Umi*d StatM
Enwenm«niil Prewciion
Of Ac* ol
Em«rg«ncy and
EPA/BOO/R04-87/022
July 1987
&EPA Superfund
Record of Decision:
TOWER CHEMICAL, FL
-------
• «wr"tiwMh ncr-wn l' OATA
fftw ntd /nttwnom OH tHt rtvtrn frfa comff/,,mf;
SPA/ROD/R04-87/022
|4. TlTLi
5UPERFUND RECORD OP DECISION
Tower Chemical, PL
10 >e**0«MING ORGANIZATION NAMi AND
lJ SPONSORING AOtNCv NAM! ANO AOOMfSS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
NOTfS
3. MClHINT'S ACCJSSiO*
OAT|
July 9, 1987
•M**0«MINO ORGANISATION Af'OMT
13. TVPf O*
14. S'ONSOHINQ AOINCV COO«
800/00
The Tower Chemical Company (TCC) site is an abandoned manufacturing facility located
along the eastern edge of Lake County, Plorida. The TCC owned and utilized two separate
parcels of land: a main facility and a spray irrigation field approximately 16
residences, located within a 1.2 mile radius of the site? ttfp the underlying aquifer for
their water supply. Wetlands and swamps are also nearby the site. Prom 1957 to 1981,
the TCC manufactured, formulated and stored various pesticides, acidic wastewaters,
produced during the manufacturing process were .discharged into the unlined
percolation/evaporation pond located at the main facility. In July 1980, the pond
overflowed and discharge was diverted to the spray irrigation field. In June 1980, as a
result of damages caused by the wastewater pond overflow, the Plorida Department of
Environmental Regulation (FDER) ordered TCC to cease all discharges from the site
studies, initiated by both EPA and FDER, indicated high concentrations of DDT and
associated pesticide compounds in the main facility and a below normal fish population
in the unnamed stream onaite. In April 1983, the Centers for Disease Control (CDC)
recommended site stabilization and access restriction to the main facility/disposal
areas. In July 1983, an IBM was initiated. It included: excavation of 2,275 sq. ft.
of soil, 1,545 cu. yds. of s«dia»nt and 72 drums with offsite disposal, wastewater pump
and treatment of approximately 1,000,000 gallons with discharge to the unnamed stream;
(See Attached ShMt)
17.
HIV WOAOS AMD OOCUMIMT
«rrom
b.lQSNTIPI|NS/OMN €NOtO Tt«M«
c. COSATI Field/Croup
Record of Decision
Tower Chemical, Ft
Contaminated Media: gw, sw
Key contaminants: DDT, pesticides,
metals
IS. OltTMlSUTION STATIM1NT
if. SICUMiTV
(/ Tttu Rtpofti
I. NO. O'
20. SICUAirv
33.
I PA fi*m 2230.1 (*•». 4-77) •••viowf COITION i» o«fOu«r(
-------
EPA/ROD/R04-87/022
Tower Chemical/ PL
16. ABSTRACT (continued)
backfilling, capping, surface water runoff diversion system, and fencing.
Currently, soil and ground water are contaminated with DDT, pesticides and
mecals.
The selected remedial action includes: removal and onsite treatment of
approxiamtely 100,000,000 gallons contaminated ground water with temporary
onsite storage followed by discharge to surface water; provision of
individual treatment units for two private wells within the immediate site
vicinity, excavation and incineration of approximately 4,000 cu. yds. of
contamianted surface soils from both the overflow area and portions of the
burn/burial area of the site; analysis of the treated soils to determine the
proper action for residual management; exploration of the burn/burial area
to determine the source of a magnetic anomaly. If relic drums are
identified, the contents will be typed and disposed of by thermal
destruction; decontamination of two storage tanks and nearby concrete pads;
and point source run-off diversion. The estimated capital cost for the
remedy is $6,788,000 with no O&N costs.
-------
I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
'*, x/
""*^* REGION IV
3*3 COURTLANO STKCCT
ATLANTA, SCOftSf A 30SI9
DECLARATION FOR THE RECORD OF DECISION
Tbwer Chanical Company Site
Clermont, Florida
STATEMENT OF PURPOSE
This decision document represents the selected remedial action for the Tower
Chemical Company site which was developed in accordance with the Conprehensive
Emironmental Response, Compensation and Liability Act (CERCIA), as amended
by the Superfund Amendments and Reauthorization Act (SARA), and to the
extent practicable, the National Contingency Plan (NCP).
The State oc Florida has concurred with the selected remedy ana has agreed
to provide funding tor 10* of the Remedial Action cost which is estimated
to oe 56.8 million.
STATEMENT OF BASIS
This decision is based on the administrative record which is on file in the
EPA Region IV offices, 345 Courtland Street, Atlanta, GA or is available at
the Cooper Manorial Library, 620 West Montrose Street, Clermont, Florida.
The attached index identifies the documents whicn comprise the administrative
record upon which the selection of a remedial action is baaed*
DESCRIPTION OF THE SELECTED REICDY
Oroundwater recovery operations will be conducted to remove all groundwater
which contains contamination in excess of the criteria presented in Section
VIII of the Sunury of Remedial Alternative Selection. Recovered groundvater
will be trvstsd in an on-site treatment facility. Treated groundwater will
be stored OB-Slts until analytical results confirm that the effluent meets
the establiahsd clean-up criteria. Disposal will be via surface water
discharge* QraudMBter recovery operations will be considered as part of
the RMfrratal Action for 10 years fron inception or until the groundwater
clean-up goals are reached; whichever occurs first. If the groundwater
recovery system is still operating atter 10 years, the efficiency of the
gromdwater recovery system will be re-evaluated.
Individual treatment units will be provided for the two active wells within
the unusdiate site vicinity; one owned by Mr. and Mrs. Charles Hubbard and
one owned by Classic Manufacturing Inc. wnich provides potable water to
the employees of Vita-Green, Inc. EEfc will maintain the units until tne
groundwater recovery is complete.
-------
Surface soil removal will be conducted in the overflow area of the former
waste water pond, the bum/burial area, around the storage tanks, and
all soils which have contaminant concentrations in excess of the clean-up
criteria established in Section VIII of the Summary of Remedial Action
Selection. This will be approximately 4,000 cubic yards.
Excavated soils will be treated on-site by thermal destruction of the con-
taminants. Thermally treated soils will be analyzed after the test bum to
determine the proper action for residual managanent. Exploration of the
bum/burial area to determine the source of a magnetic anomaly will be con-
ducted in conjunction with the soil removal program. If relic drums are
identified, the contents will be typed and disposed of by thermal destruction
In addition, two storage tanks and nearby concrete pads from the Tower
Chemical Co. operations will be decontaminated. Any sludges from the tanks
will be thermally destroyed and wash down fluids will be treated in the on-
site treatment facility. The decontaminated tanks will bo recycled and the
concrete pads will be backfilled with the treated soils.
Point source run-off diversion will divert run-off from the main building
roof and the wash down waters for the Vita-Green Company to reduce erosion
of the soils. All areas affected by implementation of the selected remedy-
will be regraded and revegetated to enhance soil stability.
Operation and maintenance activities will be limited to verification of the
completeness of the Remedial Action since all site contaminants will be
destroyed.
DECLARATION
The selected remedy is protective of human health and the environment,
attains Federal and State requirements that are applicable or relevant and
appropriate, and is cost-effective. This remedy satisfies the preference
for treatment that reduces toxicity, mobility, or volume as a principal
element. Finally, it is determined that this remedy utilizes permanent
solutions and alternative treatment technologies to the maximum extent
practicable.
cu
Jack E. Raivr 7 /&* /
Regional Administrator C/
-------
Tower Chemical Company Sice
Administrative Record Index
Action Memorandum
Community Relations Plan
Decision Memorandum
Environmental Service Division Investigation Report
Feasibility Study -- Draft Final
Feasibility Study Appendices — Draft Final
Geologic Profile
Hazard Ranking System Score
Hydrogeologic Tests
Indicator Qnemicals used in the Remedial Investigation
Intergovernmental Review Letter
Natural Resouces Damage Assessment
Public Healtn Evaluation
Public Meeting Transcripts 9/16/db
RCRA Lana-San Policy
Remedial Action Master Plan
Remedial Investigation Volume I Final
Remedial Investigation Volume II final
Remedial-Investigation Site Operation Plan
Remedial Investigation/Feasibility Study Work Plan
Removal Action Report
Responsiveness Summary
Risk Assessment
Soil Technologies Letter Report
As of 6/24/d7
-------
SKCTICN I
SITE LOCATION AND DESCRIPTION
The Tower Chemical Company (Tower) NPL Site is located on County Road 455
along tne eastern edge of Lake County, Florida. The site is 3.3 .niles east
of Clement, Florida and 15 miles west of Orlando, Florida (Figure 1). Tne
Tower site is an aoandoned facility which manufactured various pesticides
tram 1*57 to 1981.
The Tower Chemical Corpany owned and utilized two separate parcels of land
during the time the company was in operation: a main facility and a spray
irrigation field.
The lain facility (Figure 2) consisted of a production building, a small
utility ouilding, an office, and two disposal areas: a Durn/burial area
for solid wastes and a percolation/evaporation pond for acidic wastewaters.
The spray irrigation tield covers approximately seven acres and consists ot
tour parallel strips or land (Figure ». A series of spray oeus were used
in i^au cor discharging process wastewaters.
'
The sita is relatively flat across the main facility with only aoout 5 feet
oc relief. The spray irrigation tield snows aoout 20 ceee oe reiiet,
descending from south to nortn. Both portions of the site drain into
swampy areas wnich eventually drain into an unnamed stream north oc tne
site, wni.cn in turn, drains into the Gourd Necx area of Lake Apoptca. The
lane and nearoy swamps and wetlands provide an important natural naoitat
for local wildlife, including nesting Dald eagles.
Within a 1.2 mile radius of the site, land use consists of agricultural
lands (4d%), lakes and wetlands (311), range land and forest (9%), extraction/
transitional lands (7%), residential property (less than 3D, and commercial/
industrial land (less'than 21).
Locally there is no central water supply; thus, approximately 16 local
households (60 consuasrs) rely on private wells wnich tap the Florioan
Aquifer for tneir water supply, within the site area, no surface water
resource* as» used for drinking water supplies, out Lake Apopka is used tor
recreational purposes.
-------
MAftlON COUNTY
TOWIH CNIMICAL
COMPANY SIT!
Figure 1A - Sic* Location Map, Tovtr Ch«mic«l Coopany Sice.
-2-
-------
-------
rONTIOM Of f NK
MICAt COMPANY •!?*
foil f MI
Figure 2 - Detailed Site Map. Main Facility.
-------
•PMAV MftMATMMt f«LO F
-------
SECTION II
SITE rflSTOR*
OPERATIONAL HISTORY
Fran 1957 to 1981, the Tower Chemical Company manufactured, formulated, ana
stored various pesticides. The two main products produced by Tower were
chiorobenzilate (a miticide) and a copper-cased agricultural fungicide with
tne trade name "Cop-o-ciae". In order to produce ctuorooenzilate it was
necessary to either txiy or manufacture the compound dicnlorobenzil. During
periods in wnicn aicniorooenzil was difricult to obtain, the Tower Chemical
company manufactured it in-nouse from dicaLoro-diphenyl-tricnloroethane
(OUT). This operation was used during tne last few months" of the Company's
operation.
Acidic wastewaters were produced during the manufacturing process.
Originally, tnese wastewaters were discharged into the unlined percolation/
evaporation pond located at the main facility. In July 1980, the spray
irrigation field was operational and was Deing used for discharge of tne
acidic wastewaters. The spray irrigation field was,jused because the
percolation/evaporation pond was toll, and in cactr'did overflow its banxs
during July 1980.
