PB97-964016
EPA/541/R-97/074
November 1997
EPA Superfund
Record of Decision:
Sherwood Medical Industries,
Operable Unit 3,
Deland, FL
9/18/1997
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RECORD OF DECISION
OPERABLE UNIT 3
SHERWOOD MEDICAL NPL SITE
DeLand, Volusia County, Florida
1
Prepared by:
Environmental Protection Agency
Region 4
Atlanta, Georgia
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RECORD OF DECISION
SHERWOOD MEDICAL COMPANY
OPERABLE UNIT 3
1. DECLARATION
SITE NAME AND LOCATION
Sherwood Medical Industries Site
DeLand, Volusia County, Florida
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for Operable Unit 3 at the Sherwood
Medical site in DeLand, Florida, which was chosen in accordance with CERCLA, as amended by
SARA, and, to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This decision is based on the Administrative Record for this site.
DESCRIPTION OF THE REMEDY
The remedy selected in this ROD addresses contaminated sediment in Lake Miller. Based on the
administrative record, EPA has determined that no further action is necessary to address sediment
contamination in Lake Miller. However, the site Operation and Maintenance Plan shall be revised
to incorporate the following additional monitoring requirements to ensure that no unacceptable
exposures to risks posed by conditions at the site occur in the future:
• Semiannual sampling of Lake Miller sediment and surface water;
• Limited fish tissue sampling in Lake Miller and adjoining lakes.
DECLARATION STATEMENT
EPA has determined that no further remedial action is necessary at the site. The previous response
actions identified in the ROD for Operable Unit 1 eliminated the need to conduct additional remedial
action. Therefore, because ongoing long-term response actions do not require additional physical
construction, the site now qualifies for inclusion on the Construction Completion List. However,
because contamination remains at the site, EPA will conduct a review every five years in accordance
with Section 121 of CERCLA to ensure that all remedies for the site continue to provide adequate
protection of human health and the environment.
The Florida Department of Environmental Protection (FDEP) has provided input as the support
agency for the site in accordance with 40 CFR 300.430. Based upon comments received from FDEP,
concurrence by the State of Florida is expected, but a letter of concurrence has not yet been received.
c\f\
Richard D. Green, Acting Director Date
Waste Management Division
U.S. EPA Region 4
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RECORD OF DECISION
SHERWOOD MEDICAL COMPANY
OPERABLE UNIT 3
2. DECISION SUMMARY
1.0 Site Name, Location, and Description
The Sherwood Medical Company site is an active medical supply manufacturing facility located in
Volusia County, Florida approximately three miles northeast of downtown DeLand, Florida. Though
the facility was originally outside the city limits in an unincorporated area of Volusia County, the
Sherwood property was annexed by the City of DeLand in 1996.
The site occupies approximately 42 acres, including a section of Lake Miller along the western site
boundary (see Figure 1). International Speedway Boulevard (U.S. Highway 92) runs along the
northern boundary of the site while a wooded, swampy area lies to the south. A commercial and
residential area along Kepler Road is located directly east of the site. The Sherwood property is
currently occupied by several manufacturing buildings, a biological laboratory, sizeable parking areas,
plus additional structures, including an industrial wastewater treatment facility.
To generate water for plant operations, the Sherwood facility pumps approximately 175,000 gallons
of water per day from the underlying Floridan Aquifer. The water is used for industrial operations
such as cleaning, manufacturing, and cooling, and for some potable uses. An industrial wastewater
treatment facility was constructed in July 1983 to meet the Florida Drinking Water Standards. The
facility was permitted by the Florida Department of Environmental Regulation (FDER) to treat
wastewater from the plant and discharge it to the denitrification field and perimeter percolation pond.
In late 1985 Sherwood installed an air stripper to pretreat water used onsite in facility operations.
The air stripper removes contaminants in the water pumped from the Floridan Aquifer production
wells onsite. As a result of the annexation of the Sherwood property by the City of DeLand, treated
industrial wastewater is now discharged to the City's wastewater treatment facility.
2.0 Site History and Enforcement Activities
Sherwood Medical Industries, now known as Sherwood Davis & Geek, has used the property since
1959 for the manufacture of medical supplies, primarily hypodermic needles and syringes. Industrial
operations currently include grinding, hub processing, and cleaning of stainless steel and aluminum
parts used to manufacture hypodermic syringes. Sherwood also molds plastic syringes and conducts
in-house laboratory work.
2.1 Site History
Between 1971 and 1980, the company disposed of approximately two tons of liquid and sludge waste
into two unlined percolation ponds. During this time, solids were removed from the ponds and placed
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Figure 1. Sherwood Site Map
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into unlined impoundments on the site. From 1980 through 1982, Sherwood analyzed the contents
of the impoundments. Under the direction of FDER (predecessor to FDEP), Sherwood then disposed
of the wastes in an onsite landfill.
At the request of FDER, EPA proposed the Sherwood site for listing on the National Priorities List
(NPL) on December 20, 1982, with a Hazard Ranking System (MRS) score of 39.83, primarily
because of the threat of contamination from wastes stored in the holding ponds and impoundments.
The site's listing on the NPL was finalized on September 8, 1983.
FDER was designated as the lead agency for the site and remained in that capacity until November
1990, when both agencies agreed that EPA should assume the role of lead agency for completing
actions at the site. Though FDER initially believed that the removal of wastes from onsite storage
areas was sufficient to eliminate the threat of contamination, subsequent testing conducted by
Sherwood and FDER revealed significant groundwater contamination in onsite wells.
In October 1985, Sherwood Medical notified EPA that they would perform a focused Remedial
Investigation (RI) at the site. During EPA's negotiations with Sherwood to conduct the RI, FDER
and the Florida Department of Health and Rehabilitation Services received health related complaints
about private wells from nearby residents. Water samples were collected and analyzed in September
1986 from off-site private wells and Sherwood's onsite supply wells, but no violations of drinking
water standards were found in private well samples. However, additional samples collected in
October 1986 from onsite Floridan Aquifer wells confirmed onsite contamination of trichloroethylene
(TCE) and tetrachloroethylene (PCE) in the Floridan Aquifer. These compounds were historically
used by Sherwood for degreasing purposes. In light of this new information, it was agreed that a full
scale Remedial Investigation and Feasibility Study (RI/FS) would be conducted at the site. In
October 1987 Sherwood Medical entered into an Administrative Order on Consent (AOC) with EPA
Region 4 to perform the RI/FS.
In August 1987, at FDER's request, Sherwood sampled the onsite Floridan water wells and a down
gradient residential well to assess the extent of contamination and evaluate the need to implement
interim remedial measures (IRM) to control and treat the contamination of the Floridan Aquifer prior
to completion of the RI/FS. Based on the observed onsite Floridan Aquifer contamination, FDER
recommended that an IRM action be undertaken. In July 1988, Sherwood hired Roy F. Weston, Inc.,
as primary contractor for IRM and RI/FS activities. Sherwood developed an investigation plan to
evaluate the Floridan Aquifer and the shallower surficial aquifer through a thorough sampling
program. Field testing was completed in April of 1989.
As part of the IRM, Sherwood tested all of the private wells along Kepler Road semi-annually. The
wells are located immediately adjacent to the site and extend from the intersection of U.S. 92 and
Kepler Road through the intersection of Marsh and Kepler Roads. Sherwood also monitored another
private well, to the west of the site, just across Lake Miller. The investigation identified one private
well with volatile organic compound (VOC) concentrations above safe drinking water standards.
This well is located on Kepler Road, and the test results indicated PCE and TCE concentrations of
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11 ppb and 4 ppb, respectively. The applicable Florida Drinking Water Standard for both PCE and
TCE is 3 ppb. This well was plugged and a new well was installed.
In October 1989, Sherwood submitted a design workplan to FDER outlining further interim measures
to be conducted at the site including the installation of a pump and treat system to extract and treat
contaminated water from the surficial aquifer. In September 1990, FDER approved the design
workplan following the receipt of the Final IRM study report. In November 1990, FDER requested
that EPA assume the lead role for all actions at the site.
In December 1989, EPA and FDER approved the RI/FS Workplan. The initial field work for the RI
began in January 1990 and included the installation and sampling of additional Floridan aquifer
monitoring wells, drilling and sampling of soil borings, and sampling and analysis of surface water,
sediment, surface soil, and all existing wells. The draft RI was submitted to EPA in March 1991.
