United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-90/061
September 1990
Superfund
Record of Decision
Schuylkill Metal, FL
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50272 101
-
I REPORT DOCUMENTATION I 1. REPORT NO. I ~ So RecJplenh ACC888/on No.
PAGE EPA/ROD/R04-90/061
4. Title Ind SubIItJe 5. Report Data
SUPERFUND RECORD OF DECISION 09/28/90
Schuylkill Metal, FL
I.
First Remedial Action - Final
7. AutMr(a) 8. Performing ~anlzatlon Rept. NO'
8. Performing OrpinlZ8llon N8me and AddrH8 10. P,ojac:tlT88IIIWoril Unit No.
11. ConIf8Ct(C) 0' Grant(G) No.
(C)
(G)
1 ~ Sponaorlng Organization ....... and Add.... 1 So Type o. Report . Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplementary No..
16. Abatract (Umlt: 200 worela)
The 17-acre Schuylkill Metal site is a former battery recycling facility containing
marsh areas in the southwest portion of Plant City, Hillsborough County, Florida.
From 1972 to 1986, the facility was used to recycle lead from batteries; the lead was
subsequently sent off site for smelter processing. Wastes generated in the recycling
process included rubber and plastic chips from battery casings and sulfuric acid
solution. In 1980, the State required the removal of approximately 250 tons of
sediment from a disposal pond, 3,000 tons of battery casings, and 500 tons of soil
underlying the battery casings. Prior to 1981, acidic washdown wastewaters were
stored in a 2.2-acre, unlined wastewater holding pond, and neutralized with lime or
ammonia. In 1981, the facility upgraded the wastewater treatment system, and acidic
rinse washdown wastewaters were neutralized with sodium hydroxide and discharged into
the city's treatment plant. Site investigations conducted in 1981 revealed that
onsite surficial aquifer monitoring wells contained elevated levels of ammonia.
Analyses of soil, surface water, and sediment samples near the processing area and
around the holding pond revealed elevated concentrations of metals. This Record of
(See Attached Page)
17. DoeunvnlAn8lyala L De8alplOff -
Record of Decision - Schuylkill Metal, FL
First Remedial Action - Final
Contaminated Media: soil, sediment, debris, gw, sw
Key Contaminants: metals (lead, chromium, arsenic), acids
b. Icfen1llleralepen.€ndad Terma
c. COSA TI ReIdIGroup
18. Availability SIat8m8nt 18. SecurIty CI... (Thla Report) 21. No. of P.II"
None 109
I 20. Security CI... (Thla Page) ~ Price
None
See ANSI-Z38.18 (4-n)
See Inatrucllona on Ra"e,..
(Formarty NTlS-35)
Department o. Commerce
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EPA/ROD/R04-90/061
~chuylkill Metal, FL
rirst Remedial Action - Final
Abstract (continued)
Decision (ROD) provides a final remedy and addresses all contaminants
contaminants of concern affecting the soil, debris, sediment, ground
water are acids and metals including lead, arsenic, and chromium.
at the site. The
water, and surface
The selected remedial action for this site includes excavation and onsite solidification
of approximately 36,000 cubic yards of contaminated soil from the process area and
approximately 2,000 cubic yards of contaminated sediment from the ditches; onsite
disposal of treated soil and sediment; debris recycling; onsite treatment of surface
water from the wastewater holding pond and pumping and treatment of ground water by
chemical action and filtration, followed by offsite discharge of the treated surface and
ground water to a publicly owned treatment works (POTW) or to surface water; biological
monitoring of the east and west onsite marshes; installing flood control mechanisms to
maintain continued surface water inundation in the east marsh; mitigating the wetlands
that have been adversely impacted by the site; and implementating of site access
restrictions including fencing. The estimated present worth cost for this remedial
ranges from $5,864,000 to $8,161,000, depending on O&M costs, which will be estimated
during the RD/RA phase.
PERFORMANCE STANDARDS OR GOALS: All soil with lead levels of 500 mg/kg and ditch
sediment to a depth of 2 feet will be treated by chemical stabilization. This cleanup
level was based on site-specific analyses to prevent excessive lead leaching to the
7round water. Debris will be excavated to a depth of between 3 and 10 feet below land
surface and will be recycled. Ground water cleanup level is lead 0.015 mg/l (MCLs or
background levels), and treated water discharged to nearby wetlands will achieve lead
levels of 0.013 mg/l (WQC). The Ambient Water Quality Criteria for the existing marsh
and for surface water has been waived, due to the potential for destructive effects of
the remediation on the wetlands.
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RECORD OF DECISION
THE DECLARATION
SITE NAME AND LOCATION
Schuylkill Metals Corporation
Plant City, Hillsborough County, Florida
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action
for the Schuylkill Metals Corporation site, in Plant City,
Florida, which was chosen in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and to the extent
practicable, the National Contingency Plan (NCP). This
decision is based on the administrative record for this site.
The State of Florida has concurred in the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health,
welfare, or the environment.
this
DESCRIPTION OF THE SELECTED REMEDY
This response action represents the first and final action for
the site. This remedy addresses the source, soil, sediment,
surface water, and groundwater contamination. This action
addresses the principal threat at the site by excavating and
treating the most highly contaminated soils. This action also
addresses the potential environmental threat of the marshes.
The major components of the selected remedy include:
Excavation and treatment, via on-site solidification, of
approximately 36,000 cubic yards of contaminated soils
from the process area and approximately 2,000 cubic
yards of contaminated sediments from the perimeter
ditch;
Disposal on-site;
Debris recycling;
Treatment of surface water from the wastewater holding
pond and groundwater on-site;
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-2-
Disposal of treated water to the publicly owned
treatment works (POTW) or surface waters;
East and west marsh fencing and biological monitoring;
East marsh flood control mechanisms to maintain
continued surface water inundation and biological
monitoring;
Mitigation to compensate for the wetlands that have been
adversely impacted by the site; ~nd,
A waiver of the Federal Ambient Water Quality Criteria
(AWQC) is required for the surface water. The waiver is
justified by the potential negative environmental impact
that could be created by achieving this standard in the
marsh. This would involve complete destruction of
wetlands and potential mobilization of metals beyond the
site area (CERCLA 121(d)(4)(B)).
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, except where a waiver can be justified for
whatever Federal and State applicable or relevant and
appropriate requirement will not be met, and is .
cost-effective. This remedy satisfies the statutory preference
for remedies that employ treatment for the reduction of
toxicity, mobility or volume as a principal element and
utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable for this site.
Because this remedy will result in hazardous substances
remaining on-site, a review will be conducted within five years
after commencement of remedial action to ensure that the remedy
continues to provide adequate protection of human health and
the environment.
SEP 2 g 1990:
(\ - .
U
Greer C.
Regional
\\.1~~~~
I
t+"-'
Tidwell
Administrator
Date
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1.0
2.0
3.0
4.0
5.0
6.0
SITE
1.1
1.2
1.3
1.4
1.5
TABLE OF CONTENTS
BACKGROUND. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Site Location......................................... . 1
Site Deser iption. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Site Geology & Hydrogeology.................. ..........5
1.3 . 1 Introduction.................................... 5
1.3.2 Surficial Aquifer System........................5
1.3.3 Surficial Aquifer Hydraulic Properties..........5
1.3.4 Intermediate Aquifer System.....................5
1.3.5 Intermediate Aquifer Hydraulic Properties.......5
1.3.6 Floridan Aquifer. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10
Site Hi story. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Enforcement Activities.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12
COMMUNITY RELATIONS HISTORY. ...............................13
SCOPE & ROLE OF RESPONSE ACTION............................13
SITE
4.1
4.2
4.3
4.4
4.5
4.6
4.7
4.8
4.9
4.10
CHARA.CTERISTICS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .14
Soil. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .14
Groundwater: Surficial Aquifer...................... .16
Groundwater: Intermediate Aquifer...... ............. .16
Surface Water: East and West Marshes................ .16
Surface Water: Wastewater Holding Pond.............. .20
Surface Water: Perimeter Ditch Surface Water...... ...20
Sediments: Wastewater Holding Pond & Perimeter Ditch.20
Sediments: East and West Marshes.................... .22
Contamination Distribution...... ........ ..... ........ .22
Wetland. Impact Study.................................. 25
SU!11w1A.RY OF 5 ITE RISKS...................................... 26
5.1 Indicator Chemicals................................... 26
5.2 Exposure Assessment.................................. .27
5.3 Toxicity Assessment...................................27
5 .4 Human Health Risk..................................... 31
5.5 Wetland Risk to Humans and Ecology................... .31
5.5.1 Identification of the Wetland
Contaminants of Concern........................ 31
5.5.2 Exposure Assessment Summary for the Wetlands...31
5.5.2.1 Human Exposure Pathways in the
Wet lands. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
5.5.2.2
Environmental Exposure Pathways
in the Wetlands................. . . . . . .35
5.5.3
5.5.4
5.5.5
Summary of the Aquatic Toxicity Assessment:
E a s t Mar s h. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 5
Environmental Summary......................... .35
Environmental Risk Conclusions.................36
DESCRIPTION OF ALTERNATIVES................................37
6.1 Soil, Pond, Ditch, and Groundwater Alternatives.......37
6.1.1 Alternative 1 - No Action..................... .37
6.1.2 Alternative 2 - Containment....................37'
6.1.3 Alternative 3 -
Source Removal/Off-Site Disposal.............. .39
6.1.4 Alternative 4 -
Source Removal/On-Site Treatment of Soils
(F ixation) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .39
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6.2
7.0
6.1.5
6.1.6
Wetland
6.2.1
6.2.2
6.2.3
6.2.4
-ii-
Alternative 5 -
Source Removal/On-Site Treatment of Soils
(Heap Leaching)/Off-Site Lead Recovery. ..........17
Surface and Groundwater Remediation........... ...42
6.1.6.1 Surface Water And Groundwater
6.1.6.2
Recovery. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .42
6.1.6.1.1 Holding Pond and
Infiltration Trench..........42
Surface and Groundwater Treatment.......43
6.1.6.2.1 Ion Filtration...............43
6.1.6.2.2 Electrochemical Precipitation
and Clarification.. ..........44
6.1.6.2.3 Microfiltration/
Electrochemical
Precipitation................44
Al ternati ves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .45
No Action Alternative........................... .45
Mechanical Controls Alternative.................45
6 . 2 . 2 . 1 We 5 t Mars h. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
6 . 2 . 2 . 2 Eas t Mars h. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47
Low Permeablility Cover and Solidification
Al t e rna t i ve. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 7
6 .2 .3.1 West Marsh.............................. 48
6 . 2 . 3 . 2 E a 5 t Mar s h. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 8
Sediment Removal Alternative.....................48
6.2.4.1 West Marsh......................... . . . . .49
6 . 2 . 4 . 2 Eas t Mars h. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES..............50
7.1 Overall Protection of Human Health and the Environment..51
7.1.1 Soil, Pond, Ditch, and Groundwater Alternatives. .51
7.1.2 Wetland Alternatives.............................52
7.2
7.3
7.4
7.5
7.6
7.7
8.0
9.0
Compliance with ARAR.s. . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . .53
7.2.1 Soil, Pond, Ditch, and Groundwater Alternatives..58
7.2.2 Wetland Alternatives..... .......... ........... ...58
Short-term Effectiveness................................ 58
7.3.1 Soil, Pond, Ditch, and Groundwater Alternatives..58
7 . 3 . 2 Wetland Al ternati ves . . . . . . . . . . . . . . . . . . . . . . . . . . . . .59
Long-term Effectiveness. . . . . . . . . . .. . . . . . . . .. . . . . . . . . . . . .59
7.4.1 Soil, Pond, Ditch, and Groundwater Alternatives. .59
7.4.2 Wetland Alternatives............................ .60
Reduction of Toxicity, Mobility, or Volume
Through Treatment....................................... 60
7.5.1 Soil, Pond, Ditch, and Groundwater Alternatives. .60
7.5.2 Wetland Alternatives.............................61
Implementabil i ty. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62
7.6.1 Soil, Pond, Ditch, and Groundwater Alternatives..62
7.6.2 Wetland Alternatives............................ .62
7.7.1
7.7.2
Cos t. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62
Soil, Pond, Ditch, and Groundwater Alternatives. .63
Wetland Alternatives.............................63
STATE AND COMMUNITY
ACCEPT.ANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3
THE SELECTED REMEDY.......................................... 6 =:,
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-iii-
10.0 STATUTORY DETERMINATIONS.....................................70
10.1 Protection of Human Health and the Environment.........70
10.2 Attainment of A.RARs................................. . . .71
10.3 Cost Effectiveness.....................................72
10.4 Utilization of Permanent Solutions and Alternative
Treatment (Or Resource Recovery) Technologies to the
Maximum Extent Practicable.............................72
10.5 Preference for Treatment as a Principal Element....... .73
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES.........................?3
References
Appendix I - Wetland Sampling Data
Appendix II - Responsiveness Summary
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Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
FIGURES
Title
Paqe
Loca tion Ma.p. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .' . . . . . .2
General 5i te Map.......................................... 3
Topographic Site Map...................................... 4
Hydrogeologic Column and Hydrostratigraphic Nomenclature..6
Hydrogeologic Cross-Section
Hydrogeologic Cross-Section
A-A' . . . . . . . . . . . . . . . . . . . . . . . . . 7
B-B I . . . . . . . . . . . . . . . . . . . . . . . . . 8
Wa ter-Table Map.....'...................................... 9
Total Lead Levels for Surface Soils Depth of 0.5' - 1.0'.15
Concentration of Lead in Surficial Aquifer...............17
Field Parameters: pH of Surficial Aquifer................18
Total Lead Concentration in Samples from Ditch
and Marsh Surface Water..... ...... .......... ...... ...19
Total Lead Concentration in Pond And Ditch
Sediment Samples..................................... 21
Total Lead Concentration in Marsh Sediment Samples.......23
Concentration of Sulfates in Surficial Aquifer...........24
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- Number
1
2
3
4
5
6
7
8
9
10
TABLES
Title
Paqe
Matrix of Potential Exposure Pathways:
Baseline Conditions.. ............ ...... .......28-29
Health-Based Criteria for Contaminants of Concern....30
Calculation of Chronic Hazard Index..................32
Applicable Water Quality Criteria.......... ..........33
Exposure Scenarios Wetland Area......................34
Remedial
Alternatives............................... .38
Applicable and Relevant and Appropriate Requirements
Groundwater. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54
Applicable and Relevant and Appropriate Requirements
Surface Water and Air..........................55
Cleanup Goals for Soil............................... 57
Total Present Worth Costs for
Remedial Action Alternatives...................64
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RECORD OF DECISION
DECISION SUMMARY
SCHUYLKILL METALS CORPORATION SITE
Plant City, Hillsborough County, Florida
Prepared by
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia
September, 1990
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Record of Decision
The Decision Summary
Schuylkill Metals Corporation
Plant City, Florida
Site
1.0
SITE BACKGROUND
1.1
Site Location
The Schuylkill Metals Corporation (SMC) site is located at 402
South Woodrow Wilson Street in the southwestern portion of
Plant City, Florida (Figure 1). The population estimate for
Plant City is 20,000 and covers an area of 1,423 sq. miles.
Plant City is located approximately 25 miles east of Tampa,
Florida. Residents of Plant City and the vicinity primarily
work in agriculture, phosphate mining or commute to Tampa or
Lakeland for emploYment. Land use in the Plant City area is
primarily agricultural. Row crops such as strawberries and
citrus are the primary crops cultivated in the area.
1.2
Site Description
SMC in Plant City covers an area of approximately 17.4 acres
and has an irregular shape. Adjacent properties include
undeveloped lands and a railroad line to the north, a housing
development and agricultural pastureland to the south, an oil
distribution terminal and housing to the east, and agricultural
land with scattered housing to the west.
A general sit€ map of the SMC facility is shown on Figure 2.
The facility can be divided into several areas based on former
SMC operations. These areas are the processing area (office,
truck scales, maintenance building, liquid storage area, the
railroad spur area and the truck parking area), the wastewater
holding pond, the perimeter ditch and the marsh areas. The
processing area (Figure 2) consists of approximately 2.3 acres
and the former wastewater holding pond covers approximately 2.2
acres.
A 5-acre east marsh borders the eastern side of the site and
measures approximately 800 feet by 500 feet. A "T"-shaped
canal exists within the marsh and periodically discharges to a
culvert. The wetland is classified as permanently flooded
depressional Palustrine emergent; however, various species of
shrubs are present also. The facultative plants vegetate the
higher areas of elevation within the marsh. The dominant
emergent is smartweed which is high in value as a waterfowl
source.
A contour map showing the site topography is shown on Figure 3.
There is a gen~le slope from the west and the southwest toward
the SMC property. To the north, the railroad embankment
controls the elevations on that side of the site.
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2000
.
Scal. in Fut
4000
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10
20
30
Scol. in Milu
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PLANT CITY,
FLORIDA
LOCATION MAP
SCHUYLKILL METALS
SITE - PLANT CITY
FLORIDA. '
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DATI: 07/29/86
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SCHUYLKILL METALS SITE-AERIAL 10/04/86
PLANT CITY, FLORIDA
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SCHUYLKILL METALS CORPORATION
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SCHUYLKILL METALS SITE
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- ----
SCHUYlK ILL METALS CORPORATION
II'
TITLE
TOPOGRAPHIC SITE MAP
Woodward-Clyde Consultants
CONTOUR INTERVAL: I FOOT
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-5-
1.3
1.3.1
Site Geology and Hydrogeology
Introduction
The SMC site is underlain by three aquifer systems. In
descending order these aquifers are the surficial, intermediate
'(Hawthorn), and Floridan aquifers (Figure 4).
1.3.2
Surficial Aquifer System
The surficial aquifer system of the SMC site consists of well
sorted and silty sand, having high concentrations of organic
material. Locally, this unit ranges from eight to twenty feet
in thickness. Figures 5 and 6 are northeasterly trending
cross-sections, showing a thinning of the unit in the central
portion of the site. Groundwater in the surficial aquifer
occurs under unconfined conditions.
1.3.3
Surficial Aquifer Hydraulic Properties
Aquifer testing indicat~s a moderate transmissivity of 132
square feet per day (ft /day) and a hydraulic conductivity of
10.15 ft/day. The estimated groundwater flow velocity
calculated from aquifer characteristics and the observed
water-table gradient is 0.3 ft/day. Figure 7 shows the
configuration of the water-table aquifer and direction of
groundwater flow.
1.3.4
Intermediate Aquifer System
The upper unit of the intermediate aquifer is dominantly a
sandy and phosphatic clay, ranging from 36 to 55 feet in
thickness (Figures 5 and 6). This upper confining clay is
interrupted by limestone beds measuring one to five feet in
thickness. Immediately below the clay, a laterally persistent,
moderately-to-highly permeable limestone unit ranging from 10
to 25 feet in thickness forms the actual aquifer. Below this
limestone, a 30 foot thick calcareous clay, interstratified
with a stiff clay overlies the Tampa limestone. The Tampa unit
is the upper member of the Floridan aquifer and is the lower
confining unit of the intermediate aquifer. This sequence of
clays and limestones below the surficial aquifer belongs to the
Hawthorn Formation.
1.3.5
Intermediate Aquifer Hydraulic Properties
-Vertical permeability measurements made50n samples from the
upper confining clay gave values of 10- ft/day, indicating
very low permeab~lity. This is in contrast to the transmis-
sivity of 160 ft /day and hydraulic conductivity of 16 ft/day
calculated from an aquifer test conducted in a well completed
in the limestone of the Hawthorn Formation. The estimated
groundwater flow velocity of the intermediate aquifer is 2.5
ft/day.
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~
u 50
:
IE
~ .
C RBONATE INTERMEDIATE
o . SYSTEM
.
z 80 .
j .
. LIMESTONE,CHERT, TRACE ftHOSPHAT . INTERMEDtATE
~ HIGHLY ~EAMtAILE AOUI"-ER
I 7'0 .
.
t;
1&1
... (UPPER
! 80 MIOCENE)
%
~
~
LOWER
.0 HAWTHORt-4 CONFINING
a.AT CALCAREous. INTERBEDOED WITH STJf1f C\..AY UNIT
100
-6-
LAND SURFACE
,: j!jl~~IIII~ii~I][~'~]'~iiM~lli'i]~i~i~:;~'~m~'iimlli~i'm!\,/II!
20
30
40
HAWTHOR"
CLAY, PHOSPHATIC, SANDY
110
110
TOTAL
DEPTH
125 'EET
FIGURE 4
SUR"'CI~
AQUI'[~~ I
t PLEISTOCENE
AND
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UPPER
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-10-
The permeability of the 30 foot section of clay comprising the
10wSr confining unit was found to be approximately
10- ft/day.
1.3.6
Ploridan Aquifer
Below the intermediate aquifer, the limestones of the Floridan
aquifer measures over 1,000 feet in thickness. The top of the
unit exists at an elevation of approximately 5 feet above sea
level (110 feet below land surface). The Floridan aquifer is
the primary source of potable water in the Plant City area.
1.4
Site History
Prior to 1972 the site was relatively undeveloped. From 1972
until June 1986, SMC operated a battery recycling facility at
the site. Lead from automobile batteries was reclaimed and
sent to Baton Rouge, Louisiana for smelter processing. Until
the late 1970's waste generated from the lead recovery process
included rubber and plastic battery casings in the form of
chips and sulfuric acid solution (electrolyte); however, by the
late 1970's most battery casings no longer contained rubber.
Battery casing chips were initially used as fill in the process
area and later marketed for plastic reclamation. The
electrolytic solution in the batteries was also marketed during
the later years of operation.
Prior to 1981, acidic washdown wastewaters were stored in an
approximately 2.2 acre, unlined wastewater holding pond.
Initially, lime was utilized for pH adjustment of the waters
stored in the holding pond and later ammonia was used. In
1981, the wastewater treatment system was upgraded and no
acidic rinse waters were discharged into the pond. After this
date, all wastewaters were treated with sodium hydroxide for pH
adjustment and discharged under permit to Plant City's
Wastewater Treatment Plant.
Site investigations began in 1978 when Law Engineering and
Testing Company (LETC), representing SMC, attempted to define
wastewater contamination problems at the site and develop
possible alternative wastewater treatment and disposal
methodologies. Recommendations for improvement to the then
existing system of stormwater and surface water run-off
controls were made and subsequently implemented. A test boring
and monitoring well installation program, also performed by
LETC, provided stratigraphic and hydrogeologic information as
'well as preliminary data concerning on-site groundwater
quality.
In 1981, Ecology and Environment, Inc. as a contractor to
US EPA, Region IV, conducted an investigation of SMC. The
intent of the study was to determine whether hazardous
materials at the site were causing groundwater contamination
and, if so, the extent and degree of this contamination. The
results of this study indicated that groundwater from the
surficial aquifer contained elevated levels of cadmium,
chromium, and lead around the wastewater holding pond and
elevated levels of lead near the processing area
-------
-11-
(E & E, Inc., 1981). In addition, on-site surficial aquifer
monitoring wells showed elevated levels of ammonia. No
indication of contamination was found in the private wells in
the vicinity of the 5MC facility; however, the off-site
downgradient surficial aquifer was not sampled. Analyses of
soil, surface water and sediment samples showed elevated
concentrations of lead and cadmium.
In 1984, SMC retained Brown & Kirkner, Inc. and Gulf Coast
Engineering, Inc. to prepare a Groundwater Monitoring Plan in
compliance with the requirements of Florida Administrative Code
Chapter 17-4. Sampling of wells installed in accordance with
this plan indicated contaminant concentrations which exceeded
Florida's primary drinking water limits for lead and chromium
and secondary limits for sulfate in the surficial aquifer east
of the processing area.
As a result of the 1981 EPA study and subsequent listing of the
site on the National Priorities List (NPL), Woodward-Clyde
Consultants performed a Remedial Investigation (RI) at the
facility during 1987. This investigation was completed in
December, 1987. The investigation was performed at the site to
characterize the nature and extent of contamination. Various
site media were sampled including soils, surface water,
sediments, and groundwater. Soil sampling concentrated around
the processing area which was considered to be the probable
source of contamination.
In April 1988, Woodward Clyde's RI Addendum Report addressed
specific areas of concern that were not included in the initial
study. An assessment of the public health was also performed
as part of this study. Chemical, hydrologic, and geologic data
collected during the RI confirmed that elevated levels of lead
and chromium exist in the surficial aquifer underlying the
processing area, in the soil underlying the processing area,
and the surface water of the wastewater holding pond and
perimeter ditch (WWC, 1988).