The burn/burial area had historically been used as a burning ground for
disposal of the company's solid chemical wastes and for burial of solid
wastes. The buried wastes were both drummed and undrummed wastes.
As a result of the percolation/evaporation pond overflow, the Florida
Department of Environmental Regulation (FDER) and the U.S. Environmental
Protection A-ancy (EPA), initiated sit* investigations in early 1981. In
December 19fc. all production'operations wen stopped at the Tower Chemical
Company and the facility was decommissioned during 1981.
In 1981, prior to the decommissioning, the warrenty deed for the property
owned by tns Tower Chemical Company Plant was transferred to James E.
Gallagher, as trusts* and tne spray irrigation field was sold to O.T.
Enwpriss*
After "\trmn at the Tower Chemical Company, two new businesses were opened
on tne mitt facility; Classic Manuracturing Company and Vita-Green Inc.
from 1981 to 1986, Classic Manufacturing used aoout 1 acre of tne main
facility for the manufacture of plastic worm cisning lures. During the
summer ot_1986, Classic Manufacturing moved to a new location off-site
although Classic still holds the property deed. After leasing an other
portion of ths- property, Vita-Green, Inc. moved onto th* site in September
1981. This company blends potting soils and packages it tor home garden
ud*. Vita-Grssn is still actively operating on the western portion of tne
main facility.
-------
The area used for the eastern portion of the spray irrigation field was
bought jointly in tne early l*ao's oy Ms. Mabel Watson ana Mr. William
Watson, Jr. Both owners now live on tne property and use the land for
cattle and goat grazing as well as sugar cane cultivation. The western
portion was purchased Dy Mr. Ben Harrison who nas Duilt his hone on the
property ana used most ot the land to establish a wholesale nursery.
None of the activities subsequent to the Tower Chemical Company operations
have significantly impacted the site.
PERMIT AND REGULATORY HISTORY
The permit and regulatory history began in July 1979, when the Tower Chemical
Company applied tor a National Pollutant Disnarge Elimination System
(NPDES) permit, followed in November 197y, by an application to construct
an industrial wastewater treaonent and disposal system. These applications
referred to occasional discharge of wastewater into the unnamed stream at
times of flooding and to the construction of the spray irrigation field. .
The EPA did not issue the NPDES permit, but the FDER did grant a Permit to
Construct tor the spray irrigation system. The conditions of the construction
permit included an initial period of operation jgpr-appropriate testing to
determine compliance with the permit conditions. The permit required
tne installation ot monitoring wells before use of the area as a disposal
site to determine baocground water quality. Groundwater monitoring every
six months after operational start-up was also a condition of the permit.
As a result of the damages caused by the wastewater pond ov^rtlow, on June
5, 19dO, FDER ordered Tower Chemical Company to cease all discharges from
the site. The Tower Chemical Company responded to the order and assured
rDER of compliance. In July 1980, the State Circuit Court ruled that the
Tower Chemical Company could continue to operate only if the company met
the FOER requirement*. From this point, Tow»r Chemical Company and FDER
entered into negotiation* to da-tin* tn* clean-up process cor the site.
Meanwnile, FDEK pursued legal action against the Tower Chemical Company and
its president, Mr. Ralpn Roane.
In August 1940, EM conducted a preliminary hazamnna waste site investigation
of the UMSST Chemical Company site. The site received a Hazardous Ranking
System (BMt eooce of 44.03 (Appendix A). As a result of the MRS score,
the Tower flea 1 1 •! Company site wae proposed for inclusion on the National
Priorities* list of Hazardous Wist* sites (NFL) in October 1981. The site
was finalised on th* NPL in o*c*mo*r
On Jun* 15, 1982, FDER, Tower Chemical Company, and Mr. Ralph Roane agreed
to the entry ot a Consent Final Judgement in which Tower Chemical Company
was to pay compensatory damages in the amount of 510,000,000 and Mr. Roane
was to pay $40,000.
-7-
-------
In develocment of a clean-up plan, EPA provided input to FDER regarding the
need to prepare a feasibility study (FS) to develop a range of remedial
alternatives. The Tower Chemical Company agreed to prepare an FS. Inter-
actions occurred over a period of about one year among EPA, FDGR, and Tower
Chemical Company, but the FS was not developed, in February 1983, FDER
considered filing for contempt of court because neither the company nor Mr.
Roane had paid the court-ordered judgements. Instead of taking further
legal action, FDER requested that EPA acguire the management role for the
remedial planning process for the Tower site.
In March 1984, EPA tasked NITS Corporation, under the original REM-FIT
contract, to conduct a Remedial Investigation and Feasibility Study (RI/FS)
for this site.
A public meeting was held on September 16, 1986, to present the draft
Remedial Investigation report and the draft Feasibility Study. The public
meeting was the initiation of a public comment period which closed on
October 7, 1986. Each comment received during the public oawnent period
was addressed in the Responsiveness Summary (Appendix B).
PREVIOUS STUDIES
As a result of the 1980 wastewater pond overflow incident, both EPA and
FDER initiated separate studies of the Tower site. The FDER found that
water with a low DH extended from the overflow area* to" Lake Apopka. In
August 1980, the Florida Game and Fresh Mater Fish Commission conducted a
study of the unnamed stream and Lake Apcoka. Their results indicated that
the fish population in the stream was below normal.
On August 12, 1980, EPA Region IV Environmental Services Division (ESD)
conducted a site sampling investigation which included the main facility
disposal areas, the unnamed stream, four private wells, and the spray
irrigation field. High concentrations of DOT and associated pesticide
compounds were found in samples collected from the main facility waste
disposal areas. The stream was determined to have been affected by chemicals
from the Tower sits. Of the four wills sampled, one organic compound was
identified in a sample1 frcn one well, but EPA suspected that this compound
was the result of laboratory contamination. Sens pssticids compounds were
also identified in soil sample* from the spray irrigation field. In
February 1981, three of the four residential wells were resampled and the
analytical result* revealed no presence of organic compounds.
In 1981, FOB collected samples from the spray irrigation field and the
main facilitr disposal areas. The soils at the spray irrigation field were
found to be contaminated by pesticides primarily within the upper foot of
soil. Higher levels of pesticide contamination were identified at the
bum/burial area and at greater depths. A geophysical survey was also
performed at the main facility as part of the PDER study. The report
issued by FDER indicated a possible groundwater contamination problem caused
-8-
-------
by mounding effect of the qround water beneath the former wastewater oond.
EPA's Contractor, NUS Corp. recommended further hydrogeological investigation
with the concern focusing on a oossible hydraulic connection between the
surficial and Ploridan aquifers.
In 1982, FDER collected several ground water samples from temporary sandpoint
wells set just below the water table. These analytical results indicated
the presence of CUT and dicofol in the ground water. Later the same year,
the FIT contractor for EPA (Ecology & Environment, Inc.) attempted a
geoohysical survey at the site with limited success, presumably due to very
dry soil conditions.
Also in 1982, EPA/ESD conducted an ambient air sampling investigation to
suooort the site's HRS score. The Tower Chemical Company was not in
operation at the time of the study. The results of the investigation
indicated that there was not an ambient air quality problem in the vicinity
of the main facility.
In April 1983, the Centers for Disease Control (CDC) recommended site
stabilization and access restriction to the main facility disposal areas.
This recommendation lead to the authorization and implementation of an
immediate removal measure in July 1983. Following the removal activites, a
Remedial Action Master Plan (RAMP), was developed for the site but the RAMP
itself did not entail field work. . -
PREVIOUS SITE RESPONSE ACTICNS
Following the closure of the Tower Chemical Company, FDER requested assistance
from EPA to implement remedial action at the sita. The main facility was
further sampled and an immediate removal measure (IRM) was conducted by EPA
in July 1983. FDER maintained the lead authority for the removal work
necessary at the spray irrigation field. Descriptions of the IRMs follow.
Main Facility IRMt The .Cariters for Disease Control Agency for Toxic
Substance and Disease Registry (CDC/ATSDF) determined that a potential
threat to public health existed at the Tower sita due to the potential for
exDosura to wastes in tha main facility area. Field studies identified a
2,275 square foot ana that comprised tha bum/burial area. This area was
excavated to an muga depth of 8 faat, where previously elevated levels
of pesticidaa diminished. At a depth of 5 faat, approximately 70 empty
drums and 2 pacCtelly filled drum* were unearthed. All of these excavated
materials war* ahippad to tha Chemical Waste Management facility in Qnille,
Alabama for disposal.
Simultaneous with tha excavation activities, watar was pumped frcn tha
percolation/evaporation pond. The wastewater was treated on-sita
to levala which complied with existing laws by usa of an activated carbon
filter and pH adjustment.
-9-
-------
The treated wastewater, which had oeen verifed for release, was discharged
into tne unnamed stream nortn or the site, and thereoy into Lake Apopka.
Approximately 1,000,000 gallons of contaminated water were treated and
discharged. Once the water level in the percolation/evaporation pond was
lowered surticently, excavation ot the contaminated sediments began. The
sediments were dewatered ana oulked with the excavated soils before oeing
shipped to Dm lie, Alabama. Approximately 1,545 cubic yards of contaminated
sediments were removed from the site.
After the ranoval activity was completed, both the burn/burial area ana the
pond were backfilled witn clean fill material. The excavated portion ot
the burn/burial area was covered with a clay cap. A surtace water run-oft
diversion system was installed to reduce the amount ot precipitation wnich
could percolate enrough tne tormer pond area. Finally, a chain link fence
with a locking gate was erected around the perimeter of the two disposal
areas.
Spray Irrigation Field IBM.; In 1981, FDER ordered O.T. Enterprises, the
property owner, to clean-up the spray irrigation field. This clean-up was
to consist of removal of the contaminated soils around each sprayhead and
disassembly of the system. the PVC lines and sprayheaos were removed and
approximately • 1.5 feet of soil were removed from tne defoliated areas
surrounding each spraynead. This soil reported?/Vas placed on the west
side of the west pond. The retaining soil was then tilled and lined.
Other reports suggest that the spray irrigation field was disced and limed
only, and that no soil was removed (Hubbard, 1984). With this uncertainty,
the spray irrigation field was addressed as part of the RI/FS.
-10-
-------
SECTION III
CURRENT SITE STATUS
The physical characteristics of the Tower Chemical Company site were
evaluated during the Renedial Investigation (RJ) process. As a result of
the Rl field study the current status of the site has been well defined.
In order to understand the current site conditions it is necessary to kno
what compounds were historically used on the site. This information is
presented in Appendix C.
SOILS
•lain Facility Soils
The soil samples collected in the area of the main facility were obtained
from both surface and subsurface sampling points from five areas which wei
defined by drainage pathways (Figure 4). The five areas are:
The east drainage field ^
The north bum/burial drainage area *"**
The south burn/burial drainage area
The former pond overflow area, and
The main building drainage area
Surface soil sample locations are shown in Figure 5. The locations of
subsurface soil samples collected at depths of 2 feet are shown in Figure
6 and those collected at depths of 7 feet are shown in Figure 7.
Analysis of the surface soil samples indicated that the compounds listed
in Table 1 were present in significant quanitities compared to the
background samples. The compounds identified in these analyses are
reflective of the known historical operations at the Tower Chemical Company
site. The analytical results'of the two-foot and seven-foot subsurface
soil samples are shown in Tables 2 and 3 respectively.
