PB94-964076
EPA/ROD/R04-94/209
February 1995
EPA Superfund
Record of Decision:
Reeves Southeastern Galvanizing
Corp. (O.U. 3), Tampa, FL
6/28/1994
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RECORD OF DECISION
OPERABLE UNIT THREE
June 1994
Reeves Southeastern Superfund Site
Hillsborough County, Florida
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 Record of Decision (ROD) document presents the selected
remedial action for the Reeves Southeastern Corporation site in
Hillsborough County/ Florida. This ROD was developed in
accordance with the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) of 1980, as amended by
the Superfund Amendment and Reauthorization Act (SARA) of 1986,
42 U.S.C. 9601 et seq., and to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan
(NCP) (Section 105 of CERCLA), 40 CFR Part 300. This ROD is
based on the Reeves Southeastern Site Operable Unit Three
Administrative Record.
The State of Florida, as represented by the Florida Department of
Environmental Protection (FDEP), 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.
DESCRIPTION OF THE REMEDY
This operable unit is the third of three operable units planned
for the site. The first operable unit selected for this site
involves the remediation of the soils/sediment on the site. The
second operable unit addresses the contamination in the northern
surficial aquifer groundwater underlying the site.
The major components of the selected remedy include:
o No Action;
o Long-Term Monitoring of the North Wetland and unnamed
creek;
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DECLARATION STATEMENT
The EPA has determined that no action is necessary to ensure the
protection of human health or the environment. The five year
review will apply to the no action remedy because monitoring of
the North Wetland and unnamed creek will be performed.
t -&-
John H. Hankinson, Jar. Date
Regional Administrator
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TABLE OF CONTENTS
1 .0 SITE NAME, LOCATION, AND DESCRIPTION I
«
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 3
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 5
4.0 SCOPE AND ROLE OF OPERABLE UNIT 6
5.0 SUMMARY OF SITE CHARACTERISTICS 7
5.1 Scope 7
5.2 General Site Characteristics 7
5.3 Results of VIS and Additional Studies 8
6.0 SUMMARY OF SITE RISKS.. 9
6.1 Human Heal th Risks 9
6,1.1 Scope 9
6.1.2 Chemicals of Concern Identification 13
6.1.3 Exposure Asfssment Information 14
6.1.4 Toxicity Assessment Information 14
6.1.5 Risk Characterization Information 20
6.2 Environmental Risks 22
6.2.1 Scope 22
6.2.2 Bioaccumulation 25
6.2.3 Environmental Toxicity Assessment 25
6.3 Uncertainties and Limitations in the BRA Process 26
7.0 DESCRIPTION OF ALTERNATIVES 27
7.1 Applicable or Relevant and Appropriate Requirements 27
7.2 Description Of Alternatives 27
7.2.1 Description of Process 27
7.2.2 Alternative 1A - No Action 34
7.2.3 Alternative IB - No Action/Monitoring 34
7.2.4 Alternative 2 - Filling of Wetland and Unnamed Creek 34
7.2.5 Alternative 3A, 3B, 3C - Excavation of Sediments 34
8.O 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 ARARs 37
8.3 Primary Balancing Criteria 37
8.3.1 Long-Term Effectiveness 37
8.3.2 Reduction of Toxicity, Mobility or Volume 37
8.3.3 Short-Term Effectiveness 37
8.3.4 Implementability 37
8.3.5 Cost 37
8.4 Modifying Criteria 38
8.4.1 State Acceptance 38
8.4.2 Community Acceptance 38
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9.0 SELECTED REMEDY 38
9.1 Selection of Remedy 33
9.2 Major Coaponanta of Remedy 39
9.3 Compliance with ARARs 40
10.0 DOCUMENTATION OF SIGNIFICANT CHANGES 40
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1 —
FIGURES PASS ft
1 Area Hap 2
2 Sampling Locations 10
3 Criteria for Evaluation of Remedial Alternatives.36
TABLES
1 Sediment Data Summary 11
2 Surface Water Data Summary 12
3 Summary of Chemical Concentrations of the COCa
in the North Wetlands 15
4 Summary of Exposure Pathways for the
North Wetlands 16
5 Assumptions Used in Estimating Exposure via
Ingestion of Sediment.. 17
6 Assumptions Used to Estimate Exposure via
Dermal Contact of Sediment 16
7 Assumptions Used to Estimate Exposure via
Dermal Contact with Surface Water 19
8 Summary of Chronic Rfds and Slope Factors 21
9 Cancer Risk by Individual Pathvay 23
10 Hazard Index Estimates by Pathvay 24
11 Potential Chemical Specific ARARs 26
12 Location Specific ARARs 29 - 31
13 Action Specific ARARs 32 - 33
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RECORD OP DECISION
JPERABLE UNIT THREE
REEVES SOUTHEASTERN SUPERFUND SITE
HILLSBOROUGH COUNTY FLORIDA
DECISION SUMK •.*
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 Southeastern Wire
(SEW) facility located on the south side of SR 574 approximately
600 feet west of Faulkenburg Road. Originally, just the SEG
facility was listed in the National Priorities List (NPL) and it
was considered to be the site. Because contamination was
discovered on the SEW facility during the RI, both facilities are
now considered part of the sice. 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 th
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The largest building on the SEW facility is where steel wire is
drawn, weaved into chain link fence, pre-treated and galvanized.
The smaller building on the facility is an office building.
There are three former percolation/evaporation ponds: one on the
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. The North Wetland is the
one that is associated with the Reeves site.
Aerial photographs from the 1950s show that the North Wetland and
unnamed creek predated the SEG facility. In the late 1970s, the
developers of Sabal Industrial Park submitted a permit
application for the construction of a stormwater management
system for the proposed development. The Permit Application
Appraisal, dated May 9, 1978, included the unnamed creek as a
part of the system and defined the unnamed creek as a swale. A
letter from FDER dated December 31, 1981 states that the North
Wetland drainage system is a part of the already existing
stormwater management sy -em for Sabal Park and a letter from the
Southwest Florida Water anagement District (SWFWMD) dated April
18, 1984 reconfirms this. The plat for the Sabel Park Master
Drainage Plan thcic was submitted to SWFWMD in IS84 clearly shows
that the unnamed creek and, by extension, the North Wetland are
considered by Sabal Park to be a part of its stormwater
management system. In the early 1990s, after the sampling for
the WIS had taken place, the unnamed creek was dredged by an
unknown party.
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 Galvanizing 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
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in the late 1960s. Its dimensions were approximately 75' long
and 25' wide and was located along the central western border of
SEW. A second pond was constructed prior to 1969; it was
subdivided- in 1975 to form the two current ponds in the southwest
corner of the facility. Both ponds are approximately 35' by 35',
and are surrounded by a 3' berm. The ponds were excavated to a
depth of 3'. Discharge into these ponds ceased in. 1980 when SEW
began using its wastewater pretreatment program. Discharge from
this facility also goes into the local POTW.
The U.S. EPA conducted a site investigation in 1981 that
indicated elevated metal levels in surface water and groundwater
at the SEG facility. Subsequently, the Florida Department of
Environmental 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.
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 for the Reeves site 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, 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 and the resulting remedy
selection on the groundwater underlying the Reeves site are
documented in the Operable Unit Two - Record of Decision.
September 1993. The remedy decision consists of the following:
natural attenuation of the Northern Surficial Aquifer;
installation of additional monitor wells in the Northern
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Surficial Aquifer; prevention of discharge of gro'_ ater fr
the Northern Surf i -ial Aquifer ir.r.o the surface w<^ in the
unnamed creek; installation of a monitor well in * Upper
Floridan Aquifer in the general -cinity of the fcjiaer production
wells on the Reeves SEG facility implementation of an inteisive
well survey within a one mile raaius of the site; and completion
of the remedial design for the contingency remedy. The
contingency remedy, to fce implemented 2.6 years after completion
of the GUI remedy should the OU2 remedy be failing, is to pump
and tre.- che grour vwater in the Nc -them Surficial Aquifer and
then di. .arge the reated water i: o the POTW.
EPA conducted the Wetlands Impact Study (VIS) at the same time
the area-wide groundwater RI/FS was being conducted by Reeves and
the Peak Oil/Bay Drums PRPs. The risk assessment was provided by
the PRP groups as a part of the -rea-wide RI. The FS was
developed by EPA personnel info;. cion provided by the P groups
and the WIS.
In February 1993, Reeves signed a Modification to the site-
specific RI/FS AOC under which Reeves agreed to perform the
Remedial Design for the OU1 remedy. For the Reeves OU1 and OU2
remedies, EPA issued a special notice letter (SNL) to the Reeves
Southeastern Corporation on September 30, 1993. The SNL c fered
Reeves the opportunity to perform the OU1 and OU2 remedies and
reimburse outstanding EPA past costs relating to the site.
Reeves and EPA Region IV signed a Consent Decree (CD) in which
Reeves agreed to perform the work, pay EPA's future oversight
costs and reimburse EPA's past costs. The past cost amount was
$297,778.28. The CD was referred to the Department of Justice
(DOJ) on April 21, 1994.
3.0 HIGHLIGHTS OF COMMUNITY RTICIPATION
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 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
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RI/FS was completed and presented to the public in February 1993.
The public meeting was held on February 24, 1993. The preferred
alternative presented at this meeting for the Reeves site was a
pump-and treat remedy for the northern surficial aquifer. The
selected remedy in the ROD was natural attenuation, with the
pump-and-treat sy&tem selected as a contingency remedy. In
addition, measures will be taken in the design process to prevent
the surficial aquifer from draining into the unnamed creek. The
only written comments received on the Reeves site from either
comment period came from the Reeves Corporation itself.
The North Wetland WIS/FS and Proposed Plan for the Reeves
Southeastern Site were released to the public on April 30, 1994.
