United States        Office of
          Environmental Protection   Emergency and
          Agency           Remedial Response
EPA/ROD/R04-93/134
October 1992
SEPA   Superfund
         Record of Decision:
          Reeves Southeastern
          Galvanizing
          (Operable Unit 1), FL

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50272-101
  REPORT DOCUMENTATION
           PAGE
1. REPORT NO.
EPA/ROD/R04-93/134
3. Recipient's Accession No.
   Title and Subtitle
   SUPERFUND RECORD  OF DECISION
   Reeves Southeastern Galvanizing (Operable Unit 1), FL
   First Remedial  Action - Final
                                          5.  Report Dot*
                                          	10/31/92
7.   Authors)
                                          8.  Performing Organization Rapt. No.
9.   Performing Organization Name and Address
                                          10  Project Task/Work Unit No.
                                                                    11.  Contract(C) or Grant(G) No.

                                                                    (C)

                                                                    (G)
12.  Sponsoring Organization Nam* and Address
    U.S.  Environmental  Protection  Agency
    401 M Street, S.W.
    Washington, D.C.   20460
                                          13.  Type of Report & Period Covered

                                             800/800
                                          14.
15.  Supplementary Notes
                   PB94-964028
16.  Abstract (Limit: 200 words)

  The 28.96-acre Reeves Southeastern Galvanizing  (Operable Unit 1)  site consists of the
  17.36-acre Reeves Southeastern Galvanizing (SEG) facility and the 11.6-acre Reeves
  Southwestern Wire (SEW)  facility, located in Hillsborough County,  Florida. Land use  in
  the area  is  predominantly  industrial or  undeveloped.   Two additional Superfund sites,
  the Peak  Oil site and the  Bay Drums site,  are located  in the adjacent area to.the west
  of this site.   The topography is generally flat and contains small wetland areas -to  the
  south  of  the site.  The  largest building on the SEG facility is where commercial steel
  products  are pre-treated and galvanized.   There is also a small office building and
  maintenance  shed. Two inactive liquid waste percolation/evaporation ponds, a wastewater
  pretreatment facility, and a double-lined storage basin for settled solids are also
  located on the SEG portion of the site.   The largest building on  the SEW facility is
  where  steel  wire is drawn,  weaved into chain link fence,  pre-treated,  and galvanized.
  The smaller  building on  the facility is  an office building.  There are also three
  former percolation/evaporation ponds located on the SEW.  The currently-owned
  Southeastern Galvanizing Corporation facility began operations in the mid-1960s using  a
  300-gallon tank in the maintenance shed  as a wastewater catch basin during

  (See Attached  Page)
17. Document Analysis    a. Descriptors
   Record of Decision - Reeves Southeastern Galvanizing  (Operable Unit 1),  FL
   First  Remedial Action - Final
   Contaminated Media:  soil, sediment
   Key  Contaminants:  VOCs (benzene),  other organics (oils, PAHs,  PCBs, pesticides),
                       metals (arsenic,  chromium,  lead)

   b.  Identifiers/Open-Ended Terms
   c.  COSATI Field/Group
18. Availability Statement
                         19.  Security Class (This Report)
                                    None
                                                    20.  Security Class (This Page)
                                                              None .
          21.  No. of Pages
                  48
                                                                              22. Price
(See ANSI-Z39.18)
                                   See Instructions on Reverse
                                                   OPTIONAL FORM 272 (4-77)
                                                   (Formerly NTIS-35)
                                                   Depart mem of Commerce

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EPA/ROD/R04-93/134
Reeves Southeastern Galvanizing  (Operable Unit  1), FL
First Remedial Action  - Final

Abstract  (Continued)

electroplating.  The SEG  facility utilized two  depressions as percolation/evaporation
ponds for their wastewater until 1982, when the current wastewater pretreatment system was
installed.  Wastewater from the facility is currently discharged to the local POTW. The
SEW facility began operations in 1955, at which time the first percolation/evaporation
pond for disposal of the  SEW's wastewater was used until it was backfilled in the late
1960s.  A second pond  was constructed prior to  1969 and used until 1980, when the SEW
began using its wastewater pretreatment program.  In 1981, an EPA investigation identified
elevated metal levels  in  the surface water and  ground water at the SEG facility.
Subsequent studies conducted by Reeves and the  State indicated a possible ground water
contamination problem  in  the surficial aquifer  underneath both facilities, as a result of
past disposal operations.  This ROD addresses the first of two remedial actions for the
contaminated soil and  sediment at the SEG and SEW facilities, as OU1. A future ROD will
address contamination  in  the ground water, waste ponds, and wetlands, as OU2. The primary
contaminants of concern affecting the soil and  sediment are VOCs, including benzene; other
organics, including oils, PAHs, PCBs, and pesticides; and metals, including arsenic,
chromium, and lead.

The selected remedial  action for this site includes excavating approximately 6,000 yd^ of
contaminated soil and  sediment from the two facilities, followed by onsite ex-situ
solidification/stabilization to prevent both current direct contact risk and continued
migration of contamination into the ground water; backfilling the excavated areas to
grade; disposing of the solidified material above ground where the SEG ponds formerly
existed; capping the stabilized material; monitoring ground water; and implementing
institutional controls, including deed and land use restrictions.  The estimated present
worth cost for this remedial action is $551,000, which includes an annual O&M cost of
$7,000.

PERFORMANCE STANDARDS  OR  GOALS:

Risk-based action levels  are based on a cancer  risk of 10~4.  Chemical-specific soil and
sediment cleanup goals are based on State and Federal MCLs and MCLGs, and include chromium
69 mg/kg; lead 280 mg/kg; and zinc 10,860 mg/kg.

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        RECORD OF DECISION
        OPERABLE UNIT  ONE
           October 1992

Reeves Southeastern Superfund Site
   Hillsborough County, Florida
             REGION IV
          Atlanta, Georgia

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SITE NAME AND LOCATION

Reeves Southeastern Corporation Site
Hillsborough County, Florida

STATEMENT OF BASIS 3ND PURPOSE

This decision document presents the selected remedial action for
the Reeves Southeastern Corporation site in Hillsborough County,
Florida, which was chosen in accordance with CERCLA, as amended
by SARA, and, to the extent practicable, the National Contingency
Plan.  This decision is based on the Administrative Record for
this site.

The State of Florida, as represented by the Florida Department of
Environmental Regulation (FDER), has been the support agency
during the Remedial Investigation and Feasibility Study process
for the Reeves Southeastern site.  In accordance with 40 CFR
300.430, FDER, as the support agency, has provided input during
this process.  Based upon comments received from FDER, it is
expected that concurrence will be forthcoming; however, a formal
letter of concurrence has not yet been received.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from the
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.

DESCRIPTION OF THE REMEDY

This operable unit is the first of two operable units planned for
the site.  The first operable unit for this site will involve the
remediation of the soils/sediment on the site.  This action will
address the principal threat by solidifying/stabilizing the
contaminated soils/sediment.

The major components of the selected remedy include:

     o    Excavation of approximately 6,000 cubic yards of
          contaminated soils/sediment

     o    Ex-situ solidification/stabilization of contaminated
          soils/sediment

     o    Onsite disposal of solidified/stabilized material above
          the water table and capping.

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  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, and is cost-effective.  This remedy utilizes
  permanent solutions and alternative treatment technologies to the
  maximum extent practicable and satisfies the statutory preference
  for remedies that employ treatment that reduces toxicity,
  mobility, or volume as a principal element.  Because this remedy
  will not result in hazardous substances remaining onsite above
  health-based levels, the five-year review will not apply to this
  action.
^«:Greer C. Tidwell                            Date
'  Regional Administrator

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                             TABLE OF  CONTENTS


1.0 SITE NAME, LOCATION, AND DESCRIPTION	1

2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES	3

3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION	4

4.0 S-C..-5 AMD ROLE OF OPERABLE UNIT	;

5.0 SUMMARY OF SITE CHARACTERISTICS	6
 5.1 Scope	6
 5.2 General Site Characteristics	6
 5.3 Results of Site Source Remedial Investigation	7
 5.4 Area-Vide Groundwater Investigation	10

6.0 SUMMARY OF SITE RISKS	13
 6.1 Human Health Risks	13
  6.1.1 Scope	13
  6.1.2 Contaminant Identification	13
  6.1.3 Exposure Assessment Information	17
  6.1.4 Toxicity Assessment Information	18
  6.1.5 Risk Characterization Information	19
 6.2 Environmental Risks	24

7.0 DESCRIPTION OF ALTERNATIVES	24
 7.1 Remedial Action Objectives	24
 7.2 Volumes	26
 7.3 ARARs	26
 7.4 Development and Screening of Alternatives	32
  7.4.1 Process	32
  7.4.2 Alternative 1	32
  7.4.3 Alternative 3A	33
  7.4.4 Alternative 3D	34
  7.4.5 Alternative SB	35

8.0^ SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES	35
 8.1 Criteria for Evaluating Remedial Alternatives	35
 8.2 Threshold Criteria	36
  8.2.1 Overall Protection of Human Health and  the
        Environment	36
  8.2.2 Compliance with ARARs	36
 8.3 Primary Balancing Criteria	36
  8.3.1 Long-Term Effectiveness	36
  8.3.2 Reduction of Toxicity, Mobility or ^Volume	38
  8.3.3 Short-Term Effectiveness	.*	38
  8.3.4 Implementability	38
  8.3.5 Cost	38
 8.4 Modifying Criteria	38
  8.4.1 State Acceptance	38
  8.4.2 Community Acceptance	39

9.0 SELECTED REMEDY	39

10.0 STATUTORY REQUIREMENTS	41
 10.1  Purpose	41
 10.2  Protection of Human Health and  the Environment	41
 10.3  Attainment of the Applicable or Relevant  and
       Appropriate Requirements	42
 10.4  Cost Effectiveness	42
 10.5  Utilization of Permanent Solutions  to the
       Maximum Extent Practicable	43
 10.6  Preference for Treatment as  a Principle Element	43

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                       RECORD OF DECISION
                        OPERABLE UNIT ONE
               REEVES SOUTHEASTERN CORPORATION SITE
                  HILLSBOROUGH  COUNTY,  FLORIDA


1.0 SITE NAME. LOCATION.  AND DESCRIPTION

The Reeves Southeastern Corporation Site is located in central
Hillsborough County, Florida.  The site consists of two
facilities located across the road from each other:  the 17.36
acre Reeves Southeastern Galvanizing (SEG) facility on the north
side of State Road (SR) 574 approximately 1200 feet west of
Faulkenburg Road; and the 11.6 acre Reeve Southwestern Wire (SEW)
facility located on the south side of SR 574 approximately 600
feet west of Faulkenburg Road.  Two additional Superfund sites
are located in the area.  These are the Peak Oil site, which is
located immediately west of the SEW facility and the Bay Drums
site, which is located immediately west of the Peak Oil site.
Figure 1-2, taken from the Reeves site source characterization
Feasibility Study (FS), shows a map of all three sites.