The results of the) main facility soil sample analyses show that the surface
soils throusjwut the facility are contaminated with 4,4'-DCT and its
derivative*, chemicals which are directly associated with the Tower ChemicaJ
Company4* operation (Figure 8). Specifically, four areas were identified
at the main facility that contained significantly elevated concentrations
of 4,4'-DOT and its derivatives in comparison to background levels (Figure
9). These four areas are: the storage tank ana next to the main building
(to depths of less than 1 foot), the overflow area (to depths of less than
-------
Figure 4 - Surface Water Run-Off
-------
Figure 5 - Surface Soil Sa^le Locations
the Remedial Investigation Main Facility.
-------
Figure 6 - Subsurface Soil Sample Locations Used In tlie Remedial Investigation, 2 Foot Depths. Main Facility.
-------
Cn
I
Jt.
LEGEND
10CATIOM
Figure 7 - Subsurface Soil
-------
o, Seated C.,.,^ |. SurfjlM
s. Main Facility.
M'-DDT
M'-ooe
i.v-ooo
A*ha-BHC
Beta-BHC
DelU-BHC
Clhion
ChJorobenzilaie
Oicolol
Xylcne
E«hy| Benzene
Chromium
NA
NA
NA
3.000J
NA
NA
NA
NA
NA
NA
NA
SS-M.SS-II
NA
NA
NA
5.000 - 12.000
*.000 * 400,000
SS-0*. 50-21
50-25. CMF-OI
21
12
NO-9.200C
NfM.MOC
ND-I2.000C
NO - )«OC
ND-220C
NO-«6C
N0-).600
7-IN- J.800
t.9M _ t AAA
NA
NA
NA
NO-7,400
NO-IOO.OOOJ
ND-37.000C
IM.M.OOOC
30.000JC
NA
NA
NA
ND-6.MO
'.000-24,000
SS-IJ. SS-M
»-it; c-ois
SS-102. SS-IOJ
material.
-------
,„
Area
M'-DDT
M'-DDC
M'-ooo
Beta-BHC
Gamma-BHC
Delta-BHC
Ethion
Chlorobenzilate
Oicofol
Xylene
Ethyl Benzene
Chromium
Copper
" " JJD J**lwi»' analysed for but not detected.
N Presumntiw* «*»,rf__~ * »-•«»».
•
•»
NA
NA
NA
HCC-02
1AM-AA nnni
••W-oo,(JUOJ
NfM,IOOJ
Mf\_IA VCAI
"•l*-l*,/jOJ
ND-J.430J
NO-260
3.9N-I.300
' ND-3,600
NA
1^*»
NA
NA
NO- II, 600]
6,000-720,000
W\_A* C«% *• ^—
Outside F*«r*
NO-|,%OOC
2]-3X)C
ND-2.IOOC
NO-5.%]N
NO- UN
ND-J5.7J
NO-«.6J
NA
NA
NA
XX)
27, XW]
--— jpiiiaj
Process Area
NO-0. 7]
ISJH 1 1
I»U- 1 J
ND-2J
4,000 JN
NA
NA
ND-3,600
2,000 3-60.000J
K_Areas^
l«tral^"A«>.T
ND-I.9QON
ND-J70C
ND-300JN
NA
NA
NA
800
4.200
SO-04.SS-05
SO-lf. SQ-20. SO-2%
SS-19. SS-20
N
3
C
NA
not etected.
Presumptive evidence of presence of material.
Estimated value.
Confirmed by CC.
Not analyzed.
. ss-n
-------
CD
I
C«p.rlso» of SeUc.ed Conta»lo.,uo ,,„„. J^irfL Soil s ,
Hai« F,cuay. ,„, ,alv«s ,££.*£ sriu^,-" rm •*"»•
11
M'-DDT
*.«'-DDE
».V-DOD
Alpha-BHC
Beia-BHC
Camma-BHC
Delu-BHC
Elhion
Chlorobenzilate
Dicofol
Xylene
Ethyl Benzene
Chromium
Copper
7.9* /*— .
fTflVtB
..F
«
»
NA
•\l A
NA
NA
NA
NA
NA
NA
SS-O3
. . Burn/
&SL JM3 7-F«*»t»
ND-«00
NO -19
NO -67
NA
NA
NA
NA
NA
NO - 362
MA
WA
•wl A
NA
NA
• vrv
NA
NA
A-J. B-2.
•-3. CO
Burial Area
^•^•^^S^^— _z~ ^*™
T«i%7^^-
1 1 - ««OC
?.J - 290C
)] - S80C
NO - 26
^*^ avo
(L * *
NA
•Vft A
NA
NA
3.0003-4,700
8,300 - 40. 000 3
50-01, SO-IO
SS-06.SS-IO
— |MJ-,§g^ Wa»tew^ter P««d
!^J l-i'aftt* IM«v«. .»^
19,000-3,200,000
260.000-14,000.000
26.000-2M.OOO
NA
NA
NA
NA
NA
&l A
NA
NA
• »• »
NO-13
NO-IJ.J
NO-340
e-OI. F-41. C-OI
H-OI. Uli i AI
-^-—~ • T,""""^!
2.600.11.000
16.M03C-IIO.OOOC
NO - 2.000
300.0003
140 -
48 -
3,600-
51,000 -
THI-OIS
"
~
—
_
-390,000
I.IIOJ
1973
•4,400
160,000
. TRI-02S
Estimated value.
Not analyzed.
K-OI, L-OI, M-OI
-------
MOUNDS OF POrfMG SOIL
LOCATION
LOCATION
Figure 8 - Distribution of Total 4 A'-DUT ^ i ,
Main Facility. ' a"d lts Derivatives in Surface Soil and Sediment Samples,
-------
O
J (.._._
I »WBMFM
x'":
LEGEND
A •MftFACI SON. SAMPIC LOCATION
CONCMKTI FAO LOCATION
A^raOIIMATC CMTCNT Of MOT-SPOT
*umm*+m goM. CONTAMINATION
*c«n
» - "Hot Spot» Surface *,„ Co.,,amlnatlon>
-------
1 foot), tns- drainage ditcn northeast ot the burn/burial area (to depths ofc
less than 1 toot), and an area northeast ot the ent.ince orwe (to depths
of aoout 3 feet). The drainage area south of the burn/burial area was
found to be contaminated with copper as well as other minor constituents.
Subsurface soils in the burn/burial and former wastewater pond disposal
areas also were round to contain elevated levels ot site-related contaminants
(Figures 10 and 11). Contaminants in the burn/burial area soils are
located in the unsaturated zone while those in the former wastewater pond
are already below the water table.
The horizontal extent of contaminated soil in the burn/burial area
roughly corresponds with the boundaries shown in Figure 12. Intiitration
through the contaminated unsaturated zone appears to be contributing to
groundwater contamination ot the surticial aquifer. Dispersal ot contaminated
surface soil was a problem in the past as evidenced by contaminated soils
in tne receiving drainage areas. Since tne tormer waste disposal areas
nave oeen covered, run-oft and erosion of contaminated soils appear to
currently be only a minor concern.
The overall results of the RI revealed that only a small volume ot soils in
the main facility area exceed tne clean-up criteria specified as part of
tne selected remedy (Appendix D). The areas which show contamination in
excess of the 'clean-up criteria are along the seutJHtestern portion oc the
burn/burial area, along the burn/burial ana run-off zone, tne overflow
area ot the tormer waste water pond area, and the tank spillage area adjacent!
to the main building. The overall volume of these contaminated soils is
approximately 4UUO cubic yards.
Spray Irrigation Field Soils
The soil samples collected from the spray irrigation field were also
collected trora surtace and subsurface sampling points. The sample collection
area consisted ot four rectangular strips: Area 1, Area 2, Area 3S, and
Area 3N. These four anas are based on tne ana affected oy the tour
sprayneads used by the Tower Chemical Company for wastewater disposal.
Surface soil samples ware collected from the points indicated in Figure 13
and subsurface samples wan collected at the points indicated in Figure 14.
Subsurface 9011 sample* wan collected at depths of 2,3, and 4 feet. Due to
the hcmogesjeous nature of the spray effluent/ it was feasible to use composite
sampling techniques. No surface samples wen collected from Area 3N due to
the active presence ot private regrading operations in which clean planting
soils wen added in that ana during the field ettort. An additional
composite surface sample was collected along the western boundry of the
west pond when excavated spraytield soils from the FDER ISM were reportedly
stored.
-21-
-------
I
Kl
Figure 10 - Distribution of Total 4 V-
DDT
in Subsurface Soils. 2 Foot Depths. Haln
-------
LCOCM0
«••« M tOM.
. OC AVION
• l««4 •• •-• FT. 6OM»OMT« SOM,
•AM^IC 1OCATIOM
• ^^Atf fli V* AMft flA* ^Mf AflfeU
^^^^v ^w 9 ^^^* w^ ^^
Figure 11 - Distribution of Total A.A'-DOT
Facility.
Derivatives in Subsurface Soils. 7 Foot Depths. Hal7
-------
I
KJ
Conta.iaat.cn. «... Faclllty.
-------
Ln
I
-------
Figure 14 - Subsurface Soil
Spray Irrigation
L°Catl°ns
Remedial Investigation - 2,
and 4 Foot Depths.
-------
All control samples, oodi surface and suosurcace, were collected fron a
citrus orcnara wnicn lies upgradient and west oc tne spray irrigation cieid.
me nature of the contaminants found in tne surface ana subsurface soils at
tne spray irrigation cield can also oe direcuy related to tne operations
at cne lover Site due to tne presence of 4,4'-DDT and its derivatives. A
comparison oc selected contaminants round in samples collected during tne RJ
from surface and suosurcace soils is presented in Table 4.
rne surtace soil sampling ecforts revealed tnat soils could oe transported
downgradient if eroded, as snown in Figure 15, Due it was demonstrated in
tne RI Report tnat significant erosion is not occuring. rne horizontal
extent ot surface contamination is generally expected to oe as shown in
Figure 16. Surface expression of tne soil contamination is reflected oy
tne presence ot stressed vegetation in tne areas around the former
sprayneads.
Analysis of tne subsurcace samples has indicated that contamination by 4,4'-
DOT and its derivatives is detectable to depths oc about 3 feet in Areas
1,2, and 3S (figure 17). In Area 3N, the spray line apparently was not
used to any great extent during die Tower Chemical Company spray irrigation
operations because no contamination was identified in any of tne subsurtaca
soil samples collected in tnat area. No significan&»soii contamination was
found along die wast bank of the West Pand.
The remedial investigation snowed tnat no contamination exists witnin tne
spray irrigation field in excess ot tn« established soil clean-up criteria
cor cms site (Appendix 0). There core, soil contamination in tne area oc
tne spray irrigation field is not of concern cram eidier a public neaitn or
an environmental standpoint.
HYDHOGEOLOGY
Groundvater Characteristics
*
Groundwater in the vicinity of di« lower Sit* occurs in tne unconfined
surticial aquifer and tne confined Fioridan Aquifer (Figure id), ina
surf icial aquifer extend* ever moet of tne site and is composed mainly of
quartz MO* «rttn varying amounts of clay and silt. Wells screened in tne
surf icial aqjdfer are not used for domestic water supplies. Groundvater in
tne Florida* Aquifer flow* tnrougn solution cnannels and joint systems in
tne limestone bedrock. The Fioridan Aquifer is tne major potable drinking
water source) in central Florida and many local residents nave walls screened
in solution channels witnin tne Fioridan Aquifer.
-27-
-------
M--ODF
••••-one
I
Kl
tfl
ND.lt/
NA
NA
NA
NA
I.MI-I./W
££ »*»
-------
I
KI
VO
I
Figure 15 - Distribution of TotalAA'DhT , . Ml «•/««
Irrigation Field. ' and Derivatives in Surface SolJs and Sediments. s,,ray
-------
O
I
Figure 16 - Areas of Surface SoU Contaa,luat
Spray Irrigation Field.