These documents were released in conjunction with the Peak Oil/
Bay Drums Central and South Wetlands WIS/FSs and Proposed Plans
and were made available to the public in both the Administrative
Record and the information repository maintained at the EPA
Docket Room in Region IV and at the Brandon Public Library. The
notice of availability of these documents and announcement of the
pending public meeting was published in the Tampa Tribune on May
3, 1994. A public comment period was held from May 2 to May 31,
1994. The public meeting was held on May 11, 1994. At the
meeting, representatives from EPA presented the two Proposed
Plans and answered questions regarding the problems at the three
sites and the wetlands remedial alternatives under consideration
for the North, Central and South Wetlands. A response to the
comments received for the North Wetland during the public comment
period is included in the Responsiveness Summary, which is
Appendix A of this ROD. This decision document presents the
selected remedial action for the North Wetland and unnamed creek
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 three operable units (OUs). These are:
o OU One: Contamination in the soils and sediments;
o OU Two: Contamination in the groundwater;
o OU Three: Contamination in the North Wetland and unnamed
creek.
OU One has been addressed in the Reeves OU One - ROD. October
1992. OU Two has been addressed in the OU Two - ROD. September
1993. The Reeves OU Three will address the North Wetland and
unnamed creek. This is planned to be the final Operable Unit for
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the Reeves site. The Peak Oil/Bay Drums OU Four will address .he
Central and the South Wetlands. The Peak Oil and Bay Drums OL
Four will be selected in a separate ROD.
5.0 SUMMARY OF SITE CHARACTERISTICS
5.1 Scope
This section will discuss general site characteristics and
outline the results of the WIS and other North Wetland sampling
events. The issue of source contamination is addressed in the
Operable Unit One - Record of Decision; the issue of groundwater
contamination is addressed in the Operable Unit Two - Record of
Decision.
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 ar^a 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
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protection strategy. A Class IIB aquifer is considered a
potential drinking water source.
The North Wetland is located to the immediate west of the Reeves
SEG facility. It is about 1.75 acres in size and is located in
the maintained right-of-way of power lines and is the only one of
the studied wetlands with a surface water inlet and outflow.
After rain events, surface water inflow originates in a ditch
paralleling SR 574 and running west between the Peak Oil/Bay
Drums sites and the south side of the road. The topographic
contour of the SEW facility would tend to cause surface water
runoff to the south of the plant, not into the ditch. This ditch
is joined by runoff from the Peak Oil/Bay Drums sites via a
series of culverts that run from the sites under the CSX railroad
and then into the drainage ditch. The surface water then runs
through a culvert under SR 574 at the power lines and then enters
the North Wetland. It exits the North Wetland and flows in a
drainage ditch northeast and crosses the northwest corner of the
SEG facility, where it is joined by a drainage ditch carrying
runoff from the SEG facility. The drainage ditch (a.k.a the
unnamed cr2ek) then heads north, where it is joined by the runoff
from the parking lots of various other office buildings and
another road, and eventually flows into the retention pond for
the stormwater drainage system at Sabal Industrial Park. The
outflow from the retention pond flows into the Tampa Bypass
canal. The classification of the wetland was conducted according
to a U.S. Fish & Wildlife methodology. The vegetative
classification is palustrine system, emergent/aquatic bed class.
5.3 Results of WIS and Additional Studies
The topography of the SEG site slopes toward the northwest. The
drainage off the SEG facility is into a drainage ditch that runs
from the east to the west of the facility, immediately south of
the two ponds, then turns north and joins the unnamed creek
immediately north of the northwest corner of the facility. Other
sources of contamination for the North Wetland can potentially be
identified. In particular, stormwater in an urban setting
contains elevated levels of inorganics such as zinc, lead,
copper, cadmium and chromium from vehicular use of highways and
parking lots. The sources of such inorganics include vehicle
parts such as brakes, tires and hydraulic fluids, as well as
direct fallout from the atmosphere and degradation of highway
materials.
A limited amount of sampling done for the WIS tested material
from the site itself. Surface water from the two inactive ponds
and soil from the eastern part of the SEG facility did not show
significant toxicty to the test organisms. Sediments from the
SEG ponds, however, are highly toxic. Other onsite soil areas
that showed toxicity were the former drum storage area and the
onsite drainage ditch. The onsite source areas that tested toxic
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will be addressed by the Operable Unit One remed -hat was
selected in the October 1992 Record of Decision.
Three phases of sampling were done for the North Wetland and the
unnamed creek. Phase I sampling took place in November 1989 and
Phase 2 sampling took place in January 1990. Phase 1 and Phase 2
were composed of both surface water and sediment sampling. Both
Phase 1 and Phase 2 data were used in the WIS. On its own,
Reeves undertook a third phase of sampling. This data was taken
in 1993 and consisted only of sediment sampling. The sample
points are shown on Figure Two. The sediment data is reported in
Table One and the surface water data is reported in Table Two.
The data reported in these two tables have been narrowed down to
the data reported for the contaminants of concern (as selected in
Chapter Three of this FS). The entire range of results can be
found in Tables 4.5 and 4.6 of the HIS. The levels of metals
found in the North Wetland are comparable to those found in the
drainage ditch leading to it. The levels found during the WIS in
the unnamed creek, after being joined by drainage off the SEG
facility, were significantly higher than the levels in either the
North Wetland or upgradient drainage ditch. However, since the
field work for the WIS was completed, the unnamed creek has been
dredged by an unknown entity. Sampling performed on Reeves'
behest by its consultant in 1993 indicate that the current levels
of contaminants of concern (COCs) in the unnamed creek are
significantly lower than the levels found during the sampling for
the WIS. Surface water levels in the North Wetland and
upgradient drainage were comparable; the levels were
significantly higher in the unnamed creek. There are no 1993
sample results for comparison purposes for the surface water.
The WIS concluded that the wetlands associated with the three
Superfund sites provide a diversity for a balanced community of
plants and animals. The ecological functions of these wetlands
were rated as moderate to high. The apparent toxicity of the
sediment does not appear to impair the wetland functions. On the
other hand, the WIS showed that the unnamed creek associated with
drainage from the SEG facility was severely impacted by heavy
metal contamination.
6.0 SUMMARY OF SITE RISKS
6.1 Human Health Risks
6.1.1 Scope
A baseline risk assessment (BRA) was conducted as part of the RI
to estimate the health or environmental problems that could
result if the Northern Wetland was not remediated. A BRA
represents an evaluation of the "No Action" alternative, in that
it identifies the risk present if no remedial action is taken.
The assessment considers environmental media and exposure
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Station 10
a
o
10
Station B
(UMC)
Station A
(NOW)
-- I-J v
Station 1
Station 4
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TABLE ONE
Sediment Data Summary (MG/KG)
Station
Date 19-
arsenic
cadmium
chromium
lead
mercury
nickel
zinc
4
89
11.1
2.8N
92. 2N
860
.24
9.8
2960
93
8.6
6
320
1100
.4
19
4500
1
89
46N
2N
168N
3070
.16
71.9
4480N
93
5.2
<1
25
160
.3
<8
470
A (01-NOW)
89
12. 7U
1.1B
22.3
266
1.1*
4.5B
355EN
93
<2
<1
3
3
<.l
<8
6
B (01-UNC)
89
NT
. 8B
21.9
70.8
.22*
9.7
11,200
EN
90
__
—
--
18
— —
--
—
93
<2
<1
9
2.7
.5
<8
170
10
89
3.4UN
1.6N
23.4
62.8
.09
4.9B
3430
93
<2
<1
9
2.7
.5
<8
160
II1
89
3.8U
.25
UN
7.9N
5U
.04
2B
153
1 - Station not sampled in 1993
U - Analyzed but not detected
B - Analyte present in associated blank
N - Spike sample recovery out of control limits
* - Duplicate analysis out of control limits
E - Estimated value due to interference
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K)
I
TABLE TWO
Surface Water Data Summary (UG/L)
Station
Date
arsenic
cadmium
chromium
lead
mercury
nickel
zinc
4
11/10/89
__
— -
__
5.1
--
— —
37.9
A (01-NOW)
11/30/89
3B
—
--
--
NA
4. IB
48.7
B (01-UNC)
11/30/89
41. 2S
9.8
135
352
NA
155
172000
1/9/90
_ _
--
16
15
--
— —
11000
10
11/10/89
__
-_
__
5W
--
__
1410
( — ) - non detect.
B - Analyte found in associated blank as well as in sample.
W - The post-digestion spike for furnace AA analysis is outside of the
85-115% control limits while sample absorbance is less than 50% of
the spike absorbance.
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pathways that could result ~n u -ceptable levels ^f exposure in
the foreseeable future. Da~a c lected and ana. .-ad during the
RI provide_d the basis for the r_5k evaluation. _.ie 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) and the Northern Surficial Aquifer BRA is
discussed in detail in the Operable Unit Two ROD (September
1993). The BRA for the North Wetland and associated drainage
ditch was developed as a part of the area-wide BRA. This section
will discuss the BRA for the North Wetlands and associated
drainage system.
6.1.2 Chemicals of Concern Identification
Based on *he study area data, the BRA selected chemicals of
potential concern (COPCs) to focus on those likely to pose the
greatest threat to human health. The final list of COFCs for the
site-wide BRA included chemicals found on all three sites. For
reasons that are more fully explained in another Chapter, it has
been determined that the main contributor to any potential
problem in the North Wetlands is the Reeves SEG facility.
Therefore the initial selection of COPCs for the North Wetlands
would be the same as the COPCs identified in the Reeves Site
Source Characterization Baseline Risk Assessment, February 1992.
