
protection of-public health, welfare, and the environment. The
State of Florida has been consulted and agrees with the approved
remedy. In addition, the action will require future operation
and maintenance activities to ensure the continued effectiveness
of the remedy. These activities will be considered part of the
approved action and eligible for Trust Fund monies for a period
of one year.
I have also determined that the action being taken is appropriate
when balanced against the availability of Trust Fund monies for
use at other sites.
_
Efete Jack E.'Ravan
Regional Administrator
EPA Region IV
56
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000004
Summary of Remedial Alternative Selection
Whitehouse Waste Oil Pits
May 1985
SITE LOCATION AND DESCRIPTION
The community of Whitehouse, Florida (population approximately
6,000) is located within 0.25 miles east and southeast of the
site. The community is composed primarily of two-bedroom houses
and mobile homes on one-half to one-acre lots. Two major east-
west highways, U.S. Highway 90 and Interstate 10, are approximately
0.5 miles south of the site (Fig. 2-1, 2-2). A low-density
residential area is located west and northwest of the site, and
several miles northwest of the site is the Cecil Field U.S
Naval Air Station. The area north and northeast of the site is
largely undeveloped land comprised of pine forests and cypress
swamp.
The Whitehouse Waste Oil Pits occupy approximately seven acres
on an upland area immediately adjacent to a cypress swamp system
(Pig. 2-3). The southern side of the site is bordered by open
grassland, with the exception of the southwestern corner, which
is a private residence. The nearest home is approximately 300
feet from the diKe around the pits and a small backyard garden
at that home is approximately 30 feet from the south ditch.
The northern and western sides of the site border a swamp system
through which the Northeast Tributary runs. The stream originates
from a 220-acre cypress swamp located approximately 0.5 miles
upstream from the site.
The surficial and the Floridan are the two aquifer systems
which supply drinking water in this area. The Floridan is at a
depth of approximately 525 feet below the surface and supplies
large water users. It is separated from the surficial aquifer
system by the confining Hawthorn Formation which is about 350
feet thick in this area. The surficial aquifer system can be
subdivided into 3 parts: the water table zone, a semi-confining
(aquitard) tone, and the limestone unit (Fig. 2-4). The water
table son* begins at 1.5 to 5 feet below land surface and is
approximately 20 feet thick. The semi-confining zone exhibits
a hydraulic conductivity in the 10~5 to 10*6 cm/sec, range and
is about €0 feet thick. The final zone in the surficial system
is the limestone unit, locally known as the "rock* aquifer.
Local residents obtain their water from individual veils drilled
into this zone.
The shallow groundwater contributes to local streams through a
series of man-made ditches and natural drainage ways such as
the Northeast Tributary of McGirts Creek.
57
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nr,COOS
WHITEHOUSE
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Fig. 2-4 TYPICAL SUBSURFACE LITHOLOGY AT WHITEHOUSE OIL PITS
r
60
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OGCOU~
-2-
The site itself consists of seven unlined pits where waste oil
sludge, acid and contaminated waste oi1 from an oil reclaiming
process were disposed.
SITE HISTORY
Allied Petroleum constructed the pits to dispose of waste oil
sludge and acid from its oil reclaiming process. The first
pits were constructed in 1958, and by 1968 the company had
constructed and filled seven pits. Allied Petroleum then went
bankrupt, and most of the property transferred to the City of
Jacksonville for nonpayment of taxes. After they were abandoned
by Allied Petroleum, the pits remained an .open dump. for several
years. It is reasonable to assume that indiscriminant dumping
occurred o~ during that time.
In 1968 the dike surrounding Pit No.7 ruptured, and the
contents spilled onto adjacent private property and into McGirts
Creek. Pit No.7 vas backfilled vith soil after this incident.
Recognizing the need to control the vater level in the other
pits to prevent further discharge, the City of Jacksonville
Mosquito Control Branch began building a tvo-celloil-water
separator in series vith a limestone filter to dewater the
- pits. The project vas never completed because of budget problems.
On June 29, 1976, the EPA Region IV Environmental Emergency
Branch became involved folloving a 200,000-gallon oil spill
from one of the remaining six pits. The spill resulted when the
Jacksonville Mosquito Control Branch was attempting to repair a
dike vall. EPA took control of the spill assessment and the
cleanup of McGirts Creek and spent about $200,000 under provisions
of Section 311 of the Clean Water Act. EPA also recognized the
potential hazard posed by the remaining five pits, and with the
assistance of the City of Jacksonville, constructed a treatment
system in order to drain the pits.
. After draining the water from the pits, the Mosquito Control
Branch took measures to stabilize the ponds. Since the remaining
viscous waste oil sludge vould not support heavy construction
equipment, the ponds were backfilled with selected construction
debris, .crap lumber, trees, wood chips, and non-degradable
wastes. A three-inch layer of automobile shredder waste was
placed on top of this matrix. The more liquid portion of the
waste oil .ludge was pumped off, mixed with Fuller'. earth, and
then used as a backfill/sealer over the automobile .hredder
waste. This layer of Fuller's earth and 011 vas relatively
impervious and should have prevented vertical percolation of
rainwater. The Fuller's earth mixture was covered with eight
61 ."
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ar ~~:
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D
(i)
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--- ....
-
OROP 5 TRue TunE
FLOW DIRECTION
TOE OF SLOPE
TREATMENT PLANT AREA
PIT
UORTIIEAST TRIBUTARY OF r.,CGIRTS CREEK ~
-
...-
{:f)
. --
~
\ \
TO MCGIRTS CREEK
J:
U
t-
o
....
...t
_'H' --1
MACttEllE RO,
~
"''''1""'
1 ~~'8'J- 9 ~
-- --. - -. --~---
o
N
(~)
: ,
o
- - -
- --
SOUTH DITCH
- ------- --
GRAYSON ST.
& fiT - REGION IV
t~,'urll~)' /llIeI t~lIvin'IIII"'''f. iflC'.
.111'1 (OVINI . 'ON IlIfillWJ\ Y. IJl C J\ It III 1;10111.11
o
1---1
rElT
NOT TO SCAlE
- --" ~ - -
200
I
r Jr,lIlIf i'-l
',I T I St'rTUI
-------
OCOOiO
-3-
to twelve inches of clean earth (mostly sand). After the
project ran out of Puller's earth, local clay was substituted
as a landfill capping material for the Puller's earth and oil
mixture. A theoretical cross-section of the oil pit stabilization
plan is presented in Pigure 2-5.
After stabilization was completed, the site was planted in
local grasses and ditches were constructed to control drainage.
This system was destroyed by vandals, and subsequent monitoring
in 1979 showed the continuing release of pollutants to surface
water and groundwater.
Following this monitoring, the City of Jacksonville covered the
surface and sides of the pits and dikes with six inches of low-
perneability local clay, followed by twelve inches of topsoil.
This cover was revegetated using local grasses. The drainage
system was again modified and lined with clay to keep leachate
out of the surface water and drop structures were constructed
to control flow velocity and erosion. This arrangement diverted
surface water away from the landfill, thus reducing the mechanism
for pollutant transport. This second stabilization project was
completed in the summer of 1980. As an initial remedial action,
drainage was further modified to control leachate seepage into
the ditches along with steps to strengthen the dikes around the
pits.
CURRENT SITE STATUS ^
The waste oil recovery process used by Allied Petro Products
was the Acid-Clay Process. This process forms as byproducts a
waste-acid tar and spent acidic clays which are corrosive* The
seven unlined pits contained an estimated 127,000 cubic yards
of waste. Stabilization activities have increased the volume of
contaminated material to an estimated 240,000 cubic yards.
Contaminants Detected
Major contaminants at the site include hexavalent chromium,
arsenic, lead, phenols, benzene and PAH, (fluoranthene,
phenanthrene, pyrene).
Groundwater data showed arsenic (lOppb), chromium (68,000ppb),
lead (376ppb), benzene (9ppb), and phenols (330ppb) in the
shallow water table aquifer beneath the site.
Off-site groundwater data showed metals contamination
with a maximum concentration of chromium at lOppb.
Phenanthyrene was found at 710ppb at the 10' depth at one
location in soil.
Adjacent off-site surficial soils showed 7ppb chromium at
the 10' depth.
63
-------
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-
00
Zc
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-i
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. 4 '1' ':! tI.~ . ~
I
Fig. 2-5 THEORETICAL CROSS-SECTION OF THE FILLED OIL PITS
")
)
, )
-.)
..
UNKNOWN
t
200
11
" ..
8-12INCUES
I
~
CLEAN DIRT FILL
....-. - ...----
OIL/FULLERS EARTH
5-10lNCHES
3 INCitE S
AUTO SHREDDER WASTE
36 INCUE S
DIKE
DIKE
-- .---.- -
\
VISCOUS SLUDGE
NATIVE SANDV SOIL
I
-------
~
-4-
nron12
Surface water samples showed significantly lowered pH.
