PB94- 964074
EPA/ROD/R04-94/207
February 1995
EPA Superfund
Record of Decision:
Peak Oil Co./Bay Drums Co,
(O.U. 4), Tampa, FL
6/28/1994
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RECORD OF DECISION
OPERABLE UNIT 4
CENTRAL *ND SOUTH WETLANDS
PEAK OIL/BAY DRUMS NPL SITE
Brandon, Hillsborough County, Florida
Prepared By:
Environmental Protection Agency
Region IV
Atlanta, Georgia
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RECORD OP DBCISION
OPBRABLB UNIT POUR
CENTRAL AND SOUTH WETLANDS
PBAlt OIL/BAY DRUMS NPL SITS
DECLARATION
SITB NAMS AND LOCATION
Peak. Oil/Bay Drums Superfund Site
Brandon, Hi~lsborough County, Florida
STATEHBNT OP BASIS AND. PURPOSE
This decision document presents the selected remedial action for
Operable Unit Four at the Peak Oil/Bay Drums site in. Brandon~
HillsboroughCounty, .Florida, which was chosen in accordance with
the Comprehensive Bnvironmental Response Compensation and .
Liability Act of 1980 (CERCLA), as amended by the Superfund.
Amendments Reauthorization Act of 1986 (SARA), and,to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This decision is based on the. .
administrative record file for this site.
The State of Florida, as represented by the Florida Department of
Bnvironmental Protection (FDEP) , has been the support agency
.during the Remedial Investigation and Feasibility Study process
.for the Peak.Oil/Bay Drums site. In accordance with ~O CPR
300.430, as the support agency, FDEP has provided input during
this process and although a formal letter of concurrence has not
yet been received, concurrence is expected.
DESCRIPTION OF SELECTED REMEDY
The selected remedy described in this document addresses the
fourth and final operable unit, which consists of two wetlands,
the Central Wetland and the South Wetland, located in the area of
the Bay Drums and Peak Oil site. The Operable Unit One remedy
addresses the source of contamination at the Peak Oil site
through the treatment of contaminated soils and the ash pile
l~cated OD the site. The Operable Unit Two remedy addresses the
. groundwater contamination of the southern surficial. aquifer and
.. the.Upper Floridan Aquifer at the Peak Oil and Bay Drums sites.
The Operable Unit Three remedy addresses the source of
contaminatio~ at the Bay Drums site through the treatment of
contaminated soils on the site. The implementation of the
Operable Unit One, Two, and Three remed~es will eliminate or
significantly reduce the potential for contaminant migratiori from
the Bay Drums. and Peak Oil facilities to the wetland areas;
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.;
The selected remedy is.a "no-action" remedy that will include
~cologicarmonitoring of the wetlands. The purpose of the
selected remedy is to monitor the ecologic status of the Central
and South wetlands as the Operable Upits O~e, Two, and Three
remedies are being implemented and. to ensure. that conditions in
the. .~etlands are protective of human health and the environment ~
DECLARATION STATEMENT
The EPA has determined that no action is necessary to ensure the
. protection of human health or the environment. Because.
monitoring will be conducted in the wetlands, the five year. .
review will apply to this site as required in Section 121(c) of
CERCLA.
Date
(, -2P-74
.~~~~
John H. Hankinson, .
Regional Administrator
U.S. EPA Region IV .
ii
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TABLB OP CONTBHTS
DECLARATION
. ... ................. ......... ... ..... ......
PAGE
i
,Table of Contents ..................,.................... iii
List of Figures and Tables....................... ......
1.0
2.0
Site Location and Description ..................~..
Site History and Enfqrcement Activities ...........
2 . l' Site Wetlands.... . . . . . . . . . . . . . . . . . . . . . .0 . . . . . .
2 . 2 Peak 0 i 1 Sit e .....;.................;........
2.3 Bay Drums Site.... '. . . . . . .. . . . . . . . . . ~ . . . . . . . . .
, ,
3.0 ,Highlights of COImnunity participation .............
~.o
5.0
. 6.0
7.0
Scope and Role of Operable Unit
...................
Summary of Site Characteristics ................... 9
5 . 1 Cl ilt\a. t e .............. "! . . . . . . . . . ... . . . . . . . . . ~.".. 9
5.2 Site 0 Topography., 'drainage and
o Surface Features ...........................~ ,9
Regional Geology. '. . . '. . . . . . . . . . . . ~ . . . . . . . . . ... 9
Regional Hydrogeology ....'.................... 10
Potential Contaminant Sources and 0
Chemical Transport Mechanisms................
5.6 Sampling Results. .............................
S.- 6.1 Sediment..............................
5.6.2 Surface Water...... ~ . . . . . . . . . . . . . .. . . .
5.3
5.4
5.5
v
1
4
4
5
6
7
8
13
13
14
15
Base~ine Risk Assessment Summary .................. 20 .
6 . 1 Human Heal th Risks............. 0... . . . . . . . . . . .0 20
6 . 2 EnviroIU:1ental Risks..........;............... 20
6.2.1
6.2~2
6.2.3
6.2.4
Wetland Characterization and
Functional Assessment ................
Bioaccumulation '..........0.............
Environmental Toxi~ity Assessment ...~.
Bndangered 0 Species. . . . . . . . . . . . . . . . . . . '.
Description of Remedial ~ternatives ..............
7.1 Alternative No.1 - No Action: with 0 "
Bcological Monitoring.......................
7.2 Alternative No.2 - Filling of the Wetlands.. .'
7.3 Alternative No.3 -,Wetland Excavation and,
Restoration. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
iii
20
'20
21
22
22
22
23
25
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Table of Contents (Continued)
PAGE
8.0
, '
Comparative Analysis of Remedial Alternatives ....
8.1 Overall Protection of Human Health and'
25
25
8.2
8.3
8.4
8.S
8.6
, 8.7
8.8
8.9
'.the Environm.ent .............. ~ . . . . . . . . . ". . . . .
Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs) ............ 26
Long-Term Effectiveness and Permanence ....... 26,
Reduction of Toxicity~ Mobility, or -
Volume, Through Treatment .................... 28
Short-Term Effectiveness .........."..........0 28
Implementability iii......".... ..... ."............." 28
Cost. . . . . . ... . . . . . . . . . . . . ". .'. . . . . . . ~ . . . . . . . . . . . 29
State Acceptance.............. . . . . . . . . . . . . .. . .. . 29
Community'Acceptance ......................... 30
Selected Remedy................................... 30
'9.1 Major Components of the Remedy... ,. . . . . . . . . . ,. . ~, 30
9.2 Compliance with ARARs...... . . . . -. . . . . . . . . . . . . .. . 31'
9.0
10.0
Documentation of Si~ificant Changes
. . . . . . . . . . . . .
31
Appendix A - Responsiveness S11mmary
iv
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Figure 1
Figure :2
Figure 3
Figure 4
Table '1
List of Figures
Site Location Plan......... ...................
Study Area Plan...............................
Typical Geologic Profile......................
Surface Water .and Sediment
Sampling Locations......... .............. .'.,...
List of Tables
Sediment Screening Values.....................
Table:2 Ratio of Analyte Concentrations in Wetland
Sediments to NOAA ER-L Values.~....~......... 18
Table 3 Concentration of Analytes Exceeding Florida
Surface Water Quality Standards in the Central
And South Wetlands.. . . . . . . . . . . . . . . . . . . . . . . . . .
Table 4
Glossary of Evaluation Criteria...............
v
PAGE
:2
3
11
16
17
19
27
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Decision S1111nftary
Operable Unit Pour - Central and South Wetlands
Peak Oil/Bay Drums Superfund Site
Brandon, Billsborough County, Plorida
Site Location. and Descri~tion
1.0
The adjacent Peak Oil and Bay Drums sites and two nearby wetlands
(collectively referred to in this document as the "site" or the
"Peak Oil/Bay Drums site") are located in north central
Hillsborough County, Florida within the southeast quarter of
Section 7, Township 29 South, Range 20 East (Figure 1) . . The site
is .located on State Road 574 (SR 574), approximately 0.25 ~iles
west of Faulkenburg Road. The two site wetlands are called the
Central Wetland,. located immediately to the south of the former
Bay Drums facility, and the South Wetland, located about 500 feet
southeast o.f the former Peak Oil .facility (figure 2). Both the
Central and the South wetlands are located on property owned by
Hillsborough County. . Two additional wetlands, the Cypress Pond
Wetland and the Srayfield Wetland, are evaluated as comparison
. wetlands ~nd are located several hundred yards south of the site.,
., .
The site is located in a primaTily industrial area which contains
a number of facilities. The Reeves Southeastern Wire facility
and the Cast-Metals facility are located to the east of the Peak
Oil site. Located between the Central and South wetlands are the
Peoples Gas Company's natural gas distribution center and a 80il
and construction debris pile referred to as the shingle pile. The
.shingle pile was moved by EPA to its present location from the
Bay Drums site during an EPA removal action in 1989. The .
Consolidated Bag Company is located southwest of the shingle
pile. An abandoned CSX Railroad spur runs south between the Peak
Oil and Bay Drums sites and leads to the South Wetland. This
spur once serviced the Tampa Bay Sunshine Skyway Bridge painting
s,ite located both north. and south o'f the spur near. the -South -
Wetland. The area south of the Bay Drums site is un~eveloped
Hillsborough County-owned land. South of the Central Wetland is
an area which was historically used as a sprayfield for the
Hillsborough County Wastewater Treatment Plant~ The industrial
nature of the site area is expected to be maintained in the
foreseeable future. .
The close.~ residential area to the site consists of
single-family houses and mobile homes and is located.
approximately 0.3 miles east of the site across Faulkenburg Road.
Other residential areas include. single-family homes,
approximately 0.75 miles north of the site across SR 574 on
Martin Luther King Avenue; single-family homes in an area -
approximately 1.2 miles west of the.site near the intersection of
u.S. Highway 301 arid SR 574; and single-family homes and mobile
homes in an area approximately 1.8 miles northeast of the site.