-------
Figure 17 - Distribution of Total 4 4'-DOT i „ ~~
»«pth8. Spray Irrigation Field. U*rlvat**«« *» Subsurface Soil Sa.ples - 2. 3. and 4
-------
Systeai
StrlM
Formation
Thickness (ft.) llthologlc Otscrlptlon
and to
Quaternary Moloceoe 90
Melstoceee Deposits
Miocene or 10
Deposits 110
Tertiary Mawthom 2SO
SOO
Eocene Ocala Limestone
S
W *
> Q
F U
I 1
C F
1 t
A R
L
F
L A
0 Q
R 0\
1 K
0 f \
A f
N R
Sand, tan to yellow, loose, medium to fine ejuartz. some-
times with shells and/or minor clay content - often has
hardpan layer of Iron-oil de-cemented, rusty red to dark
brown, medium to fine sand In upper part of section;
source of water for shallow sandpolnt wells.
Upper part Is tan to buff, fine to coarse sand and gray
to light gray sandy clay, clayey sand, and shell beds;
clay often contains abundant mo Husk shells. Lower
part Is limestone, tan to yellow, often highly sandy.
porous, and cavernous. Also with a few thin beds of
brown crystalline, dolomltlc limestone; Tertiary
section Is major source of water for shallow wells.
Gray to blue-green and olive-green clay, sandy clay.
and sandy limestone; usually phosphatlc with abundant.
well-rounded, polished, granules and pebbles of
phosphate. Formation not usually considered a good
source of water; some wells tap lenses of sand and
limestone In the upper part.
White to cream; chalky, massive, fossil Iferous. marine
limestone; with zones of tan to buff granular limestone;
and discontinuous zones of gray to brown, hard.
crystalline dolomite near the base of the unit.
Formation cons' Idered a good source of water.
I
OJ
to
Reference: Falrchlld. 1972
Figure 18 - Generalized hydrogeologic profile of the surflcial aquifer syate* and the Florldan Aquifer.
-------
Surficial Aquifer. The surficial aquifer, in the area of the Tower Chemical
Company site, flows generally to the northeast, towards the unnamed creek.
The water table ranges from 0 to 20 feet below the land surface. Horizontal
groundwater velocity is estimated to be less than 2 feet per year over most
of the site, but a 150 foot area extending fron the northeastern portion of
the burn/burial area may have a horizontal velocity of 10 feet per vear due
to localized mounding of the groundwater. Groundwater flow front the site
may, in part, discharge into the unnamed creek north of the site and
ultimately reach Lake Aoopka. Based on the field investigation, it is very
likely that a vertical component of flow exists from the surficial aquifer
downward into the Floridan Aquifer.
Floridan Aquifer. The Floridan Aquifer, in the site area, is poorly confined
by the overlving Hawthorn Formation which is laterally discontinuous across
the Main Facility due to the presence of relic sinkholes. Groundwater in
the Floridan Aquifer moves rapidly through solution channels in a
northeasterly direction. The top of the Floridan Aquifer ranges between 54
and 188 feet below the land surface, with the potenticrnetrie surface between
5 and 10 feet below the land surface. Generally, the potent iometric surface
of the Floridan aquifer imitates the topology of the surficial aquifer's
water table. The Floridan Aquifer is the primary drinking water source
within the site area.
Analytical Results
Surficial Aquifer. Groundwater samples fron the surficial aquifer were
collected in November 1984 and in March 1985 from 8 new monitoring wells
and 2 wells installed by the Tower Chemical Company (Figure 19). Samples
collected from the uogradient well, DS-01, provided background information.
Two additional samples were collected to provide information on the ground
water quality in areas of high soil contamination: from the surface of the
wastewater pond (a surface expression of the water table) and from ground
water which had infiltrated an excavation trench in the area of the former
wastewater pond.
•
Table 5 lists the contaminants of concern identified in the surficial
aquifer at the main facility. The contaminants of concern were selected
based on tns overriding health and environmental risks posed by the compounds
present, as ilstsjpilnsrt in accordance with the Public Health Evaluation Manual,
October 198$, aoi existing environmental laws.
The results of tne- groundwater sampling and analysis show that the surficial
aquifer at ths- main facility is contaminated with xylens-, ethyl benzene,
gamna-BHC, chlorobenzilats, 4,4'-OOT with its derivatives and several other
compounds. Contaminant migration to ths northeast has extended beyond the
boundaries of the bum/burial area with possible contaminated groundwater
-33-
-------
-------
in
I
Material analyzed for but not detected
Estimated valu. "elected.
NO-2JN
Below Bum/
Burial Are*
ND-O.I
ND-J.S
NM.2I
ND-J.J
Np-700
IJD-I30
«
Agfev <•
ND-5I
I7-33J
11-22
OI.SS-02
&lff% Ja A
ND-4»0
42-320J
62-3.900
I«-J(OOOJ
110-700
32-*30
OS-03vOS-Of
~
ND-9.S
NO-460
ND-1,700
NO-500J
N£^I,IOO
1 5-100 J
DS-04, DS-0*
NA
NA
NA
-
JJ
ns-07
-------
discharge occurring into the ditch east of the facility (Figure 20).
Vertically, contaminated ground water in the burn/burial area was identified
at a depth of 35 feet in monitoring wells set on top of the Hawthorn
formation.
Activities from the Tower Chemical Company site did impact the surficial
aouifer groundwater in the vicinity of the main facility. Contaminants
were also detected at a depth of 60 feet beneath the former wastewater pond
in the relic sinkhole. Migration of contaminants from the surficial aquifer
is probably occurring via this relic sinkhole.
Samples collected from the area of the spray irrigation field indicated
that there has been minimal impact on the surficial aquifer in that area,
and no health criteria were exceeeded. Therefore, it was concluded that
the wastewater spray irrigation practices of the Tower Chemical Company did
not significantly impact surficial ground water resources in the vicinity
of the spray irrigation field.
Floridan Aquifer. Groundwater samples from the Floridan Aquifer were
collected from a total of 12 private water supply wells and two newly
installed monitoring wells (Figure 21). Monitoring well MFW-01 was used
as a background well.
The analytical results of the groundwater samples collected from the Floridan
Aquifer indicate that Tower Chemical Company site*'has not impacted the
groundwater quality of the Floridan Aquifer. Of all compounds identified
in samples collected from the Floridan Aquifer, the only constituent known
to have been used by the Tower Chemical Company is copper. However, the
concentration of copper found in the downgradient Floridan Aquifer samples
is similar to the concentration found in the sample collected from the
upgradient well. Overall, it is believed that the operations associated
with the Tower Chemical Company have not impacted the water quality of the
Floridan Aquifer.
SURFACE MATER AND
Surface water and sediment samples were collected from the following
locations in the sit* vicinity* the east ditch on the main facility, the
unnamed stree» north of the site, and the spray irrigation field ponds.
Surface
Surface water samples were collected from the points indicated in Figure 22.
The background surface water sample was collected from a small pond within
the swamp (SW-01); at a point unaffected by the Tower Chemical Company
operations.
-36-
-------
S*~r-——
•jjfc
cfi
LCOCNO
OMHMOWATIII (MONITOMNO WILL}
•AMFLI LOCATION
•VNFACI WATM SAMPLC LOCATION
•NALLOW OMMNN>WATI« CTMNCN}
•AMrur LOCATION
• ••4 CONDUCTIVITY CONTOUfl
fOm 4« MILLIMNOa/MKTCN
«••! CONOWCTIVITV CONTOIIN
fOm 4« •ILLI«NO«/MCTC«
kAmiOXIMATC MOWZONTAL CXTKNT Of
'•NALLOW a«OUM»WATCH CONTAMINATION
•CM.1
t«o' wo* i
—t 1
-------
oo
Figure 21 - Croundwater saupllne
•Pling
~"'1^"
U8ed jn the Radial Investigation. Floridan
-------
-------
Table 6 shows the ooncentrations of selected contaminants found in surface
water samples collected from both the unnamed stream and the east ditch.
It is obvious that 4,4-DDT and its derivatives were found in surface water
samcles collected west of the main facility from the unnamed stream at the
former wastewater pond overflow point and east of the main facility in the
east ditch. Therefore, the nature of the contaminants in these two areas
can be related to past activities at the Tower Chemical Company. However,
as previously discussed, it appears that these contaminants may be the
result of groundwater discharge rather than the result of surface water run-
off.
Table 7 shows all the contaminants found in the surface water samples
collected from the spray irrigation field ponds. As can be seen from this
table, all contaminants were at low concentrations and these contaminants
do not appear to be related to Tower Chemical Company operations. It
appears that activities conducted in the spray irrigation field did not
significantly impact the nearby ponds.
Sediments
Sediments samples were collected from the points indicated in Figure 23.
The background sediment sample, SE-01, wan collected from a small pond
located in a swamp area which was unaffected by operations from the Tower
Chemical Company. -*•.• —
Table 8 shows the concentrations of selected contaminants from the samples
collected in the unnamed tributary and from the east ditch. The concen-
trations of 4,4'-DOT and its derivatives and metals in samples from the
unnamed tributary were comparable to those found in the control sample and
all of which are below action levels established in this Record of Decision,
In contrast, the concentration of copper from the east ditch sample was
50,000 ug/kg» which is significantly higher than the concentration found in
the control sample (5,000 ug/kg). The copper contamination can be related
to operations conducted at the) Tower Chemical Company. However/ the concen-
tration levels of copper contamination in the east ditch does not exceed
the health based clean-ta? criterion. Table 9 presents the maximum concen-
trations of contaminants from all samples collected from the ponds in the
spray irrigation field area. The compounds identified in the irrigation
field sedifflsnt Msple* an not associated with operations from the Tower
Chemical OamjMiy. In any case, they do not significantly differ from the
control savptoand are below established clean-up levels/ thus the con-
taminants dor not present any significant health or environmental threat.
AIR INVESTIGATION
During ths 1983 EPA removal action air quality monitoring stations were
established at the points shown in Figure 24. The monitoring conducted
during the 1983 removal activity indicated that the concentration of
-40-
-------
Table 6
Comparison of Selected Contaminants in Surface Water Samples,
Nain Facility.
Parameter
t.V-DDT
*,V-DDC
*,*'-DDD
Beta-BHC
Gamma-BHC
Delta-Uric
Ethion
Chlorobenzilate
Dicofol
Xylcne
Ethyl Benzene
Chromium
Copper
NA
NA
NA
NA
NA
NA
SW-4)I
Downstream of
afOverflow
0.1-1.2
O.IJ-0.3
NA
NA
NA
6-10'
ND-J9'
-or NO
J
NA
Material analyzed for but not delected.
Estimated value.
Not analyzed.
Stream
North of
Itotn Facility
E«slof
itaui Facility
O.IS
0.32]
0.072
NA
NA
NA
NA
NA
NA
0.9
0.22
6«
sw-oa.sv-09
-------
Table 7
Maximum Concentrations of All Contaminants Found in
Sazples Collected From Ponds in the
Spray Irrigation Field Area.
Spray Irrigation
Parameter (ua/D FieJd Ponds
Bis(2-Ethylhexyl)phthalate
Acetone 30J
Carbon Disulfide 2J
Chromium 6
Lead 93
Zinc
Aluminum *10 .
s>* *•*'
Manganese
Iron 200
Sample Locations SV-02, SW-05
Estimated vaJue.
Material-analyzed for but not detected.
-42-
-------
i Used in the Ki»in<>
Investigation.
-------
ol
Table 8
c
Main Facility.