Improvements aade to the site by the City of Jack80nvile in
1980 and the initial remedial measures (IRM) done under cooperative
agreement with the State have 8ignificantly reduced the hazards
at the sit. and ensured that no large-scale spills would occur
again. Ero.ion continues to be a problem at the site. Testing
by the State indicated that heavy rains and eroding dike walls
have allowed pollutants to slowly seep into surface water. As
expected, soil samples from beneath the clay cap of the pits
show gross contamination by heavy metals and low levels of a few
organic compounds. The only 80ils beyond the pits which are
badly contaminated are the 80i18 in the 8wamp or floodplain
north of the pits, between the pits and the northeast tributary
(Fig. 2-3).
The quality of 8urface water was tested at five sampling stations
in the drainage basin. These 8amples show that the 8urface
water quality in McGirt8 Creek significantly improved since
1977. This improvement is directly related to the work done by
the local, state and federal agencies which prevented further
large scale contamination. However, the effect of the pits is
still evident 8ince the surface water contains heavy metals and
a lowered pH. The water quality of the creek is also
threatened by the 8eepage which has polluted the soil in the
- flood plain north of the pits.
Areas of potential groundwater contamination were located by
conductivity test8. Thirty-six wells at a variety of depths
were installed to sample groundwater. The 8hallow groundwater
(7-15 ft) between the pits and the northeast tributary ia
grossly contaminated by heavy metals and organic compounds.
Only low levels of organic compounds were detected across the
northeast tributary and beyond the 80uth drainage ditch. Thus,
shallow groundwater contamination seems to be localized close
to the site (Fig. 2-6).
Vertical migration has reached into the aquitard (35'-60').
The deeper wells (100-125 ft) close to the site show low levels
of heavy metals and organic compounds. This is of special
concern since these wells are in the same aquifer used by many
residents. All the re8idential wells near the site that were
downgradient of the pits were tested during the remedial
investigation. No contamination from the pits was detected in
any of the wells. The State will continue to monitor quality
of the residential wells.
Potential Pathways/and Receptors
Pathway
Ingestion/contact
Ingestion/contact
Receptor
McGirt'. Creek
Surface streams
Release
Surface Water
~rourAwater (lsteral)
65
r.
-------
'"
0"\
0"\
-
Fig. 2-6 COh I ~MINAN" MIGRATION
"J
("\
o
o
~
~
I
\
\
-------
*
OOC014
Ingestion Groundwater (vertical) Bedrock aquifer (domestic
wells)
Direct contact Waste on site Humans and animals
Inhalation Air Emissions (waste) Local population
The eventual receptor Cor surface runoff is McGirt's creek
which empties into the St. John's River approximately 10 miles
downstream. Neither of these bodies of water supply drinking
water, but are areas of environmental concern.
As late as 1983 (prior to completion of the IRM) seepage of
contaminated leachate through the dike walls was observed.
State bioassays using a weak concentration of the leachate
showed it to be very toxic. Direct contact with leachate and
leachate contaminated surface water is a concern.
The domestic water supply aquifer beneath the site is protected
by a fairly consistent aquitard. Sampling has shown contamination
in the shallow aquifer and evidence of contamination moving
down into the aquitard (permeability about 10~5 en/sec).
Groundwater degradation is an immediate concern and a reason
for taking preventative action.
Although the IRM was constructed as an attempt to reinforce the
dike walls and prevent further spread of contamination, this
measure is not adequate for long term containment of the waste.
To compound site problems, erosion caused by motorcycles, dirt
buggies, heavy rainfall and hurricanes pose additional risks
to all population groups surrounding the site.
The Whitehouse community has approximately 6,000 residents.
Almost all depend on groundwater from the 110'-160' deep "rock"
aquifer. In the area of the site there are approximately 255
users of water from the "rock" aquifer.
ENFORCEMENT
The Whitehouse Waste Oil Pits Site was established by Allied
Petro-Products, Inc. (APP) in the late 1950's for receiving
waste oil and acid clay sludges. The potentially responsible
parties known at the site are APP, Richard Peters - current property
owner, and the City of Jacksonville. However, both the Office
of Regional Counsel (ORC) and the program office recommended
not to identify the City of Jacksonville as a responsible party
because the city was an incidental owner by tax default.
Mr. Peters and APP were sent notice letters on March 5, 1982.
The letter to APP was returned unclaimed. Mr. Peters responded
to the notice letter by correspondence dated June 5, 1982. He
... does not appear to be a viable PRP at this time.
APP has been defunct for almost 18 years. In addition,
investigation by the ORC indicated that almost all of the
corporate principals have passed away and there are no facts
67
-------
000015
Problem
Waste
(Source Control)
Remedial Technology
1. Excavation and disposal in a secure
landfill off-site
2. Excavation and disposal in a secure
landfill or vault on-site
3. Excavation and thermal destruction on-
site or of f-site
fluidized bed
liquid injection
wet air oxidation
molten salt
starved air pyrolysis
rotary kiln
multiple hearth furnace
4. No action
Groundwater
Contami nat ion
1. Permeable treatment beds
2. Bioreclamation
3. Impermeable barriers
• slurry wall
• grout curtain
• sheet piling
4. Groundwater pumping and treatment
• biological (activated sludge,
anaerobic, aerobic, facultative
lagoons, support growth reactors)
• chemical (chlorination, photolysis,
oxidation, neutralization,
precipitation)
• physical (precipitation, carbon
adsorption, ion exchange, liquid ion
exchange, reverse osmosis, wet air
oxidation, ultrafiltration, stripping^
5. No action
Problem
Surface Water and
Soil Contamination
Remedial Technology
1. Surface seals
68
-------
'Of..C016
-6-
presently available that would suggest that the government
could reach the pri~cipals either by penetrating the corporate
~ntity or a. joint tort-feasors. We have discovered no
information ,linking the waste disposal to any presently existing
corporate entities 'either as generators or as auccessors to APP.
-
ALTERNATIVES EVALUATION
Response Objectives
Groundwater
Objective: To prevent further migration of contaminated
groundwater i~to the underlying aquitard: to prevent
contamination of the local drinking water ~upply.
Criteria: Groundwater quality to meet FDER Primary
Drinking Water Standards. pollutants with no standards
are to be kep~ to existing background concentrations or
minimal risk levels.
Surface Water
Objective; To reduce or eliminate migration of
contaminatiOG to surface water.
Criteria: su~face water quality to meet the State
water quality atandards.
Waste Sludges
Objective: To eliminate the aource, treat the source
to a less ha%~rdous or non-hazardous state, or contain
the release o~ hazardous polluta~ts off-aite.
Criteria: Surface water quality to meet the State
water quality standards.
Contaminated Soil and Sediment
Objective: To reduce or eliminate migration of
contaainated .oil and sediments.
Cri~eria: Acceptable concentrations of contaminants
migrating from aoils and sediments off-site to meet
background CDncentrations in adjacent .011. or .in1..1
risk levels.
Initial List of Al~ernatives
The following initi.l list of alternatives were evaluated for
this site:
69
r'
-------
'-- ,,'-''----
-8-
2 .
Diversion/collection structures
3.
Regrading and revegetation
4.
No action
Air Poll:..Jtion
1.
Thermal oxid~tion
2.
Vapor phase adsorpt!on
L
3.
No action
Contaminated Sediment/PCB's
1 .
Hydraulic dredging
Mechanical dredging
2.
3.
No action
Detailed Evaluation of Alternatives
The draft feasibility study included a detailed description of
17 alternative remedial actions. The 17 alternatives involve
different combinations of actions that fall within three main
options: 1) no action, 2) excavation, and ) containment.
In addition to handling the pit waste, some alternatives include
strategies to deal with contaminated groundwater and residual
contamination in the stream sediment left from the pit overflows
that took place in the last decade. To insure that rainfall
will not increase the movement of contaminants through percolation
or stormwater runoff, some alternatives include placing a clay
cap over the site. A complete list of alternatives for the
excavation and containment options can be found in Table I and
Table II. A summary of these options follows.
No Action Option - the site is left as is and monitored every
six month..
Excavation Options - The ten excavation options involve digging
up speclfic areas of the site and disposing of the contaminated
material in .ome fashion. The excavation option. differ primarily
by the area to be excavated and the disposal method used.
Three disposal methods were considered, the vault .ethod, the
landfill method and the incineration method. The vault .ethod
requires construction of an on-site cement lined cavity that
would be filled with excavated material. The off-site landfill
method requires that excavated material by hauled to a federally
i-.i
~'
70
r
-------
MSA v
Mir* Sit*
Fit* Only
Circk SedMtnl*
trnto
Vailt
Undfill On-»it»
Ilk inrr«t icn Oni le
IncincrMiat Off-*iu
lielntrrflat Of S1u%n Only
Inctnervtim Of Entire fit
Mi OUpoMl On-«il*
Arft DicyaMl Off-«ilc
antm VATCT
Oant W««r Ti**tnMit Oiv-«lt«
QvMtnictiai t>Mtlcrln| (ta^ormry)
Nrwnmt Urctian Wtlli
SUtf ACZ CAP
fcrf«c«> Oplntir* Site
Surf K* Cap r«rtul Site
TA»t« 1
or T ION •
• 1C A? AT IOM
| {
•
• * I « t I * B
m « « « « » K x ,
i
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• IKK
1 II
« « II
m K
m •
oooois
I
•
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' 4
« m . « • « • m. K B •
IB •• • « • » K m «
1 » « K
V
OUT (pr«i«< «prt») $12.611,000 »66.?*«.000 IIX.RM.OOO tlT.9T).000 W.IW.OOO fllO.IM.OOO SIM.76I.OnO JI17.Wl.OOO |?l,)M.Om $«/,.?W.OnO
-------
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;.," ,'.'»