1
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STUDY AREA
VICINITY MAP
NOT TO SCALE
REFERENCES,; *
- USGS 75 MIN SOaCS. BRANDON
QUADRANGLE. FLONDA-HILS8OROUGM CO..
1956. PMOTOREVISCO 1987.
2.0OO
2.000 FEET
tO-J-M
S-U-92
SSUGO TO CM
rssueo ro« MXMCT
ran «vcw
SfTE LOCATION PLAN
BAY DRUMS, PEAK OIL. AND REEVES
SUPERFUND SITES
TAMPA. FLORIDA
PREPARED FOR
POTENTIALLY
RESPONSIBLE PARTIES
CanonteEnvironrrientai-
No.
DATE
ISSUE / REVISION
MM. n are
DATE: 5-11-92
SCALE: AS SHOWN
DRAWING NUMBER
87-538-A98
Figure 1 Site Location Plan
Source: Canonie Environmental, Area-Wide FS
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STUDY AREA PlNt .
BAY DRUMS, P£N< OIL. AND REMS
SUPERfUND SITES
TAMPA, flORIOA
Pll(l'NI(D rOIl
POTENTIAlLY
RESPONSIBLE PARTIES
CanonleEnvircrnnental
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'The Central wetland is approximately 6.25 acres in size ~nd has'
no defined surface water inlet or outlet. A 2 to 3 foot ridge
forms a distinct boundary along the southern edge of the wetland.
A maintained pasture area and a power line right-of.way boarder
the Central W~~~~nd to the west and south and a Seaboard Coast'
Railroad line spur borders the wetland to the east.,
The'South Wetland measures about 9.7 acres. Similar to the
, .
Central Wetland,' the South Wetland has no defined surface water
inlet or outlet.
As shown on Figure 1.2, the Peak Oil site is approximately four
acres in area. The Peak Oil site currently contains two '
warehouse-type buildings, a concrete block office building, a
small storage shed, a small lagoon from which waste oil sludges
were excavated during a. previous' EPA rempval' accion, a 6,000 '
cubic-yard ash pile lined and covered with plastic liners (~lso'
from the previous EPA removal action), and a 400 cubic-yard soil
pile. A concrete pad, 90 feet by 110 feet, is also located in
the southeast corner of the site.
The Bay Drums facility is approximately 14.8 acres in area,. The
facility ,currently contains three small ponds. Two site'
buildings were destroyed in early 1994 and the foundations remain
on-site.
2.0 Site History and Enforcement Activities
2.1 Site Wetlands
The Central and South wetlands were evaluated in two separate
studies, one conducted by the Potentially Responsible Parties
(PRPs), and one conducted by EPA. The Peak Oil PRPs, entered into
'an Administrative Order on Consent wich EPA in 1989 to conduct an
Area-wide Hydrologic Remedial Investigation/Peasibility Study
("Area-Wide RI/PSW). The study focusea on groundwater,
contamination,. but, included an evaluation of area wetlands,
including the'Central and South ,wetlands. BPA conducted the
Area.Wide Wetlands Impact Study concurrently with the Area.Wide
RI/FS to evaluate 'the ecologic status of the wetlands. Pield
work for the studies 'was performed in 1989 and 1990. BPA .
conducted a feasibility'study for the Central and South wetlands
in 1993 aDd 199~. '
Central WKlancS
The Central Wetland appears to have been relatively undisturbed
until 1965. Since taat time, this system has been impacted by
surrounding land uses' and direct alterations of wetland
hydrology. Activities which appear to have altered this system
include scraping and possible installation of a perimeter ditch,
construction of a ditch to the northeast, powerline maintenance
4 '
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on the west side of the system, and agricultural activities to
the south. Water levels and thus the lateral extent of the
Central wetland have been affected through the years by a
county~owned spray field for treated waste water. Use of the
pasture area immediately to the south for spraying of treated
effluent has likely contributed to a current state characterized
. by dense vegetation by species adapted to high nutrient'
conditions. .'
South Wetland
The South Wetland has changed significantly over. the past several
decades. In an areal photograph from 1948 it appears that the
. South Wetland is being drained by a system of ditches. . In the
photo, less than ten percent. of the current system had a wetland
sign~ture. It is unclear what the South Wetland looked like
before the ditches were. installed. Activities which have
influenced the current state 'of this system include Drainage
changes, construction of a road to the south, agricultural'
activities, construction of a railroad spur to the northwest,
construction of a fill area on the west side, industrial storage
in the f{ll a~ea, and construction of a ditch draining the access'
road along' the Reeves S~E. Wire facility. .
2.2
Peak Oil Site
The Peak Oil Facility began operation as a waste oil re-refinery
'in approximately August, 1954, under the ownership of Mr. John
Schroter. Ownership of the company was transferred in 1974 to'
Mr. Robert Morris. Mr. Morris and his sons continued the
operation of the business as a waste oil re-refinery.
Facility operations involved a re-refiningprocess to purify
waste oils and lubrication fluids. The compounds accepted
throughout facility operations' were primarily used auto and truck
crankcase oil, hydraulic oil, transformer fl~id, and other waste
oils. An acid/clay purification and filtrat.ion process was used
to re-refine the oil. This process generated a low-pH sludge and
. oil- saturated clay, which were stored over the life of the' .' .
facility in thre~ separate impoundment areas (Lagoons No. ~, No.
2, and No.3) in the southern portion of the ~ite. Sludge
storage Lagoon No.1 was in use until sometime after 1960.
Another sludge storage lagoon area was constructed further south
of 'Lagoon ~. 1. This area consisted of two large, unlined
impoundments measuring approximately 90 feet by 100 feet each
(Lagoon No.2 and Lagoon No.3). The two 'impoundments were
connected by an oil/water separator.
Lagoon No.1 and Lagoon No.3 were backfilled~ However, the
exact. dates of backfilling are unknown. Lagoon No.2 is the only
impoundment on the site that was not backfilled. This lagoon
originally contained up to approximately 12 feet of sludge.
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Overflow from Lagoon ~o. 2 was apparently directed to the .
oil/water separator to remove free oil, and the aqueous phase was
discharged into Lagoon NO.3, to the east. In 1983, the U.S.
Environmental Protection Agency (EPA) and the Florida Department
of Environmental Protection .(FDEP) conducted inspections at the
Peak Oil and Bay Drums sites and reported that various chemical
constituents were present in. site soils, including heavy metals, .
petroleum hydrocarbons, trace concentrations of. polychlorinated .
biphenyls (PCBs), and sOlvent-type chemical compounds. In 1986,
EPA initiated a removal action at the Peak Oil site to incinerate
the sludges found in Lagoon No.2. Ash generated during the
incineration process (appro~imately 6,000 cubic yards) is
presently being stored at the site on a liner. The ash.pile is
. alSo covered with a liner. In 1989, approximately 120 Peak Oil
potentially responsible. parties (PRPs) entered into two separate
Administrative Orders on Consent (AOCs) with the EPA. One AOC .
was to conduct a remedial inve$tigation/feas.ibility study. (RI/FS) .
for the soils, sediment, .and surface water at the Peak Oil s~te, .
and the other AOC was to conduct an RI/FS for area groundwater
contam;i.nation~
2.3
Bay Drums Site
The Bay Drums site is a former'drum reconditioning facility.
When the Bay Drums site was active, drums from many sources were
transported to the site for reconditioning. Nearly.all of the.
site property was used for drum storage, although the active drum
reclaiming area only covered approximately 2 acres of the site.
Drum reconditioning activities ceased sometime in ~984.
Beginning in .1984, and continuing for approximately two and.
one-half years, the Bay Drums site was operated as Resource
Recovery Associates, Inc. During that time, waste roofing
shingles were deposited on most of the site at heights ranging
from three to nineteen feet. The stated intent of the company
was to recycle the shingles for asphalt, but no significant
recycling ever occurred, and the site essentially operated. as an
unp~rmitted dump. On November 12,. 1986, the U.S.. Environmental
Protection Agency (BPA) issued a Unilateral Administrative Order
to the site operator to cease bringing materials on~siteand to
remove materials already located on the site. As a result of the
property oWD~r's failure to comply with the order and remove the.
shingles tram the property, EPA's Emergency Response and Control
Section (BRCS) commenced a removal action in March, 1989 to
. remove the roofing shingles .and debris from the surface of the
. $ite. EPA removed approximately 70,000 cubic yards of shingles
from the site prior to beginning field activities. This removal
was .necessary in order to evaluate the extent of soil
contamination.
Initial sampling and trenching operations conducted at the site
in March, 1989 revealed buried drums, sludges and other materials
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throughout the entire northeast corner of the site. Further.
examination of the site revealed three additional drum burial
areas south of the site buildings on Hillsborough County
property. An BPA.removal action was initiated in June 1989, to
address the areas containing buried drums and high levels of
contamination. The removal 'action consisted of the removal of
drums, contaminated soils, sludges and pesticides from the site.
The drums were decontaminated and disposed of off-si~e while,
approximately 4,000 cubic yards of soils and other materials were
placed into a lined and covered cell which had been constructed
on-site by BPA. In early 1990, this 4,000 cubic yards of
contaminated materials were taken to a permitted hazardous waste
facility in Utah ~ia railcar. . .
. .
Subsequent to the BPA removal action, EPA conducted a source
control Remedial Investigation/Feasibility Study (RI/FS) to.
determine the nature and .extent of contaminatipn in the. soils,
sediments, and surface wat.er. The 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 Peak Oil and Bay
Drums-source control .cleanup plan was presented. The preferred
alternative for the Reeves site was also presented at this
meeting. In 1993, a group of Bay Drums PRPs signed the Area-Wide
Ground Water RI/FS Consent Order. The RI/FS for the area-wide
groundwater had been conducted and funded jointly by a group of
Peak O~l PRPs and by Reeves Southeastern Corporation. The Bay
Drums PRPs then contributed their share of the funding after
signing the Consent Order.
