United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R04-91/092
March 1991
Superfund
Record of Decision:
Sherwood Medical Industries,
FL
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50272-101
REPORT DOCUMENT A T10N 1" REPORT NO. I ~ 3. Reclpient'a AcceaaIon Mo.
PAGE EPA/ROD/R04-91/092
4. 111Ie and Sub1I1Ie 5. Aepor1 Dale
SUPERFUND RECORD OF DECISION 03/27/91
Sherwood Medical Industries, FL
6.
First Remedial Action
7. Author(8) 8. F\8rIonnlng Orgmlza1lon A8pL Mo.
t. Perfonnlng Org81nlza1lon Name and Addre.. 10. ProjKtfT-*1Work UnIt Mo.
11. Contnct(C) or Grant{G) Mo.
IC)
(G)
1 ~ Sponaorlng Org8nization Name and Addre.. 13. Type of Repor1 & PerIod CoWlf8d
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplementarf Holea
16. Aba1Jact (UmI1: 200 wolda)
The 42-acre Sherwood Medical Industries (SMI) site is an active medical supply
manufacturing facility just outside the city limits of Deland, Volusia County,
Florida. Land use in the area is commercial and residential. Lake Miller is along
the western boundary, and a wooded swampy area is located to the south of the site.
The underlying Floridan Aquifer, which is restrictively connected to the contaminated
surficial aquifer, is the drinking water source for local residents. From 1959 to
present, SMI has used the site for manufacturing medical supplies, primarily
hypodermic needles. From 1971 to 1980, SMI disposed of approximately 2 tons of
liquid and sludge waste into two unlined percolation ponds onsite. At that time,
solids were removed from the ponds and placed into onsite, unlined impoundments.
From 1980 to 1982, SMI analyzed the contents of the impoundments and disposed of the
wastes in an offsite landfill. Initial site investigations conducted by SMI and the
State identified ground water contamination in onsite wells. In 1987, the State
requested that SMI perform additional investigations to determine the nature and
extent of ground water contamination, and to evaluate the need to implement interim
remedial measures. Based on the observed onsite contamination of the Floridan
(See Attached Page)
17. DocumenI AnIIly8la .. Deacripton
Record of Decision - Sherwood Medical Industries, FL
First Remedial Action
Contaminated Medium: gw
Key Contaminants: VOCs (PCE, TCE)
b. IdenlitieralOpen-Ended Terma
Co COSA 11 FIeIdIGrcql
18. Avllilabilly St81emen1 11. Secui1y CI8aa (nIla Report) 21. Mo. of Pagea
None 22
20. Secui1y a... ('JtQ Page) 22. PrIce
Nonf!
l 0". 0
(See ANSl-Z3t.18)
See ".tructi
nRe",,-
(Formetfy NTlS-35)
D8pu1ment of Commerce
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EPA/ROD/R04-91/092
Sherwood Medical Industries, FL
First Remedial Action
Abstract (Continued)
Aquifer, the State required SMI to conduct extensive ground water testing and
monitoring, and to provide bottled water to an affected residence. In 1990, the State
approved SMI's design work plan, which outlined further interim measures to be
conducted at the site including installation of a ground water pump and treat system.
This Record of Decision (ROD) addresses an interim remedy for the surficial aquifer to
prevent the contaminant plume from spreading offsite and migrating vertically into the
Floridan aquifer. Future RODs will fully address the principal threats posed by the
conditions at the site. The primary contaminants of concern affecting the ground water
are VOCs including PCE and TCE.
The selected remedial action for this interim remedy includes installing a system of
recovery wells in the onsite surficial aquifer; and pumping and treatment of
contaminated ground water using air stripping, followed by onsite discharge of the
treated water to Lake Miller. The estimated capital cost for this interim remedial
action is $400,000, with an annual O&M cost of $35,000.
PERFORMANCE STANDARDS OR GOALS: Treated ground water will meet all Federal and state
water quality standards for discharge to surface water. Final clean-up levels will be
addressed in a future ROD.
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'~i
Record of Decision
Inter~ Action for the Surficial Aquifer
Declaration
SITE NAMB ARD LOCATION
Sherwood Medical Industries Site
DeLand, Volusia County, Florida
STATEMENT OF BASIS ARD PURPOSB
This decision document presents the selected interim action for the
surficial aquifer at the Sherwood Medical Site (the Site), in
DeLand, Volusia County, Florida, which was chosen in accordance with
CERCLA, as amended by SARA, and, to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan
(NCP). This decision is based on the Administrative Record file for
this Site.
The State of Florida has concurred with this interim action for the
surficial aquifer.