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-~
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SLLRRY WAIL
Sltny Wall Aromd r.ntir~ Site
Siuny Wall A~ piu Onl,
PJ[('AYA1'mf
~at ion Selecttd ~- Other 11\181 piu
txavat ion Of CrM S~i.nu
QOHD WAT!R DP.A'MJfr
On1ite T~8b1Mt r.::i1ity
Conatruction ~terinl (ttlllpJ"8ry)
Pe~t btrection wplI.
StRFN% aP
s«f~ Cap &ttire Site
Surf~ Cap P8rtul Site
msr (p8ft1t tIOrth)
1
TAIL! II
"
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OPTIOIt C
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CJ.j
COltTAlltM!NT
0-1 C-2 0-3 G-4 c-~ ~
11 11 J(
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JI It
JI X JI It
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$1,049,000 $2,447,000 $2,122,000 $2,120,(0) $2,JJ8,OOO $1,991,(0)
-------
:ocoozo
-9-
apvroved hazardous waste landfill. The. on-site landfill requires
diapoaal of excavated materials in a double lIned facility
constructed on-aite. The incineration method involves burning
the excavated ..teriala in a rotary kiln or multiple hearth
furnace. The by-product of incineration is an ash that would
require di8poaal in a landfill.
In addition-to the disposal methods, the excavation options
vary with the area covered by a surface cap and the use of
groundwater treatment.
Containment Options
to prevent movement
options involve the
contaminated area.
- the 8ix containment options are designed
of-contaminants off-site. The containment
placement of a slurry wall around the
This option can be very effective in eliminating movement of
contaminated groundwater when used in conjunction with a
groundwater recovery and treatment system.
The containment options differ primarily in the area contained
and the use of groundwater treatment. The options also consider
excavation of certain areas and surface caps.
RECOMMENDED REMEDIAL ACTION
An important part of the feasibility 8tudy was to evaluate the
remedial alternatives and identify the most appropriate cost
effective alternative which meets the objectives. In addition
to the response objectives, other factors were used to evaluate
the alternatives. These factors included: capital coat,
operation and maintenance cost, level of cleanup, reliability,
special engineering considerations, implementability, environmental
effects (air, 8urface water, groundwater, 8oil/8ediments),-
legal constraint8, and time required for implementation. A
detailed evaluation was conducted by the engineering consultant
and is presented in the feasibility study. This evaluation is
summarized in Table III.
73
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Allernntive
[lIpU.I
PreDent
Mor t"
o .. H"
.. . ............
Tal
"'oI,llc ''''e1th
(onllidenliooll
~~,...,...
It
[ny I rOfWent.1
[Heelll
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T edm I r n I
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11,611
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269
Oneil not !lleet WI' re.ed 1111
rllllponse objeel hell. Proh..
hln cont-In.t Ion or re!ll-
dentllli wllter .upply. Prell-
enl ptJhllc hll811h thre.t
below relerence rlllk level.
IIo"ever, futllre IIIOr!lt-c.!lfI
IIllu.tlon Indlcatell un.c-
cept.ble level of rlllk.
ConUnuerl MlgnUm of con.
t..ln.t~1 grounrlw.ter 0((.
.Ile, lelldlng to JIO!t!llhle
rut lire cont_lnet Ion or
drlnklnq ".ler euppllell o(
.re. re!lldentll. [ontlnued
le.chete gener.tlon Iru.
.ource (pllll). le.chlltll
plc- .Iqretlnq north rrma
the 111111 ,,111 eventllllily
Intllrllect lhe trlbul.ry
crelltlng, In turn, . lonq-
tel"18 thrll.l to ...ter qc,.I-
Ity of McGlrtll [reek.
fte.ovell cont..ln.tlon
BOurce (1IIudge. IInd cover
..lerl.ls). Allevl.llls
probleM o( conl..lnant .1-
qr.tlon In groundwllter .nd
8Urf.ce ...ter. PerMllnent
dlllruption of .re. enylron-
!llent b, on-Illte I.ndflill
.., .(Iect property valuell
.nd ere. dflvelo"..ent poten-
U.I.
ReMoye. cont..ln.tlon
eource
-------
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1\ It efnllil VI!
Table
fnlll ($1,000)
[n"I181
o " ...
rrl!nenl
Norlh
Puhllc: IlelUh
[n"..lltar.llonl
(ooot .1)
."
[nvlr_flnl..1
[rrect a
lf1chnleol
[nnsl.I"r.' In.."
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8-1\
8-~
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f.;.~ rT
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r- r-
.
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224,/104
17, '~6
86,Ul
109,S06
,.)
SS.I
n.'
n..
)4.2
n.4
16.1
224,824
11,91)
81,104
110,122
10111ly .eell re.edlll re-
eponee obJect.hell. Reducell
public huHh lhn.t C08-
rilltely. HIQh rlak to r..e-
dl.1 workera durln9 e.clvl-
lIan or "I".
lotliit .eetl reeedill re-
eponee obJectives. Reduces
public hellth threlt to IIC-
cepteble level. High rl"
to re.eltlel workers durln9
e.cI..tlon or pltl.
101.11, .eetll re.edlel re-
eponlle obJectlvee. Reducell
, public helUh threet to 8C-
cepteble level. High rlek
10 re.eltlll workere durlnq
e.clv.tlon or p:ta.
10tell, ..,etll reeediel re-
aponee obJective.. Reduce.
pt.lllc heeUh thre.t to IIC-
er.ptehle level. High rlek
10 re.edllli worker. durlnq
e.cevetlon or pll..
R_vee IIOlIrc:e nr cont...l-
nlliion end III .econlfer, .
on-elt. cont..lnetlon.
le.porer, dl.rupllnn or
.rel envlr_enl durln9
r-dlel worlc.
Reeovee eont..lnliion
eource (.ludgell Ind cover
..lerlell). Allevlelee
prObIe. or .19r.llon or
cont-lnente In «)roltnd.lter
end lIurrlCe .eter. Per-
..nent dl.ruptlon or e.lll-
1"9 .ree envlron.ent by on-
IIlte vlult, vlauell, not
leelhetlc, .e, errect prop-
ert, velur.. IInIt Iree devel-
o.-ent potentlel. .
Re80vel cont..lnetlon
eeuree (sltl.t«)ee). Alle-
vl.tel probl~ or cont..l-
Aftnt .19rltlon In 9ro.tnd-
.eter end lurrlce .eter.
Air quellty .rrected b,
on-llll Inclner.tlon.
Pe,.enent dl.ruptlon 0'
e.lltl"9 .ree envlrDn8llnt
by on-II Ie lendrili. .ey
Irrect propert, vlluea end
Ir"l develo...ent potent III.
Re80vel cont..lnetlon
eource (.ludgel). Alle-
ville. probl.. 0' cont..l-
nlnt .19rlt Ion In 9ro1lfld-
.eter ... IIlIrrlce ..ter.
Air qulllt, .,rected b,
on-elte Inclneretlon. 1..-
porlr, dl .,upt ICIfI or Irel
eo.lrCJfl.ent durlnQ re.edlll
IcUvlUes.
Rei Ie. CIfI atrel'lM - (or....,..1
construct Ion lechool..q,.
Rellee on wlltel )"UIII'It 'ech-
oolo«)le.. 0" H requlre-
Mnt II ror vII'11t "M qrollnd-
.eter he..t.ent 'lIellll y
.111 be lIubshntllll.
Rellel on IItete-or.the-lIrt
technolO«J' (.oblle Inclnl'r-
etlon), high operellon IInd
.llntenenee requlre..,n's.
Provldell ultl.llte ItlllpO~1I1
or lIOurce eonl_lnllnls.
ltalle. CIfI III.ete-or -tIMl-IIrt .
technol09' (8Gblle Inclner-
Itlon). hlQh operetlon 8nIt
..Inten..nee requlre~r.nt8.
Provlde8 ulU.ete disposel
0' source conl~lnnn's.
-------
Allernelive
n.7
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(el'IlIII
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1H,nfi8
7O,1I~'
1I),lU
f081 ('1,000)
o & H"
10.1
19.1
~ 1..
16.1
H.'
16.1
n.'
16.Z
Prrllent
"url"
126,162
07,(,0)
11 . ''10
M.1~O
"'..llc IIfIIIllh
(on8 I cie rallons
10"11)' ..eets lhe re_dlllt
re5pOn~ objecl Ive~. Re-
dur"" polbllc healll, thrud
10 acct'plehle II..Hs. IIlgh
risk 10 re.edlel workers
dur log e.caullon of pHs.