3.0 Hiahliahts of Communi tv particioation
In accordance with Sections 113 and 1.17 of CERCLA, ~PA has
conducted community relations activities ~t.the site to ensure
that the public remains. informed concerning a~tivities at the
site., EPAissued press releases to keep the public informed.
There was some local press coverage at BPA's.activities, and EPA
held meetings with local (county) and state officials to advise
them of the progress at the site. .
A community relations plan (CR~) ,was developed in 1988 and
revised in 1989 to establish EPA's plan for community
participatlaa during remedial activities. Following completion
of the FS, . Proposed Plan fact. sheet was mailed to local. .
r'esidents and public officials on April 29, 1994. The fact sheet
detailed BPA's preferred alternative for addressing ,the wetlands
contamination (Operable Unit' Four) at the Peak Oil/Bay Drums
site. .Additionally, .the Administrative Record for the site,
which cont~inssite related documents including the Area-Wide
Wetlands Impact Study, FS reports and the Proposed Plan, was made
.available for public review at the information repository in the
Brandon Public Library. A notice of the availability of the
7
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Administrative Record for the Peak Oil/Bay Drums site was
. publisned in the T~a Tribune on'May 3, 1994.
A 30-day'public comment period was held from May 2, 1994 to
'May 31,. 1994 to sOlicit public input on EPA's preferred
alternative. fo~ Operable Unit Two. EPA held a public meeting on
May ~1, 1994 at the Hillsborough Community College in Brando~
Florida, to discuss the remedial alternat'i ves under considerat'ion
and to ~nswer any questions concerning the proposed plan for the
site. EPA's response to each of the comments received at. the
public meeting or during the public comment period is presented
in the Responsiveness Summary which is provided as Appendix A of
this ROD. .
.This decision document presents. the selected remedial action for
'Operable Unit Four of the. Peak Oil/Bay Drums site in Brandon,
Florida, chosen in accordance with CERCLA, as'amended.by SARA,
and to the extend practicable, the NCP.This decision is based
on the Administrative Record for the site. .
4 . 0 BeODe and R.ole of ODerable Un! t
. As with many Superfund sites, the problems at the Peak Oil/Bay'
Drums site. are complex. As a ;oesult,EPA has divided the remedy'
for the site into four operable units (OUs). These are:
o au One:
o au. Two:
o au Three:
o au Four:
Contamination in the soils and sediments at
~he Peak Oil site;
Contamination in the groundwater and surface
water at the Peak Oil and Bay Drums sites;
Contamination in the soils and sediments at
the Bay Drums site;
. qontamination in the Central and South
wetlands at the Peak Oil and Bay Drums site.
The remedial actions for OUs One, Two,' and Three. are have been'
selected in separate RODs.
au Four, the subject of this ROD, addresses the contaminated
water and .ediment of the Central and South wetlands. The
principal.ri8k from this contamination is to. the ecology. of the.
'wetlands. The Baseline Risk Assessment conducted as part of OU
Two "indicates that the contaminants found in the Centr~l and.
South Wetland' pose no unacceptable risk to h~ health. The
purpose of the selected remedy is to prevent excessive ecological
impact from contaminated surface water and sediment in the
Central and South wetlands. This fourth operable unit will be
. the final response action for this site. .
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5.0 Sn--rv of Site Characteristics
5.1 Climate
The climate in the Tampa a~ea is characterized by mild winters
and relatively long, humid, and warm summers. Spring and fall
tend to be dry, with the majority of the rainfall occurring in
the summer. '
5.2 Site Topography and drainage
Relief throughout'the site and surrounding areas is flat with
some localized depressions around wetlands, and streams. Surface
run-off water either collects in localized depressions and
'wetlands, or drains into ditches 'or streams.' Due to the study
area's elevation above MSL, tidal surges will not impact the,
area.' The area south of SR 574 demonstrates only minor changes
in'elevation (from about 39 to 42 feet above MSL) with the land
sloping gradua~ly toward small wetland areas. Surface water
run-off is expected during prolonged or heavy precipitation
5.3 Reqional Geology
The geology of the Tampa area consists of a series of sedimentary
sequences of rock and unconsolidated sediments overlying a,
basement of crystalline igneous or metamorphic rock. The
basement rock is of Paleozoic age, and the sedimentary rocks
,range in age from the Mesozoic era through the Pleistocene epoch
of the Cenozoic era (Figure 3).
The upper rock and sediment sequences include the Tampa limestone
member of the Hawthorn Group (referred to as the Upper Floridan,
, Aquifer), the Arcadia formation and Peace River formation of the
Hawthorn Group (referred to as the ,low-permeability unit or low-
permeability layer) and undifferentiated Pliocene, Pleistocene
and, Holocene deposits (referred to as the surficial aquifer).' '
The limestone layer is approximately 80 feet to 400 feet thick,
varying throughout the area, the Hawthorn clay layer is 15 feet
to 40 feet, and finally 'the surficial sand ranges from 9 feet up
to 37 feet in some areas.
Sedimentary rocks and unconsolidated deposits in the Tampa area
consist of limestones, sand, clay and' silt. The variability of
rock and sediment types suggests e~vironments of deposition
ranging from open ocean to shoreline to lagoons and tidal
marshes. 'The rock sequence consists of sand, fine-grained
carbonate rocks and fine-grained clay or shale.
, ,
Rocks of the Miocene age underlie most of the Tampa area, and
these strata are mostly clastic, with the' exception of (1) sandy
limestone that comprises the Tampa member and its equivalents and
9'
-------
(2) dolomite beds that commonly make up the lower part of the
Arcadia formation.
The Suwannee Limestone formation and the overlying Tampa
Limestone member comprise the upper portion of the Upper Floridan
Aquifer. The Suwannee Limestone formation consists of white,
yellow and light-brown, soft to hard, dense, tine-grained
. limestone with chert lenses to 25 feet thick.
The Hawthorn Group consists of highly variable sequences, mostly
of clay, silt and sand beds, all of which contain scarce to.
abundant phosphate. The clays are characterized by swelling when
hydrated and have the ability to absorb and retain certain ions'
in an exchangeable state. .
The Hawthorn generally consists af a basal calcareous unit. and a
middle clastic "unit knoWn as the Arcadia formation, .and an upper
unit that is a highly variable mixture of clastic and carbonate
rocks, known as the Peace River Formation. The middle and upper
parts. of the Hawthorn everywhere contain more phosphate than the
lower calcareous unit. Because of its heterogeneity and the' .
predominantly fine-textured nature of both the clastic and the
carbonate beds within the Hawthorn, the entire group constitutes
a low-permeability rock unit except for the Tampa limestone
member. .' "
5.4 Reqional Hydrogeoloqy
The groundwater system beneath the study area consists of two
major water-bearing units: a class II surficial aquifer (the
term surficial aquifer refers to permeable material that is
exposed"at land surface and that. contains water under unconfined
conditions) and the class I Floridan Aquifer system. A low- '
permeability unit comprised of a low-permeability sequence of
rocks separates ~he Floridan from the upper surficial aquifer.
. . . .
The Floridan Aquifer system consists of a th1c~ sequence of
carbonate rocks of the Ter~iary age. The ~nit is comprised. of
white to light-gray, sandy, hard to soft, locally clayey, .'.'
fossiliferous (pelecypod and gastropod casts. and molds) limestone
that contains phosphate and chert in places. "
The phosphate content of the Tampa limestone is relatively low in
comparison with that of the overlying Arcadia and Peace River
Formation. Much of the Tampa member contains soft lime muds and "
10
-------
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FORMATION,
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HAWTHORN
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, GENERAL LITHOLOGY
rRCOOMINANTl Y flN[ SANO,
INTEROEDDED CUIY. MARL.
SHELl. LIMESTONE. PltOSPIiORiT(
GR([N. BlUE. AND GRAY CUlyEY
SAND AND CLAY; lIMCSTONE .N[AR
BOTTOM or roRMA TION IS WHIT ( TO
GRAY. Sort, SANDY. AND POROUS,
rORMATION GENERALLY CONSISTS
or A BASAL CALCAREOUS UNIT,
A MIDDLE CUIS TIC UNIT. AND
AN UPPER UNIT Of CLASTIC
AND CARBONATE ROCK AND SOIL
'MIDDLE AND UPPER PARTS '
CONTAIN MORE PHOSPHATE
THAN LOWER CALCAREOUS UNIT,
(NOTE: UPPER PART Of TAMPA
rORMATION IS RELAllVEL Y HIGH'
IN CLAY CONlENT MAKING CONTACT
BETWEEN TAMPA AND HAWTHORN'
DlmCULT TO D[1(RMIN[.) ,
WHITE, CR[AM. AND GRAY. HARD
TO son, SANDY LIMESTONE; ,
SANOY, PHOSPHATIC. fOSSILIfEROUS
WITH CHERT LENSES: SAND AND
CLAY IN LOWER PART IN SOME
SECTIONS; MANY UOLDS Of
PELECYPODS AND GASTROPODS
WHITE. YELLOW AND LIGHT BROWN.
son TO HARD D(NSE. fINE-
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TYPICAL GEOLOGIC PROFILE
BAY DRUMS, PEAK OIL, AND REEVES
SUPERFUNf) SITES ;,.
TAMPA, FLORIDA
PREPAR(D fOR
POrENTIALL Y
RESPONSIBLE PARTIES
CanonleEnvironmental
DATE 5-1I-
-------
solution cavities.. Therefore, the Tampa limestone is highly
porous in~some zones, and its porous nature permits large volumes
of water to flow through it. The upper part of the Tampa'
limestone is relatively high in clay. content, making the contact
between it an~ ~~e clayey Arcadia formation difficult to
determine. .