In July 1988, a draft Feasibility Study (FS) was completed
which included proposed cleanup levels for soil and groundwater
and evaluated the available remedial alternatives for this site
(WWC, 1988).
The FS report was revised to address FDER/EPA review comments.
A treatability study work plan was submitted in January 1989,
to evaluate chemical fixation as the proposed soil remedy.
In July 1989, Woodward-Clyde completed the FS Addendum 1,
Sampling Report for Marsh, Perimeter Ditch, and Surface
Impoundment to determine appropriate cleanup levels for the
soil, perimeter ditch sediment, and marsh sediment. The
Addendum allowed EPA to address potential remedial actions to
mitigate the environmental threat to the marshes posed by the
release of contaminants from the SMC site.
In May 1989, the Environmental Services Division (ESD) of EPA
conducted two studies on the east marsh at the site: a
-------
-12-
wetland classification assessment and a sampling
investigation. The wetland was classified, delineated, and
analyzed for its functional value. Samples of the surface
water and sediment were collected and analyzed. The ESD
sampling Report and the Wetland Classification Report were
completed in August 1989.
These reports identified the need to perform biological testing
on marsh samples. In September and October of 1989, ESD
collected surface water and sediment samples to determine the
toxicity of the metal contaminants to terrestrial and aquatic
organisms, indigenous plant and animal bioaccumulation, as well
as the fate of these metals in the wetland system. The Wetland
Impact Study, finalized in April of 1990, presented the
chemical and biological data and the affect of potential
remedial activities on the marsh.
A Draft Final Addendum to the Feasibility Study Report,
concluded in July of 1990, evaluated the technologies for
remediation and the remedial alternatives appropriate for the
wetlands. It compared the feasibility of four alternatives in
relation to the nine evaluation criteria.
1.5
Enforcement Activities
A temporary operating permit (TOP) was issued by FDER to SMC in
July 1980. As a result of a special condition in the TOP,
action conducted by SMC included the removal of approximately
250 tons of sediment from the disposal lagoon, 3,000 tons of
battery casings and 500 tons of soil beneath the battery
casings.
In October 1983, SMC received an Industrial Operating permit
from FDER (permit #10 29-51092). The specific conditions of
the permit required SMC to evaluate the groundwater quality in
both the shallow aquifer and the underlying Floridan Aquifer
system by installing a network of monitoring wells at the
site. The company's conclusion was not to take immediate
remedial action involving the disposal pond.
A comprehensive groundwater interim status inspection was
conducted by the EPA Environmental Services Division (ESD) and
the FDER Southwest District Office in January 1985, to
determine the Resource Conservation and Recovery Act (RCRA)
compliance status of Schuylkill Metals Corporation. SMC used
the surface impoundment for treatment and disposal of their
waste for a number of years. Under a State order, SMC agreed
to comply with the RCRA requirements for surface impoundments
through the CERCLA action. As a result of violations found
during a subsequent RCRA inspection conducted at the facility,
the FDER Southwest District Office's enforcement section issued
a Notice of Violation (NOV) to SMC in September 1985.
In July 1986, the FDER and SMC entered into a Consent Order
which required SHC to perform a remedial investigation/
feasibility study (RI/FS) as required by CERCLA.
-------
-13-
In October 1988, a RCRA closure permit was issued under the
provisions of Section 403.722, Florida Statutes, and Florida
Administrative Code Rules 17-3,17-4, 17-21, 17-22, and 17-30.
This directed Schuylkill Metals to close the unlined hazardous
waste pond and specified the closure procedures. The RCRA
closure/post-closure plan for the disposal pond will be
addressed by the CERCLA design for remedial action.
2.0
COMMUNITY RELATIONS HISTORY
The RI/FS and Proposed Plan for the SMC site were released to
the public in August 1989 and August 1990. These two documents
were made available to the public in both the administrative
record and an information repository maintained at the Plant
City Public Library and the EPA Docket Room in Region IV,
Atlanta. The notice of availability of these two documents was
first published in The Courier, and the Tampa Tribune on August
27, 1989. A public comment period was held from August 31,
1989 through September 22, 1989. No comments were received
during this public comment period. In addition, a public
meeting was to be held on August 16, 1989. However, this
meeting was postponed.
A FS Addendum was placed in the repository and a second public
comment period was held from August 17, 1990 through September
14, 1990. A notice of availability was published in the Tampa
Tribune at the start of the comment period and in The Courier a
week prior to the public meeting held on August 30, 1990. At
this meeting, representatives from EPA answered questions about
the problems being addressed at the site, the remedial
alternatives considered, and the alternative tentatively
selected by EPA. A response to the comments received during
this period is included in the Responsiveness Summary, which is
part of this Record of Decision. This decision document
presents the selected remedial action for the SHC site in Plant
City, Florida, chosen in accordance with CERCLA, as amended by
SARA and, to the extent practicable, the National Contingency
. Plan. The decision for this site is based on the
administrative record.
3.0
SCOPE AND ROLE OF RESPONSE ACTION
This cleanup remedy will address all contaminants at this site
and is considered a final remedy. This action will address the
principal threats of the SMC site: contaminated soils in the
processing area, surface waters in the holding pond, surface
water and sediment in the perimeter ditch, sediment in the east
marsh, and groundwater contamination in the surficial aquifer.
This action will also address the environmental threats of the
east and west marsh.
The soils in the processing area were determined to be the
principal threat at the site due to the potential threat of
direct contact with the soils and also the leaching of
contaminants from the soil to the groundwater. The objective
of the response action is to prevent current and future
-------
-14-
exposure of human and other receptors to the contaminated soils
and reduce contaminant migration from the soil to groundwater
in order to achieve health based levels in the groundwater.
The surface water of the pond will be remediated through a
groundwater collection and treatment system. The risks
associated with exposure to ditch surface water will be
significantly reduced by sedLment excavation. Long-term
groundwater monitoring following groundwater remediation will
ensure that this remedy is effective in removing the principal
threat of exposure through the use of contaminated groundwater
as a drinking water source. Verification sampling of the pond
sedLments after dewatering will address the potential for
sedLment excavation. The remedial action will be evaluated
periodically. This document will also address the east and
west marsh contamination. The cleanup objectives for the west
marsh are designed to prevent human exposure to the
contaminated sedLment and surface water through the
installation of mechanical barriers. The cleanup objectives
for the east marsh are to prevent human and environmental
exposure to the contaminated sedLments by flooding the marsh,
i.e. containment, and to reduce the migration of contaminants.
Biomonitoring of the east marsh will document the remedy's
Lmpact to the environment and mitigation will create additional
wetlands.
4.0
SITE CHARACTERISTICS
Contaminants of concern at the site include the heavy metals
lead, cadmium~ chromium, and antimony. These chemicals are
present in the soils and in the waters of the site. The
processing area soils contain lead at levels which would be
classified as a RCRA hazardous waste under the Extraction
Procedure (EP) Toxicity test. The surface waters on-site
contain levels of lead, cadmium, chromium, and antLmony above
Florida surface water standards and prLmary drinking water
standards. On-site groundwater also contains concentrations of
lead above Florida's drinking water standard.
4.1
Soil
Soil contamination is limited to the area surrounding the
existing process pad. Figure 8 shows the horizontal extent of
soil contamination. During field investigations, this area was
noted to have empty battery casings to depths of up to 7 feet
below grade (WWC, 1987).
During the RI and RI Addendum studies, sixty-six soil samples
were collected and analyzed to a depth of 8 feet. Total lead
concentration in the process area was as high as 51,000 mg/kg
in the 1.0 to 2.0 feet below ground surface (BGS) depth range.
Results of EP toxicity analysis for lead ranged from below
detection limits (BDL) to 34 mg/L in the 0.5-1.0 foot BGS soil
samples. Samples collected from the 2 to 3 foot interval had
EP toxicity concentrations ranging from BDL to 6.6 mg/L;
however, only two of these samples exceeded the 5 mg/L limit
for determining hazardous waste under RCRA (WWC, 1988).
-------
LEGEND
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High total lead levels (up to 39,000 mg/kg) were also detected
in soil samples collected from the 3 to 8 foot BGS depth
range. These high values are attributed to the burial of
battery casings during past operations (WWC, 1987).
4.2
Groundwater:
Surficial Aquifer
Groundwater of the surficial aquifer contained concentrations
of lead above 0.015 mg/L, the proposed cleanup goal. The
concentrations ranged from 0.01 to 0.18 mg/L (Figure 9). The
only other metal detected above the MCL in the surficial
aquifer was chromium, ranging in concentration from 0.06 mg/L,
to 0.58 mg/L (WWC, 1987). Chromium has an MCL of 0.050 mg/L
and a pMCL of 0.10 mg/L.
The presence of high (13 to 180,000 mg/L) concentrations of
sulfate in the surficial aquifer is due to the washdown waters
from the process area. The washdown waters have percolated
through the soils in the processing area. In addition, waters
from the wastewater holding pond have entered the surficial
aquifer. Elevated concentrations of sulfate have been noted in
the surficial aquifer over a large portion of the site (WWC,
1987) .
The pH of the surficial aquifer beneath the processing area is
. 3.3, approximately two standard units (SU) below control levels
(Figure 10). The pH of the control samples is 5.6 and is
characteristic of Florida's surficial aquifer. The pH values
approach that of the control sample at the processing area
boundary (WWC ,. 1987).
4.3
Groundwater:
Intermediate Aquifer
No contaminants above values detected in the control sample
were detected in groundwater samples collected from the
intermediate aquifer. This suggests that the waters of the
surficial aquifer and intermediate aquifer are separated
hydraulically. Other factors influencing lack of contaminant
migration may be dilution through the relatively rapid movement
of groundwater in the intermediate aquifer.
Soil core samples collected and analyzed from the confining
unit separating the surficial and intermediate9aquifers
indicate that it is relatively impervious (10- ft/sec). As
a result of the very low permeability and thickness of this
unit, the confining unit appears to be an effective barrier
separating the surficial and intermediate aquifers (WWC, 1987).
4.4
Surface Water:
East and West Marshes
Surface water samples collected from the east marsh during the
RI and subsequently during an investigation conducted by EPA
indicate lead concentrations ranging from BDL to 0.440 mg/L
(WWC, 1987 and u.S. EPA, 1990). Figure 11 shows the 13 east
marsh and 3 west marsh sampling station locations and
distribution of lead. Sampling of the west marsh's surface
-------
LEGEND
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water indicated lead concentrations ranging from 0.110 mg/L to
0.570 mg/L (Figure 11) (U.S. EPA, 1990). These lead levels
exceed Florida's Class III Surface Water Criterion (0.030 mg/L)
and the U.S. Ambient Water Quality Criterion (AWQC), which,
when adjusted for water hardness at this site, is 0.013 mg/L.
Iron concentrations in surface water samples collected from the
east marsh ranged from 0.63 mg/L to 27 mg/L. The surface water
samples collected from the west marsh ranged from 1.6 mg/L to
2.8 mg/L iron. Surface water zinc concentrations in the east
marsh ranged from 0.01 mg/L to 0.54 mg/L in 18 out of 20
sampling locations and in the west marsh ranged from 0.029 mg/L
to 0.39 mg/L in the 3 sample locations. Arsenic was not
detected in the 3 west marsh surface water samples: however,
arsenic was detected in 4 out of 20 east marsh surface water
samples ranging from 0.013 mg/L to 0.54 mg/L. Surface water
data for all contaminants tested is found in Appendix I.
4.5
Surface Water:
Wastewater Holding Pond Surface Water
Elevated concentrations of lead (average concentration of 1.3
mg/L) were detected in water samples collected from the
wastewater holding pond during the 1987 investigation. Sulfate
concentrations of approximately 2,200 mg/L were found in all
pond water samples. However, since a surface water quality
standard for sulfate does not exist and sulfate does not have a
secondary drinking water standard, the sulfate is not
considered a contaminant of concern. Because the water surface
of the holding pond is higher than the surficial aquifer,
groundwater mounding creates a potential for movement of
contaminants from the pond into the surficial aquifer (WWC,
1987).
4.6
Surface Water:
Perimeter Ditch Surface Water
One on-site surface water sample and two off-site samples
collected in the ditch contained lead at concentrations ranging
from 0.10 to 0.19 mg/L, exceeding the AWQC for this site and
the Florida surface water standard. Chromium was below
detection limits in the samples analyzed (WWC, 1987).
Additional surface water samples collected during the FS
Addertdum 1 study had concentrations of lead ranging from 0.014
to 0.033 mg/L of lead. Figure 11 shows the distribution of
lead in surface waters during both studies.
4.7
Sediments:
Wastewater Holding Pond and Perimeter Ditch
Analyses of sediment samples from the perimeter ditch and
wastewater holding pond showed levels of lead below the EP
Toxicity threshold. Random sampling of the upper 0.5 ft of
perimeter ditch samples indicated the presence of lead in 7 out
of 10 samples at concentrations ranging from 5.7 to 58 mg/kg.
The remaining three samples ranged between 580 to 1,100 mg/kg
(Figure 12).
-------
LEGEND
I'
.'1
. SEDIMENT SAMPLING LOCATION.
TOI AI. lEAD CONCENTRATION
IN MGiKG VAlUE IN PARENTHESIS
IS RESULT OF DUPlICA TE SAMPLE.
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-------
-22-
4.8
Sediments:
East and West Marshes
Analytical data from sediment samples obtained from both
marshes are shown on Figure 13. Lead concentrations in the 13
east marsh sample locations range from 110 to 3,500 mg/kg. The
highest concentrations were found in the east marsh's canal,
where lead concentrations range from 1,200 to 3,500 mg/kg
(Figure 13). Arsenic was detected in all marsh sediment sample
locations from 9 to 72 mg/kg. Mercury was detected in nine of
the sediment samples (0.07 to 0.37 mg/kg).
Of the three sediment samples analyzed from the west marsh, all
contained detectable concentrations of lead (520 to 2,800
mg/kg, Figure 13). All of the data shown on Figure 13
represents analytical results for the upper one foot of
sediment. Limited data shows decreased lead concentration with
depth. Soil and sediment data can be found in Appendix I.
4.9
Contaminant Distribution
The sources of contamination at the site are the processing
area, and the former wastewater holding pond. The operation of
the plant entailed the disassembly of batteries containing
sulfuric acid, metallic lead and lead dioxide. This
disassembly resulted in spillage of battery materials to the
soils. After pH processing, liquid wastes were piped to the
wastewater holding pond where the contaminants (dissolved lead
and sulfates) were more widely dispersed.
The high porosity of the surface soils at the site suggests
that the primary movement of liquids is downward until they
encounter the base of the surficial aquifer. The movement of
groundwater within the surficial aquifer is generally radial,
away from the holding pond.
Although there are differences in the hydraulic head between
the surficial aquifer and the intermediate aquifer, the very
low permeability of the intervening confining layer precludes
significant vertical movement of groundwater below the
. surficial aquifer and into the underlying intermediate aquifer.
Movement of sulfate through the shallow aquifer is not
controlled by adsorption. Furthermore, precipitation of
sulfate only occurs at extremely elevated concentrations, above
those observed at the site. However, sulfate in groundwater
may be reduced due to its metabolism by bacteria, provided the
shallow ground water is without dissolved oxygen and contains
organic matter. Despite the potential for the reduction of
sulfate, the shallow groundwater concentrations of sulfate
demonstrate an elongated plume which extends in a southeasterly
direction from the SMC processing site (Figure 14).
The ratio of dissolved lead to sulfate in the site's
groundwater is not the same as that typically found in
lead-acid batteries. As indicated above, sulfate is subject to
biological reduction. Lead may even be less conservative in
nature compare to sulfate. For example, dissolved lead
-------
LEGEND
A Rl'fS SEDIMENT SAMPLING
STATION TOTAL PBCONCENTRA-
liON IN MGiKG
. WI.1LANDS STUDY SAMPliNG
SIA110N TOTAl PBCONCENTRA-
liON IN MG/KG UPPER NUMBER
MAY 1969 t OWER NUMBER
Sf!'T 19119 NS NOt SAMPLED
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CONC[NTRATIOII 01 SUUAT[S (n 504' IN SUllflCIAL AQUIfER
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-------
-25-
concentrations in groundwater could be greatly effected by
adsorption processes in the soils as well as by the
sequestering effects of lead sulfide formation. The efficiency
of the adsorption processes is controlled in part by the pH of
waters as well as the amounts of clay and organic material in
the soil.
Volumetric determinations of est~ated amounts of contaminated
media, shown below, were made for the following areas. These
calculations were based on data obtained during field
investigations.
o
Process Area Soils/Debris - 54,500 cubic yards (cy)
(soil - 36,000 cy) (battery casings - 18,500 cy)
o
Per~eter Ditch Sed~ent - 500 cubic yards
Surface Impoundment - 4.2x106 gallons
Groundwater - 17.7x106 gallons
o
o
The above figures are min~um volumes for soil expected to need
remediation since the possibility does exist that there are
contaminated soils beneath the paved process area. Soils
beneath this pad will be analyzed for total lead during
remediation. Any soils having lead levels above the cleanup
criteria will also be remediated. Verification sampling will
be conducted to assure all the soil contaminated above the
cleanup criterion is remediated.
Results from the RI showed that all areas on-site, including
the soils, pond, ditch and marsh, showed some level of
contamination as a result of the past operations at the site.
4.10
Wetland Impact Study
In September 1989, the Ecological Support Branch of EPA Region
IV conducted a Wetland Impact Study at the Schuylkill Metals
Corporation Site. The overall goal of the study was to provide
the biological and chemical information necessary to evaluate
the ecological hazards associated with the wetland
contaminants. Field, laboratory, and evaluation studies were
designed to provide information on:
1. The existing water quality of the wetland community as
measured by biosurvey techniques.
2. The toxicity of wetland surface waters to aquatic
organisms.
3. The toxicity of sediment samples and sediment
elutriates to terrestrial and aquatic organisms under
diverse environmental conditions.
4.
The fate of the metals in the wetland system.
5. The existing level of metal bioaccumulation by
indigenous plants and animals.
-------
-26-
The study reported that virtually all the species tested
demonstrated some degree of toxicity associated with the
sedLment elutriate. The report cautioned that these tests
reflect worst possible conditions. No toxicity was observed
associated with the canal surface water. In the vegetated
marsh areas, algal growth was significantly retarded but not
precluded. Only one surface water station in the vegetated
marsh area demonstrated moderate toxicity to fathead minnows.
No toxic effects were observed in the terrestrial plant test
with surface water.
Of the metals assessed in the study, only iron and aluminum
exceeded the National Ambient Water Quality Criteria. The
report compared higher concentrations of metals present in the
surface water during the May 1989 sampling to those found in
September 1989. The difference is believed to be due to
dilution of contaminants by rainwater during the September
sampling event. Iron concentrations which remained elevate~
during September probably are the product of the sulfide regime
associated with anaerobic sedLments. Also, the concentration
variance is due to irregular distribution of contaminants and
the differences in exact sampling locations.
The study proposed changing the wetland's hydroperiod to a
permanently flooded marsh condition. Under flooded conditions
the wetland sediments become anaerobic with the overlying water
column having a substandard level of dissolved oxygen. Under
this condition, the sediments would be a likely source of
sulfide which sequesters the metals as a metallic sulfide.
The study further cited biological data gathered by the
National Oceanic and Atmospheric Administration (NOAA) which
indicated a no effect level of 35 mg/kg of lead in the marsh
sediments. The report concluded that trying to achieve this
goal by excavation might result in a disruption of the
anaerobic chemistry and result in the mobilization of lead,
ultimately having a negative environmental impact on the marsh
and downstream from the marsh.
5.0
SUMMARY OF SITE RISKS
The following discussion provides an overview of the baseline
public health and environmental risk from the soils in the
processing area, the pond and the ditch (Chapter 7.0, WWC,
1987). The risks associated with the marsh will be addressed
in a separate section. This evaluation helps determine whether
a remedial action is necessary by addressing the present risk,
should no remedial action be taken.
5.1
Indicator Chemicals
The specific contaminants of concern selected for this
particular site have been evaluated for their human
carcinogenic and non-carcinogenic risk and environmental
effects. The indicator chemicals are chosen to focus the
assessment on the chemicals of greatest concern based on their
frequency of detection, fate and transport, concentration and
-------
-27-
toxicity. The selected compounds and their media of concern
for this site are as follows: soils - antimony, cadmium, lead;
surface water - antimony and lead; and groundwater - antimony,
chromium, lead and sodium.
5.2
,
Exposure Assessment
The exposure pathways for the site are presented in Table 1.
At the present time, the surrounding population's water is
supplied by Plant City and no known drinking water withdrawals
occur in the shallow aquifer downgradient of the site. The
processing area, holding pond, and perimeter ditch are fenced,
decreasing the possibility of adults or children entering the
site and ingesting soils or surface water. Both marshes were
available to public access at the time of the exposure
assessment. However, in developing the hypothetical exposure
scenarios for the various media of concern at this site, it was
assumed that nearby residents could be exposed to any
contaminants on site. The possible future exposure routes if
no action were taken include: ingestion of water from a well
downgradient of the site; incidental ingestion of soils,
surface water vegetation or wildlife on site; dermal adsorption
of soils, surface water, or dusts; or inhalation of fugitive
dusts. No modeling for exposure was performed.
5.3
Toxicity Assessment
None of the indicator chemicals are carcinogens via the oral
exposure pathway with the exception of recent animal data for
lead (see discussion below). Cadmium and chromium are
potential carcinogens by the inhalation route and classified as
B1 and A carcinogens, respectively. However, the risk of
chromium inhalation is not considered significant at this site
due to its presence in groundwater, not soils. The EPA has
developed cancer potency factors (CPF) for estimating excess
lifetime cancer risks associated with exposure to potential
carcinogens. The CPF via inhalation for cadmium is 6.10
(mg/kg/d) .
Chemicals exhibiting non-carcinogenic effects are assessed
using risk reference doses (RfD) or, if unavailable, the Health
Effects Assessment (HEA) developed by EPA. The acceptable
intake for chronic exposure (AIC) and the acceptable intake for
subchronic exposure (AIS) are used to describe the degree of
toxicity of a chemical and are designed to be protective of
sensitive populations. Exposures which exceed concentrations
equivalent to these values would be unacceptable.
Recently, lead has been classified as a B2 carcinogen, but
there are no Agency-approved CPF or RfD at this time. The main
health effect of concern due to lead is neurotoxicity to
children. Presently, the noncarcinogenic effects of lead are
the primary concern, and will be the main consideration at this'
site until the Agency establishes specific limits based on
carcinogenicity.
The health-based criteria for cadmium, chromium, and lead are
listed in Table 2.