Tolell)' ..eels lhe re.edlal
resf'OOlIe ohjllcllvee. RII-
ciucu \I..tIllc hea Ilh thr"al
10 BCceplllhie II.H.. High
rill" 10 (f'.lIdlel worken'
during e.cavallon of plla.
Totall, ..et~ lhe re.lldlal
reepone. ObJectlvee.
Reducea ptjJllc health threat
to acceptable 1..lIih. High
rl" 10 re-dlal workere
during eocavatlon of pita.
'DIal I, .eet. the r-.edlal
reeponlle objecllves. Re-
ducu ~"Ilc huHh threat
to acceptable 11.lta. High
rl.k 10 re.edlal workllr.
clurlOlJ e.cawellon of plla.
I
.table III (ca1t.)
£nw I ron_nlal
(Heele
Re80ves cont..lnallon
1J0urce (aIUll!)ea aOiI cover
.alerlals). Allevlatt's
probleM of cont..lnant
.Iqretlon In qroundwsler
and surface wsler. Air
quill It, effected by on-elte
'ncineraUon. T_porer,
dleruptlon of ar.a environ-
Ment during reMedial ectlv-
IUn.
Re80vee cont..lnetlon
sollrce (el udqe e end cove r
.aterlllle). Allevletes
probleM of conl..lnent
.Igrallon In groundwelllr
end surfeee water. Air
qual It)' Iffectlld by on-lite
Incinerilion. '88pOrar)'
dlarupllon of eree environ-
Ment during r..edlal ICtlv-
Itles.
R880vel tnnt..lnetlon
eDurce (aludges). Alle-
vlatlll probleM 0' cont..l-
nant .Iqretlon In qround.
weter and aurface weter.
TeMpOrery dllrurllon of
area envlrOO8ent dutlng
r88edlel actlvltlee.
~vlla conl..lnat Ion
aource (elodges and cover
.lIterlal.). AIlevlete8
probl.. of cont..lnent
.Iqrallon In qro,~waler
end .urfece wlllf'r. le.por-
er)' dlarurllon of eree
environMent during reMedlel
.ct Ivilieli.
. ,
-~--
.)
.'1
;,) .
!;:)
l'J
w
lerhnlclIl
(onsllienllon.
Rellee on Itele-of.II....",1
lechnolo!))' (lWOblle I", III"'.
.llon) I hlqh OfJenll"" "nd I
..alnlen.nce requl '''''''"1...
Provides ull 1.,,111
-------
-..J
-..J
,U I ernlllh..
Cot
[-2
~
C-'
C--
C."I hi
2,'02
2 ,012
',98~
t,lS-
ftJet U' ,000)
0''''
02.0
40.8
_0.'
81.0
)9.8
'''.8
rrlleent
""r'"
',049
2,--7
2,121
2, no
"'1b'le 11e.lth
Cnnelder.llone
lohll, ..eete the r_dl.1
re~pnnee obJecllvee. Re-
ducee fdJllc: he.Hh threet
10 ecu"hhle 1I.1t1l. low
rlell 10 re.edlel workere.
Pertlell, .eete the re.edlel
reeponse obJectlvee. Onee
nol reduce public heellh
lhreel 10 Kcephble 11.lte.
la. rllk to re.edlel
workere.
lotell, .eete the r~edlel
r~5"onse ObJecllves. Re-
dur.ee public heelth threet
to accept.ble 11.lte. Hod-
e,.te risk to ,e.edlel
workers durln9 Instelletlon
0' elurry well In conl..l-
".led lone.
Pertlell, .eet. the ~dlel
respoRes obJecllvee. Onee
not reduce public he.llh
threet to ecceptable 11.lt..
Hoder.te ,I.k to re.edlal
work.r. during Inalallatlon
0' elurr, .,.11 In cont..l.
neted 'one.
th~ nt «amt..'.
[""Ir-nlel
(Uede
leolete" ...de MurCt! rr,.
aree grnonll"eler end "018
BUrr.ce _ler Inri Hretlon.
le.por.r, dlftrupllnn 0'
a,ell r.nv tro~nl Ih., I nq
re.edlal ec:llwllle~.
180Ietell weste lIource rr08
aree ground..ler end rrDe
au,recII weter InrtUrell..n.
(.Iellng conte.lneled
,roundweler will Mlgr.tll
o"-lIltll. 'eepnrer, dl~-
ruptlon 0' ere. envlron.ent
during reeedl.1 activit lee.
'eolele. -8111 80urce "08
eree ground..ter end 'rne
eurrace willer InraHratlon.
Prow I lie II partlel reMovlI1
(801111 north 0' pits) 0'
Mcondar, cont.lnaUon.
Ie.por.r, dl.ruptlon or
area envlron.ent during
re.edlal ec:llvillee.
IlOlat.. ...t. BOure. , I.'"
erea ground..ter end 'r08
eurracII _ter Inrillratlnn.
Provldell p.rtlal re.uvlIl
(.olt. north or pit.) or
eecondar, cont..ln.llon.
(.18tlng eont..lnated
groundwetor will .19ralo
o"-8It.. '~por.r, dis-
ruption 0' .re. envlron8l!nt
during ~dl.1 activities.
~..
.;:)
'echn 1....1
Consllln,nlion..
- -
.... '. .
Relle. on ""11.,,,,1..,.\1,,'18"
lec""ologle,,. "I" U''lulre
long-t... ,,""llo,11M1 or tllf!
r.onlelrw~nt ey"l.... 10 checlc
errect ivene8~.
(:)
o
N
....
I
Relies on well-e,,'ablillhed
technologl~s. ifill requlr.
long-term ~nl'o,lnq 0' '''e
cnnt.lllIIIen' ~y"l"e 10 checlc
effecl heness.
ReUee on well-nt.hI hhed
tl!choologlu. SllIrr)' wnll
pl.ce_enl In conl88lne'~d
,on. Incre.ses polen'I..1
'or '.lIu,e. Mill reqlll re
long-ter. 8Onllorlng or the
cont.lnment eys'~ lo check
effect henes5.
1'8".. on wll-eehblhhed
technologlee. Slurry willi
plece.enl In conl..lnell!d
loroe lncre.~es polenllAI
for r., I ..re. "1'1 re'1"I,e
long-te"" 810ft" or 1111) or lhe
coot.l...en' lIysteM to check
effect henes5.
-c
o
O()
:;<: :,t)
f:? ,C)
?~ ~!;
J> r~.-
r- --
-t
-<
-------
Table ItLJgJnt.)
Alterllnllv"
(onl (\I,OUO)
(aplt el
O&H"
Prl'lIl.nl
Norl h
rl/tlllc l\eolt"
[nllllllirrollulIlI
[nv I r orwent el
[ f f ~d 5
.' .
----~- - ~--
,:)
:""")
(' )
':>
l'J
CJ1
. .
111£110 Ie' n I
(onlll("rol III""
"--------
(-'>
..,
(-6
1,978
1,6'0
)'}. Z
}R. }
Z, })8
1,991
Pullelly ."1'18 lhe ret8edlel
response objecllves. Ones
nol rt:'duell plllllc l~ell h
Ihreel to 8Cceplllble Ii-Ite.
10. rlllk to re_edlel
worken.
Pert lei I, 88ete the re~edlel
rellf'O~e objective.. 001'5
not reduce puhllc heelth
Ihreal I" 8Ccepl lib Ie II.Ue.
Hodl'rote rl.k 10 re.edlel
worker. durIng Inslellatloo
of slurry .ell In conl_i-
net I'd lone.
l.olele5 ....tll BOurce frOll
eree grouAI.eler end fr-
eudeee .eler In(jUrellon.
(olstlng conlR8lneted
qrollnd...ter will _Igrete
off-eile. 'e.por.ry di.-
rupt Ion of eree envlrou.enl
durlA) re.edlel eellvllle5.
I..olell'll w881e eource hOll
eree ground.eter end frOlll
eurfeee ..ter Inflltr.t Ion.
(ont_lneled 801Ie north of
p.le will re.eln. hl.llng
cont _Ineted ground-ter
.111 .Igrale off-site.
'e.rorery dlerupl Ion of
eree env Iro.-ent during
n-edl.1 8Ct Ivilin.
Rellee on well.",' ""I shc~d
tedlfloloqlell. Will rrlulre
1009-Ie... 8Onllo'lI") of lhe
contel~nl 8 yo! 1 ,.. 10 check
effecllvelll!1!ls.
Rell88 on .1'11-.,.,1 ""Ished
lechnologles. ~llJrry ...11
pler_nt In conl-Inel OIj
lone Ine remes 1'011'111 1111
for fellure, 11111 re'l'oIre
long-Ier. 8Onllorl"'l of lhe
contel,.enl a~l,.. 10 d'"ek
ef fecllve,,"s.
-'J
()
QC)
,"'....:' "'.1
£5;)
L (~
;; j;:
r- ,....
-i
-<
-...J
00
-------
.
. '
. r.:- .:n06
. ..,...../ ' Iw
-10-
This evaluation revealed the f0110wing:.