Rainfall infiltrates the permeable surficial materials and, . after
percolating downward to the water table, moves laterally to
points where it is discharged into surface streams and wetlands.
Water levels within the surficial aquifer fluctuate seasonally.
. and change .rapidly in response to rainfall and other natural
stress'es . such as 'evapotranspiration or the s.tages of streams. .
The. groun~water flow patterns also change due to the in~reased
rainfall during the summer months which raises the surface water
elevation in the wetlands and lagoons, changing them into.
. recharge basins for the surficial aquifer. .
The thickness and lithologi.c character of the low-permeabiiity
layer that separates the surficial aquifer from. the Upper'
Floridan Aquifer system determine the degree of hydraulic
interconnection between the two. Where the low-permeability unit
is thick or where it contains a high concentration of clay, there
is essentially no interconnection between the surficial and
Floridan.aquifers. In these thick or clay-rich areas, ~ater in
the surficial aquifer moves laterally as opposed to vertically
and does 'not breach the low-permeability unit. Breaches'in the
low-permeability unit in some locations, such asuncased
boreholes, reduce hydrologic separation between the aquifers.'
The regional groundwater flow pattern within the Upper Floridan
Aquifer is based upon the USGS potentiometric surface map. The.
contour map and review.of the.water level plots' indicate the
regional groundwater flow is in a southwe~terly direction in this
area. The Tampa Bypass. Canal divides the regions and. forces the
flow .direction to shift northwes.terly' near the .site. . Reportedly ,
the canal excavation cut into the low-permeability layer and
breached the Upper Floridan Aquifer in several places. In the
vicinity' of the site, the general groundwater flow direction is
northwesterly. .
Approximately 70 percent 'of the .annual precipitation in the Tampa
area is 108t through evapotranspiration and about nine inches of
the 47 inche8 of. annual precipitation is available for
groundwater recharge. .
Th~ 'surficial aquifer. is composed of undifferentiated Pliocene
and Pleistocene age deposits. The groundwater is suitable for
domestic a~d small-quantity municipal supplies, although in some
areas there is a high iron content. The surficial aquifer
. underlies the Peak Oil/Bay Drums site and is' hydrologically
connected to the Central and South wetlands. .
12
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5.5 potential Contaminant Sources and Chemical Trans~ort
Mechanisms .
Central and South wetland water and sediment quality is
pot2ntially influenced by a variety of area sourc~s through
several mechanisms of chemical transport. These mechanisms
i~clude stormwater run-off, discharge from the surficial aquifer
and areal. drift. Because the Bay Drums and Peak Oil superfund
sites are located adjacent to and within the drainage basin of
the Central Wetland, the sites are considered to be the principle
sources of contaminants found in the Central Wetland. The
northern pa+t of the Central Wetland has been connected
.hydrologically above ground to an excavated pond on the Bay site
. during pe~iods qf increased rainfall. In general, the Central
Wetland sampling stations located.closer to t.he Bay Drums and. .
Peak Oil sites showed higher contaminant concdntrations than the
. stations located f.urther. from the sites. .
The South Wetland is potentially affected by a variety of area
sources, including the southern portion of the Peak Oil site. .
. One likely source for elevated lead, zinc and aluminum found in.
the north~rn part of the South Wetland is the former Sunshine
Skyway Bridge painting area, located adjacent to the South
Wetland. Several additional ind~strial facilities are with the
South Wetland drainage area, including the Consolidated Bag
.Company, the Reeves Southeastern Wire facility, and the
Cast-Metals Corporation. .
Lateral migration of impacted ground water has generally not
resulted in widespread transport of chemical constituents found
at the Bay Drums and Peak Oil sites. Because of the Central
Wetland's proximity to the sites it is possible that contaminated
surficial aquifer water is discharging to the wetland. Any
groundwater discharging to. the wetlands would have to meet
.Fl.orida Surface Water 7 Standards at the point of discharge.
All area wetlands are under the influence of areal drift from
nearby industries, including a municipal incinerator and a
Hillsborough County wastewater treatme~t plant sprayfield .
(currently not operating). .
5.6 Samplina Results
. . .
Wetland surface water and sediment sampling results for the
Central and South wetlands and two comparison wetlands. (the.
Cypress Pond and Sprayfield Wetlaqds) were included .in the
Area-Wide Wetlands Impact Study and further evaluated in the
Central and South Wetland Feasibility Study. The Samples were
analyzed for Volatile Organic Compounds (VOCs), Semi-Volatile
. Organic Compounds (SVOCs), pesticides, and various inorganic
. parameters. Sampling results were evaluated f~om 4 locations in
13
-------
. -_._p .. h---
. the Central Wetland, 4 locations in the South Wetland, and 1
location !n each of the comparison wetlands (~igure 4). Surface
wat~r was evaluated against Florida Surface Water Standards,
which are based on Federal Ambient Water Quality Criteria. Since
there are no Federal or State ARARS for sediment, the sediment
.contaminant levels are evaluated against NOAA screening criteria.
5 . 6 . 1 Sediment.
There are no federal or state ARARs for sediment. However, NOAA
Effects Range-Low (ER-L), and Effects Range-Medium (ER-M)
screening criteria for sediment are currently being use~ by EPA
at Superfund sites (Table 1). NOAA developed the screening
method through evaluation of biological effects data on aquatic
(marine and freshwater) organisms. If sediment contaminant"
. concentrations are below the ER-.L, adverse effects are considered
unli.kely. If concentrations are above the ER-M, adverse ef.fects
on. the biota are consid~red probable. Ifcontaminant ... .
concentrations are between the ER-L and the ER-M, adverse effects
are considered.possible, and EPA recommends conducting toxicity
tests as .a follow~up. Such sediment and surface water toxicity
tests were conducted as a part of the Area-Wide. Wetlands Impact
Study and are described in section 6.2 of this ROD. ..
Although the screening criteria are not ARARs, they are useful as
a tool to help determine if. there is a" significant problem. A
combination of screening criteria and the observed effects of the
contaminants. on the ecology is used in determining whether or not
.the wetlands should be remediated. A comparison of ER-Ls and the
sediment results is presented in table 2. The table. lists only
those analytes. which showed ER-L exceedances at at least one
sampling station.
. Central Wetland
. .
As shown in table 2, station 02-CLW showed the greatest number of
ER-L exceedances in the Central Wetland. ER-L values were
. exceeded at this station for lead, . mercury and zinc and ER-M
values were exceeded for PCB-1260 and DDE. .Station Ol-CLW
exceeded the ER-M. for PCB-1260. It should be noted that station
02-CLW.and station Ol-CLW are located on the Bay site in an .
excavated area .that will be dredged and filled as a part of the
Bay source remediation. Of the sampling stations located in the
main (sout~rD) part of the Central Wetland, station 03-CLW
showed exceedances of the ER-L.fo~ antimony; benzo(a)anthracene,
and dlbenzo(a,h)anthracene. No.exceedances were registered at
station 04-CLW~ .No ER-M values were exceeded in the main
(southern) part of the Central Wetland. .
South Wetland
The ER-L value for zinc was exceeded in two of the four South
14.
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Wetland stations. PCB-1260, detected at station 02-S0W, exceeded
both ER-L and ER-M values. No other exceedances were reported in
the South -Wetland. -
Comparison Wetlands -
No ER-L values were exceeded in the Cypress Pond Wetland or the
Sprayfield Wetland.
5.6.2
Surface Water
A comparison of surface water sampling results of the Central and
South wetlands to Florida Surface Water Quality Standards reveals
that exceedances of the standards were limited in terms of the
number of analytes detected above- the standard and the number of
sampling stations where -the ana,lytes were found above the --
standard. Table 3 outlines the exceedances of standards at the
individual sampling stations. Surface water standards are
applicable to groundwater at the point of discharge into the
wetlands.
Central Wetland
Lead is the only analyte which exceeded the surface water
standard at more than one Central Wetland sampling station.
Although all of the samples exceeded the -lead standard, only
station Ol-CLW, at 165 ppb, showed _lead levels significantly
above the standard. As indicated previously, stations Ol-CLW and
02-CLW are located in areas to be remediated under the Bay Drums
source control remedy (OU3). Additional surface water standard
exceedances include zinc at station Ol-CLW (410 ppb) , and PCB--
1260 at station 04-~LW (1 ppb). - -
South Wetland
Detected concentrations for zinc and lead at-station 01-S0W
significantly exceeded Florida Surface Water Quality Standards.
-Zinc and lead concentrations were detected at 3980 ppb and 248 -
ppb respectively at this station. In addition, the standard-for
metals was exceeded to a lesser extent for lead at stations
02~SOW (4.9 ppb) and 04-S0W (3.4 ppb), and for zinc at station
02-S0W (63.2 ppb) and 03-S0W (67.7 ppb). Estimated levels of
Phthalate "ters (9 ppb) exceeded the Florida standard at station
01-S0W.
COmparison Wetland8
No ~lorida Surface Water Quality Standards were exceeded at any
surface water sampling station in the-Spray-Field and Cypress
Pond wetlands. -
15
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RAILftOAO
f£ ,ct
UNIMPROVED ROAOWAt
DRAINAGE DITCH
DIRECTION OF SURFAQC WATER FLOW
STAN01NC VKATER
SURFACE WATER/SCOlMENT SAMPLE
SURFACE WATER/SEDIMENT AND WETLAND
IMPACT STUDY SAMPLE
1 COORDINATE GRID IS REFERENCED TO THE FLORIDA
STATE PLANE COORDINATE SYSTEM
scut
too
800 rcn
SURFACE WATER AND SEDIMENT
SAMPLING LOCATION PLAN
BAY DRUMS, PEAK OIL. AND REEVES
SUPCRFUND SITES
TAMPA. FLORIDA
rax
POTENTIALLY
RESPONSIU.L; PARTIES
CanonloErnironmoiial
'•II'.