-------
Release/
Tra:'\sport
MOOi urn
Release 5cAJrce/
Mechanism
TABLE 1
t-',ATRIX OF POTENTIAL EXPOSURE
PATIlWAYS: BASELINE CONDITIONS
SCKWLYJLL METALS CORPORATION
pwrr CITY, FLORIDA
E;.-pooure Point
Pr 1mary
~e
Route(s)
Number of People
Potentially
~ed
Pa thway
Canpletion
Possible
Probabil i ty of
SignHicant
~e
Gra.mdwater
-------------------------------------------------------------------------------------------------------------------------------------------------
Soi Is
Contaminated Soils
and Fill,
Contaminated SUrface
~ters/Slte Leaching
Contaminated $oils
and Fill,
Contaminated SUrface
waters/Site LeachJng
and SUrface Run-oft
Contaminated So118
and Fill,
F\Jgi tive Dust
Generation
Contaminated So11s
and Fill,
Tracking
Persons currently
utilIzing the
shallow aquifer for
drinking water
Future groundwater
\Ell users (shallCM)
downgradient fran
the site
Perso:'\9 consuming
plants grCMn on-site
or site wildlife
Nearby residents
Enpl0yee9 working
at the site
En1'10"fCC9 working
at the site
Jngestion
Ingestion
Ingc:;t1on
Ingestion,
Inhalation,
Dennul
contact
Ingestion,
Inhalation
Ingrotion,
Inhalation,
Dennal
contact
None: no with-
drawals noted in
the shallow aquifer
downgracUcnt of the
site. Currently,
downgrudient residents
are supplied with Pl&,t
City water
Future use 15 unlIkely
to occur due to the
availabilIty of public
water supply
U:\kna.m:verylCM
Unknown: very low
Unknown: very low,
currently, the site
15 vacan t and
access Is restricted
Un1~: very low,
currently, the sIte
15 vacant ard
access Is restricted
No
Yes
Yes
Yes
No
No
nil
nil to low
nil to low
nil to low
nil to low
nil to low
I
N
00
I
r
~
i
i
I
-------
Release
Transport
Mod J uum
Release Source/
Mechanism
~e Point
TABLE 1
( cant 1nued)
MATRIX OF POTEtn'IAL EXPOSURE
PATIMAYS: BASELINE CONDITIONS
SCtJ.M..Y.ILL METALS CORPORATION
PLANT CITY, FLORIDA
Pr imary
E<-rpoaure
Route(s)
Number of People Pathway
Potentially Completion
Exposed Pos31ble
Probabl1 i ty of
Significant
E;qxxrore
Air
-------------------------------------------------------------------------------------------------------------------------
nil to low
SUrface
Water
ContamJnatcd 5011s
and Fill, Fugitive
Dust Generation
Contaminated Soils
and Fill,
Cont~~inated ~tace
Wutcrs/Runoff and
Groundwater Seepage
Nearby Residents
PeI'SOl1nel on-si te
(CUrrently, the
si te vacant and
accessed by
authorized personnel)
Persons eating
waterfowl fran
marsh
Persons uti Uzlng
on-site surface
water for drinking
or industrial
intakes
Persoro swinning or
fishing in inter-
m1 ttent streams or
its discharge points
Inhalation,
Ingestion,
Dennal
Contact
100
yes
Inha lation
30
yes
Ingestion
Unknown, very
low
Yes
Ingestion
tJone; no intakes No
noted
I~tion
Unknown
Yes
nil to low
nil to low
I
N
\0
I
nil to low
low
r
~
Q
1
i
I
-------
Table 2
Summary of Baseline Risk Characterization
for Groundwater and Soil
GROOImWATKR
Contaminant Concentration (mg/kg) CDI (mg/kg/day) AIC (Source) CDI/AIC
Min Max Mean Maximum Mean Mean Maximum
Antimony 0.10 .005 2.86E-03 1.40E-04 4.00E-04(RfD) 3.5E-01 7.15
Lead 0.17 .029 4.86E-03 8~29E-04 1.40E-03(HEA) 5.9E-Ol 3.47
Chromium (3+) 0.35 .04 1.00E-02 1.14E-03 1.00 (RfD) 1.1E-03 0.01
Chromium (6+) 0.35 .04 1.00E-02 1.14E-03 5.00E-03(HEA) 2.3E-01 2.00
Bazard Index (HI) 1.17 12.63
SOIL
Contaminant
Concentration
Min Max
(mg/kg)
Mean
CDI (mean) mg/kg/day
YQ child adult
AIC (Source)
CDI/AIC
YQ child adult
I
W
a
I
Antimony
Lead
Cadmium
4.1
<0.2
<0.1
4.8
593.2
0.1
5.9
51,000
1.3
1. 3E-05
1.5E-03
2.6E-07
8.4E-08 4.00E-04
1.0E-05 1.4E-03
1.7E-09 2.9E-04
Bazard Index (BI)
3.3E-02
1.1
9.0E-04
1.1
2.2E-04
7.8E-03
6.6E-06
8.0E-03
RID:
Chronic Daily Intake
Acceptable Intake for Chronic Exposure
Risk Reference Dose
Health Effects Assessment
Hazard Index
CDI:
AlC:
DKA:
HI:
-------
-31-
5.4
Human Health Risk
This section quantifies the potential for adverse health
effects due to site related chemical exposure.
Non-carcinogenic health effects are quantified using the Hazard
Index (HI) and are unacceptable if the HI exceeds one (1). The
sum of the Hazard Quotient for each contaminant (HI value) is
calculated for multiple contaminants that may be affecting the
surrounding population or someone with access to the site.
This number represents the estimated risk associated with a
particular exposure route for non-carcinogens. Based on
exposure levels found in the above toxicity assessment, EPA has
determined that the potential for cumulative non-carcinogenic
effects of the indicator chemicals does exist. These risk
values associated with the indicator chemicals are quantified
in Table 3.
The upper bound risk estimate for carcinogens is calculated
using the CPF. Although cadmium is a potential carcinogen by
the inhalation route, it has not been concluded that such a
hazard exists by the oral route (ATSDR, 1987c, WWC, 1988).
Risks for carcinogens representing an excess upper bound
individgal's lifetime cancer risk are acceptable between 10-4
and 10- under the National Contingency Plan (NCP).
5.5
Wetland Risk to Humans and Ecology
Both human and environmental risks were evaluated for the
wetlands area, Due to the greater sensitivity of the
ecological community to the contaminants of concern in the
wetlands, the environmental impacts override the human health
risks for the marshes. The risk evaluation for the SMC
wetlands is based on a Wetlands Impact Study conducted on a
similar wetland in the area.
5.5.1
Identification of the Wetland Contaminants of Concern
Most recent surface water analyses indicate that several metals
were present above the National Ambient Water Quality Criteria
(AWQC) and the Florida Class III Water Quality Standards in the
marshes (Table 4). Lead and iron exceeded these standards in
the west marsh surface water. Iron also exceeded the standards
in the east marsh surface water. Zinc exceeded the Florida
Standard in the surface waters of the west marsh and the AWQC
in the east marsh. Arsenic was present in {he east marsh
surface water at a level representing a 10- risk of cancer
for humans consuming fish from water at this concentration.
5.5.2
Exposure Assessment Summary for the Wetlands
The exposure pathways for contaminants in the marshes are
evaluated for two possible receptors, human and environmental.
5.5.2.1
Human Exposure Pathways in the Wetlands
The exposure pathways for humans in the marshes are presented
in Table 5. Potentially exposed populations are adults and
-------
-32-
Woodward-Clyde ConsuItanta
TABLE 3
CALCULATION OF CHRONIC HAZARD INDEX
EXPOSURE POINT:
ON-SITE SURFICIAL AQUIFER
Chemical
Chromium
Lead
CD I ( 1 )
9.4E-03
4.8E-03
AIC (2)
5.0E-03
1.4E-03
-
(~) CDI - Chronic Da~ly Intake
(2) Calc~lated values from ~able 7.12
AIC - Acceptable Intake for Chronic Exposure
CD!: AIC
>1.0
>1.0
-------
-33-
TABLE 4
Applicable ~ater Quality Criteria
Florida \later
Quality Stds (ug/l)
Class
III
Nat'l Ambient ~ater Quality Criteria
Aquatic Life Criteria
Maximum Continuous
Concentration Concentration
(ug/l)
Hunan Heal th
Cons~tion
of Fish/Shellfish
General
P~RAMETER
.
ALUMINUM 750 87
ARSENIC 50 III 360 III 190 0.14-
BARIUM 50
B~cYLLIUM 11(a);1,100Cb) 0.117-
CADM IUM 0.8Ca);1.2Cb) eC1.128C1nH).3.828) e(0.78S2C1nH)-3.49) 10MCL
CHROMIUM 50
III eCO.819C1nH)+3.688) eCO.819C1nH)+1.S61) 3,433,000
VI 16 11 SO MCL
COPPER 30 eCO.9422C1nH)-1.464) eCO.854S(1nH)-1.46S) 10000
LEAD 30 eC1.273C1nH)-1.46) eC1.273C1nH)-4.70S) SO MCL
ANTIMONY 4308
ZINC 30 eCO.8473(1nH)+.8604) eCO.8473C1nH)+.7614) SOOOo
MANGANESE 30 MCL
MERCURY 0.2 2.4 0.012 0.1S3
NICKEl 100 eCO.846C1nH)+3.3612) eCO.846C1nH)+1.164S) 4584
SELEN IUM 25 20 S 10 MCL
SILVER 0.07 eC1.72C1nH)-6.52)d
CALCIUM
MAGNES!UM
IRON 1000 1000
SOO"'"
POT '14
TH.. 48
D!S~_~.'ED OXYGEN >5 mg/L
AMMONIA (NH3) 20 C C
ALKALI 14 I TY >20 mg/L
CHLORIDE CMG/L) 860 230
NITRATE 10000 MCL
SULF!DES
.-.--.-.....*-.--.-.....-........-.....-.---------.-.--.-.-.....
--FOOTNOTES...
J - EST!MATED VALUE
NA - NOT AN A~ALYTE
. - AT A 10'0 CANCER RIS~ LE~EL
H . HARDNESS IN mg/l as C3C03
o - BASED ON T':'S7E ':'1;;) :::~
I~I - TRIVALENT FCRM OF METAL
VI - HEXAVALENT FORM OF ~ETAL
~CL - CRITERIA SET ECUAL TO MAXIMUM CONTAMINANT LEVEL
a - FOR \.,'ATER Io'ITH A :~.\~!)NESS OF ~150 mg/L as CaCO)
b - FOR Io'ATER Io'ITH A H':'RDNESS Of >150 mg/L as CaCO)
: . FUNCTICN OF pH, TE~PERATURE
d - NOT TO BE EXCEEDED VALUE
Lowest Observed
LC50 ChY
160
5.3
13,000 1600
1400
57
-------
-34-
TABLE 5
EXPOSURE SCE~ARIOS
WETLAND AREA
~EDIL.:~
TRA.NSPORT
MECHANISM
EXPOSURE
POINT
ROUTE
EXPLA.'ATION
Ground Wacer
( shallow)
Ground Wacer
( :loridan)
Surface Wacer
Sedi:nencs
Surface Soils
~one
~one
None
Volatil-
ization
~one
Volatil-
izacion
None
Nearest
Receptor
(hypothetical
we 11 )
Nearest
Receptor
Marsh
Nearest
Receptor
Onsite
Nearest
Receptor
Nearest
Receptor
Ingestion
Inhalacion
Dermal
Ingestion
Inhalacion
Dermal
Ingestion
Dermal
Bioaccumulation
Inhalation
Dermal
Ingestion
Inhalation
Inhalation
Dermal
Ingestion
Meets EPA ~CLs , FLJER Sta~~a~~s~
addressed.
Meets EPA MCLs & FLDER S:~~:a~:s;
addressed.
Not feasible exposure scena~io; ..-
addressed.
Recreational activities; addresse
refer to Aquatic Life Toxicology
section of the Risk Assess:nent.
Inorganics are not volacile;
addressed.
Possible Scenario; addressee.
Possible scenario childreQ ~-6;
addressed.
Inorganics are not volacile; ~o:
addressed.
No samples; not addressed.
-------
-35-
children residing in or frequenting the area. Under current
site conditions, it was determined that a viable route of human
exposure to the contaminants of concern was through the
ingestion of beef from cattle foraging in the west marsh.
Other exposure pathways include dermal exposure to marsh
surface water or sediments and ingestion of marsh sediments.
However, the marshes have fluctuating water levels with the
highest level in the west marsh being unsupportive of
recreational swimming. Another factor reducing the potential
for human exposure in the west marsh is the dense vegetation
and limited area of open water. Access to the east marsh is
inhibited by the fence and tall dense vegetation. Potential
for human ingestion of fish is considered minimal since fish
were not observed during the September 1989 investigation.
Other potential exposure pathways were evaluated, such as
ingestion of surface water, inhalation of vapors from surface
waters or sediments. Since the indicator chemicals were
inorganic and hence nonvolatile, these pathways were determined
not to be viable exposure pathways.
5.5.2.2
Environmental Exposure Pathways in the Wetlands
Aquatic biota may be exposed via contaminated surface water and
sediments. The Wetlands Impact Study indicates that there is a
potential for flora and fauna to bioaccumulate the metals.
5.5.3
Summary of the Aquatic Toxicity Assessment:
East Marsh
The biosurvey indicated that the community of benthic
macro invertebrates associated with the canal and surrounding
wetland area are restricted in diversity.
Only the stations in the vegetated wetland surrounding the
canal showed some degree of toxicity associated with surface
water. In these marsh samples algal growth was significantly
reduced but not precluded.
No toxicity associated with the contaminated sediments was
detected in the representative population. However, toxicity
was observed associated with the sediment elutriate studies
performed on a variety of representative organisms.
5.5.4
Environmental Summary
The impact of contaminants on aquatic biota is characterized in
this evaluation since exposures associated with surface water
and sediments at SMC are a potential environmental risk. The
chemical of concern for the pond, ditches, and the marsh is
lead. Iron, zinc, mercury, and arsenic have also been
identified at elevated levels in the surface waters of the
marshes. Wetlands are potentially a habitat for a variety of
invertebrates, amphibians, reptiles, fish, and birds.
Endangered species have not been observed at the SMC site.
The flora is diverse and in the east marsh is dominated by
wetland species such as primrose willow, Carolina willow, and a
large stand of mild water-pepper. The west marsh has some
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willow shrubs; however, dominating vegetation is mild
water-pepper, giant bristlegrass, and cattail.
Lead has been found to bioaccumulate in a variety of aquatic
species. Lead has also been found to be more available for
bioaccumulation in low pH waters such as those that exist on
this site.
Excavation of the marsh sedLffient or engineered inundation of
the marsh sedLffient decreases the risk of heavy metal
bioaccumulation in the long-term. SedLffient entrainment by
surface water is the most likely mode of contaminant
distribution from the process area to the marsh. There is
little likelihood of significant contaminated sedLffient
transport beyond the confines of the marsh. Surface water
runoff is not expected to result in extensive transport of
sedLments.
5.5.6
Environmental Risk Conclusions
The Wetlands Impact Study concluded that the contaminated
sedLments are having a negative impact on the ecology of the
marsh. The study concludes that a biologically safe level of
lead in the sedLments would probably be in the range of 35 to
60 mg/kg. However, the report also states that trying to
. achieve this cleanup goal in the marsh might result in the
mobilization of lead, ultimately having a greater negative
environmental impact on the marsh. To attain this cleanup
level, all of the east and west marsh sediments would need to
be excavated. For the east marsh this would be overprotective,
considering that a resulting mitigation plan may not attain the
level of diversity presently existing at the east marsh.
The routes by which the SMC site impacts the wetlands is
through surface water transport and groundwater flow. Water
flows from the processing area where the battery components are
buried to the wetlands, providing a pathway for metal transport
into the wetlands. Remediation of soil contamination will
reduce the input of lead to the wetlands by removing the source
of lead.
Finally, the Wetland Impact Study recommended changing the east
wetland's hydroperiod from a semi-permanently flooded marsh
system to a permanently flooded marsh system. Under flooded
conditions the wetland sedLffients shall become anaerobic with
the overlying water column often having a reducing
environment. The sulfur bacteria in the sediments reduce
sulfate to sulfide which reacts with most heavy metals to form
a metallic sulfide. Anaerobic or reduced conditions in the
sediments will cause the metals to be sequestered and will
reduce the potential for migration of metals. No such
recommendation was given for the west marsh, since inundation
was not feasible.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an Lmminent and substantial
endangerment to public health, welfare, or the environment.
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6.0
DESCRIPTION OF ALTERNATIVES
The major objective of the feasibility study (FS) was to
evaluate possible actions which could remediate the site.
First, appropriate technologies were identified for the
containment, collection, and treatment of the contaminated
soils. Different methods for surface water and groundwater
treatment and handling of debris were also examined. These
technologies were initially screened based on site and
contaminant characteristics, then further screened based on
effectiveness, ~plementability, health risk, and cost.
Technologies which satisfied the screening requirements were
combined to form remedial action alternatives.
6.1
Soil, Pond, Ditch, and Groundwater Alternatives
The feasibility study described sixteen alternatives that would
be appropriate to remediate this site. However, the
alternatives included only five different methods of soil
remediation in .combination with various methods of the
collection and treatment of surface water and groundwater and
disposal of battery casing debris (separated from the soils).
The 16 feasibility study alternatives are combined and
presented as 5 alternatives in this ROD (Table 6).
. In this document, only the five soil remediation methods will
be considered as separate alternatives, since all appropriate
methods of groundwater and surface water collection and
treatment and debris handling can be used in conjunction with
each of these alternatives. Each of the five alternatives for
soil remediation and the options for debris handling are
described below. Surface and groundwater treatment methods are
examined in Section 6.1.6.
6 . 1 . 1
Alternative 1 - No Action
An evaluation of the no-action alternative is required to be
considered by the National Contingency Plan (NCP). It provides
a baseline for comparison of other alternatives. Under the
no-action alternative, no remedial actions would be undertaken
at the site at the present time. Long term groundwater
monitoring would be used to detect the potential occurence of
contaminant migration off-site. Existing wells would be used.
Total present worth cost is est~ated at $557,000.
6.1.2
~ternative
2 - Containment
The containment option has two components: a slurry wall and a
surface cap to contain the contaminated soil debris in the
source area. This alternative would minimize leaching and
horizontal migration of contaminants to the surficial aquifer
and eliminate the possibility of discharge to surface waters
either from groundwater or surface water runoff. The entire
process area would be surrounded by the low slurry wall in a
trench 3 feet wide by 25 feet deep. This wall would be
approximately 2,000 feet long. The RCRA-type cap would consist
of layering three (3) feet of compacted clay, a plastic liner,
geotextiles, geonet (for drainage) and top soil to support
vegetation.
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ROD
Alternative
1
2
3
4
5
-38-
Remedial Alternatives
Table 6
FS
Alternative
1
2, 3, 4, & 5
6 & 7
8, 9, 11, 12,
14 & 15
10, 13, & 16
Remedial Action
Alternative Description
No Action
Containment by surface cap and
slurry wall
Source removal;
soil and debris to offsite
landfill disposal; and,
backfill and regrade
excavated area
Source removal;
soil and debris separation;
chemical fixation of soil;
and, onsite replacement
variations:
pond backfilled
pond left intact
debris recycling
debris incineration
debris landfill
Source removal;
soil and debris separation;
and, heap leaching of soil
variations:
debris recycling
debris incineration
debris landfill
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Existing site buildings will be razed; this area will be
included with the process area to be capped. The approximate
area to be capped would be 200,000 square feet. The time to
implement this alternative is estimated to be three to six
months. Total present worth cost is estimated to range from
$3,143,000 to $5,442,000 for the RCRA cap.
Long-term operation and maintenance includes periodic mowing,
inspection for erosion, and some repairs to insure integrity of
the cover. Potential for future exposure from leachate would
be limited, but continued groundwater monitoring would be
required. Future development of the site will be limited.
Deed restrictions would restrict the site to non-residential
use.
6.1.3
Alternative 3 - Source Removal/Off-Site Disposal
This alternative consists of excavating the contaminated soil
and debris, loading it onto trucks and hauling it to an
approved RCRA Class I landfill. Upon excavation, trenches will
be constructed within the source area. After excavation, clean
backfill material will be placed in the excavated area and
regraded. This method would meet the cleanup criteria.
Excavation and disposal off-site would remove the potential for
future off-site migration of leachate by surface and
sub-surface routes. The excavation would cover an area of
approximately 170,000 sq ft, including the actual process
area. Confirmatory sampling beneath existing concrete pads
will be performed.
It is estimated that depths of excavation for soils and debris
will range from 3 to 8 feet below ground surface. Excavation
will take place until soils with lead concentrations below the
cleanup criteria are reached. Confirmatory sampling will
ensure that soils contaminated above the cleanup goal are
removed and treated. Based on information gathered during the
field investigations, it is anticipated that approximately
54,500 cubic yards of material will require excavation. The
excavated areas will be backfilled with clean fill. Excavated
soils and debris will be transported to a RCRA Subtitle C -
permitted landfill in Pinewood, South Carolina for disposal.
Excavation below the water-table will require the construction
of three dewatering trenches. The trenches will be excavated
100 ft apart, range from 290 to 510 feet in length and be
approximately 12 feet deep. At the surface the trenches will
measure 12 feet and narrow to 5 feet near the base.
The excavation and transportation of the hazardous material are
expected to each require three (3) months to implement. Time
required for disposal at a Subtitle C - approved landfill
depends'on the facility. Long-term operations and maintenance.
are mowing and a monitoring program. Total present worth cost
is estimated to range from $16,425,000 to $18,500,000. This
range depends on the groundwater treatment method.
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6.1.4
Alternative 4: Source Removal/On-Site Treatment of
Soils (Fixation)
This alternative consists of excavation of contaminated soils
and debris, separation of debris from soils, chemical fixation
of soils and treated soil replacement. A treatability study
for the chemical fixation process has been conducted. The
results from the study have been used to selected a fixant
combination that, when mixed with the contaminated soils, will
Lmmobilize the contaminants and minimize the threat of future
leaching into the groundwater. Thus, the source of groundwater
contamination will be removed.
As in Alternative 3, it is anticipated that 54,500 cubic yards
of material will require excavation. It is estimated that this
will consist of 18,500 cubic yards of battery casings and
36,000 cubic yards of soils. As in the above alternative, the
soil would require hazardous characteristic testing. The
debris will be separated from the soils by screening and
handled by one of the three options as described below:
A.
Off-site Landfill
In this method of debris disposal the material is
transported and disposed in a RCRA Subtitle C - approved
landfill. The time estimated for implementation is 3
months. The total present worth cost for this alternative
with landfill disposal of debris ranges from $8,469,000 to
$10,766,000.
B.
On-site Incineration
Rotary kiln incineration would be used to treat the
excavated debris. The standard incineration process using
a rotary kiln will yield some ash which will require
hazardous characteristic testing prior to being disposed at
an appropriate facility. This is estimated to require
three months for debris incineration. The total present
worth cost for this alternative with debris incineration
ranges from $6,768,000 to $9,064,000.
Off-Site Recycling
c.
A third alternative method of handling the debris screened
from the soil is recycling. The debris is reduced to
approximately one-half inch diameter chips and washed
before transport to an EPA-approved recycling firm. The
screening process and the grinding and washing each will
take approximately 3 months.
Soils will be stored on a temporary storage pad.
Construction of this pad shall entail placing a clay layer
over a plastic membrane large enough to store 1,000 cubic
yards of soil at a depth of 5 feet. At the pad, the soils
will be combined with the fixant(s). After mixing on-site,
the mass will be tested for compressive strength,
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homogeneity, and Toxic Characteristics (TC) to assure
performance criteria and RCRA requirements have been met.
The fixed material will then be replaced in the excavated
areas; any remaining empty volume will be backfilled with
clean fill.
Estimated time for implementation is 3 months each for
excavation and screening. Chemical fixation requires
approximately 100 days. Long term operation and
maintenance will require mowing, site maintenance, and a
monitoring program. The total present worth cost for
Alternative 4 and debris recycling is estimated to range
from $5,864,000 to $8,161,000.
6.1.5
Alternative 5: Source Removal/On-Site Treatment of
Soils (Heap Leaching)/Off-Site Lead Recovery
This alternative consists of excavating the contaminated soils
and debris, screening the debris from the soils, heap leaching
of the soils (soil washing), site restoration, and smelter
recovery of lead from the leach lead cake.
Source material will be excavated and debris will be screened
and remediated, as described in Alternative 4.
Heap leaching, or soils washing, will be performed on the soils
as they are excavated. A temporary storage pad will hold this
soil, approximately 9,000 cubic yards, for treatment. Spray
equipment will distribute a heap leach solvent over the 10 ft
high pile. This metal-extracting solvent will then be
collected after percolating through the soil pile in a storage
pad drain.
The lead will be extracted (approximately 95% recovery) from
the solvent, thickened, dried, and sent to a smelter. The
collected solvent will be recycled until spent. Sampling of
soils will determine the final treatment pass and will meet the
standards approved by the EPA and FDER.
A non-hazardous solvent will be added to the soils to destroy
the heap leaching solvent. Verification sampling of this soil
will be done to insure clean-up criteria is met. On-site
backfilling and regrading will proceed with additional fill if
necessary.
A pilot study will be required to provide data on the
feasibility of heap leaching these soils.
As estimated for the previous alternatives, the time for
implementation is approximately 3 months for excavation,
screening, and disposal. Heap leaching will require 12 to 18
months. Operation and maintenance after remediation will be
similar to any of the other alternatives involving backfilling, .
regrading, and revegetating, i.e. a mowing and monitoring
program. The pilot study time would require a few months.
Once segregated from the soils, the battery casing debris will
be handled by one of the three methods described for
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~ternative 4. The estimated total present worth cost for heap
leaching of soils combined with landfilling the debris ranges
from $9,334,000 to $11,230,000, with incinerating the debris
ranges from $7,633,000 to $9,064,000, and with recycling the
debris ranges from $6,729,000 to $8,625,000.