The .no-action. alternative is an unacceptable'solution to the
problems at the Whitehouse site, since it does not .eet any of the
objective8. The potential for the heavily contaminated shallow
aquifer just beneath the site to seep into the drinking water
supply clas~1fies the site, according to risk calculations. as
a site at which remedial action must be taken. Additional
concern is the,lateral movement of contaminants to groundwater
via the surface streams. 80yles (FDER-RI Report) strongly
suggests that the streams and near~ creek are intercepting
contaminated water from the site.
Alternatives 8-1 and 8-4 involve removal of the most concentrated
waste products and storage in an on-site landfill or vault.
These actions do not provide total source cleanup and create
additional technical, environmental, and health problems
associated vith their implementation. Specific concerns are
addressed in the feasibility studY and include limited space,
higher health hazards to workers and residents, and permanent
disruption of the area environment by the on-site landfill or
vault. The remaining excavation options involve incineration or
disposal at an off-site landfill and are cost-prohibitive.
Alternatives C-2, C-4, C-5, and C-6 are unacceptable because
they only partially address the remedial objectives.
Alternative C-l appears to be the most rea80nable and, further,
is recommended by the consultant since it fully meets the
objectives at the lovest cost. The recommended alternative C-l
consists of: (See Fig. 2-7)
- Construction of a slurry wall around the entire 8ite;
- Recovery and treatment of contaminated groundwater;
- Removal of contaminated sediments from the Northeast
Tributary of McGirts Creek; and
- Surface cap entire site.
The slurry vall will be effective in preventing horizontal
movement of contaminated groundwater. 8y placing a cap over
the site, t.he amount of groundwater and .urface water .eeping
into t.he contaminated area viII be greatly reduced.
An int.egral part of the alternative is the groundvater
pumping/treatment .ystem. The removal of contaminated groundwater
from the area enclo.ed by the slurry wall will create an upward
flov into the area through the aquitard which will effectively
prevent any downward ,migration of contamil:\ant.. An addit.ional
advantage of this upward flow is that t.he influx'of clean vater
will create a .flushing. action which will provide for .ome
removal of t.he .oluble contaminanta. The rs con.ultant. believes
that the 25 year period proposed will accomplish sufficient
flushing to allow shutdown of the groundwat.er recovery system.
79
-------
~
u
o
..)
, .,
"
Fig- 2-7
DREDGE UOIUtH"
AND OISl'OSI ON""
UHDIR $In cu.
IIIIUHI CHANNEL
LEGEND
UIIIID
"&8 C..;
""'.". 01... I....... UP.
....In... I.... 8A4 ......
...... c......
.
'."K'~ _,: AI........... C., _I,
NOllnliASJ TlII.urARY
01' &lCGla" ehnK
GROUNDWATER
rR(A'WiHr FACilITY
IAL U RHA "V, C. , OHl WI
... ... . .. ... ... ... .. ... .. ..
... .. ....w.
.ou'" GnCH
o '00
-- -
ICALI
:tOO 400
800 "1'
I
,....I'IN
Joo
100
o
..... -
40
10
no
AL TERNATlVe C-1
U.U""Y WALL
GRAno. S11111
SLURRY WALL AND GROUNDWATER TREATMENT
c
~
o
C
III
III
..
..
~
i5
o
00
';. -~
i
_: -J
::.; ~)
(j /~
-J
C' 0 ~;.,
cj 6
()
Ci..
'",
-------
. -:- . 1
. . '-
. I'.' .
0L,:D28
-11-
COMflfJNITY RELATIONS
Three public meetings were held to inform the public of activities
at the 8ite. 'act 8heets and press releases were prepared for
a11 meeting8. The press and television covered the 8eetings
extensively. The third meeting was to present the draft
feasibility-study and allow for public comment. A responsiveness
summary outlining the results of public comment is enclosed.
An information repository was established at the elementary
school in Whitehouse. When approved, this record of decision
will be 8ent to the repository.
\.-
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
Alternative C-l would result in.the di8charge of treated vater.
We anticipate meeting the technical requirements of NPDES for
this discharge. While PCB's have been found at the aite,
concentrations are well below those that trigger action under
TSCA. The RCRAprogram has commented on the remedy and their
comments can be addressed during the remedial design phase.
We do not 8ee, nor do. we anticipate, any conflict vith other
environmental laws. Table III aummarize8 the evaluation of
alternatives with respect to environmental concerns, among 'others.
OPERATION AND MAINTENANCE (05M)
,.
.
Alternative C-l includes recovery and treatment of contaminated
groundwater. The conceptual design 8ugge8ta a ..ximum flow-through
capacity of approximately 80;000 gallon. per day. A groundwater
monitoring program will be initiated conaisting of eight new
monitoring wells. Six veIls viII be set into the aiddle aquifer
and tvo into the aquitard. Exi8ting veIl D4 viII be included
in this 8ystem to monitor the bedrock aquifer. The estimated
annual 05M cost 18 96,630, projected for a 25 year period. A
letter 18 included with this ROD confirming the State'. committment
to funding these continuing costs.
l
,
SCHEDULE
The Corps of Engineers (COE) has adverti.ed for firms to conduct
the remedial design. Review and 8election of a contractor i8
8cheduled for June 1985 with remedial de8ign complete 1n June 1986.
Construction should proceed immediately thereafter with
construction complete in June 1987.
81
-------
... -
. ,,- "
(\CO(':"';~
-12-
FU'I'URE ~C'I'10NS
Oak Ridge National Laboratory has been tasked through an lAG to
provlde guidance on design of the groundwater recovery aystem
to maximize ita effectiveness for flushinQ soluble ..ates from
the pits. Thia may allow us to reduce the time that the
Qroundwater recovery system operates.
~
,
82
r
-------
APPENDIX C
TABLES 1 - 17
83
-------
Table 1
S1JMMARY OP' CONTAMINANTS OP' CONCERN BY MEDIUM
WHITEHOUSE WASTE OIL PITS SITE
Frequency
RME
Surface Soil
Semivolatile Orqanics (uq/kq)
1,4-Dichlorobenzene
Naphthalene
2/8
1/8
328
301
Volatile Orqanics (uq/kq)
Methylene Chloride
1, 1,2, 2-Tetrachlorethane
Tetrachloroethene
Chlorobenzene
Toluene
2/8
1/8
1/8
1/8
5/8
11. 8
2.9
10.6
4
38
Bxpoeed Wastes
Inorqanics (mq/kq)
Barium
Copper
Lead
Antimony
Zinc
4/4
4/4
4/4
1/4
4/4
5445
269
29604
31.9
941
Semivolatile orqanics (mq/kq)
Napthalene
2-Methy1naphtha1ene
3-and/or4-Methylphenol
Pesticides (mq/ka)
PCB 1260 (Aroclor 1260)
3/4
4/4
2/4
87
76
87
2/4
48
Surf ace Water
Inoraanics (uq/l)
Manganes.
4/4
14
Volatile Orqanic8 (uq/l)
Carbon Di8ulfide
2/5
35.3
84
-------
85
Table 1 (con't)
Frequency
RHE
Groundwater
Inoraanics (ua/1)
Barium
Chromium
Copper
Nickel
Lead
Antimony
Selenium
Vanadium
Zinc
Manganese
Volatile OraanicB (ua/1)
11/16
13/16
3/16
9/16
13/16
1/16
2/16
10/16
2/16
14/16
61
67
12.2
65
313
30
11
32
52
93
Trichloroethene
Acetone
Carbon Disulfide
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Methylbutyl Ketone
Toluene
Xylene
Semivolati1es (ua/l)
2/18
2/18
6/18
1/18
1/18
1/19
1/18
3/18
3
5
11
114
26
12
5
4
Isophorone
Phenol
3-and/or 4-Methylphenol
Naphthalene
1/18
1/18
1/18
2/18
5
48
3S
9
Trenches
Inoraanics (ma/ka)
Cadmium
copper
Lead
Zinc
5/8
7/8
8/8
7/8
6.8
83
12751.1
1882
Semivolatile Oraanic8 (ua/ka)
Napthalene
B18(2-ethylhexyl)phthalate
2-Methylnaphthalene
2/8
1/8
1/8
24
89
23
-------
Table 1 (con't)
Frequency
RME
Volatiles (uq/kq\
Toluene
Total Xy1enes
Ethy1benzene
3/8
3/8
3/8
3.8
16.6
2.6
Pesticides (uq/kq\
PCB 1260 'Aroclor 1260)
1/8
23
* RME s Reasonable Maximum Exposure values are the exposure
point concentrations used in the determination of average daily
exposure levels and are derived according to Agency guidance
(EPA/540/1-89/002).