In January 1991, EPA issued a Proposed Plan for Interim Action to address surficial aquifer
contamination at the site. During the 30-day public comment period, EPA held a public meeting on
January 31, 1991, at Stetson University to discuss the Proposed Interim Action and to allow
concerned citizens to comment on EPA's preferred alternative and ask questions about the Sherwood
site. On March 27,1991, following the public comment period, EPA issued a Interim Action Record
of Decision (ROD) for the surficial aquifer. The goal of the interim action was to prevent the spread
of contaminated groundwater by treating the surficial aquifer early in the process before the RI/FS
was completed. The Interim Action ROD called for installation of recovery wells and an air stripper
for treatment of contaminated surficial groundwater and discharge of treated water to Lake Miller.
FDER concurred on the Interim Action ROD on April 2, 1991.
Between January 7 and April 17, 1991, additional IRM activities were conducted at the site. These
activities included the rehabilitation of two Floridan aquifer water supply wells SMFW and SMWS,
conversion of an out of service Floridan aquifer well SMFA 1 to a stainless steel monitoring well, and
installation of nine extraction wells in the surficial aquifer as part of the surficial groundwater
recovery system. In April 1991, Sherwood submitted the Remedial Design (RD) Work Plan and
Preliminary Design for the Surficial Aquifer Groundwater Remedial Action. Following EPA and
FDER review and comment, Sherwood submitted a Final Design Package for the IRM Remedial
Design/Remedial Action (RD/RA) in June 1991. However, in a subsequent meeting between FDER,
EPA, and Sherwood on June 20, 1991, Sherwood agreed to undertake a study of Lake Miller's water
quality to determine if Lake Miller was in compliance with applicable FDER Class JH Ambient Water
Quality Standards for metals, thereby making it suitable for treatment system discharge.
Surface water and sediment samples were collected at the site from July 1991 through November
1991 to further characterize the metals concentrations in Lake Miller in order to verify the lake's
compliance with applicable FDER Class HI Ambient Water Quality Standards. The November 1991
Lake Miller Water Quality Report concluded that, with the exception of cadmium, metals
concentrations in Lake Miller were in compliance with FDER Class IE Water Quality Standards.
Based on this report, Sherwood submitted a National Pollutant Discharge Elimination System
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(NPDES) application for the proposed discharge to Lake Miller. The data gathered for the Lake
Miller study was incorporated into the RI.
In February 1992, Sherwood resubmitted the Final Design Package along with the Remedial Action
Work Plan and the Operation and Maintenance Plan for the Interim Action treatment system.
Following EPA approval of these documents in March 1992, construction of the IRM system began
on May 5, 1992, and the system began operating on July 31, 1992.
On October 8, 1992, following publication of the final RI/FS in July 1992 and a 30-day public
comment period, EPA issued a second ROD (known as Operable Unit 1) specifying the final
groundwater remedy for the site. In addition to requiring the continued operation of the surficial
aquifer extraction and treatment system, the OU1 ROD called for a comprehensive groundwater
monitoring program, including periodic sampling of residential wells, and continued operation of the
Floridan Aquifer water supply well and associated treatment system.
Based on the RI results, EPA directed Sherwood to conduct further studies on the potential
ecological effects of chromium contamination in Lake Miller sediment. The results were published
in a December 1993 draft report entitled "Evaluation of Effects of Chromium in Sediments, Lake
Miller, FL, Sherwood Medical Company." This report generally confirmed the findings of the RI
with respect to sediment contamination in the lake. After extensive discussions concerning the need
for and scope of additional sediment studies, EPA and Sherwood conducted independent
investigations in June and July of 1994. The results of EPA's sampling effort were summarized by
EPA's contractor, ManTech Environmental Technology, Inc., in a draft report dated July 1994.
Sherwood's findings were published in a May 1995 draft report entitled "Evaluation of Impacts to
Biota from Chromium Sediments in Lake Miller, Florida," by O'Brien & Gere Engineers, Inc.
2.2 Enforcement Activities
Following issuance of the Interim Action ROD and four months of settlement negotiations, a Consent
Decree (CD) between EPA and Sherwood Medical was lodged by the Department of Justice (DOJ)
on October 24, 1991, with the United States District Court for the Middle District of Florida,
Orlando Division. The CD required Sherwood to perform the Remedial Design and Remedial Action
(RD/RA) of the remedy outlined in the March 1991 ROD. Notice of the proposed settlement was
published in the Federal Register on November 14,1991, initiating a 30-day public comment period.
The District Court entered the CD on February 3, 1992.
Upon signature of the final ROD dated October 8,1992, EPA and Sherwood negotiated the terms
of an Amendment to the Consent Decree to incorporate additional requirements of the new ROD.
The Amended CD was lodged by DOJ on October 4, 1993. Following notice of the proposed
settlement in the Federal Register on October 26, 1993, and a 30-day public comment period, the
District Court entered the Amended CD on December 10,1993.
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3.0 Highlights of Community Participation
In accordance with Sections 113 and 117 of CERCLA, as amended, EPA has conducted community
involvement activities at the Sherwood site to solicit community input and to ensure that the public
remains informed about site activities. EPA's Proposed Plan Fact Sheet for OU3 was mailed to the
public on June 19,1997, and a copy of the Administrative Record for OU3 was made available in the
information repository at the DeLand Public Library. Public notices were published in The Volusian
on June 21, 1997 and the Daytona News-Journal on July 6, 1997 advising the public of the
availability of the administrative record and the date of the upcoming public meeting. EPA held a
public meeting on July 8,1997 to answer questions and receive comments on the Agency's preferred
alternative for addressing Lake Miller sediment contamination. In addition, a public comment period
was held from June 23, 1997 to July 23, 1997. EPA's response to any significant oral or written
comments received during this period is included in the Responsiveness Summary in Section 3 of this
ROD.
4.0 Scope and Role of Operable Unit
Because of the variety and complexity of problems at the Sherwood site, EPA determined that the
remedial actions needed to resolve these problems could best be addressed in discrete phases known
as operable units. The interim action outlined in EPA's March 27, 1991, ROD addressing
contamination in the surficial aquifer is known as Operable Unit 2 (OU2) in the site management
strategy. The OU2 remedy called for pumping and treating contaminated groundwater from the
surficial aquifer to reduce the potential for contaminant migration downward into the Floridan
aquifer, which is the primary source of drinking water in the DeLand area.
The final groundwater and soil remedial action, known as Operable Unit 1 (OU1), is documented in
EPA's October 8,1992 ROD. The OU1 ROD specified the following elements: continued operation
of the surficial aquifer pump and treat system and the Floridan Aquifer water supply well and
treatment system; groundwater monitoring, including offsite residential wells; and excavation and
disposal of chromium-contaminated soil whenever existing site features are removed. Deed
restrictions and other institutional controls were also required to restrict the property to industrial use
and prevent access to contaminated areas and Lake Miller.
Based on the results of surface water and sediment sampling in Lake Miller during the design of the
interim remedial measures, EPA identified the need for a third operable unit (OU3) to evaluate and
address sediment contamination in Lake Miller. This ROD presents EPA's selected remedy for
addressing Lake Miller sediment.
5.0 Summary of Site Characteristics
5.1 Environmental Setting
The Sherwood site is situated in a low topographic area 40 to 60 feet above mean sea level (MSL).
The foliage typical of the site is best described as floodplain with fiatland soil and is a combination
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of deciduous and coniferous trees with intermittent grazing lands and wetlands. Due to the large
number of freshwater lakes (e.g., Lake Miller, Cypress Lake, North and South Lake Talrnadge) and
low topography, much of the area is best described as swamp.
The land surrounding the Sherwood site is primarily residential, with some commercial properties.
Residential areas are divided into 6-acre lots. According to real estate maps, 95% of the individual
parcels of land (419 out of 440) within a 0.5 mile target area are north or east of the site. Most of
the residential areas are sparsely populated, and their growth is restricted by zoning codes. There are
about 800 private residences with approximately 2,500 people located within one mile of the site.
Forested areas and swamps occupy approximately 200 acres of land to the south of the site. Most
of this land is owned in large tracts. The area to the east of the site is almost entirely residential. Next
to the site on Kepler Road is an 80 acre residential area with 15 homes. Approximately 1,000 feet
to the east of the Sherwood site lies a residential area occupying one to two square miles known as
Daytona Park Estates. North of U.S. 92, the northern border for the Sherwood site, lies a 150 acre,
moderately populated development, DeLand Highlands. This area has shown the greatest recent
growth, and the size of the housing lots are the smallest in the area. Beyond DeLand Highlands the
area is characterized as rural. Southwest of the site is mostly wooded swamp. Northwest of the site
are large tracts of land owned by the DeLand Municipal Airport, the Municipal Waterworks and the
Florida Military School.
