United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R04-93/149
September 1993
SEPA Superfund
Record of Decision:
Reeves Southeastern
Galvanizing
(Operable Unit 2), FL
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R04-93/149
3. Recipient's Accession No.
4. THI« and Subtitle
SUPERFUND RECORD OF DECISION
Reeves Southeastern Galvanizing (Operable Unit 2), FL
Second Remedial Action - Final
5. Report Date
09/09/93
6.
7. Author(s)
8. Performing Organization Rapt. No.
9. Performing Organization Name and Address
10 Project Taskwork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name 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
PB94-963029
16. Abstract (Limit: 200 words)
The 28.96-acre Reeves Southeastern Galvanizing (Operable Unit 2) 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, with the nearest residence located
0.25 miles from the site. Two additional Superfund sites, the Peak Oil site and the
Bay Drums site,-are located in the adjacent area to the west. Small wetland areas are
located to the south of the site, and there are also two surficial aquifers, the
Northern Surficial Aquifer and the Floridian Aquifer, underlying the site. Buildings at
the SEG facility include a commercial steel products building where materials are
pre-treated and galvanized, a small office building, and a 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. Buildings at the SEW facility include the main building where
steel wire is drawn, weaved into chain link fence, pre-treated, and galvanized, and an
office building. There also are three former percolation/evaporation ponds located on
the SEW property. The SEG facility began site operations in the mid-1960s and used 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 2), FL
Second Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: metals (arsenic, chromium, lead)
b. laemmers/Open-Ended Terms
c. COSATl Field/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None .
21. No. of Pages
58
22. Price
(See ANSI-Z39.18)
Sea Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R04-93/149
Reeves Southeastern Galvanizing (Operable Unit 2), FL
Second Remedial Action - Final
Abstract (Continued)
electroplating. The SEG facility also 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 into 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. The SEW began
using its wastewater pretreatment program and discharging into the local POTW in 1980. In
1981, an EPA investigation identified elevated levels of heavy metals 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
beneath both facilities, as a result of past disposal operations. Another FY93 ROD
addressed contaminated soil and sediment at the SEG and SEW facilities, as OU1. This ROD
addresses the contaminated ground water in the Northern Surficial Aquifer, as OU2. The
primary contaminants of concern affecting the ground water are metals, including arsenic,
chromium, and lead.
The selected remedial action for this site includes allowing for natural attenuation of
the Northern Surficial Aquifer; installing additional ground water monitoring wells in the
Northern Surficial Aquifer and the Upper Floridian Aquifer; preventing the discharge of
ground water from the Northern Surficial Aquifer into the surface water of an unnamed
creek; implementing a well survey; providing for a contingency remedy, including
extraction and treatment of ground water using chemical precipitation to remove heavy
metals, and discharging the treated water into the POTW, if satisfactory progress is not
made by the natural attenuation process; monitoring the ground water to follow the
progress of the natural attenuation; and implementing institutional controls, including
ground water use restrictions. The estimated present worth cost for this remedial action
is $136,000.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific ground water cleanup goals are based on SDWA MCLs and MCLGs, EPA action
levels, and State levels, and include arsenic 50 ug/1; cadmium 5 ug/1; chromium 100 ug/1;
lead 15 ug/1; nickel 100 ug/1; and zinc 10,000 ug/1.
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RECORD OF DECISION
OPERABLE UNIT TWO
September 1993
REGION IV
Atlanta/ Georgia
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DECLARATION OF THE RECORD OF DECISION
SITE NAME AND LOCATION
Reeves Southeastern Corporation Site
Hillsborough County, Florida
STATEMENT OF BASIS AND 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 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 Potection (FDEP) (formerly the Florida Department
of Environmental Regulation), 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,
FDEP, as the support agency, has provided input during this
process. Based upon comments received from FDEP, 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 second of two operable units planned
for the site. The first operable unit selected for this site
involve the remediation of the soils/sediment on the site. The
second operable unit, the subject of this ROD, addresses the
contamination in the Northern Surficial Aquifer. Potential
ingestion of water extracted from this aquifer poses the
principal -threat to human health because EPA's acceptable risk
range is exceeded and concentrations are greater than MCLs.
The major components of the selected remedy includes
o Implementation of Operable Unit One as selected in the
October 1992 Operable Unit One Record of Decision;
o Natural attenuation of the Northern Surficial Aquifer;
o Installation of additional monitor wells in the
Northern Surfical Aquifer;
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o Prevention of discharge of groundwater from the
Northern Surf icial Aquifer into the surface water in
the unnamed creek;
o Installation of a monitor well in the Upper Floridan
Aquifer in the general vicinity of the former
production wells on the Reeves SEG facility;
o Implementation of an intensive well survey within a one
mile radius of the site;
0 Completion of the remedial design for the contingency
remedy .
The cost of the selected remedy, not including the cost of
Operable Unit One, is $136,000.
If satisfactory progress, as defined in the Decision Summary, is
not made by the natural attenuation process, then the contingency
remedy shall be implemented. The major componants of the
contingency remedy include:
o Extraction of contaminated groundwater from the
Northern Surf icial Aquifer;
o Treatment of extracted groundwater by chemical
precipitation to remove heavy metals;
o Discharge of treated groundwater into local POTW.
The cost of the contingency remedy is $2,504,000.
STATUTORY DETERMINATIONS
Both the selected remedy and the contingency remedy are
protective of human health and the environment, comply with
Federal and state requirements that are legally applicable or
relevant and appropriate to the remedial action, and are cost-
effective. These remedies utilize permanent solutions and
alternative treatment technologies to the maximum extent
practicable and satisfy the statutory preference for remedies
that employ treatment that reduces toxic ity, mobility, or volume
as a principal element. Because either of these remedies will
result in hazardous substances remaining onsite above health-
based level* for a time period exceeding five years, a review
will be conducted within five years after commencement of the
remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
Patrick M. Tobin Date
Acting Regional Administrator
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. TABLE OF CONTENTS
1.0 SITE SAME, LOCATION, AND DESCRIPTION 1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 3
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 4
4.0 SCOPE AND ROLE OF OPERABLE UNIT 6
5.0 SUMMARY OP SITE CHARACTERISTICS 6
5.1 Scope. 6
5.2 General Site Characteristics .. .. 7
5.3 Area-Wide Groundvater Investigation 7
6.0 SUMMARY OP SITS RISKS 8
6.1 Human Health Risks 8
6.1.1 Scope .8
6.1.2 Contaminant Identification 11
6.1.3 Exposure Assessment Information 13
6.1.4 Toxicity Assessment Information 13
6.1.5 Risk Characterization Information 17
6.1.6 Uncertainties and Limitations in the BRA Process 18
6.2 Environmental Risks 21
7.0 DESCRIPTION OF ALTERNATIVES . 22
7.1 Remedial Action Objectives 22
7.2 ARARa 25
7.3 Development and Screening of Alternatives 25
7.3.1 Process 25
7.3.2 No Action Alternative 32
7.3.3 Alternative 1 32
7.3.4 Alternative 2A 32
7.3.5 Alternative 2B 33
7.3.6 Alternative 2C.. 33
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. 35
8.1 Criteria for Evaluating Remedial Alternatives 35
8.2 Threshold Criteria 35
8.2.1 Overall Protection of Human Health and the
Environment 35
8.2.2 Compliance with ARARm 35
8.3 Primary Balancing Criteria 35
8.3.1 Long-Term Effectiveness 35
8.3.2 Reduction of Toxicity, Mobility or Volume.. 35
8.3.3 Short-Term Effectiveness 37
8.3.4 Implement »*nity 37
8.3.5 Cost 37
8.4 Modifying Criteria 37
8.4.1 state Acceptance 37
8.4.2 Community Acceptance -. » 38
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9.0 SELECTED REMEDY jg
9.1 Selected Remedy * .3$
9.1.1 Description of Remedy 33
9.1.2 Performance Standards 39
9.2 Contingency Remedy 42
9.1.1 Description of Remedy 42
9.1.2 Performance Standards 43
10.0 STATUTORY REQUIPRMWITS 45
10.1 Purpose .45
10.2 Protection of Human Health and the Environment 46
10.3 Attainment of the Applicable or Relevant and
Appropriate Requirements .46
10.4 Cost Effectiveness 46
10.5 Utilization of Permanent Solutions to the
Maximum Extent Practicable 46
10.6 Preference for Treatment as a Principle Element , 46
11.0 EXPLANATION OF SIGNIFICANT DIFFERENCES .46
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FIGURES
Page
Figure One ........ Site Map ........................................ 2
Figure Two ........ Surfical Aquifer Flow Direction, 1990 ........... 9
Figure Three ...... Surfical Aquifer Flow Direction, 1991 .......... 10
Figure Four ....... Northern Surfj.ci.al Aquifer ..................... 23
Figure Five ....... Extraction Veil System ............... .......... 34
Figure Six ........ Wine Criteria ............. . .................... 36
TABLES
Table One. .. .Summary of Chemical Concentrations of the
Chemicals of Concern in the Surficial Aquifer ..... "12
Table Two. . . .Summary of Exposure Pathways ........................ 14
Table Three. .Assumptions Used to Estimate Exposure via
Ingeation of Groundwater . . . ......................... 15
Table Four. . .Summary of Chronic Rfds and Slope factors
fOral ToxicityJ ..................................... 16
Table Five. . .Cancer Risk by Individual Pathway. . . ................ 19
Table Six. . . .Hazard Index by Individual Pathway .............. ... .20
Table Seven.. ARARa .......................................... 26 - 31
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RECORD OF DECISION
OPERABLE UNIT TWO
REEVES SOUTHEASTERN SUPERFUND SITE
HILLSBOROUGH COUNTY, FLORIDA
. DECISION SUMMARY
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 Reeves Southwestern Wire
(SEW) facility located on the south side of SR 574 approximately
600 feet west of Faulkenburg Road. The SEG facility is on the
NPL, the SEW facility is not. Both facilities are still in
operation. 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 One, 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.