These COPCs are as follows:
o arsenic
o cadmium
o chromium
o gold
o lead
o mercury
o nickel
o polychlorinated biphenyls (PCBs)
o polynuclear aromatic hydrocarbons (PAHs)
o 1/2/4-trichlorobenzene
o zinc
Further examination of the COPCs for the source control RI/FS,
however, reveals that the organic COPCs were found only on the
Reeves S?w facility. The organics on the SEW facility were not a
result c the facility itself, but rather were a spil -ver of
contaaiir. its from the immediately adjacent Peak Oil sx.e. There
is no complete pathway between the SEW facility and the North
Wetlands. For that reason, the organic COPCs were eliminated
from the list of indicator chemicals. Gold was eliminated from
-13-
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the list because it was not found in the surface water or
sediment of the North Wetland. The final list of chemicals of
concern (COCs) for the North Wetlands and associated drainage
areas is as follows:
o arsenic
o cadmium
o chromium
o lead
o mercury
o nickel
o zinc
Appropriate exposure point concentrations (EPC) were then
calculated for each COC. The COCs, the highest concentrations
detected and the EPCs are found in Table Three.
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. The
North Wetland presents a potential route of exposure through
wading and subsequent contact with chemicals in the water. For
the current use scenario, exposures are assumed to occur to
trespassers near the site. These individuals would be exposed
through dermal contact and incidental ingestion of sediments and
incidental contact with sediment. Direct ingestion of surface
water was not considered because the water in the wetland would
not ordinarily be considered suitable for drinking. Incidental
ingestion of the surface water was not considered because the
wetland is too shallow for swimming. For the future use
scenario, exposures are assumed to occur to children and
teenagers living at the site. The exposure pathways would remain
the same. The summary of exposure pathways and scenarios can be
found in Tables Four through Seven.
6.1.4 Toxicitv Assessment Information
Slope factors (SFs) have been developed by EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risks
associated with exposure to the potentially carcinogenic
contaminant(s) of concern. SFs, which are expressed in units of
(mg/kg-day)"1, are multiplied by the estimated intake of a
potential carcinogen, in mg/kg-day, to provide an upper-bound
estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The term "upper bound" reflects
the conservative estimate of the risks calculated from the SF.
Use of this approach makes underestimation of the actual cancer
risk highly unlikely. Slope factors are derived from the results
of human epidemiological studies or chronic animal bioassays to
which animal-to-human extrapolation and uncertainty factors have
been applied (e.g., to account for the use of animal data to
-14-
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TABLE THREE
Summary of Chemical Concentrations of the Chemi<--is of
Concern in the North Wetlands
Chemical
Arsenic
Cadmium
Chromium
Lead
Mercury
Nickel
Zinc
Media
surface
water
sediment
surface
water
sediment
surface
water
sediment
surface
water
sediment
surface
water
sediment
surface
water
sediment
surface
water
sediment
Concentration
surface water (ug/1)
sediment (mg/kg)
Highest
Concentration
Detected
3
12.7
ND
1.6
ND
108
5
266
ND
1.1
6
4.9
1410
3430
Exposure Point
Concentration
2
8.7
— —
1.28
—
73.8
4
177
—
0.712
6
4.7
971
2200
-15-
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TABLE FOUR
Summary of Exposure Pathways
for the North Wetland
Current Use Condition/Onsite Trespasser
Dermal contact with sediments
Dermal contact with surface waters
Incidental ingestion of sediments
Future Use Conditions/Onsite Resident
Dermal contact with sediments
Dermal contact with surface waters
Incidental ingestion of sediments
-16-
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_ Ass .ptior
^l"*^^^^?^™"^^^^^^^^^^^^*'"^^!;^^^s
Parameter
Chemical
Concentrations in
Sediment
Ingestion Rate
(mg/day)
Exposure Frequency
( days /year )
Exposure Duration
(years)
Body Weight (kg)
Average Time ( days )
Noncarcinogens
Carcinogens
TABLE FIVE
is Used to Estimate Exposure via
Ingestion of Sediment
Current Use Future Use Resident
Trespasser
see EPCs in Table Three
100
30
9
35
3,285
25,550
100
30
9
35
3,285
25,550
-17-
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TABLE SIX
_ Assumptions Used to Estimate Exposure via
Dermal Contact of Sediment
Parameter
Chemical
Concentrations in
Sediment
Skin Area Exposed
(cm2)
Deposition Factor
(mg/cmVday)
Exposure Frequency
(days /year)
Exposure Duration
(years)
Body Weight (kg)
Average Time (days)
Noncarc inogens
Carcinogens
Absorption Factor
(unitless)
Current Use
Trespasser
Future Use Resident
see EPCs in Table Three
1520
0.2
30
9
30
3,285
25,550
Chemical Specific
1520
0.2
30
9
30
3,285
25,550
Chemical Specific
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TABLE SEVEN
- Assumptions Used to Estimate Exposure via
Dermal Contact with Surface Water
Parameter
Chemical
Concentrations in
Sediment
Skin Area Exposed
(cm2)
Dermal Permeability
Coefficient (cm/hr)
Exposure Time
(hours /day)
Exposure Duration
( years )
Exposure Frequency
(days /year)
Body Weight (kg)
Average Time (days)
Noncarcinogens
Carcinogens
Absorption Factor
(unitless)
Current Use
Trespasser
Future Use Resident
see EPCs in Table Three
1520
1520
Chemical Specific
1
9
30
35
3,285
25,550
Chemical Specific
1
9
30
35
3,285
25,550
Chemical Specific
-19-
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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
drinkingwater can be compared to the RfD. RfDs are derived from
human epidemiological studies or animal studies to which
uncertainty factors have been applied (e.g., to account for the
use of animal data to predict effects on humans). The Chronic
Daily Intake (GDI) factors and the applicable route-specific
Slope Factors for the chemicals of concern can be found in Table
Eight.
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
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 a
concentration 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
cancer risk is calculated from the following equation:
Risk = GDI x SF
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 in 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
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)"1
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 maximum estimate, an
-20-
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TABLE EIGHT
Summary of Chronic Rfds and Slope Factors
Chemical
Arsenic
Cadmium
Chromium
Lead
Mercury
Nickel
Zinc
Oral Toxic ity
RfD
(mg/kg/day)
3.00E-4
5.00E-4
5.00E-3
HA
3.00E-4
2.00E-2
3.00E-1
SF
I/ (mg/kg/day)
1.75
NA
NA
NA
NA
NA
NA
Reference
IRIS
IRIS
IRIS
UBK model
used
instead
HEAST
IRIS
IRIS
-21-
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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 nonearcinogenic effects is evaluated by
comparing an exposure level over a specified time period (e.g.,
life-time) with a reference dose derived for a similar exposure
period. The ratio of exposure to toxicity is called a hazard
quotient (HQ). By adding the HQs for all contaminant(s) of
concern that affects the same target organ (e.g., liver) within a
medium or across all media to which a given population may
reasonably be exposed, the Hazard Index (HI) can be generated.
The HQ is calculated as follows:
Non-cancer HQ = CDI/RfD
where:
GDI = Chronic Daily Intake
RfD = reference dose; and
CDI 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 Nine. 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 Ten. The results for both the
carcinogenic and the nonearcinogenic COCs were well within the
range that EPA considers acceptable.
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%.
6.2 Environmental Risks
6.2.1 Scope
The Area-Wide Wetland Impact Study (WIS) has two objectives: (1)
to evaluate the ecological status of wetlands in the study area;
and (2) to extend the toxicity testing to include possible source
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TABLE NINE
Cancer Risk by Individual Pathway
SCENARIO/ EXPOSED
POPULATION
RISK
CURRENT USE -
Dermal Contact,
Surface water
Ingest ion, Sediment
Dermal Contact,
Sediment
CHEMICAL
TRESPASSER
2E-9
1E-6
9E-8
FUTURE USE -
Dermal Contact,
Surface water
Ingest ion, Sediment
Dermal Contact,
Sediment
• RESIDENT
2E-9
1E-6
9E-8
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TABLE TEN
Hazard Index Estimates by Pathway
SCENARIO/EXPOSED
POPULATION
RISK
CURRENT USE -
Dermal Contact,
Surface water
Ingest ion, Sediment
Dermal Contact,
Sediment
CHEMICAL
TRESPASSER
0.0003
0.03
0.001
FUTURE USE -
Dermal Contact,
Surface water
Ingest ion, Sediment
Dermal Contact,
Sediment
• RESIDENT
0.0003
0.03
0.001
-24-
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materia_3, soil, surface water and samples from the thre sites.
Since t.ie source material from the Reeves site is addret =d in
Operable Unit One, that information is not further discussed
here.
Five wetlands were considered in the Area-Wide WIS. These
wetlands are: The North Wetland; the Central Wetland; the South
Wetland; the Spray Field Wetland and the Cypress Pond Wetland.
The latter two wetlands have no relation to any of the three
sites, but instead were selected as comparison wetlands based on
their hydrologic, vegetative, and sediment similarities to the
three site related wetlands.
6.2.2 Bioaccumulation
Overall, fish and crayfish sampled from the various wetland ar 3
that comprise this studv vere not impacted with a wide spectrv
of chemicals at concent :ions grossly over background. The
exception is the very hj.Tn concentrations of iron and zinc found
in either fish or crayfish samples from the unnamed creek.
Several inorganic analytes were widely present over the area
sampled at concentrations moderately over background. These
include aluminum, barium, copper, iron, manganese, titanium and
zinc. Mercury concentrations in tissue analyzed were typically
lower than the national mean values. However, three of the four
samples of fish and crayfish taken from the reference wetlands
exceeded criteria proposed for the protection of birds that may
prey upon them.
6.2.3 Environmental Toxicity Assessment
This section discusses the results of the toxicological
assessment performed to determine the impact cc -tituents may
have upon the biota. Samples of water, soils e : sediment were
evaluated for toxicity based on acute and chronic: test results
after various organisms were exposed to various site media.
