United States
           Environmental Protection
           Agency
             Office of
             Emergency and
             Remedial Response
EPA/ROD/R04-89/055
September 1989
SEPA
Superfund
Record  of  Decision
           American Creosote Works, FL

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50272-«)1
 REPORT DOCUMENTATION
    i    PAGE
                        1. REPORT NO.
                             EPA/ROD/R04-89/055
                                                                   3. Recipient* Accaaaion No.
4. Title and SubtWe
 SUPERFUND RECORD  OF DECISION
 Rmerican Creosote Works  (Pensacola Plant), FL
 First Remedial Action (Amendment)
                                                                    5. Report D*te

                                                                           09/28/89
 7. Auttior(a)
                                                                   8. Performing Organization Rept. No.
 9., Performing Organization Nun* and Addree*
                                                                   10. Pro|ecVTaak/Work Unit No.
                                                                    11. Contncqo or GranqG) No.

                                                                    (C)
 12. Sponsoring Organization Nun* and AddnMo
   U.S.  Environmental Protection Agency
   401 M Street,  S.W.
   Washington,  D.C.  20460
                                                                   13. Typ» of Report 4 Period Covered

                                                                       800/000
                                                                    14.
 15. Supplementary Note*
 16. Abetract (Limit: 200 wonte)
  The  18-acre American  Creosote Works  (Pensacola  Plant)  site,  is  in a dense  moderately
 commercial and residential area of  Pensacola, Florida,  approximately 600  yards from
 Pensacola Bay and Bayou Chico.  American Creosote  Works, .Inc.  operated a  wood preserving
 facility onsite from 1902 to 1981.  During this  time,  process  wastewater  containing
  entachlorophenol  (PCP)  was discharged into two  0.9-and 1.8-acre unlined, onsite surface
   Łoundments.   Prior to 1970, wastewater-in these  ponds was allowed to overflow through
 a spillway into the  neighboring Bayou Chico and  Pensacola Bay.   After 1970,  wastewater
 was periodically drawn from the ponds and discharged to designated onsite spillage
 areas.   Additional discharges occurred during periods  of heavy rainfall when the ponds
 overflowed.   In March  1980, the city  found considerable quantities of oily,  asphaltic,
 creosotic material in  the ground water near the  site.   Because of the threat posed to
 human health and the environment due  to frequent overflows from the waste ponds, EPA and
 the State performed  an emergency cleanup in 1983,  which included dewatering the two
 ponds,  treating the  water via coagulation and filtration, and discharging treated water
 to the  city sewer system.  The sludge in the ponds was then solidified and  capped.  EPA
 signed  a Record of Decision  (ROD) in  1985 requiring all onsite and offsite  contaminated
 solids,  sludge, and  sediment to be  placed in an  onsite RCRA-permitted landfill.  Because
 the State did C9ncur with the selected remedy, no  remedial action was taken.
 Consequently,  a post remedial investigation was  conducted in  (Continued on  next nacre)	
 17. Document Analyaia a. Oeacriptora
   Record of Decision - American  Creosote Works  (Pensacola  Plant),  FL
   First  Remedial Action (Amendment)
   Contaminated Medium: soil
   Key Contaminants:  organics  (dioxin,  PAHs, PCP)
   b. Identiftera/OpmvEndad Term*
   If. COSATI Field/Group
   'Availability Statement
                                                     19. Security daaa (Thla Report)
                                                            None
                                                     20. Security CUM (Tola Pag*)
                                                     	None	
                                                                              21. No. of Pages
                                                                                   52
                                                                               22. Price
(See ANSI-Z39.18)
                                      See Jrwfructron* on fltwanw
                                                                              OPTIONAL FORM 272 (4-77)
                                                                              (Formerly NTIS-3S)
                                                                              Departnant at Commerce

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16".  Abstract (Continued)

American Creosote Works (Pensacola Plant),  FL
^A/ROD/R04-89/055

n?88 to characterize the extent of contamination followed by a post feasibility study in
1989 to identify, develop,  and evaluate alternatives.  This ROD is the first of two
planned operable units and addresses remediation of contaminated surface soil.  A
subsequent operable unit will address treatment of contaminated subsurface soil, sludge,
and ground water.  The primary contaminants of concern affecting the surface soil are
organics including dioxins, carcinogenic PAHs, and PCP.