The land near the Sherwood site supports recreational activities including fishing, hunting, boating,
and swimming. Lakes generally used for fishing in the area include Cypress, Daytona, and Talmadge.
Because of the relatively large tracts of undeveloped land, hunting occurs in the area.
The predominant natural feature of the Sherwood site is Lake Miller, a 12-acre swamp lake. Lake
Miller is partially on the Sherwood site, located along the western boundary of the site. It receives
inflow from North Lake Talmadge south of the site via a narrow canal, base flow from the surficial
aquifer, and site run-off. Lake Miller is the primary area of concern for potential ecological damage
from the site and is a Florida Class IE water body designated for wildlife and recreational purposes.
5.2 Lake Investigation Summary
During the RI, sediment sampling episodes were first conducted in April and August 1990. A total
of 18 sediment samples were collected within, upstream, and downstream of Lake Miller and in on-
site drainage ditches and basins. At the request of EPA and FDER, an additional 19 sediment
samples were taken in November 1991 in Lake Miller and upstream in North Lake Talmadge to
further define the extent of metals concentrations in the sediment of these water bodies.
The RI concluded that the highest levels of site-related compounds (TCE, PCE, and chromium) were
found in the sediment along the eastern bank of Lake Miller. This area received aqueous wastes
containing spent solvents from floor drains in buildings B and F, which led into former drain fields
along the bank of Lake Miller. In addition, this contamination may have resulted from the discharge
of groundwater from the surficial aquifer into Lake Miller. Chromium concentrations in sediment
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ranged as high as 922 mg/kg. Based on sampling results for surface soil, the chromium detected in
Lake Miller sediment was assumed to be the less toxic and less mobile trivalent chromium. The
chlorinated solvents trichloroethene (TCE) and tetrachoroethene (PCE) were detected at maximum
concentrations of 8.8 mg/kg and 30 mg/kg, respectively.
Based on the results of the RJ, EPA directed Sherwood to conduct further study on the potential
ecological effects of chromium contamination in Lake Miller sediment. The results were published
in a December 1993 draft report entitled "Evaluation of Effects of Chromium in Sediments, Lake
Miller, FL." Analytical results from 10 sediment sampling locations in and around Lake Miller and
2 from an upstream reference lake (South Lake Talmadge) generally confirmed the RI findings.
Chromium was detected in 9 of 13 samples, up to a maximum concentration of 1150 mg/kg in Lake
Miller. An additional 13 sediment samples were collected from Lake Miller to evaluate the oxidation
state of chromium in the sediment. The results confirmed that hexavalent chromium was not present
in the sediment. In addition, toxicity tests of a small crustacean (Hyalella aztecd) were unsuccessful.
After extensive discussions concerning the need for and scope of additional sediment studies, EPA
and Sherwood conducted independent investigations in June and July of 1994. In June 1994, EPA's
ESAT Biological Assessment Team collected 13 sediment samples (12 stations, plus a duplicate at
Station 7) from Lake Miller and two upstream background reference lakes, South Lake Talmadge
and Blue Lake. The approximate sampling locations are shown in Figure 2. Sediment samples were
analyzed for Target Analyte List (TAL) metals and Target Compound List (TCL) organic
compounds. Analyses for purgeable organics, extractable organics, and pesticides revealed no organic
contamination with the exception of a spike of DCE (2.4 mg/kg) and TCE (0.24 mg/kg) in one
location (Station 1) at the eastern end of the lake near the Sherwood facility. For metals, chromium
levels were substantially lower than previous sampling events, with a maximum concentration of 60
mg/kg at Station 4 near the southeastern edge of the lake. Sampling results for metals are shown in
Table 1.
In addition to the chemical analyses described above, 5 samples from Lake Miller and the two
reference lake samples were subjected to various toxicity tests to assess sediment and sediment pore
water toxicity. Toxicity tests of the Hyalella azteca were again unsuccessful due to the low survival
rate of the control organisms. Whole sediment toxicity tests of water fleas (Ceriodaphnia dubia)
revealed no toxicity related to any constituents found in the sediment. The Microtox test indicated
sediment pore water toxicity in only one location, Station 1. This result is probably due to elevated
levels of TCE and DCE, since the bacteria used in the Microtox test is known to be sensitive to TCE.
The lettuce seed (Lactuca sativd) root elongation tests of a sediment pore water sample from Station
9 near the western end of the lake indicated some toxicity, probably due to a marginally toxic level
of cadmium in the sediment. However, no toxicity related to chromium contamination was observed.
During June and July 1994, Sherwood's consultant, O'Brien & Gere Engineers, Inc.(O&G), also
performed a number of tests to evaluate the biological impact of chromium in the sediment of Lake
Miller. Among other things, the effort included a Lake Miller chromium stratification study and biota
sampling in Lake Miller and the two reference lakes, South Lake Talmadge and Blue Lake. It should
be noted that before the study was conducted, EPA and Sherwood did not agree on the scope of the
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K>
I
VO
Lake Miller
Sample Locations
( North Lake A
V T«bnado« }
N
Figure 2. A map showing the locations of the sampling stations on Lake Miller and the
background lakes, Deland, Florida.
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Table 1. Levels of metals in sediment of Lake Miller and from background lakes in the vicinity of Sherwood Medical, Deland, Florida, June 1994.
MeUls
mj/kg
Alumimnum
Antimony
Arsenic
Barium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc
• Estimated Va
* - Toxicity tests
Sampling Stations
01*
1200
0.84U
1.7U
7.7
0.84U
510
3.5J
0.84U
20U
430
8.7
120
2.0
0.2IU
4.2U
120
220U
0.97
21.0
02*
300
0.61U
I.2U
2.5
0.6IU
240
I.SU
0.61 U
5.0U
230
1.3
50
1.4
0.15U
3.IU
70U
140U
0.6 IU
11.0
ue.U- Undetected. N
were performed on th
03
3900
1.3U
2.6U
18
I.3U
1100
7.6
1.3U
20.0U
1800
3.6
450
9.1
0.32U
6.4U
130U
260U
1.5
30.0
04*
5900
0.7U
3.0U
11.0
0.7U
540
60
0.7U
20.0U
320
30.0
140
2.0
O.I7U
3.5U
180
I80U
5.7
18
05*
570
0.6U
1.2U
3.5
0.6U
340
1.5U
0.6U
5.0U
160
2.8J
71
1.2
0.15U
3.0U
70U
IIOU
0.6U
10.0
06
2200
0.59U
1.2U
4.1
0.59
810
3.5
0.59U
5.0U
200
2.4
120
1.6
O.I5U
2.9U
70
IIOU
0.7
9.7
07
900
0.7U
I.4U
3.6
0.7U
380
I.SU
0.7U
5.0U
240
2.0
110
1.5
O.I8U
3.5U
SOU
I30U
0.7U
12.0
07
Duplicate
950
0.64U
2.0U
2.8
0.64U
250
1.6
0.64
5.0U
160
1.2
75
1.0
0.16U
3.2U
70U
I30U
0.64U
10.0
08
4800
0.55U
1.IU
8.9
0.55U
190
8.1
O.S5U
10.0U
260
6.3
82
1.0
O.I4U
2.9
100
IIOU
2.9
10.0
09*
5100
I.2U
5.0U
19.0
1.2
MOO
8.1
I.2U
20U
1900
5.5
400
8.0
0.3IU
8.4
I30U
290U
1.7
26.0
10
1500
0.9U
1.8U
7.2
0.9U
27000
2.9J
0.9U
IO.OU
530
7.7
300
6.7
0.22U
5.6
170
300U
1.8
5.3
ir
450
0.5U
I.OU
3.7
O.SU
200
I.2U
O.SU
4.0U
70
1-7
38.0
1-4
0.12U
2.5U
SO
SOU
O.SU
9.1
12*
1000
O.SU
I.OU
8.5
O.SU
350
I.7J
O.SU
4.0U
120
2.6
65
4.3
O.I2U
2.5U
SOU
80U
0.79
8.0
A - Not Analyzed
is sediment sample.
I
M
O
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studies to be performed. In addition, EPA and FDEP provided comments to Sherwood citing serious
disagreement with some of the analysis and conclusions drawn in the draft report prepared by O&G.
However, much of the data generated for the study is valuable and is discussed below.