6.1.6
Surface Water and Groundwater Remediation
Both surface water and groundwater quality at the SHC site have
been affected by past disposal practices. Lead concentrations
in the holding pond were found to be as high as 1,300 mg/L.
Generally, lead concentration in the groundwater is below 0.040
mg/L, e~cept Lmmediately northeast of the holding pond where it
ranges between 0.13 and 0.17 mg/L. Remediation of the
groundwater shall include recovery of groundwater from the
effected areas and subsequent treatment.
Groundwater treatment will address lead and chromium
contamination. The volume of contaminated groundwater cannot
be precisely calculated due to fluctuations from stormwater
percolation, soil porosity, and the topography of the surficial
confining unit. However, the estimated volume of contaminated
groundwater is approximately 17 million gallons.
6.1.6.1
Surface Water and Groundwater Recovery
Due to the relatively thin (10 feet in mid-1987) saturated
thickness of the surficial aquifer, use of wells for
groundwater recovery is not an efficient method for recovering
contaminated groundwater. Rather, the existing holding pond,
supplemented with an infiltration trench excavated in the most
contaminated part of the surficial aquifer, will allow recovery
of the affected ground water.
6.1.6.1.1
Holding Pond and Infiltration Trench
The holding pond is excavated into the surficial aquifer and
thus is hydraulically connected with it. Multiple rounds of
water level measurements indicate that groundwater flows
radially, away from the pond due to local groundwater
mounding. During the early stages of groundwater remediation,
the holding pond will be emptied by pumping pond water to the
treatment system described below and ultimately to one of the
followings the Plant City publicly owned treatment works
(POTW); recirculated to on-site wetlands; or to the aquifer to
promote flushing. The permitting requirements will be met for
any of these discharge options. Lowering the level of the pond
water is expected to cause reversal of the groundwater
gradient, inducing groundwater to flow to the pond. The
emptied pond will be backfilled with clean sand and capped with
low permeability material. A large diameter well will be
installed in the north central part of the backfilled pond to
permit continued recovery and treatment of the affected
groundwater.
An infiltration trench trending in a northeasterly direction
will be excavated near the northeastern corner of the holding'
pond. The length will be approximately 320 feet and will be
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excavated to the confining unit, a depth of approximately 15
feet. A perforated collection pipe will be installed at the
base of the trench prior to backfilling the trench with sand.
It is estimated a static flow rate of 50 gallons per minute
(gpm) is planned for the pond water and groundwater system.
The trench will 'be pumped at an approximate static rate of 20
to 25 gpm to a 10,000 gallon storage tank. With both units
operating the flow rate is estimated to be 75 gpm.
6.1.6.2
Surface Water and Groundwater Treatment
During development of the remedial alternatives for the SMC
site three processes were considered for treatment of the
recovered surface water and groundwater. The water produced
during soil excavation prior to remediation will be treated by
one of the processes described below.
The first alternative includes chemical precipitation of metals
followed by ion' filtration. ~he second alternative involves
electrochemical precipitation followed by clarification and
multimedia filtration. The third groundwater treatment process
evaluated was electrochemical precipitation followed by
microfiltration.
Each treatment unit will be sized for a flow rate from the
holding tank of 75 gpm. The influent lead concentration for
design purposes was established as 1.5 mg/L. The treatment
methods proposed are capable of treating the waste to meet the
state of Florida Drinking Water Standards (DWS). Treatability
studies will be required to determine the efficiency of the
proposed treatment technologies.
It is reasonable to assume a construction and start-up time of
six months for each of the methods. The treatment plant can
easily be located on-site.
6.1.6.2.1
Ion Filtration
Groundwater recovered from the converted pond, infiltration
trenches and the dewatering trenches will be pumped to a 10,000
gallon storage tank where chemicals will be added to prolong
filtration cycles and prevent binding of the filter cloth on
the filter press. In addition, caustic soda and agents to
promote floc formation will be added to promote the formation
of a lead hydroxide precipitate and co-precipitate the lead.
The specific agents to be used will be determined following
treatability testing. Following precipitation and flocculation
of metals, the process will remove suspended solids by sand
filtration prior to removal of the remaining solubilized lead
and sulfates by ion filtration. Solids generated during the
filtration process will be fixed in the same manner site soils,
shall be.
The ion filtration process is based on passing metal-
contaminated water through a medium that selectively binds,
cations. The medium removes metal ions and tends to
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neutralize the treated water. Ion filtration does not produce
sludges; however, after the filtration media become saturated
and incapable of collecting additional metals, the spent media
must be disposed. The medium will have to be landfilled in a
RCRA Class I landfill or chemically fixed and landfilled.
Bench and pilot scale testing will be necessary for this and
the other technologies discussed below. This testing will
determine treatability, size, loading, and other design
parameters. This method will achieve the cleanup goals for the
lead contaminating the groundwater by treating it to levels
which meet the disposal requirements. This treatment system is
anticipated to meet a "best available technology economically
feasible" criteria. Construction of this system will be
sLmpler than the two other technologies described. Once flow
rate is established, filtration is continuous. Operation and
maintenance (0 & M) involves checking flow rates, mechanical
conditions and pressures in addition to sampling the influen~
and effluent. 0 & M will be relatively simple, requiring onl~
two hours a day for oversight.
6.1.6.2.2
Electrochemical Precipitation and Clarification
Water from the 10,000 gallon storage tank is adjusted to
between 8.0 and 8.5 pH units prior to pumping into an
electrochemical cell where lead and iron hydroxide
co-precipitate. From the electrochemical cell,
precipitate-bearing water is transferred to a clarifier for
separation of the precipitate. Coagulants are added in the
clarifier to promote sludge formation. The sludge formed is
dewatered and transported to an approved RCRA Class I
landfill. Additional multimedia filtration is required to
remove the precipitate which did not settle out during
clarification.
Monitoring will be done frequently during the initial start-up
and less frequently after four months. In addition to water
samples, the sludge will be tested for TCLP extraction of lead
as well as total lead. This will determine its status as a
hazardous material and whether enough lead is present to be
recovered economically in the smelter. Operation and
maintenance for this option would require four man-hours a day
and would include routine monitoring of the system (daily),
sludge removal from the filter press (weekly) and sampling
(bi-weekly) .
6.1.6.2.3
Microfiltration/Electrochemical precipitation
As with electrochemical precipitation and clarification, this
process requires pH adjustment and electrochemical
precipitation. After precipitation, the process differs in
that the water is routed to a recirculation/equalization tank
where a coagulant is added. Water then is routed to
microfiltration vessels for solids removal prior to routing th,
water for final disposal either off-site or onsite.
Clarification is not required in this process, since floc size
need only be large enough to be screened ~ut. Sludge
production will be approximately 1 - 2 ft /d. Sampling
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would be done as described in the process described for
electrochemical precipitation and clarification.
Pumping and treatment may require from six to nine months for
construction and implementation; however, before the desired
results are observed, it is expected that a minimum of five
years of continued 0 & M is necessary. Long term operation and
maintenance will require culvert cleaning, and pump and piping
replacement.
Discharge of treated water to the Plant City POTW is the
preferred disposal option and will likely be allowable
following POTW review of SMC's treatment verification and water
volumes. However, if all water cannot be routed to the POTW,
other options, including discharge under a National Pollution
Discharge Elimination System (NPDES) permit and re-injection
will be pursued. The NPDES permit would set specific
contaminant discharge limits for the discharged waters. The
decision will depend on the degree of groundwater treatment.
Any change from the selected option will require public
notification, pursuant to Section 117 of SARA.
6.2
Wetland Alternatives
, The wetland alternatives were evaluated in the Addendum to the
Feasibility Study. A detailed analysis of appropriate
technologies were screened for their use at the SMC site and
four alternatives were identified. The alternatives are
described below.
6.2.1
No Action Alternative
CERCLA S300.430 (e)(6) requires that the no action alternative
be considered at every site. Under the no action alternative,
EPA would take no further action in the wetlands to control or
remediate contamination therein. The no action alternative
implies leaving the site in its present condition without
disturbing contaminated sediments. However, physical,
chemical, and biological monitoring would be performed over a
period of 30 years in this alternative. A public health
assessment would be performed every five years to evaluate
potential changes in risk associated with no action.
Potential health risks would remain associated with current
conditions. This alternative exceeds EPA's acceptable target
risk range and does not attain ARARs.
The estimated present worth cost of this alternative is
$608,000.
6.2.2
Mechanical Controls Alternative
The mechanical controls alternative consists of placing
barriers to restrict access to contaminated soils and sediments
within the wetlands. The western and eastern marsh areas would
be approached differently due to different environmental and
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human receptor exposure potentials. The western marsh
mechanical control would consist of the construction of a fence
to restrict cattle access to the marsh area from adjacent
pasture. The FS Addendum for the wetlands did not consider
fencing for the eastern marsh because access by cattle is
already l~ited by site conditions and its location.
The mechanical controls in the eastern marsh include placement
of a flood control mechanism at the outlet of the eastern marsh
to ensure inundation. This is not considered for the western
marsh because of its isolation and lack of surface water flow
into it. The alternative, as it applies to each marsh, is
described below in the following sections.
There is a possibility that, by leaving contaminated sediments
in the marsh, the AWQC for surface water may be exceeded. The'
conclusion of the Wetland Impact Study stated that if the marsh
was permanently flooded, the hazardous metals in the sediments
would remain under anaerobic conditions and would be chemically
bound and sequestered in the sediments. This would greatly
decrease the potential for metal transport from the sediments
to the surface water. In order to select this alternative a
waiver of the AWQC is required. The waiver is justified by the
potential negative environmental impact that could be created
. by trying to excavate the contaminated marsh sediments, which
involves complete destruction of the wetland and potential
mobilization of lead beyond the site area (CERCLA
121(d)(4)(B». This waiver will not apply to the treated
waters discharged to the marsh surface waters. EPA did not
identify this waiver in the Proposed Plan; however, this waiver
does not significantly alter the scope, performance, or cost of
the remedy.
Federal Executive Order 11990, Protection of Wetlands, requires
federal agencies in carrying out their responsibilities to take
action to minimize the destruction, loss, or degradation of
wetlands, and to preserve and enhance the natural and
beneficial values of wetlands.
Section 404(b)(1) of the Clean Water Act also requires that
practicable steps must be taken to minimize adverse impacts to
wetlands from fill. In the case of this alternative, the
contaminated sediments remaining in the marsh will continue to
impair the biological productivity and diversity of the wetland
ecosystem. To minimize the effects of this impact, mitigation
is required to created new areas of wetlands that will replace
the functions lost in the onsite wetland. A specific
mitigation plan will be developed as part of the Remedial
Design and in accordance with the EPA regional mitigation
guidelines.
6.2.2.1
West Marsh
This alternative would involve installation of a fence to
enlarge the existing fenced area surrounding the SHC site.
fence would consist of approximately 400 feet of a 3-strand
The
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barbed wire fence, four feet in height, between the cow pasture
and the western marsh. This should deter passage of humans and
cattle.
potential health risks by ingestion of marsh sedLments and
surface water would remain, since access is not completely or
permanently prevented. Wildlife use of the marsh will not be
entirely inhibited. This alternative may exceed the surface
water ARARs; however, this may be temporary.
O&M would consist of fence repair, and monitoring of water and
sediment quality and biological systems. The total estLmated
present worth cost for the west marsh mechanical control
alternative is $214,000.
6.2.2.2
East Marsh
This alternative would involve utilizing a flood control
measure at the outlet of the eastern marsh. The flood control
would consist of a fixed weir and associated supporting berm
constructed at the outlet of the eastern wetland. Height of
the weir would be determined during design; however, for cost
calculation purposes the FS Addendum estLmated an elevation of
approximately 115 feet based on the topography of the eastern
wetland.
In addition, the present onsite perimeter ditch will be
diverted to the eastern wetland to increase the supply of
surface water input and ensure inundation. Diversion will
depend upon the concentrations of contaminants in the ditch, as
well as onsite soil and groundwater remediation activities.
A hydrologic study shall be performed prior to design of the
weir which will ensure the effectiveness of controls in
achieving continual surface water inundation over the east
marsh.
The monitoring program for this alternative would follow the
same procedure as that proposed for the no action alternative.
However, emphasis would be placed on hydraulic monitoring to
assess whether the model correctly estLmated water elevations.
In addition, plant community monitoring is required to assess
any changes in community restructuring.
Need for restoration of approximately one acre of wetlands in
the east marsh is expected due to potential Lmpacts from
construction activities.
The total estimated present worth costs, including O&M, for the
east marsh mechanical control alternative is $674,000.
6.2.3
Low Permeability Cover and Solidification Alternative
This alternative was evaluated for both wetlands on the SMC
site in the FS Addendum. The low permeability (clay) cover
requires placement of clay and topsoil over solidified
contaminated sediments. It is estimated that the upper four
feet of marsh sediments would have to be solidified in order to
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achieve cap stability. However, the actual depth must be
determined during the remedial design, and is based on
contamination depth and composition of sediment. Following
preparation of the subgrade, a one-foot clay liner, a one-foot
drainage layer, and six inches of topsoil would be placed in
both marshes. If necessary, drainage diversion features, such
as cover grading and culvert modification would be constructed
to promote runoff of surface water.
Operation, maintenance, and monitoring of the cover system
would be performed for a period of 30 years.
Section 404(b)(1) of the Clean Water Act also requires that
practicable steps must be taken to minimize adverse impacts to
wetlands from fill. To achieve no net loss of wetlands, and to
minimize the adverse effects of filling at the site, mitigation
is required. This involves replacing lost wetlands at the site
by creating or restoring a wetland area. A site specific
mitigation plan will be developed as part of the Remedial
Design and in accordance with the EPA regional mitigation
guidelines.
6.2.3.1
West Marsh
Solidification of approximately 10,200 cubic yards (cy) of
sediment would be required in the west marsh. Cap construction
is estimated to cover the entire marsh, also estimated at 7,085
square yards (sq yd).
The total present worth cost for this alternative in the west
marsh is estimated to be $978,000, including a 2:1 ratio
wetland mitigation of $110,000 and operation and maintenance
for cover and mitigated wetlands of $40,400.
6.2.3.2
East Marsh
Solidification of approximately 31,000 cy of sediment/soil
would be required in the east marsh. Cap construction is
estimated to cover an area of 29,350 sq yd, which is the
approximate area of the entire marsh.
The total present worth cost for this alternative in the east
marsh is estimated to be $3,255,000, including a 2:1 ratio
wetland mitigation of $275,000 and operation and maintenance
for cover and mitigated wetlands of $181,600.
6.2.4
Sediment Removal Alternative
This remedial alternative consists of excavation of sediments
and soils exceeding specific lead concentrations. The FS
Addendum evaluates this alternative for a variety of lead
concentrations and assumes a depth of two feet is adequate to
remove the contaminated sediments. A range of lead
concentrations were used to determine relative cost. However,
soil cleanup criteria is the overriding factor of soil depth
removal. The soil and sediment would require hazardous
characteristic testing to determine whether the soil would be
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considered hazardous under the Land Disposal Restrictions.
Removed sediments will be solidified and disposed onsite or
offsite at a RCRA landfill. Regrading the site to original
contours, such as restoring historical wetland features, or
backfilling the excavated wetland will be performed following
wetland excavation. Treatability or bench-scale studies are
necessary to determine the most appropriate mixture for the SMC
site.
An extensive chemical, physical, and biological monitoring
program similar to that described in the no action alternative
would be performed biannually for 5 years. The creation,
maintenance, and monitoring period of the wetland would be for
thirty years.
There is a possibility that in selection of a safe clean-up
goal for contaminated sediments in the marshes, the AWQC for
surface water may be exceeded by any remaining contaminated
sediment. In order to select this alternative a waiver of the
AWQC is required. The waiver is justified by the potential
negative environmental impact that could be created by trying
to excavate the remainder of the contaminated sediments, which
involves complete destruction of the wetland and potential
mobilization of lead beyond the site area (CERCLA
121 ( d) ( 4 ) ( B) ) .
Federal Executive Order 11990, Protection of Wetlands, requires
federal agencies in carrying out their responsibilities to take
action to minimize the destruction, loss, or degradation of
wetlands, and to preserve and enhance the natural and
beneficial values of wetlands.
Section 404(b)(1) of the Clean Water Act also requires that
practicable steps must be taken to minimize adverse impacts to
wetlands from fill. One type of minimization is compensatory
mitigation to achieve no net loss of wetlands, and to minimize
the adverse effects of this impact. This type of mitigation
involves replacing wetlands lost at at the site by creating or
restoring a new wetland area. In the event contaminated
sediments remain in the marsh, they will continue to impair the
biological productivity and diversity of the wetland
ecosystem. Mitigation is required to create new areas of
wetlands that will replace the functions lost in the onsite
wetland. A site specific mitigation plan will be developed as
part of the Remedial Design and in accordance with the EPA
regional mitigation guidelines.
6.2.4.1
West Marsh
Transport and disposal is estimated for 4,700 cy of material in
the west marsh. The same amount of fill is estimated in the
event that the wetland would be backfilled during restoration
of the entire site to historical topography and contaminated
material will be disposed offsite. Backfill is estimated to be
9,900 cy for onsite disposal of contaminated material
(non-wetland area).
Cost evaluations for this alternative are performed on the
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assumption that the entire marsh will be excavated. Total
present worth cost, including operation and maintenance, for
this alternative in the west marsh is estimated to be
$2,664,000 for offsite disposal and restoration of entire site
to historical topography; $2,572,000 for offsite disposal and
restoration of present wetland; and $545,000 for onsite
disposal and restoration of present wetland.
6.2.4.2
East Marsh
This alternative for the east marsh evaluates removal of the
marsh sedLment exceeding lead concentrations of 110 mg/kg and
350 mg/kg. Removal of sediments exceeding the lower
concentration would be equivalent to removing sediments within
the entire wetland to a depth of two feet. Removal of
sediments exceeding the 350 mg/kg lead concentration would
limit removal to a portion of the marsh.
East marsh sediments exceeding 110 mg/kg are estimated at
15,600 cy. Sediments will be excavated and solidified and
require the same amount of backfill. Sediments exceeding 350
mg/kg are estimated to total 8,400 cy. Sediments will be
excavated and solidified and require the same amount of fill.
Total present worth cost, including operation and maintenance,
for this alternative in the east marsh is estimated to be
$8,411,000 for excavation of sediments exceeding 110 mg/kg
lead, offsite disposal and entire site restoration; $4,828,000
for excavation of sediments exceeding 350 mg/kg, offsite
disposal and entire site restoration; $5,452,000 for excavation
of sediments exceeding 110 mg/kg lead, offsite disposal and
east marsh restoration; $4,676,000 for excavation of sediments
exceeding 350 mg/kg lead, offsite disposal and east marsh
restoration; $1,641,000 for excavation of sediments exceeding
110 mg/kg lead, onsite disposal and east marsh restoration; and
$1,047,000 for excavation of sediments exceeding 350 mg/kg
lead, onsite disposal and east marsh restoration.
7.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
All alternatives were evaluated based on the following nine
criteria.
Threshold Criteria which each alternative must meet criteria
to be eligible for selection:
1. Overall protection of human health & the environment;
and,
2. Compliance with all federal & state applicable or
relevant appropriate requirements (ARARS).
Primary Balancing Criteria which evaluate tradeoffs among
threshold criteria based on the following criteria:
3. Long term effectiveness and permanence;
4. Short term effectiveness;
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5. Reduction of toxicity, mobility or volume through
treatment;
6. Implementability; and,
7. Cost.
Modifying Criteria will also be considered:
8. State acceptance; and
9. Community acceptance.
A summary of the relative performance of the alternatives in
the FS and the FS Addendum with respect to each of the nine
criteria is provided in this section.
7.1
Overall Protection of Human Health and the Environment
Overall protection of human health and the environment
addresses whether or not a remedy provides adequate protection
and describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls.
7.1.1
Soils, Pond, Ditches, and Groundwater Alternatives
Alternative 1 does not provide protection to human health or
the environment so it will not be addressed further in the
selection of alternatives.
All of the remaining alternatives, including containment,
disposal or treatment of contaminated soils would prevent
further surface or groundwater contamination; existing
contamination of surface water and groundwater would be removed
through treatment. Thus, each of these alternatives would be
protective of human health via the water ingestion pathway.
Alternative 2 would provide adequate protection of human health
due to ingestion and inhalation of the contaminants in the soil
(through use of contaminant containment). A reduction in
mobility of contaminants is provided through containment.
There is the potential for continued migration of contaminated
groundwater; however, institutional controls within this
alternatives provide protection against risk from contaminated
groundwater ingestion. Dermal contact during remediation
should be prevented by appropriate safety measures.
Potential for off-site exposure to site-related contaminants
would diminish with isolation of the source by reducing the
mobility of contaminants. By minimizing contaminant migration
in the surficial aquifer and eliminating the possibility of
discharge to surface waters from surface run-off, this
alternative provides a moderate level of protection to the
environment.
Alternatives 3 through 5, which involve treatment, would be
effective in preventing adverse health effects due to ingestion
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and inhalation of the contaminants in the soil. The potential
for on-site exposure to contaminated soil and off-site exposure
through migration of possible leachate would be diminished
during remediation. Alternative 3 presents a potential for
local exposure through inhalation of dusts, and distant
exposure from truck releases and accidents during
transportation. Substantial impacts would not be expected if
appropriate management practices are implemented.
Implementation of alternatives 4 and 5 has the potential for
exposure due to inhalation of dusts. However, this can be
effectively controlled by standard dust suppression techniques.
In addition to eliminating potential exposure to soils,
alternatives 3 through 5 provide an adequate level of current
and future protection to the environment by limiting
contaminant migration off-site. Alternative 3, excavation and
disposal, would reduce the potential for future off-site
migration of leachate through surface and subsurface routes
from onsite sources; however, potential exposure at the offsite
disposal area would exist. .
Alternative 4 (chemical fixation) would isolate the waste and
minimize future leaching into the environment. Alternative 5
(heap leaching) would minimize the potential for off-site
migration of leachate through surface and subsurface routes.
7.1.2
Wetland Alternatives
Because the no action alternative offers no reduction in risk
to human health and the environment, it is not considered
further in this analysis.
The mechanical control alternative for the west marsh would not
provide complete protection to a human exposure route via soil
ingestion, dermal contact or beef cattle grazing in wetland;
however, reduction would occur immediately. Environmental
exposure is not protected, since the fence is not an adequate
barrier to utilization by wildlife. However, the functional
value of the wetland is maintained with this alternative.
'Mechanical control of east marsh through inundation provides a
reducing environment which limits the bioavailability of lead
to the plant and animal community, decreasing the potential for
environmental exposure. However, the extended period of
wetland inundation would promote increased burial of the
vegetation and increased peat accumulation. It is believed that
gradual protection of human health and the environment will
occur through the natural treatment process within the
ecosystem. A reduction in mobility of contaminants through
flooding controls provides some protection to human health and
the environment, by sequestering the lead in the sediments.
The potential for human exposure to lead due to swimming in
ditc~es and ingesting water and sediments exists; however, this,
potential is minimal due to the limited access to the the east
marsh. This alternative also decreases the potential to
introduce new environmental risks associated with any
disturbance of sediments and release of lead to the
environment. Excavation of sediments prior to flooding the
east marsh would potentially release lead to the environment.
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The capping alternative reduces direct contact risk and soil
ingestion risk; however, continued migration of contaminated
groundwater exists. Capping is considered protective of human
health and the environment through reduction in mobility of
contaminants. Off-site exposure to site-related contaminants
would diminish with isolation of the source by reducing the
mobility of contaminants and the potential of future exposure
to leachate. By minimizing water infiltration through
contaminated soils and eliminating the possibility of marsh
water discharge to surface waters through surface run-off,
capping provides a moderate level of protection to the
environment. Dermal contact during remediation should be
prevented by appropriate safety measures.
The sediment removal and solidification alternative would
provide protection of human health and the environment by
reducing or controlling risk through treatment. The cleanup
goal established would effect the degree of protection to human
and environmental risk. However, such construction within the
wetland would damage the wetland and restoration of its
functional value is not guaranteed.
7.2
Compliance with ARARS
Compliance with ARARs addresses whether or not a remedy will
meet all of the applicable or relevant and appropriate
requirements of other environmental statutes and/or provide
grounds for invoking a waiver.