 The selected remedial action for this site includes excavating and treating 23,000 cubic
yards of PAH-contaminated soil using solid-phase bioremediation in an onsite land
treatment area followed by onsite disposal  of treated soil in the excavated areas or
spreading the soil over the entire site; implementing temporary erosion control measures
to preserve surface water quality; collecting leachate and drain water for spraying over,
the treatment area to moisten soil; monitoring dissolved oxygen, pH, nutrients, and soil
moisture content; removing debris, repairing fences, sampling the cap and disposing of
drums containing drilling mud; and implementing land and ground water use restrictions.
The estimated present worth cost is $2,275,000 which includes an O&M cost of $319,000.

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                          Record of Decision

                              Declaration

               Surface Soil Contamination Operable Unit
Site Name and Location;  American Creosote Works/  Inc.
                         Pensacola, Escambia County,  Florida


Statement of Basis and Purpose;

This decision document presents the selected remedial action for the
American Creosote Works, Inc. Site in Pensacola, Florida, which was
chosen in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA),  as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and, to
the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP).  This decision document explains
the factual and legal basis for selecting the remedy for the site.

The State of Florida has concurred on the selected remedy.  The
information supporting this remedial action decisio.n is contained in
the administrative record for this site.


Assessment of the Site;

Actual or threatened releases of hazardous substances from this site,
if not addressed by implementing the response action selected in this
Record of Decision (ROD), may present'an unacceptable risk to public
health, welfare, or the environment.


Description of the Selected Remedy;

The remedy selected by EPA will be conducted in two separate operable
units.  This operable unit is the first of two operable units for the
site.   This initial operable unit addresses treatment of the
contaminated surface soil and is fully consistent with all planned
future site activities.  Future site activities include treatment of
the contaminated ground water and previously solidified sludges and
underlying subsurface soil.

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                                  -2-


The major components  of  the selected remedy for thia first operable
unit are as  follows:                                                '

         Excavating,  screening, and stockpiling the contaminated
         surface  soil
         Treatment of  this contaminated soil by bioremediation
         On-aite  disposal of the treated soil in the excavated
         areas
         Support  activities?  remove debris, repair fence/ sample
         drums containing drilling muds and properly dispose of
         contents, and repair existing clay cap.


Qeclaration;

The selected remedy 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.  This remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable, and  it satisfies the statutory preference for
remedies that employ  treatment that reduce toxicity, mobility, or
volume as their principal element-.

Because this remedy will result in hazardous substances remaining on
site above health-based  levels, a review will be conducted within
five years after  commencement of remedial action to ensure that the
remedy continues  to provide adequate protection of human health and
the environment.
Greer C. Tidwellyj      Date
EPA Regional Administrator     U

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         RECORD OF DECISION

        The Decision Summary
   American Creosote Works, Inc.
   ,                ,              • *
Pensacola, Escambia County/ Florida
            Prepared by:
U.S. Environmental Protection Agency
             Region  IV
          Atlanta, Georgia

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                           TABLE  OP  CONTENTS


1.0   Introduction	1
      1.1   Scqpo and Role of  Operable  Unit	1

2.0   Site Name,  Location, and Description	2

3.0   Site History	2
      3.1   Enforcement Activities	6

4.0   Community Relations	6

5.0   Summary of  Site Characteristics	7
      5.1   Geomorphology	7
      5 .2   Local Geology	7
      5. 3   Surface Water	9
      5.4   Surface Water  Drainage	9
      5.5   Hydrogeology	9
      5.6   Ecology	10
      5.7   Soil	11
      5 .8   Sediment and Surface Water	14

6.0   Summary of  Site Risks	.1.... 14
      6.1   Identification of  the Contaminants of Concern. ,|. ; . .14
      6 .2   Exposure Assessment Summary	 14
      6.3   Summary of the Toxicity Assessment of the
            Contaminants of Concern	15
      6.4   Risk Characterization Summary	16
      6 .5   Remediation Goals	17