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BEEVES SOUTHEASTERN
CALVANlZiNC DIVISION •
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The smaller building on the facility is an office building.
There are three former percolation/evaporation ponds: one on the
central western edge of the property (now backfilled); and two on
the southwestern corner of the property. There are several
offsite wetlands near the three sites.
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 publicly 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 grpundwater
at the SEG facility. Subsequently, the Florida Department of
Environmental Protection (FDEP) (formerly the Florida Department
of Environmental Regulation) 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.
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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
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. The results
of the source characterization RI/FS and the resulting remedy
decision is documented in the Operable Unit One - Record-of -
Decision, October 1992. That remedy decision consists of the
following: excavation of contaminated soils and sediments on the
SEG and SEW facilities; backfilling of excavated areas with clean
fill; solidification/stabilization of the contaminated soils and
sediments; disposal of the solidified material above the water
table on the SEG facility; and capping of the solidified material
with a low permeability cap.
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/FS are detailed in the Area-Wide Hydroloaic
Remedial Investigation and Risk Assessment, Canonie
Environmental, Inc., April 1992 and the Area-Wide Hydro logic
Feasibility Study. Canonie Environmental, Inc., October 1992.
There is also a wetlands impact study being performed by EPA on
wetlands which are located to the north and south 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 s
"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
(SWFKMD), Tampa Bay Regional Planning Council (TBRPC), and
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Florida Department of Environmental Regulation, Southwest
District (FDEP-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.
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 control RI/FS was completed and presented to the
public in August 1992. A public meeting was held at the Brandon
Community College on August 18, 1992, at which the Agency's
preferred alternative for the Reeves source control cleanup plan
was presented. The preferred alternatives for the sources at the
Peak Oil and Bay Drums sites were also presented at this meeting.
The preferred alternative was, in fact, the cleanup plan that was
selected in the October 1992 ROD.
The area-wide groundwater RI/FS Report and Proposed Plan for the
Reeves Southeastern Site were released to the public on February
20, 1993. 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
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availability of these documents and announcement of the pending
public meeting was published in the Tampa Tribune on both
February 18 and February 22, 1993. A public comment period was
held from February 20 to March 22, 1993. The public meeting was
held on February 24, 1993. At the meeting, representatives from
EPA presented the three Proposed Plans and answered questions
regarding the problems at the three sites, the groundwater
remedial alternatives under consideration for the Reeves, Peak
Oil and Bay Drums sites and the ash pile remedial alternative
being considered for the Peak Oil site. 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 groundwater remedial action for the northern surficial
aquifer at 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
into two operable units (OUs). These are:
o OU One: Contamination in the soils and sediments.
o OU Two: Contamination in the groundwater.
OU One has been addressed in the Reeves OU One - ROD. October
1992. The Reeves OU Two will address the northern surficial
aquifer. The Peak Oil and Bay Drums OU Twos will address the
southern surficial and Upper Floridan aquifers. The Peak Oil and
Bay Drums OU Two will be selected in separate ROD. Originally,
it had been planned that the wetlands issues would also be
addressed in the OU Two RODs. However, no FS has been prepared
for the wetlands issues as of the time of this ROD, therefore
these issues will have to be addressed in a later, separate
action.
5.0 SUMMARY OP SITE CHARACTERISTICS
5.1 Scope
This section will discuss general site characteristics and
outline the results of the groundwater RI. The issue of source
contamination is addressed in the Operable unit One — Record of
Decision, October 1992 and will not be discussed further in this
ROD.
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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 being 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.
The groundwater system beneath the area consists of two major
water bearing units: a surficial aquifer and the Floridan
aquifer system. The surficial 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 surficial
aquifer is hydraulically connected to the wetlands near the site
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. The Floridan
aquifer is the primary source of drinking water and water for
industrial use in Hillsborough County, however, there are no
permitted wells which are used for drinking water in the general
vicinity of the site. To EPA's knowledge, the surficial aquifer
is not currently used for any purpose. It meets the criteria for
classification as a Class IIB aquifer under EPA's groundwater
protection strategy. A Class IIB aquifer is considered a
potential drinking water source.
5.3 Results of Area-Wide Groundwater Remedial Investigation
The area-wide groundwater RI was done in conjunction with the
Peak Oil and Bay Drums sites. The area-wide RI for the three
sites was divided into two phases of field work. Field work for
the first phase was conducted from October 1989 through January
1990; field work for the second phase was conducted from July
1991 through September 1991.
The analytical sampling, in the surficial aquifer showed 25
volatile organic compounds (VOCs), 29 semivolatile organic
compounds (SVOCs), 6 pesticides and 23 inorganic compounds. Most
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of the VOCs were found in the area of the Peak Oil and Bay Drums
sites. The compounds found under the SEG facility were, for the
large part, inorganic. These findings are consistent with the
findings in the Site Source Characterization Rls that were done
for the three sites.
The analytical results from the upper Floridan aquifer detected
impacts primarily in two of the ten wells sampled, Well F2 (the
Peak Oil Site production well) and Well F3 (the Bay Drums
production well). Wells F2 and F3 contained 13 and 15 VOCs,
respectively. These contaminants are not thought to be related
to the Reeves Southeastern Corporations's activities. There were
levels of trichloroethylene (TCE) found in the two former
production wells on the SEG facility. However, it is thought
that this result was a function of contamination that drained
down the inside of the casings and contaminated the water in the
wells themselves, not a result of a plume of contamination in the
upper Floridan aquifer. Ranges of the contaminants of concern
for the northern surficial aquifer can be seen in Table One.
In summary, the RI identified three areas of concern: the
northern surficial aquifer, which is primarily impacted by
metals; the southern surficial aquifer, which is impacted by
VOCs, SVOCs, and metals; and the upper Floridan aquifer, which
contains levels of VOCs. Figures Two and Three show the
direction of groundwater flow in the surficial aquifer at
different points of the year. Closer inspection of the results
indicated, however, that only the contaminants found in the
northern surficial aquifer could be substantially tied into the
operations at the Reeves facilities. Although there were some
levels of heavy metals in the southern surficial and Upper
Floridan, the vast majority of contaminants in these aquifers are
the result of source contamination at the Peak Oil and Bay Drum
sites.% For this reason, this ROD will focus on the northern
surficial aquifer and the Peak Oil and Bay Drums Oil Two RODS, to
be issued separately, will address the southern surficial and
Upper Floridan aquifers.
Sampling of the surface waters and sediments in the several
nearby wetlands was performed as a part of this RI. However,
this Proposed Plan only address the proposed groundwater remedy.
Therefore, those results will not be discuss as a part of this
Proposed Plan, but will be addressed in a later, separate
proposed plan and ROD.
