PB97-963157
EPA/541/R-97/184
'anuary 1998
EPA Superfund
Record of Decision Amendment:
Coleman-Evans Wood Preserving Co,
Whitehouse, FL
9/25/1997
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5 9
U J u
AMENDED RECORD OF DECISION
-INTERIM ACTION-
COLEMAN-EVANS WOOD PRESERVING
DUVAL COUNTY
WHITEBOUSE, FLORIDA
Prepared By
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia
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5 9 CG02
DECLARATION FOR THE AMENDED RECORD OF DECISION
-INTERIM ACTION-
SITE NAME AND LOCATION
Cdeman-Evans Wood Preserving
Duval County
Whhehouse, Florida
STATEMENT OF BASIS AND PURPOSE
This decision document represents an amendment to the selected remedial action for the
Coleman-Evans Wood Preserving Site (Site) in Whitehouse, Florida. This decision is made in
accordance with the Comprehensive Environmental Response, Compensation and Liability Act of
1980, as amended by the Superfund Amendments and Reauthorization Act of 1986 and, to the
extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan. This
decision is based on the Administrative Record for the Site.
This amendment is necessary because during design of the remedy that was selected in the 1990
Amended Record of Decision, dioxin was discovered at the Site as a new contaminant of concern
Subsequent treatability studies have shown that the selected treatment train of soil washing,
biotreatment, and solidification/stabilization, is not effective in reducing the concentrations of
dioxin at the Site to acceptable levels.
This document selects a new interim remedy to address an estimated 45,000 cubic yards of
pentachlorophenol (PCP) and dioxin-contaminated source material (i.e., soil, sediment, and
debris) and expands the scope of the ground water remedy to permanently address PCP-, and
potentially dioxin-, contaminated groundwater in the upper surficial aquifer.
This amendment is considered an interim action because the U.S. Environmental Protection
Agency (EPA) is selecting a soil dioxin cleanup level of 1.0 Mg/kg as an interim cleanup level for
the Site. EPA believes that this cleanup level is protective of human health and the environment,
but that the Agency should defer a final cleanup decision at this site pending release of EPA's final
dioxin reassessment (embodied in the documents entitled "Health Assessment Document for
2,3,7,8 tetrachlorodibenzo-p-dioxin (TCDD) and Related Compounds" and "Estimating
Exposure to Dioxin-like Compounds") and pending an evaluation of the effects of the findings of
the final dioxin reassessment on Superfund dioxin cleanup levels. EPA believes it is appropriate
to take an interim action at this time to achieve significant risk reduction quickly while the
reassessment is being completed.
The Florida Department of Environmental Protection (FDEP) has provided input as the support
agency throughout the remedy selection process. Based on FDEP's comments to date, EPA
expects that concurrence on this remedy will be forthcoming, although a formal concurrence letter
has not yet been received.
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ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this She, if not addressed by
implementing the response action selected in this document, may present an imminent and
substantial endangerment to public health, welfare or the environment.
DESCRIPTION OF AMENDED REMEDY-INTERIM ACTION
The major components of the amended interim remedy include:
• Excavating approximately 45,000 cubic yards of PCP and dioxin-contaminated
soil, sediment, and wood debris from the on-she and off-site areas;
• Treating the excavated soil, sediment, and some wood debris (primarily sawdust)
in an on-she thermal desorber, followed by treatment of the off-gas;
• Backfilling the excavated area with treated material and/or clean fill and re-grading
and re-vegetating all excavated areas;
• Recovering and treating PCP-contaminated groundwater in the upper surficial
aquifer and collecting fret-product for recycling and/or off-site disposal;
• Relocating residents, as necessary, to facilitate construction;
During pre-design, a treatability study will be conducted to verify the effectiveness of the thermal
desorption treatment system. Should implementation of the selected interim remedy prove
ineffective for remediation of PCP and dioxin-contaminated source material, a contingency
remedy will be implemented. The contingency remedy is also an interim action pending release of
the Agency's final dioxin reassessment.
The major components of the contingency remedy include:
• Excavating approximately 5,000 cubic yards of off-site contaminated soil and
sediment and distributing it on-she;
• Backfilling the excavated area with clean fill and re-grading and re-vegetating all
excavated areas;
• Constructing a multi-layer RCRA cap to contain the affected on-she area,
including surface drainage controls;
• Recovering and treating PCP-contaminated groundwater in the upper surficial
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5 9 • 0004
aquifer and collecting free-product for recycling and/or off-site disposal;
• Relocating residents, as necessary, to facilitate construction;
• Implementing deed restrictions and/or other institutional controls to prohibit future
use of the Site in a manner that would compromise the integrity of the cap and its
associated systems.
STATUTORY DETERMINATIONS
This amended interim action is protective of human health and the environment, complies with
Federal and State requirements that are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. Although this interim action is not intended to fully address
the statutory mandate for permanence and treatment to the maximum extent practicable, this
interim action utilizes treatment and thus is in furtherance of that statutory mandate. Because this
action does not constitute the final remedy for the Site, the statutory preference for remedies that
employ treatment that reduces toxicity, mobility, or volume as a principal element, although it is
partially addressed by this remedy, will be addressed by the final response action. Subsequent
actions may be used to address fully the threats posed by the conditions at this Site. Because the
contingency remedy will result in hazardous substances remaining on-site above health-based
levels, a review will be conducted to ensure that the remedy continues to provide adequate
protection of human health and the environment within five years after commencement of the
remedial action. Because this is an interim action decision, review of this Site and of the selected
and contingency remedies will be continuing as EPA continues to develop final remedial
alternatives for the Site.
Richard D. Green, Acting Director Date
Waste Management Division
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5 9 0005
AMENDED RECORD OF DECISION
-INTERIM ACTION-
COLEMAN-EVANS WOOD PRESERVING
DUVAL COUNTY
WHTTEHOUSE, FLORIDA
TABLE OF CONTENTS
Page
1.0 SITE LOCATION, BACKGROUND, AND DESCRIPTION 1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 4
3.0 REASONS FOR ISSUING THE ROD AMENDMENT 6
4.0 HIGHLIGHTS OF COMMUNITY INVOLVEMENT 6
5.0 SCOPE AND ROLE OF THE OPERABLE UNIT 8
6.0 SUMMARY OF SITE CHARACTERISTICS 8
6.1 Genera] Site Conditions 8
6.2 Site Geology and Hydrogeology 9
6.3 Nature and Extent of Contamination 9
6.3.1 Soil and Sediment 11
6.3.2 Groundwater 12
6.4 Contaminant Fate and Transport 16
7.0 SUMMARY OF SITE RISKS 17
7.1 Summary of 1986 Public Health Evaluation 17
7.1.1 Identification of Potential Receptors 17
7.1.2 Identification of Exposure Pathways 17
7.1.3 Risk Characterization 18
7.2 1996 Focused Baseline Risk Assessment Addendum , 18
7.2.1 Exposure Assessment 19
7.2.2 Identification of Exposure Pathways 21
7.2.3 Summary of Exposure Assumptions 22
7.2.4 Toxicity Assessment 22
Dioxin 25
Pentachlorophenol 26
7.2.5 Risk Characterization 26
7.3 Remedial Action Objectives 28
7.4 Groundwater Cleanup Levels 29
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5 9 0006
7.5 SoD and Sediment Cleanup Levels :'. • 29
7.5.1 Pentachlorophenol 30
7.5.2 Dioxin 31
8 O DESCRIPTION OF ALTERNATIVES 32
8.1 Alternative 1: No Action 32
8.2 Alternative 2: Containment by Capping With Ground water Recovery and
Treatment : , 33
8.3 Alternative 3: Incineration 33
8.4 Alternative 4: Thermal Desorption 34
9.0 EVALUATION OF ALTERNATIVES 35
9.1 Threshold Criteria 36
9.1.1 Overall Protection of Human Health and Environment 36
9.1.2 Compliance with ARARs 36
93 Balancing Criteria 37
9.2.1 Long Term Effectiveness and Permanence 37
9.2.2 Reduction of Mobility, Toxicity or Volume 37
9.2.3 Short-Term Effectiveness 37
9.2.4 Implementability 38
9.2.5 Cost 38
9.3 Modifying Criteria 39
9.3.1 State Acceptance 39
9.3.2 Community Acceptance 39
10.0 SUMMARY OF THE SELECTED REMEDY 39
10.1 Selected Interim Remedy-Thermal Desorption With Ground water Recovery and
Treatment, Alternative 4 40
10.1.1 Performance Standards For Soil and Sediment 42
10.1.2 Performance Standards For Groundwater 43
10.1.3 Cost 44
10.2 Contingency Remedy—Containment by Capping With Groundwater Recovery and
Treatment, Alternative 2 44
10.2.1 Performance Standards For Soil and Sediment 46
10.2.2 Performance Standards For Groundwater 47
10.2.3 Cost 48
11.0 STATUTORY DETERMINATIONS 49
11.1 Protection of Human Health and the Environment 49
11.2 Attainment of Applicable or Relevant and Appropriate Requirements 49
11.3 Cost Effectiveness 49
11.4 Utilization of Permanent Solutions and Alternatives 50
11.5 Preference for Treatment as a Principal Element '. 50
11.6 Documentation of Significant Changes 53
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59' 0007
LIST OF TABLES
Page
Table 6.1: Maximum Concentrations of Contaminants Detected in Soil, Coleman-Evans
Wood Preserving Site, Whitehouse, Florida 11
Table 6.2 Characteristics of Contaminated Soil in the Process and Landfill Areas.
Source: Focused Feasibility Study, April 1995 14
Table 7.1 Reasonable Maximum Exposure Point Concentrations for Contaminants of
Potential Concern .20
Table 7.2 Potential Human Exposure Pathways Under Current and Future Land Use
21
Table 7.3: Exposure Parameters for Incidental Ingestion of Contaminants in Surface Soils
Under Current and Future Land-Use On-She 23
Table 7.4: Exposure Parameters for Incidental Ingestion of Contaminants in Surface Soils
Under Current and Future Land-Use off-site 24
Table 7.5: Oral Toxicity Values for the Contaminants of Potential Concern 25
Table 7.6: Non-Cancer and Cancer Risks Associated With Exposure to Surface Soils Under
the Current and Future Land Use Scenarios , 27
Table 7.7: Cleanup Levels for Soil and Sediment at the Coleman-Evans Wood Preserving Site
30
Table 7.8: SPLP Test Results in Soil at the Coleman-Evans Wood Preserving Site 31
Table 10.1: Performance Standards for Soil and Sediment 42
Table 10.2: Performance Standards for Groundwater 43
Table 10.3: Performance Standards for Soil and Sediment 47
Table 10.4: Performance Standards for Groundwater 47
Table 11.1: Applicable or Relevant and Appropriate Requirements (ARARs) for the Coleman-
Evans Wood Preserving She 50
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5 9 OQ08
LIST OF FIGURES
Page
Figure 1.1: Coleman-Evans Wood Preserving Site Location Map, U.S.G.S. Base Map,
Marietta, Florida Quadrangle (Revised 1982) 2
Figure-1.2: Coleman-Evans Wood Preserving She Map, Whitehouse, Florida 3
Figure 6.1: Generalized Geologic Cross-Section, Coleman-Evans Wood Preserving Site,
Whitehouse, Florida 10
Figure 6.2: Interim Dioxin and Final PCP Soil and Sediment Contamination Boundaries,
Coleman-Evans Wood Preserving Site, Whitehouse, Florida 13
Figure 6.3: Updated Ground water PCP Concentrations in the Surficial Aquifer (1980, 1983,
1985, 1994), Coleman-Evans Wood Preserving Site, Whitehouse, Florida; Source:
Focused Feasibility Study, April 1995 15
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59 OG09
LIST OF APPENDICES
Page
APPENDIX A A!]
APPENDIXB .B-l
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AMENDED RECORD OF DECISION
-INTERIM ACT1ON-
COLEMAN-EVANS WOOD PRESERVING
DUVAL COUNTY
WHTTEHOUSE, FLORIDA
1.0 SITE LOCATION, BACKGROUND, AND DESCRIPTION
The Coleman-Evans Wood Preserving Site (She) is an 11 acre, former wood preserving facility,
located in the town of Whitehouse, Florida, approximately eight miles west of Jacksonville
(Figure I.I). The Site is bordered on the north by the Seaboard Coastline Railroad, on the south
by residential homes along General Avenue, on the east by heavy vegetation, and on the west by
residential homes across Celery Avenue (Figure 1.2).
From 1954 to the mid 1980s, the Coleman-Evans facility (Coleman-Evans) treated wood products
with a mixture of pentachlorophenol (PCP) and fuel oil. The treatment process included
steaming, drying and pressure soaking the wood, all of which were carried out within a single
pressurized chamber.
During the steaming process, wood products were impregnated with PCP and No. 2 fuel oil,
using 255 degree Fahrenheit steam for a period of eight hours. During this process, wood
extracts were driven from the pores of the wood which settled on the bottom of the chamber
along with PCP and wastewater from the condensed steam.
Prior to 1970, the effluent waste-water from the treatment process was precipitated with caustic
soda and aluminum sulfate, passed through a sand filter and discharged into a drainage ditch
which channeled the water south to McGirts Creek. The precipitated sludge was deposited into
two unlined pits, each approximately 100 feet by 50 feet, located along the southeastern boundary
of the Site. In 1970, usage of the sludge disposal pits was discontinued when the company began
storing its waste sludge in above ground storage tanks located adjacent to the pit area near the
southwestern edge of the Site. The company voluntarily engaged the engineering firm of
Reynolds, Smith and Hill to design a wastewater treatment system. Chlorination and lime
precipitation were then incorporated into the treatment system to clarify waste-water.
Although wood treating operations ceased in the late 1980s, sawing and kiln drying of untreated
lumber continued at the Site until mid-1994. Currently, all commercial activities at the Site have
ceased.
Colenuo-Evsni Wood Proofing
Amended Record of Deciiion-laurim Adtoo
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59 0011
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The Site is currently composed of two distinct areas. The first area, located on the western
portion of the property, comprises the former wood treatment facility. The second area, located
on the eastern portion of the property, comprises the landfill which was used for the disposal of
wood chips and other facility wastes. Site surface features formerly include two unlined disposal
pits, the contents of which were partially removed in July 1985 under an U.S. Environmental
Protection Agency (EPA) Emergency Response Action, and the inactive wood treatment facility.
The treatment facility was composed of a large pressure filter system and several storage sheds,
most of which also were removed from the Site during early Emergency Response Actions.
2.0 SITE HISTORY AND ENFORCEMENT ACTTVniES
In September 1980, ground water contamination was confirmed at the She by the City of
Jacksonville, Department of Health, Welfare and Bio-Environmental Services. As a result,
Coleman-Evans incorporated activated charcoal filters into its existing waste-water treatment
system to improve the removal of organics.
In 1981, a closed-loop steam treatment system was constructed on-site which resulted in no
discharge of process water. In that same year, Coleman-Evans was found by EPA to be in
violation of hazardous waste reporting, planning, and safety requirements enforced under the
Resource Conservation Recovery Act (RCRA). In October 1981, the Site was proposed for
inclusion on the National Priorities List based on a hazard ranking score of 59.14.
In March 1983, the proposed inclusion of the Site on the National Priorities List became final. In
that same year, Coleman-Evans was identified by EPA as a generator and storer of hazardous
waste, in violation of RCRA requirements.
In September 1984, a Remedial Investigation/Feasibility Study (RI/FS) was initiated. The RI was
delayed by Coleman-Evans' refusal to allow access to the Site. As a result, EPA and the
Department of Justice filed a motion in Federal Court to obtain an order, granting access to the
Site.
In June 198S, EPA and its agents were granted access to the Site. In that same year, EPA issued
a Section 106 Removal Order to Coleman-Evans pursuant to the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA). Coleman-Evans did not comply
with the Section 106 Removal Order. As a result, in July 1985, EPA conducted an Emergency
Response Action at the Site to control the major source of PCP contamination in the upper
surficial aquifer. Two unlined pits were excavated and the contaminated soil/sludge was shipped
off-site to a hazardous waste management facility in Emelle, Alabama. The pits were backfilled
with clean material and french drains were installed.
In April 1986, the RI was completed which characterized the extent of contamination at the Site.
In that same year, a Public Health Evaluation (baseline risk assessment) identified PCP as the
Colenun-EvBiB Wood Preserving
Amended Record of Decuioo-lntmm Action 4
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59 0014
primary contaminant of concern at the Site. PCP was shown to be present in sediment, soil,
surface water and in the upper surficial aquifer. In July 1986, the draft FS was released to the
public and in August 1986, a public meeting was held to present the FS alternatives to the
community. In September 1986, the Record of Decision (1986 ROD) was signed. The 1986
ROD called for the: 1) excavation and incineration of soil (approximately 9000 cubic yards)
contaminated with PCP at levels greater than 10 mg/kg, and 2) recovery of PCP-contaminated
groundwater during excavation and treatment via a granular activated carbon adsorption unit. In
October 1986, a General Notice letter was issued to Coleman-Evans regarding implementation of
the Remedial Design/Remedial Action (RD/RA). Citing financial inability, Coleman-Evans
declined to implement the RD/RA.
In December 1987, a Special Notice Letter was issued by EPA, giving Coleman-Evans an
opportunity to enter into negotiations with EPA to implement the RD/RA. Citing financial
inability, Coleman-Evans again declined to implement the RD/RA.