**-»n
i-ri-il
?"«• ' [0*1 4-M-M I
r*V i hem AS SHOOK |
4UWNO NUUM*
-------
~ TABLE 1
SEDIMENT SCREENING VALUES
Chemical Analyte. NOAA ER-L NOAA ER-M
Concentration Concentration
Inorganics(ppm)
Antimony 2 25
Arsenic 8.2 70 ..
Cadmium 1.2 9.6
Chromium. 81 370
Copper 34 270
Lead 46.7 218
Mercury 0..15 .71
Nickel 20.9 51.6
Zinc 150 410
Polychlorinated Biphenyls (ppb)
Total PCBs 22.7 46.9
Pesticides (ppb)
DDE 2 15
Chlordane 0.5 6
PolYnuclear Aromatic Hyd.rocarbons (ppb)
Bepz(a)anthracene .261 1600.
Benzo(a)pyrene 430 1600
Chrysene 384 2800
Dibenz(a!h)anthra- 63.4 260
cene
Fluoranthel1e 600 5100
Pyrene 665 2600
Total PAHs 4022 44792
17
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I
I '
TABLE 2
RATIO OF ANALYTE CONCENTRATIONS IN WETLAND SEDIMENTS'TO
. NOAA ER-L VALUES..
I
C81'RAL h"ETLAND STATIONS SOUTH WETLAND STATIONS COMPARISON
WETLAND
STATIONS
station ID Ol-CLW 02-CLW 03-CLW 04-CLW 01-S0W 02-S0W 03 -'SOW 04-S0W Ol-CPW 01-8PW
(No.5) (No:6) (No.7) (No.8) (D) (8) fP) (G)
Inorganic ~lements
Antimony - - - - 1.85 - - - - - - - - - - - - - -
Lead - - 1.42 - - - - - - - - - - - - - - - -
Mercurv - - 1.60 - - - - - - - - - - - - - - - -
.
Zinc - - 2.68 - - - - - - 1.37 1.56 " - - - - - -
Organochlorine Pesticides Analysis
PCB-1260 11.45 21.14 - - - - - - 9.8 - - - - - - - -
DDS - - 60.0 - - - - -'- - - - - - - - - - -
Polynuclear Aromatic Hydrocarbons
Benzo(a) an- - - . - - 1.37 - - - - - - - - - - - - - -
thracene
Dibenz(a,h)an - - - - 3.15 - - - - - - - - - - - - - -
thra-cene
Figures are giveI:1 for only for sample concentrations that exceeded NOAA ER-L values.
18
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Table. 3
Concentration of Analytes Exceeding Florida Surface Water Quality Standards I
in the Central and South Wetlands
CBNTRAL WETLAND STATIONS SOUTH WETLAND STATIONS Florida Surface
(CLW) (SOW) Water Quality
Standard, Class III
01 02 03 04 01 02 03 04
Analyte C~ncentrations(ppb)
Lead (ppb) / 165/ 4.6/ 2.5/ 4.6/ 248/ 4.9/ 7.....9../ 3.4/ Water Hardness
Hardness- 6.82 1.12 1.12 1.12 1.32 0.09 4.97 3.18 Dependent"
Specific
Standard
.Zinc (ppb) / 410/ i2.J.! ~/ JL.2/ 3980 63.2 67.7 ~/ Water Hardness
Hardness- 176 52.9 52.9. 52.9 / /9.8 / 106 Dependent"
Specific 58.9 142
Standard
Total ND ND ~ ND 9.0. J.....Q ND ND 3.0 ppb
Phthalate
Bsters
(ppb)
PCB 1260 ND ND ND 1.0 ND ND ND ND .000045 ppb annual
(ppb) avg .; .03 ppb max
. Underlined readings did not exceed the Florida standard but were included for
comparison. ... .
.. Hardness readings were taken. at each sampling station to generate a hardness-specific
standard for each sampling station..
19
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6.0 Baseline Risk Assessment SUJIIDIArv
6.1
Human Health Risk Assessment
Risk to human ~:~lth from wetland contaminants was evaluated as a
part of Operable Unit Two. in the Area-Wide Hydrologic Baseline
Risk Assessment. This evaluation addressed exposur~ scenarios
invQlving on-site trespassers and future on-site residents.
Human health risks levels were found to be well below levels
which EPA considers unacceptable. A summary of the human health
risks assessment process and results is included in the Central
and South Wetland Feasibility Study.
6.2
Environmental Risk
Environmental Risks for.the wetlands in the study area are
addressed. in the Area-Wide Wetlands Impact Study through.
bioaccumulation studies and environmental toxici.ty assessments.
Study objectives were to evaluate the ecological status of the
wetlands, and to extend the toxicity testing to include possible
source materials, soil, surface water, and s~diments from several
study area In4ustrial sites. Because the source contaminati.ori
. for the Bay Drums and Peak Oil sites are addressed as separate
operable units, only wetland study results are further discussed
here. An assessment of endangered. species in the area of the
wetlands is included in this section. .
6.2.1
Wetland Characterization and functional assessment
The Central and South Wetlands as well as the two comparison
wetlands are classified in the Wetlands Impact Study as
palustrine, emergent systems. 'Even though the wetl~nds are.
relatively small, they are highly functional ecosystems providing
surface and ground water quality benefits .and protection plus
fish and wildlife habitat. The study wetlands are colonized with
at least 4 kindc of fisn and 53 kinds of macroinvertebrates. .
The.se animals are .coImlonly associated with Florida freshwater
wetlands and can tolerate low dissolved oxygen concentrations,
.marked temperature changes and seasonal surface water. level .
fluctuations characteristic .of isolated wetlands. Because of the
seasonal water level changes in the wet and dry periods of the
year, a hydrologic mechanism is established in which food
organisms 8Uch as small fish and invertebrates are concentrated
for harvesting by wading birds and other predators. Overall, the
study wetlands, including the comparison ~etlands, were rated as.
moderate to high in their. ecological functions and values. .
6.2.2
Bioaccumulation
There.are three primary objectives for determining chemical
levels in aquatic organisms living near the Peak Oil/Bay DrUms
site. The first is to evaluate the potential for chemicals to
20
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. travel up the food ch~in, and thus, to migrate. from the'study
area with the organisms or predators that ~ngest the aquatic
organisms: The second is to reveal bioaccumulative chemicals of
concern in surface water in the study area t~at may be present in
concentrations too low to measure .in the water directly, but can.
be detected in the organisms. Finally, chemicals found in biota
at elevated concentrations can be tracked during and following
the source remedial actions to help assess the effectiveness of
the actions. . .
.The Wetlands Impact Study concluded the following concerning
bioaccumulation studies in the Central and South wetlands and. the
comparison wetlands: . .
Overall, fish and crayfish sampled from the various
wetland ar~as that comprise this study .were not
contaminated with a wide spectrum of contaminants at
concentrations significantly over background. .Several
inorganic analytes were widely'present over the area
sampled at concentrations moderately elevated over'
background. These include aluminum, barium, copper,
. iron, manganese, titanium and zinc..
6.2.3
. Mercury concentrations in tissues analyzed were'
typically lower than national mean values. However"
three of four samples of fish and crayfish taken from
the comparison wetlands exceeded criteria proposed for
the protection of birds that may prey upon them. The
comparison wetlands are considered not to be impacted
by the Bay and Peak NPL sites.
BDviroDmeDtal Toxicity As...8m8Dt
Samples from the Central and South wetlands as well as the two
comparison wetlands were analyzed, .and subjected to to~icity
te~ts. -Data generated from analysis of surface water and. .
sediments indicated the following: .
In general, waters of the Central and South wetlands
showed little toxicity to the organisms tested.
The sediments of all wetland areas including the
comparison wetlands (Cypress Pond and Sprayfield)
toxic to daphnia in a chronic toxicity te~t.
The sediments of the .Cypress Pond (comparison wetland)
were toxic to fish, daphnids, algae, and bacteria.
were
21
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6.2.4
Endangered Species
Several s~ecies'of endangered plants and animals have a range
that includes Hillsborough County. It is highly possible that
th€ endangered wood stork (Federal Register 2/28/84) is utilizing
the study wetlands for feeding, especially during periods of
receding surface water levels when fish and macroinvertebrates
are concentrated in small isolated pools. ESD field personnel.
obs'erved in May 1989 one wood stork landing in the spray field
located south of Columbus Drive. Even though feeding habitat is
present at all the studY'wetlands, suitable nesting habitat is
not available in the study wetlands with the exception of the
, tree communities which fringe the South Wetland. However, no
sign of. past or present nesting sites have been observed in the'
Sou~h Wetland. .
Even though the range of the bald eagle, Florida scrub' jay,.
. eastern indigo snake and. Florida golden aster includes
Hillsborough County; adequate feeding, breeding and/or growth
requirements do not exist within the study wetlands and. their
adjacent ecotones.' .
7.0 Description of Remedial Alternatives
A feasib~lity study was conducted to develop and evaluate
remedial alternatives for contaminated wetlands at the site.
Preliminary remedial alternatives were initially evaluated for
effectiveness, imp 1 ementability, arid cost.. Based on this
evaluation, the following remedial alternatives were selected for
the site. .
7.1 Alternative 1 - No Action with Ecoloqical Monitoring
. .
In accordance with the requirements of s~part E of the NCP, "no
act.ion" is included for consideration as a paseline against which
othe~ remedial alternatives should be compared., The' "no action"
alternative may include monitoring to assure that conditions
remain the same, but cannot include any active cleanup measures
or institutional controls. .