The primary ARARs for the groundwater are the Florida Water
Quality Standards for groundwater, EPA Maximum Contaminant
Levels (MCL) and the proposed MCL goal (pMCLG), and EPA Ambient
Water Quality Criteria (AWQC) for protection of human health
(Table 7).
Also considered as ARARs for groundwater are the RCRA Subpart F
groundwater protection standards. These use background MCLs or
Alternate Concentration Limits (ACLS) as the cleanup level.
The criteria for choosing between background MCLs and ACLs are
detailed in the 40 CFR Part 264.94. Florida Water Quality
Standards for groundwater, MCLs, and proposed MCLG are also
ARARs for the surficial aquifer at this site.
Primary surface water ARARs (Table 8) for this site are the
AWQC to protect aquatic life from chronic toxicity and human
consumption of toxic fish and shellfish and the Florida Class
II Surface Water Standards. The primary surface water ARAR for
this site was calculated using the site's water hardness and
the AWQC.
Additional ARARs, which are related to discharge options, would
need to be met if either of the alternatives for groundwater
treatment were chosen. These ARARs include the Clean Water
Act, which COVE' .S discharges to surface water bodies, and POTW
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Table 7
APPLICABLE AND RELEVANT AND APPROPRIATE REQUIREMENTS
SCHUYLKILL METALS CORPORATION, PLANT CITY, FLORIDA
GROUNDWATER
(mg/L)
Indicator Chemical
Florida
Water Quality Standards
EPA
MCL
EPA
Proposed
Action
Leve1*
EPA WQC for
Protection of Human
Health: Threshold
Toxicity Protection
(ingestion of
drinking water only)
Lead .05 .05 .015
Chromium (+3) 179
(+6) .05 .05 I
VI
(total) .05 ~
I
Antimony .146
Sodium 160
MCL:
MCLG:
WQC :
* EPA
Maximum contaminant Level
Maximum Contaminant Level Goal
Water Quality Criteria
Office of Drinking Water and Headquarters
Guidance
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Table 8
APPLICABLE AND RELEVANT AND APPROPRIATE REQUIREMENTS
SCHUYLKILL METALS CORPORATION, PLANT CITY, FLORIDA
SURFACE WATER
Florida Water Quality Standards
for Class III Surface Water
EPA WQC for Protection of Aquatic
Life for Freshwater Chronic
Criteria (adjusted for water
hardness)
EPA WQC For Protection
Health
(ingestion of aquatic
organisms only)
of Human
Lead
Antimony
.03
.013
45
AIR
I
\..11
\..11
I
Lead Concentration
National Ambient Air Quality Standard
(NAAQS)
1.5 ug/m3
Federal Occupational Safety and Health
Administration Act (OSHA)
50 ug/m3
MCL:
MCLG:
WQC:
POTW:
Maximum contaminant Level
Maximum Contaminant Level Goal
Water Quality Criteria
Publicly Owned Treatment Works
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pretreatment requirements, which cover contaminant levels being
discharged to a POTW. The relevant ARARs will be met by the
discharge option chosen.
The appropriate ARARs for lead are based on the more stringent
protection levels. For groundwater and surface water these are
the proposed MCL and the AWQC for the protection of aquatic
life from chronic toxicity effects, respectively.
The Clean Air Act (CAA) identifies and regulates pollutants
that could be released during the remedial activities. The CAA
Section 109 outlines the criteria pollutants for which National
Ambient Air Quality Standards (NAAQS) have been established.
CAA Section 112 identifies pollutants for which there are no
applicable NAAQS. These substances are regulated under the
Federal National Emission Standards for Hazardous Pollutants.
As an ARAR these standards will be complied with during any
excavation activity.
The Federal
(OSHA) will
necessary.
Table 8.
Occupational Safety and Health Administration Act
be complied with when any applicable activity is
NAAQS and OSHA ARARs for lead in air are listed in
EPA has determined that RCRA requirements for closure of the
surface impoundment are relevant and appropriate for this site.
Alternatives 2 through 6 will incorporate RCRA closure of the
surface impoundment in the remedial design.
The primary ARARs for the soil are the RCRA Subtitle C closure
requirements, state requirements, and the treatability variance
for soil and debris proposed by 40 CFR 268 Land Disposal
Restrictions (LDRs). The criteria for choosing between these
standards is specific for each site. Cleanup standards for
soils consider the potential for leachate formation under
environmental conditions which might cause the concentration of
dissolved contaminants in groundwater to exceed 0.015 mg/L, the
Proposed Action Level from the Office of Drinking Water and EPA
Headquarters Guidance (June, 1990). These target soil
concentrations are listed in Table 9.
The RCRA LDRs promulgated in the 1984 Hazardous and Solid Waste
Amendments (HSWA) require that RCRA hazardous wastes be treated
to BDAT (Best Demonstrated Available Technologies) Standards
prior to placement into the land. EPA has promulgated
treatment standards for hazardous wastes in a phased approach
and promulgated the Toxicity Characteristic (TC) Rule on March
29, 1990. The on-site wastes exhibit EP Toxicity as defined in
40 CFR 261; however, they will now have to be tested using the
TC Leaching Procedure (TCLP) to determine if they would be
characterized as a hazardous waste.
Excavation and treatment in a separate unit is considered to be"
placement under RCRA LDR. Therefore, LDR will be an applicable
or relevant and appropriate requirement. However, the
treatment process will immobilize the metals to the extent that
the waste will no longer be hazardous waste as defined by RCRA.
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Table 9
CLEANUP GOALS
SCHUYLKILL METALS CORPORATION, PLANT CITY, FLORIDA
SOIL
EP Toxicity *
Regulatory Level
Toxic Characteristic
Regulatory Level
Target Concentration
mg/L
mg/L
mg/kg
Lead
Cadmium
*
5
1.0
5.0
1.0
.
.
Definition of hazardous waste (40 CFR Part 261.24(b))
500
I
\J1
--.J
I
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The following are the RCRA ARARs which may apply to this site
under 40 C.F.R. Part 264:
Subpart
"
F Groundwater Protection;
G Closure and Post-Closure;
I Containers;
J Tanks;
K Surface Impoundments;
L Waste Piles;
M Land Treatment;
N Landfills; and,
X Miscellaneous Units.
"
"
"
"
..
"
"
7.2.1
Soil, Pond, Ditch, and Groundwater Alternatives
Alternatives 2 and 3 meet the ARARs by containing or removing
the contaminated soil which has been found to exceed the
ARARs. Containment, Alternative 2, would comply with LDRs when
the soils meet testing goals such as the TCLP. Alternative 3
would need to comply with CERCLA S121 (d)(3) and 40 CFR 268
(Subpart D) regarding off-site disposal of hazardous waste
thereby achieving the cleanup levels. Alternatives 4 and 5
would treat the soil on-site, and are designed to satisfy
ARARs .
Alternatives 2, 3, 47 and 5 meet the federal ARARs and State
environmental laws. Groundwater treatment and monitoring will
assure compliance with all cleanup goals.
7.2.2
Wetland Alternatives
The Alternatives as they are described in the Wetland FS
Addendum may not meet the the ARARs; however, a composite of
alternatives or a remedy chosen from various components of
alternatives may be more likely to meet ARARs. Mechanical
controls requires a waiver of the Federal AWQC. The capping
alternative meets all ARARs. The sediment removal alternative
may require a waiver of the Federal AWQC due to the potential
negative environmental impact that could be created by trying
to remediate the marsh to a selected cleanup goal.
7.3
Short-term Effectiveness
Short-term effectiveness addresses the period of time needed to
achieve protection, and any adverse impacts on human health and
the environment that may be posed during the construction and
implementation period, until cleanup goals are achieved.
7.3.1
Soils, Pond, Ditch, and Groundwater
Soil remediation for alternatives 2 and 3 would be rather quick
to implement and would provide immediate protection from direct
contact with soils. Implementation of soil remediation for
alternative 4 would take somewhat longer, The method of soil
treatment for alternative 5 would probably take the longest
time of any alternative, perhaps two years or more. However,
both alternatives 4 and 5 would provide immediate protection
upon completion.
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For all alternatives, surface water and groundwater remediation
would take an extended length of t~e to achieve cleanup goals,
perhaps five years or longer. Construction of the
collection/treatment system; however, could be completed in a
short period of t~e.
The debris treatment and disposal methods are quick to
~plement and pose small risk to the community. Incinerating
the debris may cause an incomplete combustion and off-gas
release. However, controls and monitoring would be
~plemented.
All alternatives carry some risk of worker exposure to
contaminated soils, water and airborne particles during
construction. However, these problems can be min~ized by
personal protection and air monitoring. Truck spillage during
transport of contaminated material on-site or off-site may
occur if Alternative 3, 4, or 5 is ~plemented. Alternative 5
may also release some air pollutants or storm water runoff
problems from the leaching/smelting process. Measures such as
air pollution control systems on the smelter process and runoff
control would min~ize any environmental ~pacts.
7.3.2
Wetlands
The mechanical controls alternative for the west marsh would
immediately interrupt the soil ingestion and dermal contact
exposure pathway, as well as preventing grazing by cattle. The
latter would interrupt the human exposure pathway through
consumption of contaminated meat. The mechanical controls
alternative for the east marsh would allow sediments to remain
in place; however, the pathway would be greatly reduced.
Monitoring would determine whether natural processes of
vegetation uptake and burial achieve a level of protectiveness
over the long-term. The capping and sed~ent removal
alternatives provide immediate protection from exposure,
depending on amount of sediment removed. Min~al risk is
associated with remedy construction for each alternative;
however, solidification would require additional precautionary
measures to ensure the safety of workers.
7.4
Long-Term Effectiveness
Long-term effectiveness and permanence refers to the ability of
a remedy to maintain reliable protection of human health and
the environment over time, once cleanup goals have been met.
7.4.1
Soil, Pond, Ditch, and Groundwater
Containment of the soils in Alternative 2 cannot be considered
a permanent solution. There exists the potential for the cap
to fail. This alternative is moderately effective at
eliminating the possible exposure pathways and transport
mechanisms.
Off-site removals of the soils to a landfill as in Alternative
3 is a long-term solution for this site; however, this does not
address the waste itself in a permanent manner. The long-term
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effectiveness of soil fixation as in Alternative 4 will be
demonstrated by the treatability study. The effectiveness will
be more than adequate as the process is designed to decrease
the possibility of the contaminants leaching over time by
~obilizing the contaminants in a permanent manner. The
treatment and monitoring of groundwater will indicate any
deficiency in the effectiveness of the remedy. Heap leaching
soils, as required by Alternative 5, could be very effective as
a long-term solution, as it removes contaminants from the soils
and recovers them for future use.
The proposed methods for treatment of the debris separated from
the soils uniformly eliminate the contaminant source and are
effective in the long-term for the site.
Assuming the source of groundwater contamination is removed,
all of the treatment methods for surface water and groundwater
would provide long-term protection.
7.4.2
Wetlands
Sediment removal and solidification provides the greatest
degree of long-term elimination of risk posed by contaminants
at the SMC site because the contaminants are permanently
bound. The low permeability cover alternative would also
provide long-term protection to public health and the
environment; however, there is a very slight chance that flood
events might occur which could compromise the integrity of the
cap. The cap's effectiveness would be evaluated through
long-term monitoring.
The long-term effectiveness of the flooding alternative would
be evaluated through extensive long-term chemical, physical and
biological monitoring. This alternative is expected to
gradually diminish the risk posed by contaminants through
natural vegetation uptake and a self-cleaning ecosystem.
Long-term effects of wind disturbance to sediments are
estimated to be minimal at this site. The fence is a permanent
structure with routine maintenance required. Institutional
controls will be implemented, such as conservation easements,
in the wetlands to insure that the area remains undisturbed.
7.5
Reduction of Toxicity, Mobility, or Volume Through
Treatment
Reduction of toxicity, mobility, or volume is the anticipated
goal of the remedy's various treatment technologies.
7.5.1
Soil, Pond, Ditch, and Groundwater
Alternatives 4 and 5 would reduce the mobility, toxicity, and
volume of the groundwater contamination by decreasing the size
of the plume and eliminating the source. Alternative 3 only
relocates the source. Alternative 2 does not incorporate any
treatment and does not meet the goal of treatment. The volume
of treated soil in Alternatives 4 and 5 is such that it can be
replaced into the excavated pit; however, stabilization will
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increase the volume by approximately 37 percent. Mobility is
reduced in Alternative 4 through the binding of hazardous
constituents into a solid mass with low permeability that
resists leaching. Alternative 5 can be used to remove the most
soluble portion of the lead, thus removing the most important
negative environmental impact associated with this site's type
of soil contamination, which is toxic metal mobility.
7.5.2
Wetlands
The sediment removal and solidification would provide a
significant reduction of potential toxicity through treatment
of the contaminated sediments. There would be a potential for
an increase in the volume of waste associated with
solidification. The capping alternative provides for a
reduction of toxicity and mobility of the contaminants since
the sediment would be solidified; however, volume reduction
would also not occur with this alternative. These actions
would destroy the existing marsh systems and its functions
identified in the wetland study.
With the cleanup of the SMC processing area, the magnitude of
metal contamination in either the east or west marsh would be
limited to existing levels, with the exception of the urban
runoff input. The potential toxicity of the contaminated
wetland sediments is realized mainly when the sediments are
found in an aerobic environment. During the dry season and
under drought conditions, the wetlands dry out and the normally
reduced surficial sediments become oxidized by oxygen which
promotes chemical mobility of the metals contained in the
sediments. With increased mobility, the potential for toxic
effects is increased.
By implementing the flooding alternative for the east marsh,
the period of wetland inundation and the associated reduced
condition of its sediments would be extended, thus further
minimizing the potential toxic effects of the contaminated
sediments. Under an extended period of inundation, the
sediments would remain in a reduced state which would promote
the production of sulfide and benefit the sequestering effects
associated with the formation of metallic sulfide. The
extended period of wetland inundation would also promote
increased burial of the contaminated sediments. The natural
accumulation of organic debris in the wetlands would be
enhanced during the extended flooded conditions, because the
surface inundation would minimize the contact of the organic
peat with the atmosphere. This would promote peat accumulation
rather than loss via oxidation effects.
The highest concentration of lead in sediments are associated
with the dredge canal located in the east marsh. Because of
its greater depth, the existing contaminated sediments will be
subject to the continued effects of natural burial. Both
organic and inorganic material such as detritus, silt, and clay
particles will naturally accumulate as bottom sediment in the
deeper canal. Since the SMC will cease to be a source of metal
contamination, newly sedimented material would reflect normal
chemical characteristics of the area.
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Extended flooding and the resulting natural treatment process
of the east marsh will reduce the potential toxicity of the
contaminated wetland sediment and maintain the beneficial
functions of the wetlands. This alternative, however, would
not reduce the volume of contaminated material, but instead it
would promote isolation of the contaminated material.
.
The fencing of the west marsh does not address the concern of
available sediment toxicity; however, burial by seasonal
vegetation will tend to provide a reduction in the sediment
metal availability in the same manner as above at a slower
rate.
7.6
Implementability
Implementability is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular option.
7.6.1
Soil, Pond, Ditch, and Groundwater
All of the alternatives are technically and administratively
feasible. They all involve technologies which have been used
in the past and have a demonstrated performance record. The
services and material required for each alternative are
expected to be readily available. Each would require obtaining
any necessary permits if a surface water discharge is used.
Approval and a discharge point would be necessary if the POTW
discharge is chosen for these Alternatives.
In Alternative 2, capping and construction of slurry walls
requires the demolition of the building. Alternatives 3, 4,
and 5 all require dewatering during excavation of the soils due
to the high water table and a limited area for equipment
mobilization.
Alternative 4 is dependent upon bench scale treatment testing.
Alternative 5 will require construction of a treatment pad in a
limited available space.
7.6.2
Wetlands
All of the alternatives are technically and administratively
feasible. They all involve technologies which are
straightforward and easily implemented. The materials required
for each alternative are easily obtainable. The east marsh
flooding alternative is dependent upon development of a
hydrologic model. The cover alternative requires stabilization
of sediments to ensure adequate cap support. Solidification
requires treatability testing.
7.7
Cost
Cost includes estimated capital and operation and maintenance
costs, and are net present worth costs.
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7.7.1
Soil, Pond, Ditch, and Groundwater
Each alternative described will have a range in cost depending
on the groundwater treatment associated with the specific
source remedy where the lowest cost and the highest cost is
associated with ion media filtration and microfiltration of the
groundwater, respectively. All costs described are the total
present worth value.
Alternative 2 with a RCRA-type cap has a total present worth
cost of $3,143,000 to $5,442,000. Alternative 3, requiring
landfill disposal, has a total present worth cost from
$16,425,000 to $183,999,000. Costs for Alternatives 4 and 5
will depend on treatment of the screened battery debris from
the processing area soils. Alternative 4, where the debris is
disposed off-site, is from $8,469,000 to $10,766,000.
Alternative 4, where debris is incinerated on-site, is from
$6,768,000 to $9,064,000. Alternative 4, where debris is
recycled, is from $5,864,000 to $8,161,000. Alternative 5,
involving off-site lead recovery where the debris is disposed
off-site, would range from $9,334,000 to $11,230,000.
Alternative 5, where the debris is incinerated on-site, would
range from $7,633,000 to $9,064,000. Alternative 5 where the
debris is recycled, would range from $6,729,000 to $8,625,000.
Recycling is the most cost effective method for dealing with
the soil-screened debris from either Alternative 4 or 5.
Total present worth cost calculated for capping the source is
the most economical; however, the waste is not treated, only
contained in this remedy. Landfill disposal is not felt to
offer significant increases in protection to public health and
the environment, short-term or long-term effectiveness for the
extra cost. Chemical fixation is slightly less costly than
heap leaching. A summary of these costs is provided in Table
10.
7.7.2
Wetlands
Sediment removal and solidification is estimated to be the most
expensive remediation alternative at a range of $2,186,000 to
$11,076,000 for both marshes at the SHC site. This range is
reflective of the amount of sediment removed, the disposal
option for the solidified sediments and the mitigation option
for damages to the wetland. The cost for the capping
alternative is $4,233,000 for both marshes; however, this
includes solidification. The cost for the mechanical control
alternative is substantially less than either of these
alternatives. The cost of fencing the west marsh and flooding
the east marsh is estimated to be a total of $888,000. The
cost of also fencing the east marsh is estimated to be $28,000.
8.0
STATE AND COMMUNITY ACCEPTANCE
The State of Florida, as represented by the Department of
Environmental Regulation (DER), has had the lead for the SHC
site during the RIfFS, and therefore has been actively
involved. Both agencies (DER and EPA) concur in the selection
which will address the source of contamination, surface water,
-------
Table 10
Total Present Worth Costs
for Remedial Action Alternatives
Alternative
Description
1
2
No Action
RCRA Cap
3
4
Landfill Disposal
Solidification
a. debris: off-site disposal
b. debris: on-site incineration
c. debris: recycled
5
Heap Leaching
a. debris: off-site disposal
b. debris: on-site incineration
c. debris: recycled
Total Present Worth Cost
$557,000
$ 3,143,000 - $
$16,425,000 - $
$ 8,469,000 - $
$ 6,768,000 - $
$ 5,864,000 - $
$ 9,334,000 - $
$ 7,633,000 - $
$ 6,729,000 - $
5,442,000
18,400,000
10,766,000
9,064,000
8,161,000
11,230,000 ~j\
9,064,000 f
8,625,000
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-1)5-
groundwater, and the marshes. L~ited comments were received
from the community regarding the RIfFS study. Based on
comments made by citizens at the public meeting held on August
30, 1990, and those received during the public comment period,
the community believes the chemical fixation, surface water and
groundwater treatment, and the wetland mechanical controls will
effectively protect human health and the environment.
9.0
THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA,
available data collected to date, the detailed analysis of
alternatives, and public comments, both EPA and the State have
determined that Alternative 4, or more specifically,
Alternative 15c of the FS for the soil, ditch, pond, and
groundwater and the mechanical control alternative for the
wetlands are the most appropriate remedies for the Schuylkill
Metals site. These alternatives involve:
- Excavation of contaminated soil and debris
- Separating soils from debris by screening
- Excavation of contaminated ditch sed~ent
- Chemical fixation of soil and sed~ent
- Grinding and washing of debris
- Debris recycling
- Groundwater collection trenches
"
- Pond-pumping groundwater collection
- Groundwater chemical treatment and filtration
- Discharge of treated water to POTW or site waters
- East marsh flood control mechanisms
- East and west marsh fencing
- East and west marsh physical, chemical, and biological
monitoring
- Mitigation
- Operation and Maintenance
The EPA and the State have also included in the list above
additional requirements to the alternatives described in the
Feasibility Studies to ensure the remedy is effective, such as
mitigation and east marsh fencing. Battery casings, chips, and
debris mixed with soil will be excavated, screened, washed and
marked for recycling or chemical fixation. It is estimated
that removal of the casings and debris would require a maximum
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excavation of 54,500 cubic yards (cy), as indicated by the
casings and debris generally being confined to lenses within
the soil. The maxLmum volume of battery casings which may be
recycled at an EPA approved facility is calculated to be 18,500
cy. The remaining 36,000 cy of contaminated soil will be
excavated and treated. Excavation for battery casings and
debris will be performed on 50 foot by 50 foot cells with an
estLmated depth of 3 to 10 feet below land surface. Dewatering
techniques during excavation will depend on site conditions and
will include direct pumping, well points, or drainage
trenches. This collected water in addition to wash water from
the separation process will be pumped to the groundwater
treatment system.
Confirmatory sampling of each cell will determine the extent of
excavation. Cells with soil concentrations exceeding the
cleanup goal of 500 mg/kg lead will continue to be excavated.
The perimeter ditch will be excavated to a depth of two feet,
where the lead above 500 mg/kg is believed to be located.
Confirmatory sampling will determine the extent of excavation.
This is easily implemented and meets the protectiveness level
for potential leaching to groundwater. During the remedial
design the appropriate ditch reconstruction will be determined,
considering the effects of other site remedial activities,
especially the wetlands.
All sediment in the ditches to a depth of 2 feet and soil above
500 mg/kg lead will be treated using chemical stabilization to
bind the hazardous contaminants into a solid mass that resists
leaching. Treatability tests performed on site soil has
determined the most desirable mix to maintain long-term
solidification and stabilization. The resulting solid monolith
will be replaced in the excavation area.
Groundwater will be pumped from the pond and the dewatering
areas to a surge tank to equalize flow rate prior to
treatment. It is estimated that the average daily flow to the
treatment system is 259,200 gallons per day. The water from
the surge tank will be pumped to a barge anchored in the pond
and screened for large debris removal. Chemicals, caustic and
filter-aid will be added to the inlet tank on the barge to
precipitate the lead. The chemical slurry mix will be
dewatered and solids will be treated with the site soil.
Treated water will be discharged to the local POTW or
reintroduced to the wetlands onsite. This will be determined
during remedial design. Treated water will be monitored for
flow, pH and other required permit parameters prior to
discharge to the city sewer.
The purpose of this response action is to control risks posed
by direct contact with contaminated soils, groundwater and
surface water and to minimize migration of heavy metals to
groundwater and surface water. Additionally, this action will
provide a measure of protection to aquatic and terrestrial
organisms living in and around the wetlands while still
preserving the integrity of the wetlands by eliminating the
source of contamination in the processing area.
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The primary contaminant at the site, lead, has been shown to
produce chronic and subchronic adverse health effects.
Calculations performed using likely routes of exposure to
contaminants at the site have determined that acceptable daily
intakes of lead may be exceeded by persons frequenting the site
if no remedial action is taken.
Since no Federal or State ARARs exist for soil, the cleanup
goal for the lead in soil was determined through site-specific
analysis. This analysis involved the calculation of the
possible daily intake of soils associated with the site by
persons of the most sensitive age group. Using a previously
established acceptable daily intake of lead for this age group,
it was determined that a lead concentration of 538 mg/kg in
soils would be protective of health through the direct contact
pathways. Based on site investigations (WWC, 1989), it was
determined that a cleanup goal of 505 mg/kg should prevent
excessive leaching of lead from soils that would result in
groundwater lead concentrations above 0.05 mg/L. Based upon
these analyses, the EPA determined that 500 mg/kg lead is an
appropriate cleanup level for this target ground water level.
The amount of lead in the leachate must not exceed the recently
proposed revision to the MCL of 0.015 mg/L.