7.0   Description of Alternatives	18
      7.1   Alternative 1   - No Action	20
      7.2   Alternative 2   - Capping/Landfilling	20
      7 .3   Alternative 3   - French Drain System	21
      7.4   Alternative 4   - Ground Water Pump and Treat	21
      7.5   Alternative 5   - Solidification/Fixation	21
      7.6   Alternative 6   - On-site Incineration	22
      7.7   Alternative 7   - Bioremediation - Slurry Phase	23
      7.8   Alternative 8   - Bioremediation - Solid Phase	24
      7.9   Alternative 9   - Bioremediation - In Situ	26
      7.10  Alternative 10 - Low Temperature Thermal Aeration..27

8.0   Summary of Comparative Analysis of Alternatives	28

9 .0   Selected Remedy	31

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10.0  Statutory Determinations	32
      10.1  Protective oŁ Human Health and the Environment	32
      10.2  Attainment of the Applicable or Relevant  and
            Appropriate Requirements (ARARs)	32
      10. 3  Cost-effectiveness	34
      10.4  Utilization of Permanent Solutions and Alternative
            Treatment Technologies to the Maximum Extent
            Practicable	35
      10.5  Preference for Treatment as a Principal Element.... 35
                            LIST OF FIGURES

Figure 2.1- Site Location Hap	3

Figure 2.2- Site Layout	4

Figure 5.1- Generalized Stratigraphic Volumn	8

Figure 5.2- On-site Soil Sampling Locations	12

Figure 6.1 - Remediation Areas. ,	.<.,',*	19
                                                   i  »



                             LIST OF TABLES

Table 5.1- Carcinogenicity of  PAHs	13

Table 8.1- Glossary of  Evaluation Criteria	29



                           LIST OF APPENDICES

Appendix A - Site Data

Appendix B - Responsiveness Summary

Appendix C - State's Concurrence Memorandum

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                          Record of Decision

                         The Decision Summary

                  American Creosote Works, Inc. Site

                  Pensacola,  Escambia  County/  Florida
1.0   Introduction

The American Creosote Works,  Inc.  (ACW)  Site was proposed for
inclusion on the National Priorities List (NPL)  in October 1981 and
became final on the NPL in September 1983.  In September 1985,  EPA
signed a Record of Decision (ROD)  for remediation of all on-site and
off-site contaminated solids, sludges, and sediments.  Ground water
contamination was not specifically discussed.  The State of Florida
was not in agreement with the ROD as developed at that time.
Consequently, a Post Remedial Investigation (RI) was conducted in
June 1988 by EPA to provide further information on the extent of
contamination.  A follow-up Risk Assessment was done utilizing the
results of the Post RI.  In August 1989, a Post Feasibility Study
(FS) was completed to identify, develop, and evaluate alternatives
for remediation at the site.   Also in August 1989, the Proposed Plan,
which outlines these alternatives, was released to the public.


1.1   Scope and Role of Operable Unit

As with many Superfund sites, the problems at the ACW site are
complex.  As a result, EPA has organized the remedial work into two
smaller units or phases, referred to as operable units.  The first
operable unit, which is addressed in this Record of Decision (ROD),
will eliminate the potential for direct exposure to the contaminated
surface soil.  The proposed action is consistent with plans  for
future work to be conducted at the site.  The second operable unit  is
undergoing additional study to further define the applicability of
remediation technologies to the contaminated ground water and the
solidified sludges and underlying subsurface soil.