This no actioa alternative co~sists of semi-annual ecological
assessment. of the wetlands for ~ period of at least (5) years
(at least 10 monitoring events in all) and the installation of
surficial aquifer monitor wells. The monitoring schedule would
be timed such that one or two assessments occur before work
begins on the Operable Units One, Two, and Three remedies., The
rema'ining assessments. would 'occur once the Operable Unit One,
Two, and Three remedies have,been implemented (i.e. when the
surface transpOrt pathway has been eliminated and when surficial
aquifer pumping begins). Each assessment includes the following:
22
-------
a. General vegetation surveys to assess the composition and
health of the plant communities and collection of samples to
asse~s relative abundance and diversity of aquatic
vertebrates and invertebrates.
b. Sampling and analysis of wetland surface. water,
,sediment, and biota. ' Assays will be conducted forpurgeable
halocarbons and aromatics, phthalate esters, phenolic'
compounds, organochlorine pesticides and PCBs, extractable
organics and Priority Pollutant Metals. Toxicity and
bioaccurnulation analysis will be conducted at least once
each year of sampling (5 rounds in all) .
c. Field measurement of hardness, pH, temperature,
dissolved oxygen and conductivity at each sampling station.
d. Monitoring surficial aCNifer wells for the same
parameters indicated in part band cof this alternative.
The purpose of the well monitoring is to assess potential
surficial aquifer contamination close to the point of
discharge into the wetlands. Florida surface water
standards are applicable at the point of discharge. The
wells shall be placed so they would intercept surficial
aquifer flow from the direction of the Bay Drums and Peak
Oil sites.
This alternative would provide a means of determining the, current
ecological status of the wetlands, for observing changes in
ecological status through time, and for confirming whether or ,not
hazardous substances are entering the wetlands from the adjacent
sites. The estimate present worth cost of this alternative is
$278,000. .'
7.,2 Alternative 2 - Filling of the Wetlands
This alternative requires filling of the South 'and Central
, wetlands to preclude their use by wetland wildlife species, and,
mitigation for the lost wetlands. Required actions for 'filling
the wetlands would include the following:
a.
Removal of woody vegetation. .
Pilling of depressions with downed vegetatiori and clean
,80il to at least a level grade. '
b.
c
Prevention of erosion by revegetating filled ,areas, with
species similar to that of ,the surrounding, land.
Mitigation'of'LoSS:
, ,
, There are several possibilities for mitigating the loss of the
wetlands, and some combination of the following optiqns may be
23
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.acceptable to the responsible agencies:
b.
. c.
d.
a.
~reate wetlands in close proximity to the potentially
impacted wetlands (on-site mitigation). Although this
mitigation option is preferred from the viewpoint of.
the agencies, it may be limited by the.unavailability
of nearby land for wetland construction. .
Create wetlands off site. The Florida Department of
Environmental Protection and the Southwest Florida
Water Management District normally require that
mitigation for wetland impacts be conducted in the same
watershed where the impacts occur, and that created.
wetlands be of the same ecological type as the impacted
wetlands. . .
Restore or enhance existing wetlands. Thisoption
would be largely restricted to an off-site area. since.
there are no wetlands in the vicinity of the site which
appear to provide sufficient restoration/enhancement
. potential. Mitigation through restoration/enhancement
normally' requires a higher replacement. ratio tha~ .
wetlands creation. .
Secure through purchase or other agreement, and protect
in perpetuity, an area of. natural wetlands (and
possibly uplands as well). This option is occasionally
implemented when it is impossible to fulfill mitigation
requirements through other means. Typically, on-site
wetland creation is used to fulfill the "no net loss"
criterion and additional required mitigat~on may be
allowed to be fulfilled through purchase of land for
presezvation. . Mitigation of wetland impac~s through
land purchases is done at a.much higher replacement
ratio than wetland creation (e.g. 20:1). In a small
nUmber of cases, the Southwest Florida Water Management
D~strict has allowed wetland' impacts to be partially
mitigated through contributions to its Save OUr Rivers
program which purchases land for conservation.
. .
. ..'
If. a 2 :.1 mitigation ~atio is required for filling the Central and
South wetlands the estimated present-worth cost for filling and
mitigation (10 years of monitoring and maintenance) is projected
to be $1,478,000. .
7.3 Alternative 3 - Wetland Excavation and Restoration
This alternative involves the removal and appropriate disposal of
wetland vegetation and contaminated sediments. Clean wetland
muck would then be placed in the wetlands and desiraQle native'
herbaceous plants would be installed.' Monitoring would be
conducted as described in Alternative No.1, although the number
24.
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of ecological/chemical parameters to be monitored would be
reduced t_o several ".indicator" parameters since the contaminated
sediments would be removed. Vegetation maintenance would be
conducted to meet success criteria required by any applicable
permits. The estimated present-worth cost for this remedy is
. expected to be $1,465,000
8.'OComDarative Analvsis of Remedial Alternatives'
A detailed comparative analysis was performed on. the remedial
alternatives developed during the FS using the nine evaluation
criteria set forth. in the NCP. The advantages and disadvantages
of each alternative were compared to identify the alte~ative .
with the best balance among the nine criteria. A glossary of the
evaluation criteria is provided' in Table 8-1. According to the
NCP, the. first two criteria are labeled "Threshold Crit~ria",
relating to statutory requirements that each alternative. must
satisfy in order to be eligible for selection. . The next five
criteria are labeled "Primary Balancing Criteria", the technical
criteria upon which the detailed analysis is based. . The final
two criteria are known as "Modifying Criteria", assessing the'
public's and.State agency's acceptance of the alternative. . Based
on these final two 'criteria, EPA may modify aspects of the .
specific alternative. . .
A summary of the relative performance of each alternative with
respect to the nine evaluation criteria is provided in the
following sUbsections. A comparison is made between each of the
alternatives for achievement of a specific criterion.
8.1 Overall Protection of Human Health and the Environment
The first criterion against which each of the remedial .
alternatives is analyzed in detail is that of overall protection
of human heal th and the environment. CERCLA mandates that
remedial a~tions provide this protection. . Each remedial
alternative is analyzed to determine whether it will eliminate,
reduce, or control the risks identified in Area-Wide'Hydrologic
Baseline Risk Assessment an4 the Wetlands Impact Study. The' .'
remedial.alternatives are also evaluated to' determine. whether
unacceptable short-term or cross-media impacts will result from
implementation. Overall protection of human health and the
environment draws on the assessments of other evaluation
criteria, especially long-term effectiveness and permanence,
short-.term effectiveness, and compliance with ARARs.
All three alternatives are protective of human health and the
Environment.
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8.2 Compliance with Applicable'or Relevant and Apprcoriate
Re~irements (ARARs)
The second evaluation criterion in the detailed analysis of
alternatives is compliance ~~ith ARARs. Each remedial alternative
is assessed to determine whether it 'will meet the requirements
. that are applicable, or relevant and appropriate, under the
federal and state environmental laws. Unless a waiver is
justified, the remedial alternative must be in compliance with
all chemical-specific, location-specific, or action-specific
ARARs .
All three alternative c~n be des~gned to meet chemical-~pecific .
ARARs. Alternative 1 would initially allow contaminant
concentrations above ARARs to remain, but would monitor wetland
quality. . Contaminant' Levels would be expected to be re~uced
since the previous site' removals were conducted, and with. the'
implementation of the source and groundwater remedies for the
Peak Oil/Bay Drums site. Alternatives 2 and 3 may conflict 'with
the Executive Order on the Protection of Wetlands, 40' CFR part 6,
which requires federal agencies to avoid, when possible, the'
destruction or loss of wetlands. "
8.3 Long-Term Effectiveness and Permanence
The third evaluation criterion for the detailed analysis is the
long-term effectiveness and permanence of the remedial action.
The degree to which each remedial al.ternative provides a long-
term, effective, and permanent remedy is assessed, and the degree
of certainty that the alternative will be successful in achieving
. the response objectives is evaluated. This assessment includes
factors such as an evaluation of the magnitude of the risks'
remaining at the conclusion of remedial activities, the degree to
which treated residuals remain hazardous (considering volume,
toxicity, mobility, and propensity to bioaccumulate), the
adequacy and reliability of controls, and the potential exposure
pathways and risks posed should the remedial' action require .
" replacement. . "
The long-term eff~ctiveness of Alternative 1 depends on the
analytical data collected and if the expected. reduction in
contaminant concentrations is seen: Alternative 2 is considered
to be the most effective and permanent in the long term since
only minor maintenance would be needed. Improvement of the
wetlands as a result of alternative 3 may~not. be permanent since"
the industrial setting of' the area could result in degradation .of
the wetlands to pre-remedial conditions.
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Table 4
GLOSSARY OP EVALUATION CRITERIA
THRESHOLD CRITERIA:
Overall Protection of Hm".n Health and the
Addresses whether or not a remedy provides
and describes how risks posed through each
eliminated, reduced, or controlled through
. controls or institutional controls.
Environment -
adequate protection
pathway are
treatment, engineering
COmDliance with ARARs - addresses whether or not a r~medy will
meet all of the applicable or relevant and appropriate. .
requirements of other. "federal and state environmental statutes"
and/or provides "grounds for invoking a waiver.
PRDKARY BALANCING CRITERIA:
Lonq-Term Bffectiveness and Permanence - refers to the magnitude
of residual risk and the ability of a remedy to maintain reliable
protection of human health" and. the environment over time once
cleanup goals have been met. "
Reduction of Toxicity. Mobility. or Volume Throuqh Treatment -
addresses the anticipated performance of the treatment
. "technologies that may be employed in a remedy.
Short-Term Bffectiveness - refers to the speed with which the
remedy achieves protection, as well "as the remedy's potential to "
create adverse impacts on human health and the environment that
may result during the construction and "implementation period.
ImDlementability - the technical and administrative feasibility
of aremedYi including the availability of materials and services
needed to implement the chosen solution. .
~ - includes capital and operation and maintenance costs.
MODIFYING CJu:TBRIA:
State Acc~~ce - indicates whether the State concurs with,
opposes, or has no comment on the Proposed Plan.