Water samples were tested using a bacterium, a freshwater algae,
a small freshwater cladoceran, a freshwater fish and a species of
lettuce. Sediment samples were eluated and the eluates produced
were tested using the same suite of organisms. The data
generated indicated the following:
o The waters of the North, Central, and South Wetlands
showed little toxicity to the organisms tested;
o The sediments of each wetland area studied were at
least chronically toxic to daphnia;
o The water and sediment of the unnamed creek at the
northeast corner of the Reeves SEG facil. / were toxic
to almost all organisms tested;
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o The sediments of the Cypress Pond were highly toxic to
fish, daphnids, algea, and bacteria.
It should be noted that, since the WIS was completed, some
unknown entity has dredged the unnamed creek area that was highly
toxic. As discussed in Section 5.3 of this ROD, data taken in
1993 indicates the levels in the sediments are now lower than the
levels found in the WIS.
6.3 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
following categories:
o environmental sampling and laboratory measurement;
o mathematical fate and transport modeling;
o receptor exposure assessment; and
o toxicological assessment.
The BRA is based on surface water and sediment data specific to
the sites gathered for the Area-Wide RI. The quality of data
depends on 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 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,
-26-
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many of this BRA'S assumptions were assumptions made ^A. As
can be expected any time that an assumption is made, -2 is
some dispute as to the appropriate level of conserva 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.
7.0 DESCRIPTION OF ALTERNATIVES
7.1 Applicable or Relevant and Appropriate Requirements (ARARs)
Section 121 (d)(2)(A) of CERCLA specifies that Superfund
Remedial Actions must meet any Federal standard, requirement,
criteria or limitation that is determined to be an applicable or
relevant and appropriate requirement (ARAR). ARARs fall into
three categories: contaminant-specific; location-specific; and
action-specific. Some rules do not specifically apply to a
remedial action; however, because of the subject matter, they may
provide some guidance in implementing a chosen RA. These rules
are called to-be-considered (TBCs). Potential ARARs.and TBCs can
be found in Tables Eleven through Thirteen.
7.2 Description of Alternatives
7.2.1 Description of Process
The contaminated material both at the site and in the North
Wetland and unnamed creek was evaluated in regard to the
applicability of the RCRA Land Disposal Requirements (LDRs) and
it was determined that the RCRA LDRs were not an ARAR.
Based on the WIS results, EPA conducted a FS to identify and
evaluate appropriate remedial alternatives for minimizing risks
to people and the environment which could be caused by
contaminated surface water and sediments in the North Wetland and
the unnamed creek. EPA considered six remediation alternatives
in the wetlands FS. Those six alternatives are listed in the FS
as Alternatives 1A, IB, 2, 3A, 3B and 3C. Two of these
alternatives are variations of the mandatory no action
alternative developed as required by the National Contingency
Plan (NCP). The no action alternative is developed to provide a
base.ine comparison of human health and environmental benefit to
-27-
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N)
CO
I
TABLE ELEVEN
Potential Chemical-Specific ARARs and TBCs
Authority/
Requirement
Description
Status
Consideration
in the FS
Federal
Clean Water Act (CWA),
Section 304 (a) (1),
Ambient Water Quality
Criteria (AWQC)
Health based criteria for
chemicals - designed to
protect aquatic life and
human health
To Be
Considered
Considered in
development of
remedial
alternatives
State
Florida Surface Water
Quality Standards, FAC
17-302
Establishes minimum
surface water quality for
designated classes
Relevent and
Apprpriate
Considered in
development of
remedial
alternatives
-------
XI
TABLE TWELVE
Potential Location-Specific ARARs and TBCs
Authority/
Requirement
Description
Status
Consideration
in the FS
Federal
Executive Order on
the Protection of
Wetlands, 40 CFR
Part 6, Appendix
Fish and Uldlife
Act, 40 Uft 6.302
Endangered Species
Act (50 CFR Part
402)
Requires federal
agencies to avoid, to
the extent possible, the
adverse impacts
associated with
destruction or loss of
wetlands
Requires EPA to
coordinate with federal
and state agencies if
the remedy would modify
any stream or other
water body. Remedy must
contain provision for
protection of fish and
wildlife resources
Requires action to
conserve endangered
species for activities
in critical habitats.
The DOI Fish and
Wildlife Service and DOC
NOAA need to be
consulted
Relevant and
Appropriate
Applicable
Applicable
Consideration
if remedy
involves
alteration of
wetland
Cons ider a t ion
if remedy
involves
discharge to,
or alteration
of, wetlands
and streams
Consideration
if site is
located in
the area of a
critical
habitat for
endangered or
threatened
:>pecies
-------
la
O
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
Consideration
in the
development
of
alternatives
if remedy
involves
dredging,
filling, or
other
excavation
activities
near or in
wetland
State
Florida Regulation
of Stonnwater
Discharge, FAC 17-
25.020(14)
Florida Regulation
of Stonnwater
Discharge, FAC 17-
25.020(16)
Florida Regulation
of Stonnwater
Discharge, FAC 17-
25.025
Definition of a
"Stonnwater Discharge
Facility-
Definition of a "Swale"
Defines the design and
performance standards
required of a Stonnwater
management system.
Relevant and
Appropriate
Relevant and
Approp riate
Relevant and
Appropriate
Consideration
in the
development
of remedial
action
objectives
Cons ider a t ion
in the
development
of remedial
action
objectives
Consideration
in the
development
of remedial
action
objectives
-------
Florida Rules on
Hazardous Waste
Warning Signs, FAC
17-736
Requires use of
appropriate warning
signs to inform public
of potentially harmful
conditions at the site.
Applicable
May be
required on
borders of
Wetland
-------
TABLE THIRTEEN
Potential Action-Specific ARARs and TBCs
Authority/
Requirement
Description
Status
Consideration in
the FS
Federal
Identification and
Listing of
Hazardous Waste, 40
CFR Part 261
Identifies solid
wastes which are
subject to
regulation as
hazardous waste
Applicable
Considered in
development of
alternatives
Land Disposal
Restrictions
(LDRB), 40 CFR 268
Regulations identify
hazardous wastes
that are restricted
from land disposal
and define the
circumstances under
which an otherwise
prohibited waste may
continue to be
disposed.
Applicable
Considered in
development of
alternatives
Water Quality
Standards [CWA
402(a)(l)]
Effluent limitations
are required to
achieve all
appropriate state
water quality
standards
To Be Considered
Considered in
the development
of remedial
alternatives
-------
Florida Surface
Water Standards,
FAC 17-302.300
State
Antidegradation
policy for surface
water quality.
Prohibits discharge
of wastes into
Florida waters
without treatment to
protect beneficial
uses
Relevant and
Appropriate
Considered in
the development
of remedial
alternatives if
a remedy
involves
discharge to
surface water
that are
considered
"waters of the
state"
Florida Hazardous
Waste Rules, FAC
17-730
Florida hazardous
waste management
regulations
Applicable
Considered in
the development
of remedial
alternatives if
a remedy
involves
hazardous waste
treatment,
storage or
disposal
Florida Permit
Regulations, FAC
17-4
Establishes
procedures and
requirements to
obtain a permit from
FDBR
Applicable
Considered in
the development
of remedial
alternatives if
a Florida permit
is required
-------
that which ia provided by the active remediation alternatives.
In conjunction with the source characterization and groundwater
RI/FSs, the North Wetland FS was developed. It assumes that the
Reeves selected source control and groundwater remedial actions
will be implemented.
7.2.2 Alternative 1A - No Action Alternative
For this alternative, no action would be taken to remove
orcontrol any of the constituents of the sediments in the North
Wetland. The North Wetland and the unnamed creek would be left
in their present condition without disturbing the sediments. A
no action response provides a baseline assessment for comparison
with other alternatives for the North Wetland and unnamed creek
that contain greater levels of response. Under no action, no
remedial technologies would be implemented. However, these other
operable units will improve the general conditions in the area
and thus should have a beneficial effect on the North Wetland.
TOTAL COST: $0
7.2.3 Alternative IB - No Action/Monitoring
Monitoring of the sediments would be conducted at intervals over
a period of eight years to verify that the improved conditions in
the North Wetland is maintained. Under no action/monitoring, no
remedial technologies would be implemented in the North Wetland.
TOTAL COST: $39,860
7.2.4 Alternative 2 - Filling of Wetland and Unnamed Creek
Filling of the North Wetland and the unnamed creek would involve
the removal of vegetation and placement of clean fill over areas
of sediment that exceed the clean-up goals established by the
EPA. It would further be necessary to construct a replacement
detention pond and replacement swale to handle the stormwater
management functions currently handled by the North Wetland and
the Drainage Swale. It may also be necessary to prepare and
implement a mitigation plan for the wetl&nd that would be
destroyed.
TOTAL COST:
with land purchase - $546,250
without land purchase - $316,250
7.2.5 Alternatives 3A, 3B and 3C - Excavation^ of Sediments
These alternatives would involve the excavation of sediments.
Excavated sediments would have to be placed on adjacent land or
disposed off site. Due to the low levels of constituents in the
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sediments, it would not be necessary to place the excavated
sediments in a RCRA Subtitle C hazardous waste landfill or to
treat the sediments by solidification or other means. However,
it would be necessary to determine a location for placement of
the sediments. Three options have been identified as
possibilities. Those options are as follows:
o Alternative 3A - disposal in industrial waste landfill
in Georgia;
o Alternative 3B - disposal in Springhill Regional
Sanitary Landfill in Graceville, Florida;
o Alternative 3C - disposal in Pinellas County Landfill
in St. Petersburg, Florida.
After completion of the excavation activities, the excavated area
would have to be backfilled with clean soil from an off-site
location, and the original contours would have to be established.