To evaluate the stratification of chromium in Lake Miller sediment, O&G collected three sediment
core samples from each of three locations, producing a single composite sample per location for the
following depth ranges: 0-5,5-10,10-20,20-30, and >30 cm. Chromium concentrations generally
decreased with increasing sediment depth, with the highest observed chromium concentration of 50.7
mg/kg occurring in the 0-5 cm horizon from Station 1, located in the southeast quadrant of the lake
adjacent to the Sherwood site. This result was consistent with EPA's findings noted above.
O&G also performed extensive sampling and analysis of biota living in Lake Miller and the two
reference lakes. The organisms collected for chromium analysis included two aquatic vegetative
species, arrow arum and smartweed, and five fish species, bluegill, golden shiner, seminole killifish,
carp, and largemouth bass. The analysis of smartweed root tissue suggested the potential for uptake
of chromium. Chromium was detected in all 8 smartweed samples in areas of historically high
chromium levels in sediment, with concentrations ranging from 1.6 to 3.6 mg/kg, whereas smartweed
root tissue concentrations in lesser contaminated areas of Lake Miller and the reference lakes were
low or non-detect. Detection of chromium in arrow arum root tissue samples was limited, indicating
no statistically significant difference in concentrations between Lake Miller and the reference lakes.
Twenty-seven fish from Lake Miller and 25 fish from South Lake Talmadge and Blue Lake were
analyzed for chromium. In Lake Miller, chromium concentrations in fish tissue ranged from non-
detect to 2.3 mg/kg. Fish tissue samples from the reference lakes ranged from non-detect to 1.3
mg/kg. A statistical analysis of the data concluded that there was no significant difference between
chromium concentrations in fish from Lake Miller and the reference lakes.
6.0 Summary of Site Risks
A Baseline Risk Assessment (BRA) was conducted during the RI to determine whether contamination
at the Sherwood site, if not addressed by any remedial action, could pose a current or future threat
to human health or the environment. This evaluation serves as a baseline for determining whether any
cleanup actions are necessary. The BRA evaluated human health and ecological risks associated with
contamination in soil, groundwater, surface water, and sediment. Based on the conclusions of the
BRA, EPA determined that remedial actions were necessary to address the potential risks associated
with soil and groundwater contamination at the site. These actions are documented in the final ROD
for OU1. In addition, the following institutional and access controls were included in the OU1 ROD
to address the potential risks to off-site residents and Sherwood workers associated with eating fish
from or swimming in Lake Miller.
• posting of 10 signboards around Lake Miller with the inscription tcNO
FISHING OR SWIMMING IN LAKE MILLER"
• notification of the adjacent property owner on Lake Miller that the lake
should not be used for fishing or swimming purposes
2-11
-------
• maintenance of the current security fence around the site property and
enforcement of the current Sherwood policy restricting employee access to
Lake Miller
• deed restrictions to ensure the Sherwood property remains industrially zoned
• monitoring of the surficial and Floridan aquifers and Lake Miller.
The risks related to soil, groundwater, and surface water are being addressed by implementation of
the OU1 remedy pursuant to the CD entered into by Sherwood and EPA. Therefore, the following
risk summary focuses on the potential human health and ecological risks attributed to sediment
contamination in Lake Miller. Although several sediment sampling investigations were conducted
following the RI, the risk assessment relied upon data collected during the RI.
6.1 Contaminants of Concern
hi identifying contaminants of concern, the risk assessment included all organic chemicals confirmed
to be present in sediment samples from the site. However, since inorganic compounds such as metals
occur naturally in the environment, only those inorganic compounds which exceeded background
concentrations were selected as chemicals of concern. The contaminants of concern for sediment at
the Sherwood site and their associated range of concentrations from the RI are shown in Table 2.
Although all of the compounds presented in Table 2 were included in evaluating human health risks,
EPA considered the following additional factors when determining whether a remedial action was
necessary: the frequency of detection of the compound; the toxicity of the compound; and whether
the compound has been linked to facility operations.
6.2 Exposure Assessment
In the exposure assessment, EPA considered ways in which people could come into contact with
Lake Miller sediment under both current and future conditions. The BRA evaluated the risk to a
swimmer as a potential future scenario using the same exposure assumptions applied to a resident
swimmer in a backyard pool (see Table 3). The swimmer is assumed to be a child aged 10 to 18 years
who would come into contact with surface water and sediment for 78 days per year (3 times per week
for 6 months). The exposure routes evaluated included ingestion and dermal contact with Lake Miller
surface water and sediment. These assumptions are conservative, since the following factors make
swimming in Lake Miller fairly unlikely: access to the lake is limited by its location, partial ownership
by Sherwood and only one other private owner, and the presence of thick vegetation up to the
water's edge; alligators have been observed in the lake, which may deter prospective swimmers; and
other area lakes are more attractive and accessible for swimming.
6.3 Toxicity Assessment
The toxicity assessment evaluated possible harmful effects of exposure to contaminants of concern
and assigned toxicity values to each contaminant based on the scientific literature. Some of the
compounds found at the site have the potential to cause cancer (carcinogenic). Other contaminants
of concern may cause other problems not related to cancer.
2-12
-------
Table 2
Sediment — Lake Miller
Chemicals of Concern
Data Summary
Chemical
Frequency
of
Detection
Range of
Sample
Quantitation
Limits
(mg/kg)
Organic
Acetone
Benzene Acid
Bis(2-ethylhexyi)
phthalate
2-Butanone
Chloromethane
4,4'-DDT
Ll-Dichloroethane
1,1-Dichloroethene
12-Dichloroethene
(total)
Ethylbenzene
Metbylene Chloride
4-Methylphenol
Tetrachloroethene
Toluene
Trichloroethene
Vinyl Chloride
Xylenes (total)
6/6
2/6
2/6
3/6
1/6
1/6
1/6
2/6
4/6
2/6
5/6
1/6
3/6
5/6
4/6
2/6
5/6
NAV
1.6
0.059-13
0.020-0.19
0.02-0.12
0.038-0.041
0.013-0.06
0.01-0.093
0.064.093
0.015-0.020
0.015
0.29-18.0
0.01-0.093
0.093
0.06-0.093
0.02-0.19
0.093
Range of
Concentrations
(mg/kg)
Mean
Concentration
(mg/kg)
Upper 95%
Confidence
Limit of
the Mean
(mg/kg)
0.13-9.5
1.6-1.9J
1.6J-1LJ
0.047-0.17
0.14J
0.038J
0.019J
0.01J-0.02
0.078-0.46
0.013J-0.041J
0.021-022
029J
83-30.0
0.007J-0.11
0.002J-8.8
0.036-0.051
0.007J-0.0074
23
1.6
22
0.072
0.043
0.035
0.019
0.020
020
0.014
0.092
i.7"
8.6
0.049
2.7
0.045
0.037
52
1.7
53
0.12
0.081
0.041"
0.032"
0.032"
034
0.024
0.16
4.4"
17.4
0.082
53
0.068"
0.061"
Inoiganis
Aluminum
Arsenic
Padmiiim
Calcium
20/20
16/20
15/20
19/20
NAV
0.58-6.8
0.44-4.5
2390
1330-14,100
0.75-5.4
0.53-2.7
500-39,870
9290
2.9
036
13,100
10,800
33
1.6
16300
2-13
-------
Table 2
Sediment - Lake Miller
Chemicals of Concern
Data Summary
(continued)
Chemical
Chromium
Copper
Iron
Lead
Magnesium
Nickel
Potassium
Sodium
Vanadium
Zinc
Frequency
of
Detection
20/20
16/20
20/20
20/20
19/20
14/20
17/20
19/20
15/20
20/20
Range of
Sample
Quantitation
Limits
(mg/kg)
NAV
1.7-22.5
NAV
NAV
2390
1.7-343
60-2390
2390
0.87-23.9
NAV
Range of
Concentrations
(mg/kg)
4.9-922
102-132
222-9,870
2.7-228
85.8-1,400
53-25.8
144-917
21.1-869
17-20.0
22-300
Mean
Concentration
(mg/kg)
237
44.0
6,070
823
1000
13.1
516
505
12.5
143
Upper 95%
Confidence
Limit of
the Mean
(mg/kg)
332
57.1
7210
102
1,170
15.6
620
606
.14.8
177
J <* Estimated value.
NAV «= Sample quantitation Emits or method detection limits were not available.