ASSESSMENT OF TBB SITH
Actual or threatened releases of hazardous substances from
Site, if not addressed by implementing the response action
in this Record of Decision (ROD), may present a current or
threat to public health, welfare, or the environment.
this
selected
potential
DBSCRIP'l'IOR OF TBB RBIIBDY
The major goal of this interim action is to prevent the spread of
contaminated. groundwater in the surficial aquifer from migrating off
the Sherwood Site boundaries and to prevent the potential of
vertical migration downward into the Floridan aquifer. "The
surficial aquifer under the Site is contaminated with volatile
organic compounds (VOCS). The major VOC contaminants in the
surficial aquifer, trichloroethylene and tetrachloroethylene,
greatly ezceed both state and federal groundwater standards.
Although the surficial" aquifer is not the source of drinking water
for the local residents, under future use scenarios it presents a
threat to human health and the environment. This interim action is
intended to prevent the spread of contaminated groundwater by
treating the surficial aquifer early in the Superfund process before
the Remedial Investigation/Feasibility Study (RI/FS) at the Site has
been completed. This is not the final action planned for the
surficial aquifer at the Site. Subsequent actions are planned to
fully address the principal threats posed by the conditions at the
Site. These actions will be defined when the RI/FS is complete.
'--.----.
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-2-
The major components of the interim action remedy include:
Installation of a system of recovery wells in the surficial
aquifer onsite.
Installation of an onsite air stripper to treat recovered
groundwater.
Discharge of treated groundwater into an onsite lake.
The estimated cost for the interim action remedy is $400,000 with an
annual operation and maintenance cost of $35,000. Present worth
cost could not be calculated because the number of years that the
interim action system will be in place is uncertain.
STA'l'tJ'l'ORY DETERMINATIONS
This interim action is protective of human health and the
environment, complies with Federal and State applicable or relevant
and appropriate requirements directly associated with this action,
and is cost-effective. This action utilizes permanent solutions and
alternative treatment technologies (or resource recovery), to the
maximum extent practicable, given the limited scope of this action.
Additionally, this interim action satisfies the statutory preference
for remedies that employ treatment that reduces toxicity, mobility,
or volume as a principal element. Because this interim remedy will
result in hazardous' substances"'remaining onsite above health-based
levels, a review will be conducted at least every five years after
commencement of the remedial action, to ensure that this remedy
continues to provide adequate protection of human health and the
environment. Of course, because this is an interim action ROD,
review of the Site is expected to be more frequent, and is, in fact,
continuing as part of the development of the final remedial.
alternatives for this Site. Subsequent actions are planned to
address fully the principal threats posed by the conditions at this"
Site.
MAR J 7 1991
~/11Ie
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Record of Decision
InterLm Action for the Surficial Aquifer
The Dee is ion SI11111ftAry
Sherwood Medical Site
DeLand, Volusia County, Plorida
Prepared by.
u. S. Bnvirolll88ntal Protection Agency
Reqion IV
Atlanta, Georgia
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1.0
2.0
3.0'
4.0
5.0
6.0
7.0
8.0
9.0
10.0
11.0
TABLE OF CONTENTS
Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Site Name, Location, and Description .........................1
Site History and Enforcement Activities ......................1
Highlights of Community Participation ........................5
Scope and Role of Response Action Within Site Strategy .......6
Summary of Site
6.1 Hydrology
6.2 Surficial
Characterizations ............................6
.........:................................... .6
Aqui fer. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Summary of Site
Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Description of Alternative................................. .10
8.1 Alternative 1 - No Action .............................10
8.2
Alternative 2 - Pump and Treat System .................10
Summary of Comparative Analysis of Alternatives .............11
9.1 Overall Protection of Human Health ,and the Environment.11
9 . 2 Compl iance with ARARs ................................. 11
9.3 Long-Term Effectiveness and Permanence ................11
9.4 Reduction of Toxicity, Mobility, or Volume of the
Contaminants Through Treatment ........................11
Short-Term Effectiveness.............................. 13
Cost. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
State Acceptance...................................... 13
C~DDDuni ty Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
'9.5
9.6
9.7
9.8
Selected Remedy............................................ 13
Statutory Determinations.................................... 14
11.1 Protective of Human Health and the Environment ........14
11.2 Attainment of the Applicable or Relevant and Appropriate
Requirements ( ~) ................................... 14
11.3 'Coat Effectiveness ....................................14
11.4 Utilization 'of Permanent Solutions and Alternative
Treatment Technology or Resource Recovery Technologies
to the Maximum Extent Practicable .....................15
11.5 Preference for Treatment as a Principal Element .......15
11.6 Documentation of Significant Changes ..................15
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Figure 2-1
Figure 2-2
Figure 6-1
Table 6-1
Table 9-1
LIST OF FIGURES
Geographic
Location Map.............................. 2
81 te Map ............................................. 3
Surficial Aquifer Monitoring Well Locations ..........8
LIST OF TABLES
VOC Analysis of the Surficial Aquifer
.................9
Glossary Of Evaluation Criteria ......................12
LIST OF APPENDICES
Appendix A - Responsiveness Summary
Appendix B - State's Concurrence Memorandum
~
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RECORD OF DBCISION
Interim Action for the Surficial Aquifer
The Dee is ion Smllllun.y
Sherwood Medical Site
DeLand, Volusia County, Florida
1.0
Introduction
The Sherwood Medical Site (the Site) was proposed for inclusion on
the National Priorities List (NPL) in December 1982. The Site has
been the subject of an Interim Remedial Measures Report (IRK)
performed by the responsible parties, Sherwood Medical, Inc.