It then would be necessary to replant the site with appropriate
vegetation. Monitoring of the vegetation would be necessary for
a period of three years to verify the establishment of the
planta.
TOTAL COST:
o Alternative 3A - $2,526,550
o Alternative 3B - $2,003,300
o Alternative 3C - $2,311,644
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 explained in more detail in
Figure Three on the next page. The comparison of the six
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
Protection of human health and the environment is provided by
Alternatives 2, 3A, 3B and 3C. Alternatives 1A and IB provide
slighter lesser protection of the environment in that these
alternatives would leave levels of two metals that are slightly
above the ER-Ls.
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CRITERIA FOR EVALUATING REMEDIAL ALTERNATIVES
In selecting its preferred cleanup alternative, EPA uses the following criteria to evaluate each of
the alternatives developed in the Feasibility Study (FS). The first two criteria are essential and
must be met before an alternative can be considered further. The next five are used to further
evaluate EPA's proposed plan after public comment period has ended and comments from the
State have been received. All nine criteria are explained in more detail here.
Overall Protection of Human Health and the Environment - Assesses degree to which alternative
eliminates, reduces, or controls health and environmental threats through treatment, engineering
methods, or institutional controls.
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) • Assesses
compliance with Federal/State requirements.
Cost • Weighing the benefits of a remedy against the cost of implementation.
ImplementabiHly - Refers to the technical feasibility and administrative ease of a remedy.
Short-Term Effectiveness - Length of time for remedy to achieve protection and potential impact
of construction and implementation of a remedy.
Long-Term Effectiveness • Degree to which a remedy can maintain protection of health and
environment once cleanup goals have been met
Reduction ofTaaddty, Mobility, or Volume Through Treatment' Refers to expected performance
of the treatment technologies to lessen harmful nature, movement or amount of contaminants.
State Acceptance- Consideration of State's opinion of the preferred alternative.
Community Acceptance - Consideration of public comments on the preferred alternative and the
Proposed Plan, :
FIGURES
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8.2.2 Compliance with ARARs
All of the altern? ives meet ARARs.
8.3 Primary Balancing Criteria
8.3.1 Long-Term Effectiveness and Permanence
Alternatives 1A and IB have the least long-term effectiveness
inthat nothing would be done. Alternative 2 has relatively more
long-term effectiveness because it prevents further degradation
of the environment by preventing contact between the contaminated
media and the ambient environment. Alternatives 3A, 3B and 3C
provide the most long-term effectiveness and permanence by
permanently removing the contaminated media from the site.
8.3.2 Reduction of Toxicity. Mobility, or Volume
Alternatives 1A and IB wouldn't result in any iduction <•
toxicity, mobility or volume. Alternative 2 ild resul n a
reduction of toxicity and mobility by preventi.-.g contact -etween
the contaminated media and the ambient environment. This
alternative would not affect volume. Alternatives 3A, 3B and 3C
offer the reduction of toxicity, mobility and volume by
permanently removing the contaminated media from the site.
However, given the proximity of the North Wetland to the road,
there is the possibility that this may not be a permanent
condition.
8.3.3 Short-Term Effectiveness
The short-term effectiveness of Alternatives LA and IB is higher
than that of Alternatives 2, 3A, 3B and 3C. The reason is that
there is some minimal hazard to workers who would be involved in
the construction of these four alternatives.
8.3.4 Implementabilitv
Alternatives LA and IB have no administrative barriers to
implementation. Alternative 2 may require mitigation under the
Clean Water Act in addition to the alternative as described.
Alternatives 2, 3A, 3B and 3C will require obtaining the
permission of the property owners of the land on which the North
Wetland and the unnamed creek are located. Alternatives 3A, 3B
and 3C may require permits to transport and dispose of the
contaminated material.
8.3.5 Cost
The cost of the six alternatives are compared below:
o Alternative 1A - $0
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o Alternative IB - $39,860
o Alternative 2
w/ land purchase - $546,250
w/out land purchase - $316,250
o Alternative 3A - $2,526,550
o Alternative 3B - $2,003,300
o Alternative 3C - $2,311,644
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
letter of concurrence has not yet been received.
8.4.2 Community Acceptance
The general public in the community expressed no major concerns
about the selected remedy during the public comment period. The
comments are discussed in detail in the Responsiveness Summary,
which is Appendix A of this ROD.
9.0 SELECTED REMEDY
9 .1 Selection of 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 IB, the No
Action/Monitoring 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, 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 North Wetland and unnamed creek as the
Operable Units One and Two 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
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and ER-M screening values. The remedies for Operable Units One
and Two (described in detail in the ROD-OU1. Reeves Site. October
1992 and the ROD-OU2, Reeves Sit 3. September 1993) are expected
to significantly reduce or eliminate the potential for the Reeves
Southeaster site to act as sources of contamination to the North
Wetland and unnamed creek. However, If monitoring indicates a
potential threat to human health or the environment, 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 $39,860. This Selected
Remedy is protective of human health and the environ.- ^nt.
9.2 Malor Components of the Remedy
The No Action/Monitoring remedy consists of ecological
assessments of the wetlands for a period of at least 8 years, to
be performed on no less that a semiannaual basis for the first 5
years. The 8 year time period was selected to parallel the
approximately eight year time period that the OU2 natural
attenuation remedy is anticipated to take. If the OU2
groundwater remedy takes longer than eight years, then the
monitoring of the North Wetlanc and unnamed creek will be
extended to match the monitor period for the OU2 remedy.
Depending on the final selection of the engineering measures that
will be undertaken to prevent infiltration of the surficial
aquifer into the unnamed creek, the installation of surficial
aquifer monitor wells immediately upgradient of the unnamed
creek, for the purpose of monitoring the discharge of the
surficial aquifer into the surface water in the unnamed, may be
required. Every effort shall be made to time the monitoring
schedule such that one or two assessments occur before work
begins on the Operable Un-LS One and Two remedies. The remaining
assessments shall occur once the Operable Unit One and Two
remedies have been implemented. Each assessment shall include
the following:
a. General vegetation surveys to assess the composition and
health of the plant communities and 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. At a minimum, assays shall be
conducted for the COCs identified in the FS and Section 6 of
this ROD. Toxicity and Bioaccumulation analysis shall be
conducted at least once each year of sampling (at a minimum,
8 rounds in all).
c. Field measurement of hardness, Ph, temperature,
dissolved oxygen and conductivity at each sampling station.
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d. Monitoring selected surficial aquifer wells for the same
parameters as in part b and c of this section.
The wetland remedial action will be considered complete when the
following conditions are met:
a) (1) engineering measures taken to prevent discharge of
groundwater to the unnamed creek have proven to be
effective; or
(2) monitoring wells immediately upgradient of the
unnamed creek demonstrate that groundwater discharging
to the surface water in the unnamed creek 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 OU2 ROD (or any subsequent modification of those
cleanup goals) have been met; and
c) u. review of post-ROD monitoring data confirms the
effectiveness of the selected remedy in providing
adequate protection of human health and the
environment.
9.3 Compliance with ARARs
The Florida Administrative 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. However, these values are expected
to be achieved over a short period of time once the source and
groundwater remedies are implemented. Once the Reeves source and
groundwater remedial actions are implemented, the potential for
contaminant transport from the Reeves Southeastern facilities
will be significantly reduced.
10.0 DOCUMENTATION OF SIGNIFICANT CHANGES
In the North Wetland FS, F.A.C. 17-302 was listed as a TBC rather
than as an ARAR. In listing it as a TBC, EPA was narrowly
focusing on its application to surface water runoff from the road
and other non-site sources. F.A.C. 17-302 is an ARAR in regard
to hazardous substances discharges into the surface water from
the site. The ARARs table in the ROD has been modified to
reflect this change.
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RECORD OF DECISION
OPERA- " Z UNIT THREE
APPENDIX A
RESPONSIVENESS SUMMARY
Reeves Southeastern Superfund Site
Hi:\sborouqh County, Florida
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RESPONSIVENESS SUMMARY
REEVES SOUTHEASTERN SUPERFUND SITE
HILLSBOROUGH COUNTY, FLORIDA
I. Overview
The United States Environmental Protection Agency (EPA) held a
public comment period from May 2, 1994 to June 1, 1994 for
interested parties to comment on EPA's Proposed Plan for Operable
Unit (OU) Three addressing the North Wetland and unnamed creek at
the Reeves Superfund Site. The comment period was originally set
to end on May 31, but because the newspaper ran the notice a day
late, on May 3, the comment period was extended to June 1.
During this comment period, the EPA held a public meeting at the
Brandon Campus of the Hillsborough Community College on May 11,
1994. At this time, EPA representatives presented both the
results of the studies undertaken at the site and EPA's preferred
alternative for addressing the surface water and sediment
contamination in the North Wetland and unnamed creek. EPA also
informed the audience about the one day extension of the public
comment period.
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 OU Three.
This responsiveness summary consists of the following sections:
I. Overview: This section provides an overview cf the
contents of the responsiveness summary.
II. Background of Community Involvement an Concerns: This
section provides a brief history of community interest
and concerns regarding the Peak Oil/Bay Drums site.
III. Summary of Malor Questions and Comments Received from
the General Public During the Public Comment Period and
EPA'3 Responses: This section presents both oral and
written comments submitted by the public and interested
government agencies during the public meeting and
public comment period, and provides the responses to
these comments.
IV. Summary of PRP Comments and EPA's Responses; This
section presents comments submitted by the PRP, the
Reeves Southeastern Corporation, and EPA's reply to
those comments. These comments were contained in the
June 1, 1994 letter from Gayle Carlson, Esq., (Reeves'
attorney) to Martha Berry, RPM/EPA. The PRP's comments
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are subdivided into three sections: comments on the
Proposed Plan; the Feasibility Study; and the
Administrative Record.