Community AqceDtance - the Responsiveness Summary" in the appendix
of "the Record of Decision responds to public comments received
from the Proposed Plan public meeting and the public comment
period and shows how the Agency used these comments to make" the
remedy selection.
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8.4 Reduction o~ Toxicity. Mobility. or Volume Through Treatment
.:...
The fourth evaluation criterion for the detailed analysis is the
reduction of toxicity, mobility, or volume through treatment.
Each alternati,rc is evaluated against this criterion to assess
the anticipated performance 'of the treatment cechnologies used in
the alternative to achieve the reduction in toxicity, mobility, .
and/or volume of the principal threats. CERCLA requires that a .
preference be given to treatment alternatives which reduce the
toxicity, mobility, or volume of hazardous constituents.
'Alternatives 1 does not reduce the mobility, toxicity or volume
of contaminants. 'Alternatives 2 and 3 provide some degr~e of .
reduction.of' the mobility of site constituents. None of. the
alternatives offer a reduction in toxicity or volume.
'8~5 Short-Term Effectiveness
The fifth criterion, short-term effectiveness, addresses the
effectiveness of the alternative during. construction and
operation of the remedial action. Alternatives are .evaluated
with respect to their effects on human health and the
environment, including risks 'to the community posed by
implementation of the action, protection of the wQrkers during
implementation and the reliability and effectiveness of
protective measures available to the workers, potential impacts
to the environment caused by the remedial alternative and the
effectiveness and reliability of mitigative measures which could
be employed during implementation, and the.time required to
achieve .the final response objectives. .
None of the alternatives are expected to have any short term
impacts on site workers. or the surrounding commUnity.
Alternative 2 will have a shprt t~rm i~act 'onthe environment
since the wetlands would be destroyed. Alternative 3 .would cause
a short term disruption in the wetland ecosystems since
vegetation and sediments would be removed.
8.6 Implementability
The sixth criterion upon which. the detailed analysis of remedial
alternatives is based is implementability. This criterion.
involves analysis of ease or difficulty of implementation,
considering the following factors: . .
. 1.
. .
Technical feasibility, that is, the feasibility to
reliably construct; operate, and monitor the
effectiveness of a remedial. action., as well as
potential technical difficulties or unknowns associated
with construction or operation; .
Administrative feasibility, that is, the feasibility of
2.
28
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obtaining permits or rights-of-way for construction or
operation, and coo~dinating interagency approval or
,-activities; .'
3.
Availability of services and materials for a treatment
method or technulogy, such as the availability of
disposal capacity, off-site treatment or storage
capacity, availability of equipment or specialists, 'and
availability of special resources.
All o~ the alternatives are considered to, be easily implementable
from a technical perspective, though alternative 1 would be the
easiest 'to implement. Alternative 2 and 3 would require approval
9f property' 'owners and easement holders or property purchases.
,Although the sediment to be disposed of as a part of alternative
2 would not be considered hazardous, there might be difficulty in
finding a non-RCRA facility willi,ng to accept ~he excavated
sediment because of its origin near three Superfund sites.
8.7 Cost
The seventh criterion assesses cost of the Remedial ActIon. Both
capital and O&M costs are considered. Cost estimates for each'
alternative were submitted to ~PA by Biological Research
Associates Inc., and modified, where appropriate, by EPA.
Estimated costs from the Feasibi~ity Study are considered rough
approximations. No contingency costs are included and inflation
to fieldwork and laboratory costs during the remediation period
was not cons ide red . ' '
Alternative 1 is the least expensive alternative, at $278,000.
Alternatives 2 and 3 are similar in cost at $1,478,000 and
$1,465,000 respectively. '
8.'8 State Acceptance
This criterion assesses the technical and
and concerns the state may have regarding
alternatives. Many of these concerris 'are
compliance with applicable ARARs.
The State of Plorida, as represented by the Florida Department of
Environmental Protection (FDEP), has been the support agency'
,during the Remedial Inyestigation and Feasibility Study ,process,
for ,the Area-Wide Hydrological Study. In accordance with 40 CPR
300.430, as the support agency, FDEP has provided'input duri~g
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.
administrative issues
each of the remedial
addressed through
29
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8.9 Community Acceptance
This criterion assesses the' issues and concerns the public may
have regarding each of the remedial alternatives.
This criterion ,is addressed in the Responsiveness Summary, ,
Appendix A, of this document.
9.0 SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the NCP,
the detailed analysis of alternatives and public and state
comments, EPA has 'selected alternative 1, the no-action remedy,
as, the remedy for this site. Results of the Wetlands Impact,
Study,and the Area-Wide Baseline Risk Assessment indicated that
no ,action is 'necessarY at the site. However, because'
contaminants were found at levels above background in wetland
sediment and surface water, biannual monitoring of wetland
surface water, sediment,' and,the nearby surficial aquifer shall
be conducted.
The purpose of the selected remedy is to assess ,the overall.
ecologic status of the Central and South wetlands as the 'Operable'
Units One, Two, and Three remedies are being implemented. . ,
Monitoring data shall be compared to past wetland data, Florida
Surface.Water Standards (F.A.C, 17-302) and NOAA sediment ER-L'
and ER-M screening values. The remedies for Operable Units One,
Two and Three (described in section 4.0) are expected to
significantly reduce or eliminate the potential for the Bay Drums
'and Peak Oil facilities to act as sources of wetland
contamination. However, If monitoring indicates a potential
threat to human health or the environmerit, EPA, in consultation
with the State of Florida, will reconsider the protectiveness of,
this alternative and the need for additional remedial actions.
The estimated cost for the remedy is $,278,000. ,This Selected
Remedy is protective of" human health and the environment.
9.1
Major Components of the Remedy
The no 'action remedy, consists of semi-annual ecological
assessments of the wetlands for a period of at least (5) years
(at least 10 monitoring events in all) and the installation of
surficial ,aquifer monitor wells. The'monitoring schedule shall
be timed such that one or two assessments occur before work
begins on the Operable Units One, Two, ,and 'Three remedies. The
r~mainingassessments shall occur once the Operable Unit One,
Two, and Three remedies have, been implemented (i.e. when the
surface transport pathway has been eliminated and when surficial
aquifer pumping begins) Each assessment shall include the
following:
30 "
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a. General vegetation surveys to assess the composition and.
health of the plant comrnunitiesand collection of samples to
assess relative abundance and diversity of aquatic
vertebrates and invertebrates.
b. Sampling 'and analysis of wetland surface water,
sediment, and biota. Assays shall be conducteq for.
. purgeable halocarbons and aromatics, phthalate esters,
phenolic compounds, organochlorine pesticides and PCBs,
extractable organics and Priority Pollutant Metals.
Toxicity and bioaccumulation analysis shall be conducted at
least once each year of sampling (at least 5 rounds).
c. Field measurement of hardness, Ph, temperature,
dissolved oxygen and conductivity at each sampling station.
d. Monitoring surf.icial aquifer wells for'the .same .
parameters as in part band c of this section. The purpose
of the well monitoring is to assess potential surficial
~quifercontamination close to the point of discharge into
the wetlands. Florida surface water standards are .
applicable at the point of discharge. The wells shall be
placed so they would intercept surficial aquifer flow from'
the direction of the Bay Drums and Peak.Oil sites.
The ~etland remedial action will be considered complete when
a) monitoring wells immediately upgradient of both the South and
Central wetlands demonstrate that goundwater discharging to the
wetlands does not exceed F.A.C. 17-302 surface water standards
for site-related contamination, b) Operable Unit Two groundwater
. cleanup goals identified in the OUII ROD (or any subsequent
modification of those cleanup goals) have been met, and c) an
evaluation of post-OU4 ROD monitoring data confirms the,
effectiveness of the selected remedy in providing adequate
protection of h~n health and .the environment.
, ,
9.2
Compliance with ARARs
. . .
The Florida Administrat.ive Code Chapter 17-302 MaXimum. .
Contaminant Levels (MCLs) for class .III surface water bodies are
considered to be ARARs for the site wetlands. NOAA ER:'M/ER-L
values are not ARARs for this site, but will serve as guidelines
to assess overall conditions in the wetlands. The Florida
surface water standards and the NOAA ER-Ls may not be initially
met by the selected remedy. ~owever, the~e values are expected
. to be achieved over a short period of time once the source'and
g.roundwater remedies a're implemented. If the surface water
standards and the NOAA ER-Ls are not achieved then EPA will
re-~valuate the effectiveness of the remedy.
Removal actions conducted in between 1985 and 1990 at the Bay
Drums site/Peak Oil site have likely reduced the influx of
31
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contaminants from the~e sites to the wetlands.' In addition, once
the Bay Drums and Peak Oil source remedial actions are
implemented,. and the groundwater remedy is in place, the
potential for contaminant transport from the Bay Drums and Peak
Oil facilities will be significantly reduced.
10.0
Documentation of Sicrnificant Chanqes
The Proposed Plan for the Peak Oil/Bay Drums site was released to
the public on May 2, 1994. The Proposed Plan identified
Alternative 1, No Action with Bcologic Monitoring, as the
'preferred alternative for wetland remediation. BPA reviewed all
written and verbal comments' submitted during the public,comment
period. Upon review of these comments, it was determined'that no
significant changes to, the remedy, as originally identified in
the Proposed Plan, were necessary~
.
32 .
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"APPENDIX A
RBSPONSIVBNBSS StDOIAJlY
-------
RESPONSIVENESS SUMMARY
PEAK OIL/BAY ,DRUMS SUPERFUND SITE
HILLS BOROUGH COUNTY, FLORIDA
The Environmental Protection Agency (EPA) held a public comment
period from May 2, 1994 to May 31, 1994 for interested parties to
comment on EPA's Proposed Plan for OperaQle Unit (OU) Four
addressing the Central and South Wetlands at the Peak Oil/Bay'
Drums Superfund site. During this comment perjod, the EPA held a
public meeting at the Hillsborough Community College in Brandon,
Florida on May 11, 1994. This meeting addressed the wetlands
alternatives for both the Peak Oil/Bay Drums site and the nearby
Reeves site., At this time, EPA representatives presented the
results of the studies undertaken at the site and also EPA's
~preferred alternative for the wetl~nds. .