6.0 SUMMARY OF SITE RISKS
fi. i Hnmar> Health Risks
6.1.1 Scope
A baseline risk assessment (BRA) was conducted as part of the RI
-a-
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BAY DRUMS. PEAK OIL. AND REEVES
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PRCPMUO roii
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to estimate the health or environmental problems that could
result if the Reeves site was not remediated. A BRA represents
an evaluation of the "No Action" alternative, in that
itidentifies the risk present if no remedial action is taken.
Theassessment 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 BRA process
can be divided into four components: contaminant identification;
exposure assessment; toxicity assessment; and risk
characterization.
Two separate BRAs 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 BRA is discussed in detail in the Operable Unit One ROD
(October 1992); the area-wide groundwater BRA is discussed in the
remainder of Section 6 of this ROD.
6.1.2 Ponfeaminant Identification
Based on the study area data, the BRA selected contaminants of
concern (COCs) to focus on those likely to pose the greatest
threat to human health. The COCs were based on those found in
the entire surficial aquifer, not divided up into the results of
the northern and southern surficial aquifers. As explained in
more detail in Section 7.2 of this ROD, the COCs for the northern
surficial aquifer were narrowed down to contaminants in the
groundwater that resulted from sources identified on the site and
were above any MCLs and/or exceeded a risk level of 1E-6 or a
hazard quotient of 0.1.
Appropriate exposure point concentrations (EPC) were then
calculated for each COC. Because the BRA did not separate the
COCs in the northern surficial aquifer from those in the southern
surficial aquifer, the exposure point concentrations calculated
in the BRA and identified in this ROD were calculated from the
data from the entire surficial aquifer. The COCs,.the highest
concentrations detected and the EPCs are found in Table One.
For arsenic, chromium, lead and nickel, there were wells on all
three sites containing concentrations above acceptable levels of
these four contaminants. Therefore, the EPCs reported in Table
One are moat likely reflective of the EPCs that would be
calculated for the northern surficial aquifer alone. For zinc
and cadmium, the majority of the zinc and cadmium concentrations
were found in the northern surficial aquifer. By factoring in
the large number of non-detects or detects at low levels from the
southern surficial aquifer, the EPC for the entire surficial
aquifer is lowered from the EPC that would be calculated from the
data from the northern surficial aquifer alone.
-11-
-------
TABLE ONE
Summary of Chemical Concentrations of the Chemicals of
Concern in the Surficial Aquifer
Chemical
Arsenic
Cadmium
Chromium
Zinc
Nickel
Lead2
Concentration (ug/1)
Highest
Concentration
Detected1
95
20
780
337,000
330
180
Exposure Point
Concentration1
123
53
67. 63
33,8003
46. 33
13.4 ug/1 (water)4
187,000 (soil)4
1 The concentrations reported in this table are for the entire
surficial aquifer. Concentrations calculated for just the
northern surficial aquifer would be slightly different. See
Section 6.1.2 of this ROD for a more detailed explanation of
this point.
2 The risk calculation for lead was done using the UBK model,
rather than the standard risk and/or hazard quotient
calculation. See Section 6.1.4 of this ROD for a more
detailed explanation of this point.
3 Upper 95% confidence limit on arithmetic mean confidence.
4 Arithmetic average for Reeves site.
-12-
-------
6.1.3 Exposure Assessment Information
Generally, there are two scenarios developed for the BRA: a
current use scenario; and a potential future use scenario. Under
the current use scenario, there is no exposure to groundwater,
therefore the current use scenario will not be discussed further
in this ROD. The future use scenario assumes that industrial
manufacturing operations take place at the three sites with no
cleanup of current levels of contaminants. A future use
residential scenario was also developed because it is the goal of
EPA's Superfund program to return Class I and Class II aquifers
to their beneficial uses which include human consumption. The
exposure pathways developed for the future use scenario are found
in Table Three. The exposure assumptions used in this BRA are in
Table Four.
6.1.4 Toxicity 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
the potential for adverse health effects from exposure to.
contaminant(s) of concern exhibiting nonearcinogenic 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 (CDZ) factors and the
applicable route-specific Slope Factors for the chemicals of
concern can be found in Table Five.
Environmental contamination with lead presents a problem in the
development of the BRA. This is because the "normal* background
exposures to lead from sources such as food, water and air
together contribute a substantial fraction of what EPA considers
-13- .
-------
TABLE TWO
SUMMARY OF EXPOSURE PATHWAYS
FOR THE GROUNDWATER
Future Use Condition/Onsite Worker
o Ingestion of groundvater from the surficial aquifer
Future Use Conditions/Onsite Resident
o Ingestion of groundwater from the surficial aquifer
o Dermal contact with surficial aquifer water while
showering
o Inhalation of surficial aquifer contaminants while
showering '
-14-
-------
TABLE THREE
Assumptions Used to Estimate Exposure via
Ingestion of Groundwater
Parameter
Chemical
Concentrations in
Water
Ingestion Rate
(L/day)
Exposure Frequency
(days /year)
Exposure Duration
(years)
Body Weight (kg)
Average Time (days)
Noncarc inogens
Carcinogens
Future Use Worker
Future Use Resident
see EPCs in Table One
1
250
30
70
10,950
25,550
2 ' .
365
30
70
10,950
25,550
-IS-
-------
TABLE FOUR
Summary of Chronic Rfds and Slope Factors
Chemical
Arsenic
Cadmium
Chromium
Nickel
Zinc
Oral Toxic ity
RfD
(mg/kg/day)
3.00E-4
5.00E-4
5.00E-3
2.00E-2
3.00E-1
SF
I/ (mg/kg/day)
1.75
NA
NA
NA
NA
Reference
IRIS
IRIS
IRIS
IRIS
IRIS
-16-
-------
the "acceptable" level of exposure and because the normally
accepted measure of maximum allowable exposure is expressed not
as a daily intake as is for most chemicals, but as aconcentration
in the blood. EPA has examined several procedures for assessing
lead and currently recommends the Uptake/Biokinetic (UBK) model
be used to predict blood lead concentrations resulting from
environmental concentrations of lead. For this BRA, version 0.4
of the UBK model was used. Blood levels for children from 0-6
years of age were modeled. Based on a directive from EPA Region
IV, acceptable exposures were defined as those that result i,n
predicted blood levels of less than 10 ug/dl in at least 95% of
the exposed children.
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:
Risk * GDI x SF
where:
risk = a unit less probability (e.g., 2E-6) of an individual
developing cancer;
GDI = chronic daily intake averaged over 70 years (mg/kg-day) ;SF
- slope-factor, expressed as (mg/kg-day)~l
These risks are probabilities that are generally expressed in
scientific notation (e.g., 1E-6). An excess lifetime cancer risk
of 1E-6 indicates that, as a reasonable Tnqx*""m 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 1E-6
to 1E-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:
-17-
-------
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).
Using these procedures, the lifetime cancer rates estimated to be
caused by the surficial aquifer at these sites can be found in
Table Six.
The hazard index due to ingestion of surficial aquifer water for
both future use scenarios are greater than 1.0. The results can
be seen in Table Seven.
The UBK model predicts as its output a probability curve around
the geometric mean of the blood lead concentrations, from which
the 95th percentile of the children's blood level concentration
can be determined. The model calculated that the percent of
exposed children predicted to have blood levels below 10 ug/dl is
99.70%.
All of the COCs have been found in the northern surficial aquifer
at levels higher than either mgyiimim contaminant levels (arsenic,
chromium, cadmium, lead, nickel) or acceptable health based
numbers (zinc). The northern surficial has been classified by
EPA as a Class I IB aquifer. The goal of EPA's Superfund approach
is to return usable and potentially usable groundwaters to their
beneficial uses within a reasonable timeframe. For Class I and
II aquifers, MCLs are generally considered the appropriate
preliminary cleanup goals; in their absence, health based numbers
are most often used. Any exceedences of these preliminary
cleanup goals is considered an appropriate justification to take
an action to return the groundwater to its beneficial use.