(Sherwood) under the direction of the Florida Department of
Environmental Regulation (FDER). In July 1988, Sherwood retained
Roy F. Weston, Inc. (Weston) to perform IRK activities and initiate
the Remedial Investigation and Feasibility Study (RI/FS), as
specified in a Administrative Order on Consent entered into in
October 1987 with the u.S. EPA Region IV. The RI/FS is currently
. being conducted by Weston. .
2.0
Site Naae, Location, and Description
The Sherwood Site is located approximately three miles northeast of
Deland, Florida. Although close to Deland, the Site lies outside
the city limits in an unincorporated area of Volusia County. Figure
2-1 shows the geographic location of the Site. The Site occupies
approximately 42 acres, including a section of Lake Miller, located
along the Site's western boundary. u.S. Highway 92 runs along the
northern boundary of the Site, while a wooded, swampy area lies to
the south. A commercial and residential area along Kepler Road is
located to the east of the Site. The SherWood property is currently
occupied by several manufacturing buildings, a biological
laboratory, sizeable parking areas, plus additional structures,
including an industrial wastewater treatment facility. A Site map
is presented as Figure 2-2.
3.0
Site History and Bnforcement Activities
Sherwood Medical Industries has occupied the property since 1959 for
the manufacturing of medical supplies, primarily hypodermic
needles. Industrial operations currently include the grinding hub
processing, and cleaning of stainless steel and aluminum parts used
to manufacture hypodermic syringes. Sherwood also molds plastic
syringes and conducts in-house quality assurance and quality
control. .
The Sherwood facility pumps approximately 175,000 gallons of water
per day from the underlying Floridan Aquifer. Approximately 150,000
-1-
.'
-------
~
<'<1-
~
Volu8la
County
~~
~
.
o
30
Mlle.
60
Soun:e: ERM
FIGURE 2-1 GEOGRAPHIC LOCATION MAP
SHERWOOD MEDICAL COMPANY
DELAND. FLORIDA
-2-
-------
1-"'
am
I.JJte
1/111..
,
I
,
I
,
I
,
I
,
I
, ~
, I
I
,
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fi
ii
li
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- .II
- _._.~.a~.~~~
.-.-
-
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-
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0.--.4~
-
".
--
LEGeND
- . - Pr-'Y 11,.
- Paved roatJ
- F-
r:::::J SuI/a/fig
'ilQtJIt1$
SWIIIIID
FIGURE 2-2
200
---"
FACILITY SITE MAP
o
,
- - .
-)-
POOR QUALITY
ORIGINAL
-':C
( ,
. i
O\_! -
~
U ,- ~/ 0 .:
(1/' f
~!
,'-.
r '\ \ .
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. ,
-------
gallons of the water is used for industrial processes and the
remainder (25,000 gallons) is used for domestic purposes. Water
drawn for industrial needs is used for cleaning, manufacturing, and
cooling/evaporation processes. Several manufacturing steps result
in wastewater which must be treated. An industrial wastewater
treatment (IWT) facility was constructed in July 1983 to meet the
Florida Drinking Water Standards. This facility is permitted by
FDER to receive and treat wastewater from the plant, and to
discharge the resulting effluent. The.treated effluent is currently
disposed of by percolation and evaporation in the denitrification
field and perimeter percolation pond. In late 1985, Sherwood
Medical Industries installed an air stripper to pretreat production
water used onsite in the facility's operations. The air stripper
removes chlorinated solvent compounds existing in the water pumped
from the Floridan Aquifer production wells onsite.
Between 1971 and 1980, the company disposed of approximately two
tons of liquid and sludge waste into two unlined percolation
ponds. During this time, solids were removed from the ponds and
placed into onsite, unlined impoundments. From 1980 and 1982,
Sherwood analyzed the contents of the impoundments and disposed of
the wastes in an offsite landfill.