Currently, the area north of the SEG facility is Sabal Industrial
Park, a development containing various light industrial and
office buildings.  The area south of the Reeves site is generally
undeveloped, but does encompass about 400 acres owned by
Hillsborough County that contains a wastewater treatment plant, a
solid waste resource recovery facility and an area designated as
the potential  location of a new jail.  There is no residential
development in the immediate vicinity; the nearest being .25
miles east of the SEW facility.  According to the Official Zoning
Atlas for Hillsborough County (1985),  the Reeves, Peak Oil and
Bay Drums properties are all currently zoned  for light
manufacturing.  All of this information would indicate that it is
unlikely that  the future use of the property would include
residential development.

The largest building on the SEG facility is where commercial
steel products are pre-treated  and galvanized.  There is also a
small office building and maintenance shed.  A 300 gallon tank
situated in a  small rectangular area in the northwest corner of
the maintenance shed was used in the 1960s as a wastewater catch
basin during electroplating.  Two inactive liquid waste
percolation/evaporation ponds are located in  the north-central
part of the property area.  A waste-water pretreatment facility
and a double-lined storage basin for settled  solids are located
on the northeast portion of the SEG:

The largest building on the SEW facility is where steel wire is
drawn, weaved  into chain link fence, pre-treated and galvanized.
The smaller building on the facility is an office building.
There are three former percolation/evaporation ponds:  one on the

                                -1-

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BEEVES SOUTHEASTERN
CAl.VANIZ.Hi; DIVISION      •
                                           FIGURE  1-2
                                           AREA  MAP
                               REEVES SOUTHEASTERN  CORPORATION

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central western edge of the property (now backfilled); and two on
the southwestern corner of the property.


2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES

The SEG facility was originally built and operated as Acme
Plating and Galvanizing Company in the mid-1960s.  In 1970, the
facility was acquired by Metal Coatings,  Inc, which merged into
the Southeastern Galvanizing Corporation in 1971.  Through
internal reorganizations, Southeastern Galvanizing Corporation
became the Southeastern Division of Reeves Southeastern
Corporation.  The SEG facility utilized two depressions as
percolation/evaporation ponds for their wastewater.  The ponds
were later enlarged to their present size of 100' by 100' each,
with 5' berms surrounding them and a below grade depth of about
10'.  The ponds were used for disposing of process wastewater
until 1982, when the current wastewater pretreatment system was
installed.  Wastewater from the facility is now discharged into
the local publically owned treatment works (POTW).

The SEW.facility was originally built in 1955 and operated by
Florida Wholesale Fence, Inc., a subsidiary of Reeves Fences,
Inc.  Through two mergers, Florida Wholesale Fence became the
Southeastern Wire Division of Reeves Southeastern Corporation.
The first percolation/evaporation pond for disposal of SEW's
wastewater was built in 1955 and was used until it was backfilled
in the late 1960s.  Its dimensions were approximately 75' long
and 25' wide and was located along the central western border of
SEW.  A second pond was constructed prior to 1969; it was
subdivided in 1975 to form the two current ponds in the southwest
corner of the facility.  Both ponds are approximately 35' by 35',
and are surrounded by a 3' berm.  The ponds were excavated to a
depth of 3'.  Discharge into these ponds ceased in 1980 when SEW
began using its wastewater pretreatment program.  Discharge from
this facility also goes into the local POTW.

The U.S. EPA conducted a site investigation  in 1981 that
indicated elevated metal levels in surface water and groundwater
at the  SEG facility.  Subsequently, the Florida Department of
Environmental Regulation  (FDER) conducted a  survey of the types
and magnitude of chemical contamination at SEG; this survey
resulted in the 1982 placement of SEG on EPA's National
Priorities List (NPL).  Reeves contracted in 1985 with CH2MHill
for a terrain conductivity survey utilizing  electromagnetic
induction technology to be performed at both SEW and SEG.  The
results indicated a possible groundwater contamination problem in
the surficial aquifer underneath both facilities.

In  1988, the Reeves Southeastern Corporation and a group of
potentially responsible parties  (PRPs) for the adjacent Peak Oil
site signed individual Administrative Orders of Consent  (AOCs) to

                               -3-

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perform source characterization Remedial Investigations and
Feasibility Studies  (RI/FSs) at their respective sites.  Under
the AOCs, the Peak Oil PRPs agreed to perform a source
characterization RI/FS at the Peak Oil site and the Reeves
Southeastern Corporation would perform a source characterization
RI/FS at its SEG and SEW facilities.  EPA decided to perform a
source characterization RI/FS at the Bay Drums site.  In addition
to the source control RI/FSs being conducted by Reeves, the Peak
Oil PRPs and EPA, the Peak Oil and Bay Drums PRPs and the Reeves
Southeastern Corporation agreed in a separate AOC to perform an
area-wide groundwater RI/FS.  The results of the groundwater RI
are detailed in the  "Area-Wide Hydrologic Remedial Investigation
and Risk Assessment", Canonie Environmental, Inc., 1992 and will
be addressed in detail in a separate Record of Decision.  There
is also a wetlands impact study being performed by EPA on
wetlands which are located to the north of the three sites; the
results of this study will also be addressed in a separate ROD.


3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION

Community relations  for the Reeves Site has, for the most part,
been handled in conjunction with the Peak Oil and Bay Drums
sites.  Interest in  the Reeves site itself has been minimal.
What community interest that has been noted was focused on EPA
activities at the other two Superfund sites.  This is probably
due to the removal at Peak Oil, where contaminated sludge from a
lagoon was incinerated, and the removal at Bay Drums, where a
large pile of roofing shingles had to be removed from the site in
order to conduct the RI/FS.  The 1989 Community Relations Plan.
prepared by Beverly Mosely, EPA, states the following:

     "Community involvement at the Bay/Peak/Reeves sites has been
     minor to date,  judging from responses during interviews of
     local environmental agency staffs.  Agency personnel from
     the Hillsborough County Environmental Protection Commission
     (HCEPC), Southwest Florida Water Management District
     (SWFWMD), Tampa Bay Regional Planning Council  (TBRPC), and.
     Florida Department of Environmental Regulation, Southwest
     District  (FDER-SWD) were contacted to ascertain the nature
     of comments or  complaints received at those agencies.  No
     formal complaints or inquiries were on record, however there
     have been concerns over the disposition of the roofing
     debris on the Bay Drum site.

     Elected officials or their representatives displayed general
     knowledge of the sites, but overt concern within the
     community was not known to them.  General concerns
     associated with groundwater contamination and  hazardous
     materials were  referenced frequently by officials, but
     nothing specific to the Bay/Peak/Reeves sites  was presented.


                               -4-

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     Many national and regional environmental organizations,  such
     as National Audubon Society,  Sierra Club, and National
     Wildlife Federation, have local groups in the Tampa-St.
     Petersburg area.   Local environmental organizations,  such as
     Brooker Creek Preservation Society, Manasota-88,  and Izaak
     Walton League, also have interest in situation similar to
     the Bay/Peak/Reeves sites.  Specific interest in the
     Bay/Peak/Reeves sites by any of the national or local
     organizations has not been identified at this time.   Contact
     with the organizations usually has resulted in a request to
     be notified of public meetings or issuance of public
     documents.

     Contact with the Brandon area Chamber of Commerce did not
     reveal specific concerns.  The Brandon Chamber does have a
     committee that follows local activities associated with
     water, wastewater, and hazardous waste activities."

In the time period between the preparation of the 1989 CRP and
the public comment period for the Reeves RI/FS, no significant
community interest in the Reeves site was noted.

The Source Characterization RI/FS Report and Proposed Plan for
the Reeves Southeastern Site were released to the public in
August 1992.  These documents were released in conjunction with
the Peak Oil and Bay Drums RI/FSs and Proposed Plans and were
made available to the public in both the Administrative Record
and the information repository maintained at the EPA Docket Room
in Region IV and at the Brandon Public Library.  The notice of
availability of these documents and announcement of the pending
public meeting was published in the Tampa Tribune on both August
11 and 17, 1992.  A public comment period was held from August
13, 1992 to September 12, 1992.  The public meeting was held on
August 18, 1992.  At the meeting, representatives from EPA
presented the three Proposed Plans and answered questions
regarding the problems at the three sites and the source control
remedial alternatives under consideration for the Reeves, Peak
Oil and Bay Drums sites.  A response to the comments received for
the Reeves site during the public comment period is included in
the Responsiveness Summary, which is Appendix A of this ROD.
This decision document presents the selected source control
remedial action for the Reeves Southeastern Site, in Hillsborough
County, 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.
4.0 SCOPE AND ROLE OF OPERABLE UNIT

As with many Superfund sites, the problems at the Reeves
Southeastern site are complex.  As a result, EPA divided the work

                               -5-

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into two operable units (OUs).  These are:

     o  OU One:    Contamination in the soils and sediments.

     o  OU Two:    Contamination in the groundwater and wetlands.

OU Two will be addressed in conjunction with the groundwater and
wetlands remediation at the Peak Oil and Bay Drums sites.  OU Two
will also address any needed disposal of surface water from the
ponds.  The remedial action for OU Two will be selected in a
later ROD.

This ROD for OU One will address the soil and sediment
contamination on the Reeves SEG and SEW facilities.  The purpose
of this response action is to prevent current or future exposure
to levels of contamination that exceed EPA's acceptable risk
range in contaminated soils/sediment and to prevent current or
future migration of contamination to the groundwater.  Potential
ingestion of water extracted from these aquifers poses the
principal risk to human health because the EPA's acceptable risk
range is exceeded and concentrations are greater than MCLs." This
operable unit will be the first response action for the site.