6.1.6 Uncertainties and Limitations in the BRA Process
Risk assessment provides a systematic means for organizing,
analyzing, and presenting information on the nature and magnitude
of risks posed by chemical exposures. Nevertheless,
uncertainties and limitations are present in all BRAs because of
the quality of available data and the need to make assumptions
and develop inferences based on incomplete information about
existing conditions and future circumstances. These
uncertainties and limitations should be recognized and considered
when discussing quantitative risk estimates. In general, the
uncertainties and limitations in the BRA can be classified in the
-is-
-------
TABLE FIVE
CANCER RISK BY INDIVIDUAL PATHWAY*
SCENARIO/EXPOSED
POPULATION
RISK
CHEMICAL
FUTURE USE - ONSITE WORKERS
Ingest ion, surficial
aquifer
8.81E-5
Arsenic
FUTURE USE - ONSITE RESIDENT
Ingest ion, surficial
aquifer
Inhalation while
showering, surficial
aquifer
Dermal absorption
while showering,
surficial aquifer
2.57E-4
5.83E-7
Arsenic
Arsenic
none
* The data used to calculate the risks was from the entire
surficial aquifer. However, only the results for the COCs are
reported here.
-19-
-------
TABLE SIX
HAZARD INDEX BY INDIVIDUAL PATHWAY"
SCENARIO/EXPOSED
POPULATION
RISK
CHEMICAL*
FUTURE USE - ONSITE WORKERS
Ingest ion, surficial
aquifer
Total
3.91E-1
1.32E-1
2.27E-2
1.10
Arsenic
Chromium
Nickel
Zinc
1.65
FUTURE USE - ONSITE RESIDENT
Ingest ion, surficial
aquifer
Total
Inhalation while
showering, surficial
aquifer
Dermal absorption
while showering,
surficial aquifer
Total
1.14
3.86E-1
6.61E-2
3.22
Arsenic
Chromium
Nickel
Zinc
4.81
none
2.59E-3
1.04E-2
2.94E-2
2.40E-3
1.17E-2
Arsenic
Cadmium
Chromium
Nickel
Zinc
.056
* The data used to calculate the hazard quotients was from
.the entire surficial aquifer. However, only the results for
the COCs are reported here.
-20-
-------
following categories:
o environmental sampling and laboratory measurement;
o mathematical fate and transport modeling;
o receptor exposure assessment; and
o toxilogical assessment.
The BRA is based on groundwater data specific to the sites
gathered for the Area-Wide RI. The quality of data depends dn
the adequacy of the set of rules or procedures that specify how a
sample is selected and handled. The quality assurance and
quality control procedures used to minimize uncertainties were
based on Region IV procedures and were reviewed and approved in
advance by EPA. They are described in detail in the RI Report.
The use of mathematical models to predict the fate and transport
of chemicals is accepted by EPA, however/ EPA does not specify
which models are would be the most appropriate to use in any
given situation. Because few models have been authoritatively
verified by field observations, there is some uncertainty
associated with their use. Tradeoffs in the various models
between simplicity, generality and accuracy are made on a site
specific basis and are based in part of the professional
judgement of the technical staff involved in that particular
site.
In the BRA, a large number of assumptions are made to assess
potential human exposure. In the absence of site specific data,
many of this BRA's assumptions were assumptions made by EPA. As
can be expected any time an assumption is made, there is some
dispute as to the appropriate level of conservatism should be
factored into that assumption.
Available scientific information is currently insufficient to
provide a thorough understanding of all the toxic properties of
chemicals to which humans are potentially exposed. This makes it
necessary in some cases to infer these properties by
extrapolating them from data obtained under other conditions of
exposure, generally in experimental laboratory animals. This may
introduce uncertainties of two types into the BRA: those related
to extrapolating from one species to another and those related to
extrapolating from the high exposure doses usually used in
experimental animal studies to the lower doses usually estimated
for human exposure situations.
6.2 Environmental Risks
The environmental risks at this site were addressed in a separate
study (Area-Wide Wetlands Impact Study). This study evaluates
-21- :
-------
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 Area-Wide 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
This OU2 ROD addresses only cleanup of the groundwater in the
northern surficial aquifer. The cleanup of the southern'
surficial aquifer and the upper Floridan aquifer will be
addressed in separate OUR RODS issued for the groundwater at the
Peak Oil and Bay Drums sites. This conclusion is reached based
on the aquifer flow directions, the confining layer between the
surficial and the Upper Floridan aquifers, and because the
contaminants found in the southern surficial and the upper
Floridan aquifers are considered to be a result of operations at
the Peak Oil and Bay Drums sites. The selection of chemicals
attributed to operations at the Reeves site is discussed in
moredetail later in this section. The area to be addressed in
the Northern surficial aquifer can be seen in Figure Four.
As stated before, the Risk Assessment that was done for the
groundwater RI/FS did not differentiate between that contaminants
that were found in the northern and southern surficial aquifers.
Instead the BRA separate the exposure scenarios based on
surficial and Upper Floridan aquifers. This ROD separates the
chemicals of concern found in the northern surficial aquifer
resulting from the Reeves site from the chemicals of concern
found in the southern surficial and Upper Floridan aquifers
resulting from the Peak Oil and Bay Drums sites. The methodology
used by EPA was to compare the list of indicator chemicals that
were determined to be important in the Reeves Source
Characterization risk assessment to the list of indicator
chemicals in the Area-Wide Groundwater risk assessment. The
indicator chemicals list from the Reeves source characterization
was as follows:
o arsenic
o cadmium
o ctupo^frj_mtt
o gold
o lead
o mercury
o nickel
o polychlorinated biphenyls (PCBs)
o polynuclear aromatic hydrocarbons (PAHs)
o 1,2,4-trichlorobenzene
o zinc.
-22-
-------
LLCitlQ.
t«—-«^.^ —«1__ J^"^^ f'-t "* '" •• " "',,1'— * '"^ I.*-" p ^"*"""
*
POOR QUALITY
U
R«il ROAD
>I«CI
UNtuf'uOvtO NOAfWAT
Ufl«il'".[ OIICll
OiRlCliQ" Or SUHlACt *A1tB flOK
SUfiOiKG HAllR
SURf.CIAl AOUlUR UOIIllORlHC Will
Aouirtn
MOMIORIHI
OCU fOH MOllllOHlNC PROGRAM
PROPOSIO SuRriciAi AOmrCR UONIIOB
win roR uONitoniHC PROGRAM
ARIA or IMPACKO GROUND »AI[R
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- AtRO-unmC (NONtCRMO. WC. JANVIAMY. I9«0.
PROJCCT NUMKM 0484*0
COMPLIANCE OOUNDARY AND
ARtA OF IMPACTED GROUND WATER
NORTHERN SURFICIAL AQUIFER
BAY DRUMS. PEAK OIL. AND REEVES
SUPERFUNO SITES
TAMPA. FLORIDA
PRCPAHCD rOH
POTENTIALLY
RESPONSIBLE PARTIES
CanonleEnvironment
SCAlC AS SHOWN
DRAiinC m,
17-iM-ut
-------
Of these indicator chemicals, gold, PCBs and 1,2,4-
trichlorobenzene were not determined to be present in the
groundwater in levels significant enough to be included in the
groundwater risk assessment. Some PAHs were found on both lists,
however no PAHs have ever been associated with the Reeves
operation. The PAHs were included in the Reeves
sourcecharacterization risk assessment because of their presence
in the soils on the western border of the SEW facility and have
been attributed to operations at the Peak Oil site. Mercury was
not found in the groundwater in levels above the federally
established MCL of 2 ug/1. This methodology leaves the following
list of contaminants found in the groundwater that can be
attributed to the Reeves site:
o
o
o
o
o
o
arsenic
cadmium
chromium
lead
nickel
zinc.
After reviewing the above list, the State of Florida had one
addition, aluminum. This addition is based on the elevated
levels of aluminum in the groundwater and in State regulations
mandating that secondary drinking water standards be enforced as
cleanup goals in Class 61 and Gil aquifers. These regulations
were amended in January 1993 to include aluminum. The original
risk assessment list was developed prior to the 1993 amendments;
therefore aluminum was not included in that list.
Cleanup levels for those contaminants were selected to protect
human health, welfare and the environment and to be in compliance
with applicable or relevant and appropriate requirements (ARARs).
The cleanup levels selected for the contaminants of concern in
the groundwater are as follows:
Contaminant of
Concern
Arsenic
Cadmium
Chromium
Lead
Cleanup
Level (UG/L)
50
5
100
15
Source of Cleanup Level
Federal MCL
Federal MCL; value from 56CFR
3528, 1/30/91; effective date
7/30/92
Federal MCL; value from 56CFR
3528, 1/30/91; effective date
7/30/92
Current Action Level, EPA
OSWER Directive #9355.4-02
-24"
-------
Nickel
Zinc
100
10,000
Federal MCL, proposed value
55CFR 30370-448, 7/25/90
None arc inogenic risk-based
concentration for future
onsite resident
7.2 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. Potential ARARs can be found in Table Seven.