86
-------
Ta}:)le 2
EXPOSURE AND INTAKE ASSUMPTIONS: DERMAL CON'I'AC'r
AND ACCIDEN'I'AL INGESTION OF SURFACE SOIL AND EXPOSED WASTE
WHITEHOUSE WASTE OIL PITS SITE (PRESENT AND P'UTtJRE)
LOCAL RESIDENCES-AGE GROUPS (Years)
0-1 2-6 7-11 12-17 18-75
Exposure Frequency (Soil)
(days/year) *
180
365
Exposure Frequency (Wastes)
(days/year) *
Body Weight (kg)
o
5
10
17
5
Duration of Exposure (Years)
2
Soil to Skin Adheherence
Factor (mg/cm2)
1.4
1.4
Skin Surface Area Exposed
(cm2/event)
1700
2200
Dermal Absorption Factors:
Semi-volatile organics
1.2\
1.2\
5\
Volatile Organics
5\
Metals
n
1\
Ingestion Absorption Factors:
Semi-volatile Organics/
Metals
50\
50\
Volatile Organics
Soil Ingestion (mg/day)
100\
100\
100
200
365
10
30
5
1.4
3800
1.2\
5\
1\
50\
100\
100
365
365
10
o
55
72
30
6
1.4
1.4
5900
2000
1.2\
1.2'.
5\
5\
1\
1\
50\
50\
100\
100\
100
100
*
Only the frequency of dermal exposure changes from the 80il pathway
model to the exposed wastes pathway model, all other model parameters
remain the same.
Sources:
Skin surtace areas exposed are from USEPA Exposure Factors
Handbook (1990); other parameter values were derived as
descr ibed in the text.
87
-------
Table 3
BXPOSURB AND INTAD ASSUMPTIONS: SURl"ACE WATER DERMAL CONTACT
WHITEHOUSE WASTE OILS PITS SITE
AGE GROUP (YEAAS)
0-1 2-6 7-11 12-17 18-75
Duration of Exposure (years) 2 5 5 6 30
Frequency of Exposure
(days/year) 0 0 52 10 0
Length of Exposure (hours/day) 0 0 1.0 0.5 0
Skin S~rface Area Exposed
(cm2) 0 0 3800 5900 0
Permeation Constants (PC) for Surface Water Contaminants
Contaminant
PC (cm2 hour)
S.SxlO-2
Carbon Disulfide
Manganese
8.4xlO-4
88
-------
89
TaDle 4
EXPOSURE AND IN'l'AD AsSUMP'I'IONS FOR
GROUNDWATER INGESTION
WHITEHOUSE, WASTE OIL PITS SITE
AGE GROUPS
Q::.1 ~ 7-11 li:.11 ~
Duration of Exposure (years) 2 5 5 6 30
Groundwater Ingestion
(l/day) 1 1 1 2 2
Ingestion Absorption
Factor (all contaminants) 1.0 1.0 1.0 1.0 1.0
Frequency of Exposure
(Ingestion (days/year) 365 365 365 365 365
Frequency of Exposure
(Irrigation) 122 122 122 122 122
Inhalation Rate (mJ/hr) 0.83 1.17 1.63 2.50
Length of Exposure (hours/
day, irrigation) 4 4 4 4
Inhalation Absorbtion Factor
(all contaminants) 1.0 1.0 1.0 1.0 1.0
-------
Table 5
TOXICOLOGIC CRITERIA VALUES:
CANCER HEALTH EFFECTS
WHITEHOUSE WASTE OIL PITS SITE
CANCER POTENCY
FACTOR (SLOPE FACTOR)
(mg/kg/day) -1
WEIGHT OF EVIDENCE
SUBSTANCE CLASSIFICATION ORGAN(S) AFFECTED ORAL 1
INHALATION SOTJRCE
Cadmium 81 Lung, Respiratory * 6. lIRIS
Tract
Chromium All Lung * 4111 IRIS
Nickel All Respiratory Tract *
0.8411 HEAST
Methylene Chloride 82 Lung, Liver 0.0063
0.0063 HEAST
Bromodichloromethane B2 Liver 0.13 NAHEAST
Tetrachloroethene B2 Leukemia, Liver 0.051
0.0033 HEAST
Trichloroethene B2 Lung, Liver .011 . o 17HE.AS':
1,4-Dichlorobenzene B2 Liver 0.024 NAHEAST
Bis(2-ethylhexyl)phthalate 82 Liver .014 NAHEAST
PCBs B2 Liver 7.7 NAIRIS
Notes:
1/
2/
1/
* = Not carcinogenic by this route
Values given are for hexavalent chromium
Value given is for Nickel refinery dust
NA = Not Available
90
-------
TABLB 6
TOXICOLOGIC CRITERIA VALUES: NONCANCBR BBALTH IPF2CTS POR COC8
WHITEHOOSE WASTE OIL PITS SITE
SUBSTANCE
Antimony
System
Barium
Cadmium
Chromium
Cobalt
Copper
Irritation
Lead
Manganese
System
Mercury
System
Nickel
Weight
Selenium
Vanadium
Zinc
Hethylene Chloride
~cetone
arbon Di8ulfide
~,2-Dichloroethene
4-methyl-2-pentanone
Tetrachloroethene
Toluene
Irritation
Chlorobenzene
Xylenes, Total
Decreased
Increased
Phenol
1,4-dichlorobenzene
Benzoic Acid
Di-n-butylphthalate
Bis-(2-ethylhexyl)-phthalate .
Naphthalene/2-methyl-naphthalene
Notes:
1/
Y
11
!/
Value given i8 for
Value given is for
Value given i8 for
Value8 for toluene
RfD concentrations
NA ~ Not Available
91
ORAL EXPOStTRE
UNCERTAINTY
RfD (ma/ka/dav) FACTOR
4.0xlO-4 1000
5xlO-2 100
5xlO-4 .!/ 10
5xlO-3 1/ 500
NA NA
3.7xlO-2 None
NA NA
2xlO-l 100
3x10-4 10
2xl0-2 1/ 300
3xl0-3 1000
9xl0-3 100
2xl0-1 10
6x10-2 100
0.10 1000
0.10 100
2xlO-2 1000
5xlO-l 100
lXI0-2 100
3xlO-l 100
2x10-2 1000
2 100
0.60
NA
4.0
1.0
2x10.2
4xlO.3
100
NA
1
100
1000
1000
ingestion of groundwater.
hexavalent chromium
nickel refinery dust.
and xylene are based on inhalation
from HEAST.
ORGAN(S}
AFFECTED
Hematopetic
Blood
Kidney
Not Defined
NA
Gastric
Developmental
Central Nervous
Central Nervous
Reduced Organ
Skin, Muscles
?
Anemia
Liver
Liver, Kidney
Fetotoxicity
Liver
Liver, Kidney
Liver
Eye and Nose
Liver, Kidney
Hyperactivity,
Body Weight,
Mortality
Fetotoxicity
NA
Irritation
Mortality
Liver
Ocular
-------
TABU 6
(con't)
TOXICOLOGIC CRITERIA VALUES: NONCANCER HEALTH EFFECTS FOR COCa
WHITEHOUSE WASTE OIL PITS SITE
SUBSTANCE
SOURCE
Ant imony
Barium
Fetotoxicity
Cadmium
Chromium
Cobalt
TLV
copper
Lead
Based
Manganese
Nervous System
Mercury
Nickel
Selenium
Tract
Vanadium
Zinc
Hethylene Chloride
Acetone
Carbon Disulfide
1,2-Dichloroethene
4-methyl-2-pentanone
Kidney
Tetrachloroethene
Toluene
Irritation
Chlorobenzene
Kidney
Xylenes, Total
Irritation
Phenol
1,4-dich1orobenzene
Kidney
Benzoic Acid
Di-n-butylphthalat8
3is-(2-ethylhexyl)-phthalat8
Naphthalene/2-methyl-naphthalen8
Notes:
11
Y
II
5./
Value given is for
Value given is for
Value given is for
Val~~s for toluses
Rf~ ~ncentrationB
Nc~ !.ilable
NA -
RiD (mq/kq!dav)
INHALATION EXPOSURE
UNCERTAINTY
FACTOR
NA
lxlO-4
IRIS
NA
NA
3.4x10-s
NA
1000
NA
NA
100
NA
NA
NA
NA
3x10-9 100
IRIS
NA NA
NA NA
1x10-3 1000
HEAST
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
2x10-1 100
HEAST
NA NA
6x10-1 if 100
HEAST
5x10-J 10,000
HEAST
1x10-1 if 100
NA NA
7X-l 100
HEAST
NA NA
NA NA
NA NA
NA NA
ingestion of groundwater.
hexavalent chromium
nickel refinery dust.
and xylene are based on inhalation
from HEAST.