In December 1982, the Sherwood site was proposed for inclusion on
the National Priorities List at the request of the FDER because of
the threat of contamination from wastes stored in the holding ponds
and impoundments. FDER.initially believed that the removal of
wastes from onsite storage areas was sufficient to eliminate the
threat of contamination. However, subsequent testing conducted by
Sherwood Medical and FDER revealed groundwater contamination in
onsite wells.
In October 1985, Sherwood Medical notified EPA that they would
perform a focused Remedial Investigation (RI) at the site. During
EPA's negotiations with Sherwood to conduct the RI, FDER and the
Florida Department of Health and Rehabilitation Services (HRS)
received health related complaints on private wells from nearby
residents. Water samples were collected and analyzed in September
1986 from off8ite private wells and Sherwood's onsite supply well.
Chlorinated 80lvents we~e detected in samples from the onsite supply
wells, but no violations of drinking water standards were found in
private well samples. Additional samples collected in October 1986
confirmed on8ite contamination of the Floridan Aquifer. In light of
this information, it was agreed that a full scale Remedial
Investigation/Feasibility Study (RI/FS) would be conducted at the
Site. In October 1987 Sherwood Medical entered into a
Administrative Order on Consent to preform the RI/FS.
In August 1987, at FDER's request, Sherwood sampled the onsite
Floridan water wells and a downgradient residential well to assess
the extent of contamination and evaluate the need to implement
interim remedial.measures (IRM) to control and treat the
-4-
-------
I~
contamination of the Floridan Aquifer. Based on the observed onsite
Floridan Aquifer contamination, FDER recommended an IRK action be
undertaken prior to the completion of the RIfFS. Sherwood developed
an investigation plan to evaluate the Floridan Aquifer and the
shallow aquifer through a sampling program. Field testing was
completed in April of 1989.
As part of the IRK, Sherwood Medical has been testing all of the
private wells along Kepler Road every six months. The wells are
immediately adjacent to the site and extend from the intersection of
U.S. 92 and Kepler Road through the intersection of Marsh and Kepler
Roads. Sherwood is also monitoring the only downgradient private
well to the west of the site, just across Lake Miller. The
investigation detected one private well with VQC concentrations
above safe drinking water standards. This well is located on Kepler
Road, and the test .results indicated tetrachloroethene (PCE) and
trichloroethene (TCE) concentrations of 11 ppb and 4 ppb,
respectively. The applicable Florida Drinking Water Standard for
both PCE and TeE is 3 ppb. Since the discovery of this
contamination, Sherwood has supplied the affected residence with
bottled water. In June 1990 a new well was installed in the
Floridan aquifer for the affected residence by Sherwood Medical.
The new well has been tested and no contamination has been found..
In October 1989, Sherwood submitted a design workplan to FDER
outlining further interim measures to be conducted at the site
including the installation of a pump and treat system to begin
cleaning the contaminated groundwater. FDER approved the design
workplan in September 1990 following the receipt of the Final IRK
study report. In November 1990, FDER requested that EPA assume the
lead for Interim Actions for the site.
In December 1989, EPA and FDER approved the RIfFS workplan submitted
by Sherwood Medical's contractor, Roy F. Weston, Inc. The field
work for the RI began in January 1990. The field work included the
installation and sampling of a~ditional Floridan aquifer monitoring
wells, sampling of soil, sediment, and surface water, and a thorough
resampling of all existing wells. The final RI report is scheduled
to be submitted to EPA in mid-1991 and the FS is scheduled for
submission in early 1992.
4.0
Highlights of C~l'Inity Participation
The Interim Remedial Measures Report and the Proposed Plan for the
Sherwood Site were released to the public on January 8, 1991. These
two documents were made available in both the administrative record
and an information repository maintained at the EPA Docket Room in
. Region IV and at the DeLand Public Library. The notice of
availability was published in the Deland Sun News on January 16,
1991 and a second notice was published on January 30, 1991. A
public comment period was held from January 2~, 1991 through
-5-
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February 21, 1990. In addition to public comment and the
accessibility of the information, a public meeting was held on
January 31, 1991. At this meeting, representatives from FDER and
EPA answered questions and addressed community concerns. A response
to comments received during this period is included in the
Responsiveness Summary, Appendix A of this Record of Decision. This
decision document presents the selected interim remedial action for -
the surficial aquifer at the Sherwood Medical Site, chosen in
accordance with CERCLA, as amended by SARA and, to the extent
practicable, the National Contingency Plan. The decision for this
site is based on the administrative record.