This ROD has been prepared to summarize the remedial alternative
selection process and to present the selected remedial alternative
for the first operable unit.
                                   -1-

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                                  -2-


 2.0    Site  Name,  Location,  and Description:

 The  ACW  site  occupies  18  acres in a moderately dense, commercial and
 residential district of Pensacola, Florida.  See Figure 2.1.  The
 site is  located about  one mile southwest of the intersection of
 Garden and  Palafox  Streets  in downtown Pensacola and is approximately
 600  yards north of  Pensacola Bay and Bayou Chico.  Immediately north
 of the site is a  lumber company, an auto body shop, an appliance
 sales and repair  shop, and  a wide storage area.  Residential
 neighborhoods are immediately adjacent to the site on the east and
 south, and  a  yacht  sales  shop is southwest of the site.  The
 residential population within a one mile radius was approximately
 5,000 people  in 1970.  The  approximate population in the area of the
 site was 1,055 in 1970.   A  total of 404 dwelling units were present
 in this  same  area in  1970.

 The  more pertinent  features of the site are shown on Figure 2.2.  The
 site is  about 2,100 feet  long, east to west, and an average of 390
 feet wide,  north  to south.  Primary access to the site is off Pine
 Street at its intersection  with J Street.  Originally, a railroad
 spur line of  the  Burlington Northern Railroad traversed the site to
 the  west and  east.  .The majority of site buildings, process tanks,
 and  equipment were  situated near the center of  the site in  an area
 designated  as the main plant area.  A  few small work sheds,
 miscellaneous equipment,  and debris lay about the remainder of the
•site. At the present, only two small  buildings remain standing  on
 the  site.

 Four surface  impoundments were  located in the western portion of the
 site. The  main pond and  the overflow  pond, located  adjacent to
 L Street, were used for disposal of process wastes and are  1.8 and
 0.9  acres in  size,  respectively.  During former plant operations,
 liquid wastes periodically  overflowed  and were  drawn off  from  the two
 larger impoundments.   The liquid wastes accumulated  in the  smaller
 0.3  acre railroad impoundment and 0.1  acre holding pond or  were
 spread on the ground in spillage areas.


 3.0    Site  History

 Wood-preserving operations  were carried out at  the ACW  site from 1902
 until December  1981.   Prior to  1950, creosote exclusively was  used  to
 treat poles.  Use of  pentachlorophenol (PCP)  started in  1950  and
 steadily increased  in the later years  of the  ACW  operations.   During
 its  years of  operations,  liquid process wastes  were  discharged into
 two  unlined,  on-site surface  impoundments.  Prior to 1970,
 wastewaters in these ponds  were allowed  to  overflow  through a
 spillway and  follow a drainage  course  into  Bayou  Chico  and
 Bay.

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                  -3-
                         —•-V
                         '»   •
                         i» 9


                   PENSACOLA
           AKESICAS CXŁOSOTE WORKS
•64
SITE LOCATION
AMERICAN C1ZOSOTE WORKS SIT2
PSUSACOU,
                     EBASCO
             E3A3CO 3c3VICES INCORPORATED

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PE.NSACOLA YACHT CLUB
                                        0   200  400   600   800  1000
                                           APPROXIMATE SCALE OF FEET
SITE LATOTTT
AMERICAN OLZOSOTI VORXS SITE
PENSACOLA, FLORIDA
                                  EBA5CO
                       EflASCC SERVICES INCORPORATED

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                                  -5-


 In subsequent  years/ wastewater was periodically drawn off the ponds
 and discharged to designated, on-site spillage areas.  Additional
 dischargee  occurred during periods of heavy rainfall when the ponds
 overflowed  the containment dikes.

 In March 1980,  considerable quantities of  "oily/asphaltic/
 creosotic material" were  found by the City of Pensacola in the ground
 water near  the intersection of L Street and Cypress Street.  In July
 1981,  the U.S.  Geological Survey (USGS) Installed nine ground water
 monitoring  wells in the vicinity of the ACW site.  Samples taken  from
 the wells revealed that a contaminant plume was moving in a  southerly
 direction toward Pensacola Bay.