M'-DOT
M'-OOC
M'-OOO
II
II
II
MO-9J
NO-I.IM
NO-1J
MBJ-I.1M
MD-I.M*
NA
NA
NA
C-MS
se-tr
• «v NO
C
J ft
-------
Maximum Concencracions of
Parameter (u*7D
Hexadecanoic Acid
Toluene
Barium
Cadmium
Chromium
Copper
Lead
Selenium
Vanadium
Zinc
Aluminum
Manganese
Iron
Sample LocMMBi
Material analyzed
J Estimated value.
Control
Soil
•
6,100
650
14,000
51,000
9,400
81,000
1,800,000
87,000
2,600,000
SO-01
Spnyfield
Soil
500 JN
20J
2,500
*
2,3503
12,000 '"
2,900
•
1,900
5,900
1,430,0003
13,000
960, 000 J
SO-03, SO-12
SO-lf
Vest Pond
Sediment
1,OOOJN
64-
8,200
28
5003
'""" 2,0003
1,0003
240
800
•
260,000
600
160,000
se-02
East Pond
Sediment
•
3003
1,0003
900 J
4003
700
330,000
•
34,000
SE-05
for but not detected.
N Presumptive evidence of presence
R Data invalid.
of material.
-------
24 - Air Sampling Locations
-------
particular and volatile contaminants in the air did not differ significantly
oetore oc during tne excavation activity. The ambient concentrations of
cne particulate and volatile pesticides in samples collected from the site
remained at levels oetween lu"* and It)"1* milligrams per cuoic rater oetore
ana during tne immediate rentoval. Excavation work in tne former disposal
areas required personnel respiratory protection for tnose workers in tne
immediate vicinity as a precautionary health and safety measure.
The air monitoring performed during tne RI found no detectable levels oc
contaminants in tne Dreatning zone except when five of tne six monitoring
wells at the main facility were opened and purged for sampling, ttuie
working at tnese wells personnel respiratory protection was required oecause
of the extremely elevated hydrogen sulfide concentrations. An ambient
hydrogen sulfiae prooiom was not detected.
ENDANGERED AND THREATENED SPECItS
mere are no cederaily-listed protected plant species in Laxe County. Ot
tne State-protected plant species only Adder's tongue cern has oeen reported
as possioly existing in tne vicinity of tne sit*. This plane, wnose
scientiric name is Ophioqlossum paimatun, is considered endangered oy tne
State of Florida.
•,.. "-••
There are several federally protected animal species within tn« area of tne
Tower Chemical Company site. These endangered or threatened species are
listed in Table 10. Any remedial aceion^taken ac tnis sita muse include
consideration of tne potential impact tnat implementation could have on
tnese species.
A iSatural Resource Damage Assessment was conducted for tnis site by the
U. S. fish and Wildlife Service (fW3). In this assessment, tne EWS concluded
tnat tne Tower Chemical Company siea may have impacted the surrounding
trustee resources in a manner tnat threatens the ability of tne area to
sustain resident floral and fauna! populations. Howsver, aftar reviewing
tne remedy being proposed for the Towac Chemical Company sita, tne fws
concluded that tna steps oaing raccmnendad cor remediation will be sufficient
to provide protection of tna trustee resources (Appendix E).
-47-
-------
Table 10
Federally Protected Species Which Have Known Habitats
Within the Vicinity of the Tower Chemical Company Site,
Florida Panther
Scientific Name
Felis concolor coryi
tion
Bald Eagle
Bachman's Warbler
Ivory-billed Woodpecker
Red-codcaded Woodpecker
00
I
Ke»tile»
American Alligator
Eastern Indigo Snake
Haliaectus leucoccpnalus
Vermi vof a bachmanii
Cajnpeptiilus pricipalis
Pjcoides borealif
Alligator miisissippiensis
Dryroarchon corais coupcri
E
E
E
E
T
T
E - Endangered
T - Threatened
Source; USFWS, 1985.
-------
SECTION IV
ENFORCEMENT PROFILE
Initial notice letters were sent to all identified potentially responsiole
parties (PRPs) on Marcn 5, 1982. The recipients included Ralpn ftoane,
President, Tower Oiemical Company,- James Gallagher, Trustee, Gallagher
Land Trust ("Trust"); and John Balncnard, owner, 0. T. Enterprises.
Following issuance of tne letters, a meeting was held on May 15, 1982 in
EPA's regional offices in Atlanta, Georgia with all PRPs except Ralph
ftoane present. At the meeting, representatives of the Trust committed to
prepare a feasibility study to identify options for clean-up of the site.
Following several requests for extentions of tint* by the Trust and repeated
missed deadlines for providing the study, EPA, with eh* encouragement of
the State of Florida, determined in June 1983 that an immediate removal
action was warranted.
On June 9, 1983, EPA Region IV issued a CERCLA Section 106 Administrative
Order to the PRPs requiring a surface clean-up of the sic*. The PRPs
railed to comply with the order and during June and July 1983, EPA Region
IV conducted a fund financed removal action at the site.
**. *-
Prior to the commencement of tne flamedial Investigation and Feasibility
Study (3I/FS) ac the site EPA again notified tne PRPs and invited them to
conduct or participate in the RI/FS. The PRPs failed to reply and EPA
initiated the RI/FS.
On June 30, 1984, EPA riegion IV referred a Section 107 cost recovery case
to EPA Headquarters and to the Department of Justice. The complaint was
filed in April 1985. The defendants named ware those noted above. *0n
June 5, 1*86, an amended complaint was filed naming individual Trust
members a* defendants. A trial data had been set for June 1987, but the
case has been removed trcm tne trial docket pending finalization of a
Consent Deere* between £Bt and several individual members of tne Gallagher
Land Trust to partially reiaourse the Hazardous Substances Trust Fund tor
expenditures related co the 1983 roncval action.
To date, tns* IU» have not made a proposal to undertake any response
actions at IS* site and, based on past performances, there is no reason
to believe> tftsC they will do so in the future.
-------
SECTION V
ALTERNATIVES EVALUATION
PUdLIC HEALTH AND ENVI«ONME^^AL OBJECTIVES
Public Health Concerns
The public health threat posed oy tne Towar Chemical Company site, as
identified in the RISK Assessment (Appendices 0 and P, RI), is relatively
minimal. Several complete exposure pathways exist: ingestion of
contaminated soils and surface water, physical contact with contaninated
soils and surface water, inhalation of airDorne particulates, and potential
for ingestion of contaninated groundwater via migration of contaminated
surficial aquifer ground water into the Fioridan Aquifer. The Risk
Assessment tound that the site currently appears to pose no significant
nealth threat, Out potential exposures are a risk. This was supported by
the CDC/ATSDR Puolic teal en Evaluation (Appendix f).
Environmental Concerns
Discharge of contaminated ground water from the SturfTclal aquifer into
the surface waters of the unnaned tributary north of the Tower site poses
a potential environmental risk. The unnaned tributary discharges into
the Gourd Neck area of Lake Apopka and several federally protected
endangered or threatened species live within the range of the Tower
Chanical Company Site.
TECHNOLOGIES CONSIDERED
Several technologies ware considered for remediating the Tower Chemical
Company site. The technologies were presented in groups targeted at
remediating a single aspect ot the site. Taole 11 shows the technologies
considered for remediation of surtac* and groundwater contamination,
technologies considered for remediation of soil contamination, and
technologies responding to institutional controls.
Several coettftttions of technologies will provide remedial actions which
comply witfr Applicable, relevant, and appropriate environmental laws.
However, preference was given to treatment technologies or resource
recovery options which reduce the toxicity, mooility or volume of the
waste to the maximum extent practicaole. Remediation of the site will
respond to issues raised under the Safe Drinking Water Act (SCWA), Clean
Water A:t (CWA), the Resource Conservation and Recovery Act (RCRA).
-------
Table 11. All Technologies Considered for Remedial Response at the Tower
Chemical Company Site. ^
GROUND WATER
* Alternate Water Supply - Municipal Water Supply Extention
9 Alternate water Supply - Bottled water
9 Alternate Water Supply - individual Treatment Units
9 Ground Water Barrier
9 Ground Water Removal
9 Ground Water Treatment
SURFACE WATER
9 Surface Water Removal
9 Surface Water Diversion
9 Point Source Runoff Diversion
SOILS AND SEDIMENTS
Surface Capping - Clay or Synthetic Membrane
Surface Capping - Concrete or Asphalt
Surface Capping - Soil Mixtures
Excavation
Surface Soil/Sediment Removal
On-site Disposal
Off-Site Disposal
Soil Treatment - Soil Flushing/Soil Washing
Soil Treatment - Biodegredation
Soil Treatment - Activated Carton
Soil Treatment - Lime-Ply Ash Pozxolan Process
Soil Treatment -' Poxolan-Portland Cement
Soil Treatment - Thermoplastic Micrcencapsulation
Soil Treatnent - NKroencapsulation
Soil TtMOent - incineration
OTHER
No Action
Monitoring
Resident Relocation
Tanks and Concrete Pad Removal
Surface Regrading and Revegitation
-51-
-------
Table 12. Technologies Eliminated [Xiring the Tower Chemical Germany Site
Screening Process.
TECHNOLOGIES ELIMINATED
Ground water Technologies
Alternative Water Supply - Bottled Water
Surface Water Removal
Surface Water Diversion
Ground Water Barriers
Soil Treaonent Technologies
Soil Flushing/Soil Washing
Biodegradation
Activated Carbon
Lime-fly Ash Potzolan Process
Pozzolan-Portland Cement Process
Thermoplastic Microencspsulation
Mac
Cn-site Disposal
Concrete or Asphalt Cap
Soil Mixture Cap
NO Action
REASON
Inconvenient to residents; does
not prevent dermal exposure
Mot warranted based on Rl data
Not warranted based on Rl data
Fail to prevent.vertical
migration of ground water
High natural metals content
in soils prevents effective
use
Fails to address metals
contamination
Potential development of leachate;
long barm monitoring recuired
Expands material volume; increases
waste disposal resource needs
Expands material volume; increases
waste disposal resource needs
Increased cost without producing
health or environmental gains;
expensive)
Increased cost without producing
health or environmental gains;
expensive
See text
High failure potential
High failure potential
Fails to address potential threats
to the public health, welfare and
the environment
-53-
-------
Soil Flushing/Soil Washing. This technology has been demonstrated to be
feasible in soils which have low levels of naturally occuring metals,
however, soils typical of this site have been shown to have very high
levels of natural aluminum and iron - several orders of magnitude higher
than that of the contaminants. As a result, the washing fluids would
preferentially remove the naturally occuring metals rather than the low
levels of contamina. .3.
Bicdeqradation. Bi©degradation does not address the metals contamination
found at the site and would require long term operations before full
clean-up is effective. Other technologies, e.g.r incineration, would
provide equal destruction efficiencies in a shorter time frame.
Activated Carton. Although this technology has been proven effective for
treatment of both organics and inorganics in soils, it would require long
term monitoring to insure that no leachate develops from the site. This
remedy was eliminated in favor of more permanent response options.
Lime-fly Ash Pozzolan Process. Although this process is effective in
addressing inorganic contamination, the volume of'rtatferials would increase,
thus causing an increased disposal facility requirements. In addition,
the soils being solidified contain significant amounts of organic compounds
which could affect the integrity of the cement monolith. The presence of
organics will require containment of the monolith within an on-site
landfill built above the land surface due to the locally high water
table. This technology would also require long-term (30 years) monitoring
which is less favorable than technologies which provide permanent
destruction of wastes. Add other technologies are equally effective for
similar costs.
Pozzolan - Portland Cement Process* Sam* as Lime-fly Ash Pozzolan Process.
•
Thermoplastic Microencepeulation. Although feasible, this option requires
specialized eaiipnent, trained personnel, and is expensive, other
treatment technologic* are equally effective and less expensive.