5.0
Scop$ and Role of Response Action Within Site Strategy
The major goal of this interim action is to prevent the spread of
contaminated groundwater in the surficial aquifer from migrating off
the Sherwood Site boundaries and to prevent the potential of
vertical migration downward into the Floridan aquifer. The
surficial aquifer under the site is contaminated with volatile
organic compounds (VOC's) above safe drinking standards. Although
the surficial aquifer is not the source of drinking water for the
local residents, under future use scenarios it presents a threat to
human health and the environment. The cleanup objectives for this
interim action ROD are to prevent current or future exposure to the
contaminated groundwater ~hrough treatment and containment, and to
reduce the migration of contaminants. This is not the final action
planned for the surficial aquifer at the Site. Subsequent actions
are planned to address fully the principal threats posed by the
conditions at the site. These actions will be defined when the
RIfFS is complete and will be subject to public comment.
6.0
6.1
Sn1lllllAry of Site Characterizations
Hydrology
The hydrogeologic sequence at the Site includes the surficial or
water table aquifer, a confining unit composed of clay, sandy clay,
and shell layers, and tbe confined Floridan Aquifer.
The surficial aquifer extends from the uppermost saturated sediments
(typically le88 than 10 feet below ground surface) to the top of the
first aquitard found at depths of 25 to 50 feet below land surface.
The surficial aquifer has been recorded as 35 feet thick near Kepler
Road bordering the eastern edge of the site and 10 to -15 feet thick
along the western property boundary near Lake Miller.
The confining unit underlying the surficial aquifer is comprised of
a four to eight foot thick clay to sandy clay that overlies a 35 to
40 foot thick poorly sorted deposit of shells, sand, silt, and
clay. Collectively, these sediments seve to restrict the vertical
-6-
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movement of water from the surficial aquifer to the confined
Floridan aquifer system below.
The Floridan AqUifer is a highly productive aquifer and is
encountered beneath the confining unit. The Floridan Aquifer is the
source of drinking water for the local residents.
6.2
Surficial Aquifer
Twelve monitor wells were installed in the surficial aquifer during
the June 1989 IRK study (Figure 6-1). The analytical results (Table
6-1) of the IRK study revealed that the major contaminants were
tetrachloroethene (PCE), trichloroethene (TCE), and acetone.
Concentrations of other volatile organic compounds (VOCS) were also
detected, but these concentrations were low compared to the
concentrations of PCE and TCE. Analysis of the surficial aquifer
indicated that concentrations of PCE ranged from 130 to 11,000 ppb
and concentrations of TCE ranged from 16 to 420 ppb. The results
indicate that generally the highest concentrations of VOCs were
present on the downgradient (west) side of the Site along Lake
Hiller.
7.0
Sn_A"'Y of Site Risks
CERCLA directs that the. Agency,.muatprotect human health and the
environment from current and potential exposure to hazardous
substances at Superfund sites. In order to assess the current and
potential risks for the Sherwood Site, a full risk assessment is
being conducted as part of the Feasibility Study.
Although the surficial aquifer is not the source of drinking water
for the local residents, under future use scenarios it presents a
threat to human health and the environment. Results of the June
1989 IRK study revealed that the major contaminants were
tetrachloroethene (PCE), trichloroethene (TCE), and acetone.
Analysis of the surficial aquifer indicated that concentrations of
PCE ranged from 130 to 11,000 ppb and concentrations of TCE ranged
from 16 to 420 ppb. Th$ applicable drinking water standard for both
PCE and TCB is 3 ppb, which is the Florida State Standard. The
State standard is more stringent than the Federal standard of 5 ppb
for the respective contaminants. Therefore, given the high levels
in the surficial aquifer, EPA has determined that a potential risk
to human health and the environment exists.
The major goal of the interim action is to prevent the spread of
contaminated groundwater in the surficial aquifer from migrating off
the Sherwood Site boundaries and to prevent the potential of
. vertical migration downward into the Floridan aquifer. This action
will achieve significant risk reduction early in the Superfund
process.
-7-
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.
o 100 200
-I . I
Scale in Feet
8
MW.101
Woods
and Swamp
8MW.'1'2
Legend
. Groundwater .
Monitoring Wells
~
MW - no
8MW-104
8MW-106
Weods
8ldg.A
08
MW-109
~
III
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a:
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Fletention
18MW.107
III
~
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en
Q
Q.
en
i5
=
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FIGURE 6-1 SURFICIAL AQUIFER MONITORING WELL LOCATIONS
SHERWOOD MEDICAL COMPANY t DELAND, FLORIDA
. Park!n!;
~Lw
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TABLE 6-1
Resulls of Volalil. Org.nic Analyses
H.rch 1989 - Sh.llow Monitor W.II S..,llng
She rwood Hed I CA I
Conc.ntr.tions in Hicrogr&8S '.r lit.r (ug/l)
PArAMtus
...11 No.