In April 1988, a CERCLA Section 106 Order was issued to* Coleman-Evans to implement the
RD/RA. In response, Coleman-Evans requested a settlement conference with EPA. In April and
May 1988, demand letters were issued to Coleman-Evans and Jack Coleman (president) for past
costs incurred in the 1985 Emergency Response Action. In July 1988, the Department of Justice
filed a civil action against Coleman-Evans, seeking recovery of those funds and punitive damages
for failure to comply with the Section 106 Order.
Due to Coleman-Evans' refusal to cooperate with the Section 106 Order, EPA decided to use
Federal funding to implement the RD. Based on data collected during RD, the volume of PCP-
contaminated soil needing treatment was increased to approximately 27,000 cubic yards. Due to
the increased cost associated with treating this material, EPA and the Florida Department of
Environmental Protection (FDEP) decided to evaluate other alternatives in a treatability study.
The treatability study was initiated in March 1989. PCP-contaminated soil samples were obtained
from the Site in order to investigate the technical effectiveness of other treatment technologies,
particularly, soil washing, biotreatment, and solidification/stabilization (S/S). The treatability
study was completed in March 1990.
In April 1990, Coleman-Evans settled with the United States Government for $350,000 and a
complete covenant not to sue. In August 1990, a public meeting was held to present the
treatability study recommendations and EPA's proposed amended remedy. In September 1990, an
amended Record of Decision (1990 AROD) was signed calling for the: 1) remediation of soil
contaminated with PCP at levels greater than 25 mg/kg via a treatment train consisting of soil
washing, biotreatment and S/S, and 2) recovery of PCP-contaminated groundwater during
excavation and treatment via a granular activated carbon adsorption unit. This treatment train
was considered to be the most effective overall source control method.
At the request of the EPA's Site Assessment Section, Waste Management Division, an additional
Cotanaa-Evm Wood Preserving
Amended Record of DediioD-lmcrim Action 5
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soil sampling investigation was conducted in June 1992. This investigation determined that
dioxins/furans (henceforth referred to as dioxin) are also a contaminant of concern at the Site.
As a resuh of this finding, further sampling was performed to determine the extent of the dioxin
contamination. A removal action was performed in 1993 to remove the surface contamination
from adjacent home owner yards, and install fencing between the street and drainage ditch to
eliminate the possibility of the public coming in contact with the contamination.
Due to the presence of dioxin, the selected technology train was reevaluated. EPA completed a
Focused Feasibility Study in April 1995 as part of that revaluation.
Although PCP wood treatment operations ceased in the late 1980s, sawing and kiln drying of
untreated lumber continued on the Site until 1994. Currently all commercial activities at the Site
have ceased.
3.0 REASONS FOR ISSUING THE ROD AMENDMENT
During the design of the remedy for the 1990 AROD, soil samples were obtained as part of a
treatability study to assess the levels of performance achievable by the selected treatment train.
The samples revealed the presence of both PCP and dioxin at the Site.
The results of the treatability study show that the 1990 AROD treatment train is not effective in
treating the dioxin found at the Site. Although soil washing is marginally effective on separating
dioxin and PCP contaminants from soil panicles, a large portion of the contaminants are bound up
in the high percentage of wood fiber in the soil. Bio-treatment was found to be ineffective on the
dioxin contamination found at the Site. The effectiveness of S/S is also questionable due to the
high percentage of wood fiber in the soil, which presents problems in reaching the necessary S/S
compressive strength. Attempts to separate the wood fiber from the soil were unsuccessful due to
the heavy laden fuel oil on the wood fiber. At best, if the dioxin and PCP wood fiber could be
separated from the soil, an undetermined volume of wood fiber still would require some form of
treatment or disposal beyond that found in the 1990 AROD.
Based on the ineffectiveness of the 1990 AROD treatment train on the dioxin contamination at the
Site, EPA and FDEP decided that other alternatives would be evaluated in a Focused Feasibility
Study. The remedial alternatives evaluated in the Focused Feasibility Study are presented in
Section 8 of this AROD.
4.0 HIGHLIGHTS OF COMMUNITY INVOLVEMENT
In accordance with Sections 113 and 117 of CERCLA, as amended, and the National
Contingency Plan (NCP) §300.435 (c)(2)(ii), EPA has conducted community involvement
activities at the Site to solicit community input and ensure that the public remains informed about
Coleman-Evms Wood Preserving
Amended Record of Decinoo-hnerim Action 6
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5 9 OC16
Site activities. EPA has relied upon a number of methods for keeping the public informed,
including press releases, fact sheets, public meetings, establishment of information repositories,
and holding public comment periods. The following summary presents the community
involvement activities that were implemented in support of this document.
In October 1992, EPA and FDEP held a public meeting to inform the public of the discovery of
dioxin contamination at the Site. Although the public meeting was announced in the Florida
Times Union, only a few members of the community participated.
Door-to-door community interviews were conducted in April 1995 to listen to the concerns of the
community and explain the limited alternatives for addressing the dioxin contamination. EPA's
mailing list was also updated at this time.
The Proposed Plan was released to the public in May 1995. Documents supporting the Proposed
Plan were made available to the public for review in the Administrative Record maintained at
EPA's Region IV office in Atlanta, Georgia, and at the Information Repository maintained at the
Whhehouse Elementary School in Whitehouse, Florida. A notice of the Public Meeting was
published in the Florida Times Union in June 1995.
A Proposed Plan public meeting was held on June 7, 1995 at the Whitehouse Elementary School.
During this meeting, representatives from EPA presented various alternatives for addressing the
Site, presented EPA's preferred alternative, and answered questions.
The 30-day public comment period was held from May 31,1995 through June 30, 1995. A
response to the comments received during the public comment period is included in the
Responsiveness Summary, which is pan of this AROD (Appendix A).
During the public comment period, FDEP expressed concern with EPA's proposed cleanup levels
for the she. Specifically, FDEP requested that EPA select a PCP cleanup level that would be
protective of ground water, and a dioxin cleanup level that provides a 1 x 10"6 risk level.
Finalization of this AROD was delayed from July 1, 1995 to July 31, 1997, while EPA and FDEP
evaluated appropriate cleanup levels for the site and while additional Site characterization was
performed to delineate dioxin contaminate levels off-site. A Community Update Fact Sheet was
released to the public in August 1997 reporting the results of the off-site dioxin delineation.
This AROD will be added to the Administrative Record as required by the NCP §300.825(a)(2).
The Administrative Record for the Site has been placed at the following Information Repositories:
U.S. Environmental Protection Agency, Region IV
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104
Phone: (404)562-8855
Hours: Mon-Fri 8:00 a.m. to 4:00 p.m.
ColcnuD-EvuB Wood framing
Amended Record of Deciiioo-Inlerini Action 7
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5 9 0017
o
Whitehouse Elementary School
11160 General Avenue
Whitehouse, Florida 32220
Phone: (904)693-7542
Hours: Mon-Fri 9:00 a.m. to 4:00 p.m.
5.0 SCOPE AND ROLE OF THE OPERABLE UNIT
EPA has organized the work at this Site into one operable unit to address groundwater, soil,
sediment, and debris. Based on data currently available, this interim action is protective of human
health and the environment and to the extent possible, is consistent with future actions planned
for the She. The scope of the contaminated media are as follows:
Soil, Sediment,
and Debris: PCP and dioxin contamination on the 11- acre former Coleman-
Evans Wood Preserving property, residential area surrounding the
Site, off-site drainage ditch leading from the southeastern portion of
the Site through the residential area, and the off-site drainage ditch
leading from the southwestern portion of the Site through the
residential area to Interstate 10.
Groundwater: • PCP contamination in the upper surficial aquifer underlying the Site
and residential area.
The 11-acre Coleman-Evans property is the main area of soil contamination and debris at the Site.
This contamination has migrated, mostly through surface water runoff, to other nearby areas
including the drainage ditches and residential area surrounding the property. Groundwater
contamination primarily appears to be contained to the upper-surficial aquifer in the on-site area
underlying the 11 -acre property and in the nearby residential area.
6.0 SUMMARY OF SITE CHARACTERISTICS
This section provides a description of the Site surface features, underlying strata and
hygrogeologic information, as well as a summary of the sampling data that was collected for the
purpose of characterizing the extent of Site contamination.
6.1 General Site Conditions
The Site is relatively flat, with less than ten feet of relief over the entire 11 acres. The Site drains
by way of drainage ditches which flow southward, subsequently draining into McGirts Creek.
Within a one mile radius of the She, land use is primarily residential and light
Colonait-EvKB Wood fnterving
Amended Record of Decniao-IineruD Action 8
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59 OuiS
commercial/industrial. Agriculture near the Site is limited to small gardens. Outside of the one
mile radius, the area is primarily undeveloped rural land up to the outskirts of Jacksonville, about
eight miles to the east.
Locally, there is no municipal water supply. Thus, approximately 1000 residents rely on
groundwater resources for drinking water. Surface waters in Duval County are used extensively
for sport and recreation.
6.2 Site Geology and Hydrogeology
The top four to six feet of material covering the She consists of poorly cemented fine grained
quartz sand whh minor amounts of clay and sDt. Below this soil cover is a well cemented fine
grained quartz sand unit which extends to 35 feet below ground surface (BGS). This unit is
considered the upper surficial aquifer at the She. A sandy clay unit with intermittent clay lenses
and sand layers exists from 35 feet BGS to approximately 100 feet BGS. This 65 foot thick unit
appears to act as a confining layer which separates the upper surficial aquifer and the deeper
limestone aquifer. The limestone unit is present from 100 feet BGS to approximately 130 feet
BGS. Both the upper surficial aquifer and the deeper limestone aquifer comprise the surficial
aquifer system (Figure 6.1).
Groundwater flow in the upper surficial aquifer is predominantly from northeast to southwest.
The depth to water is generally between two to five feet BGS, and the average horizontal
hydraulic gradient is approximately 0.01. The saturated thickness of the upper surficial aquifer is
31 feet, horizontal hydraulic conductivity is 5.4 feet/day, specific yield is estimated to be 0.02, and
storativity is 0.003. Recharge to the upper surficial aquifer occurs in the vicinity of the Site and
groundwater discharges to McGirts Creek to the southwest.
Groundwater flow in the deeper limestone aquifer is toward the west-southwest under a
horizontal hydraulic gradient of 0.04. The saturated thickness of the deeper limestone aquifer is
30 feet, horizontal hydraulic conductivity is 9.7 feet/day, and storativity is 0.0015. Based on
water level measurements collected from both units, the upper surficial aquifer and the deeper
limestone aquifer are not in hydraulic communication.
6.3 Nature and Extent of Contamination
Results of on-she and off-site sample analyses reveal a widespread occurrence of both dioxin and
PCP contamination in soil and sediment and the presence of PCP in the upper surficial aquifer.
The aerial extent of the dioxin and PCP contamination covers most of the Site, portions of the
off-site residential area, as well as the drainage ditches south of the Site leading to McGirts Creek.
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0
ao
40
100
120
140
PWESAND
OAYEYSAMD
UMESTONE
G019
Figure 6.1: Generalized Geologic Cross-Section, Coleman-Evans Wood Preserving Site,
Whitehouse, Florida
s Wood Pmetvias
AaeodBd Racoricf Dacuiop-latnim Aoioo
10
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5
cc:o
€3.1 Soil and Sediment
The two major sources of contamination are the process area on the western side of the Site, and
the landfill area on the eastern side of the Site. Included in the process area is the southern border
of the She where the storage tanks and phs once were located.
Sampling data indicates the majority of on-site contamination is limited to the upper three feet of
sofl. Soil in the vicinity of boreholes 38,40, and 44 however, contain PCP-contaminated soil
down to 15 feet below ground surface. It is estimated there are approximately 300 cubic yards of
contaminated soil at each of these areas (900 cubic yards total). No apparent hot-spots of
contamination have been identified. Concentrations of PCP and dioxin (TEQ) vary across the
Site, with the maximum concentrations detected at 3120 mg/kg and 230 /^g/kg respectively for
the two contaminants. Table 6.1 shows the maximum soil concentrations detected at the Site.
Table 6.1: Maximum Concentrations of Contaminants Detected in Soil, Coleman-
Evans Wood Preserving Site, Whitehouse, Florida
ON-$nx
OFF-SITE
SOIL SAMPLE
DEPTH1
Surface
Subsurface
Surface
Subsurface
DlOXINw
< Mg/kg)
230 J
0.00037 J
54 J
7.11
PENTACHLOROPHENOL
(mg/kg)
3120
2423
480
430
1 Surface samples were taken from 0-6 inches below ground surface. Subsurface samples were taken from 24-30 inches
Mow ground surface.
7 Dioxin concentrations are total 23,7.8 TCDD Toxicity Equivalents: I-TEQt/89.
' Estimated concentrations are represented by "J".
Some dioxin contamination also has been identified in the residential area near the off-site
drainage ditches, some of which was removed during previous Emergency Response Actions.
Sampling conducted in August 1995 indicates that dioxin is present underneath one home at a
concentration of 16 A^g/kg, and in the backyard of another home at a concentration of 1.6 //g/kg
Maximum concentrations of PCP and dioxin in the off-site areas have been detected at 480 mg/kg
and 54 ^g/kg, respectively. .
A total estimated (on-site and off-site) volume of 45,000 cubic yards of PCP and dioxin-
contaminated soil and sediment are estimated to require remediation at the Site. This estimate is
based upon an interim cleanup level of 1.0 Atg/kg for dioxin, and a final cleanup level of 2.0 mg/kg
Colenun-Evias Wood Pntcrvjng
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r
>-\
9
for PCP. Figure 6.2 shows the dioxin and PCP boundaries requiring remediation:
In general, the soil found at the She is a fine sand. In the landfill area there is visible humic and
organic material, much of this being small wood chips. In the old process area the soil is stained
and oily. Table 6.2 lists the general characteristics of composite soil samples taken from these
two areas.
6.3.2 Groundwater
The contaminant of concern in the upper surficial aquifer is PCP and associated petroleum
hydrocarbons and free product. Analytical results from borehole and temporary monitoring well
samples collected in 1980, 1983, and 1985 were used to delineate the extent of PCP
contamination in the upper surficial and deeper limestone aquifers in the 1986 ROD and 1990
AROD. This data shows there is no PCP contamination in the deeper limestone aquifer.
There are presently 12 monitoring wells associated with the Site; two of the wells are located
northwest of the She, two wells are located in the southwest corner of the Site and the remaining
eight wells are located off-site near the southern Site boundary. In January 1994, these wells
were sampled by EPA and the results showed non-detect concentrations for PCP in the upper
surficial aquifer. This recent upper surficial aquifer data was added to the historical upper
surficial aquifer data (obtained over the five-year period between 1980 and 1985 from boreholes
and temporary monitoring wells that are no longer in place), and a new contour map of PCP
contamination in the upper surficial aquifer was constructed. This data is illustrated in Figure 6.3.
This updated map does not differ considerably from the original maps included in the 1986 ROD
and 1990 AROD, but the new analytical data appears to further define the western and southern
(downgradient) extent of the PCP plume in the upper surficial aquifer. It is assumed that PCP
contamination, noted in the historical borehole data, is still present on-site.
•
The reliability of the data used in this AROD to accurately define the extent of ground water
contamination is questionable due to the use of analytical methods with quantitation limits (50 to
200 /ig/1) significantly above the anticipated cleanup level. Therefore, additional groundwater
data will be collected during RD to accurately define the PCP plume.
PCP-laden oil, or free-product, has been observed in the southeastern section of the Site;
however, limited data is available on its extent. In March 1994, EPA placed seven boreholes
along the southern portion of the Site and found no measurable oil. There was however
measurable oil in a two inch pipe just south of the Site boundary. At this time it appears that the
free product is localized in pockets and not in a distinct plume. Since there is not enough
documentation at this time to estimate the volume of free-product, further characterization will be
conducted during RD.
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ct-i SOL
••07 SOL CM»U. OCT.. WC2
SB-7 KOCCHT S«Mfl£.OCT..««2
PMM SOL
MBSS SOL SMTLt. AMC
COL.MC
KCCMKK. «M
CM
MJJON OOXW
DTMATCO VALUE
3 FJMTS rot MJ.OH **M> POP CONTOUR
100
Figure
Interim Dioxin and Final PCP Soil and Sediment Contamination Boundaries,
Coieman-Evans Wood Presenting Site, Whitehouse, Florida
Calanat-'Lwa Wood Prom-ing
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''• ."! O 7
u u 2.3
Table 6.2 Characteristics of Contaminated Soft in the Process and Landfill Areas.
Source: Focused Feasibility Study, April 1995
••Characteristic
PCP(mg/kg)
Dioxin/Furan (TEQ)(^g/l)
Total Petroleum Hydrocarbon
(mg/kg)
Total Organic Carbon
(mg/kg)
Total Chloride (mg/kg)
Ash (%)
BTU (MJ/kg)
Abrasiveness
(Wt. loss rate mg/hr)
Organic Content (%)
% Gravel, > #10 mesh
•/• Sand, < #1 0 - > #200 mesh
% Clay & SDt, < #200 mesh
Process.; h,;::;;:--V:.:'
Area
6300
43
49,000
180,000
62
93
2.9
8-11
6.4
2
92
6
Landfill
Area
16
23
2200
170,000
60
68
64
25 - 29
28.3
7
80
13
Cotemtn-EvBB Wood Prccerving
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LEGEND
CREEK
— X— FENCE
C ' BUilDtNG
—•» — ISOCONCEWTRATION CONTOUR UNE
• MOwrroR wtu
(CONCENTRATIONS IN ug/L POSTED)
-N-
!