MacroencapeulatJon. Sane as Thermoplastic Microencapsulation.
On-Site Disposal. While the volume and levels of contaminants are
relatively low, a high water table at the site makes it infeasible to
solidify or build an on-site landfill which meets the design specifications
outlined in RCRA. It has been shown that the only feasible treatment
technologies available for this site, involve total destruction of the
wastes, which takes in to consideration the preference for a permanent
remedy as stated in Section 121 of SARA.
-54-
-------
Concrete or Asphalt Surface Cap, The risk of tailure ot a concrete or
asnpait cap is hijn aue to tne pocenciai tor cracture cortnacion.
Soil Mixture Caps. This tecnnology is unproven and has extensive
monitoring requirements. Development of oessication cracks could cause
failure.
TECHNOLOGIES RETAINED
Several technologies were retained for cinal consideration as alternatives
for remediating the site. These individual technologies are listed in
Taole 13. In depth discussion of each technology can be found in the FS.
During the Feasibility Study process, tne retained technologies were
grouped into remedial units which would accomplish specific remedial
objectives (Table 14). These remedial units were then combined to
develop full remedial alternatives which would respond to the conditions
surrounding the Tower Chemical Company site. A total of 8 comprehensive
remedial alternatives were designed from the various technologies retained
after the screening process. Each of the possible alternatives
was analyzed based on effectiveness L-nplementability.and cost. A general
sumnary of the concerns surrounding each technology is presented in Table
15. It is important to note that the No-Action alternative is included
in the 3 alternatives considered for final remedy selection although it
was eliminated during the initial screening phase. The No-Action alternative
must oe included at this point to -ully comply witn the legal requirements.
Alternative Description*
Alternative 1 - Mo Action - Groundwater and Surface Water Monitoring.
Under tne no-action alternative, no additional remedial activities would
be performed. Implementation of this alternative would not address the
remediation ot tne sit* nor tne potential threat to tne public or the
environment via the exposure pathways. However, the monitoring
program would provide information so that possible adverse public health
or environmental impacts tnat might arise could be addressed. At the
Tower Site, early phasing of tne groundwater/surface water monitoring
program sflMtd be considered. Based upon tne conclusions of the Remedial
Investigation (BX), groundwater contamination has been demonstrated in the
surficial aquifer wnicn poses a potential threat to the Florida Aquifer.
CAPITAL COSTSl 535,000 OPERATIONS AND MAINTEN^CE COSTS: 965,000
-55-
-------
Table 14. Remedial Units and Objectives
Ground water/Surface
water Monitoring
Ground Water Removal (Main
Facility)/Individual Treatment
Units/Water Treatment/Discharge
Municipal water Supply
Extention
Establish base line data? identify
changes in the site conditions;
determine effectiveness of
removal actions
Prevent migration of ground
water contaminants and accidental
ingestion of contaminated ground
water
Prevent accidental ingestion of
contaminated ground water
Capping (Burn/Burial Area)/Point
Source Runoff Diversion
Soil/Sediment Removal (N.E. of
Main Entrance and East Ditch);
water Treatment/ Offsite
Disposal
Soil/Sediment Removal (Overflow
Area)/Point Source Runoff
Diversion/Offsite Disposal
Surface Soil Removal/Of fsite
Disposal
Soil Removal/
Onsite Incineration
0 Tanks, Ooncrsts Pads, and
soil nsminl.ttffsite
Dis
Excavation (former Huts water
Pond)/Point Source) Runoff
Divers ion/Offsite Disposal
Excavation (Burn/Burial Area)/
Point Source Runoff Diversion/
Offsite Disposal
Soil Removal (Spray Field)/
Offsite Disposal
Prevent direct contact with soils;
reduce leachate to ground water;
eliminate erosion of contaminated
soils
Prevent direct contact with soils:•
eliminate erosion of contaminated
soils
Prevent direct contact with soils;
eliminate erosion of contaminated
soils
Prevent direct contact with soils;
eliminatts erosion of contaminated
soils
Reduce surface soil contamination;
remove source of groundwater
contamination; prevent direct
contact with soils
Prevent direct contact with
contaminants; eliminate potential
threat to ground water
Eliminate potential threat to
ground water and dermal exposure
to soils
Eliminate potential threat to
ground water
Eliminate erosion of contaminated
soil; prevent direct contact with
soils
-57-
-------
Table 13. Technologies Retained for Final
Consideration to Remediate the
Tower Chemical Company Site.
0 Ground Mater Monitoring
0 Municipal Water Supply Detention
0 Individual Treatment Units
0 Tanks and Concrete Pad Removal
0 Point Source Runoff Diversion
••»» *••-
° Capping - Synthetic Membrane
0 Surface degrading and Revegetation
0 Surface Soil/Sediment Removal
0 Ground Water Removal
0 Excavation
0 Wtter Treatment Technologies
0 Soil Incineration
0 Off Site Dispoeal
-56-
-------
Table li>. Summary ot abated id 1 Action Alternatives
ALTERNATIVE
POST ($1000)*
PUliLIC HtALTH
CONCERNS
CONCERNS
ri-JCMNICAL
CONCERNS
i
en
CD
i
1. No Action -
Monitoring
10UU
2. Monitoring;
Municipal Water
Supply Ex tention;
Tank/Soil Removal
3. Monitoring;
Ground Miter
Removal; Water
Treatment;
Individual
Treatiaent Units;
TanK/Soil Removal
4. Same as
Alternative 3;
plus: Soil/Sediment
Removal (Overflow
Area and Burn/Burial
Area); Exploration
ot Burn/tiurial Area;
Incineration of
Soils; itoint Source
KuiiotC Diversion
S.6U3
Potential imjestion
ot contaminated
ground water and
direct contact with
contaminated soil &/or
leaking tanks
Hotential ingestion
ot contaminated
ground water and
direct contact with
contaminated soils
Direct contact with
contaminated soils
impact ot
contaminated
ground water uo
tauna and tlora
in unnanecl stream
Same as
Alternative 1
i tone
none
Minimal
Minimal
Minimal
temoval and
treatiitent ot
contaminated
ground water
ifemovai and
treatment ot
contaminated
grouid water
based on present worth analyses
-------
Table 15 (cont.). Simary of Roaadial Action Alternatives
ALTERNATIVE
OGBT ($1000)'
PUBLIC HEALTH
CONCERNS
ENVIRONMENTAL
CONCERNS
6.
as
Alternative 3f
pluss Soil/Ssdi»snt
Removal (Overflow
Area); Excavation
{former Haste
Mater Pond); and
Capping (Burn/
Burial Area)
Sane as
Alternative 3;
plusi Soil/SedUaent
Renewal (Overflow
Area)i Excavation
(Burn/Burial Area);
Excavation (Fbner
Haste Hater Pond)i
Offsite Disposal
of Soils
11,210
15,968
Direct contact with
contaminated soils;
potential inhalation
of H2S during
excavation
Minimal
Potential inhalation
of H2S and/or
particulates during
excavation
Minimal
TECHNICAL
CONCERNS
Same as
Alternative 3;
plus long tem
integrity of
cap; excavation
below the water
table
Removal and
treatment of
contaminated
ground water;
excavation below
the water table
* Based on present worth analyses
-------
Table 15 (cant.). Sunraary of Remedial Action Alternatives
ALTERNATIVE
7. Sane as
COST ($1000)*
29,126
PUBLIC HEALTH
CONCERNS
Potential inhalation
ENVIRONMENTAL
CONCERNS
TECHNICAL
CONCERNS
8.
o
i
Alternative 6}
plus: Soil/
Sediment Renewal
(East Ditch and N.E.
of Main Facility;
Soil Removal and
Onsite Incineration
(Spray Irrigation
Field)
Sane as
Alternative 6;
plus: Soil/
Sediment Removal
(East Ditch and
N.E. of Main
Facility); Off-site
Soil Disposal
22,398
of H2S 4/or
participates during
excavation; PICs
during incineration
Minimal
Potential inhalation
of H2S fc/or
particulates during
excavation
Minimal
Removal and
treatment of
contaminated
ground water;
excavation
below the water
table
Removal and
treatment of
contaminated
ground water;
excavation
below the water
table
* Based on present worth analyses
-------
Alternative 2 - Ground Water and Surface Water Monitoring; Alternate water
Supply - Municipal Water Supply Extention? "ranksf Concrete Pads, and Soils
Removal. This alternative would include a monitoring program for ground—
water and surface water and the extension of the Clermont municipal water
supply, Two tanks and sane concrete support pads which remain from the
operation of the Tower Chemical Company would also be removed. The
concentrations and types of contaminants detected in ground water could
pose a potential threat to nearby private water supplies. Implementation
of this alternative would eliminate this problem at the site, but the
contaminated ground water in the surficial aquifer would continue to
remain a potential environmental problem. This option will also fail to
address the threats posed by direct contact with contaminated soils. The
proposed monitoring program should be implemented first.
CAPITAL COSTS: $546,000 OPERATION AND MAINTENANCE COSTS: $743,000
Alternative 3 - Ground water and Surface Water Monitoring; Ground water
Removal (Main Facility) and Treatment; Alternate Water Surely - Individual
Treatment units; ranxs, concrete Pad and Soil Removal. This alternative
would include the monitoring program described in Alternative 1, removal
and treatment of contaminated groundwater, and the installation of
individual treatment units on the two private wells adjacent to or on the
site. Two tanks and some concrete support pads which remain from the
operation of the Tower Chemcial Company would also be removed. The
removal of contaminated groundwater would eliminate ,the potential for
migration or ingestion. The treatment units would provide a protected
source of potable water for the duration of the ground water removal.
The monitoring program should be implemented in conjuction with the
ground water extraction system. The individual treatment units could be
installed while the monitoring wells are being constructed.
CAPITAL COSTS: $3,523,000 OPERATION AND MAINTENANCE COSTS: $907,000
Alternative 4 - Ground water and Surface Water Monitoring* Ground water
Removal and Treatment; Alternate water Supply - Individual Treatment
Units; Soil/Sediment Removal (Overflow Area); Exploration (Bum/Buri'al
Area); Surface Soil Removal; Tanks and Soil Removal; and Tank/Spfls
Removal; Qn-Site Thermal Destruction of Contaminants in the SoilsT" In
addition to monitoring, groundwater removal, water treatment, poTnt
source run-off diversion, removal of two process tanks, and excavation
and on-sits- thermal destruction of soils from the overflow area, this
alternative would also address the concerns surrounding the bum/ burial
area. Th» ooint-eource discharges from Vita-Green, Inc. would be
diverted fn these areas. Contaminated surface soils would be removed and
exploration tor burled drums in the bum/burial area would be conducted.
Dewatering for excavation can be conducted simultaneously with the ground
water recovery operation.
CAPITAL COSTSf $6,788,000 OPERATION AND MAINTENANCE COSTS:
Alternative 5 - Ground water and Surface water Monitoring;
Removal a«l Treatment? Alternate Water Supply - Individual
Ground Water
Treatment
Units? Soil/Sediment Removal (Overflow and Burn/Burial Areas)? Excavation
(Former waste water Pond)? Capping (Bum/Burial Area); Tanks/Soils Removal;
-61-
-------
and Off-Site Disposal of Soils. In addition to monitoring, groundwater
renoval, water treatment, and individual treatment units under this
alternative, contaninated soil would be excavated frera the former wastewater
pond and a cap would be installed over the burn/burial area. Also, the
surface soils and sediments in the overflow area would be removed for off-
site diposals. Excavation of the former wastewater pond should be imple-
mented orior to the installation of the groundwater exctraction wells.
Monitoring and groundwater removal could be implemented concurrently.