II. Background of Community Involvement and Concerns
In accordance with Sections 113 and 117 of CERCLA, EPA has
conducted community relations activities at the Reeves site to
ensure that the public remains informed concerning progress at
the site. EPA periodically issued press releases to keep the
public informed. There was moderate local press coverage of
EPA's activities, and EPA held meetings with county and state
officials to advise them of the progress at the site.
A community relations plan (CRP) was developed in 1988 and
revised in 1989 to establish EPA's plan for community
participation during remedial activities. Following completion
of the Wetlands Impact Study and Feasibility Study (WIS/FS), a
Proposed Plan fact sheet was mailed to local residents and public
officials in May 1994. The fact sheet detailed EPA's preferred
alternative for addressing the contamination in the North Wetland
and unnamed creek. Additionally, the Administrative Record for
the site, which contains site related documents including the WIS
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 availability of the Administrative
Record for the Reeves site was published in the Tampa Tribune on
May 3, 1994.
Finally, EPA held a public meeting in Brandon, Florida on May 11,
1994 at the College to discuss the remedial alternatives under
consideration and to answer any questions concerning the Proposed
Plans for the North, Central and South Wetlands at the Bay Drums,
Peak Oil and Reeves Superfund Sites. Although attendance was
fairly low, a few concerns were raised during this meeting.
Questions were raised concerning all three wetlands sites; this
Responsiveness Summary only addresses comments directed towards
all three sites in general or the North Wetland in particular.
Comments that apply specifically to the Central and South
Wetlands and proposed remedies are addressed in the
Responsiveness Summaries for the ROD for those wetlands. EPA's
responses to these concerns from the meeting and from written
comments that were submitted to the Agency are summarized in
Section III. The Reeves Southeastern Corporation also submitted
a number of questions in writing. Because Reeves is the PRP, its
comments are addressed separately in Section IV. A transcript of
this public meeting was prepared by a certified notary public,
and this document is a part of the Administrative Record upon
which the remedy selected in the OU Three Record of Decision is
based.
Following the issuance of the final Record of Decision for OU
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Three, EPA will continue to keep the community informed about
progress at the site through fact sheets and informal information
meetings. Additionally, design and construction documents
pertaining to the implementation of OU Three will be placed in
the information repository at the Brandon Public Library.
Ill. Summary of Malor Questions and Comments Received from the
General Public During the Public Comment Period and EPA's
Responses
1. Comment:
Response:
In the Proposed Plan, the following statements are
made concerning the results of the WIS:
a. The sediment of each wetland area studied
were at least chronically toxic to daphnia.
b. The water and sediment of the unnamed creek
at the northeast corner of the Reeves SEG facility
were toxic to almost all organisms tested.
c. The sediments of the Cypress Pond were highly
toxic to fish, daphnids, algea, and bacteria.
How would the preferred alternative, No
Action/Monitoring, satisfactorily address these
issues?
The responses to these issues are addressed in the
order they were asked:
a. Of the five wetlands studied, two, the
Cypress Swamp and the Spray Field Wetland, were
studied to provide "background" data for the WIS.
CERCLA only authorizes EPA to demand cleanup of
problems caused by the Superfund site. Since the
toxicity to the daphnia also resulted from the
sediments in the two background wetlands, EPA
concluded that this was not a problem that could
be attributed to contamination from the site.
b. The WIS found that the water and sediment
from this area was indeed highly toxic. However,
visual observation since the completion of the WIS
by several people familiar with how the unnamed
creek historically looked indicated that the
unnamed creek had been dredged and straightened
out by an unknown entity since the WIS sampling
event. Sediment sampling conducted by Reeves i**
1993 confirmed that the levels of COCs in the
sediment were dramatically lower than the levels
found during the WIS. It is EPA's conclusion that
the current levels of COCs in the sediment would
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2. Comment:
Response:
3. Comment::
not cause significantly more toxicity to aquatic
organisms that would be caused by sediment from
the background wetlands. To assure that this is
the case, EPA is proposing to require an extensive
monitor plan that would require chemical
characterization, bioaccumulation and
toxicological analyses testing over a period of
years. If the monitoring required under the plan
shows that there is extensive toxicity posed by
the current levels of COCs, then EPA will use that
information to reassess the appropriateness of the
remedy.
c. EPA is not authorized under CERCLA to address
the Cypress Swamp as a part of this project
because the Cypress Swamp is not a part of, or
affected by, the Reeves site. It was used as a
background wetland for the WIS.
In the Proposed Plan, EPA states that
implementation of the preferred alternative would
leave levels of two metals slightly above the ER-
Ls. After reviewing the data in Table 1 of the
Proposed Plan, it appears that the ER-Ls are
exceeded in the sediments for each of the seven
metals represented. Chromium was found in levels
up to four times the ER-L level, lead up to
eighty-eight times, mercury up to 1.6 times,
nickel up to 2.4 times and, finally, zinc at
levels up to 93 times. Please explain this
discrepancy.
In making this statement in the Proposed Plan, EPA
was referring to the 1993 data taken from sample
points A, B and 10. Sample points 4 and 1 are
upstream from the North Wetland and the levels
found in these samples are most likely the result
of stormwater runoff from the road. Information
found in Appendix A of the FS states that metals,
including lead and zinc, are a significant
component of road runoff. Sample points A, B and
10, which are all downstream from sample points 4
and 1, are the sample points affected by surface
water runoff from the SEG facility. Based on the
most recent sampling from these three sampling
points, implementation of the preferred
alternative would leave levels of two metals
slightly above the ER-Ls.
Are NOAA's ER-Ls for inorganics applicable to the
sediments in the wetlands, the unnamed creek and
the Cypress Pond? If not, please state what
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specific criteria are to be used in assessing
toxicological risk of the contaminants to various
organisms.
Response: Screening Guidelines for Inorganics were developed
and are used by the National Oceahographic and
Atmospheric Administration (NOAA). The ER-L
levels are the lowest screening levels used by
NOAA for purposes of evaluating the effect of
sediments in wetland areas. These ER-L levels are
the most conservative of NOAA's screening levels
for sediments and do not necessarily indicate that
sediment should be remediated to these levels.
Other screening concentrations established by NOAA
and used by the EPA Region IV in the WIS are the
Effects Range—Median (ER-M) and the Overall
Effects Threshold ("Threshold") levels. EPA does
not have any promulgated standards for sediment,
nor does EPA have a standard methodology for
selecting acceptable sediment levels on a site
specific basis.
4. Comment: In the NWFS, it was stated that the contaminated
sediments in the unnamed creek had been removed by
an unnamed entity prior to the 1993 sampling
event. Does EPA know who this entity is or where
this entity took the material?
Response: EPA is not aware of who this entity is or where it
took the material.
5. Comment: The Florida Games and Florida Fresh Water
Commission have a list of animals, specifically
birds, that are not on the federal endangered
species list. When considering the potential
effects on endangered species, does EPA look at
lists of animals designated by state agencies or
does EPA just use species that are listed by the
U.S. Fish & Wildlife Service?
Response: The concern behind this question seemed to be that
EPA did not consider State concerns when analyzing
potential effects on endangered species. However,
CERCLA/SARA mandates that both the federal and the
state government designate agencies to function as
Natural Resource Trustees (NRTs). One of the
major mandates of the NRTs is to determine
potential adverse effects on natural resources,
which include wildlife and plantlife, as well as
threatened and endangered species. Formerly in
the State of Florida, there were two agencies
designated as NRTs: the Department of
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Environmental Regulation; and the Department of
Natural Resources. Recently, these two agencies
were merged into one, the Florida Department of
Environmental Protection (FDEP). Both the federal
and the state NRTs had input into the entire
wetlands investigation process and have concurred
that the preferred alternative in vrie Proposed
Plan will be protective of both human health and
the environment.
IV. Summary of PRP Comments and EPA's Responses
The Proposed Plan
1. Comment: The "Description and History" section includes a
detailed description of Reeves Southeastern
Corporation ("Reeves") and the Superfund studies
conducted at Reeves' Southeastern Galvanizing
("SEG") and Southeastern Wire ("SEW") properties.
This section incorrectly gives the impression that
the North Wetiand is part of the Southeastern
Galvanizing site.
It is important to note that the North Wetland is
not and has never been a part of the property
owned by Reeves. It also is important to note
that only the small portion of the drainage swale
(referred to in the Proposed Plan as the "unnamed
creek") that crosses the northwest corner of
Reeves' SEG property is owned by Reeves. The
remainder of the drainage swale is owned by a
third party. Additionally, Reeves has never
conducted any activities in or around the North
Wetland.
Based on the information in the Area-Wide
Hydrologic Remedial Investigation Report ("Area-
Wide RI") and the North Wetland Feasibility Study
("NWFS"), impacts to the North Wetland would have
resulted from sources other than Reeves. As the
NWFS notes, the Area-Wide RI states that the
stormwater runoff at the SEG property flows north
and west into the drainage swale, not to the North
Wetland. In addition, the NWFS (page 2-3) notes
that the levels of inorganics in the North Wetland
are comparable to those in the upgradient drainage
ditch that flows into the North Wetland via the
culvert under State Road 574.
The Proposed Plan and the Record of Decision to be
issued subsequently should include discussions of
the many other sources of potential impacts to the
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2.