WOTI: Thi* o»*y to • ooapoOU «f
iwraiu
GRAPHIC SCALE
250 0
500
tb«
5 9 -'uvl-24
Figure 63: Updated Ground water PCP Concentrations in tbe Surficial Aquifer (1980,
1983,1985,1994), Coleman-Evans Wood Preserving Site, Wbitebouse,
Florida; Source: Focused Feasibility Studj, April 1995
15
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j
Analytical results from groundwater samples collected from monitoring wells screened in the
deeper limestone aquifer during 1980-85 show that the deeper limestone aquifer is not
contaminated with PCP. During the 1994 sampling event, only one deeper limestone aquifer
sample had any detectable PCP. This was from monitoring well MW-56 which had a PCP
concentration of 12 Mg/kg. The first set of sampling data demonstrated that the upper surficial
aquifer is unlikely to impact the deeper limestone aquifer, therefore, it is doubtful that the
contamination from the upper surficial aquifer has contaminated the deeper limestone aquifer.
Monitoring well MW-56 is located near the area where free-product has been observed and high
levels of PCP have been reported in the upper surficial aquifer. It is suspected that monitoring
well MW-56 is providing a conduit for PCP-contaminated groundwater from the upper surficial
aquifer to the deeper limestone aquifer. The monitoring well cluster (consisting of MW-55 and
MW-S6) will be re-sampled during RD to confirm EPA's conclusion that the deeper limestone
aquifer is not contaminated. If necessary, MW-55 and MW-56 will be plugged, abandoned, and
replaced.
No dioxin contamination has been identified in groundwater from the upper surficial aquifer or
deeper limestone aquifer. Dioxin is generally not mobile in the groundwater environment;
therefore, the theoretical potential for future migration is low. However, since dioxin and PCP is
associated with the free-product found at the Site, the carrier fuel oil may expedite their
movement through the groundwater.
6.4 Contaminant Fate and Transport
The primary contaminants of concern for the Site are PCP and dioxin. These contaminants of
concern have migrated from the source areas on-site as evidenced by the off-site contamination.
The migration pathways appear to be basically lateral, in other words; floating product, dissolved
aqueous phase, and runoff. The surficial soil contamination appears to be consistent with surface
water patterns. There are two particular sources of concern. First, the floating product has been
observed on-site, but not fully characterized; and second, in deep contamination areas around
boreholes 38, 40, and 44, which are in the surficial aquifer.
Predicting contaminant fate can be done, but, requires the organization of complex Site
characterization data for each contaminant of concern. This data assists in determining where a
specific waste compound is located, where it is going, how fast it is moving, and what types of
environmental degradation or chemical transformation it is undergoing in the process. This
knowledge enables prediction of the persistence, mobility, rate of transport, and migration
pathways of a given contaminant, as well as its concentration and toxicity, both in place and
during environmental transport. This type of modeling has not been done for the Site.
Before groundwater transport modeling can be done at the Site the following data would be
needed: 1) saturated soil samples must be collected and analyzed for total organic carbon, bulk
density, percent clay, and PCP contamination; 2) co-located groundwater samples must be
collected and analyzed for PCP at the same time.
I-
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At this point, no air pathway analysis has been performed. There is a series of Air Superfund
National Technical Guidance Studies that can be utilized during the RD to estimate the air
emissions during cleanup.
7.0 SUMMARY OF SITE RISKS
A baseline risk assessment is conducted to determine whether a Superfund Site poses a current or
potential threat to human health and the environment in the absence of remedial action. The
baseline risk assessment provides the basis for determining whether or not remedial action is
necessary and the justification for performing remedial action.
A Public Health Evaluation was developed in 1986 based on the presence of PCP, the only
contaminant of concern known at the time. Since subsequent sampling has indicated the
widespread presence of dioxin, a Focused Baseline Risk Assessment Addendum was prepared in
1996 to supplement the 1986 evaluation.
7.1 Summary of 1986 Public Health Evaluation
In order to assess the current and potential future risks for the Site, a Public Health Evaluation
was performed as part of the remedial investigation in 1986. This evaluation identified only PCP
as a contaminant of concern.
7.1.1 Identification of Potential Receptors
Potential receptors of Site contamination are the residents of Whitehouse, Florida, who live in the
vicinity of the Site, and the users of private water supply wells located down-gradient of the Site.
Approximately six homes in Whitehouse share a common boundary with the She. All of the
residences in the vicinity of the Site use private wells as a source of drinking water. It is
estimated that there are 180 domestic wells within a one mile radius of the Site and 1,620 wells
within a three mile radius of the Site. Several homes are downgradient and very close to the Site
and their wells may be candidates for contamination from wastes percolating into the surficial
aquifer, which may supply these wells. The Florida Department of Health and Rehabilitative
Services (MRS) has been sampling private wells for PCP and metals within the immediate vicinity
of the Site since 1990 and has found the water safe for human consumption.
•
7.1.2 Identification of Exposure Pathways
Based on the considerations of potential receptors and migration characteristics of PCP, the
evaluation identified five exposure pathways. The current industrial exposure pathways identified
in the 1986 Public Heahh Evaluation are:
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0027
1. Ingestion and dermal contact with contaminated soil.
2. Inhalation of airborne particles.
3. Dermal contact with surface waters.
The future residential exposure pathways identified in the 1986 Public Health Evaluation are:
4. Ingestion of contaminated groundwater.
5. Ingestion of vegetables grown in contaminated soil.
Potential exposure levels were determined for each pathway based on the mean and maximum
concentration of PCP detected in the appropriate media.
7.1.3 Risk Characterization
A hazard index (HI) value was calculated for each of the five pathways. All three current
exposure scenarios yielded HI values well below 1.0 indicating that no health risk would be
anticipated. However, both future exposure scenarios gave unacceptable HI values. Potential
future exposure (by ingestion) to the maximum detected level of PCP in water from the surficial
aquifer gave an HI value of 12. The consumption of root crops irrigated with this water could
produce exposure to PCP in consumers at an HI level of 4.
This 1986 Public Health Evaluation concluded that the potential future exposures to unacceptable
levels of PCP in groundwater, plus the existing soil source of PCP discharge to groundwater,
necessitates remediation of the Site.
Potential environmental effects may also occur from contaminants observed in surface waters
associated with the She. The surface water concentrations of PCP alone indicate that the Site
poses a threat to aquatic species.
7.2 1996 Focused Baseline Risk Assessment Addendum
The majority of waste generated by the wood preserving operation were managed, treated, and
disposed of on-site throughout the Site's history. The 1986 Public Health Evaluation determined
that Site-associated contamination could be localized to both soil and groundwater. To develop a
list of indicator chemicals (i.e., chemicals of potential concern), soil sampling data for metals were
compared to blanks as well as to textbook background values (Conner and ShackJette, 1977).
According to the 1986 evaluation, the final list of contaminants did not include any metals since
their concentrations were "within or close to the normal range present" in the Site area
The organic contaminants detected most frequently in on-site soil samples, according to the 1986
Public Health Evaluation, was PCP. Other organic contaminants detected on-site included
tetrachlorophenol, napthalenes, alkanes, and xylenes. Also, dioxin was detected during the
screening of five surface samples, with the highest concentration being 0.1
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Considering the distribution, toxicity, persistence, and mobility of the contaminants at the Site, the
1986 Public Health Evaluation concluded that the indicator chemicals be narrowed to include PCP
(primarily because of its widespread presence) and total xylenes.
According to the 1996 Focused Baseline Risk Assessment Addendum, xylene was not considered
a potential chemical of concern due to its low toxicity and the fact that the detected concentration
did not exceed the residential toxicity screening level of 16,000 mg/kg Also, dioxin (and hs
congeners) was added as a potential chemical of concern based on it being identified as a
widespread contaminant.. Consequently, PCP and dioxin are the chemicals of potential concern
that were carried through the calculations performed as part of the 1996 Focused Baseline Risk
Assessment Addendum. For the purpose of the 1996 Focused Baseline Risk Assessment
Addendum, contaminants were subdivided into four separate areas based on the PCP
contamination pattern: 1) on-she inside of the known PCP boundaries, 2) on-site outside the
known PCP boundaries, 3) off-site inside of the known PCP boundaries, and 4) off-site outside of
the known PCP boundaries.
7.2.1 Exposure Assessment
The 1986 Public Health Evaluation calculated a "Most Probable Case" exposure concentration by
determining the geometric mean of the detected contaminants (using one half the detection limit
when the detection limit was less than the minimum reported concentration). The "Realistic
Worst Case" concentration reflected the maximum detected concentration for each contaminant.
The reasonable maximum exposure (RME) point concentration term was calculated based on the
distribution of contamination as presented in the 1995 Focused Feasibility Study. Whenever
greater than two samples were collected, a log normal distribution was predicted statistically (W-
Test), as also seen in Table 7.1. Also, in all cases (except for PCP localized to the "On-Site
Outside Known PCP Boundaries" area), the RME log normal concentration was greater than the
maximum concentration. Therefore, the maximum concentrations were used in the calculations
per EPA guidance. It is important to note that the "maximum concentrations" used in the 1996
Focused Baseline Risk Assessment Addendum may not represent the actual maximum
concentrations that have been detected at the Site. Use of concentrations less than the actual
maximum concentrations does not change the conclusions reached for the Site. The dioxin RMEs
for the on-site areas, inside and outside the known PCP boundary were 31 Mg/kg and 72 Mg/kg,
respectively. The corresponding PCP concentrations were 430,000 Mg/kg and 220,000 Mg/kg
respectively. The dioxin RMEs for the off-site areas, inside and outside the known PCP
boundary, were 10 Mg/kg and 38 Mg/kg, respectively. The corresponding PCP concentrations
were 360,000 Mg/kg and 25,000 Mg/kg, respectively.
CotantD-EvHB Wood Preserving
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Table 7.1 Reasonable Maiimum Exposure Point Concentrations for Contaminants of
Potential Concern
•-.- ';• ; 0 Oolite laildcKMnraPCPBouiHlariet . . '
Chemical
Dioxin
PCP
Range of Detected
Cone (Mf/lcc)'
0.0077-0.031
8.7-430
95*4 UCL
Concentration
0.0349
34,600
W-Tert
Number
0.8
0.9
Distribution
Lognomud
Lojuioiiiial .
RME Exposure
Point Cone*
0.031
430
Source of
RME
Maximum
Maximum
... . •.-.-.•.. ":.;..•.:;. - •. •-•• ••••• ••::•••••-•.,.-•• . .V" " / •.••/-.-•;'•.•••-.
: Co-Site Outride KBOWD PCP Boundaries
Chemical
Dioxin
PCP
Range of Detected
Cone (me/kg)1
0.000022-0.072
0.57-240
95% UCL
Concentration
7.13
220
W-Test
N amber
0.87
0.85
'Distribution
Lognormal
Lognormal
RME Exposure
Point Cone.1
0.072
220
Source of
RME
Maximum
95% UCL
off-jjtf Inside Known PCP Boundaries
Chemical
Dioxin
PCP
Range of Detected
Cone (ing/kg)'
N/A-0.01
N/A - 360
95V. LCL
Concentration *
NC
NC
W-Test
Number'
NC
NC
Distribution *
ND
ND
RME Exposure
Point Cone '
0.01
360
Source of
RME
Maximum
Maximum
Off-die Outside Known PCP Boundaries
Chemical
Dioxin
PCP
Range of Detected
Cone (me/kg)1
0.0000060-0.038
0.13-25
95V. UCL
Concentration '
NC
NC
W-Tert
Number*
NC
NC
Distribution *
ND
ND
RME Exposure
Point Cone '
0.038
25
Source of
RME
Maximum
Maximum
•AU<
until
I vein proper million TEQ. AH PCP ceoccmraSMo* •» o> pato per million. All d*u for the *oD4itr* md-eff-tiu* vtw vt ficoi *e 1992
•mplms tauid (T>* * «. • douibcd m Ae 1995 FooMd Fusibility Study)
*KDMiaiaaiiith(oilculitien««noidcunniMdnnectiMrrwMeB)yen(artwa«np1« VC «>dK«««nh«t the ocmspoodnj vtlue i
NA wAatm um ne omucnBiucn mat couM be aagmaed toe* tun wit only out tanple
' RME fjpemn Poet CeDcontioB a the mwnmrni oBoeemuoe (• W0M^ byte 19(6 IhMkHetflhEvihiuioD for the Co)em».£vBiSnc)«id«fRiMdmlb«
dcucud « tbc Siu UK rf eeeeaantieai ka mn the »en«l miuncn ooooaBntiora deo not cfaa«e the eoBelwian ra*ched forth*
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7.2.2 Identification of Exposure Pathways
According to the 1986 Public Health Evaluation, two potential exposure pathways were presented
at that time with respect to soil contamination. The current scenarios included a worker scenario
(reflective of the plant during its operation) and a trespasser scenario ("persons living in or visiting
areas in the vicinity of the Site"). The document concluded that the worker exposure is likely to
occur more frequently and to higher contaminant concentrations and thus was the only scenario
carried through the risk assessment process. For the future scenario, the 1986 Public Health
Evaluation developed two scenarios for groundwater only. These included a plant uptake of
chemicals from solution (e.g., "soil water") and a residential groundwater ingestion pathway. The
1996 Focused Baseline Risk Assessment Addendum concurred that the worker scenario is the
best representative of current land use and thus carried H through the updated analysis for on-site
contamination. However, since the Site is near a residential neighborhood and thus could
potentially become a residential area, a future residential scenario (child only) was evaluated for
on-site contamination. Additionally, off-site contamination was not characterized prior to the
1986 Public Health Evaluation. Thus, since recent sampling indicates that contamination has
migrated off-site, an off-site residential scenario is considered complete and calculated under both
current and future scenarios. Table 7.2 lists the complete exposure pathways associated with the
Coleman-Evans Site.
Table 7.2 Potential Human Exposure Pathways Under Current and Future Land Use
Exposure
Medium
Surface
Soils
Exposure Point
Soils associated
with the on-site
area.
Soils associated
with the off-site
area.
Potential
Receptor
Workers
(current)
Resident
(future)
Resident
(current
aduhand
child
Resident
(future
aduhand
child
Potential Routes of
Exposure
Incidental ingestion,
dermal absorption,
paniculate inhalation
Incidental ingestion,
dermal absorption,
paniculate inhalation
Incidental ingestion,
dermal absorption,
paniculate inhalation
Incidental ingestion,
dermal absorption,
paniculate inhalation
is Pathway
Valid (basis)
Yes, surface soil
is available for
direct contact
Yes, surface soil
is available for
direct contact
Yes, surface soil
is available for
direct contact
Yes, surface soil
is available for
direct contact
Quantitative vs
Qualitative Evaluation
Quantitative for ingestion
only-evaluation based on
surface soil samples
Quantitative for ingestion
only-evaluation based on
surface soil samples
Quantitative for ingestion
only-evaluation based on
surface soil samples
Quantitative for ingestion
only-evaluation based on
surface soil samples
Note: • The worker is the most probable on-sitt current eqmsurt scenario, for the future, child and adult residential on-*itc scenario if considered
likely and therefore the pathwiy is assumed to be complete. Off-site current and future ocpocurt pathways include residential (child and
aduh) receptors. Although all exposure routes are considered complete, the risk assessment addendum only calculates risks based on
sofcflioo only.
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$9 0031
7.2.3 Summary of Exposure Assumptions
The 1996 Focused Baseline Risk Assessment Addendum utilized the following exposure
assumptions for the pathways identified at the Site.
Current Worker - The risk assessment assumed an on-site worker with 8 hours of
exposure a day, at 250 days per year, for 25 years. It assumed a 70 kg adult that would
incidentally ingest 50 mg of soil per day.
Future Child Resident • The risk assessment assumed a 1-6 year old on-she resident with
an average body weight of 15 kg. It assumed the child would ingest 200 mg of soil per
day, 350 days per year, for 6 years.
Future Adult Resident - The risk assessment assumed an off-she adult resident with an
average body weight of 70 kg. It assumed the adult would ingest 100 mg of soil per day,
350 days per year, for 24 years.
For current land use, the worker assumptions that approximated current risk assessment
parameters are drawn from the 1986 Public Health Evaluation with additional parameters selected
from various recent guidance documents. However, all citations in the tables are from the most
recent reference sources. The adult worker is on-site 250 days/year for 25 years with an ingestion
rate of 50 mg/day (OSWER 9285.6-03). In the on-site future and off-site current and future
exposure scenarios, exposure assumptions are adopted from the most recent guidance documents.
The child resident (1-6 years of age) ingests 200 mg of soil per day and is exposed 350 days per
year for 6 years (OSWER 9285.6-03). For the future off-site land use, the adult resident ingests
100 mg of soil per day and is exposed 350 days per year for 24 years (OSWER 9285.6-03) . A
complete list of exposure assumptions used in the 1996 Focused Baseline Risk Assessment
Addendum are included in Tables 7.3 and 7.4.