CAPITAL COSTS: $10,293,000 OPERATION AND MAINTENANCE COSTS: $971,000
Alternative 6 - Ground Water and Surface Water Monitoring? Ground Water
Recovery (Main Facility) and Treatment; Alternate Water Supply - Individual
Treatment Units; Soil/Sedijnent Removal (Overflow Area)? Excavation (Former
waste Water Pond and Bum/Burial Area); Tanks, Concrete Pads, and Soil"
Removal; Tanks/Soils Removal. If this alternative were implemented, it
would be identical to Alternative 13 except that the bum/burial area
would be excavated and the two tanks, concrete pads, and soils would be
removed. These actions could be performed in conjunction with the
excavation of the former wastewater pond.
CAPITAL COSTS: $15,440,000 OPERATION AND MAINTENANCE COSTS: $1,367,000
Alternative 7 - Ground Water and Surface Water Monitoring; Ground Water
Removal (Main Facility) and Treatment; Alternate Water Supply - Individual
Treatment Units; Soil Sediment Removal (overflow Area)? Excavation (Former
waste Water Pond and Burn/Burial Area); Tanks, Concrete Pad, and Soil
Removal? Point Source Run-Off Diversion; Surface^Sbil'/Sediment Removal
(East Ditch and Northeast of Main Entrance); Soil Removal (Sprayfield)
and soil Treatment Incineration* This alternative would be similar to
Alternative 16, except that surface soils would be lerowed from the
sprayfield and an area northeast of the main entrance and the sediments
would be removed from the east ditch. The soils removed from the sprayfield
would be incinerated on-site and the treated soil used as backfill for
that area. Soil removal and soil incineration could be performed
concurrently with excavation or soil renoval frcn the overflow area.
CAPITAL COSTS: $28,219,000 OPERATION AND MAINTENANCE COSTS: $907,000
Alternative 8 - Ground Miter and Surface Hfcter_ Monitoring? Ground Mater
Removal (Main Facility) and Miter Treatment; Alternate water Supply -
Individual Treatment Units > Soil/Sediment Removal (Overflow Area)?
Excavation (Former Hhstewater Pond); Excavation (Burn/Burial Area)?
Tanks, Concrete Ped«, and Soil Renoval? Point Source Run-Off Diversion?
iment Removal (East D
Itch and ME of Main Entrance?? son
ield) and Off"Site Disposal.If this alternative were
It would be identical to Alternative #6 except that the
sprayfield soils would be disposed of off-site.
CAPITAL ODSTSi $21,491,000 OPERATION AND MAJNTOttNCE OOSTS: $907,000
ADDITIONAL CONSIDERATIONS
Since the enactment of the Superfund amendments and Reauthorization Act
(SARA) new requirements have been enacted on the remedial response options
available for use at Superfund sites. Of these enactments, one portion
of the Act has imposed stringent requirements which directly impact the
-62-
-------
selection of a >/iaole remedy for the Tbwer Oiemical site. This requirement
(SARA Section L2i (D» strongly opposes tne selection or remedial actions
wnicn do not offer permanent solutions or which involve the disposal of
Hazardous waste materials in landfills.
In- order to respond to the "spirit" of this amendment, EPA conrissioned a
study to furtner assess on-site soil treatment technologies. This
evaluation is presented in Appendix G. A total of 9 soil treatment
technologies were assessed (Taole 16). Of these technologies, none were
found to oe acceptaole based on the following aspects: effectiveness,
uiplementaDility, and cost. These reasons have been previously discussed
in the Technologies Eliminated portion of this section.
-63-
-------
Tacle 16. Soil Treatment Technologies Assessed
0 Soil flush ing/Soil Wishing
9 Biodegradation
,"- ---
* Activated Caroon
0 Li.-ne-Fly Ash Ft>zzolan Procees
0 Pozaoian-Portland Cement Process
0 Ihemopiastic Microencapsulation
4 Macrotncapsulation
• Incineration
-64-
-------
SECTION VI
COMMUNITY RELATIONS
Community relations efforts for the Tower Chemical Company site were
initiated in Septanoer 1984 when EPA completed the site Community t«iations
Plan. Area residents were contacted as part of the community relations
wooc. Overall, area residents expressed concern tor ootn neaitn and non-
nealth issues. However, the connunity interest overall, in this site nas
oeen limited.
An information repository was established at the Cooper Memorial Liorary,
near the site. All final documents, plus the dratt Remedial Investigation
(RI) and draft Feasibility Study (FS) were sent to tne repository to
provide Public access.
In preparation for the public meeting, a tact sheet was sent to the
interested parties listed in the Community Relations Plan, me fact
sheet provided interested parties with a summary of all remedial alternatives
being considered by EPA tor remediating the proolems surrounding the
Tower Chemical Company site. On September 16, 1986, a public .nesting waa
held to discuss the findings of the RI/PS. The public meeting served to
initiate a 3 wee* public comment period which cJJbseji on October 7, 1986.
Attendance at the public meeting was moderate/ Several written comments
were received during the public comment period. These comments have been
fully addressed in the Responsiveness Summary (Appendix B), which was
also placed in tne information repository.
-------
SECTION VTI
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
Other environmental laws which may be applicable or relevant to the
remedial activity being proposed for the Tower Chemical Company site are:
— Safe Drinking Water Act
— The State of Florida Administrative Code (FAC);
Chapter 17-3 - Surface Waters: General Criteria
— The State of Florida Administrative Code (FAC);
Chapter 17-22 - Drinking Water Standards
— The State of Florida Administrative Code (FAC);
Chapter 17-30 - Hazardous Waste
— EPA Ground Water Protection Strategy
— Clean Water Act (CWA)
— St. Johns Water Management District: Extraction
Well Permits
— Resource Conservation and Recovery Act (RCRA)
— Executive Order 11988: Floodplain Management
Locally, residents obtain their water supplies from the Floridan Aquifer,
which is poorly protected in the site vicinity .due-to the presence of
relic sinkholes. Therefore, the mandates of the'safe Drinking Water Act
apply to this site* The use of temporary water treatment units on the
two private wells nearest the site will insure that the well users will
have safe drinking water supplies until* the aquifer can be fully restored
by the ground water recovery and treatment activity. Ground water clean-
up operations are consistent with the goals established in the EPA Ground
Water Protection Strategy (GWPS); failure to respond to ground water
contamination could threaten the local drinking water supply — the
Floridan Aquifer, and would lead to degradation of the surficial aquifer.
Also, the GWPS seeks further to protect environmentally sensitive areas
such as the nearby wetlands.
The recovered ground water would be treated before being discharged to
the.unnamed stream'north of the site. The discharge of this treated water
will be conducted in accordance with the requirements of the Clean water
Act, and in accordance with the requirements of surface water criteria
specified in the Florida Administrative Code Chapter 17-3.061.3(m).
The ground Mt*r recovery operations will comply with the substantive
requirements which the St. Johns Water Management District may decide to
impose on ground water extraction wells through their permitting process.
The proposed remedy will eliminate all threats arising frcm the Tower
Chemical Company operations. As a result, there will be no requirements
under RCRA for long term site monitoring.
Surface waters are not now being adversely impacted by the Tower Chemical
Company site, however, failure to address ground water contamination will
-------
ultimately result in tne discharge or contaminated ground water into tne
unnamed creek nortn at the site. Therefore, ground water recovery and
creaonent operations are necessary to prevent eventual violation of the
Florida Administrative Code Chapter 17-3.061.3(ra).
Destruction ot the contaminated soils by incineration will nave to meet
the requiraaents of Parts 264(o) and 261 Appendix 2 of RCRA, along with
Chapter 17-30 of the Florida Administrative Code. RCRA Part 264(o) governs
all aspects of incinerator test bums, and RCRA Part 261 Appendix 2 governs
the EP Toxicity requirements for dispoals of incinerator asn. The State
of Florida requirements governing incineration (FAC 17-30) adopts RCRA
Part 264(o) without further state-imposed regulations. Therefore,
incineration activities must be conducted in accordance witn tne applicable
portions of RCRA.
The soil and ground water clean-up criteria (Appendix 0) were jointly
established o/ EPA and FDER, based on tne Superfund Public Health
Evaluation Manual.
The Natural Resource Damage Assessment conducted by the Department of tne
Interior concluded that the operations of the Tower Chemical Canpany site
may nave impacted federally protected trustee resources (Appendix E).
There are no wetlands currently being threatened by the site, nor will
the remedial action being proposed for this sior'cfeate such a threat;
however, failure to taxe remedial action at this sit* will eventually
cause the contaminants to invade all parts of the local ecosystem. The
site is above the 500-year tloodplain {Figure 25).
-67-
-------
00
I
Figure 25 - Flood Plain ioundrles
-------
SECTION VIII
RECOMMENDED ALTERNATIVE
SELECTED REMEDY
The recommended alternative for the Tower Chemical Company site consists
of removal and treatment of contaminated ground water, prevision of
individual treatment units for two private wells in the immediate site
vicinity, removal and incineration of contaminated surface soils tron
both the overflow area and portions of the burn/burial area of the site,
pilot excavation of the burn/burial area to determine the composition of
the magnetic anomaly, removal of the two tanxs, concrete pads/ and
contaminated soils, and point source run-off diversion. This is
Alternative 4, as outlined in Section V of this document.
The ground water recovery operation will require the removal of approx-
imately iuO,Ouu,uuo gallons of contaminated water fron under the site.
The recovered ground water will oe treated by a comoination of flow
equalization, chromium reduction, precipitation, filtration, and activated
caroon processes in an on-site treatment facility as illustrated in
Figure 26. Surcace water discharge of tne treated water will oe the
disposal method used for this site. The ground water will oe recovered
until sampling efforts indicate that the criteria presented in Tacle 17
are achieved, as fully as is possible given the current state-of-the-art
analytical capabilities. Prior to discharge of tip "Created efrluent to
the surface water system, samples will oe collected to confirm that the
etrluent meets tne clean-up criteria. The ground water recovery operations
will also serve to "flush out" mooile compounds which remain buried at
depth below the former wastewater pond.
Subsequently, a complete HSL scan will be performed to determine if there
are any remaining priority pollutants in elevated concentrations wnicn
should oe addressed. Since primary and secondary drinking water standards
cover only a small percentage of parameters on the list, all detected
priority pollutants will be considered in evaluating whether further
groundwater recovery and treatment will be necessary. The appropriate
tlow rate and effective concentration limits will be evaluated and
determined during the mondial Design pnas« so that the surface water
criteria specified in Section 7-3 of tne Florida Administrative Code are
not violated. This will proviue assurance that surface water disposal of
the treated ground water will not adversely impact the environment of tne
unnamed stxejej or lake ApopKa.
Individual wMer treatment units will be provided for two private wells
in tne site vicinity to prevent potential exposure to ground water
contaminants should the contaminants migrate into the Pioridan Aquifer
prior to completion ot the groundwater recovery action. The treatment
units will be installed on the private water supply well being used by
employees ot tne Vita-Green Company, whose water supply well is on the
site property and to the well owned by Mr. Charles Hubdard, wno is located
immediately adjacent to the site and whose water supply well is down
gradient from the contaminant plume. The individual treatment units will
-------
o
I
CNfMICAi
•••MCflON
treat(K!ot
-------
Table 17. Target Clean-up Levels for Ground Water Contamination at the
Tower Chemical Company Site
Florida Maximum
Indicator Ground Mater Observed
Chemical standard (ug/1) Concentration (ug/1)
Arsenic 50 2,000
Nickel NA 550
Chromium 50 1/100
Alpha-BHC NA 0.21
Chloroform NA 2,000 •»,. *—
DDT NA NO
Chlorobenzilate NA 40
Dicofol NA 700
Target
Clean-up
Level (uq/1)
0.05
350
0.05
0.05
5
0.01
1.0
1.0
Source
FAC
HA
FAC
MDL
MDL
CAG .