HW-IIO
HW-110 (DupliCAl.) HW-111 HW-1I2
tlf-101 tlf-I02
ttW-I03
ttW-I05
ttW-106
HW-109
I
\0
,
Chloro_th.n.
Iro__UtAn.
Vinyl Chlorid.
Chloro.th.n.
Heth,l.n. Chlorid.
Ace ton.
C.rbon Disulfid.
I.I-Dichloro.th.n.
'.'-Dichloro.than.
1.2-Dichloro.th.n. (Tot.l)
Chloro'o"
1.2-Dich'oro.th&n.
2-8ut.non.
1.1.I-Trichloro.th,n.
C.rbon T.trachlorid.
Vin,1 Acet.t.
Iro_dichloro..lh.n.
1.2-Dichloroprop&n'
cis-I.1-Dichlorprop.n.
'ri ch I oro.th.n.
Dibro80chlor..th&n.
I.I.Z-Trichloro.than.
l.nl8n.
Tr&ns-I.3-Dichloropreptne
Ir08O'Or8
4-Heth,I-l-P.nl&nGnt
2-H...non.
T.tr.chloro.th.n.
1.1.2.2-T.tr.chloro.than.
Tolu.n.
Chlorobenz.n.
Eth,lb.nJ.n.
Strr.n.
X, .n. (Tobl)
HW-107
HW-108
ttW-104
- ~O
-
IJI 2JI 2JI 17JI 3JI 3JI 3JI 14JB 58
200 258 100 1501 11,0 1001 250 568 270B 18.0008 24.000
31
3J 2J
Z4 10 31 21 82 62 25 11 9
10 -
14
2J
-
420 210J 73 67 140 ISO 32 81 16 170 180
68
1008
1 .0008
-
--
1801' 6,4008 11.000
2J
4001
7
3.400
2.8008
2901
2701
560
4901
2308
4908
nu
'Tetrachloroethen..d.lect.d .t 4(J) ug/l in an associated laboralor, blank.
8 - Indicates the cOMpound was found in lhe blank and lhe sample.
J - Indicales an eSli..led valu. pr.s.nl below lhe deteclion li~il;
--- Indic.t.s c08pound was anal, zed for but not de lee led above lh. deleclion
li.it pr.s.nted in Appendix 8.
-------
Actual or threatened releases of hazardous substances from
Site, if not addressed by implementing the response action
in this Record of Decision (ROD), may present a current or
threat to pub~ic health, welfare, or the environment.
this
selected
potential
8.0
8.1
Description of Remedial Action Alternatives
Alternative 1 - Ho Action
The No Action alternative is required by the National Contingency
Plan (NCP) to be considered through the detailed analysis. It
provides a baseline for comparison of other alternatives. Under the
No Action alternative, no source control remedial measures would be
undertaken at the Sherwood Site.
Construction Cost: ................................ $ 0
Annual Operation and Maintenance Costs (O&M): ..... $0
Months to Implement............................... 0
The No Action alternative would not eliminate any exposure pathways
or reduce the level of risk.
8.2
Alternative 2 - Pump and Treat Syste18
In order to minimize potential migration of contamination in the
surficial aquifer into the Floridan aquifer or into areas off the
Sherwood site property bounderies, a system of recovery wells will
be installed in the downgradient (west) side of the Site. The wells
will be located to recover groundwater in the more highly
contaminated areas, and will be designed to create a hydraulic
barrier along the west side of the Site. Recovered groundwater will
be routed to a air stripper for treatment.. The air stripper will
treat the groundwater to meet all Federal and State water quality
standards. Additionally, the air stripper will be designed to meet
the Federal and State air quality standards. The treated.
groundwater will then be discharged onsite into Lake Miller. The
treated effluent will meet the substantive requirements of the
National Pollutant Discharge Elimination System (NPDES) program.for
onsite di8charge to surface water.
Construction Cost: .......................... $400,000
Annual Operation and Maintenance Costs (O&M)I $ 35,000
Months to Implement................................ 5
The pump and treat system will prevent the spread of contaminated
groundwater in the surficial aquifer from migrating off the Sherwood
Site boundaries. This action will achieve significant risk
reduction early in the Superfund process.
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9.0
S.-ry of Comparative Analysis of Alternatives
This section provides the basis for determining which alternative
(i) meets the threshold criteria of overall protection of human
health and the environment and compliance with ARARs, and (ii)
provides the "best balance" between effectiveness and reduction of
toxicity, mobility, or volume through treatment, implementability,
and cost, and (iii) state and community acceptance. A glossary of
the evaluation criteria is provided in Table 9.1.