5.0 SUMMARY OF SITE CHARACTERISTICS

5.1 Scope

This section will discuss general site characteristics and
outline the results of the source characterization RI.  The issue
of groundwater contamination is addressed in the Areawide
Hydrologic Remedial Investigation and Baseline Risk Assessment -
Bay Drums. Peak Oil and Reeves Southeastern Superfund Sites.
Canonie Environmental, April 1992.  Although a short summary of
this report will be discussed here, EPA decisions pertaining to
the need for groundwater remediation will be addressed in a
separate ROD.

5.2 General Site Characteristics

Climate in the Tampa area is characterized by mild winters and
relatively long, humid, warm summers.  Spring and fall tend to be
dry, with the majority of the rainfall in the summer.  The
general topography is flat.  The land use in the area is either
industrial or undeveloped, with the nearest single family
residential area bei.-.g 0.25 miles east of the SEW facility.
Topographically, surface elevations on the SEG facility range
from  36 feet above mean sea level  (MSL) at the southern boundary
to 26 feet above MSL on the northern boundary.  The  southern
portion of the SEW facility slopes gradually toward  the south and
southwest toward small wetland areas.  The area around the  two
facilities is relatively flat.

                               -6-

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The groundwater system beneath the area consists of two major
water bearing units:  a surficial aquifer referred to as the
upper aquifer; and the Floridan aquifer system.  The upper
aquifer, which is defined as a Class IIB aquifer, is from 8.5
feet to 37 feet thick with a saturated thickness of about 5 to 25
feet.  It is separated from the Floridan aquifer by the Hawthorne
formation, a clayey low-permeability layer from 16 to 40 feet
thick.  The upper aquifer is hydraulically connected to surface
waters (wetlands and streams) and the flow direction varies
seasonally.  Water levels also fluctuate seasonally and change
rapidly in response to rainfall and other natural influences.
Although regionally the Floridan aquifer flows to the west-
southwest, in the vicinity of the site the flow direction shifts
to the northwest.  This is thought to be due to the proximity of
the site to the Tampa Bypass Canal, which reportedly cuts into
the low-permeability layer and reaches the upper Floridan aquifer
in several places.

5.3 Results of Site Source Remedial Investigation

The Reeves source RI of the SEG and SEW facilities included" the
collection of soil, sediment, surface water, and air samples at
the two facilities.  The field work was conducted in two phases.
Soil samples were collected from targeted areas on the properties
as well as random locations.  Sediment samples were collected
from the four inactive ponds at the two properties and the
unnamed creek.  Surface water samples were collected from the
three ponds that contain water.  The general range of
contaminants can be seen in Table One.

Elevated zinc concentrations were detected at several of the SEG
targeted and random soil sample locations.  Arsenic, cadmium,
calcium, chromium, iron and mercury were elevated in samples from
an area of high subsurface conductivity noted in studies
conducted in 1985.  Elevated lead levels were noted near a
currently used raw acid storage tank area.  Cadmium, chromium,
gold and lead were present at elevated concentrations in a yellow
waste material near a former electroplating waste storage tank.
Cyanide concentration was also elevated in this material and in a
drainage pathway south of a  former drum storage area and in the
drainage swale along the east side of the SEG  site.  Organic
species are not significant contaminant sources in soil samples
from the SEG site.

Sediment samples from the west SEG pond contained elevated  zinc
and cyanide while samples from the east pond contained cadmium,
copper, lead, zinc and cyanide at elevated concentrations.
Surface water samples from  the two ponds generally contained
elevated concentrations of  calcium, iron, magnesium, manganese,
potassium, sodium and zinc.  Organic species are not significant
contaminant sources in either sediment or surface water at  SEG.
Elevated zinc concentrations were noted at several of the SEW

                               -7-

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TABLE ONE
Summary of Chemical Concentrations of the Chemicals of
Potential Concern

Chemical
Arsenic
Cadmium
Chromium
Gold
Lead
Mercury
Nickel
Carcinogenic
PAHsb
Total PCBs
(1254/1260)
1,2,4-
Trichloro-
benzene
Zinc
Concentration3
Soils
(mg/kg)
2.02-10.3
0.264-40.2
0.462-228.0
8.14
1.28-6620
0.028-7.57
0.457-25.8
C. 03-0. 42
0.32-1.46
0.15-1.40
6.3-113,000
Surface Water
(ug/1)
33.7
	
89.0
	
8.0
___
69.0
	
	
	
149-362
Sediment
(mg/kg)
20.4
0.862-193.0
0.4-1540.0
	
21.8-2240
0.179
33.1-128.0
0.0024
	
	
80-120,000
a Values are ranges of detected concentrations, except where
only a single sample constitutes the entire data set for a
medium .
b PAHs expressed in benzo(a)pyrene Toxicity Equivalency
Approach (TEFs) (U.S. EPA, 1992)
    -8-

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targeted and random soil sample locations.   Lead was also
elevated in soils located in a backfilled pond area on the
western edge of the site.  The soils in this general area also
contained organochlorine pesticides, chlorinated benzenes,
polychlorinated biphenyls (PCBs), polynuclear aromatic
hydrocarbons (PAHs), phthalate compounds and petroleum related
compounds.

Sediment samples from the north inactive SEW pond area indicated
elevated lead and zinc.  The samples also contained a phenolic
compound and PAHs.  Samples from the south inactive pond
contained elevated lead, sodium and zinc.  The samples also
contained phenolic compounds, a chlorinated benzene compound and
petroleum related compounds.

Surface water samples from the south SEW pond (the north pond was
dry during sample collection activities) generally contained
elevated concentrations of calcium, chromium, iron, magnesium,
manganese, nickel, potassium and sodium.  Organic constituents
were not reliably present (i.e. present at low levels in two
samples but either not confirmed in a duplicate sample or also
present in a travel blank) in surface water during the Phase 1
study period and were not investigated further in the Phase 2
study with the concurrence of U.S. EPA.

The following conclusions were made in the Reeves RI based on the
information generated from the Phase 1 and 2 RI activities:

     o    Metal constituents are present at elevated
          concentrations in soils, sediments and surface water at
          both SEG and SEW.  Constituents are limited in areal
          extent and are found at concentrations that are
          amenable to conventional remedial technologies.

     o    Organic contaminants are present in soils and sediments
          on the western edge of SEW only.  Review of the
          combined Reeves Phase  1 and 2 sediment and soils data
          for SEW, Phase 1 and 2 data from the Peak Oil Site
          Source Characterization RI, available deeds, boundary
          survey information and available aerial photographs and
          the absence of significant petrochemical usage in the
          SEW operation process  indicates that the oily material
          on the western edge of SEW is probably associated with
          past operations at the adjacent Peak Oil site.

     o    Remediation of sediments  and soils for organic
          constituents along the western edge of SEW will be
          addressed in the Peak  Oil Site Source Characterization
          Feasibility Study  (Peak FS).  The Peak Oil PRPs have
          acknowledged the need  to  include these materials in the
          Peak FS.
                                -9-

-------
5.4 Area-Wide Groundwater Investigation

The study area for the Area-Wide investigation encompasses the
Reeves SEG and SEW facilities, the Bay Drums site, the Peak Oil
site, and adjacent properties covering an area of approximately
95 acres.  In addition to the existing wells, 38 additional
monitor wells were installed and ievelope.^ in the upper surficial
aquifer and 6 monitor wells installed and developed in the upper
Ploridan aquifer.  Analytical parameters that were investigated
include volatile organic compounds (VOCs), semivolatile organic
compounds (SVOCs), polychlorinated biphenyls (PCBs),
organochlorine pesticides (OCPs), total petroleum hydrocarbons
(TPHs), total suspended solids (TSSs), total dissolved solids
(TDSs), metals and cyanide.  Maps showing the well locations can
be seen in Figures 3.1 and 3.2, which were taken from Area-Wide
Hydrologic RI prepared by Canonie.

The analytical results of the groundwater sampling in the
surficial aquifer showed 25 VOCs, 29 SVOCs, 6 pesticides, and 23
inorganic constituents.  No PCBs are present in the surficial
aquifer groundwater samples.  Eight of the 23 detected inorganic
species are common constituents normally found in soil and
present in most groundwater samples.  Most VOCs were detected in
areas close to the Bay Drums and Peak Oil Sites (which is
consistent with the site source findings).  Eight inorganic
constituents in the surficial aquifer are found in amounts
exceeding federal maximum contaminant levels (MCLs) or Florida
MCLs.  These are antimony, arsenic, beryllium, cadmium, chromium,
lead, nickel, and sodium.  Elevated concentrations of zinc are
also present.  A total of 51 wells in the upper aquifer and 14
wells in the Floridan aquifer were sampled.

The analytical sampling results of ground water from the Upper
Floridan Aquifer detected impacts primarily at two of the 10
wells sampled, Well F-2 (the Peak Oil Site production well) and
Well F-3 (the Bay Drums Site production well).  Previously, these
wells acted as conduits for surficial aquifer ground water to
migrate to the Upper Floridan Aquifer.  Prior to the Phase 2
field investigation, EPA installed outer casings around these
wells to prevent further migration.  Wells F-2 and F-3 contained
13 and 15 VOCs, respectively.  For most of the VOCs,
concentrations are significantly higher in Well F-3 than in Well
F-2.  Compounds detected that are higher than MCLs include
benzene, 1,1-dichloroethene  (1,1-DCE), trichloroethene  (TCE),
methylene chloride, toluene,  1,1,2-trichloroethane  (1,1,2-TCA),
total 1,2-dichloroethene  (1,2-DCE), tetrachloroethene, and vinyl
chloride.  Sixteen SVOCs were also detected at relatively low
concentrations in Well F-2 and Well F-3.

OCPs and PCBs were not found  in the Upper Floridan Aquifer wells,
except a low level of aldrin  [0.000061 parts per million  (ppm)]

                               -10-

-------
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-------
in Well F-3.

Fourteen inorganic constituents were detected at relatively low
levels in the samples from Well F-2 and Well F-3.  Nine of the 14
inorganic constituents are also present in the background sample
from Well F-l.  Arsenic was detected in Well F-10 (0.130 ppm)
above the federal and Florida MCL of 0.050 ppm.  Since Well F-10
is upgradient from the study area, the arsenic is most likely
from an offsite source.  Beryllium was detected in Wells D-l, F-
4, F-5, and F-7 above the federal MCL.  The highest
concentrations of metals found in Upper Floridan Aquifer wells
were detected in Well F-5 and included aluminum, cobalt, iron,
magnesium, manganese, nickel, sodium, and zinc.  None of the
detected concentrations were above federal MCLs.  Well F-5 is
constructed with galvanized steel and has been in place over 20
years.