2-14
-------
Table 3
Exposure Assumptions
Exposure Factor
Abbreviation
Value
General exposure factors
Exposure Time
Exposure Frequency
Exposure Duration
Averaging Time
Body Weight (child)
ET
EF
ED
AT
BW
2.6 hours/event
78 events/year
9 years
3,285 days
50kg
Surface water (ingestion)
Ingestion Rate
IR
0.05 liters/hour
Surface water (dermal contact)
Surface Area (entire body)
SA
14,900 cm2/day
Sediment (ingestion)
Ingestion rate (sediment)
IR
100 mg/day
Sediment (dermal contact)
Surface Area (hands and feet)
SA
1,970 cm2
Surface Water Ingestion:
CWxIRxETxEFxED
Dose=-
BWxAT
Sediment Ingestion:
CSDxIRxCFxEFxED
Dose=-
BWxAT
where CW - Surface Water Concentration
where CSD = Sediment Concentration
Surface Water Dermal Contact:
CWxCFxSAxPCxETxEFxED
BWxAT
Dose=
where CF = Conversion factor
PC = Dermal permeability constant
Sediment Dermal Contact:
Dose-
CSDxCFxSAxAFxABSxEFxED
BWxAT
•where CF = Conversion factor (10* kg/mg)
AF = Sediment/skin adherence factor
ABS = Absorption factor
2-15
-------
Slope factors (SFs) have been developed by EPA's Carcinogenic Assessment Group for estimating
excess lifetime cancer risks associated with exposure to potentially carcinogenic contaminants 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.
Reference doses (RFD's) have been developed by EPA for indicating the potential for adverse health
effects from exposure to contanrinant(s) of concern exhibiting noncarcinogenic effects. RfDs, which
are expressed in units of mg/kg-day, are estimates of lifetime daily exposure levels for humans,
including sensitive individuals. Estimated intakes of contaminants of concern ingested from
contaminated sediment can be compared to the RiD.
Both RfDs and cancer SFs 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
(to account for the use of animal data to predict effects on humans). Cancer SFs and chronic RfDs
for contaminants of concern are shown in Table 4. It should be noted that dermal SFs and RfDs must
be derived from oral route values for each applicable chemical, in accordance with EPA guidance.
6.4 Risk Characterization
The risk characterization combines the other components of the evaluation to estimate the risk from
exposure to site contamination. For cancer-causing compounds, risk is a probability expressed in
scientific notation. For example, an excess lifetime cancer risk of IxlO"6 means that an individual has
an additional 1 in 1,000,000 chance of developing cancer as a result of site-related exposure over an
estimated 70 year lifetime. EPA has established a target risk range for Superfund cleanup actions of
between 1x10"* (1 in 10,000) and IxlO"6. Cancer risk is calculated from the following equation:
Risk = GDI x SF
where:
risk = a unitless probability (e.g., 2x10"5) of an individual developing cancer;
CDI = chronic daily intake averaged over 70 years (mg/kg-day)
SF = slope factor, expressed as (mg/kg-day)"1
The overall excess cancer risk to a swimmer in Lake Miller is 1.21xlO"5, or just over 1 in 100,000.
Although this risk level falls within EPA's target risk range, it exceeds the IxlO"6 point of departure
cited in the National Contingency Plan (NCP) as a basis for Superfund action. It should be noted
that sediment contamination contributes only 6 percent of the risk to the swimmer (refer to Table 5).
The remainder of the cancer risk relates primarily to the presence of vinyl chloride, arsenic, DCE,
TCE, and PCE, in surface water. The presence of these compounds in Lake Miller surface water is
thought to result from the historical discharge of contaminated groundwater from the surficial aquifer
2-16
-------
Table 4
Critical Toxicity Values
Compound
Acetone
Benzoic Acid
Bis(2-ethylhexyl) phthalatc
2-Butanone
Cbloromethane
4,4'-DDT
1 , 1 -Dichloroethane
1,1-Dichlorocthene
Ethylbenzene
Methylene Chloride
4-Methylphenol
Tetrachloroethene
Toluene
Trichloroethene
Vinyl Chloride
Xylene
Aluminum
Arsenic
OralSF
(mg/kg-day)-1
NA
NA
1.4E-02
NA
NA
3.4E-01
NTV
6.0E-01
NA
7.5E-03
NTV
5.1E-02
NA
1.1E-02
1.9E+00
NA
NA
1.8E+00
Reference
~
—
IRIS, 1992
--
--
IRIS, 1992
~
IRIS, 1992
--
IRIS, 1992
—
HEAST
—
HEAST
HEAST
~
--
IRIS, 1992
Dermal SF
(mg/kg-day)-1
NA
NA
2.8E-02
NA
NA
6.8E-01
NTV
6.7E-01
NA
8.3E-03
NTV
5.7E-02
NA
1.2E-02
2.1E+00
NA
NA
3.6E+01
OralRfD
(mg/kg-day)
l.OE-01
4.0E+00
2.0E-02
5.0E-02
2.3E-01
5.0E-04
l.OE-01
9.0E-03
l.OE-01
6.0E-02
5.0E-02
l.OE-02
2.0E-01
7.4E-03
1.3E-03
2.0E+00
1.9E-02
3.0E-04
Reference
IRIS, 1992
IRIS, 1992
IRIS, 1992
HEAST
Derived
IRIS, 1992
IRIS, 1992
IRIS, 1992
IRIS, 1992
IRIS, 1992
IRIS, 1992
IRIS, 1992
IRIS, 1992
HEAST
Derived
IRIS, 1992
Derived
IRIS, 1992
Dermal RfD
(mg/kg-day)
9.0E-02
2.0E+00
l.OE-02
4.5E-02
2.1E-01
2.5E-04
9.0E-02
8.1E-03
9.0E-02
5.4E-02
2.5E-02
9.0E-03
1.8E-01
6.7E-03
1.2E-03
1.8E+00
9.5E-04
1.5E-05
2-17
-------
Table 4
Critical Toxicity Values
Compound
Cadmium
Calcium
Chromium (III)
Copper
Iron
Lead
Magnesium
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc
OralSF
(mg/kg-day)'1
NA
NA
NA
NA
NA
NTV
NA
NA
NA
NA
NA
NA
NA
Reference
—
—
~
—
—
~
«
—
—
—
—
~
—
Dermal SF
(mg/kg-day)'1
NA
NA
NA
NA
NA
NTV
NA
NA
NA
NA
NA
NA
NA
OralRfD
(mg/kg-day)
5.0E-04 (water)
l.OE-03 (sediment)
1.1E+01
l.OE+00
3.7E-02
2.6E-01
9.4E-04
5.7E+00
3.0E-04
2.0E-02
8.0E+00
4.7E+01
7.0E-03
2.0E-01
Reference
IRIS, 1992
Derived
HEAST
HEAST
Derived
Derived
Derived
HEAST
IRIS, 1992
Derived
Derived
HEAST
HEAST
Dermal RfD
(mg/kg-day)
5.0E-05
5.5E-01
5.0E-02
1.9E-03
1.3E-02
7.0E-06
2.9E-01
NC
l.OE-03
4.0E-01
2.4E+00
3.5E-04
l.OE-02
NA Not applicable. Chemical is not categorized as a carcinogen through this exposure route.
NC Chemical is not of concern through this exposure route.
NTV No toxicity value was available.
IRIS, 1992: Integrated Risk Information System computer database, 1992.
HEAST: Health Effects Assessment Summary Tables, EPA, 1991.
2-18
-------
Table 5
C A R C I NOQI N I C R I SK • SW I NNI R IN LAKE MILLER
ROUTE Of EXPOSURE
CHEMICAL
DERMAL CONTACT INGEST ION DERMAL CONTACT INGESTION
WITH OF WITH OF
SURFACE WATER tURFACE WATER SEDIMENT SEDIMENT
ORGANICS
•IStt-ETRVLHEttYDPHTKALATf
CHLOROMETHANE
4,4'-DDT
1,1-DICHLORETNANE
1.1-DICNLOROETHENE
METNYLENE CHLORIDE
4-METHYLPHENOl
TETRACHLOROETHEME
TRICHLOROETHENE
VINTL CHLORIDE
INORGANICS
ARSENIC
LEAD
TOTAL RISK
PATHWAY RISK
PERCENT TOTAL RISK
4.24E-07
NC
NC
NC
.39E-07
.60E-09
NC
.55E-07
.39E-07
.97E-06
NC
NC
8.23E-06
68.2531
7.30E-09
NC
NC
NC
1.69E-07
1.50E-09
NC
1.40E-08
S.58E-08
2.26E-06
6.04E-07
NTV
3.11E-06
25.7966
1.21E-08
X8.92E-11
4.06E-10
NTV
1.05E-09
1.03E-10
NTV
7.80E-08
5.03E-09
8.41E-09
2.00E-07
NTV
3.0SE-07
2.5281
4.22E-09
5.80E-11
7.10E-10
NTV
6.59E-10
6.52E-11
NTV
4.89E-08
3.23E-09
5.32E-09
3.49E-07
NTV
4.12E-07
3.4221
NC • Chewletl It not of concern through thlt •upotur* rout*.