North Wetland and the drainage swale, which are
discussed in the NWFS. These other sources
include, but are not limited to, air emissions
from the Hillsborough County Resource Recovery
Plant and stormwater runoff from ditches along
State Road 574, from a culvert under State Road
574 (draining a 49-acre watershed south of the
highway, including the Peak Oil and Bay Drums
Superfuhd Sites and the railroad tracks), and from
west of the North Wetland (including drainage
through a large area formerly an automobile
salvage yard and still containing remnants of
junked vehicles and debris), and stormwater from
ditches, storm sewer outfalls and sheetflow runoff
from roadways, parking lots and other areas in an
industrial and office park.
in spite of statements to the contrary in certain
EPA documents, these culverts remain open, and in
fact there are other culverts from the Peak Oil
and Bay Drums Sites to the ditches along the
railroad tracks that are still open (see the
letter from John GooIsby contained in the Reeves'
submittal by Gayle B. Carlson to David Abbott
dated October 5, 1993, which is part of the
Administrative Record). We want to emphasize the
continuing influences from these sites as well as
the likelihood that contaminants will be released
from the Peak Oil and Bay Drums Sites to the North
Wetland during the remedial actions scheduled to
take place at those sites.
Response: EPA does not dispute the significant points of
this comment, therefore, EPA has no response.
However, EPA emphasizes that the implementation of
the remedies for the Peak Oil/Bay Drums sites, if
properly done, should not result in the release of
contamination from those sites.
Comment: Pages 2 and 4 of the Proposed Plan discuss only
Operable Units One and Two that will be conducted
by Reeves. This discussion should also include
the operable units for the Peak Oil and Bay Drums
.Sites because these other operable units may
affect the conditions in the North Wetland and in
the drainage swale. The effects could be
beneficial (e.g., reducing contaminants in a
source area) and/or detrimental (e.g., creating
the release of contaminants during construction of
a remedial action).
Response: To date, EPA has not found it useful to summarize
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the selected operable unit remedies for all three
sites in its decision documents. To provide the
histories for all three sites would be very
cumbersome and would only grow more so as the
various RO/RAs are implemented. EPA does agree
with the point that the source control RD/RAs at
the Peak Oil/Bay Drums sites may have an impact on
the North Wetland and unnamed creek if the RD/RAs
are not properly implemented.
Comment: The first paragraph on page 4, the phrase "within
a one mile radius of the site" should be omitted
to reflect the EPA's revised scope of work for the
Reeves OU2.
Response: This revision will be made as appropriate in
future documents.
Comment: Page 5 of the Proposed Plan states as follows:
"Based on data developed in the Wetlands Impact
Study ("WIS"), it has been determined that the
main contributor to any potential problem in the
North Wetlands is the Reeves SEG facility." This
conclusion is not drawn in the WIS, and the WIS
actually states that surface water drainage from
the Peak Oil and Bay Drums sites flows to the
North Wetiand via a drainage ditch and a culvert
under SR 574 (see pages 2-3 and 5-1 of the WIS).
With respect to the SEG property, the WIS states,
in much less conclusive terms than reported on
page 5 of the Proposed Plan, that surface runoff
from the SEG property "appears probable" (see page
5-1 of the WIS). Further, contrary to this
inconclusive intimation in the WIS, we show below
in the Feasibility Study comments that the SEG
facility could not have contributed to any impacts
in the North Wetland. It is clear from
information reported in the Area-Wide RI (see
pages 4-76 through 4-78), the WIS (see pages 2-3
and 5-1), and the North Wetland Feasibility Study
(see, e.g., pages 2-7, 3-6, and 3-20) that there
are many sources that may have affected and may be
affecting the North Wetland.
Responses There are many potential sources of contamination
of the North Wetland, of which the SEG facility is
probably one. The topography of the southwest
corner of the SEG facility slopes towards the
North Wetland; therefore any contaminated soils in
that area could have been carried by stormwater
runoff in~ the wetland. Regardless of the many
sources o contamination for the North w and.
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there is no question that the SEG facility is the
main contributor of contamination in the unnamed
creek and this is the area of offsite
contamination that was of most concern to EPA and
to the natural resource trustees.
Comment: At the top of the right-hand column on page 8 of
the Proposed Plan, there is a reference to "by
contaminated groundwater in the Northern Surficial
Aquifer." It appears that the above phrase should
be deleted and replaced by "by the North Wetland
and the drainage swale."
Response: This error will be corrected in future documents.
Comment: Reeves agrees with the EPA's selection of
Alternative 1 B for the North Wetland OU3. Reeves
notes, however, that the cost estimate included in
the Proposed Plan may be significantly
understated, depending on the types of testing
required (see Comment 5 below in the comments on
the North Wetland Feasibility Study).
Response: EPA concurs that the cost estimate in the Proposed
Plan does not reflect the cost of the types of
testing requested by the natural resource
trustees. However, the cost estimate is accurate
in its relationship to the other cost estimates
and, thus, fulfills its requirement to provide an
accurate comparison of the relative cpsts of the
alternatives.
The Feasibility Study
Comment: With respect to Sections 1.2.1 (Site Description)
and 1.2.2 (Site History) of the NWFS, we here
incorporate Comment 1 from the Proposed Plan
discussion above.
Response: Please refer to EPA's response to Comment #1 on
the Proposed Plan.
Comment: With respect to Section 1.2.2 of the NWFS, we also
here incorporate Comment 2 from the Proposed Plan
discussion above.
Response: Please refer to EPA's response to Comment #2 on
the Proposed Plan.
Comment: In the last paragraph of Section 1.2.2.1 (page 1-
6), the phrase "within a one mile radius of the
site" should be deleted to reflect the EPA's
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revised scope of work for the Reeves OU2.
Response: This change will be reflected in attire documents.
Comment: Reeves disagrees with the statement in Section
2.2.1.1 (page 2-8) that "for the reasons that are
more fully explained in another Chapter, it has
been determined that the main contributor to any
potential problem in the North Wetlands is the
Reeves SEG facility." There simply is no other
chapter in the NWFS that discusses any basis for
the foregoing conclusion. To the contrary, as
stated in Comments 1 and 4 from the Proposed Plan
discussion above, impacts to the North Wetland
have resulted from sources other than Reeves. As
the NWFS itself notes throughout, all the
topographical information collected during the
Area-Wide RI shows that the stormwater runoff at
the SEG property flows north and west into the
drainage swale, not to the North Wetiand. The
NWFS includes several discussions of the many
oth«»r sources of potential imports to the North
Wetland and the drainage swale (e.g., page 2-7 in
the last paragraph of Section 2.1.2, page 3-6 in
the next to last paragraph of Section 3.2.2, page
3-20 in the second full paragraph, page 6-7 in the
second paragraph of Section 6.3.3.2, page 6-1 0 in
the last paragraph of Section 6.3.4.2, page 6-12
in the second paragraph of Section 6.3.5.2, and
page 6-1 5 in the second paragraph of.Section
6.3.6.2). In addition, we note that the report in
Appendix A to the NWFS and the information in the
August 6, 1993, letter from Gayle B. Carlson to
Martha Berry (copy attached) show the many sources
of contaminants found in urban stormwater in
Florida.
The materials that have been submitted on behalf
of Reeves and the points that the EPA itself has
made in various documents indicate numerous PRPs
in connection with the North Wetland and the
drainage swale. The materials submitted on behalf
of Reeves also show Reeves is not responsible for
impacts to the North Wetland. The EPA should
consider identifying the appropriate PRPS.
Response: Please refer to EPA's response to Comment #4 on
the Proposed Plan.
Comment: In Section 5.2.2, the NWFS states that monitoring
of the sediments will be conducted over a period
of eight years and that chemical characterization,
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bioaccumulation and toxicological analyses, as
well as other types of environmental testing,
should be considered in the development of the
final monitoring plan. In the discussion of costs
of the No Action/Monitoring alternative in Section
6.3.2.5, the NWFS notes that the cost estimate
includes only the sediment sampling because cost
figures for the chemical characterization,
bioaccumulation and toxicological analyses were
not readily available. Thus, depending on the
additional sampling that ultimately is selected,
the costs of the No Action/Monitoring alternative
may be substantially higher.
Reeves objects to the requirement of sampling of
the sediments twice a year for the first five
years. Reeves requests that this portion of the
NWFS be changed to specify sampling of the
sediments once a year for the entire eight-year
sampling period.
In addition, Reeves objects to the inclusion of
chemical characterization, bioaccumulation and
toxicological analyses in this alternative. The
monitoring of the sediments on an annual basis
will be sufficient to track the status of the
North Wetland and drainage swale.
The North Wetland does not belong in the Superfund
process because it is part of a stormwater
management system. Any effects found in the North
Wetland are the same as those found in hundreds of
stormwater management systems throughout Florida
(see the submittals attached to the August 6,
1993, letter from Gayle B. Carlson to Martha
Berry). Neither the EPA nor the Florida DEP has
ever suggested that CERCLA and all of its
requirements should be imposed on all those other
stormwater management systems. Therefore, the
bioaccumulation and toxicological assessments
should not be required for the North Wetiand and
drainage swale, particularly when nothing has
shown Reeves to be responsible for the North
Wetiand, when the sediments from the drainage
swale have already been removed by some other
party, and when the OU2 ROD requires Reeves to
provide a barrier in the drainage swale.
Response: EPA disagrees with this comment. At the beginning
of the RI/FS process, there wac ample reason to
suspect that runoff from either the SE6 or the SEW
facility was carrying contamination into these
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bodies. Although the results of the WIS indicate
that the North Wetland itself is impacted by a
number of different sources, this most certainly
was not intuitively obvious at the beginning of
the process. Certainly, there can be no question
that the main contributor of contamination to the
sediments in the unnamed creek is drainage off of
the SEG facility. The sample with the highest
levels c~ metals from the offsite
wetlands/drainage ditches was found in the unnamed
creek at the point where it was joined by the
drainage ditch off of the SEG facility. The
samples from this area showed significant
toxicity. The two significant reasons that cause
EPA to consider monitoring in the area, rather
than an active remediation remedy, are: (1)
sampling from 1993 indicates that these highly
contaminated sediments have been removed from the
area; and (2) components from the OU1 and OU2
remedies, when implemented, should prevent
recontamination of the unnamed creek from the SEG
facility.