6.0 SUMMARY OF SITE RISKS

6.1 Human Health Risks

6.1.1 Scope

A baseline risk assessment (RA) was conducted as part of the RI
to estimate the health or environmental problems that could
result if the Reeves site was not remediated.  A baseline risk
assessment represents an evaluation of the  "No Action"
alternative, in that it identifies the risk present if no
remedial action is taken.  The assessment considers environmental
media and exposure pathways that could result in unacceptable
levels of exposure now or in the foreseeable future.  Data
collected and analyzed during the RI provided the basis for the
risk evaluation.  The risk assessment process can be divided into
four components:  contaminant identification; exposure
assessment; toxicity assessment; and risk characterization.

Two separate baseline risk assessments have been developed for
this site:  the first developed for»the site-specific source
control RI/FS; the second developed as part of the area-wide
groundwater RI/FS.  The source control risk assessment is
summarized in this ROD.  However, because the remedial action
recommendation in this Operable Unit One ROD does not focus on
the groundwater, the area-wide groundwater risk assessment is not
summarized in this ROD.  Since the soils and sediments evaluated
in the source control RI/FS are a source of groundwater
contamination, the risks associated with the groundwater exposure
pathway are an important consideration for any proposed remedial
action.  The risks derived in the area-wide groundwater RA for
the potential future groundwater exposure pathway for both
workers and onsite residents exceed the.acceptable range for both
the shallow aquifer and the deeper Floridan aquifer.  The

                               -13-

-------
Floridan aquifer is the current source of municipal water
supplies in the area.

6.1.2 Contaminant Identification

The Reeves source control RI/FS has focu, ;ed on soil and sediment
contamination on che Reeves SEG ind SEW . acil.'.tie?.   Both of
these facilities contain currently operating plants.  According
to the Future of Hillsborough Brandon Planning Area Land Use Plan
Map, the site falls within the Urban Level 2 (UL-2) Land Use Plan
Category.  This land use category designates those areas located
within the 1-75 Corridor and determined to be best suited for
urban use, with development occurring with the provision and
timing of transportation and public facility development.  The
area around the site does not appear to contain the public
facilities and services associated with the "urban"
classification.  An  "urban" area is defined as an area having the
characteristics of a city, with intense development and an
extensive range of public facilities and services.  The
Comprehensive Plan recognizes that development and redevelopment
should be integrated with existing adjacent land uses.

Thirty-six (36) chemical contaminants were found in the soils,
surface water and/or sediments at the Reeves site.  Based on the
chemical screening guidelines published in the U.S. EPA Human
Health Evaluation Manual (HHEM), 1989, 11 chemicals of potential
concern were retained for the detailed health risk assessment.
Those 11 chemicals are:

     o  arsenic
     o  cadmium
     o  chromium
     o  gold
     o  lead
     o  mercury
     o  nickel
     o  polychlorinated biphenyls  (PCBs)
     o  polynuclear  aromatic hydrocarbons  (PAHs)
     o  1,2,4-trichlorobenzene
     o  zinc

While the selection  of chemicals of potential concern was
conducted on a media-specific basis, each chemical on a final
list of chemicals of potential concern was modeled in the
exposure assessment  for all media  in which it was detected.
Closer analyses of the soils data, revealed that some of the
chemicals of potential concern were uniformly distributed around
the site while others were non-uniformly distributed.  Plotting
of this data indicated that four  "target areas" existed on  the
two facilities where levels of contaminants are higher than both
the levels on the remainder of the site and background levels.


                               -14-

-------
These target area can be seen on the next page in Figures 1-8 and
1-9, taken from the site source characterization FS.   The soil
and sediment exposure point concentrations at the site can be
found in Table Two.

6.1.3 Exposure Assessment Information

The two facilities are fenced and guarded, so onsite access is
limited to workers and occasional visitors.  Based in part on
this information, both a current and future use exposure
assessment were developed.  Two human receptor populations,
adolescent trespassers and Reeves employees, were evaluated in
the current use scenario.  Chemical exposure was modeled through
the following pathways:

     o  inhalation of fugitive dust;
     o  ingestion of fugitive dust;
     o  ingestion of soil;
     o  ingestion of surface water;
     o  ingestion of sediment;
     o  dermal contact with soil;
     o  dermal contact with surface water;
     o  dermal contact with sediment.

The adolescent trespassers were assumed to be exposed to soils
for 10 days/year for a period of time of 9 years.  The workers
were assumed to be exposed to soils for 8 hrs/day, 5 days/week,
50 weeks/year, for 30 years.  For sediments, workers were exposed
for 30 days/year; the trespasser scenario remains the same.
Two human receptor populations were also evaluated for the future
use scenario - onsite resident, both children and adults, and
adolescent trespassers.  Chemical exposure to the residents were
assumed to be from:

     o  ingestion of soil;
     o  dermal contact with soil.

Chemical exposure to trespassers was modeled through the
following pathways:

     o  inhalation of fugitive dust;
     o  ingestion of fugitive dust;
     o  ingestion of soil;
     o  ingestion of surface water;
     o  ingestion of sediment;
     o  dermal contact with soil;
     o  dermal contact with surface water;
     o  dermal contact with sediment.
                               -15-

-------

                                                                              FIGURE 1-8
                                                              BASELINE  RISK ASSESSMENT TARGET AREAS
                                                                 REEVES SOUTHEASTERN GALVANIZING
LEGEND
*   SA»«P|.£ IOCMICM

SO   lAOCtFID S0«. i»
R   BAHOOU SOU.
                   |    | I»«C£T »RE*

                     *  tlKfUX WAf
                     V  SCCWCMI ',»ufiE
                                          N    -16-
SO   »00      IX

SCALE M rter
             FIGURE 1-9
BASDJNE RISK ASSESSMENT  TARGET AREAS
      REEVES SOUTHEASTERN WIRE


-------
TABLE TWO

Chemical
Arsenic
Cadmium
Chromium
Mercury
Lead
Nickel
Zinc
Gold
Total PCBs
PAHS
1,2,4-Tri-
chloroben-
zene
ONSITE SOIL AND SEDIMENT CONCENTRATIONS
EXPOSURE POINT CONCENTRATIONS (mg/kg)
Soils
Sitewide
1.54
4.01
39.5
0.5
322
6.68
7795
1.41
0.036
0.002
1.90
TA1
3.20
5.63
67.8
1.76
1323
16.5
27,413
ND
ND
ND
ND
TA2
ND
49.5
238
0.31
351
5.35
3714
47.1
ND
ND
ND
TA3
ND
0.82
34.1
2.64
994
3.62
420
ND
ND
ND
ND
TA4
3.57
3.34
113
0.66
505
4.91
2198
ND
1.82
0.21
95
TA5 Back-
ground
ND
2.02
31.2
0.08
50.6
4.01
1411
ND
ND
ND
ND

Sediments

15.9
23.0
168.2
0.14
607
49.2
29,052
— —
__
—
ND - Not Detected
" — " - Not Analyzed For

-------
The standard exposure assumptions used in this risk assessment
are as follows:

                         Adult     Adolescent     Child

Body Weight (kg)           70          35           16
Soil Ingestion
 Rate (mg/day)             50         100          200
Inhalation
 Rate (mVday)              20          10           10
Skin Surface
 Area (cm2/event)         2300        1520         2500

For the resident adult scenario for exposure to soils, the period
of exposure was 80 days/year for 16 years.  The resident child
scenario period was 280 days/year for 9 years.  The future use
adolescent scenario period of exposure was 80 days/year for 9
years.  For exposure to sediments, only the trespasser scenario
was used; the exposure was assumed to be 30 days/year.

The assumption made in the risk assessment is that onsite
chemicals in soil disperse into the air at this site.  All of the
chemicals of potential concern are of low volatility and bind to
soils weakly.

In summary, the current use scenarios were based on limited
access to the site due to various security measures.  The future
use scenario were based on the assumptions that: (1) the site was
developed for residential use  (no sediment numbers were generated
because sediments would be removed for residential development);
and (2) because access is unrestricted, trespasser frequency is
greater than in the current use scenario.

6.1.4 Toxicitv Assessment Information

Slope factors  (SFs) have been  developed by EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risks
associated with exposure to the potentially carcinogenic
contaminant(s) of concern.  SFs, which are expressed in units of
(mg/kg-day)"1,  are multiplied by the  estimated intake of a
potential carcinogen, in mg/kg-day, to provide an upper-bound
estimate  of the excess lifetime cancer risk associated with
exposure  at that intake level.  The term  "upper bound" reflects
the conservative estimate of the risks calculated from the SF.
Use of this approach makes underestimation of the actual cancer
risk highly unlikely.  Slope factors are derived from the results
of human  epidemiological studies or chronic animal bioassays to
which animal-to-human extrapolation  and uncertainty factors have
been applied  (e.g., to account for the use of animal data to
predict effects on humans).

Reference doses (RfDs) have been developed by EPA for indicating

                               -18-

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the potential for adverse health effects from exposure to
contaminant(s)  of concern exhibiting noncarcinogenic effects.
RfDs, expressed in units of mg/kg-day, are estimates of lifetime
daily exposure  levels for humans, including sensitive
individuals.   Estimated intakes of contaminant(s) of concern
ingested from contaminated drinking water can be compared to the
RfD.  RfDs are  derived from human epidemiological studies or
animal studies  to which uncertainty factors have been applied
(e.g., to account for the use of animal data to predict effects
on humans).

The Chronic Daily Intake (GDI) factors and the applicable route-
specific Slope Factors for the chemicals of potential concern can
be found in Table Three.

Arsenic, cadmium, chromium, mercury, nickel, trichlorobenzene and
zinc were each evaluated for their chronic systemic poisoning
using U.S. EPA chronic reference doses.

Gold was evaluated for systemic poisoning using a derived chronic
non-carcinogenic criteria developed by SEC Donohue during the
course of this study.  U.S. EPA guidelines were followed in the
development of this criteria.  The human exposure database for
gold obtained in published scientific literature was used as the
input to this analysis.

Lead exposure was evaluated on a subchronic basis for toddlers
(children ages 1-5 years).  The current U.S. EPA
uptake/biokinetic model for lead exposure was used.  A reference
blood lead level of 10 ug/dl for 95% of the exposed population
was used to assess the potential hazard for lead at this site.
Arsenic, cadmium, chromium (VI), nickel, PCBs, and PAHs were each
evaluated for their carcinogenic potential using U.S. EPA slope
factors.  Cadmium, chromium (VI) and nickel are viewed as
carcinogenic from the inhalation route of exposure only.
Arsenic, PCBs and PAHs are assumed to be carcinogenic from all
routes of exposure.