Contaminated groundwater and pond surface water at the site
will be collected and treated to achieve the ARARs. The most
recent EPA guidance indicates a cleanup level of 0.015 mg/L for
lead in groundwater for potable water is protective of human
health. Groundwater exceeding a lead concentration of 0.015
mg/L, or the background concentration, whichever concentration
is highest, will be collected and treated to that
concentration. During the Remedial Design, EPA will select a
procedure for statistically determining the background
concentration of the contaminants. The groundwater treatment
system will treat the water to meet standards based on the
methods of disposal. Treated water to be discharged to the
POTW will meet all requirements set by the POTW. Any treated
water discharged to the wetlands will be treated to comply with
the AWQC for lead at this site of 0.013 mg/L. This will be
addressed further during remedial design.
Should lead concentrations decline with treatment and approach
aSYmPtotic concentrations following prolonged recovery and
treatment, the Agency may seek an ARAR waiver and a ROD
amendment issued. However, any permitting requirements must
still be met for surface water discharge.
The treatment method chosen for site soils will eliminate the
threat to health through direct contact by binding the
contaminated media in a solid mass. Treatability studies
demonstrate that leaching of the mass by groundwater will not
result in groundwater contamination above the cleanup goals.
groundwater monitoring program will assure the satisfactory
performance of this treatment method.
A
Though contaminants other than lead exist at the site, the
concentrations of these contaminants are such that once each
medium is remediated to the lead cleanup levels, these other
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, -.
-68-
contaminants will be reduced to concentrations that will not
pose a health threat.
The characteristics of Alternative 4 for the soil, pond,
ditches, and groundwater that are considered most important are
that it:
- Provides immediate protection to human health from direct
contact with contaminated soils upon completion of
construction.
- Provides immediate protection to human health from the
potential threats associated with consumption of groundwater
from the site.
- Limits migration of contaminated groundwater off-site and
controls migration of contaminants into the aquitard and lower
aquifers.
- Provides a measure of protection to wildlife living in and
around the east marsh while still protecting the wetlands from
further damage.
- Provides for management of surface water quality through
monitoring of contaminant levels in the surficial aquifer and
possible surface water discharges.
- Contributes to the implementation of a more permanent remedy
at the site.
The recommended alternative requires a certain degree of annual
Operation and Maintenance (O&M) activity to ensure that
groundwater will be treated to meet the cleanup levels. The
degree of O&M cannot be determined until the discharge option
is selected. An O&M plan will need to be developed during the
remedial design/remedial action phase. All O&M
responsibilities will be covered as specified in Section l04(c)
of SARA.
Wetland contamination will also be addressed in the selected
remedy. The west marsh is partially protected by the existing
site fence. This has been supplemented by the modification of
the existing fence on the western boundary of the marsh. The
fence effectively keeps humans and cattle from entering the
marsh.
A fixed weir will be constructed at the outlet of the east
marsh to maintain perennial surface water inundation in this
marsh. The height of the weir will be determined during
remedial design and will be enhanced using a supporting berm
near the outlet. Approximately one acre of wetland in the east
marsh will be impacted from construction activities. .
The perimeter ditch may be relocated after
in order to direct surface water flow into
further ensuring that it remain inundated.
incorporated into the remedial design.
sediment excavation,
the east marsh,
This will be
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Monitoring of both wetlands will include chemical and
biological sampling in sed~ent and surface water. This will
be performed biannually during the wet and dry season.
Vegetation monitoring of habitat structure will determine
~pacts from lead concentrations and reclamation of the SMC
site, metal accumulation levels over time, and protectiveness
of the remedy. Invertebrate monitoring will aid in assessing
the remedy's effectiveness. Monitoring will include vertical
sediment sampling of metal concentrations. Institutional
controls, such as conservation easements, will be implemented.
A public health assessment will be conducted by EPA five years
after remedial action implementation. Following this
assessment, monitoring activities will be evaluated on the
basis of the need for further remedial action or monitoring.
The Wetland Impact Study concluded that removal of the
hazardous waste from the site would no doubt result in a
diminished source of heavy metals to the east and west marsh.
It is assumed that the marshes receive the lead contamination
from the site soil source. Once this source is remediated,
sediments and surface waters of the marsh would then be flushed
with groundwater having safe levels for the marsh. This will
be accomplished through the reintroduction of treated water to
the surface waters of the east marsh, in the event the water is
. not entirely discharged to the POTW. Placement of treated
water on the marsh will also aid in maintaining perennial
inundation.
The study also concluded that a disruption of the anaerobi~
chemistry of the sediment would tend to mobilize the metals
through oxidation processes. Minimal disturbance of the marsh
would be effective in sequestering the metals in sediments.
Maintaining the sediments in an anaerobic state by providing
continuous surface water inundation will enhance the marshes
natural tendency to bind the metals. Mobilization of lead
could be caused by the use of heavy earth moving equipment
mixing the marsh sediments and forcing the contaminants deeper
into the peat sediments. Sediment dredging could suspend lead
particulates that are bound to the marsh sed~ents and release
them into the water column, thus allowing lead to potentially
migrate off-site. The wetlands serve as a catchment basin,
trapping and holding contaminated sediments. The dense wetland
vegetation contribute to this ability to retain sediments and
associated contaminants.
Lead, iron, and aluminum concentrations in the west marsh
surface waters exceeded National Ambient Water Quality Criteria
(AWQC) and iron and aluminum concentrations in the east marsh
surface water exceeded the Federal AWQC. Therefore, this
alternative requires a waiver of the Federal AWQC. The waiver
is justified by the negative environmental impact that could be
created py trying to remediate the entire area of the wetlands
and potential mobilization of lead beyond the site area (CERCLA
121 (d) ( 4 ) (B) ) .
Federal Executive Order 11990, Protection of Wetlands, requires
federal agencies in carrying out their responsibilities to take
action to minimize the destruction, loss, or degradation of
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wetlands, and to preserve and enhance the natural and
beneficial values of wetlands. Section 404(b)(1) of the Clean
Water Act also requires that practicable steps must be taken to
minimize adverse impacts to wetlands from fill. In the case of
this alternative, the contaminated sediments remaining in the
marsh will not allow maximum biological productivity and
diversity of the wetland ecosystem. To minimize the effects of
this impact, mitigation for the wetlands are required.
Creation of a new area of wetlands will compensate for the
functions lost or effected in the onsite wetland. The specific
mitigation plan will be developed in accordance with the EPA
regional mitigation guidelines.
10.0
STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, Section 121 of CERCLA establishes several other
statutory requirements and preferences. These specify that,
when complete, the selected remedial action for this site must
comply with applicable or relevant and appropriate
environmental standards established under Federal and State
environmental laws unless a statutory waiver is justified.
Should ARARs be unattainable for discharge to the marsh, or if
the POTW will not receive recovered groundwater and surface
water, then the appropriate permitting will be obtained for
discharge to surface waters. The selected remedy also must be
cost-effective and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. Finally, the statute includes a
preference for remedies that employ treatment that permanently
and significantly reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element. The following
sections discuss how the selected remedy meets these statutory
requirements.
10.1
Protection of Human Health and the Environment
The selected remedy of chemical fixation of the processing area
and the ditch sediments is protective of human health and the
environment by eliminating the source of contamination and the
direct threat through dermal contact with surface soils and
ditch sediments. The collection of surface water and
ultimately groundwater in the pond and trenches will reduce the
risk of consumption of contaminated groundwater. This will be
accomplished by pumping water from the pond to induce
groundwater flow from the affected surficial aquifer to the
pond area.
The routes by which the landfill impacts the wetland is through
surface water transport and groundwater flow. Water flows off
and through the processing area to the wetlands thus providing.
a pathway for metal transport into the wetland. Remediation of
the site soil will lead to greatly reduced future metal loading
to the wetlands. Also, by changing the wetland'shydroperiod
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-71-
to a more permanently flooded marsh system, the sediments
become anaerobic. The sulfur bacteria in the sediments reduce
sulfate to sulfide, which reacts with most heavy metals to form
a metallic sulfide. This process chemically binds and
sequesters the metals in the sediments through a natural
anaerobic process thus reducing contaminant mobility and risk
to the environment.
10.2
Attainment of ARARs
The selected remedy requires a waiver of the Federal AWQC
because the wetlands surface water exceeds the AWQC levels for
iron, aluminum, and lead. This waiver only applies to the
present condition of marsh surface water and not any treated
waters discharged to the marshes. The waiver is justified by
the potential negative environmental impact that could be
created by trying to remediate the wetland sediments (CERCLA
121(d)(4)(B». It is anticipated that the Federal AWQC will be
met in the long-term.
The selected remedies were found to meet or exceed all of the
following ARARs:
Resource Conservation and Recovery Act (RCRA):
- 40 C.F.R. Part 265 Subpart G:
Closure and Post-Closure
- 40 C.F.R. Part 265.228:
Post-Closure Care
Surface Impoundment Closure and
- 40 C.F.R~ Part 265.90: Groundwater Monitoring
- 40 C.F.R. Part 268 Land Ban: The RCRA land disposal
restrictions ("LDR") (40 CFR Part 268) promulgated in the
1984 HSWA amendments require that RCRA hazardous wastes be
treated to BDAT (Best Demonstrated Available Technologies)
Standards prior to placement into the land. The on-site
wastes are characterized as RCRA wastes for lead, arsenic,
and cadmium because they exhibit EP Toxicity as defined in
40 CFR Part 261.
Excavation and treatment in a separate unit is considered to be
placement under RCRA LDR. Therefore, LDR is an applicable/or
relevant and appropriate requirement. However, the treatment
process will immobilize the metals to the extent that the waste
will no longer be classified as a hazardous waste as defined by
RCRA.
Clean Water Act/Safe Drinking Water Act:
EPA's determination of appropriate groundwater cleanup criteria
involved an evaluation of contaminant concentrations relative
to available health-based standards. Such limits include the
following:
- Maximum Concentration Levels (MCLs) and Maximum
Concentration Limit Goals (MCLGs), as defined in the Safe
Drinking Water Act (SDWA) (40 CFR Part 141 and 142).
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- Ambient Water Quality Criteria (AWQC) Section 204 of the
Clean Water Act (CWA) used as prescribed in Section
121(d)(2)(B)(i) of CERCLA for consumption of drinking
water only, or for consumption of aquatic organisms and
drinking water.
Other:
- National Ambient Air Quality Standards (NAAQS)
- Florida Groundwater Standards
- Florida Department of Environmental Regulation - Class III
Surface Water Quality Standards
- POTW Standards (40 CFR 403.5 and local regulations)
10.3
Cost Effectiveness
EPA and the Florida DER believe the selected remedy is cost
effective with an estimated total worth value of $6,229,500.
This cost includes the capital cost of $4,179,000 and 0 & M of
$1,685,000 for the source, surface, and groundwater treatment
and the capital cost of $188,000 and 0 & M of $137,500 for the
wetland remediation. Mitigation and cost of fencing the east
marsh will be determined during remedial design. This remedy
is effective in mitigating the risk posed by the soils in a
reasonable amount of time. Stabilization is a proven
technology which will address the principal threat posed by the
lead-contaminated soil. This treatment will halt migration of
the contaminants into the lower drinking water aquifer and the
wetlands on-site. The costs of the selected remedy are
proportionate to the overall effectiveness it affords, such
that it represents a reasonable value for the money.
10.4
Utilization of Permanent Solutions and Alternative
Treatment (or Resource Recovery) Technologies to the
Maximum Extent Practicable
US EPA and the Florida DER have determined that the selected
remedy provides the best balance among the nine evaluation
criteria for the alternatives evaluated. The remedy uses
permanent solutions and treatment technologies to the maximum
extent practicable. The soil, pond water and groundwater remedy
provides effective protection in the short- and long-term to
potential human and environmental receptors, protects the
aquifer from contamination, is readily implementable, is cost
effective and is consistent with future response actions that
may be undertaken at the site.
By eliminating the source of contamination, the effects on the
wetlands will be significantly diminished in the long-term. By
flooding the wetland the toxicity and mobility of the
contaminants will be significantly reduced both in the
short-term and the long-term. The criteria were evaluated for
the wetlands with the consideration of the importance of the
functional value of wetlands, especially in Florida. This
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remedy for the wetlands represents the best trade-off to
maintain existing wetlands while creating or restoring
additional wetland areas. No net loss of wetlands at the
will be achieved.
site
The selected remedy for the wetlands is more easily implemented
and significantly less costly than the other alternatives. It
also offers some short-and long-term protection to human health
and long-term protection to the environment.
10.5
Preference for Treatment as a Principal Element
The statutory preference for treatment will be met for the
soil, pond, and groundwater. The principal threat from the
Schuylkill Metals Corporation site is ingestion of contaminated
groundwater and ingestion or dermal absorption of metal
contaminated soils. The selected remedy will reduce this risk
through treatment of the soils, surface water and groundwater.
By stabilizing the metals-contaminated soils, the selected
remedy addresse.s a principal threat posed by the site through
the use of treatment technologies. Therefore, the statutory
preference for remedies that employ treatment as a principal
element is satisfied.
Treatment is impracticable and was not the preference for the
wetlands, since it is not appropriate for these sensitive,
diminishing, wildlife habitat areas. Excavation and treatment
of the sediments would have greatly impaired the marsh's
thriving existing ecological ecosystem. It has been documented
to be a highly functional wetland, serving as a local catchment
basin for urban run-off.
11.0
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan was released for public comment in August,
1990. During the public comment period, the State of Florida
suggested that the east marsh be fenced to prevent access
and/or direct contact. The Proposed Plan addressed fencing the
west marsh in the preferred alternative; however, the ROD
addresses fencing the east marsh as well. EPA agrees with the
State in instituting this additional measure of protection.
Otherwise the Proposed Plan identified the ROD's selected
remedy as the preferred remedy. The capital cost estimated for
a 6 foot cyclone fence is $22,000. This fence would extend
along the south, east and northern boundary of the east marsh
connecting to the existing site fence on the western side. O&M
cost is estimated to be $6,000. Total present worth cost would
therefore be $28,000. Implementation time is approximately
1 - 2 months. The decision to fence this impacted wetland is
considered a logical outgrowth of the information in the
Proposed Plan.
-------
REFERENCES
ATSDR, 1987. Draft Toxicological Profile for Chromium, Agency for
Toxic Substances and Disease Registry, U.S. Public Health Service,
Atlanta, Georgia.
ATSDR, 1987c. Draft Toxicological Profile for Cadmium, Agency for
Toxic Substances and Disease Registry, U.S. Public Health Service,
Atlanta, Georgia.
Roy F. Weston, Inc., Draft Final Addendum to Feasibility Study
Report, Schuylkill Metals Corporation Site, Plant City, Florida,
July 30, 1990.
U.S. EPA, Wetland Impact Study, Schuylkill Metals Superfund Site,
Plant City, Florida, U.S. EPA Region IV, April 1990.
U.S. EPA, Superfund Proposed Plan Fact Sheet, Schuylkill Metals
Corporation Site, Plant City, Florida, U.S. EPA, August 1990.
U.S. EPA, Guidance on Preparing Superfund Decision
Proposed Plan, The Record of Decision, Explanation
Differences, and The Record of Decision Amendment,
July 1989.
Documents: The
of Significant
Interim Final,
WCC, 1987. Woodward-Clyde Consultants, Remedial Investiqation
Report, Schuylkill Metals Facility, prepared for Schuylkill Metals
'Corporation, Baton Rouge, LA.
wec, 1988. Woodward-Clyde Consultants, Feasibility Study Report,
Schuylkill Metals Facility, prepared for Schuylkill Metals
Corporation, Baton Rouge, LA.
WCC, 1989. Woodward-Clyde Consultants, Feasibility Study
Addendum 1, Sampling Report for Marsh, Perimeter Ditch, and Surface
Impoundment, Schuylkill Metals Site, prepared for Schuylkill Metals
Corporation, Baton Rouge, LA.
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APPENDIX I
WETLAND SAMPLING DATA
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TABlE 3
SURFACE ~ATER DATA SUMMARY
SCHUYLKill METALS
PLANT CIIY, flORIDA
May. 19R9
SM-HI SM-211 SM-311 SM-I,IJ SM-511 SM-7\I SM-811 SM-8100 SM - 9\1 SM-ml SM-PB
INORGANIC ELEMENTS UG/l UG/l UG/l UG/l UG/l UG/l UG/l UG/l UG/l UG/l UG/l
ARSENIC 51, 20 21
BA!lIUM 15 11, 11, .11, 15 11, 81, 71 1,0 11,
CADMIUM . 7.1 5.7
CHQ()4! UM 12
COPPER 36 - 30 11
lEAD (@ 330 1,6
ANT IMOMY 2~ 11
STRONIIUM 580 590 590 610 620 600 560 51,0 690 610
TIT ANIUH 30 27 15
llNC 15 13 16 10 51,0 1,30 120 "
ALUMINUM 570 550 51,0 680 870 620 8200 6600 2200 570
MANGANESE 160 160 160 160 160 160 250 220 200 160
HG/l HGll HG/l HG/l HG/l MG/l HG/l MG/l MG/l MG/l MG/l
CAI.CIUM 100 100 100 100 100 100 120 120 11,0 100
HAGNE S IUH 12 12 12 13 13 13 11, 11, 18 13
IRON 0.71, 0.63 0.68 0.77 0.86 0.66 27 22 6.0 0.67
SOO IlJH 270 270 270 290 290 280 190 200 270 280
POTASSIUM 18 18 19 18 19 19 5.0 3.6 18 19
GENERAL INORGANIC PARAMETERS MG/l HG/l HG/l HG/l HG/l HG/l HGll HGll HG/l HG/l HG/l
SULFIDES 0.67 NA 0.29 NA 0.51, NA 27 38 110 0.29
PHYSICAL PARAMETERS MGll HGll MGll MG/l MGll MGll MGll MG/l MGll MGll HGll
HARDNESS(AS CA(03) 300 320 310 31,0 330 310 390 360 1,1,0 31,0
[[[
... FOOl NOTE S."
-------
T"b/(' 6.
II""" C/If'mlstry R..,ult,
S.tlnplp. Silt,
Septemher,
1989
S lHn,d (I S i l ~ .1 nd lJn t n
rarahlPter
S~- 3
9/n/89
unl i 1 terect
S~-7
9126/89
unrll tued
S~-8
9/26/89
unflltued
SM.9
9/26/89
unl 11 tf"red
SM-} 2
9/70/89
Ullfl1lf'fpd
SM. 13
4/~b/89
UIlI i 1 t..red
s~,. ) I~
9/n/~4
UTif i It.-red
S~-I~
~/n/69
tlllf Iltt>rpd
SII.16
9n6/89
ullriltt'red
SI1-9a
10/9/89
unfiltered filtered
SM.Qb
10/9/~9
unflltrr..d Illt..r..d
Samld r 81..ok
IU/9/1;,/
unflllt,.d- (i It...rd
Alumin\lm (ul',/I.) 460 440 200 J )OI! ))OU 1 )UI! 7 ',0 1500 4700 210 ))0 140U 11.0 \OOU I ~O
AntlmollY (ur,/L) nu )5U )5U )5\1 35U 3~U )lI JW )W 30U 3UI! NA 31111 )UlI )Oll
Ar~~fli ( (,'r,lL) 5UJ 6UJ 6U 1011 211.1 IIJ )LI JlIJ JI!.I )Oll 30U N" 311U )OU 30U
811rlulO (ur,/L) 2W 2SU 25U 25U 251! 2~U ]:,[1 2W 49 26 18 NA 16 21 4/
8"rylllum (ut/I.) 2U 2U 2U 2\1 21! 211 2\ 2U 211 5U 5U NA 5\1 5.UU ~ 011
C.dmlum (ul\/L) 3UR 3UR 3UR 3\1R 3UR 3\1R 3\'R JlIR JUR 5U SU NA W ~ ou 5 Ull
C.lclum (ug/I.) 6 1000 59000 22000 4 !!JOO 21000 280UO 411)0 23uOO 28000 42000 41000 40000 41UOO 5110 5011
Chromlu," (u,,/I.) 5U 5U 5U 5U 8U 511 II 5U 22 IOU IOU NA IUU IUU IIIU
(ohaIr (ug/L) 12U 12U 12U 1211 12U 12U 1211 12U 20U IOU IOU IIA IOU lOll IOU
COPPH (ut/L) 4U ioU ioU ioU 4U loll loll ioU ioU IOU IOU IIA 1011 1011 IOI!
II'on (ug/ ) 3100 3000 1100 950 1400 1"00 11000 2800 2SUO 890 830 990 820 SOl! ~OU
Lred (ut/L) 4.1 4.1 5.1 3\1.1 ~.I 3l1J 110.1 200.1 570.1 4011 40U IIA 4011 40U 4011
M"l\nuhm (ur,lll 9200 9200 4300 S900 4700 6~,00 3~OO 2200 2200 5400 5100 5200 ~IOO IOU 20U
!iangenru (uf/L) 180 160 90 110 74 110 ~I, 38 40 140 130 120 1)0 IOU IOU
'i~rcury (ur.l ) 0.2U O.W 0.2U 0.2U 0.2U 0.2U .20U .2OU .20U NA NA IIA N" NA IIA
:I/ck,d (ug/L) 20U 20U 80U 30ll 20U 20ll IOU 20U 20ll 20U 2UU NA 2UU 1011 lOll
PotasslUJII (ug/L) ISOOO 13000 10000 120000 49UO 68UO 2'.00 23000 18000 9600 II 000 12000 11000 20U 1llU
Selrnlum (uf./I.) IUJ IUJ IUJ IlIJ 111.1 IlIJ 1\1.1 1\1.1 IUJ 40U 4011 NA 40U 2000U 2lll)O\l
.:'! Iver ("g/-) 6U 6U 6U 6U 6U 6lJ 61J 6U 6U 10lJ IOU NA II1U 40\1 411U
:,odlum (u&/L) ISOOOO 140000 38000 30000 14000 16000 "7000 41000 2 (.000 53000 34000 34000 )l.lll)O 10\1 J{llJ
Thalli"," (ug/I.) IU 2U 2U IU III III H; IU IU 100U 100U IIA IUOU 2000U 2l.0lll1
TI II (u&/I) IIA IIA NA NA NA Nil ~A NA Nil 2~U 2~lI NA 2~11 IOU IOU
'J",.adlum (ug/L) 20U 20U IIU 20U III' III! Illl 200 2UlI IOU IOU IIA IOU 50U 50\1
~ I nc (ug/L) 39 19 29 19 20 29 )9 29 29 19 84 NA RI. 100U 1(\111'
pH (sId units) 5.7 5.6 6.3 6.4 ~.R 6.3 6.1 6.0 6.0 6.2 NA NA KA 2~\) 2W
{) i..o I vrd Oxyg.n 0.2 0.2 0.1 0 2 0.4 0 5 0 1 I 0 0.1 1.11
(mr.ll.) NA IIA I:" IOU 10\1
COlirluC t j ,'J r y 183 188 439 393 184 24/, 70~0 821 305
(uhmo!i/cm) 389 NA NA /'iA IOU Jill'
E~ -0.202 .0.270 -0.254 -0. I ~I -0.0"2 .0.O9/. -(1.303 -0.262 .0.2/8 .0.098 NA NA t\A IOU IOU
"15,01 vrel S"II d, 84 IHI 1,8 M NA NA
(tal mr.lL) 205 210 96 360.1 370.1 NA r;;\ 40 60
UoJ uhu.> s.s 240 NA I'IA t\,; Nil NA
(m,../I. ... [aCO,) 4(1) 370 NA I ~ll NA 120 r:"
AI~allnlty (mf/L) 1111 NA 110 1:,\
S..llat. (mg/L )j NA 13 t\i,
::ul I idps (mr,/I.) O. SUJ NA O.5UJ t;,\
ClaI" II d. (m&/I.) 48 /'ill 41 r;.-\
th(lmtd~ ~.7 NA 5.1 ~,\
NI.....tr-N (mg/I.) 0.04 /IA 0 OIU t\,\
rntllu-t~ (mg/L) O.OIC K'
O.OIU tlA "
Ammonia (mf.ll.) 0.99 NA 0 91 t:A
Orrho."husphal.
.!'(IIIg/l.) 0.91 Nil 0.92 r:"
Ba«",11 hhn;att. Nil t:1I /'ill ,.,.
(.11,"1""11 t' (mr.!'.) 2.011 r~/I 2.0l' !'."