 In February 1983, the  EPA Site Screening Section conducted a '
 Superfund investigation.  The investigation included sampling and
 analyses of on-site soil, wastewater sludges, sediment from  the area
 drainage ditches, and  existing on-site and off-site monitoring
 wells.   Concurrent with this investigation, the USGS initiated a  site
 and laboratory research study.
 1
 /Because of  the threat  posed to human health and the environment by
 [/frequent overflows from the waste ponds, the EPA Emergency Response
 I/and Control Section performed an immediate cleanup during September
land October 1983.  The immediate cleanup work included dewaterlng the
'two large lagoons (main and overflow ponds), treating the water via
 coagulation, settling, and filtration with subsequent discharge of
 the treated water to the  .City of Pensacola sewer system.  The sludge
 in the lagoons was then solidified with lime and fly ash.  A
 temporary clay cap was placed over the solidified material.  The
 Florida Department of  Environmental Regulation  (FDER) also assisted
 during the  cleanup.

 A Remedial  Investigation/Feasibility Study (RI/FS) under CERCLA was
 completed in 1985 by EPA. In September 1985, EPA signed a Record of
 Decision (ROD)  which specified that all on-site and off-site
 contaminated solids, sludges, and sediments would be placed  in a  RCRA
 (Resource Conservation and Recovery Act) landfill to be constructed
 on-site.  The  remediation activity described would have involved
 excavation  of  significant amounts of soil  from residential areas
 adjacent to the ACW site. Ground water contamination was not
 specifically discussed.   The State of Florida was not in agreement
 with the ROD as developed at that time.

 Consequently,  a Post Remedial Investigation  (RI) was conducted  in
 June 1988 by the EPA Environmental Services Division (BSD)  to provide
 further information on the extent of contamination.  EPA performed a
 follow-up Risk Assessment utilizing the results of the  Post  RI.   In
 August 1989, a Post Feasibility Study  (FS) was  completed to  identify,
 develop,  and evaluate  alternatives for remediation at the  site.
 Using the results of the  Post FS, EPA completed the  Proposed Plan in
 August 1989, which outlined the alternatives under consideration as
 well as the preferred  alternative.

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                                  -6-


3.1   Enforcement Activities

The earliest documented incident of a release of any type from the
ACW site occurred in the summer of 1978 when a spill of liquids
flowed onto a nearby street and then onto the property of a yacht
sales company.  A flood in March 1979 resulted in a similar spill.
This incident resulted in increased regulatory attention to ACW by
the FDER.  In January 1981, the FDER completed a responsible party
search, a title search, and a financial assessment for the site.  In
May 1982, the company, American Creosote Works, Inc., filed for
reorganization in the bankruptcy court.  In 1984, the bankruptcy
court presented a final court stipulation for the approval of the
litigants.  The ACW site would be sold after cleanup and the proceeds
would be divided among FDER, EPA, and the financial organizations
holding the corporation's assets.  The stipulation was entered into
in 1988.

In March 1985, the Burlington Northern Railroad was sent a notice
letter informing them of their potential liability and requesting
that they perform certain tasks at the site.  Specifically, they were
to remove railroad spur lines utilizing an EPA-approved work plan.
The railroad spur lines, the equipment, and most of the buildings
have been removed.   At the present, only two small out-buildings
remain standing on the site.  EPA is investigating to determine
whether any other PRPs exist.


4.0   Community Relations

The Draft Final Post Feasibility Study and the Proposed Plan were
released to the public for comment in August  1989.  These two
documents were made available to the public in both the
administrative record and information repository maintained at  the
EPA Records Center in Region IV and at the West Florida Regional
Library.  The notice of availability for these two documents was
published in the Pensacola News Journal on Monday, August 28,  1989.
A public comment period on the documents was  held  from September 6,
1989 through September 27, 1989.  In addition, a public meeting was
held on September 6, 1989.  At this meeting,  representatives  from  EPA
and FDER answered questions about problems at the  site and  the
remedial alternatives under consideration.  A response to the
comments received during this period is included in  the
Responsiveness Summary, which is part of this ROD.

This decision document presents the selected  remedial  action  for the
contaminated surface soil at the ACW site in  Pensacola, Florida,
chosen in accordance with CERCLA, as amended  by SARA and, to  the
extent practicable, the NCP.  The decision for this  site  is based  on
the administrative record.