ORGAN(S)
AFFECTED
NAIRIS
NAIRIS
NAIRIS
CardiacOSHA
NAMCL
NAEbasco
on PMCL
Central
NAIRIS
NAIRIS
Skin, GI
NAHEAST
NAHEAST
NAHEAST
NAHEAST
NAIRIS
NAHEAST
Liver,
NAHEAST
Nose/Throat
Liver,
Nose/Throat
NAHEAST
Liver,
NAHEAST
NAHEAST
NAHEAST
NAIRIS
92
-------
Table 7 (a)
CANCER RISKS AND NONCANCER
HAZARD INDICES: SURPACE SOIL EXPOSURES
WHITEHOUSE WASTE OIL PITS SITE
RHE SOIL LIFETIME
CONTAMINANT CONCENTRATION (maIko) CANCER RISK
Carcinoaenic Risks
1,4-Dichlorobenzene 0.33 1.2xlO-8
Methylene Chloride 0.012 3. 9xlO-10
1,1,2,2-Tetrachloroethane 0.004 3. SxlO-9
Tetrachloroethene 0.013 2. 9xlO-9
Total Cancer Risk: 1.9xlO-8
Noncarcinoaenic Effects
1,1,1-Trichloroethane
0.003 2. 9xlO-6
0.33 3. 2xlO-6
0.013 3. 7xlO-6
0.30 S. 3xlO.4
O.Oll 2. OxlO.5
0.038 2 .3xlO-6
0.003 S. 9x10.7
0.020 3. 7xlO-6
0.006 2. 2xlO-6
Total Hazard Index:
(ages 2-6) 5. 7xlO-4
Chlorobenzene
1,4-Dichlorobenzene
Methylene Chloride
Naphthalene
Tetrachloroethene
Toluene
Acetone
Methylisobutyl Ketone
93
-------
T&1;)le 7 (b)
CANCER RISKS AND NONCANCER KAZARD
INDICES: EXPOSURE TO HOKE-GROWN VEGETABLES
(SURFACE SOIL CONTAMINANTS)
WHITEHOUSE WASTE OIL PITS SITE
CONTAMINANT
RME CONCENTRATION
IN SOIL (mQ/kq)
LIFETIME
CANCER RISK
L
Carcinoqenic Effects
1,4-Dichlorobenzene
0.33
2.7xlO-5
1,4-Dichlorobenzene
Naphthalene
0.33
0.30
CDI/RFD Ratio
3.4xlO-J
L 3xlO-l
2.
NoncarcinoQenic Effects
Total Hazard Index:
(Adults)
1.3xlO-l
rom
..
Reasonable Maximum Exposure
94
-------
Ta})le 8
CANCER RISKS AND NONCANCER HAZARD
INDICES: EXPOSURE TO EXPOSED WASTE
WHITEHOUSE WASTE OILS PITS SITE
CONTAMINANT
RME CONCENTRATION
IN WASTE (ma/ka\
LIFETIME
CANCER RISK
1. Carcinooenic Effects
PCB 1260
4.8
7.6xlO-6
2.
Ant imony
Barium
Copper
Lead
2-Methylnaphthalene
3,4-Methylphenol
Naphthalene
Zinc
23
5400
270
30000
76
87
87
94
CDI/RFD Ratio
(2-6 vear-olds1.
8.4xlO-3
1.1xlO-2
7.7xlO-4
Noncarcinooenic Effects
Total Hazard Index:
2.1xlO-3
1.9xlO-4
2 .4xlO-3
5.0xlO-4
2.6xlO-2
RME =
Reasonable Maximum Exposure
95
-------
T&ble 9
CANCER RISKS AND NONCANCER HAZARD
INDICES: EXPOSURE TO StJRlPACE WATER
WHITEHOUSE WASTE OIL PITS SITE
CONTAMINANT
RME CONCENTRATION
IN WATER /mq/l)
1.
Carcinoqenic Effects
(None)
:2 .
NoncarcinoQenic Effects
Carbon Disulfide
Manganese
0.035
1. 469
Total Hazard Index:
(ages 7-11)
RKE ..
Reasonable Maximum Exposure
LIFETIME
CANCER RISK
CDI/RYD Ratio
3.5xlO-4
1.1xlO-6
3.5xlO-4
96
-------
Table 10
CANCER RISKS AND NONCANCER HAZARD
INDICES: INHALATION EXPOStTR!:
DURING IRRIGATION (SHALLOW GROUNDWATER)
WHITEHOCSE WASTE OIL PITS SITE
CONTAMINANT
RME CONCENTRATION
IN WATER (mall)
LIFETIME
CANCER RISK
1.
CarcinoQenic Effects
Trichloroethene
0.003
3.7xlO-9
Careon Disulfide
Acetone
Toluene
Xylene
0.011
0.005
0.005
0.004
CDI/RFD Ratio
(2-6 vear-olds)
1.7xlO-5
7.9xlO-6
1 . 3xlO-6
6.3xlO-6
2.
Noncarcinoaenic Effect~
Total Hazard Index:
3.3xlO-5
RME ...
Reasonable Maximum Exposure
97
-------
Table 11
CANCER RISKS AND NONCANCER HAZARD INDICES:
FUTTJRE CONSUMPTION OF HOME-GROWN VEGETABLES
(IRRIGATION WITH SHALLOW GROUNDWATER)
WHITEHOUSE WASTE OIL PITS SITE
CONTAMINANT
RME CONCENTRATION
IN SOIL (ma/1)(1)
LIFE':'IME
CANCER RISK
1.
Carcinoaenic Effects
(None)
Naphthalene
3,4-Methylphenol
0.41
0.72
CDI/RFD Ratio
(2-6 vear-olds)
1.8xlO-l
S.6xlO-4
2.
Noncarcinoqenic Effects
Total Hazard Index:
1.8xlO-l
( 1)
Concentrations Resulting From Irrigation Water Application (See
Table 5-4).
RME = Reasonable MaxLmum Exposure
98
-------
Table 12
NONCANCER HAZARD
INDICES: EXPOSURE THROUGH
DOMESTIC USE OF DEEP GROUNDWATER
WHITEHOUSE WASTE OIL PITS SITE
CONTAMINANT
NoncarcinoQenic Effects
CONCENTRATION
IN WATER (uQ/l)
Antimony
Barium
Chromium
43
Manganese
Nickel
Zinc
69
36
120
6.8xlO-:Z
270
120
200
Total Hazard Index
(age8 2-6):
.)
99
CDI/RFD RATIO
1.0xlO.l
4.2xlO.:Z
1.4xlO.o
Copper
7.9xlO-:Z
3.SxlO.l
S.9xlO-:Z
1.2x10.1
-------
Tabl. 13
CANCER RISKS AND NON CANCER HAZARD
INDICES: FUTURE EXPOSURE THROUGH
DOMESTIC USE OF SHALLOW GROUNDWATER
WHITEHOUSE WASTE OIL PITS SITE
RME CONCENTRATION
IN WATER lua/1)
LIFETIME
CANCER RISK
CONTAMINANT
1.
Carcinoaenic Effects
Trichloroethene (ingest.)
Trichloroethene (inhal.)
Isophorone
3
3
S
7.9xlO-7
1.2xlO-6
2.2xlO-7
Total Cancer Risk: 2.0xlO-6
2. Noncarcinoaenic Effects CDI/RPD Ratio
Antimony 21 3.lxlO-o
Barium 61 7. 2xlO-2
Chromium 67 7. 8xlO-l
Copper 12 1.9xlO-2
Manganese 92 2. 7xlO-2
- Nickel 64 1.9xlO-l
Selenium 11 2. 2xlO-l
Vanadium 32 2.1xlO-l
Zinc S2 1. SxlO-2
Acetone 5 2. 9xlO-3
Carbon Disulfide 11 6. 5xlO-3
Toluene 5 1.5xlO-3
Xylene 4 1.2xlO-4
3,4-Methylphenol 6 7. lxlO-2
Naphthalene 9 1.3xlO-l
Total Hazard Index
(ages 2-6):
4.8xlO-O
RHE ~ Reasonable Maximum Exposure
100
-------
CONTRIBUTORS
EXPOSURE ROUTE
HAZARD INDEX
1.
Current Lard Use
Surface Soil
Naphthalene (94\)
Exposed Waste
Antimony (32\)
(42\)
Surface Water
Disulfide (99\)
Bome-Grown Vegetables
Naphthalene (99\)
(Soil Contaminants)
Total Current Use
2.
Future Land list
Irrigation Water
Kethylethyl Ketone (50\)
(Inhalation)
Home-Grown vegetables
Naphthalene (99\)
(Irrigation)
Groundwater Consumption
Antimony (65\)
Chromium (16\)
Deep Groundwater
Antimony (83\)
consumption
Chromium (12\)
Total Future Use
101
Table 14
. RISJtS ASSOCIATED WITH
COMBINED EXPOSURE PATHWAYS
WHITEHOUSE WASTE OIL PITS SITE
LIFETIME
MAJOR CONTRIBUTORS
MAJOR
CANCER RISK
TO RISK
HAZARD INDEX
.JQ
1.7xlO-8 1,4-Dichlorobenzene (80\) 8. 2xlO-5
7. 6xlO-6 Pcss (100\) 0.026
Barium
o (None) 3 . 5xlO-4 Carbon
2.7x10-5 1,4-Dich1orobenzene (100\) 0.13
3. 5x10-5
0.16
6.3x10-10
1.8xlO-5
Trichloroethene (100\)
o
0.14
(NOne)
2.0xl0-6
Trichloroethene (100\)
4.8
12
2.Ox10-6
16.9
-------
Table 15 (a)
COP~PARI SON 01' StTRFACE WATER CONTAMINANT LEVELS TO STANDARDS
WHITEHOUSE WASTE OIL PITS SITE
-----------------------------------------------------------------
STATE OF FLORIDA SURFACE WATER QUALITY
CLASSIFICA':'IONS
------------------------------------------------------------------
SHELLFISH
POTABLE WATER PROPAGATION
RECREATION AGRICULTURAL
SUPPLIES OR HARVESTING FISH
& WILDLIFE WATER SUPPLIES
COMPOtJND RME (mall) CLASS I CLASS II CLASS
III-FRESH CLASS IV
Inorqanics
Aluminum
49.4
~1.5 mg/l
Barium
0.031
~lmg/1
~0.03 mg/l
~0.05mg/l
~
Lead
0.03mg/l
0.011
~ 0.05mg/l
0.206
Zinc
0.03 mg/l
0.358
~ mg/l
~ 0.03 mg/l
~ 0.1 mg/l
~ 1 mg/l
~
Manganese
Volatile Orqanics
Carbon Disulfide
0.025
(1) The value given is a secondary drinking water standard.