SilIcon (ur./!.) 4.0 tlA 3.7 1:/1
O"fj;1n1(" r..ubon
(elis.mr./I.) 48 /'iA ~l) K,\
UI' r.;uti c: C... Lon
(lot. ",&/L) 71, NA ~4 r:,\
rU()INOTE~"*
. A. AVERAGE VALl'E "NA-/IOT ANALYZED .NAI.INTERfERENCES *.1 - E5T1MAHIJ VAUlt: "1'1 PR[5I1ttl'TlVt: EVlIJrr;,:[ or I'RlSI::ICI: Of HATERIA!. *r.. ACTIIAL VALUE I S KNO~'N TO BI:
1.£55 THAN \'AI.UI' r.IVI:N "I.. ACTUAL VALUE 15 KNOI.'II 10 BE GREAHR TlIAN \'/lI.\I[ GIVf.N "\I.MAHRIAI. IJAS AI;~I.\'Zt:D H't( fil'T NOT IJUECHO TIlE NUH8ER IS TilE MINIHlIM
QIIANTl1A110N LlHIT "R.QC INOICAHS TIIAT DATA U/'iUSA8I.E. COM/'OU"/) MAY 011 HAY NOT BE "lIt.HNT. RI:SAlIPl.nC A\D REANAI.YSIS IS ~ICES~AR'" "OR VERlr!CATION.
rlltt-lf'cI: O.IJ Nuclf'opOIf'''
SM-14, SM-15, and SM-16 samples located In west m~rsh
Al I other samples located in east marsh
.\ "lid b - I..pll
IAml'lp.S on 10/9/89
-------
TABLE 2
SOIL AND SEDIMENT DATA SUMMARY
SCHUYLKILL HETALS
PLANI CITY. FLORIDA
Hay, ]989
SH-1S SM-2S 'SM-3S i SH-I.S SH-5S SH-6S SH-7S. SH-8S SH-8SD SH.9S SH-10S SH-115 SH.12S SM-BS
INORGANIC ELEMENTS MG/KG MG/ICG I MG/KG I HG/KG MG/KG MG/KG HG/KG MG/KG MG/KG MG/KG MG/KG HG/KG HG/KG HG/ICG
ARSENIC 11 32 ! 1,2 1,0 .39 9.0 7Z 37 1,2 15 28 60 11, 35
BARIUM 59 11 \ 12 70 70 150 86 62 60 150 1t.0 190 57 2f
BERYLLIUM 1.1 1.2
CADMIUM 3.8 4.2 : 22 34 19 30 3.2 2.9 4.4 2.2 0.77 0.90
COBALT 2.5 ',8.5 3.8 3.9 2.5 2.6 2.0 1.7 1.5
C H R (»..lJ4 16 25 ! 33 39 30 36 39 23 23 49 39 38 20 7 - 1
COPPER 20 29 1'5 33 21, 29 9Z 19 20 37 76 53 15 1]
MOLYBDENUM 2.0 2.0 2.0 2.0 2.7
NICKEl 8.1 12 11,0 36 51, 6.2 38 1t. 15 1t. 9.5 8.9 7.2 5.1,
lEAD l6Q- .---. .,1:SL --_-.J500 1200 1500 110 1300 740 820 610...- . 310 . ..~30 Ho 320.
_.. ..
ANTIMONY 13 91 '59 140 12 560 31 39 82 83 8.2
TIN 5.3 21 n
STRONTIUM 130 140 180 130 1t.0 420 120 21,0 220 570 370 270 160 71
" TAN 1lJ4 48 92 40 71 73 89 65 1,8 3t. 110 83 150 54 1]
VANADIlJ4 18 18 19 33 23 30 26 23 22 43 29 47 16 10
YTTRIUM 10 1t. 21, 14 1t. 26 21 2Z 21 31 23 21 9.6 3.1
ZINC 170 65 210 150 180 38 290 1,8 71 66 100 27 31, 61
MERCURY 0.31 O.tS 0.12 0.11 0.08 0.07 0.12 0.08 0.07
AllJ41 NUM 12000 16000 51000 18000 27000 23000 42000 16000 16000 17000 23000 12000 8600 3000
MANGANESE 38 18 29 26 23 7.9 20 25 26 17 12 28 12 34
CALCIUM 7900 6t.00 8000 5100 6600 8600 4400 12000 13000 11000 6800 1600 14000 18000
MAGNESIlJ4 570 630 1100 970 1000 350 630 680 150 680 470 710 990 noo
IRON 10000 8300 41000 5500 6t.OO 1600 311)00 51,00 5500 2800 1900 11000 3400 5900
SOOIlJ4 2400 3500 5500 30000 1,3000 840 8t.OO 2700 2700 3000 1200 3300 740 880
TOTAL ORGANIC CARBON 29000 3100 170000 200000 290000 150000 190000 180000 160000 180000 130000 1t.0000 1,6000 220000
[[[
."FOOTNOTES."
-------
,
Table 8. Sediment Chemistry Results
September, ~89
sa""le Site 8 Date
SM-3 SM-7 SM-8A SM.8B SH.8C SM'/IO SH.9 SH.12 SM -13A SM.13B SH .ne S"-13O SH.98 SH.9b
9/26/89 9126189 9/26/89 9/26189 9/26189 9/26/89 9/26/89 9/26/89 9/26/89 9/26/89 9/26/89 9/26/89 10/9/89 10/9/89
Per_ter
AI""inun (1IIII/kg) 34000J 66000J 10000J 10000J 6900J 4200J 9200 5700 8100J 18000J "000 7500J 4800 3900
Antinony (1IIII/kg) 9W 200U 340U 40U SOU 100U 100U 90U 100U 40U 270U SOU 40U 30U
Arunic ("'!I/kg) 30U Il1o 20U 7\J 6U 20U 20U 8U 30U 19 20U 17 7U 8U
Bed... (1IIII/kg) 60U 98U 700 31 40U 70U 50 60U 70U n 45U 40U 69 49
Beryll'"" (mg/kg) 8U 7.8U 5.30 2.2U 2.5U 4.9U 3.5U 4.7U 5.3U 2.3u 3.6U 2.8U 4.eu 4.3u
Cedfth.. (1IIg/kg) 7.1111 70UJ 7.9UR 3.4UR 3.7UR 7.4UR 5.3UR ' 7UR 7.9UR 3.4UR 5.4UR 4.1UR 4.eu 5U
Calei"" (1IIII/kg) 5100 6900 7300 8300 7100 7500 6200 7600 1'000 7200 8900 4700 "OOOJ 8300J
Chromi"" (1IIII/kg) 200 48 20U S.6U 6.2U 20U 21 46 31 22 21 33 18 27
Cob81 t (1IIII/kg) 30U 50U 400 20U 27 30U 30U 30U 40U 20U 30U 20U 12u 20U
c~r ("'!I/kg) 53 54 37 4.5u 18 9.9U 32 9.3U 19 24 n 5.5U 90UJ 60UJ
Iron (1IIII/kg) 28000J 83000J 7300J 2800J 2200 1800J 2200J 2200J 4300J 2500J 2400J 2000J 2700J 1900J
lud (1IIII/kg) 1500 940 1200 25 16 B 410 120 250 75 50 5u 80 89
Magrws'"" (1IIII/kg) 1300 1500 460 540 510 720 390 620 750 440 510 340 1800 1200
Manganese (mu/kg) 42 30 21 911 20 20U 15 7U 22 18 20U 23 17 n
Mercury ("'!I/kg) 1.2U 2U 1.30 0.56U 0.62U 1.2U 0.88U 1.2U 1.3U 0.57U 0.911 0.69U 0.47U 0.46U
Nidel (II1II1 kg) 160J 80U 600 40UJ 40UJ 50UJ 60UJ 50U 70UJ 60UJ 36U 700J 30U 30U
Potanium (mu/kg) noou 22000 1500U 610U 670U BOOU 950U BOOU 1500U 610 970U 750U 460U 420U
.Selen'"" (1IIII/kg) 2.4U 3.9U 2.6U 3U 3U 2.5U Leu 2.3U 2.6U 3U Leu 1.4U 3UJ 2uJ
Silver (1IIQ/kg) 20U 30U 200 6.7U 20U 20U 20U 14U 20U 6.eu 20U 8.3U 7.2u 6.4U
Sod;'.. (mg/kg) 8800 24000 3400U 1900 2300U 4500 noou 3000U 3400U 1500U 2300U 1800U 1200 1000
Ihall i"" Img/kg) 2.4U 3.9U 2.6U 1. 1U 1.2U 2.5U Leu 2.3U 2.60 1. 1U Leu 1.4U 1.1U 1.1U
tin (1IIII/kg) NA NA NA NA NA NA NA NA NA NA NA NA NA NA
Vanedi"" (mg/kg) 40U 45 30U 30U 20U 35 40U 300 30U 30U 40U 20U 20 18
Zinc (mg/kg) 1I0J 190J SOU 55J 20UJ 40UJ 53J 400J 110J 97J 130J 85J 42 34
fOOt NOtE S" °
"A' AVERAGE VALUE 0NA'NOt ANALYZED "NAI-INtERfERENCES "J.EStIMAtED VALUE 0N.PRESUMPtlvE EVIDENCE Of PRESENCE Of MAtERIAL 0K.ACtUAl VALUE IS KNOUN to BE lESS tHAN VALUE GIVEN 0l.ACtUAL VALUE IS
ICNO\JN to BE GREAtER THAN VALUE GIVEN "U'HATERIAl YAS ANALYZED fOR BUI NOI DEIECTED. lHE NUMBER IS lHE MINIMUM QUAN111Al10N LIMII. °R-QC INDICAIES lHAI DAIA UNUSABLE. COMPOUND MAY OR MAY NOI BE
PRESElll. RESAHPllNG AND REANALYSIS IS NECESSARY fIJR VERlfICA110N. ALL SAMPLES REPRESENI lOP fOOl 01 SEDIMENI UNLESS 01HER~ISE NO lED.
A . slIqIle from 0 to , feet
B . u,,~le from 1 to 2 feet
C . s~le from 2 to 3 feet
D c s~le from 3 to 4 feet
.e end b c repl icete S8q)les on 10/9/89
SM-14, SM-lS, and SM-16 samples located in west marsh
All other samples located in east marsh
:u
-------
Table 8. Continued Sediment Chemistry Results
Sample Site and Dote
SM-14 SM-15A SM-15B SM-15C SM - 150 SM-16
9/26/89 9/26/89 9/26/89 9/26/89 9/26/89 9/26/89
Parameter
Al\.J1Iinun (mg/kg) 500J 5600J 8100J 7700J 3300J 7200J
Antimony (mg/kg) 200 80U 90U 90U 40U 500U
Arsenic (mg/kg) 3U au 6U 2U 2U au
Bari\.J1l (mg/kg) 17 60U 30U 20U 20U 70U
Beryl I 1\.J1I (mg/kg) .8loU 4.4U 1.9U 1.4U 1.2U 5.1U
Cacini \.J1I (mg/kg) 4UJ 20UJ 5UJ 4UJ 1_9UR 40UJ
Calci\.J1l (mg/kg) 3200 8400 7600 5100 1700 13000
Chromi\.J1l (mg/kg) 4.5 35 15 6U 12 4'
Cobalt (mg/kg) 5U 30U 20U 8.7U 7.4U 40U
Copper (mg/kg) 6 24 21 5.2 2.5U 32
Iron (mg/kg) 1800J 4600J 2000J 630J 330J 9800
lead (mg/kg) 520 950 700 29 22 2800
Magnesi\.J1l (mg/kg) 130 490 340 220 110U 750
Manganese (mg/kg) 10U 37 18 200 15 32
Mercury (mg/kg) .21U 1. 1U .47U .36U .3,U 1.3U
Nickel (mg/kg) 20UJ SOU 40UJ 40UJ 30UJ 90UJ
Potassium (mg/kg) 230 2200 760 600 330U 1400
Selenium (mg/kg) .420 2.2U 2u 3U .62U 2.60
Silver (mg/kg) 4U 20U 5.60 4.3U 3.N 20U
Sodium (mg/kg) 5400 29000 2400 2600 2200 3900
Thallium (mg/kg) .42U 2.2U .93U .72U .62U 2.6U
Tin (mg/kg) NA NA NA NA NA NA
Vanadium (mg/kg) au 41 20U 20U 20U 46
Zinc (mg/kg) 17J 90J 78J 70J 19J 64J
fooTNOTES"*
*A-AVERAGE VALUE *NA-NOT ANALYZED *NAI-INTERfERENCES *J-ESTIHATED VALUE *N'PRESUHPTIVE EVIDENCE Of
PRESENCE Of MATERIAL *K-ACTUAl VALUE IS KN~N TO BE lESS THAN VALUE GIVEN *l-ACTUAl VALUE IS KN~N TO
BE GREATER THAN VALUE GIVEN *U-MATERIAl UAS ANALYZED FOR BUT NOT DETECTED. THE NUMBER [S THE MIN[MUM
QUANT I TAT ION lIMIT. *R-QC INDICATES THAT DATA UNUSABLE. COMPOUND MAY OR MAY NOT BE PRESENT.
RESAMPllNG AND REANALYSIS IS NECESSARY fOR VER[fICATION.
-------
-~--- - ---~ - -
APPENDIX II
RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
SCHUYLKILL METALS CORPORATION SITE
PLANT CITY, FLORIDA
I.
Responsiveness Summary Overview
The U. S. Environmental Protection Agency (EPA) held a public
comment period from August 17, 1990 through September 14, 1990 for
interested parties to comment on the Remedial Investigation/
Feasibility Study (RI/FS) report and the Proposed Plan prepared for
the Schuylkill Metals Corporation (SMC) site in Plant City,
Hillsborough County, Florida.
The Proposed Plan, which is included as Appendix A of this document,
provides a summary of the background information leading up to the
public comment period. Specifically, the Proposed Plan includes
information pertaining to the history of the SMC site, the scope of
the proposed cleanup action, the risks presented by the site, the
descriptions of the remedial alternatives evaluated by EPA, the
identification of EPA's preferred alternative, the rationale for
EPA's preferred alternative, and the community's role in the remedy
selection process.
EPA held a public meeting at 7:00 p.m. on August 30, 1990 at the
Plant City Public Library in Plant City, Florida to outline the
remedial alternatives described in the RI/FS report and to present
EPA's proposed remedial alternative for the soil, sediment, surface
water, groundwat~r, and marsh contamination.
The responsiveness summary, required by Superfund policy, provides a
summary of citizen's comments and concerns identified and received
during the public comment period, and EPA's responses to those
comments and concerns. All comments received by EPA during the
public comment period will be considered in EPA's final decision for
selecting the remedial altenative for addressing site risks.
A June 4, 1990 U.S. EPA Memorandum from the Office of Emergency and
Remedial Response and Office of Waste Programs Enforcement
determined that responsiveness summaries should reflect a genuine
attempt to come to grips with citizens' questions and concerns. The
Memorandum outlined the procedure to satisfy the needs of the public
and suggested that the concerns of the local individuals who have
identified themselves as living in the immediate vicinity of the
site be addressed by presenting these concerns in the responsiveness
summary. However, no citizens identified themselves as living in
the Lmmediate vicinity of the SMC site. Most of the attendees at
the public meeting were officials or representatives of officials.
The two comment letters received regarding the proposed plan and
RI/FS were from the potentially responsible parties and a local
official.
This responsiveness summary is organized into sections and
appendices as described below:
-------
I.
II.
III.
IV.
v.
-2-
Responsiveness Summary Overview. This section outlines the
purposes of the public comment period and the Responsiveness
Surnary. It also references the appended background
information leading up to the public comment period.
Backaround on Community Involvement and Concerns. This
section provides a brief history of community concerns and
interests regarding the SMC site.
Summary of Maior Ouestions and Comments Recieved Durina the
Public Meetina and EPA Responses to these Comments. This
section summarizes the oral comments received by BPA at the
August 30, 1990 public meeting, and provides BPA's responses
to these comments.
Written Comments Received Durina the Public Comment Period and
BPA Responses to these Comments. This section contains the
comments in the two letters received by EPA during the 4 week
public comment period, as well as EPA's responses to these
comments.
Remainina Remedial Desian/Remedial Action (RD/RA) Concerns.
This section contains the community's comments and concerns
that EPA should be aware of in design and implementation of
the wetland alternative.
Appendix A: The Proposed Plan Fact Sheet which was
distributed to the public prior to and during the public
meeting.
Appendix B: The sign-in sheet from the Public Meeting held on
August 30, 1990 in the Plant City Public Library.
-------
-3-
II.
Backaround on Community Involvement and Concerns
The Plant City community has been aware of the contamination problem
at the SMC site for several years. The community relations
activities were coordinated by the Florida Department of
Environmental Resources (FDER) during the RIfFS. FDER and EPA
conducted the following community relations activities for the SMC
site:
During the RIfFS, background information on the SMC site was
provided to city and state officials. Officials were
encouraged to keep their constituents informed about the
status of the site. EPA and FDER responded to inquiries about
the site from state and city officials and private citizens.
A repository for reports pertaining to the site at the Plant
City Public Library was established.
A meeting with the Plant City Manager and Plant City Engineer
was held in January 1988.
EPA and FDER visited the surrounding community by going door
to door in January, 1988. Concerns about the site were noted;
however, community interest was minimal.
A Fact sheet was distributed to announce the completion and
availability at the Plant City Public Library repository of
the RI, as well as to inform citizens of an upcoming public
meeting in February, 1988.
EPA and FDER held a public meeting in February 1988, to
present the results of the RI and respond to community
concerns.
A mailing list of interested parties was compiled to identify
citizens and officials who receive information such as site
fact sheets.
The Feasibility Study (FS) was released for public review and
comment in August 1989.
A proposed plan was released in August 1989, to announce a
public meeting and preferred alternative for remediation.
The August 1989, public meeting was postponed until the SHC
wetlands could be studied further.
A community relations plan, August 1989, is prepared to
address EPA's and FDER's role regarding community activities
for the SHC site.
Public comment period held in August and September, 1989 and
no comments are received.
-------
-4-
The community relations plan and mailing list were updated in
August 1990.
A proposed plan was sent out announcing the August 1990 public
comment period and public meeting.
A public comment period on the RI/FS and FS wetland addendum
is held from August 17, 1990 to September 14, 1990.
A public meeting is held at the Plant City Public Library on
August 30, 1990 to present EPA's preferred alternative for the
SMC site.
The surrounding neighborhood of the Schuylkill Metals facility was
solicited in January 1988, for their comments regarding the site.
Most residents were not concerned with any problems from the site.
During the public meeting held in February 1988 to present the
results of the Remedial Investigation, no concerns were expressed by
the attendees about site-related problems.
As part of EPA's responsibility and commitment to the Superfund
Program, the community has been kept informed of ongoing activities
conducted at the SMC site. EPA has established information
repositories where relevant site documents may be reviewed.
Documents stored at the Plant City Public Library repository include
the RI/FS report, the FS Addendum for the wetlands, the Wetland
Impact Study, Proposed Plan Fact Sheet, and the public meeting
transcript.
III.
Summary of Maior Questions and Comments Received Durina the
Public Comment Period and EPA's Responses to these Comments
Oral comments raised during the Schuylkill Metals Corporation public
meeting are summarized below together with EPA's responses to these
questions and comments.
Comment: One attendee at the Public Meeting inquired whether
contaminants have left the premises.
Response: Contaminants have left the premises, as defined by
property boundaries. Lead was detected on multiple occasions north
of the property boundary, which transects the east marsh. In
addition, elevated concentrations of lead were detected on two
surface water samples taken in the drainage culvert, located north
and south of the railroad.
Comment:
flow.
One attendee inquired as to the direction of groundwater
Response: Regionally, groundwater in the surficial aquifer is
moving in a easterly direction, reflecting the topography. Locally,
in the vicinity of the former holding pond, movement is radial due
to groundwater mounding.
Comment:
One attendee inquired as to when cleanup would begin.
-------
-5-
Response: Remedial action is anticipated to begin in 1991.
Schuylkill Metals Corporation has prepared initial Remedial Design
plans.
Comment: One attendee expressed that inundation of the east marsh
may not be straightforward.
Response: During the Remedial Design a hydrologic study will be
developed to permit design of the overflow weir.
Comment: One attendee inquired whether health risks exist for
people that live in the vicinity.
Response: It has not been determined that humans are at risk,
rather, the risk is primarily to the ecosystem. Risk to humans may
exist in the future if the site is not remediated; however, the
proposed remedy for the ecosystem shall also protect potential
threat to human welfare.
Comment: One attendee inquired as to how deep groundwater has been
contaminated. .
Response: A 50 foot thick confining unit, which is predominantly
clay should retard deeper migration of contaminants. Long-term
monitoring of the intermediate aquifer will insure that the
population is not exposed.
Comment: One attendee suggested that by leaving the wetlands
intact, the Agency would, in fact, be attracting organisms to an
area where they would be exposed to toxic levels of lead.
Response: The Agency recognizes that there is likely to be some
impact to aquatic life and that the habitat is going to be impaired;
however, the value of that habitat is more important than the
anticipated impacts from exposure to contaminated sediments. (See
the response to the final written comment on page 7).
Comment: One attendee inquired whether the estimated cost of the
Remedial Action could conceivably escalate to the point where it is
so expensive that work would have to stop.
Response: The estimated $ 6.2 million cost for Remedial Action
reflects adjustment for an anticipated rate of inflation and future
operation and maintenance cost. Thus, provided the scope of the
Remedial Action does not change significantly, the estimated cost
should not increase substantially.
IV.
Written Comments Received During the Public Comment Period and
EPA Responses to these Comments.
The written comments from the two letters regarding the SHC site
have been summarized below, together with EPA's responses to these.
questions and comments.
Comment: One commenter noted that the proposed remediation goal for
lead in the groundwater should be 50 ppb (based on Florida's Ground
Water Rule), as opposed to EPA'S cleanup goal of 15 ppb.
-------
-6-
Response: CERCLA and SARA require that Superfund remedies must be
protective of human health and the environment, and also specify the
use of State requirements as cleanup goals only if more stringent
than Federal standards. Lead concentrations of 50 ppb are no longer
believed to be protective of human health. Available data on blood
lead levels in children indicate that levels above 10 micrograms per
deciliter (ug/dL) of blood are associated with increased risk of
potentially adverse ~pacts on neurological development and diverse
physiological functions. In addition, lead levels of 15 ppb in
drinking water correlate well with blood lead levels of 10 ug/L.
In addition, the surficial aquifer in the vicinity of Plant City is
classified as a Class II aquifer. A well survey conducted during the
RI/FS identified 23 wells described as shallow or installed to a
depth of less than 25 feet within a 0.5 mile radius of the site.
Based on the above, the Office of Emergency and Remedial Response
recommends that a final cleanup level of 15 ppb for lead in
groundwater usable for drinking water is protective.
Comment: One commenter suggested that a treatability study should be
undertaken to determine whether the contemplated treatment technology
for groundwater will result in attainment of the ARAR.
Response: The Agency
order to identify the
the groundwater ARAR.
undertaken as part of
recognizes the need for treatability studies in
specific technology required for attainment of
It is anticipated that this shall be
the Remedial Design.
Comment: One cOmmenter was concerned that the Consent Decree should
contain a mechanism for a statistical evaluation of monitoring data
during the pump and treat operation. Such an evaluation would
identify potential residual concentrations of lead above 15 ppb,
notwithstanding extended groundwater withdrawal.
Response: Should groundwater concentrations reach asymptotic
concentrations above the 15 ppb cleanup goal, it may be necessary to
amend the ROD and waive certain groundwater requirements. The
protocol for determining when these levels are reached shall be
determined during the Remedial Design.
Comment~ One commenter inquired whether sufficient monitoring of
soil, sed~ent, surface water or groundwater had been performed to
determine whether migration had occurred off-site.
Response: Soil contamination occurred as a result of on-site burial
of battery casing material. Subsurface borings conducted during the
Remedial Investigation determined the horizontal, and to a lesser
extent, the vertical extent of soil contamination. Two sediment
samples were taken at off-site locations during the Remedial
Investigation. These were found to be at background levels and
considerably below those concentrations found in the marshes and
ditch. Surface water samples were also taken at two off-site
locations during the Remedial Investigation. In both instances, lead
concentrations were found at elevated concentrations.
One off-site temporary monitoring well was sampled during the
Remedial Investigation. Lead concentration in this well was found
-------
-7-
to be 0.03 mg/L. Approx~ately 23 shallow domestic wells were
identified during the RI, located within a 0.5 mile radius of the
site. These wells have not been sampled as part of the RI.