As  an interim procedure, until more»definitive EPA guidance  is
established, Region IV has adopted a toxicity equivalency
approach  (TEF) methodology for evaluating PAHs.  This methodology
is  based on each compound's relative potency to  the potency  of
benzo(a)pyrene.  The TEFs for the carcinogenic PAHs are contained
in  Table Three.

6.1.5 Risk Characterization Information

For carcinogens, risks are estimated  as the incremental
probability of an individual developing cancer over a life-time
as  a result of exposure to the carcinogen.  Excess  life-time
cancer  risk is calculated from the  following equation:


                               -19-

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TABLE THREE
Chemical Chronic RfD Slope Factor3
(mg/kg-day) (mg/kg-day)-l
Oral Route
Arsenic
Cadmium
Chromium
Gold
Mercury
Nickel
PCBs
PAHs
Zinc
1,2, 4-Trichloro-
benzene
0.0003
0.001 (food)
0.005
0.0018
0.0003
0.02
—
—
0.3
0.00131
1.8
—
— —
—
—
0.84
7.7
5.8
—
—
Inhalation Route
Arsenic
Cadmium
Chromium
Mercury
Nickel
PAHs
1,2, 4-Trichloro-
benzene
— —
—
0.0000006
0.00009
—
—
0.003
50
6.1
41
NA
0.84
6.1
—
    -20-

-------
ND - Not Detected
NA - Not Applicable
"—" - Not Available

a The slope factor for PAHs  was obtained from the EPA
Environmental Criteria and Assessment Office  (ECAO).  The TEFs
used to evaluate the carcinogenic PAHs are:
      Compound

      Benzo(a)anthracene
      Benzo(b)fluoranthene
      Benzo(k)fluoranthene
      Chrysene
      D ibenz o(a,h)anthracene
      Ideno(1,2,3-c,d)pyrene
TEF

0.1
0.1
0.1
0.01
1.0
0.1
                              -21-

-------
Risk = GDI x SF

where:

risk =  a unit less probability (e.g., 2 x 10~5) of an  individual
developing cancer;

GDI = chronic daily intake averaged over 70 years (mg/kg-day);SF
= slope-factor, expressed as  (mg/kg-day)"1

These risks are probabilities that are generally expressed in
scientific notation (e.g., IxlO"6 or  IE"6).  An excess  lifetime
cancer risk of IxlO"6  indicates that,  as a reasonable maximum
estimate, an individual has a 1 in 1,000,000  additional chance of
developing cancer as  a result of site-related exposure to a
carcinogen over a 70-year lifetime under the  specific exposure
conditions at a site.  The National Contingency Plan (NCP) states
that sites should be  remediated to chemical concentrations that
correspond to an upper-bound cancer risk to an individual not
exceeding IxlO"6 to  IxlO"4 excess  lifetime  risk.

The potential for noncarcinogenic effects is  evaluated by
comparing an exposure level over a specified  time period  (e.g.,
life-time) with a reference dose derived for  a similar exposure
period.  The ratio of exposure to toxicity is called a hazard
quotient  (HQ).  By adding the HQs for all contaminant(s) of
concern that affects  the same target  organ (e.g., liver) within a
medium or across all  media to which a given population may
reasonably be exposed, the Hazard Index (HI)  can be generated.

The HQ is calculated  as  follows:

Non-cancer HQ = CDI/RfD

where:

GDI = Chronic Daily Intake

RfD =  reference dose; and

GDI and RfD are expressed in  the same units and represent the
same exposure period  (i.e., chronic,  subchronic, or short-term).

The level of confidence  that  one has  in the information produced
by the risk characterization  process  is dependent on the validity
of the information used  in previous  stages of the risk
assessment.  Although uncertainties  are inherent in all four
stages of a risk assessment,  the most significant uncertainty  in
this assessment is probably associated with the toxicity
assessment for carcinogenic PAHs and arsenic  and the  evaluation
of the dermal absorption exposure route.


                               -22-

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Lifetime cancer risks were estimated for all of the carcinogenic
chemicals of potential concern at the Reeves Southeastern
Corporation Site.  The only significant risks as defined by the
U.S. EPA (1990), e.g. risk j> 10~6, that were found associated
with soil contamination at this site in the current use scenario
were to onsite workers due to exposure to chromium.  This risk
was less than 10~5, however.  On-site workers who contact pond
sediments were also shown to exhibit significant risks due to
arsenic exposure.  On-site residents (future use scenario)
exhibited significant cancer risks due to exposure to arsenic,
PCBs and PAHs in soil.  Arsenic risks were at Target Area (TA) 1
and TA4, while PCBs and PAHs risks were present only at TA4.
Arsenic in pond sediments also presented a significant risk to
future adolescent trespassers.

These receptors, chemicals, and resultant cancer risks are
summarized below:

                                        Carcinogenic Risk
Receptor                 Medium    Chromium  Arsenic  PAHs  PCBs
CURRENT USE SCENARIO

Adolescent Trespasser    Soil        ---      ---
On-site Worker           Soil      8xlO~6      ---
                         Pond        ---     IxlO'5

FUTURE USE SCENARIO

On-site Resident  (TA1)   Soil        ---     SxlO'6
On-site Resident  (TA4)   Soil        ---     5xlO'6
Adolescent Trespasser    Pond        ---     2x1 0~6
As is evident, these risks  are  all well within the  EPA's  target
clean-up risk range for  Superfund sites  (10~6 to  10~4) .

With respect to the non-carcinogenic chemicals of potential
concern at the Reeves  site,  none of* the chronic  hazard quotients
for individual chemicals or the summation of all hazard quotients
for all chemicals to a receptor were greater than 1.00 under the
current use scenario.  The  largest chronic hazard quotient was
found for on-site workers inhaling fugitive  dust containing
chromium  (assumed to be  exclusively chromium VI).   This hazard
quotient was 0.79, indicating that the Reeves site  is  unlikely to
currently pose any chronic  non-cancer health risks  to  the public.

However, the subchronic  assessment of lead exposure to potential
on-site children concluded  that the levels of lead  in  on-site
soils at several target  areas (TA1, TA3) are sufficiently
contaminated to be of  health concern.  The lead  model  predicts
that exposure to lead  concentrations in Areas TA1 and  TA3 would  •

                                -23-

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result in 73% and 48% respectively, of the potential future
population to have blood lead concentrations above the EPA
benchmark of 10 ug/dl.

In the future use scenario, zinc at TA1 and trichlorobenzene at
TA4 were primarily responsible for significant hazard quotients
(>1.00), and these were associated with toddler ingestion of
soil.  Both cadmium and chromium at TA2 combined ;o produce a
significant hazard quotient to toddlers for this area of the
Reeves' properties.  These calculated quotients were also derived
in a highly conservative manner in that the on-site toddler was
modeled assuming that they will live on this site (exclusively at
each target area) for 5 years and ingest soil (200 mg/d) from
only this area.  It should be noted that, although these His
exceed unity, the individual chemical hazard quotients do not
exceed unity.

The area-wide groundwater risk assessment did not address current
exposure since onsite groundwater is not currently being used.
However, the risks associated with possible future exposure for
workers or residents exceeds the risk range for both the shallow
aquifer and deeper Floridan Aquifer, the current source of
municipal water supplies in the area.  For this reason, actual or
threatened releases of hazardous substances from the site soils
and sediments, if not addressed by implementing the response
action selected in this ROD, may present an imminent and
substantial endangerment to the public health, welfare or the
environment.  The endangerment is a result of the potential for
further degradation of the area-wide groundwater via leaching of
contaminants from the contaminated site soils and sediments.

6.2 Environmental Risks

The environmental risks at this site were addressed in a separate
study  (Areawide Wetlands Impact Study).  This study evaluates the
ecological status of  the wetlands associated with the Bay Drums,
Peak Oil and Reeves Southeastern Sites.  The results of this
study are contained in the Areawide Wetlands Impact Study Report.
The wetlands associated with these three sites will be addressed
in a separate operable unit.


7.0 DESCRIPTION OF ALTERNATIVES

7.1 Remedial Action Objectives

Risk based remediation goals were  determined for several exposure
scenarios.   Due to  the expected continued  industrial operations
at the  SEG and  SEW  facilities, risk based  action levels based on
a cancer risk of  <  IxlO"4 were considered appropriate.   None of
those  levels were exceeded in the  soils,  sediments  or  surface
water.   Although  the  average  site  concentration of  chromium did

                               -24-

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not exceed the remediation goal for the onsite worker,  some
localized areas did exceed the remediation concentration of 49
mg/kg.  No noncarcinogenic action levels were exceeded for
sediment.

Soils/sediment remediation goals that were protective of
groundwater were developed.  A number of contaminants evaluated
in the Baseline Risk Assessment did not have these goals
developed; mostly because the contaminant was not present in both
soil and groundwater or was present but in very low
concentrations.  Ultimately, remediation goals were developed for
chromium, zinc and lead.  A variety of methods were used to
develop these goals.

The leaching potential of chromium contained in the
soils/sediments was evaluated by performing TCLP analyses on
select soil and sediment samples.  The data was then evaluated to
attempt to determine a correlation between the total and TCLP
leach concentrations; however, the leach concentrations were low
and no correlation could be determined.  Considering these
results, and the conservative nature of the health-based goal of
49 mg/kg, no further efforts were made to developed a separate
groundwater protection goal.  However, an evaluation of the
chromium concentrations found during the Reeves RI indicates that
95% of the detections are below 69 mg/kg and the next highest
concentration is 138 mg/kg.  The large gap in detected
concentrations indicates that values above 69 mg/kg are elevated
for the site.  Therefore, 69 mg/kg was selected as the soil
remediation goal.

The leaching potential of zinc contained in the soils/sediments
was evaluated in the same way as the chromium potential.
Analyses of the TCLP versus total concentration data concluded
that the sediment data was more variable than the soils data,
therefore, only the soils data was used.  The groundwater
protection goal was computed using the correlation between total
soil and TCLP and the computed dilution factor for the site.  The
health based drinking water standard for zinc  (10 mg/1) was
multiplied by the dilution factor to determine the maximum
acceptable TCLP concentration and is used to determine the
corresponding total allowable soil concentration.  Based on this
computation, the resulting groundwater protection goal is 10,860
mg/kg.