7.3 Development and Screening of Alternatives
7.3.1 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, EPA considered four active remediation
alternatives in the groundwater FS. Those four alternatives are -
listed in the FS as Alternatives 1, 2A, 2B and 2C. The National
Contingency Plan (NCP) also requires the development of a no
action alternative as a basis for comparing other alternatives.
However, the groundwater FS was developed in conjunction with the
source characterization RI/FS and assumes that some type of
source control remedial action will be implemented along with the
selected groundwater remedial action. The true no action
alternative that is presented here was developed as a part of the
source characterization RI/FS.
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:
No Action Alternative
Alternative 1 - Source Control/Monitor ing
Alternative 2A - Active Restoration
Alternative 2B - Active Restoration
Alternative 2C - Active Restoration
-25-
-------
TABLE SEVEN
Aoolicable and Relevant and Appropriate Requirements
Authority/
Requirement
Safe Drinking Water Act
(SWA), 40 CFR 141.11-
141.16, 141.50-141.51
Clean Water Act (CWA)
Section 304 ( a) (1)
Ambient Water Quality
Criteria (AWQC)
Florida Surface Water
Quality Standards, FAC
17-302
Florida Underground
Injection Control
Regulations, FAC 17-
28.700
Chemical -Specific ARARs
Description
Primary Drinking
Water Standards
(MCLs and MCLGs)
AWQC are surface
water quality
criteria developed
to protect both
aquatic and human
health
Establishes minimum
surface water
quality criteria
for designated
classes
Authorizes zones of
discharge for
facilities
discharging to
groundwater as of
7/1/82
Status
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Applicable
Consideration
in the FS
Considered in
the development
of cleanup
goals
Considered in
development of
soil cleanup
levels
Considered in
the development
od remedial
alternatives
Considered in
the development
of groundwater
alternatives.
Alter
nativ
es it
appli
es to
1,
2A,B,
C
2A
1,
2A,B,
C
1,
2A,B,
C
-------
Florida Groundwater
Classes, Standards and
Exemptions, FAC 17-520
Classification of
aquifers and sets
cleanup standards
for different
classes
Applicable
Considered in
development of
groundwater
cleanup levels
1,
2A,B,
C
-------
Location Specific
Endangered Species Act
(50 CFR Part 402)
Requires action to
conserve endangered
or threatened
species for
activities in
critical habitats.
Applicable
Considered if
site is located
in critical
habitat area
for endangered
or threatened
species
2A,B,
C
Executive Order on
Protection of Wetlands,
40 CFR Part 6, Appendix A
Requires federal
agencies to avoid,
to the extent
possible, the
destruction of
wetlands
Relevant and
Appropriate
Considered in
the development
of remedial
alternatives
1,
2A,B,
C
K)
00
CWA Dredge and Fill
Provisions, 40 CFR Part
230
Restricts discharge
of dredge or fill
material that will
have an adverse
impact on wetlands
Relevant and
Appropriate
Considered in
the development
of alternatives
2A
Potable Water Well
Permitting in Delineated
Areas, FAC 17-524 and
Florida Statute 373.309
Regulatory
clearance to use
potable water wells
in areas of known
contamination.
Local Ordinance 90-
35 makes it
mandatory for
developers to
connect residences
and businesses to
public water
supplies where
available
Applicable
Considered in
the development
of remedial
alternatives
1,
2A,B,
C
-------
FAC 17-555.312
Wellhead protection
requirements.
Location of public
drinking water
wells. Specifies
buffer zone of no
less than 500 feet
between future
potable well and
existing land
applications of
reclaimed water
areas
Relevant and
Appropriate
Considered in
the development
of remedial
alternatives
2B
Florida Rules on
Hazardous Waste Warning
Signs, FAC 17-736
Requires the use of
appropriate warning
signs to inform
public of
potentially harmful
at site
Applicable
May be required
at perimeter
and entrance of
site
1,
2A,B,
C
«0
-------
Action-Specific
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
2A
Clean Water Act, Section
304(a)(l), Water Quality
Criteria (WQC)
o
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
2A
-------
I
to
CWA Water Quality
Standards [CWA 402
-------
7.3.2 No Action Alternative
Major 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 will 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.
7.3.3 Alternative 1 - Source Control/Monitoring
Ma-lor Components of the Remedial Alternative. For this
alternative, institutional actions such as regulatory
restrictions on groundwater use, groundwater monitoring and
implementation of surface and source control remediation would be
implemented. The purpose of the groundwater monitoring would be,
in part, to monitor the progress of the natural attenuation that
a groundwater model done for the FS anticipates would occur.
General Component. The source control remedy selected in the
Record of Decision - Operable Unit One, October 1992 would be
fully implemented. One new monitor well and three additional
monitor wells will be sampled twice a year for the first three
years and once a year thereafter for the remainder of the
monitoring period. It is anticipated that the groundwater would
attenuate to acceptable levels within 7.6 years of the completion
of the source control remedy. The monitoring period would last
for ten years. The location of the monitor wells would be within
or along the compliance boundary shown in Figure Four. Not
including the cost of the source control alternative, which is
stated in the Operable Unit One ROD (October 1992), the present
worth cost of this alternative is $136,000.
This alternative will meet all Federal and State ARARs.
7.3.4 Alternative 2A - Active Restoration
Ma*1or Components of the R^tnedial Alternative. This alternative
includes tbm installation and implementation of a groundwater
extraction system. . Groundwater would be extracted from the
ground, treated for heavy metals by chemical precipitation and
ion exchange, and discharged to the unnamed creek. According to
the model done for the FS, this alternative would reach
acceptable levels in the groundwater in 3.5 years of the
completion of the source control remedy.'
General Component. Approximately five extraction wells would be
-32-
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installed to recover groundwater at a steady-state extraction
rate of 25 gallon/minute (GPM). Each well would remove
approximately 5 gpm. A piping system would convey the extracted
groundwater to a central collection area for treatment. Figure
Five shows the proposed locations of the wells and treatment
system. Treatability studies will be needed in the design phase
to determine optimum treatment parameters at which most heavy
metals can be removed. The treated groundwater would be required
to meet applicable surface water standards before being
discharged into the unnamed creek. The present worth cost of
this alternative is $2,752,000.
This alternative will meet all Federal and State ARARs.
7.3.5 Alternative 2B - Active Restoration
Major Components of the Remedial Action. This alternative
includes the installation and implementation of a groundwater
extraction system. Groundwater would be extracted from the
ground, treated for heavy metals by chemical precipitation and
discharged by spray irrigation on property owned by Reeves in or
near the study area. According to the model done for the FS,
this alternative would reach acceptable levels in the groundwater
in 3.5 years of the completion of the source control remedy.
General Component. The location of the extraction wells and the •
treatment are identical to those described in Alternative 2A. In
addition, the spray irrigation system and the discharge piping
will consist of approximately 2,200 linear feet of piping. Water
entering the spray irrigation system would meat applicable
groundwater standards. Treatability studies will be needed in
the design phase to determine optimum treatment parameters at
which most heavy metals can be removed. The present worth costof
this alternative is $2,207,000.
This alternative will meet all Federal and State ARARs.
7.3.6 Alternative 2C - Active Restoration
Major Components of the Remedial Action. This alternative
includes the installation and implementation of a groundwater
extraction system. Groundwater would be extracted from the
ground, treated for heavy metals by chemical precipitation and
discharged into the local publicly owned treatment works (POTW).
According to the model done for the FS, this alternative would
reach acceptable levels in the groundwater in 3.5 years of the
completion of the source control remedy.
General Component. The location of the extraction wells and the
treatment are identical to those described in Alternative 2A.