Currently, the EPA is evaluating county well records for groundwater
heavy metal concentrations in the site vicinity, including
downgradient locations. Additional necessary offsite sampling will
be addressed during remedial design.
Comment: One commenter noted that the precise
federal ambient water quality criterion (AWQC)
marsh should be dependent upon the hardness of
system.
Response: EPA agrees with this comment. The AWQC as it is adjusted
for water hardness will be the cleanup goal for treated waters
discharged to the east marsh. The numerical value established by EPA
has calculated the site's specific water hardness into its
determination of the cleanup goal for the east marsh surface water.
numerical value of the
for lead for the east
the water in the marsh
Comment: One commenter suggested the procedure to define the extent
of functional loss to the wetlands and the amount of mitigation for
such loss be outlined in the Consent Decree for the Remedial Design
and Remedial Action.
Response: We agree that the Consent Decree should contain a
provision defining the extent of mitigation required to compensate
for adverse ~pacts observed as a result of site-specific
contamination of the wetlands. These ~pacts are not based upon
assumed functional losses, but are based upon observed toxic effects,
bioaccumulation in fish tissues and violations of Ambient Water
Quality Criteria (AWQC) for the protection of aquatic life. These
observed ~pacts and effects clearly indicate that the ability of
aquatic organisms to fully utilize these wetlands as habitat is
~paired by toxicity associated with site-specific contamination,
mainly lead.
Mitigation, at a min~um, should consist of a one-for-one replacement
of ~pacted and/or impaired areas with uncontaminated (and therefore
presumably fully functional) wetland areas. This recommendation is
based upon an approach to wetlands protection that recognizes the
value of habitat for aquatic and wetlands species in addition to the
value of preventing unacceptable levels of adverse impacts associated
with exposure of wildlife species to toxic contaminants. One
principle that should be kept in mind is that, in the assessment of
exposure to toxics, the concept of protecting individuals of a given
species is applicable only to humans (and perhaps to small local
populations of threatened or endangered species). In assessing
exposure to other species, the overall guiding principle is to
maintain a breeding population of sufficient size such that the
species, rather than individual members of that species, is not
threatened or endangered. By leaving some contamination in place at
the existing marshes at the site, aquatic and wetlands species will
be exposed to toxic effects, reducing the ability of that .
sub-population to fully utilize that impacted habitat. By providing
mitigation in the form of restored or reconstructed wetlands,
however, a habitat is provided that can be utilized to the maximum
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-8-
extent possible, in addition to the remaining impaired wetlands whic~
now exist. This insures that the species populations in the area do
not experience any 10ss of fully functional habitat, protecting the
long-term viability of those species.
v.
Remaining Remedial Desian/Remedial Action (RD/RA) Concerns.
Public comments and concerns that EPA should be aware of during
design and implementation of the wetland alternative will be
addressed in the remedial design. Remedial design documents (i.e.
Remedial Design Work Plan, Remedial Design Reports) will be
available in the public repository in a timely manner to appraise the
community of project progress. The community will be made aware of
any major changes to the remedy made during project design.
-------
APPENDIX A
PROPOSED PLAN FACT SHEET
-------
&EPA
SUPERFUND
PROPOSED PLAN FACT SHEET
SCHUYLKILL ~IETALS CORPORATION SITE
Plant City, Florida
August 1990
~JRODUcrION
This Proposed Plan Fact Sheet on tbe Schuylkill
Metals Corporation site (SMC site) in Plant City,
Hillsborough County, Florida has been prepared by
the Region IV office of the U.S. Environmental
Protection Agency (EP A) . Terms in italic print are
defined in a glossary at the end of this publication.
This Proposed Plan identifies the preferred
alternative for cleaning up tbe SMC site. In
addition, the Proposed Plan includes summaries of
other alternatives analyzed for this site. EPA, in
consultation 'With the Florida Department of
ED\ironmental Regulation (FDER), will select a
fInal remedy for the site onJy after the public
comment period bas ended and the information
submitted during this time has been reviewed and
considered by both agencies.
EP A is issuing the Proposed Plan as part of its
public participation responsibilities under section
117(a) of the CompreheJ1si\"e Em'irOl1memal
Response, Compensation and Liability Act
(CERCLA). The Proposed Plan summarizes
information that can be found in greater detail in
the Feasibiliry Srudy (FS) Report, Wetland
Addendum to the FS and other documents
contained in the Admillisrrative Record for this site.
EPA and the State encourage the public to review
these documents to gain a more comprehensive
understanding of tbe site and tbe site-specif:c
Superfund activities that have been conducted. The
Administrative Record, a fIle which contains tbe
information upon which the selection of the
response action will be based, has been placed at
the infonnation repository located at tbe:
Plant City Public Library
501 North Wheeler Street
Plant City, Florida 33566
(813) 752-8685
Contact: Mrs. Treva Moore
SITE BACKGROUND
The SMC faci1ity is 10cated at 402 South Woodrow
Wilson Street in the southwestern portion of Piant
City, Florida. The facility covers an area of
approximately 17.4 acres; an 8-foot chain-link fence
and locked entry gates surround all but the east side
of the property, which is bounded by marsh land
(See Figure 1).
In 1972, SMC began operations as a batrer:"
recyc1ing facility. The rubber and plastic batter:.
casings were chipped and initial1y used for fill in the
process area and later marketed for rec1amation.
Prior to 1981, acidic wastewater from the washdo\>'7.;
of battery chips was stored onsite in an
Dates to Remember
.
Public comment period on remedial alternatives; August 17 - September
14, 1990
. Public Meeting
Date: August 30, 1990
Time:: 7:00 p.m.
Place: Plant City Ciry Hall
301 Whee1er Street
Plant City, Flor:da 33566
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Site Location Map
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SCHUYLKill "'EH.LS CORPORATION
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GEN[Rt.L SITE MAP
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approximately 2.2 acre, unlined holding pond.
Initially lime, and later ammonia, were used for pH
adjustment of the waters stored in the holding pond.
Acidic water discharges to the holding pond ceased
after 1981. In June 1986, SMC's Plant City facility
. discontinued operations as a battery recycling
facility.
Data collected from an initial investigation carried
out by the Field Investigation Team (FIT), was used
to develop a Hauud Ranking System (HRS) score.
The site received a score of 59.19. Sites receiving
an HRS score of 28.5 or above may be added to the
National Priorities List (NPL). The SMC facility
was placed on the NPL in 1982. FDER and SMC
entered into a Consent Order in January 1986,
requiring SMC to perform a remedial
investigation/feasibility study (RIfFS) as required by
CERCLA. Sampling results indicated elevated
levels of lead and chromium in the surficial aquifer,
and elevated levels of lead in the holding pond
surface water, perimeter ditch, process area soils,
and marsh. In 1989, EPA conducted additional
studies on tWo marshes located on the western and
eastern portions of the site and developed a
Wetland Addendum to the FS in 1990 regarding
marsh remediation. Sampling results from the
additional studies detected levels of lead exceeding
Florida Water Quality Standards in marsh surface
water.
SCOPE OF PROPOSED ACTION
As indicated in the RIfFS, the site in its present
condition poses a minimal threat to public health,
though trespassers could be at a risk through direct
contact with or ingestion of contaminated media.
However, if left unremediated, lead-bearing soils at
the site could serve as a source for future
contamination of area surface water and
groundwater. The present state of contamination
within the marshes poses a threat to the
environment. Lead exceeded safe levels in the
groundwater; however only in the upper aquifer.
The deeper aquifer, the source for drinking water,
. currently shows no evidence of contamination from
this site. The remedy proposed addresses these
concerns by treating all areas of contamination.
SUMMARY OF REl\fEDlAL ALTERNATIVES
ANALYZED
This section addresses the remedial alternatives
identified and evaluated in: 1) The FS Report for
soil, surface water, and groundwater remediation;
and 2) The Addendum to the FS for marsh
remediation.
Soli. Surface Water. and Groundwater Remediation
The FS evaluated 16 alternatives in detail for
remediation of the soils in the processing area, pond
and ditch; surface water; and groundwater. Each
alternative falls into one of the following general
categories:
. No Action (Alternative 1). The Superfund
program requires that the -No Action'
Alternative be evaluated at every site to provide
a baseline for evaluation of other alternatives.
Under this alternative, EPA would take 110
further action at the site to prevent exposure to
the contaminants except to continue groundwater
monitorin&
. Source containment with groundwater collection
and treatment (Alternatives 2, 3, 4, 5). This
involves capping contaminated soils and installing
a slurry wall to minimize leaching of soils and
migration of contaminated groundwater.
Groundwater and surface water would be treated
by ion medium filtration or electrochemical
precipitation with clarification or microfi/tration.
. Source removal, offsite disposal and groundwater
collection and treatment (Alternatives 6 and 7).
This category involves excavation of
contaminated soils/sediments wid, offsite
disposal at a permitted hazardous waste disposal
facility. Groundwater and surface water would
be treated as stated above.
. Source removal, onsite treatment, offsite disposal
and groundwater collection and treatment
(Alternatives 8, 9, and 10). This category
involves chemical fixationjheap leaching of
contaminated soils/sediments with offsite
disposal of separated debris.
Groundwater/surface water would be treated as
stated above.
. Source removal, onsite treatment and
groundwater collection and treatment
(Alternatives 11, 12, 13). This category involves
chemical fIXation or heap leaching of
contaminated soils/sediments and onsite
incineration of separated debris. Groundwater
and surface water would be treated as stated
above.
. Source removal, onsite treatment, debris
recycling and groundwater collection and
treatment (Alternatives 14, 15, 16). This
category involves chemical fIXation or heap
leaching of contaminated soils/sediments and
3
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recycling of separated debris. Groundwater and
surface water would be treated as stated above.
For a detailed listing and explanation of all
alternatives considered, please refer to the FS
Report, available at the information repository.
Marsh Remediation
The Addendum to the FS evaluated the following
four alternatives for marsh remediation:
Alternative 1: No Action. The Superfund program
requires that the -No Action" Alternative be
evaluated at every site to provide a baseline for
evaluation of other alternatives. Under this
alternative, EP A would take no further action at the
site to prevent exposure to the contaminants, except
monitoring, and requires no compensation for
damage to wetlands.
Alternative 2: Mechanical controls. This alternative
involves fencing and monitoring for the west marsh
and flood control gates to provide continued surface
water inundation, resulting in anaerobic sediments
and monitoring for the east marsh.
Alternative 3: Low permeability cover, mitigation,
and monitoring. This alternative involves installing
. a clay cap over the wetland to minimize leaching of
contaminants and diversion drainage ditches to
control surface water runoff.
Alternative 4: Sediment removal. This alternative
involves sediment removal to a depth of two feet
and solidification of sediments, and (a) onsite
natural contour restoration of the area between the
two marshes or (b) backfilling with ,urface
contouring for flood control, and monitoring
including biomonitoring.
EVALUATION OF ALTERNATIVES
This section compares the performance of the
alternatives identified in the FS Report and
Addendum to the FS against the nine eiteria that
are required to be used to evaluate Superfund
remedies. The evaluation eiteria, summarized
below, are specified in EPA's Guidance for
Conducting Remedial Investigations and Feasibility
Studies under CERCLA (OSWER Directive 9355.3-
01). A summary of the evaluation criteria is
provided in a chart on page 5 of this fact sheet.
Soil. Surface Water and Groundwater Remediation
The -No Action" Alternative was eliminated from
detailed evaluation on the basis that it is not
protective of human health and tbe envin
other alternatives would fulfill tr;~ - ob~e
alternatives except the flTst WoU'? cc
ARARs and could be effecti\ 'imr
Alternatives 2-7 would require minim;:
implement and thus be most effective in
term; however, though Alternatives 8-16 ,
longer to implement, they would have an i
impact in attaining cleanup goals. In tern
term effectiveness, Alternatives 2-5
permanent solutions and do not ad,
concern; Alternatives 6 and 7 provid~'a
solution for this particular site, but DC
hazardous material itself; the long-term
Alternative 8-16 are unknown, but ba.~?d
studies are believed to have long-term' efft
Alternatives 8-16 reduce the toxicity or n
contaminants at the site; Alternatives 2 an
reduce toxicity. Costs for Alternatives
from approximately $3 to $5 million, Alter
7 from $16 to $183 million and Altern"
from $6 to $10 million. EP A will CQ!
FDER on the alternative that will be imr
at the site; acceptance by the communi
evaluated based on comments received at
meeting and during the public comment:
As a result of the evaluation an' ~omr
possible alternatives, two specifi\ ,1-na!
determined to best satisfy the eva......lon ,
a whole. The alternatives determir.
appropriate in the FS for soil, surface\'
groundwater remediation are:
Alternative 5c: Installation of a slurry w;:
process area soils, installation of leachate
trenches in the process area soils, cappi
soils with an impermeable membrane su
and treatment of surface waters and gro
with ion medium filtration.
Alternative 15c: Excavation of process ;
and sediments from the ditch, separatioJ
and debris by screening, treatment of
sediments by chemical f1X8tion, grinc
washing of debris for recycling and tree
surface waters and groundwater by ion
filtration. Verification sampling ~ ~
sediments would be conducted to as!
cleanup goals are met.
"
Marsh Remediation
The "No Action" Alternative (Ar ~ativ
eliminated from detailed evalua bn
that it is not protective of humau ';ea]tr
eO\;ronment; all other alternatives would
objective.
4
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SUMMARY OF EVALUATION CRITERIA
. Overall Protection of Human Health and the. Short-Term Effectiveness -Refers to be
Environment - Addresses whether or not a the remedy achieves protection, as
remedy provides adequate protection and potential adverse impacts on human t
describes how risks posed through each pathway the environment that may occu
are eliminated, reduced, or controlled through construction and implementation of th:
treatment, engineering controls, or institutional
controls.
. Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs) -Addresses
whether or Dot a remedy will meet aU of the
ARARs or Federal and State environmental
statutes and/or provide grounds for invoking a
waiver.
. Long-Term Effectiveness and Performance -
Refers to the magnitude of residual risk and the
ability of a remedy to maintain reliable protection
of human health and the environment over time
once cleanup goals have been met.
. Reduction of Toxicity, Mobility, or Volume
Through Treatment - Refers to the anticipated
performance of the treatment technologies that
may be employed in a remedy.
. Implementability - Refers to the ted
administrative feasibility of a remedy,
the availability of materials and service
for implementation.
. Cost - Includes capital and oper
maintenance costs.
. State Acceptance - Indicates whether
its review of the RIfFS and Proposec
State concurs with, opposes, or has ne
on the preferred alternatives.
. Community Acceptance -Assessed in
of Decision (ROD) following a revi
public comments received the followin;
Plan.
Alternative 2, mechanical controls, would be
implemented in the least amount of time and
achieve the goal of maintaining existing functional
value of the east marsh. Additional time would be
required for implementation of Alternative 4,
sediment removal and solidification. Alternative 3,
capping, would require less time for implementation
than Alternative 4. Alternative 2, fencing for the
west marsh does not provide a long-term solution.
The long-term effects of Alternative 2 for flooding
the east marsh, and Alternative 4 for sediment
solidification of both marshes are unknown at this
time. However, based on site-specific studies, it is
anticipated that Alternatives 2 for flooding the east
marsh and 4 would provide long-term effectiveness.
Alternative 3, capping, would also provide long-term
effectiveness. Alternative 2 for the east marsh and
Alternative 4 would both reduce the toxicity or
mobility of contaminants at the site; however
Alternative 4 may increase the mobility of
contaminants in the short-term. Alternative 2 for
the west marsh and Alternative 3 do not reduce
toxicity. The cost estimated for the alternatives are:
Alternative 2, east marsh - $674,000; Alternative 2,
west marsh - $214,000; Alternative 3 - east marsh -
$3,255,00; Alternative 3, west marsh - $978,000;
Alternative 4(a), east marsh - $1,047,000 -
$1,641,000; Alternative 4(a) west marsh - $545,000;
Alternative 4(b), east marsh - $4,676,000 -
$8,411,000; and Alternative 4(b), west marsh -
$2,572,000 - $2,664,000.
The total cost for site cleanup is estim
between $7 - $15 million.
PREFERRED ALTERNATIVES
Soil. Surface Water and Groundwater
Although Alternative 5c is the less ex;
two, Alternative 15c is deemed
environmentally sound as it eliminate
simply contains the source of conta
imposes fewer limits on future
Alternative 15c is therefore the altern~
by FDER and EPA for soil, surfac
groundwater remediation at the SMC
Marsh Remediation
The preferred alternative is Alte
combination with Wetland mitigatior
2 includes flooding the cast marsh a:
west marsh. Extensive biomonitoring
performed at both marshes. Impleml
be achieved within a short period of L
maintain the present functional \
marshes. This alternative provid
protection from cattle and human e.
west marsh, and long-term exposun
both marshes. Flooding would redul
of metal contamination. This alte
accepted by the State and is cost df
and sediment removal do not meet
criteria, and capping is not co~:der:
5
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and sediment removal do not meet either of these
criteria, and capping is not considered a treatment.
However, Alternative 2 requires mitigation to
replace loss in the functional value of the marshes.
. Creation or enhancement of a wetland will
compensate for the functions lost or affected in
these marshes. The location, size, and number of
the wetlands will be determined by the State and
EP A. The result will be an overall increase in the
acreage of wetlands.
THE COMMUNITY'S ROLE IN THE
SELECIlON PROCESS
EPA solicits input from the community on the
cleanup methods proposed for each Superfund
response action. EP A has set a public comment
period from August 17 - September 14, 1990, to
encourage public participation in the selection
process. The comment period includes a public
meeting near the site during which EPA and FDER
will present the Proposed Plan, answer questions,
and accept oral and written comments.
Comments will be summarized and responses
provided in the Responsiveness Summary section of
the ROD. To send \...ritten comments or obtain
further information, contact:
Barbara Dick
Remedial Project Manager
South Superfund Remedial Branch
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 347-2643
Betty Winter
Community Relations Coordinator
South Superfund Remedial Branch
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 347-2643
As part of the Superfund program, EPA is
providing communities with the opportunity to apply
for Technica.1 Assistance Grants (TAGs). These
grants (one per site up to $50,(00) are designed to
enable community groups to hire a technica.1 advisor
or consultant to assist them in interpreting or
commenting on site findings and proposed remedial
action plans.
Citizens who ar: interested in the TAG program
may obtain an application package by calling or
writing the following EP A Region IV Technical
Assistance Grants Contact:
Denise Bland
Technical Assistance Grants Specialist
Grants and Contracts Support Unit
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 347-2234
GLOSSARY
Administrative Record: A rue which is maintained
and contains all information used by the lead agency
to make its decision on the selection of a response
action under CERCLA. This file is required to be
available for public review and a copy is to be
established at or near the site, usually at an
information repository. A duplicate file is
maintained in a central location, such as a regional
EPA and/or State office.
Anaerobic: Where there is no air or free oxygen.
Aquifer: An underground rock formation composed
of material such as sand, soil, and/or gravel that
can store and supply groundwater to wells and
springs.
Biomonitoring: The periodic evaluation of
organisms residing in a defmed area.
Chemical Fixation: A technique where
contaminated soils are combined with other
ingredients (commonly cement) which immobilize
the contaminants.
Clarification: A process in which liquid is made
clear and freed from impurities or contaminants.
Comprehensive Environmental Response,
Compensation and UabiJity Act (CERCLA): A
Federal law passed in 1980 and modified in 1986 by
the Superfund Amendments and Reauthorization
Act. The Acts created a special tax that goes into a
trust fund, commonly known as Superfund, to
investigate and cleanup abandoned on uncontrolled
hazardous waste sites. Under the program, EP A
can either pay for site cleanup when the responsible
parties cannot be located or are unwilling or unable
to perform the work, or take legal action to forc~
responsible parties to cleanup the Superfund site or
reimburse EPA the cost of the cleanup.
6
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Consent Order: A legal agreement between the
state and the potentially responsible parties (PRPs)
whereby the PRPs agree to perform or pay the cost
of a site cleanup. The agreement describes actions
to be taken at a site.
Electrochemical Precipitation: A technique where
an electric.a1 current is applied to contaminated
water causing contaminants to precipitate. The
precipitate is then separated from the water by
settling (clarification) or by passing the water
through a fine filter (microfiltration).
FeasibiHty Study (FS): See
InvestigationfFeasibility Study (RI/FS).
Remedial
Field Investigation Team (FIT): A team of EPA
personnel who conduct field studies to determine if
a site poses a significant enough potential risk to
warrant an investigation.
Groundwater: Water found beneath the earth's
surface that fills pores between materials such as
sand, soil, or gravel. In an aquifer, groundwater
occurs in sufficient quantities that it can be used for
drinking water, irrigation, and other purposes.
Groundwater Monitoring: The periodic evaluation
of the hydrogeologic conditions and quality of
groundwater underlying the site.
Hazard Ranking System (HRS): A scoring system
used by EPA and the State to evaluate relative risks
to publj.c health and the environment from releases
or threatened releases of hazardous substances. An
HRS score is c.a1culated based on actual or potential
release of hazardous substances through the air,
soils, surface water or groundwater. If a site scores
above 28.5, the HRS score is a primary factor in the
placing of that site on the National Priorities List.
Heap Leaching: A technique where a solvent is
used to remove lead from soil, rendering it non-
hazardous. The lead is then recovered from the
solvent solution for recycling.
Incineration: Burning of certain types of solid,
liquid, or gaseous materials under controlled
conditions to destroy hazardous waste.
Information Repository: A rue containing current
information, technical reports and reference docu-
ments regarding a Superfund NFL site. The
information repository is usually located in a public
building that is convenient for local residents, such
as a public school, city hall, or a library. As the site
proceeds through the Superfund Remedial Process,
the rue at the information repository is continually
updated.
Inundation: To cover v.ith or as v.ith a flood,
deluge.
Ion Medium Filtration: A technique where
contaminated water is circulated through a "metal
grabber" medium which extracts metals from the
water.
Leaching: The extraction of a soluble substance
from a material caused by water filtering down
through the material.
Microfiltration: The separation of very small
particles or impurities from a liquid by means of a
mter.
Mitigation: The reduction of hazards posed by an
NPL site to human health and the environment.
National Priorities List (NPL): A listing of the
most serious, uncontrolled or abandoned bazardous
waste sites identified for possible long-term
remedial response using Superfund monies. The list
is updated yearly as required by the National
Contingency Plan of CERClA. Sites are placed on
the I'.TPL based on their HRS score.
Preferred Alternative: After evaluating and examin-
ing the various remedial alternatives, EP A selects
the best alternative based on relevant cost and non-
cost factors.
Proposed Plan: A public participation requirement
of SARA in which EP A summarizes for the public
the preferred cleanup strategy and the rationale for
the preference, reviews the alternatives presented in
the detailed analysis of the remedial
investigation/feasibility study, and presents any
waivers to cleanup standards of U21( d)( 4) which
may be proposed. This may be- prepared either as
a fact sheet or as a separate document. In either
case, it must actively solicit public review and
comment on all alternatives under Agency
consideration.
Record of Decision (ROD): A public document
that explains which cleanup alternative v.ill be used
at a National Priorities List site and the reasons for
choosing that cleanup alternative over other
possibilities.
Remedial Alternatives: A list of the most tecb.
nologically feasible alternatives for a remedial
strategy.
7
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Remedial Investigation and Feasibility Study
(RIfFS): Two distinct but related studies, normally
conducted together, intended to define the nature
and extent of contamination at a site (RI) and to
evaluate appropriate, site-specific remedies
necessary to achieve fmal cleanup at the site (FS).
Responsiveness Summary: A summary of oral
and/or written public comments received by EPA
during a comment period.
Slurry Wall: An impermeable wall that is installed
in the subsurface surrounding contaminated soils.
Composed of a mixture of soil and clay, this waIl
will prevent contaminant migration.
8
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Name
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Affiliation
Telephone
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MAILING LIST ADDmONS
To be placed on the mailing list for the Schuylkill Metals Corporation Site
- please complete this form and mail to:
Ms. Betty Winter
- Community Relations Coordinator, U.S. EPA, Region IV
345 Courtland Street, NE, Atlanta, GA 30365
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9
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APPENDIX B
PUBLIC MEETING SIGN-IN SHEET
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Schuylkill MetalsTTorporation Site
Public Meeting Sign In Sheet
August 30, 1990
Name
Address
Telephone j
Number !
Affiliation
Do you want to
be included on
the mailing list?
How did you
learn about
this meeting?
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