7.2.4 Toxicity Assessment
The toxicity for the two chemicals of potential concern, dioxin and PCP, are described in this
section. The Integrated Risk Information System's (IRIS) information is presented in Table 7.5.
For dioxin, there is no chronic oral reference dose (RfD) according to IRIS. However, the oral
slope factor (slope) is 1.5x10"'. The chemical is considered to be a class B2 carcinogen. PCP has
an oral RfD of 0.03 mg/kg-day and a slope of 1.2 xlO'1 reflective of its class B2 classification,
both according to IRIS.
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Table 73: Exposure Parameters for Incidental Ingestion of Contaminants in Surface
Soils Under Current and Future Land-Use On-Site
fto-Bu Scenario Parameter
Age Period
bgMbc* Rate (mg toil/day)"
_^. . ., • . ^^
(UnWess)*'
Exposure Frequency (dtyi/ycar) *>
Exposure Duration (yean) *
BodyW.igbt
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5 9
OC33
Table 7.4: Exposure Parameters for Incidental Ingestion of Contaminants in Surface
Soils Under Current and Future Land-Use Off-site
Ott-tttt Scenario Parameter
Aft Period
fegeaicci Rate (mg sojVday) *>
(Unities*) •'
Exposure Frequency (days/year) *»
Exposure Duration (yean) •?
Body Weight (kg)"
Averaging Tin* (nonearcHMfens:4iys/life) *
Averaging Time
Aduh (noncancer/cancer)
Quid R«fUent
14 years of age
300 - OSWER 9283.6-03
1.0 EPA/540/l-f9/002
330 OSWER 9283.6-03
6 OSWER 9283.643
13 OSWER 9283.6-03
2100 EPA/340/J49/D02
23330 EPA/340/149/002
1J3E-05 MOE-06
A4n)t Rcttdent
1-6 yon of act
100 OSU'ER 9283.6-03
1.0 EPA/340/1-89/002
330 OSWER 9283.643
24 OSWER 9283.6-03
70 OSWER 9283.6-03
•400 EPA/540/1 -89/002
23330 EPA/340/1 -89/002
1 43E-06 4.70E-07
(a) The toil natation mat are default values at rtfereooad for children of the aac range 14 and adults.
(b) A«nm>esthalalJoflbeioilin««»»ed«wieifiwnlhtSae'»coiiUmin»ledafeai
(c) The exposure frequencies arc defaults for a child and aduh resident as referenced.
(d) The closure durations are defaulu for a child and adult resident at referenced.
(e) Body weights are defaulu for a child and adult resident as referenced.
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,
ut
Table 7.5: Oral Toxicity Values for the Contaminants of Potential Concern
Ocarical
Dioxin
FCP
OraakOnl
RcfemccDoae
(Rfl>)(B|1«.
4.v)
— «
3.00E42
Itoccnataty
•Factor
^4
too
T0f«t
' Organ/ • -..:
Ottka)
Effect
— «
Liver and
Kidney
«fl>
-'. ••
• • JPvW
IRIS1
IRIS*
Oral Skip*
Factor
Xtl/ltC-toy)-!
1.3x10**.
1.2 xlO"
Weight of
Evidence
dan
B,
B,
Slope Factor
Source
Heasf
IRIS1
Uncertainty facton preatnud art the product* of apac&tmccrumtyiacun and modtrymg factors. Uncertainty factors uacd to develop
reference dotes generally comifl of multiple* of 10, with each factor raprcMotiag a ipecific area of uoeenatnty in the date of the major
Mudy. Standard factors are lined: a factor of 10 for variation ip aeositivity araoog meaiben of the buman population. 10 fold factor to
account for uncertainty m extrapolating from animal data to humam, 10 fold factor for the uncertainty in extrapolating from tot-than-
ebronk NOAEL* to chronic NOAEU, and a 10 fold factor for the uncertainty in extrapolating from LOAEU to NOAEU
DUS t> the btefraiad Ride information Synem.
Head if die Health Effect* Aneanem Summary Tables.
— Indicata that toxieity values arc not available.
Dioiin
Chlorinated dibenzo-p-dioxins are a class of compounds that are commonly referred to as dioxin
There are 75 possible dioxins of which 2,3,7,8-TCDD is the most widely studied and is believed
to be the most toxic. It is colorless and odorless and does not occur naturally and is not
intentionally manufactured except as a reference standard. It is in-advertently produced in very
small amounts during the manufacture of certain herbicides and germicides while it is also a by-
product from the incineration of municipal and industrial wastes. It also is formed in the
manufacture of pulp and paper, the burning of wood in the presence of chlorine, the accidental
burning of transformers and capacitors, and the burning of leaded gasoline by automobile engines
(ATSDR, 1989).
2,3,7,8-TCDD and related compounds are extremely potent at producing a variety of effects in
experimental animals at levels hundreds of thousands of times lower than most chemicals of
environmental interest. Based on animal studies, the effects of dioxin include wasting syndrome,
teragenesis, fetal toxieity and mortality, endocrine effects, immunotoxichy, carcinogenicity,
chloracnegenic effects, porphyria, hepatotoxicity, edema, testicular atrophy, and bone marrow
hypoplasia The no-observable-adverse-effect-level for this compound is believed to be below
1.0 ng/kg. The developmental effects in infants, based on Yusho and Yu-Cheng rice oil poisoning
episodes, include mild effects such as accelerated tooth eruption and effects on the skin, nails, and
Meibomian glands while more adverse effects include growth retardation, deficit in cognitive
function, and effects on the developing reproductive system, immune system, and altered learning
Cokman-EvaiB Wood Preurving
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behavior. Cleft palate, hydronephrosis, and reduced spermatogenesis were observed in the
offspring of pregnant female rats and mice that were exposed to dioxin. In adult animals,
alteration of immune Junction and increased susceptibility to infectious diseases was also observed
in studies involving rodents, guinea pigs, rabbits, monkeys, marmosets, and cattle. It also
decreases circulating testosterone, increases the risk of developing diabetes, and increases the risk
of developing endometriosis (EPA, 1994a).
PenUchloroohenoI
Commercial PCP preparations contain impurities that include hexachlorobenzene, polychlorinated
dibenzo-furans, and polychlorinated dibenzo-dioxin. It is difficult to determine the extent to
which the toxicity of the commercial products are due to PCP or to the very toxic impurities. The
PCP used in comparative studies is generally free of impurities. PCP is rapidly absorbed
following oral, dermal or inhalation exposure. Absorption following ingestion of drinking water is
reported to be essentially complete. Absorption following inhalation has been reported to be in
the range of 76-88 percent.
There is a large amount of human epidemiological studies describing that long term exposure to
low levels of PCP can cause damage to the liver, kidneys, blood, immune system, and nervous
system. Inhalation exposure causes inflammation of the upper respiratory tract and bronchitis.
The primary cardiovascular effects observed in humans was tachycardia. Hematologic effects
include hemolytic anemia as well as the onset of aplastic anemia and pure red blood cell aplasia.
Also, PCP exposure causes increased numbers of immature leukocytes and reduced glomerular
filtration rate and tubular function. Dermal and ocular effects range from eye and nose irritation
and inflammation of the skin and subcutaneous tissue to extensive cysts and pus-forming abbesses
prominently over the face, chest, abdomen, and proximal part of the extremities. PCP may also be
linked to habitual abortion, unexplained infertility, menstrua] disorders, and the onset of
menopause. In neurological studies, adverse effects in the central nervous system were observed.
In cancer studies, PCP was associated with Hodgkin's disease, soft tissue sarcoma, and acute
leukemia. However, this carcinogenicity was not corroborated by other epidemiology studies or
animal studies (ATSDR, 1994).
7.2.5 Risk Characterization
The non-carcinogenic hazard indices (sum total of the hazard quotients) for the chemicals of
potential concern are listed in Table 7.6. For the on-site current worker and future resident, the
hazard indexes for PCP, both within and outside the known PCP boundaries, are less than 1. Off-
site, the current and future resident hazard indices, both inside and outside the known PCP
boundaries, are less than 1.
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Table 7.6: Non-Cancer and Cancer Risks Associated With Exposure to Surface Soils
Under the Current and Future Land Use Scenarios
ON-SITE INSIDE KNOWN FCf BOUNDARIES
—
Dhncin
Kf
Toul
Non-oi UuuiuJc
Ctavrrni Worker ;
l»ft*tkm DaaeflUD
Ratio
ND
0.0)024
0.01024
Future RaMoa
Ia|«»tioo Dece/RID
Ratio
ND
0.19111
0.19111
* CurteofcBJe
•OoratW«iitrr
iaj|tiflon Boat X Step* .
Product
S.12E-04
9.02E-06
I.2E-04
fetor* Reddent
lAtcstion DOM X Slop*
Product
5.10E-03
5.65E-05
5.1SEX)3
ON^SFTE OUTSIDE KNOWN PCF BOUNDARIES
_
DmoB
Kf
Toul
NoB-carcteofeBic
Carnal Worker
JuftMoa DoM/RO)
Rrto
ND
0.00524
0.00524
fmtmn RoUcnt
lafcftlan Dow/RID
Ratio
ND
0.09778
0.09778
Cudnofcnic
Current Worker
Ia*«*tkui Doac X Slope
Prodort
1.89E-03
4.61E-06
1.89E-03
Future Resident
IB| erfon DOM \ Slope
Product
1.18E42
2.89E-OS
1.19E-02
OFF-SITE INSIDE KNOWN fCf BOUNDARIES
' —- •
Dioxin
PC?
Toul
Nofft_«tt*«4ima«alf
RcrtdMMQdld
lafotfoa Dotc/RfD
Ratio
ND
0.16000
0.16000
VfliUtnf AAnli
Infottoo DoM/RfD
Ratio
ND
0.017H
0.01714
CardnotcnJc
RdM«wCMM
Infotfon DOM X Slope
Product
1.64E-03
4.73E-OS
1.69E43
Reddest Adah
inf extion DOM X Slope
Product
7.05E-04
2.03E-05
7.25E^)4
OfT£ITE OUTSIDE KNOWN PC? BOUNDARIES
Chilled
Dmda .
Kf
Toul
Nan-cafcfcjWftnk
RaMcMCkiU
infection DoM/Rfl)
Ratio
ND
0.01111
0.0111
RaMeat A4rt
J»|MtiafiDoM/Rn>
Ratio
ND
0.00119
0.00119
urdnofciuc
Raddent CbDd
iBtcatfoH Doac X Slope
Product
6.25E-03
3.29E-06
6.25E-03
RMMeMAdoh
latotioa DOM X Soft
Product
2.68E-03
1.41E-06
2.68E-03
Colenun-EvaiB Wood Prewrvmg
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The carcinogenic risks for the chemicals of potential concent are also listed in Table 7.6. For the
on-site current worker and future resident, the total cancer risks for PCP and dioxin are 8.2x10"*
and 5.2x1 O*3 respectively inside the known PCP boundary. Outside the PCP boundary, the
current worker and future resident's total cancer risks for PCP and dioxin are 1.9x1 O*3 and
1.2xlCT2, respectively. Off-she, the current and future resident's carcinogenic risks are 1.7x1 O*3
(child) and 7.3x1 CT* (adult) respectively inside the known PCP boundaries. Outside the known
boundaries, the carcinogenic risks to the current and future residents are 6.3x10'3 and 2.7xlO*3,
respectively.
Clearly, unacceptable risk levels of greater than 1O*4 are located in all areas both on-she and off-
she. However, the hazard indices for PCP are all less than unity. Thus, the cancer risks support
remediation using either scenario.
Overall, dioxin is one of the most toxic substances known. It exhibits delayed biological
responses in many species and is highly lethal at low doses. It is persistent (10 year half-life) and
bioconcentrates readily (5000 I/kg, EPA, 1986). Thus, h is a threat to both terrestrial life as well
as aquatic life. The most toxic forms of dioxins and furans are comprised of chlorine atoms at the
2,3,7, and 8 positions (Sittig, 1985). PCP will not readily evaporate in environmental media in
that its volatization half-life, under ideal conditions, is greater than 100 days (EPA, 1982) and its
predicted biodegradation rate is 18 percent in 7 days (Dragun, 1988). Its bioconcentration factor
is 770 I/kg (EPA, 1986) indicating that it too will bioaccumulate, but not as readily as dioxin.
Therefore, the persistence, toxicity, concentration, and potential for adverse health effects based
on the exposure scenarios presented, all support the need for remediation.
7.3 Remedial Action Objectives
Remedial Action Objectives consist of medium-specific or Site problem area-specific goals for
protecting human health and the environment. Remedial Action Objectives are established under
the broad guidelines of meeting all Applicable or Relevant and Appropriate Requirements
(ARARs). During the development of Remedial Action Objectives, other regulatory guidance and
criteria to be considered and risk-based values are evaluated to establish preliminary remediation
goals.
Remedial Action Objectives are accomplished to the maximum extent practicable through
treatment and/or destruction of contaminants at the Site. However, protection of the environment
can be accomplished by addressing sources of contamination and limiting migration of
contaminants from source areas to receptors.
The objectives of this interim response action are:
• Prevent ingestion/direct contact with contaminated soils and sediments in excess of
the interim dioxin and final PCP cleanup levels.
Colenun-Evins Wood Preserving
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Protect groundwater as a current or potential drinking water supply, by reducing
contaminants to Maximum Contaminant Levels (MCLs) or other protection levels
established by EPA and FDEP.
Prevent future groundwater contamination. .
7.4 Groundwater Cleanup Levels
The 1986 ROD and the 1990 AROD addressed remediation of groundwater that is collected
during excavation of the source materials. Groundwater clean-up and surface-water discharge
levels were established for PCP. The cleanup criteria as specified in the 1986 ROD and 1990
AROD is still applicable, however in this ARO, EPA is adding a cleanup level for dioxin and
setting a more stringent cleanup level for PCP.
Although no dioxin contamination has been found in the groundwater at the Site, it is suspected
that dioxin and PCP laden fuel oil tied up in soils, may release dioxin to the groundwater over
time. Therefore, setting a cleanup level for dioxin is necessary. The permissible concentration for
dioxin in drinking water is very stringent. The MCL for 2,3,7,8-TCDD is 0.03 ng/1. The one and
ten day health advisories for 2,3,7,8-TCDD are 1.0 ng/1 and 0.1 ng/1 respectively for children and
adults respectively. The lifetime health advisory for an adult is 0.035 ng/1 (EPA, 1996).
There is a specific State drinking water standard for PCP, but not for dioxin. The drinking water
standard for PCP is 1 .0 ^g/1. The MCL for PCP is also 1 .0 //g/1. The State of Florida has also
published a drinking water criterion for dioxin, which is not a standard, but can be implemented
on a site specific basis. The carcinogenic based criterion for dioxin is 3 x 10"* /
Based on guidance concentrations for dioxin in ground water, EPA and FDEP have established 1 .0
ng/1 as the groundwater dioxin cleanup level for the Site. The 1 .0 ,ug/l cleanup level for PCP in
groundwater is based on site-specific calculations that are protective of groundwater.
7.5 Soil and Sediment Cleanup Levels
Cleanup levels were established to ensure that any persons exposed to Site soil and sediment in
the future will not be exposed to unsafe levels of Site-related chemicals. The cleanup levels
determined for this Site are shown in Table 7.7 and a summary of how these levels were
determined is included in Sections 7.5.1 and 7.5.2.
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Table 7.7:
Cleanup Levels for Soil and Sediment at the Coleman-Evans Wood
Preserving Site
Constituent
Pentachlorophenol
Dioxin*
Cleanup Level
2.0 mg/kg
1.0/zg/kgb
* Interim cleanup level for dioxin and furans and all their congeners
*. 1989 Toxitity Equivalents
7.5.1 Pentachlorophenol
The cleanup level for PCP is based upon the protection of ground water. In September 1995,
FDEP issued a memo regarding "Soil Clean-up Goals for Florida." This memo gives two
equations for calculating cleanup goals; the first equation is based on direct exposure to
contaminants in the soil via ingestion and dermal contact. The second equation is based on
leaching of organic contaminants to groundwater. The memo also includes a table of cleanup
levels (excluding dioxin) that were calculated using the above mentioned equations and generic
assumptions regarding exposure and soil characteristics. The PCP cleanup levels from the table
are 5.4 mg/kg (residential) based on direct contact, or 0.01 mg/kg based on leaching. The memo
states: "The lowest of the two should be the final cleanup goal..." Based on this memo the PCP
cleanup level for the She would be 0.01 mg/kg based on leaching. FDEP does, however, allow
deviations from the leaching criteria based on a site specific evaluation.
EPA requested the Emergency Response Team to evaluate the 0.01 mg/kg cleanup level for the
Site. The evaluation involved assessing the proposed cleanup level itself, comparing it to EPA's
leach-based Soil Screening Level (SSL), applying site specific values to calculate a SSL,
performing leach tests to calculate a SSL, evaluating whether a leach based or a direct contact
based cleanup level is more appropriate, and evaluating how the use of various SSLs as cleanup
levels will affect remediation of the Site.
The SSL was determined by performing leach tests on two Site soil samples. The leach test used
was the Synthetic Precipitation Leaching Procedure (SPLP). The results of the SPLP leach data
are shown in Table 7.8.