The leaching potential of lead contained in the soils/sediments
was evaluated in the same way as zinc.  However, the selection of
a soil remediation goal  for lead was complicated by the fact  that
lead was also a contaminant of concern at the Peak Oil and Bay
Drums sites, necessitating the selection of a common lead goal
for all  three sites.  The  level was established by averaging  the
soil cleanup levels calculated using the direct partitioning
technique  for the three  sites.  Reeves levels  are 748 mg/kg and

                               -25-

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386 mg/kg, the Peak Oil level is 246 mg/kg and Bay Drums levels
are 11 mg/kg and 30 mg/kg.  The rounded off average of these five
levels is 280 mg/kg, which was selected as the soil remediation
goal for lead.

In summary, the soil remediation goals are:

                                  Remediation
     Chemical                     Goals (mg/kg)

     Chromium                         69

     Lead                            280

     Zinc                         10,860

7.2 Volumes

Volumes of sediment and soil with metals concentrations above the
remediation goals were calculated for the SEG and SEW facilities.
As part of the proposed remediation scenarios on the SEG
facility, the drainage ditch running immediately south of the two
SEG ponds will be dredged to a depth of one foot.  This is a
precaution against contaminated surface water runoff from the
site.  Sediment and soil volumes for the two facilities were
calculated as:

               Sediment  (yd3)                Soil  (yd3)

SEG                 5000                         450

SEW                  250                           1

The areas to  be excavated can be seen on the next page in Figures
1-5 and  1-6,  taken  from  the  site source characterization FS.

7.3 ARARs

Section  121  (d)(2)(A) of CERCLA  specifies that Superfund
Remedial Actions must meet any Federal standard, requirement,
criteria or  limitation that  is determined  to be an applicable or
relevant and appropriate requirement  (ARAR).  ARARs fall into
three  categories:   contaminant-specific; location-specific; and
action-specific.  Some rules do not specifically apply to a
remedial action; however, because of their subject matter, they
may provide  some guidance in implementing  a chosen RA.  These
rules  are called to-be-considereds  (TBCs).  Potential ARARs and
TBCs can be  found in Table Four.

The contaminated material at the site was  evaluated in regard to
the applicability of the RCRA Land Disposal Requirements  (LDRs)
and it was determined that the RCRA LDRs were  not  an ARAR.  The

                               -26-

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SfOiMCttT €'C*v*TiGN ARC*
                                   FIGURE  1-12
                                EXCAVATION AREAS
                      REEVES SOUTHEASTERN  GALVANIZING
                                          FIGURE 1-13
                                       EXCAVATION  AREAS
                                    REEVES SOUTHEASTERN WIRE

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                                                 TABLE FOUR
Applicable and Relevant and Appropriate Requirements and To-Be-Considereds

Authority/
Requirement
Safe Drinking Water Act
(SWA), 40 CFR 141.11-
141.16, 141.50-141.51
Proposed Rule for
Corrective Action for
Solid Waste Managements,
40 CFR Parts 264, 265,
270 and 271
Florida Drinking Water
Standards, FAC 17-550
Chemical-Specific ARARs and TBCs
Description
Primary Drinking
Water Standards
(MCLs and MCLGs)
Proposed corrective
action levels for
soil
Drinking water
standards for class
II Aquifers,
surficial aquifers,
and Floridan
Aquifer
Status
Relevant and
Appropriate
TBCs
Relevant and
Appropriate
Consideration
in the FS
Considered in
the development
of cleanup
goals
Considered in
development of
soil cleanup
levels
Considered in
development of
soil cleanup
levels

Alter
nativ
es it
appli
es to
1,
3A,
3D,
5B
1»
3A,
3D,
5B
1,
3A,
3D,
5B
I
to
00
I

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 I
N)
VO
 I

Archeological/Historic
Preservation Act [16 USC
470; 40CFR 6.30(C)]
Fish and Wildlife Act (16
USC 611-666)
*
Endangered Species Act
(50 CFR Part 402)
Florida Stormwater
Discharge Regulations,
FAC 17-25.042
Location Specific
Establishes
procedures for
preservation of
archeological or
historic data which
may be destroyed
via federally
licensed activity
Requires EPA to
coordinate with
federal and state
agencies if remedy
would modify a
water body. Remedy
must contain
provisions for
protection of fish
and wildlife.
Requires action to
conserve endangered
or threatened
species for
activities in
critical habitats.
Specific standards
for oil/grease in
stormwater
discharged to
wetlands
Relevant and
Appropriate
Applicable
Applicable
TBC
Considered in
development of
alternatives if
archeological
or historical
artifacts may
be impacted by
remedy
Considered if
remedy involves
discharge to
unnamed creek.
Considered if
site is located
in critical
habitat area
for endangered
or threatened
species
Considered if
remedy involves
discharge of
stormwater to
wetlands

none
none
1,
3A,
3D,
5B
1,
3A,
3D,
5B

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                                                   Action-Specific
      RCRA Landfills, 40CFR
      264.300-264.339
Regulations for
closure and post-
closure care of
landfills
TBC
Considered in    3A,
development of   3D
alternatives
      Clean Air Act, National
      Ambient Air Quality
      Standards (NAAQS) for
      Particulate Matter, 40
      CFR 50.6-50.7
Specifies maximum
primary and
secondary 24-hour
concentrations for
total suspended
solids.
Applicable
Considered in    3A,
alternatives     3D,
impacting air    5B
quality
CO
o
i
      Clean Water Act (33 USCA
      1251-1376), National
      Pollutant Discharge
      Elimination System, 40
      CFR 122-125
Discharges to
surface water must
meet NPDES
requirements,
including discharge
limitations,
monitoring
requirements, and
best management
practices
Applicable
to offsite
discharges,
Relevant and
Appropriate
to onsite
discharges
Development of
alternatives
none
      Clean Water Act, Section
      304(a)(l), Water Quality
      Criteria (WQC)
WQC are health
based criteria
developed to
protect aquatic
life and human
health from harmful
effects caused by
chemical
constituents in
surface water
Relevant and
Appropriate
Considered for
discharge to
unnamed creek
none

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 I
U)
CWA Water Quality
Standards [CWA 402
(*)(!)]
CWA Discharge to Publicly
Owned Treatment Works
(POTW), CWA 307, 40 CFR
403
Florida Wetlands
Applicable Regulations,
FAC 17-611.300
Florida Surface Water
Standards, FAC 17-302.300
/
Florida Surface Water
Standards, FAC 17-302
Effluent
limitations
Pretreatment
regulations for
discharge into
POTWs
General qualitative
design criteria for
discharge of
reclaimed water
into wetlands
Prohibits discharge
of wastes into
Florida waters
without treatment
to protect
beneficial uses
Surface water
standards for Class
III waters and
site-specific
alternative
criteria
Applicable
Applicable
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Development of
alternatives
Development of
alternatives
Development of
alternatives if
remedy involves
discharge to
wetland
Development of
alternatives if
remedy involves
discharge to
wetland
Considered for
discharge to
the unnamed
creek
none
none
none
none
none

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material would have, at one time, been considered a listed
hazardous waste because of the disposal on the spent pickle
liquor, which was included in EPA's definition of a K062
hazardous waste.  However, in 1986, EPA amended the regulations
by clarifying that the listing for spent pickle liquor applies to
"Spent pickle liquor generated by steel finishing operations of
facilities within the iron and steel industry (SIC Codes 331 and
332)".  As a result, the solids generated by the treatment of
spent pickle liquor at these two facilities can be evaluated for
the characteristics of hazardous waste and is not considered a
derivative of a listed hazardous waste.  Testing done during the
RI has determined that the contaminated material does not exhibit
any of the characteristics that would make it a characteristic
hazardous waste.

7.4 Development and Screening of Alternatives

7.4.1 Process

As a part of the process, the FS preliminarily evaluates a number
of different technologies.  The technologies are generally •
evaluated on the basis of their effectiveness, implementability
and cost in relation to the remedial action goals for the site.
After the screening, four major alternatives were determined to
be worth developing into detailed alternatives for evaluation as
the final cleanup plan.  For ease of cross reference with the FS,
this ROD has maintained the numbering system used in the FS.  The
retained alternatives are as follows:
                 i
     Alternative 1   -   No Action

     Alternative 3A  -   Cement Stabilization, Backfilling and
                         Capping

     Alternative 3D  -   Cement Stabilization, Backfill Onsite

     Alternative 5B  -   Soil Washing.

7.4.2 Alternative  1 - No Action

Manor Components of the Remedial Alternative.  The National
Contingency Plan  (NCP) requires the development of a no action
alternative as  a basis for comparison with the other
alternatives.   Under this alternative, no action be taken to
reduce the risk posed by the soil/sediment contamination at the
site.  Only continued groundwater monitoring is included in this
alternative.

General Components.  The groundwater would be monitored on an
annual basis  from  the existing monitor well network.  The
estimated present  worth cost of  this alternative is $29,000.


                               -32-

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7.4.3 Alternative 3A - Cement Stabilization, Backfilling and
Capping

Major Components of the Remedial Alternative.  The major features
of this alternative include excavation of approximately 6,000
cubic yards of contaminated material from the two facilities,
solidification/stabilization of that material, backfilling of the
excavated areas to grade, disposal of the solidified material
above ground where the SEG ponds formerly existed and capping of
that material.

Containment Component.  The solidified/stabilized material will
prevent both current direct contact risk and continued
contamination of the groundwater from contamination in the
soils/sediments.  A low permeability cap would be constructed
over the stabilized material to minimize the amount of rainfall
infiltrating through it.  The cap would consist of an HDPE
membrane overlaid with a synthetic drainage net and a fabric
filter.  A two foot thick vegetated soil cover would be placed
over the fabric filter.

General Component.  A dragline would be used to excavate the SEG
pond sediments to a sloped bank constructed nearby.  The sloped
bank would allow excess water to run back into the ponds.  The
SEW pond sediment and the SEG soil would be excavated with a
backhoe and moved to a staging area near the sloped bank.  The
former ponds and excavated areas would be backfilled with soil
from the pond berms, and imported backfill, if necessary.  The
stabilization agent would be pneumatically pumped onto the
soils/sediments and mixed into the material using a backhoe.  The
stabilized material would then be placed above the water table in
the SEG pond area and capped.  To insure that contaminant
leaching did not occur, a five year annual groundwater monitoring
program would be implemented.  The capital costs for this
alternative is $544,000 and the operation and maintenance costs
for the groundwater monitoring are $7,000.  The total present
worth cost of the alternative is $551,000.