ACL
ACL
MCL * Maximum Contaminant Levels set by SDWA
HA > Office of Drinking Water Health Advisory
MDL • Minimum detection limit established for
the Contract Laboratory Ptugtam (CLP)»
provided for compounds which have 10~*
health based criteria below detection
levels
NA • Mo numerical standard exists
FAC * Florida Administrative Cod* Chanter 17-3;
Surfao* Haters General Criteria
ACL * AltaxnaftB) Concentration Limit calculated
by the* a*gion IV Regional Expert
ToxicoI0iiat; baaed on 10~* health risk
lev-Is
-7t-
-------
Table 18. Target Clean-up Levels for Soil Contamination
at the Tov»r Chemical Ccnpany Sit*. Baaed on
10"* hunan health risks.
indicator
Copoer aoo
S
Arsenic fl A
DDT ;«4 5
J 35
-72-
-------
become obsolete once tne groundwater recovery operacion reaches tne
specified clean-up goals.
Surface soil removal will occur in tne overrlow area of tne former waste
•water pond, in portions of tne tne ourn/ourial area, and in tne storage
tanK area where tne Cop-o-Cide contaminated soils are found. Removal will
continue until tne soil clean-up criteria listed in Taole 18 are reached.
It is expected cnac approximately 40UO cubic yards of soils are contaminated
in excess of these clean-up criteria. After completion of tne excavation,
a conrirnation soil sampling action will oe conducted to confirm the
success of tne removal operation.
Contaminated soils will oe treated on-site by thermal destruction of the
contaminants. The remedial design phase will include a tesc ourn to
determine optimum operating efficiencies for the thermal destruction unit
and to determine tne tate of tne residuals. It tne uncreated residuals can
meet tne HCRA de-listing requirements for hazardous wastes, tne residuals will
De oacKtilied on-site. Conversely, if the untreated residuals tail to meet
the HCRA de-listing requirements, an appropriate treatment technology will oe
selected and applied to tne residual materials.
Pilot excavation of tne burn/burial area will b« conducted in order to
conrirm or negate anecdotal information tnat additional ouried drums are
located in tnat-area. The excavation plan developed'during tne Remedial
Design will provide tor proper destruction ot any drum contents wnich may
oe found during tnis activity using the same thermal destruction unit being
utilized for soil clean-up.
Point source run-off diversion will be designed to address the run-off
•dtnanatiry fran the main ouilding root and Vita-Gireen wasndown waters wnich
now traverse tne overflow area wtiicn are generated when tne main ouilding
tloor is rinsed otf. These waters will be diverted towards the unnamed
stream. This activity will reduce the potential for erosion of the site
soils. Rev eg« tat ion and regrading of the overflow area, can* spillage
area, and the burn/bvrial area will also be considered as a necessary
part of tnis activity tp minimize future erosion*
Tne two storage tanks which are- left over from the Tower Chemical Company
operations and nearoy concrete pads will be decontaminated on-site. The
decontaminate tanks will be recycled, and the decontaminated concrete
pads will D» Backfilled on-site. The first storage tank is located at
the northernsmt corner of the main ouilding and is in a vertical position.
The second storage tank is located wast of the burn/burial area and is in
a horizontal position. The concrete pads are along the northwestern wall
of the main building.
Since this remedy will remove all contaminants of concern from the site
to levels below tne established clean-up criteria, it will not oe necessary
to undergo long term monitoring of tne ground water or the surface water.
Monitoring etrorts will be limited to confirm tne success of the remedial
action and to assess the impact that implementation of tne proposed
remedy has on the surrounding area during the period of implementation.
-73-
-------
The selected remedy is expected to cost approximately 6.8 million dollars.
The State ot Florida has instituted a program for addressing the problems
posed by uncontrolled hazardous waste site. This program is designed on
tne CEflCLA model and is operated similarly to Supercund tnrough the
rlorida Department of Ehviromental Regulation. The State of Florida has
agreed to fund 104 of tne cost for implementing tne selected remedial
action (Appendix I). A summary of tne cost estimate for the proposed
r
-------
Table 19. Summary Table of Feasible Alternatives and Cost Comparison.
Costs Presented in Millions of Dollars.
Alternative
1
2
3
Alternative Om
1
X
2
X
X
X
3
X
1
X
5
X
6
X
X
xments
7
8
9
10
11
12
•
13
14
i
*
i
15
16
Reason for
Non-Selection
Does not provide
adequate protection for
public health or the
environment. Relative
risk is 1 x 10~1 .
Pails to prevent
migration of contaminated
ground water into the
surface water regime.
Pails to provide suffi-
cient protection for
public health. Relative
risk is 8 x 10~3.
Pails to address soils
contamination which
leaves risk from dermal
exposure. Pails to pro-
vide sufficient pro-
tection for public
health. Relative risk
is 1 x 10-5.
Cost
0.84
0.94
4.29
en
I
KF.Y 1-No Action
2-Monitoring
3-Municipal Water Supply Extent ion
4-Ground Water Removal fc Treatment
5-Individual Water Treatment Units
6-Removal of Tanks, Concrete Pads
t, Associated Soils
7-Soil/Sediment Removal -
Overflow Area
8-SoiI/Sediment Removal - East
Ditch and NE of Main Entrance
9-Soil Removal - Spray
Irrigation Pield & Incineration
10-Surfaoe Soil Rer 1 - Burn/
Burial Area '
11-Excavation - Spray Pield Area
12-Capping - Burn/Burial Area
13-Excavation - Bum/Burial Area
14 Excavation - Former Waste Water
Pond
15-Off-Site DispaaIs
16-Point Source Runoff Diversion
-------
Table 19 (cont.). Sunmary Table of Feasible Alternatives and Cost Comparison.
Costs Presented in Hi11 ions of Dollars.
Alternative
4
5
6
7
Alternative On*
1
2
X
X
X
X
3
JL
•^n
X
X
X
X
JL
I
X
X
X
6
X
X
X
lonents
7
X
X
X
X
8
*
X
9
X
10
X
11
.
12
X
.
13
X
X
14
X
X
X
I*
1
15
X
X
X
X
16
X
Reason for
Non-Selection
Relative risk is
2 x lO"6.
Unnecessary excavation
activity required.
Relative risk is 1 x 10~5
Unecessary excavation
required based on clean-
up goals. Relative risk
is 2 x 10 ~6
Unnecessary excavation
required based on clean-
up goals, expensive.
Relative risk is 1 x 10~8
Cost
5.39
10.91
15.97
28.56
KEY 1-No Action
2-Monitoring
3-Municinal water Supply Extention
4-Ground Mater Removal i Treatment
5-Individual Water Treatment Units
6-Removal of Tanks, Concrete Pads
c. Associated Soils
7-SoiI/Sediment Removal -
Overflow Area
8-Soi I/Sediment Removal - East
Ditch and NE of Main Entrance
9-Soil Removal - Spray
Irrigation Field f, Incineration
10-Surface Soil Removal - Burn/
Burial Area
11-Excavation - Spray Field
12-Capping - Burn/Burial Area
13-Excavation - Burn/Burial Area
14-Excavation - Former Waste Water
Pond
15-Off-Site Disposal
16-Point Source Runoff Diversion
-------
Table 19 (cant.).
SuMary Table of Feasible Alternatives and Cost Conparison.
Costs Presented in Hill ions of Dollars.
Alternative
1
2
Alt*
3
KM,
4
\m
5
OOH
*
aoner
7
its
8
9
10
11
12
13
14
15
16
Reason for
Non-Selection
mmtn^aattaiy oju^avai tuii
activity required.
Expensive. Relative Risk
is 1 x 10~8
Cost
•)•» IQ
ZZ. IV
KEY l-i. • Action
2-Honitoring
3-Hunicipal Hater Supply Ex tent ion
4-Ground Hater ftaoval ft Treatment
5-Individual Hater Treatment Units
6-RMOval of Tanks, Concrete Pads
fr Associated Soil*
7-Soil/Sedi*ent Rnoval -
Overflow Area
8-Soil/SediMnt. Reauval - East
Ditch and NE of Main Entrance
9-Soil Raaoval - Spray
Irrigation Field t Incineration
10-Surface Soil ReMoval - Burn/
Burial Area i
11-Excavation - Spray Field
12-Cappinq - Burn/Burial Area
13-Excavation - Burn/Burial Area
14-£xcavation - Former Waste Water
Pond
IS-Off-Site Disposal
16-Point Source Runoff Diversion
-------
SECTION IX
OPERATIONS AND MAINTENANCE
(Derations and maintenance considerations for the selected remedy at the
Tower Chemical Company site will be limited. There will be no long term
monitoring related to the soils contamination sine* all soils which
exceed the clean-up criteria will be removed from the site. Once the
ground water removal ©Derations are complete there will be no long term
monitoring required to monitor the groundwater quality. The ground
water removal operation will be permanently effective since there will no
longer be any soils to recontaminate the surficial aquifer or the Floridan
Aquifer. However, it is expected that any groundwater removal action is
expected to take an extended period of time depending on the design of
the ground water recovery system.
It will be necessary to maintain the groundwater recovery sysjtem until
the removal operations are complete, but this will be part of an ongoing
remedial response. Under Section 121 of SARA, groundwater recovery
activities are considered part of the Remedial Action for the first 10
years of operation or until the groundwater recovery operation is complete,
whichever occurs first.
EPA will provide O&M, if it later becomes necessary, for a period of one
year, after which the state of Florida will assume pespensibility for the
site. " "
-------
SECTION X
PKXTECT SCHEDULE
The scneduie for the RD/RA phases of che Tower Chemical Company site
remediation are dependent on the success of enforcement negotiations. If
the PRPs agree to undertake RD/RA, the schedule will be negotiated to
accczncdate EPA, FDER, and the PRPS.
However, if negotiations with the PR? are unsucessful, EPA will follow
the scneduie outline oelow:
Schedule Landmark
Date .
for
Implementation
1. Penalization of the ROD
2. Complete Enforcement Negotiations
3. Initiate Design
4. Complete Design
5. Award/Anend Superfund State Contract
(and IAG) for Construction
6. Initiate Construction
7. Initiate Groundwater Recovery
Operation
8. Complete Construction
9. Complete Groundiater Recovery
Operation
U6/3U/87
08/15/^7
••_
09/U1/87
ue/ui/aa
07/U1/88
U7/15/8S
07/15/88
07/15/90
U7/15/93
-------
SECTION XI
FTHURE ACTIONS
Successful implementation of the selected remedy will ultimately remove
the Tower Chemical Company site from under the jurisdiction of the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) and as amended by the Superfund Amendments and Reauthorization
Act (SARA). Implementation of the selected remedy will provide a permanent
solution to the problems surrounding this site and will require no sub-
sequent actions under CERCLA or SARA.
It will be necessary to confirm the efficency of the groundwater recovery
system to insure that the concentration levels of mobile compounds in the
contaminated soils are being reduced to levels of no concern. The estimated
time to remove all currently existing contaminated groundwater is 4 years
after initiation of the groundwater recovery system.
At the time that the groundwater recovery operation is completed, it will
be necessary to analyze the residual contaminant concentrations which
will remain in the buried sediments below the former waste water ponds.
The groundwater regime will be allowed to re-equilibrate for two years
after completion.of the groundwater recovery operation. After two years/
the groundwater in the vicinity of the former wait*, water pond will be
resampled to identify the impacts, if any, which the residual soil
contamination will have on the groundwater environment.
------- |