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Table 7.8: SPLP Test Results in Soil at the Coleman-Evans Wood Preserving Site
Sample Location
AreaB
AreaD
Initial Concentration
(mg/kg)
0.12
5.9
pHSLeachate
Concentration G/g/1)
1.3
2.7
pH 8 Leachate
Concentration (Mg/I)
0.5
2.0
When the data in Table 7.8 is plotted, the SSL for a soil pH of 5 lies outside the range of data and
was not calculated. The SSL for soilpH of 8 is approximately 2 mg/kg. Since the average pH of
the Site soil is 8.0, the SSL for the Site based on the SPLP leach test is 2 mg/kg. The results
indicate that the generic assumptions used in FDEP's policy memo are not representative of Site
conditions, therefore, a PCP cleanup level of 2 mg/kg represents the actual cleanup level that is
protective of groundwater at the Site.
7.5.2 Dioxin
EPA and FDEP are continuing discussions on the selection of a cleanup level for dioxin in
residential soil and sediment at the Coleman-Evans Wood Preserving Site. While these
discussions continue, EPA and FDEP agree that it is appropriate for EPA to select a soil dioxin
cleanup level of 1.0 Mg/kg (TEQ) as an interim cleanup level for residential soils at the Site.
EPA believes that this cleanup level is protective of human health and the environment, but that
the agencies should defer a final cleanup decision at this Site pending release of EPA's final dioxin
reassessment (embodied in the documents entitled "Health Assessment Document for 2,3,7,8
tetrachJorodibenzo-p-dioxin (TCDD) and Related Compounds" and "Estimating Exposure to
Dioxin-like Compounds") and pending an evaluation of the effects of the findings of the final
dioxin reassessment on Superfund dioxin cleanup levels. EPA's dioxin reassessment report,
which is expected to be finalized in 1998, will represent the culmination of six years of EPA effort
to collect, analyze, and synthesize all of the available information about dioxin. It has undergone
significant internal and external review and is one of the most comprehensive evaluations of
toxicity of a chemical ever performed by EPA.
EPA and FDEP both believe that information contained in the report may assist the two agencies
in determining a final cleanup level, either at 1.0 Mg/kg (TEQ) or some other value. Therefore,
EPA and FDEP believe it is appropriate to take an interim action at this time to achieve significant
risk reduction quickly while the reassessment is being completed. EPA will make a final remedy
decision following the release of the final dioxin reassessment and further discussions with FDEP.
Coleman-Evvu Wood Pmerving
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1.0 Atg/kg (TEQ) is an appropriate interim cleanup level for residential soils at the Site because it
is the level that EPA has generally adopted as a cleanup level for residential sites where dioxin is
driving the remedy and is protective of human health and the environment. Based on presently
available information, the cancer risk associated with a lifetime of exposure to this concentration
of dioxin is at the upper bound of the range of cancer risks that are generally acceptable at
Superfund sites. It is unlikely, given the preliminary information available from EPA's dioxin
reassessment, that the final cleanup level for the Site would be higher than 1.0 //g/kg (TEQ).
Accordingly, this interim action should not be inconsistent with the final remedy.
EPA notes that it may well select 1.0 ^tg/kg (TEQ) as the final cleanup level for this Site
following release of the dioxin reassessment. Although the reassessment will provide a more
comprehensive analysis of dioxin risk information than has previously been available, it may not
significantly alter the final cleanup criteria for the Site. Accordingly, EPA's decision to take an
interim, rather than a final, action at this point should not be interpreted as an indication that the
final level will necessarily, or likely, differ from the interim level.
In summary, rather than defer action at the Site, EPA and FDEP have chosen to set an interim
cleanup level as a basis for immediate action to achieve significant risk reduction while EPA
completes the dioxin reassessment and EPA and FDEP can determine how, if at all, its findings
should affect the dioxin cleanup level at the Site.
8.O DESCRIPTION OF ALTERNATIVES
Four alternatives are presented in this Amended Record of Decision for the remediation of
contaminated soil, sediment, and groundwater at the Site. These alternatives are discussed in
detail in the Focused Feasibility Study (FS) dated April 1995 and summarized in this section.
8.1 Alternative 1: No Action
This alternative consists of No Action at the Site for soil or groundwater. No action is evaluated
as a baseline against which the other alternatives can be compared. Under this alternative, several
natural processes may, to some extent, treat or destroy the compounds of interest. These natural
processes include bio-degradation, volatilization, photolysis, leaching, and adsorption. This
alternative includes no further action other than periodic monitoring of the groundwater.
Since no remedial activities would be performed, there would be no capital costs incurred for
Alternative 1. The only cost associated with this alternative relates to Operation and Maintenance
(O&M) for groundwater monitoring. Groundwater monitoring would be accomplished utilizing
existing monitoring wells plus additional new wells may need to be installed. O&M costs for
monitoring the contaminants of concern for soil and groundwater for the 30 year life of this
remedy is $574,000. These O&M costs are present value based on an assumed annual interest
rate of 7% and escalation at 4%.
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8.2 Alternative 2: Containment by Capping With Groundwater Recovery and
Treatment
This alternative consists of constructing a containment system within the Site boundaries. This
alternative includes excavating the contaminated soil and sediment from the area off-site and the
areas of deep contamination on-she, backfilling the excavated areas, and consolidating the
excavated soil within the containment area. A multi-layer RCRA-approved cap would then be
constructed over identified areas of contamination.
Groundwater recovery wells would be installed. All recovered groundwater both from excavation
and recovery wells would be treated to meet the performance standards established in the AROD
in an on-site water treatment system prior to discharge to an on-site drainage ditch. The system
would utilize granular activated carbon (and if necessary filters or flocculants) and would be
designed to treat a minimum of SO gallons of contaminated water per minute. Storm water and
sediment retention basins would be constructed (on-site or off-she) as needed to control surface
water run-off (pre-cap and post-cap construction). Security fencing would be installed around the
Site to prevent un-authorized access.
Containment systems such as this are designed to prevent erosion and direct contact with
contaminated surface soils and to control contaminant migration via air, surface water,
groundwater, and sediment pathways This alternative can be implemented with proven
construction techniques. Although the soil contamination is not destroyed or removed, human
health and environmental impacts would be minimized.
The total present worth cost for Alternative 2 is SI 0,384,552. This consists of a capital cost of
$2,789,552 in 1997 dollars (escalation costs excluded) based on a preliminary design for the cap
and construction/installation of the groundwater recovery and treatment system; and an O&M
cost of $7,595,000 to operate the groundwater recovery and treatment system for 30 years. This
O&M cost is present value based on an assumed annual interest rate of 7% and escalation at 4%.
8.3 Alternative 3: Incineration With Groundwater Recovery and Treatment
This alternative consists of thermally destroying the contaminants in the soil and sediment by an
on-site incinerator. This alternative involves excavating all contaminated soils, backfilling the
excavated areas, and then processing the material through an incinerator.
Three types of incinerators are widely used: rotary kiln, fluidized bed, and infrared conveyor.
Rotary kiln systems are the most commonly used systems. Incinerators generally have two
thermal chambers: the primary which operates between 600 °F and 1200 °F and desorbs the
contaminants, and the secondary chamber which operates between 1800 CF and 2400 °F and
Colenuft-Evvu Wood Framing
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destroys the contaminants. In addition to the thermal chambers, incineration systems are
composed of feed preparation, air pollution control, ash handling, and water treatment systems.
Groundwater recovery wells would be installed. All recovered groundwater both from excavation
and recovery wells would be treated to meet the performance standards established in the AROD
in an on-site water treatment system prior to discharge to an on-site drainage ditch. The system
would utilize granular activated carbon (and if necessary filters or flocculants) and would be
designed to treat a minimum of SO gallons of contaminated water per minute. Storm water and
sediment retention basins would be constructed (on-site or off-site) as needed to control surface
water run-off (pre-cap and post-cap construction). Security fencing would be installed around the
She to prevent un-authorized access.
Since the contaminants are destroyed, this alternative would result in significant reduction or
elimination of the potential health risks and environmental impacts resulting from the migration of
contaminants.
The total present worth cost for Alternative 3 is $26,454,962. This consists of capital costs of
$23,571,962 based on a cost of $300/ton to process 45,000 cubic yards of soil and sediment in
1997 dollars (escalation costs excluded); and an O&M cost of $2,883,000 to operate the
groundwater recovery and treatment system for nine years. This O&M cost is present value
based on an assumed annual interest rate of 7% and escalation at 4%
8.4 Alternative 4: Thermal Desorption With Groundwater Recovery and Treatment
This alternative involves desorbing the contaminants from the soil and sediment and treating the
condensed contaminants to a nontoxic form. As with incineration the material would need to be
excavated, and the excavated areas backfilled. The contaminated material could then be treated
on-site.
Thermal desorption is a two step process. The first step involves passing the soil through a
thermal chamber that elevates the soil temperature and volatilizes the contaminants. These
chambers generally operate in the temperature range of 300 °F to 500 °F with some commercial
units having upper operating limits as high as 1950 *F. Many of these units utilize non-oxidizing
gases (such as nitrogen) to prevent unwanted oxidation from occurring. The volatilized
contaminants are then captured by a train of air pollution control devices that collect and
concentrate the compounds into an off-gas or a condensed liquid for further treatment (e.g.,
dechlorination or incineration).
Groundwater recovery wells would be installed All recovered groundwater both from excavation
and recovery wells would be treated to meet the performance standards established in the AROD
in an on-site water treatment system prior to discharge to an on-site drainage ditch. The system
would utilize granular activated carbon (and if necessary filters or flocculants) and would be
Colcmin-EvBas Wood Pmcrvmg
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designed to treat a minimum of 50 gallons of contaminated water per minute. Storm water and
sediment retention basins would be constructed (on-she or off-site) as needed to control surface
water run-off (pre-cap and post-cap construction). Security fencing would be installed around the
She to prevent un-authorized access.
This alternative would resuh in a significant reduction or elimination of potential health risks and
environmental impacts resulting from the migration of contaminants, because the contaminants are
first removed and then detoxified.
The total present worth cost for Alternative 4 is $20,720,000. This consists of a capital cost of
$18,020,000 based on a cost of S250/ton to process 45,000 cubic yards of soil and sediment in
1997 dollars (escalation costs excluded); and an O&M cost of $2,700,000 to operate the
groundwater recovery and treatment system for nine years. This O&M cost is present value
based on an assumed annual interest rate of 7% and escalation at 4%.
9.0 EVALUATION OF ALTERNATIVES
This section of the ROD provides the basis for determining which alternative provides the best
balance with respect to the statutory criteria in Section 121 of CERCLA and in Section 300.430
of the NQP. The NCP categorizes the nine evaluation criteria into three groups:
1. THRESHOLD CRITERIA - overall protection of human health and the
environment and compliance with ARARs (or invoking a waiver) are threshold
criteria to be eligible for selection;
2. PRIMARY BALANCING CRITERIA - long-term effectiveness and permanence,
reduction of toxicity, mobility, or volume through treatment; short-term
effectiveness; implementability, and cost are primary balancing factors used to
weigh major trade-offs among alternative hazardous waste management strategies;
and
3. MODIFYING CRITERIA - state and community acceptance are modifying
criteria that are formally taken into account after public comment is received on
the proposed plan and incorporated in the ROD.
The selected alternative must meet the Threshold Criteria and comply with all ARARs or be
granted a waiver from compliance with ARARs. Any alternative that does not satisfy both of
these requirements is not eligible for selection. The Primary Balancing Criteria are the technical
criteria upon which the detailed analysis is primarily based. The final two criteria are known as
Modifying Criteria, assess the public's and the state agency's acceptance of the alternative. EPA
may modify aspects of a specific alternative based upon these criteria.
Colenun-EvHB Wood Pmevinj
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A summary of the relative performance of each alternative, including the remedy from the 1990
AROD, whh respect to each of the nine criteria follows. This summary provides the basis for
determining which alternative provides the best balance of tradeoffs with respect to the nine
evaluation criteria.
9.1 Threshold Criteria
9.1.1 Overall Protection of Human Health and Environment
A primary requirement of CERCLA is that the selected remedial action be protective of human
health and the environment. This criterion assesses whether Alternatives adequately protect
human health and the environment and to what degree an alternative-will eliminate, reduce, or
control the risks to human health and the environment associated with the Site through treatment,
engineering, or institutional controls.
The remedy selected in the 1990 AROD would not be protective because the unacceptable human
health risk associated with dioxin-contaminated soil would not be addressed by the selected
technology. Alternative 1 would not protect human health and the environment because, the
transport pathways would not be eliminated due to unacceptable levels of contaminants (on-site
and off-site) remaining in the soil and groundwater for an indefinite period of time. Since
protection of human health and the environment is a threshold criterion for any CERCLA action,
the remedy selected in the 1990 AROD and Alternative 1 cannot be considered and thus will not
be evaluated any further with regard to the other evaluation criteria.
Alternative 2 would protect human health and the environment because the transport pathways
would be eliminated through containment of contaminated soil and treatment of contaminated
groundwater. Alternatives 3 and 4 would protect human health and the environment because the
remedies would significantly reduce contaminant levels through treatment of contaminated soil
and eliminate the threat from contaminated groundwater.
9.1.2 Compliance with ARARs
Section 121(d) of CERCLA requires that remedial actions at CERCLA sites at least attain legally
applicable or relevant and appropriate Federal and State requirements, standards, criteria, and
limitations which are collectively referred to as "ARARs" unless such ARARs are waived under
CERCLA section 121(d)(4). Applicable requirements are those substantive environmental
protection requirements, criteria, limitations promulgated under Federal or State law that
specifically address hazardous substances found at the Site, the remedial action to be implemented
at the She, the location of the Site, or other circumstances present at the Site. Relevant and
appropriate requirements are those substantive environmental protection requirements, criteria, or
limitations promulgated under Federal or State law which, while not applicable to the hazardous
materials found at the Site, the remedial action itself, the Site location or other circumstances at
the She, nevertheless address problems or situations sufficiently similar to those encountered at
CoIeman-EwB Wood Preserving
Amended Record of Decisioo-lnirrini Aaioo 36
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the She that their use is well-suited to the She.
Alternatives 2, 3 and 4 would attain their respective Federal and State ARARs. A detailed listing
of ARARs is included in Table 11.1 of this document that pertain to this interim action.
9.2 Balancing Criteria
9.2.1 Long Term Effectiveness and Permanence
This criterion assesses whether a remedial alternative will carry a potential, continual risk to
human health and the environment after the remedial action is completed. An evaluation is made
as to the magnitude of the residual risk present after the completion of the remedial actions as
well as the adequacy and reliability of controls that could be implemented to monitor and manage
the residual risk remaining.
Alternative 2 would be effective in the long-term because contaminated soil would be contained,
and precipitation would be controlled, thus reducing the rate at which contaminants would leach
to groundwater. Alternatives 3 and 4 would be effective in the long-term because contaminated
soil would be treated, thus reducing the potential volume of contaminated groundwater and
therefore shortening the length of time in which contaminated groundwater would need to be
treated. Based on presently available information regarding the toxicity of dioxin, Alternatives 3
and 4 would also significantly reduce the threat from direct contact with Site contaminants until a
final remedy can be determined.
9.2.2 Reduction of Mobility, Toxicity or Volume
This criterion assesses the degree to which a remedial alternative, by utilizing treatment
technologies, would permanently and significantly reduce the toxicity, mobility, or volume of
hazardous substances at the Site. The assessment focuses on the degree and irreversibility of
treatment.
Alternative 2 would reduce the mobility of contaminated soil and groundwater by containment
and plume control by the recovery and treatment system, respectively. Alternatives 3 and 4 would
reduce the mobility, toxicity and volume of contaminated
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5 9 OC47
and contaminated groundwater would be treated. Alternatives 3 and 4 would be effective in the
short-term because contaminated soil and groundwater would be treated.
It should be noted that short-term human health risks would exist from excavation activities
associated with Alternatives 2, 3 and 4 and fugitive emissions must be controlled with
Alternatives 3 and 4. Engineering controls to mitigate short-term risks and air quality monitoring
would be employed during activities associated with Alternatives 2, 3 and 4 to limit these short-
term risks.
9.2.4 ImplementabQity
This criterion assesses the technical and administrative feasibility of implementing a remedial
alternative and the availability of services and materials required during implementation.
Alternative 2 would be implementable because capping is a well established technology in the
industry and the equipment is readily available. Alternatives 3 and 4 are implementable, from a
technical standpoint, based on results of the 1995 Focused Feasibility Study. However, Duval
County has passed an ordinance that prohibits the incineration of PCBs in the county. While this
ordinance does not directly apply to Alternative 3, it will likely cause problems with implementing
any incineration remedy in the county. The ordinance is not likely to impact the implementability
of Alternative 4, but a thermal desorption treatability study would need to be performed to prove
its full effectiveness on contaminated material from this Site.
9.2.5 Cost
This criterion assesses the capital costs, operation and maintenance costs, and total present worth
Costs associated with implementing a remedial alternative. The capital costs are divided into
direct costs and indirect costs. Direct capital costs include construction costs, equipment costs,
and Site development costs. Indirect capital costs include engineering expenses and contingency
allowances. Operation and maintenance costs are post-construction costs necessary to ensure the
continued effectiveness of a remedial action.