A summary of EPA's, response to comments received during the
public comment period, known as the responsiveness summary, is
required under'Section 117 of CERCLA. EPA has considered all of
the comments summarized in this responsiveness summary in
determining the final selected remedy presented in the ,Record of
Decision for Operable Unit Four. .
This responsiveness summary consists of the following sections:
A.
Background of Community Involvement and Concerns:' This
section provides a brief history of community ,interest
and concerns regarding the Peak Oil/Bay Drums site.
B.
Summary of Maior OUestions and Comments Received During
the Public Comment Period and EPA's Res~onses: This
section presents both oral and written comments.
submitted during the public meeting and public comment
period, and'provides the responses to these comments.
A.
Backqround of Community'Involvement and Concerns
In accordance with Sections 113 and 1i7 of CERCLA, EPA has
conducted community relations activities at the ,Peak Oil/Bay
Drums site to ensure that the public re;mains informed concerning
progress at the site. During the numerous removal activities at
the site, SPA issued press releases to keep the public ,informed.
There was moderate local press coverage of EPA's activities, and
,EPA held meetings ~ith, county and state officials to advise them
of the progress at the site~ '
A community relations plan (CRP) ~as'developed in 1988 and
revised in 19~9 to establish EPA's plan for community
participation during remedial activities. Following completion
of the Feasibility Study (FS), a Proposed Plan fact sheet was
mailed to local residents and public officials in April, 1994.
.The fact sheet detailed EPA's preferred alternative for
~S-l
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--- ~:~--.. ~...
" ,
addressing the wetland contamination at the Peak Oil/Bay Drums,
site. Additionally, the Administrative Record for the site,
which contains site related documents including the RI and FS
reports and,the Proposed Plan, was made available for public,
review at the information repository in the Brandon Public
Library. A notice of the availabil~ty of the Administrative
Record for the Peak. Oil site was published in the Tampa Tribune
on May 3, 1994.', "
EPA held a public meeting in Brandon, Florida 'on May 11, 1994 at
the' 'Hillsborough COImnunity coll~ge ,to discuss the remedial
alternatives under consideration "and to answer any questions
concerning the Proposed Plans for the Peak Oil/Bay Drums ,and
Reeves Superfund sites. Although attend~nce was fairly low, ,a
,few concerns were raised during ,this meeting. In addition EPA,
re'ceived written comments during the cottunent period. For the
most part, no comments received conveyed an objection to ,the
selection of the No-action With Ecological Monitoring Remedy.
EPA's responses to comments and concerns are summarized in
Section~. A transcript of the public meeting was prepared by a
certified notary public, and this document is a,part of t~e'
Administrative Record upon which the remedy se,lected in the,
Operable Unit Four Record of, Decision is based.
Following the issuance of the final Record of Decision for OU
Four, EPA will continue to keep the coDmtUnity informed about
progress at the site through fact sheets, and informal information
meetings. Additionally, documents pertaining to the '
'implementation of Operable Unit Four will be placed in the
information repository at the Brandon Public Library.
B.
Summa~ of Major Ouestions and Comments Received During the
Public Comment Period and EPA' S', Resconses '
1.
CommeD t
Which metals were found in the wetlands over the accepted
levels?
ReS'OODS8
Lead and Zinc were detected in the surface water above
Florida Cl'ass III Surface Water .Standards. In the sediment
there were limited exceedances of the National Oceanic and
Atmospheric Administration (NOAA) Effects Range-Low (ER~.L)
sediment sc~eening values.' The NOAA value was exceeded for
lead at ope sampling station, zinc at three stations,
mercu~ at one station and antimony at one station.
2.
Commen t
What types of bioaccumulation and toxicity tests were
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. 4.
. n -" n. .---......- - ~ -. .
conducted, and were the toxicity tests run in-situ?
ReS'D0J1S8
For bioa~~'~mulation tests, all samples were ground and
analyzed for all target compound list ('.i.'CL) metals. and for
TCL organics other than volatiles.
Water and sediment samples were taken to the laboratory and
tested for toxicity. Water samples were tested using a
bacterium (Photobacterium nr. phosDhoreum), a freshwater
algae (Selenastrum capricornutum), a small freshwater
cladoceran (Ceriodaphnia dubia), a freshwater fish
(Pimeohales oromelas) and a terrestrial plant (Lactuca
sativa). Soils and sediments were eluted, and the .eluates
produced were tested using the same suite of. organisms.
. .
3.
.' "
Further details of the toxicity and bioaccUmulation testing
process. can be found in the Bay Drums, Peak Oil, and Reeves
.Southeastern Areawide Wetland Impact Study, which can b~ .
found in the site repository.. .
ComiDen t
A citizen expressed concern over the cost of installing
additional wells at the site and indicated that. the existing
wells should be sufficient to supply groundwater data.
R.eS'DOJ1S8
EPA's preferred alternative calls for the installation of
several surficial aquifer wells to monitor surficial aquifer
discharge to the wetlands.. These wells are necessary to .
evaluate whether or not any surficial aquifer contamination
is discharg~ng to the wetlands at concentrations above .
surface water standards. .
Commen t
A citizen expressed a concern .that the. list of endangered
water fowl generated for the wetlands was based on field
observations and that several other endangered species that
may inhabit the area could have remained unsighted during
the field visits.
R.eS'D0J1S8
Endangered or threatened species are generally confirmed at
a site through field observations. At the Peak Oil/Bay
.Drums site. one endangered species and one threatened species
was identified. In addition, assumptions were made through
habitat assessment, about the potential presence or absence
RS-3
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5.
of additional endangered species whose regional habitat
inclu.des the site area. Nevertheless, there. is a reasonable
possibility that previously undocumented endangered or
threatened species visit or inhabit the wetlands. However,
because the study results (contaminant levels,
bioaccumulation ~es~~, and toxicity tests) indicated little
apparent adverse impacts on wetl~nd biota, any discovery of
previously undocumented endangered or threatened species
would not change EPA's decision process for this site.
Commen t
A Florida State Natural Resource Trustee indicated~hat the
ROD should designate qualifiers for possible re-evaluation
of the proposed alternative based upon the monitoring
results and specify that the wetlands should be filled if
the results revealed an injurious impact to the wetlands.
ReS1)ODse.
Specific data evaluation activities will be planned during
the project scoping phase. These evaluation activities will
include comparing the new data to applicable standards and
to past data. It is not EPA's intent, however, to specify
in the ROD specific conditions that would trigger ~dditio~al
action at the site or to outline what the additional action
would consist of. EPA feels that there are too many. unknown
factors to warrant incorporating a specific. con.tingency
remedy into the ROD.
As with all superfund sites, EPA has the authority to
re-evaluate the effectiveness of a remedy should site
conditions indicate such a need. . Additionally, five-year
reviews will be conducted for this site.
6.
Comment.
A May 26, 1994 letter from the Peak Oil/Bay.Drums PRPs
presented the opinion that a no-action remedy should be
chosen rather than a remedy which calls for monitoring.
letter makes the following points/assertions about the
selected remedy (printed in bold). Each PRP comment is
followed by EPA's response:
The wetlands are ecologically indi8tingUi8hable from the
reter8l1ce wetla.ad8 evaluated in the Wetla.ad Impact Study.
The
The toxicity tests,.bioaccumulation tests, arid general
vegetation/diversification surveys conducted as a part of
the Wetlands ~mpact Study did not indicate that the Central
or South wetlands were being impacted more significantly
than the reference wetlands. However, surface water and
RS-4
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sediment samples taken .from the wetlands indicated that the
Central and South wetlands were more contaminated than the
reference wetlands in terms of the numbers and the
concentrations of =ontaminants detected.
The South Wetland rece~ved no significant stormwater
run-off or groundwater flow from the peak/Bay sites [and
.therefore no contaminants] . .
While the Feasibility Study (FS) for the Central and South
Wetlands does indicate that surficial aquifer flow from the
Peak Oil site to the South Wetland would be limited, the.
possibility for such an occurrence exists. In addition, .the'
FSindicates that the Peak Oil site is a potential source
. for South Wetland. contamination via surface migration.
. Storrnwater run-off collects from the site in a ditch on the
. . north side of Reeves Road, and then drains into the South
Wetland. The primary contaminants detected in the South
Wetland above surface water standards and sediment criteria
(lead and zinc) were also found at elevated concentrations
at the Peak Oil site. In summary,.EPA considers the Peak
Oil site to be a potential source of South Wetland
contamination. .. .
The previously-selected source and groundwater remedies for
the site would eliminate the need for any action to take
place for the wetlands.. .
As shown in the Wetlands Impact Study, Peak Oil/Bay Drums
site-related chemicals were detected in the wetlands.
Exceedances of Florida surface water standards and NOAA
sediment screening values .for these site- related chemicals
exist. While previous removals and future. remedial actions
(for OUs One Two and Three) at the site are expected to.
result in improved wetland conditions, .thi~ i~rovement must
. be demonstrated by. continued wetland monitoring and
evaluation. ....
Bstabli.hmaDt of the precise detail of any required
monitoring. program must await the project's remedial design
phas.. . .
EPA agrees that the detailed planning of the monitoring
program should await the design phase. The Selected Remedy
section of the ROD does, however, outline certain.general
. requirements for the monitoring program (sampling .
. parameters., minimum numPer of sampling events ,etc.).. For
example, the Selected Remedy section of the ROD indicates
that monitoring data will be evaluated against the
previously collected data. For this evaluation to occur,
the newly collected data must be comparable to the previous
.da ta .
RS-S
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