Groundwater would be treated to meet pollutant limits set by the
POTW prior to discharge. The treated groundwater would be
-33-
-------
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PROPOSED GROUND WAtER
EXTRACTION SYSTEM
NORTHERN SURf ICIAL AQUIFER
BAY DRUMS. PEAK OIL. AND REEVES
SUPERFUND SMES
TAMPA. FLOKlOA
I t't I'M.( |. t, ••
POTENTIALLY
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Canonic 1 11 -cinmenla
-------
conveyed via 100 linear feet of piping to an onsite sewer line
for ultimate discharge into the POTW. A permit from the POTW
would have to be obtained in order to discharge the treated
groundwater into its system. The present worth cost of this
alternative is $2,504,000. 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
Figure Six the next page. The comparison of the five
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
At the point of completion of the remedy, alternatives 1, 2A, 2B
and 2C are all equally effective at providing overall protection
of human health and the environment. Alternative 1 will take a
significantly longer period of time to be completed than
Alternatives 2A, 2B, and 2C. The no action alternative is not
protective of human health and the environment.
8.2.2 Compliance with ARARs
Alternatives 1, 2A, 2B and 2C comply with relevant Federal and
State ARARs and with Super fund's preference for treatment.
Because the no action alternative does not comply with the
firsttwo criteria, it will not be considered further in this
analysis of alternatives.
8.3 Primary Balancing Criteria
8.3.1 Long-Term Effectiveness
Alternatives 2A, 2B and 2C are all equally effective at providing
overall protection of human health and the environment.
Alternative 1 will provide slightly lesser long term
effectiveness, primarily because of the length of time to reach
the cleanup goals.
All four of the alternatives will provide for a permanent
reduction of toxicity, mobility, and volume of chemicals by
treatment-
-35-
-------
CRITERIA FOR EVALUATING REMEDIAL ALTERNATIVES
In selecting it* preferred cleanup alternative, EPA uses the following criteria to evaluate each of
the alternatives developed in the Feasibility Study (FS). The first tiao criteria are the essential
Threshold Criteria and must be met before an alternatioecan 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. Alt nine criteria are explained in more detail here.
Overa&Prcteeti&cfHummHealAandtheSnoirani^
eliminate*, reduce*, or controls health and environmental tiireats^troughireatmtn^ engineering,
ti or instrfutirffif
CbmpBance with AfpGcable or Relevant and Appropri
with Federal/State requirements*
v
Cost * Weighing the benefits of a remedy against the cost of implementation- ;
ImplemeutabiUty- Refers; to the technical feasibility and administrative ease of a remedy*
Short-Term Sflec&ieae*** Length of time fr remedy to adveve protection and potentirf impact
of construction and implementation of a remedy,
Long-Tern EffeKfweues»" Degree- to which a remedy can maintafo projection of health and
environment once cleanup goals have been met,
of the treatment iigtoo^ movement or amount of contaminants*
f v^v f^ ffff ff '* f s ' """" ' f f
tflSfOtsQtt*.~Gr wtwQlM^ ^t ODtXtiEORt- Of SOtK- ^Sf^OdWEt ftfXGF9U3tO'OtRfrS 'ff .•.••' /
^^a'^^'^V -> ,; ';„-;,£ 4' -'' :'#"/,&'''/^~ ^ ,*r//, , -' :
%^*?''v-/''/J'*"" VxV-'.", ;f'*i,';! i'^r-"'/--/;/^//:,.'
Figure 6
-36-
-------
8.3.3 Short-Term Effectiveness
All alternatives may pose a minimal hazard to workers either
installing or operating the groundwater treatment system due to
dermal contact or accidental ingestion of contaminated
groundwater. There is also a minimal hazard to workers
associated with treatment system operations. Alternative 1 will
provide slightly more short-term effectiveness because there will
be no hazard to workers from the installation and operation of a
treatment system.
8.3.4 Implementabilitv
No technical restraints are anticipated. However, both 2A and 2C
will require discharge permits that may result in administrative
difficulties in implementing these remedies. Of these two, it is
anticipated that the discharge permit for the POTW may be easier
to obtain than the permit for discharging into surface water.
All three may require access agreements which may also result in
administrative delays.
8.3.5 Cost
The comparative present worth costs of the four remaining
alternatives are as follows:
Alternative 1 $136,000
Alternative 2A $2,752,000
Alternative 2B $2,207,000
Alternative 2C $2,504,000
The substantially lower cost for Alternative 1 reflects the fact
that this is primarily a monitoring/institutional control
alternative; the cost of the source control remedy is not
included in this cost estimate. The differences in costs between
the three active restoration remedies mostly reflect the
differences in costs between the three discharge options; in
addition, Alternative 2A has a two step treatment train (chemical
precipitation/ion exchange), Alternatives 2B and 2C have only one
(chemical precipitation).
8.4 Modifying Criteria
8.4.1 State Acceptance
The State of Florida, as represented by the Florida Department of
Environmental Regulation (FDEP), has been the support agency
during the Remedial Investigation and Feasibility Study process
for the Reeves Southeastern site. In accordance with the 40 CFR
300.430, FDEP, as the support agency, has provided input during
this process. Based upon comments received from FDEP, it is
expected that concurrence will be forthcoming; however, a formal
-37-
-------
letter of concurrence has not yet been received.
8.4.2 rrttmminity Acceptance
The general public in the community expressed no major concerns
about the selected remedy during the public comment period. The
Reeves corporation, however, submitted lengthy comments objecting
to the preferred alternative and suggesting that EPA select
Alternative 1 instead. The comments from both the community and
the Reeves Corporation are discussed in detail in the
Responsiveness Summary, which is Appendix A of this ROD.
9.0 SELECTION OF REMEDY
9.1 Selected Remedy
9.1.1 Description of 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 1, with modifications, as
the groundwater management of migration remedy for the Northern
Surficial Aquifer at this site. The modifications consist of the
following:
MODIFICATION ONE
MODIFICATION TWO
MODIFICATION THREE
The northern surficial aquifer shall be
sampled as a task in the OO2 RD. The purpose
of this sampling shall be to establish "time-
zero" levels of the COCs. If the levels of
COCs have not been reduced to either below
the selected performance standards or by at
least 50% from the "time-zero* levels within
2.6 years of the completion of the OU1 RA,
the presumption shall be that the selected
remedy is not working and that the
contingency remedy shall be implemented. The
OD1 remedy shall be considered complete upon
submittal of the final Final Inspection
Report.
The RD for the contingency remedy (described
in detail in Section 9.2) shall be completed
prior to the completion of Modification One.
Groundwater from the northern surficial
aquifer shall be prevented from further
discharging into the unnamed creek. The OU2
RD will contain an engineering proposal that
will, when built, prevent further discharge.
Upon EPA's approval of the engineering
proposal, the barrier will be constructed.
-38-
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At the completion of this remedy/ the potential future risks
associated with the groundwater at this site will be within EPA's
acceptable risk range of IxlO"6 to 1x10"*. EPA has determined
that this risk range is protective of human health and the
environment. Because this remedy will result in hazardous
substances remaining onsite above health-based levels for a time
period exceeding five years/ a review will be conducted within
five years after commencement of the remedial action to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
Major Components of the Remedial Alternative. For this -
alternative, institutional actions such as regulatory
restrictions on groundwater use, groundwater monitoring and
implementation of surface and source control remediation would be
implemented. The purpose of the groundwater monitoring would be,
in part/ to monitor the progress of the natural attenuation that
a groundwater model done for the FS anticipates would occur.
General Component. The source control remedy selected in the
Record of Decision - Operable Dnit One/ October 1992 would be
fully implemented. One new monitor well and three additional
monitor wells will be sampled twice a year for the first three
years and once a year thereafter for the remainder of the
monitoring period. The model in the FS predicted that the
groundwater will attenuate to acceptable levels within 7.6 years .
of the completion of the source control remedy. The monitoring
period will last for ten years. The location of the monitor
wells will be within or along the compliance boundary shown in
Figure Four. Not including the cost of the source control
alternative, which is stated in the Operable Unit One ROD
(October 1992)/ or the costs associated with the three
modifications, the present worth cost of this alternative is
$136,000.
9.1.2 Performance Standards
The Performance Standards selected for the chemicals of concern
are as follows: -
Contaminant of
Concern
Arsenic
Cadmium
Chromium
Cleanup
Level (DG/L)
50
5
100
Source of Cleanup Level
Federal MCL
Federal MCL; value from 56
CFR 3528, 1/30/91; effective
date 7/30/92
Federal MCL; value from 56
CFR 3528, 1/30/91; effective
date 7/30/92
-39-
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Lead
Nickel
Zinc
15
100
10,000
Current Action Level, EPA
OSWER Directive #9355.4-02
Federal MCL, proposed value
55 CFR 30370-448, 7/25/90
None arc inogenic risk-based
concentration for future
onsite resident
These Performance Standards were selected based on the following
conditions being met:
CONDITION ONE A thorough door-to-door private well survey shall
be performed as a task in the OU2 Remedial Design.