The cost of Alternative 2 is estimated to be $10,384,552 ($2,789,552: capital and S 7,595,000:
O&M at 30 years). Alternative 3 is estimated to cost $26,454,962 ($23,571,962: capital and $
2,883,000: O&M at nine years). Alternative 4 is estimated to cost $20,720,000 ($18,020,000:
capita] and S 2,700,000: O&M at nine years). These estimates include cost for recovery and
treatment of contaminated groundwater. The number of years calculated for O&M costs vary
between Alternatives 2,3 and 4 due to the length of time in which the groundwater would have to
be treated following the source control remedy (i.e., 30 years if contaminated soil and sediment
are contained, versus nine years if treated).
Colenun-Evtns Wood Preserving
Amended Record of Decuion-bMim Action 38
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9.3 Modifying Criteria
9.3.1 State Acceptance
This criterion assesses the technical and administrative issues and concerns the State of Florida
may have regarding each of the remedial alternatives. FDEP and its predecessor, FDER, have
been the support agency during the previous remedy selections, providing input into all activities
conducted by EPA.
FDEP has reviewed all documents and worked directly with EPA in evaluating the alternatives to
support EPA's selection of the interim amended remedy. Based on FDEP's comments to date,
EPA expects formal concurrence on the selected remedy will be forthcoming. Once a formal
concurrence letter is received, h will be included as Appendix B of this AROD.
9.3.2 Community Acceptance
EPA has conducted community involvement activities throughout the history of this Site to advise
interested persons of EPA's activities and solicit community input.
The Whitehouse community residents have shown an interest in the Site (especially since dioxin
has been identified as a contaminant of concern) during the public meeting and public comment
period. Responses to specific comments received during the public comment period have been
addressed in the Responsiveness Summary, which is included in Appendix A of this document.
Based on interviews conducted in April 1995, the community surrounding the Site prefers
treatment over containment. The primary interest of the community seems to be that the Site be
returned to productive use.
10.0 SUMMARY OF THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the detailed analysis of the
alternatives using the nine criteria, and public comments, EPA has determined that Alternative 4,
Thermal Desorption With Groundwater Recovery and Treatment, is the most appropriate
alternative for remediating the Site.
In the event that thermal desorption is shown not to be effective in treating the Site
contamination, Alternative 2, Containment by Capping With Groundwater Recovery and
Treatment will be implemented as the contingency remedy. EPA will confer with FDEP in
evaluating the results of the thermal desorption treatability study and decisions regarding the
contingency remedy.
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Amended Record of Deonoo-lnuriin Action 39
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9 Cu49
10.1 Selected Interim Remedy—Thermal Desorption With Groundwater Recovery and
Treatment, Alternative 4
The selected interim remedy involves the use of an innovative technology known as thermal
desorption. This thermal treatment method will separate organic contaminants from Site soils and
sediments through vaporization at temperatures likely to exceed 1000 degrees Fahrenheit..
Though the contaminants will not be destroyed, the off-gas will be contained and undergorurther
treatment.
An estimated 45,000 cubic yards of PCP and dioxin-contaminated soil, sediment, and wood debris
will be excavated at the She. Of this material, approximately 39,000 cubic yards of on-site
contaminated soil and sediment (including some wood fiber) exceeding cleanup goals will be
excavated to the top of the water table (a depth of approximately three feet). Approximately 900
cubic yards of on-site contaminated soil exceeding the PCP cleanup goal in the vicinity of
boreholes 38,40, and 44 will be excavated below the water table to a depth of approximately 18
feet. Additionally, approximately 5000 cubic yards of off-site contaminated soil and sediment
exceeding cleanup goals will be excavated to a depth of approximately one foot. De-watering
will be performed, as needed, to facilitate excavation and backfilling. Any water
collected/generated during remediation will be treated in an on-site treatment system to meet
State and Federal surface water standards and discharged to on-site surface water. Security
fencing shall be installed around the Site to prevent access to the Site by un-authorized personnel.
The thermal desorption system shall employ the use of an indirect-fired heat source, both in the
desorption chamber and in any air pollution control devices. The excavated material will be fed
into the desorption chamber, exposing h to elevated temperatures. The unit will operate in a non-
oxidizing environment. Thermal energy within the unit will volatilize the organic constituents and
convert them to a gas (off-gas). Dioxin and PCP (chlorinated compounds) in the collected off-gas
will undergo further treatment. Off-gas treatment varies depending on the vendor, but usually
consists of either: 1) Thermal oxidation in a chamber similar to incinerators; 2) condensing and
concentrating the organics into a significantly smaller mass for further treatment (e.g., incineration
or dechlorination); or 3) passing the off-gas through activated carbon to adsorb the contaminants
and then regenerating the carbon. This amended ROD will not select the off-gas treatment so as
not to limit vendor competition, however, EPA will specify that the off-gas treatment be non-
combustive (i.e., units employing thermal oxidation chambers, afterburners, and other similar
equipment will not be used).
A treatability study of the thermal treatment system shall be conducted during pre-design, to
demonstrate the effectiveness of the system in meeting the performance standards. Material, as a
by-product of the treatment system, will be analyzed for dioxin and PCP for confirmation of the
Colcnua-Evam Wood Prcterving
Amended Record of Deasiao-lmenm Action 40
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effectiveness of the treatment system. A full-scale proof of process test will also be performed to
ensure that the thermal desorption system is in compliance with local, state, and federal air
emission regulations.
Excavation, material preparation, treatment, and backfilling will continue concurrently. All
excavated material shall be transported on-site, if not already there, where it will be screened to
prepare h for treatment. Oversized material and debris not suitable for treatment in the thermal
desorber may be chipped and/or crushed and treated, or sent off-site for disposal depending on
the makeup of the material.
The off-she excavated area shall be backfilled to pre-excavation grades using clean fill and re-
vegetated as necessary. Two homes are located off-site within the estimated excavation zone,
and two homes are surrounded on three sides by the excavation zone. These homeowners may
need to be temporarily or permanently relocated during the excavation. Other homeowners may
also be relocated as necessary to facilitate construction. EPA will confer with FDEP during
evaluation and decisions on relocation during RD. If it is necessary to permanently relocate these,
or other homeowners, approximately $100,000 per relocation will be added to the estimated
caphol cost of this remedy.
Once treated, material from the process will be analyzed to verify that it meets the treatment
standards-^nd will be used as on-site backfill. Any material not meeting performance standards
will be again treated by the thermal desorption unit until performance standards are achieved.
Backfilling of the on-site area will continue until appropriate grades are met. One foot of topsoil
will be placed over the on-site area that is backfilled with treated material to support vegetation.
Immediately following the treatment of all contaminated material, the thermal desorption unit shall
be de-mobilized from the Site.
All groundwater recovered during excavation and backfilling will be treated in an on-site
treatment unit prior to discharge to on-site surface water. Free-product floating on the upper
surficial aquifer will be recovered for recycling and/or off-site disposal. Modifications may be
added to the groundwater treatment unit to handle any free product that may be recovered.
Details of free-product recovery and treatment will be finalized during RD.
A water treatment system utilizing granular activated carbon (and if necessary filters or
flocculation) will be set up on Site. This system will handle 50 gallons per minute, and would be
used to treat water recovered during excavation and groundwater recovery. An oil water
separator may need to be added to handle free phase product recovery.
The groundwater recovery system will be installed to capture the plume of contaminated
groundwater. Based on Quickflow modeling results it is estimated that this system will be
operated for nine years (long enough to purge three pore volumes). This estimate may be
optimistic since additional data is required to complete a groundwater flow and contaminant
transport model.
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Amended Record of Decwon-lmcrim Action 41
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51
EPA may modify or refine the selected interim remedy during the RD/RA. Such modifications or
refinements, if any, would generally reflect results of the engineering design process. However, it
may include changes necessary to handle process residuals resulting from the selection of an
appropriate off-gas treatment. EPA will confer with FDEP in the selection of the appropriate off-
gas treatment system and corresponding changes to the selected interim remedy or associated
remedial costs.
10.1.1 Performance Standards For Soil and Sediment
In order to facilitate this remedy expeditiously and effectively, the Coleman-Evans Site is
designated as a Corrective Action Management Unit (CAMU) and an Area of Contamination
(AOC) for purposes of this amended ROD. All waste managed within the CAMU/AOC must
comply with the requirements set out in this amended ROD for soil remediation. The designated
CAMU/AOC consists of the contamination on the 11-acre former Coleman-Evans Wood
Preserving Site, the contaminated off-site residential area surrounding the Site, and the
contaminated off-site drainage ditches leading to Interstate 10, contaminated ground water related
to the Site, and all suitable areas in close proximity to the contamination necessary for
implementation of the remedy selected in this AROD.
Excavation shall continue until the remaining soil and sediment achieve the maximum
concentration levels in Table 10.1. Pertinent testing methods will be determined during RD and
used to confirm that cleanup levels have been achieved.
Table 10.1: Performance Standards for Soil and Sediment
Constituent
Pentachlorophenol
Dioxin*
Cleanup Level
2.0 mg/kg
1.0 A^g/kg*
* Interim cleanup level for dioxin and furans and all their congeners
k 1989 Toxicity Equivalents
All excavated soil, sediment, and some wood debris (primarily sawdust) will be treated in the on-
site thermal desorber in a manner that reduces dioxin and PCP concentrations to the levels in
Table 10.1. All excavation shall comply with ARARs. Oversized material and debris not suitable
for treatment in the thermal desorber may be chipped and/or crushed and treated, or sent off-site
for disposal depending on the makeup of the material. Treated material will be used to backfill
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5 9
OC52
the on-site area if h achieves the performance standards, otherwise it will be again treated by the
thermal desorption unit until performance standards are achieved.
10.1.2 Performance Standards For Ground water
Groundwater wiD be recovered from the upper surficial aquifer at a rate to be determined during
RD and shall be treated until the following performance standards set out in Table 10.2 are
achieved. Groundwater monitoring wells that will be used to determine compliance with the
performance standards will be determined during RD. There are also other contaminants in the
groundwater, such as free product and petroleum hydrocarbons associated with diesel fuel used in
the wood treatment process. The appropriate performance standards for these additional
contaminants wflJ be addressed during RD since they are not listed as contaminants of concern
and are not individually addressed in this AROD.
Table 10.2: Performance Standards for Groundwater
Constituent
Pentachlorophenol
Dioxin
Cleanup Level
l.OAtg/1
l.Onp/1
All groundwater collected during the source removal excavation and groundwater recovered via
extraction wells will be treated in the on-site treatment unit and discharged to an on-site drainage
ditch. Florida Surface Water Discharge requirements will be met in the treated groundwater prior
to surface water discharge (F.A.C. 62-302).
The goal of the groundwater recovery system is to restore groundwater to its beneficial use,
which is, at this Site, a potential drinking water source. Based on information obtained during the
remedial investigation and on careful analysis of all remedial alternatives, EPA and FDEP believe
that the selected remedy will achieve this goal. It may become apparent, during implementation
or operation of the groundwater extraction system and its. modifications, that contaminant levels
have ceased to decline and are remaining constant at levels higher than the remediation goal over
some portion of the contaminated plume. In such case, the system performance standards and/or
the remedy may be reevaluated.
The selected remedy will include groundwater extraction for an estimated period of nine years,
during which the system's performance will be carefully monitored on a regular basis and adjusted
CoIcmin-EvnB Wood Pracrvinf
Amended Record of D*anoo-Inl«rinj Action
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'J
as warranted by the performance data collected during operation. Modifications include any or all
of the following:
a) at individual wells where cleanup goals have been attained, pumping may be
discontinued;
b) alternating pumping at wells to eliminate stagnation points;
c) pulse pumping to allow aquifer equilibration and to allow absorbed contaminants
to partition to groundwater, and
d) installation of additional extraction wells to facilitate or accelerate cleanup of the
contaminant plume.
To ensure that cleanup goals continue to be maintained, the aquifer will be monitored at those
wells where pumping has ceased on an occupance of every five years following discontinuation of
groundwater extraction.
It wiD take approximately three years to complete the remedial action for soil, sediment, and
wood debris, and about 10.5 years to complete the groundwater remedial action These times
take into account one year for the RD phase, contracting and procurement, and development
plans. The actual processing of material in the thermal desorber should take about 18 months
including mobilization and demobilization of the equipment. The actual recovery and treatment of
groundwater remediation of the upper surficial aquifer is estimated to require nine years.
10.1.3 Cost
The total present worth cost for Alternative 4 is $20,720,000. This consists of a capital cost of
$18,020,000 based on a cost of $250/ton to process 45,000 cubic yards of soil and sediment in
1997 dollars (escalation costs excluded); and an O&M cost of $2,700,000 to operate the
groundwater recovery and treatment system for nine years. This O&M cost is present value
based on an assumed annual interest rate of 7% and escalation at 4%.
10.2 Contingency Remedy—Containment by Capping With Groundwater Recovery and
Treatment, Alternative 2
A contingency ROD is appropriate when the performance of an innovative treatment technology
appears to be the most promising option, but additional testing will be needed during RD to verify
the technology's performance capabilities; in this case, a more "proven approach" is identified as
the contingency remedy.
Should implementation of Alternative 4 prove ineffective for remediation of PCP and dioxin-
ColoMD-Evms Wood Preserving
Amended lUoord of Deci*ia«>-lnnrin> Action 44
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0054
contaminated soil, Containment by Capping With Groundwater Recovery and Treatment, will be
implemented as the contingency alternative.
The criterion that EPA, in conjunction with FDEP, will use to decide to implement the
contingency alternative is if the selected remedy fails to achieve established performance standards
based upon the results of a treatability study conducted during pre-design.
Alternative 2 consists of the construction of approximately an eight-acre cap over the on-site
contaminated area. Approximately 5,000 cubic yards of off-site contaminated soil exceeding the
She-specific cleanup goals will be excavated to a depth of approximately one foot. Also,
contaminated soils in the vicinity of boreholes 38,40, and 44 will be excavated down to 15 feet
and the excavated areas backfilled with imported clean soil. For each of the deeper contaminated
areas, approximately 300 cubic yards of contaminated soil will be replaced by the clean soil. De-
watering would be performed, as needed, to facilitate excavation and backfilling. All excavated
soil would be spread on the ground surface on-site within the capping limits along with foreign
borrow soil required to achieve minimum Site grades. A multi-layer cap meeting RCRA Subtitle
C requirements would be placed over the contaminated material. As pan of this cap, a clean soil
cover would be placed over the contaminated area (approximately two feet thick) and graded in
accordance with RCRA requirements.
A water treatment system utilizing granular activated carbon (and if necessary filters or
flocculation) will be set up on-site. This system will handle 50 gallons per minute, and be used to
treat groundwater, and water recovered during excavation on-site. An oil water separator may
need to be added to handle any free product that may be recovered.
A system of recovery wells will be installed, both internal and external to the cap footprint, to
pump out contaminated groundwater and contain the PCP plume. These wells can be equipped
with either dual pumps or with two phase pumps to facilitate free product recovery. Details of
free product recovery and treatment will be finalized during the RD. The recovered water will
subsequently be transferred to the on-site treatment system. Since the source of contamination
will not be removed in this alternative, and the required data to perform transport modeling is not
available, it is assumed that the groundwater recovery and treatment system will need to operate
for the 30 year life of this alternative.
The excavated area off-she will be backfilled with clean fill to pre-excavation grades and re-
vegetated, as necessary. Two homes are located within the estimated excavation zone, and two
homes are surrounded on three sides by the excavation zone. These homeowners may need to be
temporarily or permanently relocated during the excavation. Other homeowners may also be
relocated as necessary to facilitate construction. EPA will confer with FDEP during evaluation
and decisions on relocation during RD. If it is necessary to permanently relocate these, or other
homeowners, approximately $100,000 per relocation will be'added to the estimated capitol cost
of this remedy.
Cotanm-Evsm Wood Prcurving
Amended Record of Dcciiioo-lotmm Aoion 45
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Storm water and sediment retention basins will be constructed (on-site or off-site), as needed, to
control surface water run-off both during and after construction of the cap. It is possible that one
of these basins will need to be located south of the Site, therefore, approximately one-acre of land
will need to be purchased.
Prior to cap placement, the construction of an interceptor trench will be completed around the
She to re-route the surface water drainage. This trench will also serve to drain storm water from
the retention basins to McGirts Creek. The existing on-site drainage ditch (between the landfill
area and the old wood treatment facility area on the east portion of the Site) will be graded over.
Security fencing will be installed around the Site to prevent un-authorized access.
All groundwater recovered during excavation and backfilling as well as long-term groundwater
recovery and treatment for Site remediation will be treated in an on-site treatment unit prior to
discharge to on-site surface water. Free-product floating on the upper surficial aquifer will be
recovered for recycling and/or off-site disposal. Modifications may be added to the treatment unit
to handle any free product that may be recovered. Details of free-product recovery and treatment
will be finalized during RD.
It will take approximately one year to complete design, procurement, and work plans for the
containment system. Once Site activities begin, it should take approximately twelve months to
complete construction of the containment system and to install the groundwater recovery and
treatment system. The groundwater recovery and treatment system will operate for the 30-year
life of this alternative.
EPA may modify or refine the selected contingency remedy during the remedial design and
remedial action. Such modifications or refinements, if any, would generally reflect results of the
engineering design process. EPA will confer with FDEP on changes to the selected contingency
remedy or associated remedial costs.