ARARs Component.  The major federal.ARARs and TBCs for this
alternative are as follows:

     o    Safe Drinking Water Act, 40 CFR 141.11-141.16, 141.50-
          141.51;

     o    Endangered Species Act (50 CFR Part 402);

     o    Proposed Rule for Corrective Action for Solid Waste
          Management Units, 40 CFR Parts 264, 265, 270 and 271;

The major State ARARs and TBCs are as follows:

     o    Florida Drinking Water Standards/ FAC 17-550;

                               -33-

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     o    Florida Storrawater Discharge Regulations, FAC 17-
          25.042.

This alternative will meet all Federal and State ARARs.

7.4.4 Alternative 3D - Cement Stabilization and Backfill Onsite

Major Components of the Remedial Alternative.  The major features
of this alternative include excavation of approximately 6,000
cubic yards of contaminated material from the two facilities,
solidification/stabilization of that material, backfilling of the
excavated areas to grade, disposal of the solidified material
into the SEG pond areas and backfilling over the stabilized
material to grade.

Containment Component.  The solidified/stabilized material will
prevent both current direct contact risk and continued
contamination of the groundwater from contamination in ths
soils/sediments.  Soil would be backfilled over the stabilized
material to reduce the infiltration of rainwater through the
stabilized material.

General Component.  A dragline would be used to excavate the SEG
pond sediments to a sloped bank constructed nearby.  Tha sloped
bank would allow excess water to run back into the ponds.  The
SEW pond sediment and the SEG soil would be excavated with a
backhoe and moved to a staging area near the sloped bank.  The
former ponds and excavated areas would be backfilled with soil
from the pond berms, and imported backfill, if necessary.  The
stabilization agent would be pneumatically pumped onto the
soils/sediments and mixed into the material using a backhoe.  The
stabilized material would then be placed above the water table in
the SEG pond area and capped.  To insure that contaminant
leaching did not occur, a five year annual groundwater monitoring
program would be implemented.  The capital costs for this
alternative is $451,000 and the operation and maintenance costs
for the groundwater monitoring are $7,000.  The total present
worth cost of the alternative is $458,000.

ARARs Component.  The major federal ARARs and TBCs for this
alternative are as  follows:

     o    Safe Drinking Water Act, 40 CFR 141.11-141.16, 141.50-
          141.51;

     o    Endangered Species Act (50 CFR Part 402);

     o    Proposed  Rule for Corrective Action for Solid Waste
          Management Units, 40 CFR Parts 264, 265, 270 and 271;

The major State ARARs and TBCs are as follows:


                               -34-

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     o    Florida Drinking Water Standards, FAC 17-550;

     o    Florida Stormwater Discharge Regulations, FAC 17-
          25.042.

This alternative will meet all Federal and State ARARs.

7.4.5 Alternative 5B - Soils Washing

Mai or Components of the Remedial Action.  Approximately 6,000
cubic yards of material would be excavated and put into a holding
tank.  The soils washing process would strip the metals from the
soil/sediment particles.  The cleaned soil would be backfilled
into the SEG ponds.  The backfilled areas would be leveled,
covered with topsoil and reseeded.

Treatment Component.  The soils washing process itself would
consist of a chelating agent/acid solution countercurrent flow
that would strip the metals from the sediment/soil particles.
Three to seven washing stages would be required to achieve
cleanup levels.  The washed soil would go through two or three
rinse stages, dewatering by filter press and then placement back
into the SEG ponds.  The leach solution would be treated by
precipitation and recycled back through the soil washing process.
The precipitated metal sludge would be transported to a metal
reclamation facility.

General Components.  A hydraulic dredge would be used to remove
the SEG pond sediments, which would then be pumped into a holding
tank.  The contaminated soil and SEW pond sediments would be
excavated with a backhoe and mixed with the SEG sediments.
Because this process would remove the contamination from the
site, no operation and maintenance is required.  The total
present worth cost of this alternative $2,225,000.

ARARs Component.  The major federal ARARs and TBCs for this
alternative are as follows:

     o    Safe Drinking Water Act, 40 CFR  141.11-141.16, 141.50-
          141.51;

     o    Endangered Species Act  (50 CFR Part 402);

     o    Proposed Rule for Corrective Action for  Solid Waste
          Management Units, 40 CFR Parts 264, 265, 270 and 271;

The major State ARARs and TBCs are as follows:

     o    Florida Drinking Water  Standards, FAC 17-550;

     o    Florida Stormwater Discharge Regulations, FAC 17-
          25.042.

                               -35-

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This alternative will meet all Federal and State ARARs.


8.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

8.1 Criteria for Evaluating Remedial Alternatives

In selecting its preferred cleanup alternative, EPA uses nine
criteria to evaluate each of the detailed alternatives developed
in the FS.  Those nine criteria are developed in more detail in
the figure on the next page.  The comparison of the four
alternatives using those criteria can be found in the remainder
of Section 8 of this ROD.

8.2 Threshold Criteria

8.2.1 Overall Protection of Human Health and the Environment

Alternative 5B provides slightly better protection of human
health and the environment than either 3A or 3D because the
contaminants are removed from the environment.  However, the
immobilization of contaminants offered in 3A and 3D provides
adequate protection.  The protection offered by 3A is slightly
better than 3D because water contact with the stabilized waste is
minimized in 3A.  Since the No Action Alternative coes not
eliminate, reduce or control any of the exposure pathways, it is
therefore not protective of human health or the environment and
will not be considered further in the analysis as an option for
the source control.

8.2.2 Compliance with ARARs

All of the alternatives comply with relevant Federal and State
ARARs and with SARA'S preference for treatment.

8.3 Primary Balancing Criteria

8.3.1 Long-Term Effectiveness

Alternative 5B provides the greatest degree of long-term risk
reduction because the heavy metals are removed from the
soils/sediments.  Alternatives 3A and 3D provide significant
long-term protection in that the heavy metals are immobilized
onsite and therefore are not significantly available for direct
contact or leaching into groundwater.  Because 3A  minimizes the
amount the stabilized waste comes into contact with water, it
affords slightly more long term effectiveness than 3D; however,
bench scale tests indicate that the stabilized waste will not
significantly leach even if it comes into sustained contact with
water.
                               -36-

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              CRITERIA FOR EVALUATING REMEDIAL ALTERNATIVES
In selecting its preferred cleanup alternative, EPA uses the following criteria, to evaluate each of
the alternatives developed in the Feasibility Study (FS). The first two criteria are the essential
Threshold Criteria and must be met before an alternative can be considered further. The next five
are the Primary Balancing Criteria used to further evaluate the alternatives once the Threshold
Criteria have been met-  The last two Modifying Criteria are used to further evaluate EPA's
preferred alternative and Proposed Plan after public comment period has ended and comments
from the State have been received. All nine criteria are explained in more detail,here.
Overall Protection of Human Health and the Environment-Assesses degree to which alternative',
eliminates, reduces, or controls health and environmental threats through treatment^ engineering'
methods^ or institutional controls-
 Compliance with Applicable or Relevant and Appropriate Requirements • Assesses compliance
 with Federal/State requirements.
 Cost- Weighing the benefits of a remedy against the coat of implementation,


 Jmplementability - Refers to the technical feasibility and administrative ease of a remedy,


 Short-Term Effectiveness- Length of time for remedy to achieve protection and potential impact,
 of construction and implementation of a remedy,


 Lang-Term Effectiveness - Degree to which a remedy can maintain protection of health tmd
 environment once cleanup goals have been met,


 Reduction of Toxidty, Mobility, or Volume Through Treatment- Refers to ejected performance
 of the treatment technologies to lessen harmful nature, movement or amount of contaminants.

  >                         f                                     *      f,

 State Acceptance -'Consideration of State's opinion of ihe preferred alternative.


 Community Acceptance. - Consideration of public comments on the preferred alternative.   ' ,
                                        -37-

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8.3.2 Reduction of Toxicitv, Mobility or Volume

Alternative 5B provides the greatest in toxicity, mobility or
volume by reclaiming the heavy metals from the soils/sediment.
Alternative 3A and 3D are roughly equal in that the stabilization
should sufficiently reduce movement of contaminants to
groundwater.8.3.3 Short-Term Effectiveness

Alternatives 3A and 3D present minimal short-term risks, mostly
to onsite workers implementing the cleanup plan.  These can be
averted by precautionary worker safety measures.  Alternative 5B
has a slightly higher risk that the other three because of a
slight rise in potential risk to the general public due to the
transportation of the metal sludge to a reclamation facility.

8.3.4 Implementabilitv

Alternative 5B would be the most difficult to implement because
it utilizes an innovative technology that has not been used at
many sites.  Consequently, there is not a large body of knowledge
concerning how to apply the soils washing technology to a
particular site.  Implementation of Alternatives 3A anc 3D would
present identical levels of difficulty to each other.  The
technology utilized by these two alternatives,
solidification/stabilization, has been implemented at numerous
sites and is well understood.

8.3.5 Cost

The comparative present worth costs of the three remaining
alternatives are as follows:

   Alternative 3A      $551,000
   Alternative 3D      $458,000
   Alternative 5B    $2,225,000

The costs developed for Alternatives 3A and  3D are substantially
identical.  The increased cost for Alternative 3A over  3D is
based on the cost of the cap plus the cost of the additional
backfill.  The cost of Alternative 5B is primarily made up of the
hydraulic dredging, soils washing, and the transportation and
metal reclamation of the metals contaminated residual sludges.
The excavation and backfill costs are otherwise  identical to
Alternat ive 3A.

8.4 Modifying Criteria

8.4.1 State Acceptance

The State of Florida, as represented by the  Florida Department of
Environmental Regulation  (FDER), has been the support agency
during the Remedial Investigation and Feasibility Study process

                               -38-

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for the Reeves Southeastern site.  In accordance with the 40 CFR
300.430, FDER, as the support agency, has provided input during
this process.  Based upon comments received from FDER, it is
expected that concurrence will be forthcoming; however, a formal
letter of concurrence has not yet been received.

8.4.2 Community Acceptance

The community expressed no major concerns about the selected
remedy during the public comment period.  The concerns of the
community are discussed in detail in the Responsiveness Summary,
which is Appendix A of this ROD.