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                                  -7-


5,0   Summary of Site Characteristics

5.1   G
-------
 -20-4
 • 40 .-4
         r' '*;/•. rs v  €3i**s^
  -60-4
          \
«
  - aoH
-100 H
           '    ' '   v  • -   ,
           , -:,   ---t^i. ,

          '•• .  ' IU>   v ^   A. \ < .^
          | - \   I   *   '    » •• I
                          "f
         \
UJ
  -120-1
  •140-^
  -180-1
                      '   V
•180 -f
                                     ;•;.:•;.'::;
                                            SAND (SP-SM)-^i:e.to
                                            dark brown, loose to vtry
                                            d«n$«, moiit to ja:ura:ed,
                                            with trace to »om«  iu^
                                            CLAYEY SAND (SO - dark
                                            §r&y te light bro«*/n (»ome red
                                            mnd purpl«), leose, dry to
                                                   , som« sllty sand
                                          CLAY (CH) - white TO blue-
                                          gray (same red, brown and
                                          purple), medium stiff to hard,
                                          dry to moist
                                             , f'Qure 5.1


                                           GENERALIZED

                                   STRAT1GRAPHIC  COLUVN'
                                     American Creosote Wc-'-'.s
                                         Pensacola, Florida

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                                  -9-
5.3   Surface Water
The dominant body of water in the ACW site area is  Penaacola  Bay.
During rainfall events, most runoff from the site passes  through the
streets and storm drains and discharges to the bay.   There  is a small
drainage ditch on the Penaacola Yacht Club property directly  south  of
the ACW surface impoundments.  The drainage ditch begins
approximately 200 feet south of Cypress Street and  extends  to
Pensacola Bay.  Although the drainage ditch is fed  by some  land
surface runoff during rain, most recharge of the ditch is from the
ground water.  The bottom of the ditch is below the top of  the ground
water table.

Pensacola Bay exerts a tidal effect on the drainage ditch.   During
high tides/ water flows north from the bay into the ditch.   When the
tide recedes, water flows south from the ditch to the bay.


5.4   Surface Water Drainage

Storm water drainage at the site is not well-developed.  Most
drainage in the area is by overland sheet flow through the streets
and into storm drains.  Drainage also occurs by way of the drainage
ditch on the Pensacola Yacht Club property.  Storm water runoff
eventually ends up in Pensacola Bay.


5.5   Hydrogeology

In southern Escambia County, practically all the fresh ground water
is obtained from the sand-and-gravel aquifer.  The aquifer is
recharged by local rainfall.  Because of the sandy nature of the
aquifer and overlying soil, infiltration rates are relatively high.
Annual recharge is from zero to ten inches per year.

There are three recognizable geologic subunits within the
sand-and-gravel aquifer in the study area.  The uppermost unit
includes terrace sands with shallow wells to approximately 25 BLS
feet deep.  This unit provides relatively small yields of less than
50 gallons per minute (gpm).  The middle subunit includes the
Citronelle Formation where water supply wells  extend  50  to 150 feet
BLS in depth and have yields ranging from 50 to  several  hundred gpm.
The lowest subunit Includes the Miocene Coarse Clastics  and  the lower
portion of the Citronelle Formation where wells  are over 200 feet  BLS
deep and have yields ranging from  1,000 to  2,000 gpm.

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                                  -10-


Water level measurements from wells installed north of the 20-feet
deep clay layer extend to depths--of less than 100 feet and Indicate
that the ground water within the upper 100 feet is under water  table
conditions.  Water levels from the 20-feet and 60-feet deep wells
indicate similar ground water elevations.  Similar ground water
elevations are expected since recharge to this area is directly from
the infiltration of surface water coming from the overlying ground
water.  South of the site, where the 20-feet deep clay layer is
present, water levels show ground water elevations 0.5 to 3 feet
higher than ground water elevations in the sand overlying this  clay
layer.  This difference in hydraulic head indicates that ground water
below the 20-feet clay layer is confined.  This water level
difference also indicates that an upward gradient exists.  The
ultimate fate of ground water below the 20-feet clay layer is upward
migration to the overlying sand with discharge to Pensacola Bay and
Bayou Chico.