EPA also disagrees with the assertion that CERCLA
should not be applied to the North Wetland and
unnamed creek because these areas are a part of a
permitted stormwater management system. Although
this fact is considered when EPA considers the
potential land use aspects of the risk and remedy
selection process, it would not prevent EPA from
taking an action in these areas. The issue of the
stormwater management system had a more direct
impact on whether or not certain state regulations
would be ARARs, not whether EPA had the legal
authority to order a remedial acr. on in the
wetland.
EPA believes that the bioaccumulation and the
toxicity testing is necessary for the monitoring
program because the levels left in the sediments
are slightly above the ER-Ls established by NOAA.
Although the ER-Ls are not considered "cleanup
criteria", they are useful in determining what
levels of contaminants are of no concern vs. what
levels are probably not of concern but should be
monitored. It is EPA's opinion that the current
state-of-the-art knowledge about sediment
contaminant levels does not yet allow for
regulatory establishment of cleanup levels.
Therefore, the decision :>n cleanups of sediment
should be made based on site-specific data
concerning the impact of those actual sediments on
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the flora and fauna at the site. Without the
types of testing suggested in the NWFS, mere
knowledge of the levels of contaminants in the
sediments would not provide information that could
be used in determining whether the site is not
having a significant adverse affect on the North
Wetland and unnamed creek.
It should be noted that the parameters of the
monitoring plan will be established in the final,
EPA approved, Work Plan for implementing the No
Action/Monitoring alternative and will be subject
to modification based on the results of that
monitoring.
6. Comment: While not critical to the substance of the NWFS,
there are a few typographical errors that we noted
in reviewing the report. We are providing a list
of the corrections below for your use in producing
the final version of the NWFS.
Page No. Correction
ES-4 The words "may be" should be omitted at the
end of the third to last line on the page.
1-2 The word "Southwestern" should be changed to
"Southeastern" in the fourth line from the
bottom of the page.
1-4 The first two words on the fourth line of the
page need a space between them. The same
change should be made for the first two words
on the sixth line of the page. Additionally,
the word "Galvanizing" should be added
between the words "Southeastern" and
"Division" in the fifth line from the bottom
of the page.
1-6 The word "Part" in the sixth line from the
bottom of the page should be "Park."
2-20 The word "later" should be "latter" in the
fourth line from the bottom of Section
2.2.2.1. The work "creed" should be "creek"
in the fifth line on Section 2.2.2.2.
2-21 The word "discuss" should be "discusses" in
the first line of Section 2.2.2.3. The word
"toxilogical" should be "toxicological" in
the last line on the page.
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2-22 The word "that" should be added after
"conservatism" in the next to last line of
the third paragraph.
3-9 The word "and" should be "any" in the fifth
line of the second block of the second
column. In the third block of the fourth
column, it appears that either something is
missing or there are extra words.
3-12 The references to FAC 1 7-020(14) and 1 7-
020(16) should be to FAC 1 7-25.020(14) and 1
7-25.020(16).
3-17 The order of the words "the that" in the
third line of SdcfiiSn should be reversed.
5-1 The word "is" should be "are" in the third
line of Section 5.2.2.
Response: EPA will be using the NWFS information .-'n its
preparation of the OU3 ROD and will make the
necessary corrections in that document. The NWFS
found in the Administrative Record will not be
revised further.
The Administrative Record
1. Comment: Section 3.7, Item 1: All the even-numbered pages
of the authorizing statutes were omitted, probably
because they were not copied from the reverse
sides of the odd numbered pages. In addition,
only part of the Memorandum of Agreement between
FDER and SWFWMD concerning delegation of
authorities between FDER and SWFWMD is included.
Please add to the OU3 Administrative Record ("AR")
' all these missing pages.
The diskette referenced in this item was not
included in the AR. We have been advised by
representatives of the Peak Oil and Bay Drums
Groups that the contents of the diskette are
identical to the contents of the "Assessment of
U.S. EPA Bay Drums, Peak Oil and Reeves
Southeastern Area-Wide Wetland Impact Study: (1)
Comments on Wetland Impact Study; (2) Remediation
Alternatives" that accompanied Robert L. Rhodes,
Jr.'s letter of October 29, 1993, to David Lloyd,
which also is part of the OU3 AR. If there are
differences between the diskette and that
submittal of October 29, 1993, Reeves reserves its
rights to comment on the diskette contents later.
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Response: In reference to Item 1, the accompanying statutes
in the copy of the AR in the EPA Records Center
was complete. EPA will make sure the final AR
that goes out with the ROD has the correct pages.
In reference to the SWFWMD Memorandum of
Agreement, the pages duplicated in the AR reflect
the pages that are attached to the original item
in EPA's files. The files for this project to not
contain a complete copy of MOU. In reference to
the diskette mentioned in this item, a search of
the files did not reveal a copy of the diskette.
Therefore the contents of the diskette, if
different from the document referenced in this
comment, will not be concluded in the Operable
Unit Three AR.
Comment: Section 3.8, Item 1; It also appears that only one
side of each page of this report was copied (i.e.,
only the odd-numbered pages were included). After
discovering the missing pages on May 24, we
requested and received the complete copy from
Region IV, but we have not had a chance to review
the report fully. Reeves reserves the right to
submit supplemental comments on this item,
including comments concerning the appropriateness
of including this report in the Administrative
Record.
Response: In reference to this report, the copy of the AR in
the EPA Records Center was complete. ,EPA will
make sure the final AR that goes out with the ROD
has the correct pages.
Comment: Section 3.10. Items 1-12: Although letters
requesting comments on the Wetlands Impact Study
Plan (WISP) and responses to those letters are
included, the WISP itself is not included in the
AR. Reeves requests that the WISP be included in
the Administrative Record, as well.
The EPA requested comments on the WISP from a
number of people, but only three responses are
included in the AR. Please advise us whether
there were other responses, and if so, provide us
with copies. Reeves reserves its rights to
comment on any additional responses following
receipt of the copies.
Response: A copy of the WISP has been located and will be
added to the final AR. A review of the site files
did not turn up any additional replies to the
comment request letters.
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Comment: Section 3.1 0.
Items 13-14: These two memoranda
1986
Response:
Comment:
Response:
Comment:
refer to two attachments, the WISP and "a
paper by an Assistant Attorney General with the US
Department of Justice, Land and Natural Resources
Division," which were not included in the AR.
Reeves requests a copy of the 1986 Department of
justice paper and reserves its rights to submit
comments on that paper following receipt,
including comments concerning the appropriateness
of including this report in the Administrative
Record.
EPA has searched the Reeves, Peak Oil and Bay
Drums files and was unsuccessful in locating the
DOJ attachment to these two memos. Therefore, it
will not be possible to include the DOJ paper in
the Operable Unit Three AR.
Section 3.1 0, Item 23; This memorandum from
Waynon Johnson of NOAA states that the flow of
stormwater under the railroad track south of SR
574 has been eliminated. This is an incorrect
statement. As reported in a letter from John
Goolsby of Heidt & Associates, the culvert under
the railroad track south of SR 574 is open, and
stormwater continues to flow through the culvert.
The letter from Mr. Goolsby is attached to the
submittal on behalf of Reeves from Gayle B.
Carlson dated October 5, 1993, which is part of
the AR at item 25, S 3.1 0.
There also is an incorrect statement concerning
flow from the "unnamed creek" into Six Mile Creek
before it reaches the Tampa Bypass Canal. Flow
actually is into the Mango Canal and then into the
Tampa Bypass Canal.
EPA agrees that this comment is correct.
Additional Items- Reeves requests that the
following items be added to and made a part of the
OU3 North Wetland Administrative Record:
The Reeves' OUl and OU2 Administrative Records
(which can be incorporated by reference),
including the following letters and all documents
referenced in and attached to the following
letters: the letter frcaa Gayle B. Carlson, Trenam,
Simmons, et al., (September 17, 1992) regarding
documents proposed to supplement the Site Source
Administrative Record, the follow-up letter from
Gayle B. Carlson, Trenam, Simmons, et al.,
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(September 22, 1992) regarding the same, the
letter from Gayle B. Carlson, Gayle B. Carlson,
P.A. (April 21, 1993) regarding documents proposed
to supplement the OU2 Administrative Record (this
letter is already in the OU3 AR), and the follow-
up letter from Gayle B. Carlson, Gayle B. Carlson,
P.A. (April 22, 1993) regarding the same.
Aerial photographs prepared by the EPA's
Environmental Photographic Interpretation Center,
entitled "Site Analysis-Reeves Southeastern
Corporation; Peak Oil; Bay Drum—Brandon, Florida-
-Volume 2," TS-PIC-85117, December 1985.
Letter from Gayle B. Carlson to Martha Berry dated
August 6, 1993.
Supplemental Analysis of Remedial Alternative 1
Source Control/Monitoring Operable Unit Two,
Reeves Southeastern Corporation, July 1993,
prepared by RUST Environment & Infrastructure.
Response: The letters referenced in the second paragraph of
this comment all have to do with items that Reeves
requested be added to the OU1 and 2 ARs. These
issues were resolved by EPA at the time these ARs
were assembled and do not have an impact on the
remedy selection process for the OU3 remedy.
Therefore, these letters will not be added to the
OU3 AR.
The letter from Gayle B. Carlson to Martha Berry
dated August 6, 1993 and the Supplemental Analysis
of Remedial Alternative 1 Source
Control/Monitoring Oper*»hle Unit Two, Reeves
Southeastern Corporation, July 1993 are considered
by EPA to be remedial design issues for the OU2
selected remedy. For that reason, these two
documents will not be added to the OU3 AR.
EPA agrees that the aerial photographs prepared by
the EPA's Environmental Photographic
Interpretation Center and the Reeves OU1 and 2 ARs
were used in the remedy selection process and will
add them to the final OU3 AR.
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