The information to be gathered in the well survey
is as followst (1) size of private well; and (2)
depth of private well. The in-depth well survey
shall cover the same territory that was covered
for the preliminary well survey done for the Area-
Wide Groundwater RI/FS. Private wells that are in
use and are discovered in this well survey shall
be sampled for the COCs. If the levels in the .
private well water.sample are above the selected
Performance Standards and it is determined that
the private well contamination is related to the
Reeves Southeastern site, then the users of that
well should be offered the opportunity to be
hooked up to the public water at no charge.
CONDITION TWO As a task in the OD2 RD, a Floridan monitor well
shall be constructed in the general vicinity of
the former production wells on the SEG facility.
This well shall be monitored for violations of
Florida's secondary drinking water standards as
designated in F.A.C. 17-550.
If during the RD/RA phase, these conditions are not met or a
showing is made that the northern surficial aquifer is a likely
potable drinking water source, then the Performance Standards
will revert to the following:
Contaminant of
Concern
Arsenic
Cadmium
Cleanup
Level (DG/L)
50
5
Source of Cleanup Level
Federal MCL
Federal MCL; value from 56CFR
3528, 1/30/91; effective date
7/30/92
-40-
-------
Chromium
Lead
Nickel
Zinc
Aluminum
100
15
100
5,000
200
Federal MCL; value from 56CFR
3528, 1/30/91; effective date
7/30/92
Current Action Level, EPA
OSWER Directive f 9355. 4-02
Federal MCL, proposed value
55CFR 30370-448, 7/25/90
F.A.C. Chapter 17-550,
January 1993
F.A.C. Chapter 17-550,
January 1993
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.
ARARs Component. The major federal ARARs and TBCs for this
alternative are as follows:
o Safe Drinking Water Act (SWA), 40 CFR 141.11-141.16,
141.50-141.51 '
o Clean Water Act (CWA) Section 304(a)(1), Ambient Water
Quality Criteria (AWQC)
o Endangered Species Act, (50 CFR Part 402)
o Executive Order on Protection of Wetlands, 40 CFR Part
6, Appendix A
o CWA Water Quality Standards [CWA 402 (a)(l)]
The major State ARARs and TBCs are as follows:
o Florida Surface Water Quality Standards, FAC 17-302
Florida Drinking Water Standards, FAC 17-550
o
o
Florida Groundwater Classes, Standards and Exemptions,
FAC 17-520
Florida Underground Injection Control Regulations, FAC
17-28.7QO
Potable Water Well Permitting in Delineated Areas, FAC
17-524 and Florida Statute 373.309
-41-
-------
o FAC 17-555.312
o FAC 17-555.312
o Florida Rules on Hazardous Waste Warning Signs, FAC 17-
736
This alternative shall meet all Federal and State ARARs.
9.2 Contingency Remedy
9.2.1 Description of Remedy
If the conditions in Modification One of the selected remedy are
not met, then the contingency remedy for the site shall be
implemented. Based upon consideration of the requirements of
CERCLA, the NCP, the detailed analyses of alternatives and public
and state comments, EPA has selected Alternative 2C as the
contingency groundwater management of migration remedy for the
Northern Surficial Aquifer at this site. The engineering
proposal described in Modificiation Three of the original remedy
shall be constructed. At the completion of this remedy, the risk
potential future risks associated with the groundwater at this
site will be within EPA's acceptable risk range of IxlO"6 to 1x10'
4. EPA has determined that this risk range is protective of
human health and the environment. Because this remedy will
result in hazardous substances remaining onsite above health-
based levels for a time period exceeding five years, a review
will be conducted within five years after commencement of the
remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment. The
total present worth cost of the contingency remedy is estimated
at $2,504,000.
Major Components of the Remedial Action. This alternative
includes the installation and implementation of a groundwater
extraction system. Groundwater would be extracted from the
ground, treated for heavy metals by chemical precipitation and
discharged into the local publicly owned treatment works (POTW).
General Component. The location of the extraction wells and the
treatment unit are located on the northern part of the Reeves
facility. Groundwater would be treated to meet pollutant limits
set by the. POTW prior to discharge. The treated groundwater
would be conveyed via 100 linear feet of piping to an onsite
sewer line for ultimate discharge into the POTW. A permit from
the POTW would have to be obtained in order to discharge the
treated groundwater into its system. The extracted groundwater
will be treated to levels set by the POTW prior to discharge.
-42-
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9.2.2 Performance Standards
The Performance Standards selected for the chemicals of concern
are as follows:
Contaminant of
Concern
Arsenic
Cadmium
Chromium
Lead
Nickel
Zinc
Cleanup
Level (UG/L)
50
5
100
15
100
10,000
Source of Cleanup Level
Federal MCL
Federal MCL; value from 56CFR
3528, 1/30/91; effective date
7/30/92
Federal MCL; value from 56CFR
3528, 1/30/91; effective date
7/30/92
Current Action Level, EPA
OSWER Directive #9355.4-02
Federal MCL, proposed value
55CFR 30370-448, 7/25/90
None arc inogenic risk-based
concentration for future
onsite resident
These Performance Standards were selected based on the following
conditions being met:
CONDITION ONE
CONDITION TWO
A thorough door-to-door private well survey shall
be performed as a task in the OU2 Remedial Design.
The information to be gathered in the well survey
is as follows: (1) size of private well; and (2)
depth of private well. The in-depth well survey
shall cover the same territory that was covered
for the preliminary well survey done for the Area-
Wide Groundwater RI/FS. Private wells that are in
use and are discovered in this well survey shall
be sampled for the COCs. If the levels in the
private well water sample are above the selected
Performance Standards and it is determined that
the private well contamination is related to the
Reeves Southeastern site, then the users of that
well should be offered the opportunity to be
hooked up to the public water at no charge.
As a task in the OU2 RD, a Floridan monitor well
shall be constructed in the general vicinity of
the former production wells on the SEG facility.
This well shall be monitored for violations of
-43-
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Florida's secondary drinking water standards as
designated in F.A.C. 17-550.
These conditions are added in order to make a showing that the
northern surficial aquifer is exempt from compliance with Florida
secondary drinking water standards under F.A.C. 17-520. If
during the RD/RA phase, these conditions are not met or a showing
is made that that the northern surficial aquifer is a likely
potable drinking water source, then the Performance Standards
will revert to the following:
Contaminant of
Concern
Arsenic
Cadmium
Chromium
Lead
Nickel
Zinc
Aluminum
Cleanup
Level (UG/L)
50
5
100
15
100
5,000
200
Source of Cleanup Level
Federal MCL
Federal MCL; value from 56CFR
3528, 1/30/91; effective date
7/30/92
Federal MCL; value from 56CFR
3528, 1/30/91; effective date
7/30/92
Current Action Level, EPA
OSWER Directive #9355.4-02
Federal MCL, proposed value
55CFR 30370-448, 7/25/90
F.A.C. Chapter 17-550,
January 1993
F.A.C. Chapter 17-550,
January 1993
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.
ARARs Component. The major federal ARARs and TBCs for this
alternative are as follows:
o Safe Drinking Water Act (SWA), 40 CPR 141.11-141.16,
141.50-141.51
o Clean Water Act (CWA) Section 304(a)(l), Ambient Water
Quality Criteria (AWQC)
o Endangered Species Act, (50 CFR Part 402)
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o Executive Order on Protection of Wetlands, 40 CFR Part
6, Appendix A
o CWA Water Quality Standards [CWA 402 (a)(l)]
o CWA Discharge to Publicly Owned Treatment Works (POTW),
CWA 307, 40 CFR 403
The major State ARARs and TBCs are as follows:
o Florida Surface Water Quality Standards, FAC 17-30?
. o Florida Drinking Water Standards, FAC 17-550
o Florida Groundwater Classes, Standards and Exemptions,
FAC 17-520
o Florida Underground Injection Control Regulations, FAC
17-28.700
o Potable Water Well Permitting in Delineated Areas, FAC
17-524 and Florida Statute 373,309
o FAC 17-555.312
o FAC 17-555.312 -
o Florida Rules on Hazardous Waste Warning Signs, FAC 17-
736
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 H*in**Ti Health and the Environment
The selected remedy protects human health and the environment by
removing contamination from the groundwater before it can either
be ingested by humans or migrate into a surface water body and
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cause damage to the environment.