NTV • No toxfclty value MM available.
TOTAL RISK
ALL PERCENT
ROUTES OF
RISK
4.47E-07
1.47E-10
1.12E-09
NTV
1.11E-06
5.26E-09
NTV
3.96E-07
7.04E-07
8.24E-06
1.15E-06
NTV
3.7121
0.0012
0.0093
NTV
9.2137
0.0436
NTV
S.2847
5.8369
68.3301
9.5683
NTV
1.21E-05
2-19
-------
into Lake Miller prior to implementation of the interim groundwater remedy. However, EPA believes
that the groundwater pump and treat system and the swimming and fishing restrictions and other
institutional controls specified in the OU1 ROD have adequately addressed this potential risk.
For compounds which cause toxic effects other than cancer, EPA compares the concentration of a
contaminant found at the site with a reference dose representing the maximum amount of a chemical
a person could be exposed to without experiencing harmful effects. The ratio of the actual
concentration to the reference dose for a particular compound is the hazard quotient (HQ). The HQ
is calculated as follows:
HQ = CDI/RfD
where:
CDI = 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).
The sum of the hazard quotients of all the contaminants of concern for each contaminated media (i.e.
sediment and surface water) is known as the hazard index (HI). EPA considers an HI of 1.0 to be
the maximum acceptable hazard. For the swimmer scenario, the HI was 0.7, which is below EPA's
threshold for non-cancer risks (see Table 6).
6.5 Ecological Risk Assessment
As part of the BRA, an Ecological Risk Assessment (ERA) was conducted to evaluate the potential
ecological risks posed by sediment and surface water contamination in Lake Miller. Like the human
health evaluation, the ecological assessment involves selecting chemicals of concern, identifying
ecological receptors and pathways, estimating exposure point concentrations, identifying toxicity
data, and characterizing ecological risk.
The ERA identified six chemicals in surface water which exceeded critical toxicity values: aluminum,
cadmium, copper, lead, mercury, and zinc. However, none of these compounds were determined to
relate to Sherwood site operations, and copper, mercury, and nickel were detected in only 1 of 14
surface water samples.
In Lake Miller sediment, four compounds exceeded biological effect levels: 4,4-DDT, chromium,
lead, and zinc. Of these compounds, 4,4-DDT was detected in only one of six sediment samples, and
only chromium is known to be site-related. The most recent sediment sampling data, however,
indicate that chromium levels in Lake Miller sediment fall below the National Oceanic and
Atmospheric Administration's (NOAA's) Effects Range-Low (ER-L) screening value of 81 mg/kg.
2-20
-------
Table 6
HAZARD INDEX • I U I N N G It III LAKE MILLER
ROUTE OF EXPOSURE
CHEMICAL
DERMAL CONTACT INCEST IOH DERMAL CONTACT INGEST ION
WITH OF WITH OF
SURFACE WATER SURFACE WATER SEDIMENT SEDIMENT
ORGANICS
ACETONE
BENZOIC ACID
BIS(2-ETNYIHEXVL)PHTHALATE
2-BUTANONE
CHLOROKETHANE
4.4'-DDT
1,1-DICHLORETHANE
1,1-0(CHIOSOETHENE
1,2-OICHIOROETHEN£(TOTAD
ETHVLBENZENE
METHYLENE CHLORIDE
4-METHYLPHENOL
TETRACHLOROETHENE
TOLUENE
TRICHLOROETHENE
VINYL CHLORIDE
XVLENES(TOTAL)
INORGANICS
ALUMINUM
ARSENIC
BARIUM
CADMIUM
CALCIUM
CHROMIUM
COPPER
IRON
LEAD
MAGNESIUM
MERCURY
NICKEL
POTASSIUM
SODIUM
VANADIUM
ZINC
HAZARD INDEX
PATHWAY INDEX
PERCENT OF INDEX
8.05E-06
NC
1.1BE-02
NC
NC
NC
NC
1.35E-03
4.85E-02
NC
6.24E-05
NC
3.87E-03
1.30E-04
6.19E-02
1.84E-02
5.94E-06
NC
NC
NC
NC
NC
NC
NC
W^
NC
NC
NC
NC
NC
HC
NC
NC
1.46E-01
21.2244
4.44E-05
NC
2.03E-04
NC
NC
NC
NC
2.44E-04
6.22E-03
NC
2.58E-05
NC
2.14E-04
7.751-06
S.33E-03
7.11E-03
2.7BE-07
1.15E-02
8.70E-03
5.79E-04
9.57E-04
NC
2.28E-05
4.44E-04
1.53E-03
4.B6E-03
NC
2.52E-04
3.63E-04
NC
NC
1.97E-03
1.80E-04
5.08E-02
7.3857
3.51E-05
5.30E-07
3.35E-04
1.60E-06
2.36E-07
1.86E-OS
1.29E-07
1.51E-06
2.31E-05
1.63E-07
1.79E-06
7.08E-06
1.18E-03
2.76E-07
4.87E-04
2.59E-05
2.51E-09
1.39E-01
2.87E-03
NC
3.82E-04
3.62E-04
8.11E-05
3.67E-04
6.77E-03
2.66E-02
4.91E-05
NC
1.91E-04
1.89E-05
3.08E-06
5.18E-04
2.16E-04
1.79E-01
26.0847
2.216-05
1.B5E-07
1.17E-04
1. 016-06
1.51E-07
3.25E-05
8.12E-08
9.50E-07
1.45E-05
1.03E-07
1.13E-06
2.48E-06
7.45E-04
1.74E-07
3.09E-04
1.68E-05
1.58E-09
2.43E-01
5.03E-03
NC
6.70E-04
6.34E-04
1.42E-04
6.60E-04
1.18E-02
4.65E-02
B.74E-05
NC
3.34E-04
3.31E-05
5.S1E-06
9.06E-04
3.79E-04
3.12E-01
45.3052
ALL
ROUTES
1.10E-04
7.15E-07
1.24E-02
2.61E-06
3.B7E-07
5.10E-05
2.10E-07
1.S9E-03
S.47E-02
2.66E-07
9.12E-OS
9.56E-06
6.01E-03
1.39E-04
6.BOE-02
2.56E-02
6.22E-06
3.93E-01
1.66E-02
5.79E-04
2.0IE-03
9.97E-04
2.46E-04
1.47E-03
2.01E-02
7.80E-02
1.36E-04
2.52E-04
8.88E-04
S.20E-OS
8.59E-06
3.39E-03
7.75E-04
PERCENT
OF
INDEX
0.0160
0.0001
1.8076
0.0004
0.0001
0.0074
0.0000
0.2317
7.9594
0.0000
0.0133
0.0014
0.8738
0.0201
9.8880
3.7175
0.0009
57.2067
2.4158
0.0843
0.2922
0.1450
0.0357
0.2138
2.9305
11.3380
0.0198
0.0366
0.1291
0.0076
0.0012
0.4932
0.1127
6.88E-01
Nf
0.
cal I• not of conetrn throuoti thlt exposure route.
Chemical contributes less thsn 0.0001 percent of Index.
2-21
-------
In order to determine if any threatened or endangered species could be impacted by the site, the
Florida Natural Resources Survey was consulted. Three threatened species were identified within
a 1-mile radius of the Sherwood site: the Florida Scrub Jay, the Florida Pine Snake, and the Bald
Eagle. Because of the dense vegetation that borders most of Lake Miller, a fish-eating bird (avion
piscivore) was selected to evaluate potential risks to land-based (terrestrial) animals. The osprey was
selected instead of the bald eagle because ospreys eat fish exclusively, whereas bald eagles usually
eat fish from lakes larger than Lake Miller as well as other terrestrial animals.
Potential risks to the osprey due to the ingestion of fish from Lake Miller exceeded EPA's risk
criteria, with a cumulative HI of 1.39. Bis(2-ethylhexyl)phthalate accounted for 55% of the HI and
was detected at trace levels in all of the surface water samples from Lake Miller. However, this
compound, which is a widely used plasticizer and common laboratory contaminant, was also detected
in the associated laboratory method blank, suggesting that its detection was likely to be related to
laboratory contamination. Mercury accounted for 24% of the HI, but was detected in only 1 of 14
surface water samples in Lake Miller. Neither of these compounds has been linked to site operations.