9.1
Overall Protection of Human Health and Environment
The No Action alternative is not protective of human health and the
environment because it allows the contaminants to continue to
migrate. The No Action alternative would not eliminate any exposure
pathways or reduce the level of risk. Therefore, the No Action
alternative will not be considered further in this analysis as an
option for the Site.
The Pump and Treat System provides protection of human health and
the environment by reducing, or controlling, the risk through
treatment of the groundwater and preventing the spread of
contamination.
9.2
Compliance with.~.
The air stripper would treat the groundwater to meet all Federal and
State water quality standards for discharge to surface water.
Additionally, the air stripper will be designed to meet the Federal
and State air quality standards.
The final cleanup levels for the groundwater are not addressed in
this ROD because such goals are beyond the limited scope of this
action. The final cleanup levels would be addressed by the final
remedial.action ROD for the Site.
9.3
Long-1f'eJ:8 Effecti~ness and PeDMDence
Extraction and treatment of contaminats in the surficial aquifer
will achieve same reduction in the contamination at the Site, and
will enhance the attainment of a permanent remedy for this Site.
The EPA will continue to evaluate long-term effectiveness and
permanence as part of the development of the final action for the
Site.
Reduction of Torlcity, liability, or Vol\D18 of the Contaminants
Through Treat:aent
The Pump and Treat System would reduce the toxicity, mobility, and
9.4
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TABLB 9.1
GLOSSARY OF EVALUATION CRITERIA
OVerall Protection of Hu.an Health and Bnvironment 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.
ComnUance with ARARs - addresses whether or not a remedy will
meet all of the applicable or relevant and appropriate requirements
of other Federal and State environmental statutes and/or provide
grounds for invoking a waiver.
Lana-Term Effectiveness and Permanence - refers to the magnitude
of residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time once
cleanup goals have been met.
Reduction of Tozicitv. lIobilitv. or Volume 'rhrouah. Treat.ent - is
the anticipated performance of the treatment technologies that may
be employed in a remedy.
Short-Term Effectiveness refers to the speed with which the
remedy achieves protection, as well as the remedy's potential to
create adverse impacts on human health and the environment that may
result during the construction and implementation period.
I.nlementability - is the technical and administrative feasibility
of a remedy, including the availability of materials and services
needed to implement the chosen solution.
Cost - includes capital and operation and maintenance costs.
State A~AftCe indicates whether the State
opposes, or haa no comment on the Proposed Plan.
concurs
with,
Co_unity AcceotaDce - the Responsiveness Summary in the appendix
of the Record of Decision reviews the public comments received from
the Proposed Plan public meeting.
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volume of the extracted groundwater from the surficial aquifer by
treating it in an Air Stripper. The Air Stripper is a proven
treatment process which has been demonstrated to effectively reduce
VOC contamination by forcing an air stream through the water and
causing the compounds to evaporate.
9.5
Short-Term Bffectiveness
There would be no adverse effects to human health or the environment
from the Pump and Treat System. Any short-term risk to workers.
involved in construction of the remedy would be reduced through
implementation of a health and safety plan. The interim action is
effective in the short-term because it would prevent further
degradation and would initiate reduction in toxicity, mobility, and
volume of contamination until a final action is selected. The Pump
and Treat System is a treatment process which has been demonstrated
to effectively reduce VOC contamination on other Superfund sites.
9.6
Cost
The estimated cost for the Pump and Treat System is $400,000 with an
annual operation and maintenance cost of $35,000. Present worth
cost could not be calculated because the number of years that the
interim action system would be in place is uncertain.
9.7
State Acceptance
The State of Florida, as represented by the Florida Department of
Environmental Regulation, concurs in the selection of the Pump and
Treat System as an interim action for the Sherwood Site.
9.8
COJIIIDWlity Acceptance
Based on comments made by cltizens at the public meeting held on
January 31, 1991, and those received during the public comment
period, the agency perceives that the community believes the interim
action will effectively'protect human health and the environment.
10.0
The Selected Rs8edy
Based upon consideration of the requirements of CBRCLA, the detailed
analysis of the alternatives, and public comments, EPA has
determined that the Pump and Treat System for the surficial aquifer
is an appropriate interim action until a final action for the site
is determined.
The major goal of the interim action is to prevent the spread of
contaminated groundwater in the surficial aquifer from migrating off
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the Sherwood Site boundaries and to prevent the potential of
vertical migration downward into the Floridan aquifer. This action
will achieve significant risk reduction early in the Superfund
process.
The final cleanup levels for the surficial aquifer groundwater are
not addressed in this ROD because such goals are beyond the limited
scope of this action. The final cleanup levels will'be addressed by
the final remedial action ROD for the Site.