10.3 Attainment of the Applicable or Relevant and Ai
Requirements (ARARs)
The selected remedy complies with 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 groundwater at a cost
of $140,000. The selected remedy will achieve performance
standards at a significantly lower cost than the other
alternatives.
10.5 Utilization of Permanent Solutions to the Max^mum 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 groundwater management of migration 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.
10.6 Preference for Trea^-^ent as a Principle Element
By reducing the level of contamination in the northern surficial
aquifer to levels protective of human health and the environment,
EPA will meet the statutory preference for treatment as a
principal element of the remedy.
11.0 EXPLANATION OF SIGNIFICANT DIFFERENCES
The Proposed Plan for the groundwater at the site specified four
alternatives for the cleanup of the northern surficial aquifer
and identified Alternative 2C as EPA's preferred alternative.
The Proposed Plan also identified secondary drinking water
standards for zinc and aluminum as cleanup goals/performance
standards. EPA received information during the public comment
period that led it to select Alternative 1 as the appropriate
remedy, with Alternative 2C being selected as the contingency
remedy. The information received during the public comment
period also led to the lead agency adding three modifications to
Alternative 1 and to the selection of a different performance
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standard for zinc and dropping aluminum from the list of COCs
altogether. The explanations for the addition of each
modification to Alternative 1 and for the differing performance
standards are presented in more detail in the remainder of this
section.
The choice of Alternative 1 was based partially on EPA's
understanding from the groundwater model done for the FS
(Appendix A in FS and December 4, 1992 letter from Canonie to
Martha Berry, EPA and enclosure) that the active restoration
scenarios would clean up the groundwater in 3.5 years. Without
active groundwater restoration, then the groundwater model
estimated that acceptable levels would be reached by natural
attenuation in 7.6 years. The contaminant used in the
groundwater model was zinc, and the acceptable level that was
used was 10,000 ug/1 (health based number used in the source
characterization RI/FS and approved by EPA - EPA has no MCL for
zinc). EPA also had in its possession the following information
regarding land and aquifer use in the area of the site:
o Areawide RI, Section 2.4 Land Use and Zoning, Pages 2-7
through 2-13 - This section describes the land use and
zoning for the property in the area of the three sites.
According to the third paragraph on page 2-10 and the
map on page 2-8, there are no areas on or immediately
downgradient of the site that are zoned for residential.
use. Given that there are a number of other industrial
and/or commercial facilities in the vicinity of the
three sites, it is not likely that these properties
will be rezoned for residential use in the future.
o Areawide FS, Section 4.3 Private Well Survey, pages
4-38 through 4-43 - This section describes the results
of the private well survey conducted during the
areawide groundwater RI/FS. No potable water wells in
the surficial aquifer were discovered in this survey.
o Ground-Water Quality of the Southwest: Florida Water
Management District, Central Region, Section 2, April
1991, page 40 - This report states that the surficial
aquifer in the general region is only used to a limited
extent for lawn irrigation and stock watering.
o Map of the water Mains in the area of the three sites.
Public water service is readily available to properties
at and around the sites.
o FAC 17-524.300, General Requirements for Hew Potable
Water Well Permitting in Delineated Areas - These
regulations would appear to prevent the installation of
any potable water wells in the surficial aquifer for
two reasons.
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1) Under FAC 17-524.420, the procedures for
delineating areas where these permit requirements are
applicable are outlined. Under these procedures, the
area where these three sites are located has been
designated a delineated area. FAC 17-524.430
incorporates, by reference, the various maps showing
the delineated areas around the state.
2) In delineated areas, permitting of a new potable
water well, with certain well defined restrictions, is
prohibited in areas of groundwater contamination where
a distribution line of an available potable wafer *
supply is within 500 feet of the boundary of the
property for which a well construction permit is being
sought.
o If a potable water well was installed in the surficial
aquifer, FAC 17-524.600 would require that the well
shall be tested "... for the presence in the untreated
water of the ground water contamination which resulted
in the delineation." If groundwater contamination was
then detected, then FAC 17-524.650 would require "...a
well not be cleared for use without a demonstration,
through water quality testing, that a filter or other
permanent remedy prevents the users of the well from
being exposed to groundwater contamination."
Initially, FDEP had opposed the selection of Alternative 1.
FDEP's position was that the four year difference between the
completion of one of the active restoration remedies and the
completion of the natural attenuation remedy was unacceptable.
For this reason, EPA selected Alternative 2C as the preferred
alternative for the OU2 Proposed Plan. However, because the
above information concerning land use supported the unlikelihood
of the use of the northern surficial aquifer as a potable water
source, FDEP later decided that a modified version of Alternative
1 would be acceptable. Based on the Canonie groundwater model,
2.6 years after the completion of the source control remedy was
selected as an appropriate interim point at which to sample to
determine whether the natural attenuation remedy was reaching the
performance standards in the time period predicted by the
groundwater model. Modifications One and Two were added to the
remedy based on this decision. If Alternative 1 does not
performed as predicted, then Alternative 2C would be implemented
as the contingency.remedy.
As stated before, the Proposed Plan identified Florida's
secondary drinking water standards for zinc and aluminum as
performance standards. In the final October 1992 FS developed
for the site, secondary drinking water standards (SDWSs) were
specifically excluded as ARARs. Therefore no SDWSs were
identified as performance standards for the COCs for the northern
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surficial aquifer (in the PS). In December 1992, FDEP identified
to EPA regulations that would require the application of Florida
SDWSs as State ARARs. These regulations were F.A.C. Chapters 17-
520 and 550. After several exchanges of information with FDEP,
EPA agreed that SDWSs were State ARARs. These exchanges of
information are documented more thoroughly in a February 18, 1993
memorandum from Martha Berry, EPA RPM to the Reeves site file,
which.was included in the Administrative Record that was
available to the public during the public comment period. This
change did not affect the proposed performance standards for
arsenic, lead, nickel, cadmium or chromium. However it did
require the lowering of the proposed performance standard for
zinc from 10,000 ug/1 (a health based number recommended by EPA
Region IV Office of Health Assessment) to 5,000 ug/1 (Florida
SOWS). It also required the addition of aluminum as a COC with a
proposed performance standard of 200 ug/1 (Florida SWDS). These
were the proposed performance standards that were listed in the
OU2 Proposed Plan.
During the public comment period, FDEP submitted a March 30, 1993
letter clarifying its position regarding the use of SDWSs as
State ARARs. Following is a quote from this letter:
Florida Secondary drinking water standards, as defined in
Chapter 17-550, F.A.C., and as they apply to Class G-II
groundwater, as defined in Chapter 17-520, F.A.C., are
applicable or relevant and appropriate requirements (ARARs)
at NPL sites. The criteria and standards in these rules
fulfill the initial requirements as ARARs pursuant to
CERCLA 121 (d)(2)(A).
Under the FDEP's administrative rules, an existing
installation is exempt from compliance with secondary
standards "...unless the Department determines that
compliance with one or more secondary standards by such
installation is necessary to protect groundwater used or
reasonably likely to be used as a potable water source "
(17-520.520, F.A.C.). While such an exemption is probable
at the Reeves site under F.A.C., the secondary standards
specified in 17-550, F.A.C., are relevant and appropriate.
In other words, FDEP must consider exceedances of secondary
standards and make further determinations as to whether
these exceedances are violations which require cleanup to
the standards as part of a CERCLA remedial action.
Also in its March 30, 1993 letter, FDEP lists the conditions
that, if fulfilled, would result in the exemption from compliance
with secondary drinking water standards. This conditions are
listed as Conditions One and Two in the performance standards
section of the selected remedy chapter.
In this same letter, FDEP also asserted that Class III surface
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water standards as defined in 17-302, F.A.C. were ARARs that
should be applied to the surface water in the unnamed creek.
This is relevant to the groundwater remedy in that, during
certain hydrological periods, the contaminated groundwater
discharges into the unnamed creek. FDEP asserted that the
groundwater discharge into the unnamed creek was a significant
cause of the violations of those standards that were found in the
surface water during the RI/FS; therefore this discharge should
be addressed during the OU2 ROD, rather than waiting for the
wetlands ROD as EPA had originally intended to do. Based on
this, EPA added Modification Three to the selected remedy.
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