In summary, actual or threatened releases of hazardous substances from the Sherwood site have been
addressed by previous response actions. Therefore, no further action is needed to ensure protection
of human health or the environment.
Because historical sampling results have indicated the presence of elevated levels of chromium
contamination in Lake Miller sediment and volatile organic contamination in Lake Miller surface
water, routine sediment and surface water sampling shall be conducted to provide the data necessary
for evaluating the protectiveness of this remedy in the 5-year review. The specific details of these
additional sampling requirements, including contaminants of concern and sampling locations, shall
be incorporated into revisions of the Operation and Maintenance Plan for the site.
7.0 Explanation of Significant Changes
The Proposed Plan for OU3 at the Sherwood site was released for public comment on June 19, 1997.
The Plan indicated that EPA was recommending no further action to address sediment contamination
in Lake Miller, indicating that response actions outlined in previous RODs had adequately addressed
potential risks posed by the site. More specifically, the OU1 ROD called for a ban on fishing in Lake
Miller based on potentially unacceptable risks documented in the BRA associated with ingestion of
fish caught from Lake Miller.
During the public meeting, residents advised that fishing in Lake Miller has occurred historically and
continues to occur in the present. Because the risk estimates in the BRA were extrapolated by
applying bioconcentration factors for fish to surface water contaminant concentrations, EPA has
determined that sampling of fish from Lake Miller is necessary to provide a more direct evaluation
of the fish consumption pathway. In addition, comments received during the public comment period
raised concern about the possibility offish from Lake Miller swimming through canals to adjoining
lakes. Therefore, fish tissue samples from Lake Miller and any adjoining lakes which can reasonably
be assumed to be reached by fish navigating through the canals shall be collected and analyzed for
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contaminants of concern identified in the BRA. The results of these analyses will allow EPA to
determine whether the fishing ban should be lifted or additional actions should be taken to ensure the
protection of human health or the environment.
8.0 Construction Completion Certification
The construction of the surficial aquifer pump and treat system pursuant to the OU2 ROD is
documented in the IRM-2 Remedial Action Report dated January 1993. Construction activities
consisted of the installation of 9 surficial aquifer extraction wells complete with submersible pumps
and the following additional components:
• air stripper
• chlorination system
• underground extraction piping
• discharge pipe to Lake Miller for treated water
Representatives of EPA, FDEP, Sherwood, and Weston conducted a final inspection at the site on
July 29,1992, at which time no outstanding construction items were identified. EPA accepted the
IRM-2 Remedial Action Report on February 24, 1993, certifying that construction was complete and
the surficial aquifer pump and treat system was operational and functional.
The OU1 ROD required continued operation of the surficial aquifer pump and treat system,
extraction and treatment of groundwater drawn from an existing Floridan aquifer supply well, and
implementation of institutional controls. However, no additional physical construction activities were
necessary to implement the requirements of the OU1 ROD. Therefore, since no physical construction
activities are required by this OU3 ROD, the site now qualifies for inclusion on the Construction
Completion List. Because contamination remains at the site, EPA will conduct a review every five
years in accordance with Section 121 of CERCLA to ensure that all remedies for the site continue
to provide adequate protection of human health and the environment.
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Sherwood Medical Company
DeLand, Volusia County, Florida
3. RESPONSIVENESS SUMMARY
In accordance with Sections 113 and 117 of CERCLA, as amended, EPA has conducted community
involvement activities at the Sherwood site to solicit community input and ensure that the public
remains informed about site activities. EPA's Proposed Plan Fact Sheet for Operable Unit 3 (OU3)
was mailed to the public on June 19,1997, and a copy of the Administrative Record for OU3 was
made available in the information repository at the DeLand Public Library. Public notices were
published in The Volusian on June 21,1997 and the Daylong News-Journal on July 6, 1997 advising
the public of the availability of the Administrative Record and the date of the upcoming public
meeting. EPA held a public meeting on July 8,1997 in the Stetson Room on the Stetson University
campus to answer questions and receive comments on the Agency's preferred alternative for
addressing Lake Miller sediment contamination. Comments received during the public meeting were
recorded in an official transcript of the meeting, a copy of which is included in the Administrative
Record. In addition, a public comment period was held from June 23, 1997 to July 23, 1997.
This Responsiveness Summary provides information about the views of the community and
potentially responsible parties regarding EPA's proposed action, documents how the Agency has
considered public comments during the decision-making process, and provides answers to major
comments received during the comment period. It consists of the following sections:
1.0 Overview: This section discusses the recommended action for the site and the public
reaction to this alternative.
2.0 Background on Community Involvement: This section provides a brief history of
community interest in the site and identifies key public issues.
3.0 Summary of Comments Received and EPA's Responses: This section provides EPA's
responses to oral and written comments submitted during the pubic comment period.
4.0 RD/RA Concerns: This section discusses community concerns raised during the
comment period regarding ongoing remedial action activities at the site.
1.0 Overview
EPA's Proposed Plan for Operable Unit 3 recommended no junker action to address sediment
contamination in Lake Miller at the Sherwood site. The Plan cited the Baseline Risk Assessment
(BRA) for the site as the basis for concluding that human health risks posed by sediment
contamination in the lake fall within EPA's acceptable risk range for both carcinogenic and non-
carcinogenic contaminants. The Plan further stated that previous institutional controls required by the
Record of Decision (ROD) for Operable Unit 1, namely a prohibition on fishing in Lake Miller,
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provided public health protection against the potential risks associated with consumption of fish
caught in Lake Miller.
During the public meeting, residents advised that fishing still occurs in Lake Miller and that no signs
have been observed around the lake. In addition, concerns were voiced about the possibility offish
from Lake Miller swimming through canals to adjoining lakes. Therefore, in the ROD, EPA will
require the collection and analysis offish tissue samples from Lake Miller and adjoining lakes. The
results of these analyses will allow EPA to determine whether the current fishing ban on Lake Miller
should be lifted or whether additional actions such as the extension of the ban to other lakes should
be taken to ensure the protection of human health or the environment.
Very few comments directly related to EPA's proposed no further action recommendation for Lake
Miller were received either in the public meeting or during the public comment period. However, a
DeLand city official commented that though he was comfortable with EPA's proposal, if the volume
of impacted material were small, EPA should consider removing the contaminated sediment. In
addition, an editorial in the July 12,1997 edition of The Volusian. though generally positive about
EPA and Sherwood cleanup efforts at the site, expressed regret that "the federal government won't
go the extra mile and finish the cleanup it began" with respect to Lake Miller.
Finally, EPA has received letters from American Home Products Corporation (AHPC), parent
company of Sherwood Davis & Geek (the responsible party for the site), expressing strong support
for no further action to address Lake Miller sediment. In addition, EPA provided an opportunity for
AHPC to comment on the proposed fish tissue sampling since it was not included in the Proposed
Plan. AHPC raised no objections to the additional sampling requirements.
2.0 Background on Community Involvement
Despite Sherwood Medical's presence in the community since the early 1960's, community concern
about the Sherwood site has historically been low. Although a few residents recall being concerned
when the site was first proposed for inclusion on the National Priorities List in 1982, many residents
were not aware that it was a Superfund site until publication of an article in the DeLand Sun News
in September 1986. This article raised the possibility of a link between physical symptoms
experienced by residents in the area who rely on private well water and potentially contaminated
groundwater emanating from the Sherwood site. Between September and December of 1986,
several citizens filed complaints with local and state health officials, city officials, and their U.S.
Representative concerning potential contamination of their drinking water drawn from private wells
by the Sherwood site.
In developing its Community Relations Plan for the site, EPA conducted interviews of residents and
local officials in the DeLand and West Volusia County area in November 1986. EPA's Community
Relations Plan was finalized in May 1988. EPA distributed its first fact sheet to the public in
December 1989, providing information on the Sherwood site history, the Remedial Investigation and
Feasibility Study (RI/FS) process, and opportunities for public involvement. The fact sheet was
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followed by a public meeting on January 9,1990 to provide an opportunity for community members
to ask questions on any aspect of the site or the upcoming RI.
Following issuance of EPA's Proposed Plan for Interim Action in January 1991, EPA hosted a second
public meeting on January 31,1991 at Stetson University to explain EPA's recommended action for
addressing surficial aquifer contamination and to receive comments from the community on the
proposed action. A 30-day comment period was also held to solicit public input. A Responsiveness
Summary was prepared addressing questions and comments provided during the comment period.