11.0
Statutory Requirements
The U.S. EPA and FDER believe that the Pump and Treat System will
satisfy the statutory requirements of providing protection of human
health and the environment, attain applicable or relevant and
appropriate requirements directly associated with this action and
will be cost-effective. Sections 11.1 thrul1.6 below summarize the
statutory requirements for this Site.
11.1
Protection of Hwaan Health and the Bnvironment
Although the surficial aquifer is not the source of drinking water
for the local residents,'under future use scenarios it presents a
threat to human health and the environment. The interim action
remedy provides protection of human health for future users through
extraction and treatment of contaminated groundwater until a final
action is determined. The remedy also provides protection to the
environment by preventing the spread of contamination.
11.2
Attainment of the Applicable or Relevant and Appropriate
Requirements (ARM)
The final cleanup levels for the groundwater are not addressed in
this ROD because such goals are beyond the limited scope of this
action. 'The final cleanup levels will be addressed by the final
remedial action ROD for the Site.
The air 8tripPer will treat the groundwater to meet all Federal and
State groundwater quality standards for discharge to surface water.
Additionally, the air stripper will be designed to meet the Federal
and State air quality 8tandards. The treated groundwater will then
be discharged onsite into Lake Miller. The treated effluent will
meet the substantive requirements of the National Pollutant
Discharge Elimination SY8tem (NPDES) program for onsite discharge to
surface water. '
11.3
Cost Bffectiveness
The interim action remedy employs a proven technology which can be
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implemented year round and affords overall effectiveness
proportional to' its costs such that the remedy represents a
reasonable value for the money.
11.4
Ut~lizat~on of Permanent Solutions and A1ternative Treatment
Technology or Resource Recovery Technologies to the Maximum
Extent Practicable
The objectives for this interim action are to prevent current or
future exposure to the contaminated groundwater in the surficial
aquifer, through treatment and containment, and to reduce the
migration of contaminants. Extraction and treatment of contaminats
in the surficial aquifer will achieve some reduction in the
contamination at the Site, and will enhance the attainment of a
permanent remedy for this Site. The EPA will continue to evaluate
long-term effectiveness and permanence as part of the development of
the final action for the Site. This is not the final action planned
for the surficial aquifer at the Site. Subsequent actions will
address fully the principal threats posed by the conditions at the
Site. Utilization of a permanent solution will be addressed in the
final decision document for the Site.
11.5
Preference for Treatment as a Principal Blement
The Pump and Treat remedy is a treatment process which has been
demonstrated to effectively reduce VOC contamination at other
Superfund sites. Therefore, the statutory preference for remedies
that employ treatment as a principal element is satisfied.
11.6
Documentation of Significant Changes
The Proposed Plan for the Sherwood Site was released for public
comment on January 15, 1991. The Proposed Plan identified the Pump
and Treat System as the preferred interim action remedy for the
surficial aquifer. EPA reviewed all written and verbal comments
submitted during the public comment period. Upon review of these
comments, it was determined that no significant changes to the
remedy, as it was originally identified in the Proposed Plan, were
necessary.
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t.t4'iIRoNA.E~
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/~~~~
Il_~;.
fer ~
~ ;
~-41l OF F\.cJl.f>";,
Florida 'Department 0/ Environ,h~UUzl.~egulation
I
Twin Towers Office Bldg. . 2600 Blair Stone Ro~ 'u Tallahassee. Florida 32,'199-2...00
uwton Chiles. Go\'c:rnor APR ..J 3 23 Ptlc~aJ ~I Bro""nc:r. Scc:rct;1r\'
. '
. '
. .
April 2, 1991
Mr. Greer Tidwell, Regional
US EPA, Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
Administrator
Dear Mr. Tidwell:
The Florida Department of Environmental Regulation agrees wi th
the selected remedial alternative to address groundwater
contamination in the surficial aquifer at the Sherwood Medical
Superfund site in Deland, Florida. This is an interim action
only. The final site remedy will be selected after completion of
the remedial investigation/feasibility study (RI/FS).
Surficial aquifer recovery wells will be installed in
downgradient areas where the highest levels of contamination have
been observed. Groundwater recovery will resul t in a hydraulic
barrier which will prevent off-site migration. The contaminated
water will be treated on-site by air stripping to meet health
based standards prior to discharge to Lake Miller.
The estimated construction cost of the groundwater
treatment and disposal system is $400,000 with
operation and maintenance cost of $35,000.
We understand that Sherwood Medical will be performing the
interim action and that state cost share participation will not
be necessary.
recove ry ,
an annual
We look forward to completion of the RI/FS and selection of the
final remedy.
CB/khz
It«7cIftl ~ l'apw
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