10.2.1 Performance Standards For Soil and Sediment
In order to facilitate this remedy expeditiously and effectively, the Coleman-Evans Site is
designated as a Corrective Action Management Unit (CAMU) and an Area of Contamination
(AOC) for purposes of this amended ROD. All waste managed within the CAMU/AOC must
comply with the requirements set out in this amended ROD for soil remediation. The designated
CAMU/AOC consists of the contamination on the 11-acre former Coleman-Evans Wood
Preserving Site, the contaminated off-site residential area surrounding the Site, and the
contaminated off-she drainage ditches leading to Interstate 10, contaminated groundwater related
to the Site, and all suitable areas in close proximity to the contamination necessary for
implementation of the remedy selected in this AROD.
Excavation shall continue off-site until the remaining soil and sediment achieve the maximum
concentration levels in Table 10.3. Pertinent testing methods will be determined during remedial
Colenun-Evus Wood Preserving
Amended Record of Decision-Interim Action 46
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C056
design and used to confirm that cleanup levels have been achieved.
The excavated soil and sediment will be consolidated on-site within the capping limits along with
foreign borrow soil required to achieve minimum Site grades. A multi-layer cap meeting RCRA
Subtitle C requirements would be placed over the contaminated material.
Table 103: Performance Standards for Soil and Sediment
Constituent
Pentachlorophenol
Dioxin*
Cleanup Level
2.0 mg/kg
1.0 /zg/kg b
* Interim cleanup level for dioxin and furans and all their congeners
b 1989 Toxicity Equivalents
10.2.2 PefYormance Standards For Groundwater
Groundwater shall be recovered from the upper surficial aquifer at a rate to be determined during
remedial design and shall be treated until the following performance standards set out in Table
10.4 are achieved at wells that are designated by EPA in the RD. There are also other
contaminants in the groundwater, such as free product and petroleum hydrocarbons associated
with diesel fuel used in the wood treatment process. The appropriate performance standards for
these additional contaminants will be addressed during RD since they are not listed as
contaminants of concern and are not individually addressed in this AROD.
Table 10.4: Performance Standards for Groundwater
Constituent
Pentachlorophenol
Dioxin
Cleanup Level
1.0/zg/I
1 .0 ng/1
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u U
All groundwater collected during the source removal excavation and groundwater recovered via
extraction wells will be treated in the on-site treatment unit and discharged to an on-site drainage
ditch. Florida Surface Water Discharge requirements will be met in the treated groundwater prior
to surface water discharge (F.A.C. 62-302).
The goal of the groundwater recovery system is to restore groundwater to its beneficial use,
which is, at this Site, a potential drinking water source. Based on information obtained during the
remedial investigation and on careful analysis of all remedial alternatives, EPA and FDEP believe
that the selected remedy will achieve this goal. It may become apparent, during implementation
or operation of the groundwater extraction system and its modifications, that contaminant levels
have ceased to decline and are remaining constant at levels higher than the remediation goal over
some portion of the contaminated plume. In such case, the system performance standards and/or
the remedy may be reevaluated.
The selected remedy will include groundwater extraction for an estimated period of 30 years,
during which the system's performance will be carefully monitored on a regular basis and adjusted
as warranted by the performance data collected during operation. Modifications include any or all
of the foflowing:
a) at individual wells where cleanup goals have been attained, pumping may be
discontinued;
b) alternating pumping at wells to eliminate stagnation points;
c) pulse pumping to allow aquifer equilibration and to allow absorbed contaminants
to partition to groundwater; and
* ^
d) installation of additional extraction wells to facilitate or accelerate cleanup of the
contaminant plume.
To ensure that cleanup goals continue to be maintained, the aquifer will be monitored at those
wells where pumping has ceased on an occupance of every five years following discontinuation of
groundwater extraction.
It will take approximately one year to complete design, procurement, and work plans for the
containment system. Once Site activities begin, it should take approximately twelve more months
to complete construction of the containment system and to install the groundwater recovery and
treatment system. The groundwater recovery and treatment system will operate for the 30 year
life of this alternative.
10.23 Cost
The total present worth cost for Alternative 2 is $10,384,552. This consists of a capital cost of
Colenun-EvuB Wood Preserving
Amended Record of Deciiion-lfitcrim Action 48
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Ou53
$2,789,552 in 1997 dollars (escalation costs excluded) based on a preliminary design for the cap
construction and installation of the groundwater recovery and treatment system; and an O&M
cost of 57,595,000 to operate the groundwater recovery and treatment system for 30 years. This
O&M cost is present value based on an assumed annual interest rate of 7% and escalation at 4%.
11.0 STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at Superfund sites is to undertake
remedial actions that achieve adequate protection of human health and the environment. In
addition, Section 121 of CERCLA establishes several other statutory requirements and
preferences. These specify that, when complete, the selected remedial action for this Site must
comply with applicable or relevant and appropriate environmental standards as established under
Federal and State environmental laws unless a statutory waiver is justified. The selected remedy
also must be cost effective and utilize permanent solutions and alternative treatment technologies
or resource recovery technologies to the maximum extent practicable. Finally, the statute includes
a preference for remedies that employ treatment that permanently and significantly reduce the
volume, toxichy, or mobility of hazardous wastes as their principal element. The following
sections discuss how the selected interim remedy meets these statutory requirements.
11.1 Protection of Human Health and the Environment
The selected interim remedy protects human health and the environment through isolating and
treating the soil contamination at the Site. Based on presently available information, the selected
remedy provides protection of human health and the environment by eliminating, reducing, and
controlling risk through treatment and engineering controls. The contingency remedy protects
human health and the environment through isolating and containing threats of Site contamination
in the soil. The contingency remedy provides protection of human health and the environment by
eliminating, reducing, and controlling risk through containment, engineering and/or institutional
controls.
11.2 Attainment of Applicable or Relevant and Appropriate Requirements
Remedial actions under CERCLA must comply with all applicable or relevant and appropriate
requirements (ARARs). All alternatives considered for the Site were evaluated on the basis of the
degree to which they complied with these requirements, The selected remedy will meet or exceed
the ARARs listed in Table 11.1 that pertain to this interim response action.
11J Cost Effectiveness
T
Cost-effectiveness is determined by comparing the costs of all alternatives being considered with
their overall effectiveness to determine whether the costs are proportional to the effectiveness
ColnrurvEvuB Wood Preserving
Amended R*oord of Dxasor-lmmm Action 49
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'~. :~i
uu
achieved. EPA evaluates the incremental cost of each alternative as compared to the increased
effectiveness of the remedy. Both the selected and contingency remedies result in an acceptable
degree of long-term effectiveness, reduction of mobility, toxicity, and volume, and short-term
effectiveness. When the relationship between the cost and overall effectiveness of the selected
remedy is viewed in light of the relationship between the cost and overall effectiveness afforded
by other alternatives, the selected interim remedy appears to be the most cost effective. The
contingency remedy can be implemented with less cost than the selected remedy, but does not
utilize treatment.
11.4 Utilization of Permanent Solutions and Alternatives
Although this interim action is not intended to fully address the statutory mandate for permanence
and treatment to the maximum extent practicable, this interim action utilizes treatment and thus is
in furtherance of that statutory mandate.
11.5 Preference for Treatment as a Principal Element
Because this action does not constitute the final remedy for the Site, the statutory preference for
remedies that employ treatment that reduces toxicity, mobility, or volume as a principal element,
although h is partially addressed by this remedy, will be addressed by the final response action.
Table 11.1: Applicable or Relevant and Appropriate Requirements (ARARs) for the
Coleman-Evans Wood Preserving Site
ARAR
ENVIRONMENTAL LAWS AND
REGULATIONS
APPLICATION
COMMENTS
RESOURCE CONSERVATION AND RECOVERY ACT
40 CFR Part 261
Identification and Listing of
Hazardous Waste
Action specific for
Soil
Identifies those solid wastes which are subject
to regulation as hazardous wastes. Defines the
term "solid waste" and "hazardous waste".
A&R
40 CFR Part 262
Standards Applicable to Generators
of Hazardous Waste
Action Specific for
Soil
Establishes standards for generators of
hazardous waste.
R&A
40 CFR Part 264
Standards for Owners and Operators
of Hazardous Waste Treatment,
Storage, and Disposal (TSD)
Facilities
Action Specific for
Soil
Establishes minimum national standards which
define the acceptable management of
hazardous waste for owners and operators of
facilities which treat, store, or dispose of
hazardous waste
Colenun-Evsm Wood Preserving
Amended Record of Decuioo-buerim Action
50
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0060
ARAR
ENVIRONMENTAL LAWS AND
REGULATIONS
APPLICATION
COMMENTS
R&A
40 CFR Part 268
Land Disposal Restrictions
Chemical Specific
for Soil
Identifies hazardous wastes that are restricted
from land disposal and describes those
circumstances under which an otherwise
prohibited waste may be land disposed
Federal Register/Vol. 58
February 16,1993
40 CFR Part 260 etal
Corrective Action Management Units
and Temporary Units; Corrective
Action Provisions; Final Rule
Action Specific for
Soil and
Oroundwater
Finalizes provisions for corrective action
management units (CAMUs) and temporal}'
units under Subpart S of 40 CFR Pan 264.
Defines the term "remediation waste".
40CFR264SubpartX
Miscellaneous Units
Action Specific
for Soil
Requires that miscellaneous units (thermal
desorbers) be designed, operated, and closed
in a manner that is protective of human health
and the environment.
CLEAN WATER ACT
R&A
40 CFR Pans 122-124
NPDES Requirements
Chemical Specific
for Groundwater
Sets forth requirements for direct discharge of
treated groundwater and surface water to en-
sile streams
R&A
40 CFR Part 131
Ambient Water Quality Criteria
Requirements
Chemical Specific
for Groundwater
Provides for the establishment of water quality
based on toxicity to aquatic organisms and
human health
R&A
40 CFR Part 141
National Primary Drinking Water
Regulations
Chemical Specific
for Groundwater
Establishes primary drinking water regulations
pursuant to Section 1412 of the Public Health
Service Act, as amended by the amended Safe
Drinking Water Act; and related regulations
applicable to public water systems
R&A
40 CFR Pan 142
National Primary Drinking Water
Regulations Implementation
Chemical Specific
for Groundwater
Sets forth Sections 1413-1416,1445, and
1450 of the Public Health Service Act, as
•mended.
R&A
40 CFR Part 143
National Secondary Drinking Water
Regulations
Chemical Specific
for Groundwater
Establishes National Secondary Drinking
Water Regulations pursuant to Section 1412 of
the Safe Drinking Water Act, as amended (42
U.S.C. 300g-l). and control contaminants in
drinking water that primarily affect the
•esthetic qualities relating to the public
acceptable of drinking water.
40 CFR Part 457
Effluent Guidelines
Chemical Specific
for Groundwater
Sets forth effluent water quality standards to
be applied to on-site discharge of treated
waters
Colcman-Evws Wood Preserving
Amended Record of Decision-Interim Action
51
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5 9
ARAR
ENVIRONMENTAL LAWS AND
REGULATIONS
APPLICATION I
- .; COMMENTS
SAFE DRINKING WATER ACT
A
40 CTR Parts 141 «nd 143
Maximum Contaminant Levels
(MCLs)
Chemical Specific
for Groundwater
Sets forth mflxir"""1 contaminant levels for
drinking water.
CLEAN AIR ACT
R&A
40CFRPart50
National ambient air quality
standards (NAAQS)
Action Specific for
Soil
Thermal Desorplion and earthmoving
operations will result in emissions to air.
Wind erosion or dust generated by human
activities may result in contaminant dispersal
Ui. DEPARTMENT OF TRANSPORTATION (DOT) REQUIREMENTS
A
U.S. Department of Transportation
(DOT) Regulations (40 CFR Parts
170-179)
Action Specific for
Soil
Contents of tanks and construction rubble may
be transported offsite for treatment or disposal.
STATE OF FLORID A
R&A
A
R&A
R&A
A
A
Florida Administrative Code Chapter
62-3 —
Florida Administrative Code Chapter .
62-6
Florida Administrative Code Chapter
62-2
Florida Administrative Code Chapter
62-25
Florida Administrative Code Chapter
62-302
%
Florida Administrative Code Chapter
62-520
Action Specific for
... Water
Action Specific for
Groundwater
Action Specific for
Soil
Action Specific for
Soil
Action Specific for
Groundwaler and
Soil
Chemical Specific
for Groundwater
Water quality standards for surface water and
groundwater affected by leachate and storm •
runoff from the site must be met.
Effluent limitations and operating
requirements for wastewater facilities treating
contaminated groundwater must be met.
Air emissions
Storm Water Control Standards
Surface Water Quality Standards
Groundwater Classes. Standards and
Exemptions
CoJeman-Evm Wood Preserving
Amended Record of Dcctnan-lnurim Action
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ARAK
ENVIRONMENTAL LAWS AND
REGULATIONS
APPLICATION
COMMENTS
Florid* Administrative Code Chapter
62-550
Chemical Specific
for Groundwater
Drinking Water Standards, Monitoring and
Reporting
RAA
Florida Administrative Code Chapter
62-730
Chemical Specific
for Groundwater
and Soil
Hazardous Waste (Trans from 17-30)
Florida Administrative
62-736
Action Specific for
Groundwater and
Soil
Warning Signs at Contaminated Sites
Florida Administrative Code Chapter
62-770
Action Specific for
SoU
State Underground Petroleum Environmental
Response (Trans from 17-71)
R&A
Florida Administrative Code Chapter
62-296
Action Specific for
Soil
Thermal Treatment Facilities
STATE LAW TO SPECIFICALLY ADDRESS A HAZARDOUS SUBSTANCE, POLLUTANT,
CONTAMINANT, REMEDIAL ACTION LOCATION OR OTHER CIRCUMSTANCE AT THE COLEMAN-
EVANS SITE
R&A— RELEVANT AND APPROPRIATE REQUIREMENTS WHICH WHILE THEY ARE NOT "APPLICABLE"
TO A HAZARDOUS SUBSTANCE, POLLUTANT. CONTAMINANT, REMEDIAL ACTION. LOCATION,
OR OTHER CIRCUMSTANCE AT THE COLEMAN-EVANS SITE, ADDRESS PROBLEMS OR
SITUATIONS SUFFICIENTLY SIMILAR TO THOSE ENCOUNTERED AT THE COLEMAN-EVANS SITE
THAT THEIR USE IS WELL SUITED TO THE SITE
11.6 Documentation of Significant Changes
The selected remedy for the Site was refined somewhat after the proposed plan fact sheet was
published and the public meeting was held. These refinements include: 1) selecting an interim
remedy instead of a final action, 2) not specifying the type of off-gas treatment for the thermal
desorption remedy, and 3) expanding the scope of the groundwater remedy.
EPA is taking an interim action at the She by selecting a soil dioxin cleanup level of 1 .0
(TEQs) as an interim cleanup level for the She. EPA believes that this cleanup level is protective
of human health, but that the Agency should defer a final cleanup decision at this Site pending
release of the EPA's final dioxin reassessment (embodied in the documents entitled "Health '
Assessment Document for 2,3,7,8 tetrachlorodibenzo-p-dioxin (TCDD) and Related Compounds"
and "Estimating Exposure to Dioxin-like Compounds") and pending an evaluation of the effects
the findings of the final dioxin reassessment on Superfund dioxin cleanup levels. EPA believes it
is appropriate to take an interim action at this time to achieve significant risk reduction quickly
while the reassessment is being completed.
CoieniD-Evam Wood Procrviag
/Vacated RJCOT) of Decisico-lM*!
—53
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5 9 OC63
EPA indicated in the proposed plan fact sheet that the thermal desorption unit would utilize
dechlorination as a means to treat the off-gas residuals from the process. To maximize vendor
competition, EPA will not specify these details in this A ROD.
The 1986 ROD and 1990 AROD called for the recovery of PCP-contaminated ground water only
during the excavation of the on-she source materials. EPA's proposed plan feet sheet for this
AROD indicated that the amended remedy would not change the previously selected groundwater
remedy, with the exception of adding a cleanup level for dioxin. However, during the June 7
1995, Public Meeting, EPA explained that groundwater would be recovered from the upper
surficJal aquifer and treated as a component of Alternatives 2 and 4. Remediation of the upper
surficia] aquifer was also included as a component of Alternatives 2 and 4 in the 1995 Focused
Feasibility Study. As a clarification to the 1995 proposed plan and public meeting, EPA believes
it is necessary to actively remediate groundwater in the upper surficial aquifer to ensure
contaminant levels are reduced to acceptable levels in a reasonable time frame (i.e., nine years).
Therefore, the scope of the original groundwater remedy is being clarified to provide for the
recovery and treatment of PCP-, and potentially dioxin-, contaminated groundwater in the upper
surficia] aquifer via extraction wells.
Colemm-Evam Wood Praerving
Amended fUccrd of Deciwo-biteriB Action 54
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5 9 0064
APPENDIX A
RESPONSIVENESS SUMMARY
Coknun-Evmi Wood Proerving
Amended Record of Deasion-lmcrim Aeiioii
-------
Responsiveness Summary
The U.S. Environmental Protection Agency (EPA) established a public comment period from
May 31,1995 through June 30,1995 for interested parties to comment on EPA's Proposed Plan
for remedial action at the Coleman-Evans Wood Preserving She. The comment period included a
public meeting on June 7,1995, conducted by EPA and held at the Whitehouse Elementary
School in Whitehouse, Florida. The meeting presented the results of the studies undertaken and
the preferred remedial alternative for the She.