Secondary drinking water standards
are unenforceable federal guidelines regarding the taste, odor,
color and certain other
aesthetic effects of drinking water. EPA recommends them to the
States as reasonable goals,
but Federal law does not require water systems to comply with
them. Statea may, however,
adopt their oWn enforceable regulations governing these
concern..
* RMB. Reasonable Maximum Exposure; see Section 6.2 for
description of calculation
methodology.
102
-------
Table 15 (b)
COMPARISON OF SURFACE WATER CONTAMINANT LlVELS TO STANDARDS
WHITEHOUSE WASTE OIL PITS SITE
-----------------------------------------------------------------
STATE OF FLORIDA SURFACE WATER QUALITY
CLASSIFICATIONS
------------------------------------------------------------------
COMPOUND
LEVELS
DRINKING WATER
USEPA DRINKING
WATER STANDARDS
~
USEPA AMBIENT
WATER QUALITY
CRITERIA (AWQC)
SUGGESTED
Inoraanics
Aluminum
Lead
~ 0.05 mg/1
~ 0.05 mg/l
~ 5 mg/l
1mg/l
0.05 mg/l
0.05 O1g/l
Bariwu
Manganese
Zinc
0.05 mg/l(l)
5 mg/l(l)
Volatile Oraanics
Carbon Disulfide
0.025
(1) The value given is a secondary drinking water standard.
Secondary drinking water standards
are unenforceable federal guidelines regarding the taste, odor,
color and certain other
aesthetic effects of drinking water. EPA recommends them to the
States as reasonable goals,
but Federal law does not require water systems to comply with
them. States may, however,
adopt their own enforceable regulations governing these
concerns.
. RME. Reasonable Maximum Exposu~e; see Section 6.2 for
description of calculation
methodoloqy.
103
-------
TABLE 16
GLOSSARY OF EVALUATION CRITERIA
overall Protection of Human Health and Environment -
addre..es whether or not a remedy provides adequate
protec~ion and describes how risks posed through each
pathway are eliminated, reduced, or controlled through
treatment engineering controls or institutional controls.
Compliance with ARARs - addresses whether or not a remedy
will meet all of the applicable or relevant and appropriate
requirements of other Federal and State environmental
statutes and/or provide grounds for invoking a waiver.
Lonq-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 Throuqh Treatment -
is the anticipated performance of the treatment technologies
that may be employed in a remedy.
Short-Term Effectiveness - refers to the speed with which the
remedy achieves protection, as well as the remedy's potential
to create adverse impacts on human health and the environment
that may result during the construction and implementation
period.
Implementability - is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement the chosen
solution.
~ - includes capital and operation and maintenance costs.
State Acceptance - indicates whether the State concurs with,
opposes, or has no comment on the Proposed Plan.
Community Acceptance - the Responsiveness Summary in the
appendix of the Record of Decision reviews the public comments
received from the Proposed Plan public meeting.
104
-------
Bat.8 1'7
RISK-MaD AIm AItAR-BU8D
CLDHUP GOALS
_IftIIOOU D.Sft OIL ,Ift SIft
_..N"~~
UU-."~
us ...~
SOILS U801kG}
InoraanicB
Antimony
Arsenic
Barium
cadmium
Chromium VI
Copper
':..ead
Nickel
Oraanics
Benzene
Benzo(a)pyrene
Bis(2-ethylhexyl)-phthalate
Chlorobenzene
1,4-Dich1orobenzene
Di-N-Butyl Phthalate
Methylene Chloride
PCB 1260
2-Methyl Naphthalene
Naphthalene
Phenol
Tetrachloroethene
Toluene
Trichloroethene
42
32
5,262
53
526
3905
500 (**)
2,105
0.4 (*)
0.1
61.5
42 ( *)
36
7,911
115
1
NTD
317
47,467
4 (*)
2,000 (*)
0.7 (*)
-------------------------------------------------------
(**)
includes inhalation pathway (IR = 20 m3,
BW = 70 kg, VF = OSWER 9285.7-01B, Target
Risk 1& 10-6)
OSWZR directive (9355.4-02) lead Boil
clean-up level
no toxicity data available to calculate
Note: ( * )
NTD
105
-------
~A8LI 17 (con't)
RISlt-BASED AND ARAR-BASED
CLBANUP G<».LS
WBI'l'BBOO9 WASTS OIL PITS SITE
COIftMIDIft AMR-BA.Sm IUSlt-BASm
GROONDWATER (uQ/l)
Inorqanics
Ant imony 5 (PMCL)
Arsenic 50 (MCL)
Barium 1,000 (MCL)
Cadmium 5 (MCL)
Chromium 100 (MCL)
Copper 1,300 (MCLG)
Lead 15 (*)
Manganese 50 (MCL)
Nickel 100 (PMCL)
Selenium 50 (MCL)
Vanadium 150 (A)
Zinc 5,000 (MCL)
Orqanics
Acetone 1,700 (A)
Benzene 1 (**)
Benzo(a)pyrene 0.2 (PMCL)
Bis(2-ethy1hexyl)-phthalate 4 (PMCL)
Carbon Disulfide 1,640 (A)
Ethylbenzene 2 (**)
Methylethyl Ketone 8,460 (A)
3/4-Methylphenol 850 (A)
Naphthalene 10 - (**g)
2-Methylnaphthalene 67 (A)
Phenol 10,000 (A)
Toluene 24 (**g)
Trichloroethene 3 (**)
Xylene 50 (**p)
--------------------------------------------------------------------
(**)
( **p)
( **g)
Risk Assessment Table 8-1
Maximum Contaminant Level
Maximum Contaminant Level Goal
Proposed Maximum Contaminant Level
Action Level (6/21/90 Memorandum from the office of
Emergency and Remedial Response and the office of Waste
Program)
FDER Standard
FDER Proposed standard
FDER Proposed Guidance
Note:
(A)
(MCL)
(MCLG)
(PMCL)
(* )
106
-------
107
APPENDIX D
FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION
CONCURRENCE LETTER
-------
~~
Florida Department 0/ Environmental Regulation
Twin Towers Office Bldg. . 2600 Blair StOne Road. TaJla.hassee, Florida 32399-2400
laWton Chiles, Governor
Carol M. Browner, Secretary
October 30,
1992 ,.........,
("~', r-':! i;;~~-; r-:J ;:-j~~\ 11\ rJ \ rt \
\ n. ' If, , '..::' I...,.".. ..-.......~ ,
I t t V-~~-;""",~, ...,....-. i ;
Ii ! \ ~ "1 jog? i in
\ ~\<, i'~ ::r,! .l ( ,.,) '- ~ hI' ~
,\ " ~ I 1.
\ \ \ \ --'-'''''-;-;-i''''~'-';'' r-i U }
\ \ ! n Li v} \ !, t \ U l.::J. :...-t'
\J tJ \_~ \~~:.;.\.~'.;:';~;\0:; ~ 'J
/. 7.1. ."~'::":" GA,
Mr. Greer Tidwell, Regional Administrator
u.s. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Tidwell:
The Florida Department of Environmental Regulation agrees
with the amended selected alternative to address contaminated
soils and groundwater at the Whitehouse Oil pits site in Duval
County.
The remedial action for soils includes soil washing to remove
the coarse clean soil fraction followed by biological treatment of
. the slurry p4as~ with ~olidification/stabilizationof the residual
. .flne:grath~ci""contamiiiated fraction:~"'Buik.materia..lswil1: be' .. "'" . '.
decontaminated and disposed of off-site. contaminated groundwater
and waste from the soil treatment facility will be treated by
chemical precipitation and granular activated charcoal adsorption.
The treated water will be discharged to the McGirt's Creek
tributary.
. .
The capital cost for construction is estimated to be
$15,500,000 with an annual operation and maintenance cost of
$204,000. The estimated present worth over a period of thirty
years is $18,900,000. We understand that EPA is negotiating a
Consent Decree with potentially responsible parties (PRPs) and
that state cost share will not be required.
We look forward to completion of site remediation.
s~
Carol M. Browner
Secretary
CMB:khh
109
~~)Paper
L:.;-..!..:.' r;~'c'; ~':,':- -;;,:.' .'--;:~
-------
110
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