9.0 SELECTED REMEDY

Based upon consideration of the requirements of CERCLA, the NCP,
the detailed analyses of alternatives and public and state
comments, EPA has selected Alternative 3A as the source control
remedy for this site.  At the completion of this remedy, the risk
associated with the soils and sediments at this site has been
calculated to range between IxlO"6 and IxlO"5,  which is  within
EPA's acceptable risk range of IxlO'6 to  IxlO"4.   EPA has
determined that this risk range is protective of human health and
the environment.  Because this remedy will not result in
hazardous substances remaining onsite above health-based levels,
the five-year review will not apply  to this action.  The total
present worth cost of the selected remedy is estimated at
$551,000.

Maior Components of the Remedial Alternative.  The major features
of this alternative include excavation of approximately 6,000
cubic yards of contaminated material from the two  facilities,
solidification/stabilization of that material, backfilling of the
excavated areas to grade, disposal of the solidified material
above ground where the SEG ponds formerly existed  and capping of
that material.  The areas to be excavated can be seen  in Figures
1-5 and 1-6 on page 27 of this ROD.
                                   *.
Containment Component.  The solidified/stabilized  material should
prevent both current direct contact  risk and continued migration
of contamination from the soils/sediments into the groundwater.
A low permeability cap shall be constructed over the stabilized
material to minimize the amount of rainfall infiltrating through
it.  The cap  shall consist of an HOPE membrane overlaid with
synthetic drainage net and a fabric  filter.  A two foot thick
vegetated soil cover would be placed over the fabric  filter.

Performance  Standards.  Performance  standards for  excavation of
the soils/sediment were developed to protect  human health, to
prevent contamination of the groundwater and  to  be in  compliance
with ARARs.   Excavation shall continue  until  the remaining

                               -39-

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soils/sediment are at or below the selected performance
standards.  All excavation activities shall comply with ARARs.
Testing methods approved by EPA shall be used to determine
whether the performance standards have been achieved.  The
standards selected for the chemicals of concern are as follows:

                                       Performance
    Chemical	Standards (ir.q/kq)

    Chromium                               6 9

    Lead                                  280

    Zinc                               10,860

After the soils/sediments that are contaminated above the
performance standards are excavated, it will be stabilized.
Based in part on recommendations found in the EPA publication
Stabilization/Solidification of CERCLA and RCRA Wastes.
(EPA/625/6-89/022, May 1989), EPA has determined that the
following performance standards for the stabilized material are
appropriate:

                      Performance              Testing
    Parameter	Standard	Methodology

    Permeability       £ IxlO'7                EPA Method 9100-
                                              SW846

    Unconfined
    Compres s ive
    Strength           >. 200 psi               ASTM 1633-84

    Leachability       < 5 mg/1 Lead
                       < 5 mg/1 Chromium      TCLP

    Leachability       leachability           Modified
                       index > 12             ANS 16.1

Because certain performance standards may not be determined until
the Remedial Design  phase, it shall be understood that the list
of performance standards in this section is not exclusive and may
be subject  to addition and/or modification by the Agency in the
RD/RA phase.

General Component.   A dragline shall be used to excavate the SEG
pond sediments to  a  sloped bank constructed nearby.  The sloped
bank would  allow excess water to run back into the ponds.  The
SEW pond  sediment  and the SEG soil  shall be excavated with a
backhoe and moved  to a staging area near the sloped bank.  The
former ponds and excavated areas shall be backfilled with  soil
from the  pond berms, and imported backfill, if necessary.  The

                               -40-

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stabilization agent shall be pneumatically pumped onto the
soils/sediments and mixed into the material using a backhoe.  The
stabilized material shall then be placed above the water table in
the SEG pond area and capped.  Deed restrictions or some other
type of land use restrictions will be sought in order to prevent
any activity with the potential to damage the
solidified/stabilized monoloth.  To insure that contaminant
leaching did not occur, a five year annual groundwater monitoring
program shall be implemented.  Addition operation and maintenance
activities will be outlined in the Operations & Maintenance Plan
that will be developed as a part of the RD/RA.  The capital costs
for this alternative is $544,000 and the operation and
maintenance costs for the groundwater monitoring are $7,000.  The
total present worth cost of the alternative is $551,000.

ARARs Component.  The major federal ARARs and TBCs for this
alternative are as follows:

     o    Safe Drinking Water Act, 40 CFR 141.11-141.16, 141.50-
          141.51;

     o    Endangered Species Act  (50 CFR Part 402)

     o    Proposed Rule for Corrective Action for Solid Waste
          Management Units, 40 CFR Parts 264, 265, 270 and  271;

The major State ARARs and TBCs are as follows:

     o    Florida Drinking Water  Standards, FAC  17-550.

     o    Florida Stormwater Discharge Regulations, FAC 17-
          25.042.

This alternative shall meet all Federal and State ARARs.
 10.0  STATUTORY DETERMINATIONS

 10.1  Purpose

 Under CERCLA  section  121, EPA must  select remedies that  are
 protective  of human health  and the  environment, comply with ARARs
 (unless  a statutory waiver  is justified), are cost-effective,  and
 utilize  permanent  solutions and  alternative treatment
 technologies  to  the maximum extent  practicable.   In  addition,
 CERCLA 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.

 10.2  Protective  of Human Health  and the Environment

                               -41-

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The selected remedy protects human health and the environment by
immobilizing the contaminants in the stabilized matrix and
disposing of the matrix above the water table.  Stabilization
will reduce and/or eliminate the direct contact threat to human
health and, by binding the contaminants in the stabilized matrix,
will eliminate further migration of contamination to the
groundwater.  The stabilized matrix will be disposed of above the
water table, covered with a low permeability membrane and a two
foot soil cover that will be revegetated.  This will serve
further to prevent direct contact with the stabilized material
and leaching into the groundwater from the material.

10.3 Attainment of the Applicable or Relevant and Appropriate
Requirements (ARARs^

The selected remedy of excavation, stabilization, disposal above
the water table and capping will comply with all ARARs.  The
ARARs are presented below.

     o    Safe Drinking Water Act, 40 CFR 141.11-141.16, 141.50-
          141.51;

     o    Endangered Species Act (50 CFR Part 402);

     o    Proposed Rule for Corrective Action for Solid Waste
          Management Units, 40 CFR Parts 264, 265,  270 and 271;

The major State ARARs and TBCs are as follows:

     o    Florida Drinking Water Standards, FAC 17-550;

     o    Florida Stormwater Discharge Regulations, FAC 17-
          25.042.

This alternative will meet all Federal and State ARARs.

10.4 Cost Effectiveness

EPA believes that the selected remedy will reduce the risk to
human health and the environment from the soils and sediments at
a cost of $551,000.  The selected remedy, though slightly more
expensive than the similar Alternative 3D, provides a higher
level of long term protectiveness by removing the contaminated
material from contact with the groundwater.  This will prevent
further contamination of the groundwater.  Although Alternative
5B provided the greatest degree of long  term effectiveness, it
cost significantly more than the other three alternatives without
providing a significantly greater degree of reduction of risk to
human health and the environment.
                               -42-

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10.5 Utilization of Permanent. Solutions to the Maximum Extent
Practicable

EPA has determined that the selected remedy represents the
maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost-effective manner for the
final source control operable unit at the Reeves Southeastern
site.  Of those alternatives that are protective of human health
and the environment and comply with ARARs, EPA has determined
that this selected remedy provides the best balance of trade-offs
in terms of long-term effectiveness and permanence, reduction in
toxicity, mobility, or volume achieved through treatment, short-
term effectiveness, implementability, and cost, while also
considering the statutory preference for treatment as a principle
element and considering state and community acceptance.

The selected remedy will effectively immobilized the contaminants
in the soils and sediments and will prevent any further direct
risk to human health or threat to the groundwater.

10.6 Preference for Treatment as a Principle Element

By immobilizing the contaminants in the stabilized matrix, EPA
will meet the statutory preference for treatment as a principal
element of the remedy.
                               -43-

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                       RECORD OF DECISION
                        OPERABLE UNIT ONE
              REEVES SOUTHEASTERN CORPORATION  SITE
                  HILLSBOROUGH  COUNTY,  FLORIDA


1.0 SITE NAME. LOCATION,  AND DESCRIPTION

The Reeves Southeastern Corporation Site is located in central
Hillsborough County, Florida.  The site consists of two
facilities located across the road from each other:  the 17.36
acre Reeves Southeastern Galvanizing (SEG) facility on the north
side of State Road (SR) 574 approximately 1200 feet west of
Faulkenburg Road; and the 11.6 acre Reeve Southwestern Wire (SEW)
facility located on the south side of SR 574 approximately 600
feet west of Faulkenburg Road.  Two additional Superfund sites
are located in the area.   These are the Peak Oil site/ which is
located immediately west of the SEW facility and the Bay Drums
site, which is located immediately west of the Peak Oil site.
Figure 1-2, taken from the Reeves site source characterization
Feasibility Study (FS), shows a map of all three sites.

Currently, the area north of the SEG facility is Sabal Industrial
Park, a development containing various light industrial and
office buildings.  The area south of the Reeves site is generally
undeveloped, but does encompass about 400 acres owned by
Hillsborough County that contains a wastewater treatment plant, a
solid waste resource recovery facility and an area designated as
the potential location of a new jail.  There is no residential
development in the immediate vicinity; the nearest being .25
miles east of the SEW facility.  According to the Official Zoning
Atlas for Hillsborough County (1985),  the Reeves, Peak Oil and
Bay Drums properties are all currently  zoned for light
manufacturing.  All of this information would indicate that it is
unlikely that the future use of the property would include
residential development.

The largest building on the SEG facility is where commercial
steel products are pre-treated and galvanized.  There is also a
small office building and maintenance shed.  A 300 gallon tank
situated in a small rectangular area in the northwest corner of
the maintenance  shed was used in the 1960s as a wastewater catch
basin during electroplating.  Two inactive liquid waste
percolation/evaporation ponds are located in the north-central
part of the property area.  A waste-water pretreatment facility
and a double-lined storage basin for settled solids are located
on the northeast portion of the SEG.

The largest building on the SEW facility is where  steel wire is
drawn, weaved into chain link fence, pre-treated and galvanized.
The smaller building on the facility is an office  building.
There are three  former percolation/evaporation ponds:  one on the

                                -1-

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    SOUTHEASTERN
GAI.VANIZiNG DIVISION
                                         FIGURE 1-2
                                          AREA MAP
                              REEVES SOUTHEASTERN  CORPORATION

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