A responsiveness summary is required by Superfund policy to provide a summary of citizen
comments and concerns about the site, as raised during the public comment period, and the
responses to those concerns. All comments summarized in this document have been factored into
the final decision of the preferred alternative for cleanup of the Coleman-Evans Wood Preserving
She.
This responsiveness summary for the Coleman-Evans Wood Preserving Site is divided into the
following sections.
I. Overview: This section discusses the recommended alternative for remedial action and the
public reaction to this alternative.
n. Background on Community Involvement and Concerns: This section provides a brief
history of community interest and concerns regarding the Coleman-Evans Wood
Preserving Site.
ffl. Summary of Major Questions and Comments Received During the Public Comment
Period and EPA's Responses: This section presents both oral and written comments
submitted during the public comment period, and provides EPA's response to these
comments. ....
17
TV. Remaining Concerns: This section discusses community concerns that EPA should be
aware of in design and implementation of the remedial alternative for the Site.
Overview
During the design of the remedy for the 1990 AROD, soil samples were obtained as pan of a
treatabilhy study to assess the levels of performance achievable by the selected treatment traiiv -
The samples revealed the presence of both PCP and dioxin at the Site.
The results of the treatability study show that the 1990 AROD treatment train is not effective in
treating the dioxin found at the Site. Although soil washing is marginally effective on separating
dioxin and PCP contaminants from soil particles, a large portion of the contaminants are bound up
*
CoIeman-EvuB Wood Preserving
Aranritd Record of Dtciiioo—tottnfl) Action ~ ~A~1 . ~
-------
5 9 0066
in the high percentage of wood fiber in the soil. Bio-treatment was found to be ineffective on the
dioxin contamination found at the She. The effectiveness of S/S is also questionable due to the
high percentage of wood fiber in the soil, which presents problems in reaching the necessary S/S
compressive strength. Attempts to separate the wood fiber from the soil were unsuccessful due to
the heavy laden fuel oil on the wood fiber. At best, if the dioxin and PCP wood fiber could be
separated from the soil, an undetermined volume of wood fiber still would require some form of
treatment or disposal beyond that found in the 1990 AROD.
This AROD selects a new interim remedy to address an estimated 45,000 cubic yards of
pentachlorophenol (PCP) and dioxin-contaminated source material (i.e., soil, sediment, and
debris) and expands the scope of the groundwater remedy to permanently address PCP-, and
potentially dioxin-, contaminated groundwater in the upper surficial aquifer.
•4 .
This AROD is considered an interim action because the U.S. Environmental Protection Agency
(EPA) is selecting a soil dioxin cleanup level of 1.0 Mg/kg as an interim cleanup level for the Site.
EPA believes that this cleanup level is protective of human health and the environment, but that
the Agency should defer a final cleanup decision at this site pending release of EPA's final dioxin
reassessment (embodied in the documents entitled "Health Assessment Document for 2,3,7,8
tetrachlorodibenzo-p-dioxin (TCDD) and Related Compounds" and "Estimating Exposure to
Dioxin-like Compounds") and pending an evaluation of the effects of the findings of the final
dioxin reassessment on Superfund dioxin cleanup levels. EPA believes it is appropriate to take an
interim action at this time to achieve significant risk reduction quickly while the reassessment is
being completed.
The major components of the amended interim remedy include:
• Excavating approximately 45,000 cubic yards of PCP and dioxin-contaminated
soil, sediment, and wood debris from the on-site and off-site areas;
• Treating the excavated soil, sediment, and some wood debris (primarily sawdust)
in an on-site thermal desorber, followed by treatment of the off-gas;
• Backfilling the excavated area with treated material and/or clean fill and re-grading
and re-vegetating all excavated areas;
•• Recovering and treating PCP-contaminated groundwater in the upper surficial
aquifer and collecting free-product for recycling and/or off-site disposal;
• ~ Relocating residents, as necessary, to facilitate construction;
During pre-design, a treatabilhy study will be conducted to verify the effectiveness of the thermal
desorption treatment system. Should implementation of the selected interim remedy prove
Colcnun-Evm Wood Preserving
Amended Record of DccntOD-loKrim Action A-2
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5 9 C067
ineffective for remediation of PCP and dioxin-contaminated source material, a contingency
remedy will be implemented. The contingency remedy is also an interim action pending release of
the Agency's final dioxin reassessment.
The major components of the contingency remedy include:.
• Excavating approximately 5,000 cubic yards of off-site contaminated soil and
sediment and distributing h on-she;
• Backfilling the excavated area with clean fill and re-grading and re-vegetating all
excavated areas;
• Constructing a multi-layer RCRA cap to contain the affected on-site area,
including surface drainage controls;
• Recovering and treating PCP-contaminated groundwater in the upper surficial
aquifer and collecting free-product for recycling and/or off-site disposal; .
• Relocating residents, as necessary, to facilitate construction;
• Implementing deed restrictions and/or other institutional controls to prohibit future
use of the Site in a manner that would compromise the integrity of the cap and its
associated systems.
Based on public input, the community surrounding the Site favors the selected interim remedy,
but also supports the contingency interim remedy.
n. Background on Community Involvement and Concern
The Jacksonville community has been aware of the contamination problem at the Coleman-Evans
Wood Preserving She for several years. The first public meeting was held on August 7, 1986, to
discuss the findings of the Remedial Investigation/Feasibility Study (RI/FS). The public meeting
served to initiate a three week public comment period which closed on August 28,1986.
During this public comment period, EPA submitted a proposal for remedial action at the Site.
That proposal suggested treatment of the contamination by incineration. As noted in this AROD,
that alternative was rejected due to concern over the cost effectiveness of the action due to A
reassessed volume increase. Subsequently, EPA initiated a treatability study to examine
bioremediation and solidification/stabilization as a viable remedy for the Coleman-Evans Wood
Preserving Site. The results of the study confirmed that the amended remedy described in the
previous section satisfies-EPA's goal for source control.
Cotann-Evms Wood Preserving
Amended Record of Dcdtioo-Imaim Action . ....... A*3
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5 9 0268
The treatability study for the Coleman-Evans Wood Preserving Site was released to the public on
August 9,1990. Also, the modified proposed remedial action plan which revised the remedy EPA
had proposed in hs initial 1986 Record of Decision (ROD), was placed in the information
repositories.
EPA conducted the second public meeting on August 23,1990. The purpose of this meeting was
to explain the results of the site studies, to present the recommendations for site cleanup, and to
accept questions and comments from the public on any aspect of the site or its cleanup. The first
AROD for the she was signed on September 26,1990.
In October 1992, EPA and FDEP held a public meeting to inform the public of the discovery of
dioxin contamination at the Site. Although the public meeting was announced in the Florida
Times Union, only a few members of the community participated.
Door-to-door community interviews were conducted in April 1995 to listen to the concerns of the
community and explain the limited alternatives for addressing the dioxin contamination. EPA's
mailing list was also updated at this time.
Another Proposed Plan was released to the public in May 1995 with the purpose of selecting a
new remedy to address the newly identified dioxin contamination. Documents supporting the
Proposed Plan were made available to the public for review in the Administrative Record
maintained at EPA's Region IV office in Atlanta, Georgia, and at the Information Repository
maintained at the Whitehouse Elementary School in Whitehouse, Florida. A notice of the Public
Meeting was published in the Florida Times Union in June 1995.
A Proposed Plan public meeting was held on June 7,1995 at the Whitehouse Elementary School.
During this meeting, representatives from EPA presented various alternatives for addressing the
Site, presented EPA's preferred alternative, and answered questions.
The 30-day public comment period was held from May 31,1995 through June 30,1995. During
the public comment period, the FDEP expressed concern with EPA's proposed cleanup levels for
the site. Specifically, FDEP requested that EPA select a PCP cleanup level that would be
protective of ground water, and a dioxin cleanup level that provides a 1 x 10"* risk level.
Finalization of this AROD was delayed from July 1,1995 to July 31,1997, while EPA and FDEP
evaluated appropriate cleanup levels for the site and while additional Site characterization was
performed to delineate dioxin contaminate levels off-site.
A Community Update Fact Sheet was released to the public in August 1997 reporting the results
of the off-site dioxin delineation.
During the 30-day public comment period held in 1995, few issues and concerns were identified
by the community. The following section summarizes the key issues and concerns identified.
CataaiMfEvsm Wood Preserving
Amended Record of Decuioo-taterim Action A-4
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5 9 0069
DL Summary of Major Questions and Comments Received During the Public Comment
Period and EPA's Responses
Public Meeting held June 7.1995
1) One commentor asked if the Florida Department of Environmental Protection (FDEP)
is in agreement with EPA's proposed alternative.
EPA Response; The FDEP has reviewed an documents and worked directly with EPA in
evaluating the alternatives to support EPA's selection of the interim amended remedy.
FDEP also supports EPA's choice of Alternative 2 as the contingency remedy. Based on
FDEP's comments to date, EPA expects formal concurrence on the selected remedy will
be forthcoming.
2) A representative for the City of Jacksonville, Air Quality Division was concerned about
air quality standards being met during site remediation and also expressed a preference
that she contamination be treated (as opposed to being contained) to prevent future
problems.
EPA Response: EPA shares the City of Jacksonville's concern regarding air emissions
during she remediation and has already been in contact with the City of Jacksonville, Air
Quality Division to discuss appropriate requirements. EPA will work directly with State
and local officials during preliminary remedial design to identify appropriate air
monitoring requirements to ensure protection of human health and the environment.
3) One commentor expressed concern with whether a risk assessment had been performed
for the site to address the newly discovered dioxin contamination.
•*•.
EPA Response: A baseline risk assessment is required to determine whether a Supcrtund
She poses a current or potential threat to human health and the environment in the ....
absence of remedial action. The baseline risk assessment provides the basis for
determining whether or not remedial action is necessary and the justification for
performing remedial action.. _ ._
A Public Health Evaluation was developed in 1986 based on the presence of PCP, the only
contaminant of concern known at the time. Since subsequent sampling has indicated the .__
widespread presence of dioxin, a Focused Baseline Risk Assessment Addendum was
prepared in 1996 to supplement the 1986 evaluation. The findings from both the 1986 -
Public Health Evaluation and the 1996 Focused Baseline Risk Assessment support the
decision to remediate the she.
Colcmaa-Evtn Wood PiMcrviag
Amended Record of DeeinoB-hunn Action -A-5
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5- 9 0070
4) One commentor expressed concern that some nearby residents may use the surficial
aquifer for irrigation which would be another potential pathway for exposure to dioxin and
PCP contamination.
Response; The 1986 Public Health Evaluation determined that the consumption of
root crops irrigated with groundwater from the upper surficial aquifer could produce
unacceptable levels of exposure to PCP. For this reason, EPA believes it is necessary to
remediate groundwater in the upper surficial aquifer to prevent the possibility of future
exposure. While EPA agrees with the commentor that groundwater in the upper surficial
aquifer is a potential future source of PCP contamination to local residents, the Agency is
not aware of any wells that currently access this aquifer that are used for either drinking
water or irrigation.
5) A representative for the City of Jacksonville Air Quality Division asked what type of
dioxins have been found at the site.
EPA Response; The term "dioxin" at the Coleman-Evans Wood Preserving Site refers to
a toxicity weighted concentration of (TEQ) of over 200 poly chlorinated dibenzofurans
(PCDFs) and poly chlorinated dibenzodioxins (PCDDs). Small amounts of PCDDs and
PCDFs can be potentially produced in the wood treatment process. Consequently, the
types of dioxin found at the Coleman-Evans Wood Preserving Site are consistent with
those typically found at all wood treating sites (i.e., primarily Hepta and Octa). Very little
2,3,7,8-TCDD has been found at the she, which is the most widely studied and believed to
be the most toxic.
Comment Letter; Department of Regulatory & Environmental Services. Water Quality
Division. City of Jacksonville. Florida, dated June 13.1995
l)This division supports the selection of Remedial Alternative #4, Thermal Desorption and
Dechlorination. It also supports and requests that your contractor conduct air monitoring
as stated in the fact sheet.
EPA Response: Support for Alternative 4 is noted. EPA shares the City of
Jacksonville's concern regarding air emissions during site remediation and has already
been in contact with the City of Jacksonville, Air Quality Division to discuss appropriate
requirements. EPA will work directly with State and local officials during remedial design
to identify appropriate air monitoring to ensure the protection of human health and the
environment.
2) In the event the Treatability Study demonstration is not effective, the Contingency
v *•
Colcmm-Evm Wood Preserving
ArocndMl Record of DecnraD-lmcnmAOka -A-6
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5 9 0071
Remedy must be revised before it is acceptable to this agency. Alternative #2 is
unsatisfactory as described because h does not properly dispose or treat the excavated soil
presently stored on-she nor the soil that will be excavated off-site. The Water Quality
Division could support capping the site "as is"; however, all excavated soil must be
removed for disposal or treated prior to spreading under the stabilized cap.
EPA Response: Alternative 2 provides for the excavation of approximately 5000 cubic
yards of off-site contaminated soil and sediment exceeding cleanup goals. The excavated
material will be consolidated on-site within the capping limits along with foreign borrow
soils required to achieve minimum she grades. A multi-layer cap meeting RCRA Subtitle
C requirements will be placed over all contaminated material. As pan of this cap, a clean
soil cover will be placed over the contaminated area (approximately two feet thick, and
graded in accordance with RCRA requirements.
The primary objectives of Alternative 2 are to prevent the possibility of direct contact to
she contaminants above the specified cleanup levels and to prevent the affected media
from continuing to act as a source to groundwater. These objectives are met by the
planned remedial action and EPA does not believe a modification to the remedy is
necessary. Furthermore, h is not cost effective to treat or dispose of contaminated
material that is otherwise effectively controlled by the on-site containment system.
IV. Remaining Concerns
The community's concerns surrounding the Coleman-Evans Wood Preserving Site will be
addressed in the following areas: community involvement support throughout RD/RA and
incorporation of comments/suggestions from the community during RD.
Community involvement will consist of making available final documents (i.e., RD Workplan, RD
reports, etc..) in a timely manner to the local information repository for the she. EPA will also
issue fact sheets to individuals on the mailing list to provide further Information on progress of the
project and schedules for future activities at the site. EPA will inform the community of any
principal design changes made during the project design. If, at any time during the RD/RA, new
information is revealed that could affect the implementation of the remedy or if the remedy fails to
achieve the necessary design criteria, the AROD may be revised to incorporate new technology
that will attain the necessary performance standards.
Community involvement activities will remain an active aspect of the RD/RA phase of the project.
Colenanv-Evns Wood Praeving
Amended Record of Deciwoo-lnMrim Action - A-7
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5 9 tu72
APPENDIX B
STATE CONCURRENCE LETTER
Coknun-Evm Wood Proerving
Amended Rmrd of Dccuico-lmeniD Aclioo
-------
Lawton Chiles
Governor
Department of
Environmental Protection
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee. Florida 32399-2400
Virginia B. Wetherell
Secretary
March 13, 1998
Mr. John H. Hankinson, Jr.
Regional Administrator
U.S. Environmental Protection Agency
Region IV
100 Alabama Street, Southwest
Atlanta, Georgia 30303
Dear Mr. Hankin
V
The Florida Depav
srt^VW.
epaVtment
of Environmental Protection (DEP) has
reviewed the September 1997 Amended Record of Decision (AROD) for
the Coleman Evans Wood Preserving Superfund Site and concurs with
the selected interim remedy.
The EPA has selected an interim remedial action which
includes recovery and treatment of contaminated water, and
excavation and thermal desorption of contaminated soil, sediment
and wood debris. In the event the pilot study indicates that
thermal desorption is unable to accomplish site remedial goals, a
contingency remedy will be implemented whereby off-site
contaminated soils will be relocated to the site and placed
untreated under a RCRA cap. The groundwater remedy would proceed
as planned. Remedial goals for groundwater at the site include
1.0 ng/1 for pentachlorophenol (PCP) and 1.0 ng/1 for dioxin.
Both onsite and off site soils and sediment will be remediated to
meet the 2.0 mg/kg goal for PCP and 1.0 ^ig/kg for dioxin under
both the selected and contingent remedies.
We understand that the 1.0 ^ig/kg level for dioxin in soils
is an interim cleanup level. And we agree that it is appropriate
to move ahead with the interim action in order to achieve
significant risk reduction quickly while the federal dioxin
toxicity reassessment is being completed. Following the release
"Protect, Conserve and Manage Florida's Environment and Natural Resources"
Printed on recyded paper.
-------
Mr. John Hankinson
Page Two
March 13, 1998
of the EPA's final dioxin reassessment and a re-evaluation of the
appropriate and final dioxin cleanup levels consistent with a
10~6 risk management goal for unrestricted future residential
use, a final Record of Decision for the site will be issued.
As a federally funded cleanup, we understand that there will
be a ten percent State cost share for construction, operation,
and maintenance at an estimated present worth of $2.07 million
for the selected remedy or $5.6 million if the contingent remedy
is necessary.
We look forward to completion of the cleanup of the Coleman
Evans Superfund site. • £
Sincerely,
Virginia B. Wetherell
Secretary
VBW/lkb
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