This document was included as part of the Interim Action ROD.
EPA conducted a third public meeting on July 30, 1992 to explain the proposed final remedy
addressing groundwater, soil, and surface water contamination at the Sherwood site. Comments
were received at the meeting and throughout the 30-day public comment period for this phase of the
project.
Finally, following issuance of the Proposed Plan for OU3, EPA hosted a public meeting at Stetson
University on July 8, 1997 to outline the no farther action proposal for addressing Lake Miller
sediment. A comment period was held from June 23,1997 to July 23,1997. This Responsiveness
Summary provides EPA's responses to comments received during the meeting and comment period.
Based on EPA sign-in rosters, community participation at EPA public meetings has generally been
light, with between 20 and 30 people typically in attendance. The key issue raised consistently by the
community throughout the history of the site has been concern that groundwater contamination from
the Sherwood site has already or may in the future impact their private drinking water wells. A host
of other concerns stem from this issue, including potential health effects from drinking contaminated
water, a desire for testing and treatment of their water, and property devaluation due to
contamination.
3.0 Summary of Comments Received and EPA's Responses
1. An adjacent property owner advised that he and family and friends had caught and consumed
fish from Lake Miller for many years. He has never been advised not to fish in the lake nor
seen any "No Fishing or Swimming" signs posted around the lake. He asked if it is now safe
to eat fish caught from the lake.
EPA Response: Based on the results of the BRA, EPA recommends that residents do not eat
fish caught from Lake Miller. Under the Amended Consent Decree between EPA and
Sherwood effective on December 10,1993, Sherwood is required to install 10 "No Fishing
or Swimming" signs around the lake and notify the adjacent property owner concerning the
restrictions. EPA will work with Sherwood and the adjacent property owner to identify
appropriate locations for the signs.
2. A commenter advised that fishermen come into Lake Miller via canal from Blue Lake,
Talmadge Lake, and North Talmadge Lake, and no sign has been posted along the canal.
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Another commenter noted that since potentially contaminated fish could migrate through the
canals to other lakes, EPA should consider whether fishing in these lakes should be restricted.
EPA Response: In response to these concerns, EPA believes that fish tissue samples offish
from Lake Miller and the adjoining lakes should be collected to better assess the risks
associated with the fish consumption pathway. EPA is working with Sherwood and the
Florida Department of Health to design an appropriate sampling plan for this evaluation. On
the basis of these results, EPA can determine whether to extend the fishing ban to other lakes,
leave the restriction on Lake Miller in place, or lift the ban altogether. However, in the
meantime, signs will be posted at appropriate places around Lake Miller and along the canals
leading into Lake Miller to advise fishermen of the restriction.
3. A commenter asked whether shallow wells in the area had been evaluated for potential
contamination and whether there is a potential for downward movement of contaminants.
EPA Response: During the Remedial Investigation (RI), groundwater sampling was
conducted in both the surficial (shallow) and Floridan aquifers. In addition, a number of
private wells completed in the Floridan aquifer were sampled. Based on the results of these
samples, EPA determined that a groundwater pump and treat system was needed for the
surficial aquifer to prevent any further downward migration of contamination into the Floridan
aquifer. This system was built and began operating in 1992 and continues to operate today.
In addition, because of contamination found in the Floridan aquifer, EPA required Sherwood
to continue operation of an industrial water supply well and treatment system for the Floridan
aquifer. Sherwood conducts semi-annual groundwater sampling of monitoring wells in the
Floridan and surficial aquifer and a few private water supply wells and reports the results to
EPA, EPA reviews these semi-annual sampling reports to monitor progress toward cleanup
of the aquifers. During the next year, EPA will conduct a formal review of the data collected
over the last five years (known as the five year review) to ensure that the actions being
implemented remain protective of human health and the environment.
4. A commenter asked if there were any potential effects to adjoining properties other than by
contact with Lake Miller?
EPA Response: EPA believes that ongoing groundwater remediation activities are adequate
to prevent any off-site migration of contamination from the site. In addition, once the
institutional controls specified in the OU1 ROD are in place, public access to potentially
contaminated areas (i.e. Lake Miller) will be restricted.
5. A commenter indicated that her late husband and her current husband's late wife both died
of cancer. The commenter also indicated her husband has prostate cancer. All of these
family members had consumed fish from Lake Miller, and the commenter was concerned that
eating contaminated fish from Lake Miller may have contributed to these cancers.
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EPA Response: EPA does not have the expertise to determine if there is a link between these
cancers and the consumption of potentially contaminated fish from Lake Miller, so this health
concern has been forwarded to the Florida Department of Health and the Agency for Toxic
Substances and Disease Registry (ATSDR) for consideration. However, it should be noted
that the only fish tissue sampling data available for Lake Miller and adjoining lakes is for
chromium, which is not considered to be a carcinogen by EPA. This data suggests that the
non-cancer risk associated with chromium levels in fish from Lake Miller are below EPA's
threshold for concern. Since the BRA indicated a potentially unacceptable risk associated
with eating fish from Lake Miller, EPA believes that fish tissue sampling should be conducted
to provide the data needed to make a more representative assessment of the potential risks
from this exposure pathway.
6. A commenter asserted that groundwater flows to the east of Sherwood toward his property,
indicating that his well was determined to be contaminated in October 1986 with zinc
chromate and alum. He advised that his well water is no longer useful for anything but the
toilet. He also claimed that people were getting sick and pets were dying. The commenter
also alleged that "in 1985 a 6" well was drilled at night to pour waste down," and efforts to
do an onsite inspection at the time were thwarted.
EPA Response: The direction of groundwater flow in the Upper Floridan aquifer in the
vicinity of the Sherwood site (where most private wells are completed) is heavily influenced
by pumping of Sherwood's onsite industrial water supply well. Therefore, Upper Floridan
groundwater generally flows toward the site from all directions. The Volusia County district
of the Florida Department of Health & Rehabilitative Services collected groundwater samples
from the private well in question in September 1996, and the results indicated no exceedences
of EPA's National Primary Drinking Water Standards. This documentation has been added
to the Administrative Record. However, the health concerns cited in the comment have been
relayed to HRS and ATSDR for consideration. Throughout the history of EPA's involvement
at the site, there is no indication of Sherwood denying access to inspect or investigate the
facility. Extensive EPA investigations at the site have not revealed the presence of any
disposal or injection wells at the site.
7. An official of the City of DeLand advised that Sherwood had been annexed into the city and
was now being served by the city sewer system. Various supporting documents were
submitted for inclusion in the Administrative Record. The commenter also asked what
volume of sediment is contaminated, noting that if the amount is small, EPA should consider
proceeding with removal of the contaminated sediment.
EPA Response: The estimated aerial extent of contaminated sediment is approximately 3.4
to 3.5 acres. The EPA cost estimate assumes that 1 foot of sediment must be removed,
resulting in about 6,000 cubic yards of material at an estimated cost of about $480,000. The
estimate prepared by Sherwood assumed a sediment removal depth of 2 feet, for an estimated
volume of 11,000 cubic yards. Sherwood evaluated various dredging scenarios, resulting in
widely divergent cost estimates ranging from $320,000 to $6.1 million, depending upon the
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disposal options for contaminated sediment, the need for sediment stabilization, and the
restoration actions necessary for the lake. Based upon the findings of the BRA and other
actions already planned by EPA pursuant to earlier RODs, EPA determined that dredging of
the lake was not warranted.
8. A commenter advised that she lives across the street from the Sherwood facility and has been
diagnosed with bladder cancer. She indicated that she has lived in the same location for 21
years and that her well "went bad" in the 1980's. She currently buys bottled water. The
commenter wondered whether the bladder cancer may be linked to groundwater
contamination from the Sherwood site.
EPA Response: EPA has forwarded this health concern to the Florida Department of Health
for followup. EPA believes that the surficial aquifer treatment system and the Floridan
aquifer water supply well on the Sherwood property are sufficient to prevent any further
migration of groundwater contamination from the site. However, within the next year, EPA
expects to conduct a review of the groundwater monitoring data collected over that last five
years to determine whether any changes need to made to ensure protection of public health.
4.0 Remedial Design/Remedial Action Concerns
Since EPA is proposing no further action for addressing sediment contamination in Lake Miller at the
Sherwood site, no additional design or construction activities are planned at this time. In response
to concerns raised during the comment period, EPA met with Sherwood and the adjacent property
owner to identify appropriate locations for the "NO FISHING OR SWIMMING" signs around Lake
Miller. The signs are scheduled to be installed in the very near future.
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