The ground water below the 100-feet clay layer is also under water
table conditions with little difference between wells above and below
this clay layer.  This deeper clay contains profuse layers and lenses
of clayey sand which allow hydrologlc communication between the two
sand units.

The direction of ground water flow is to the south with  discharge to
Pensacola Bay.  There are no public water supply wells in the
immediate vicinity of the ACW site; however, there is an active well
at the Crystal Ice Company plant approximately 1/4 mile  northeast of
the site.  The closest well field belongs to the City of Pensacola
and is located approximately one mile northeast of the site.  The
cones of influence of these wells do not reach the ACW site and are
not affected by the contamination from the ACW site.

Based on data from monitoring wells installed to a depth of 20  feet
BLS, the hydraulic gradient in the unconfined water-bearing zone
above 20 feet is 0.0031.  Based on wells installed to a  depth of 100
feet BLS, the vertical gradient in the confined  zone below  the
20-feet clay layer is 0.0016.  This variation is attributed to  the
confining function of the clay layer.


5.6   Ecology

The ACW site is located in the Pensacola urbanized area.  Vegetation
around the site consists mostly of cultivated grasses,  trees,  and
shrubs.  Trees in the surrounding area are  largely oaks, however,  no
mature trees are present on the site.  Vegetation on  the site  is a
mixture of grasses and other shrubs.

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                                 -11-


Wildlife in the area is typically urban with rodents,  squirrels/
raccoons, opossums,  and'urban bird .species.   Some shore  birds  from
adjacent marine and freshwater habitats frequent  the site.   Fensacola
Bay and Bayou Chico represent critical environmental systems
downgradient of the ACW site.  The ecosystem in these water bodies
has been stressed in the past due to pollution of these  waters caused
by industrial, municipal, and storm water discharges.


5.7   Soil

The most recent soil sampling was conducted in July 1988.   Soil
samples were collected from nineteen grids.   Each grid had a total
land area of 200 square feet.  See Figure 5.2.  Samples  were
collected from the approximate center of each 'area, except around th©
landfill, at depths of 4 to 12 inches BLS, 18 to  24 inches BLS, and
from above the vadose zone for a total of three samples  at each
location.  Four additional 4 to 12 inch BLS aliquots of soil were
collected from each grid area at locations approximately 65 feet from
the grid center at angles of 45, 135, 225, and 315 degrees from
north.  The additional .aliquots of soil were composited with the 4 to
12 inch BLS soil samples collected from the center of. the area to
generate one composite sample.  Polynuclear aromatic hydrocarbons
(PAHs) were detected in most of the soil samples.  PAHs are a diverse
class of compounds consisting of two or more fused aromatic rings.
They are formed during the incomplete combustion of materials
containing carbon and hydrogen and are ubiquitous in the
environment.  PAHs are commonly found as constituents of coal tar,
soots, vehicular exhausts, cigarette smoke, certain petroleum
products, road tar, mineral oils, creosote, and many cooked foods.

Concentrations of carcinogenic PAHs in the upper 12 inches  range from
below detection limits to 498.0 milligrams per kilogram (mg/kg).  The
highest concentration detected in soil samples collected from 18 to
24 inches BLS was 1078.0 mg/kg.  This sample was taken downgradient
of the old waste Impoundment area.  Table 5.1 contains the  list of
carcinogenic PAHs.  Pentachlorophenol was detected  in eight grid
areas across the site.  The concentrations ranged  from below
detection limits to 110 mg/kg.  Three dioxin compounds  including
hexa-, hepta-, and octa-chloro-dibenzodioxin and three dibenzofuran
compounds including hexa-, hepta-, and octa-chlorodibenzofuran were
detected in samples analyzed for these compounds.   The extremely
toxic compounds 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD)
and 2,3,7,8-tetrachlorodibenzofuran were  not detected in any  of the
samples.  Appendix A contains site data obtained during the Post
Remedial Investigation.

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\  &ERA
            FIGURE: 5.2
ON-SITE SOIL SA,"P_"iG LDCAT1QNS
 AMERICAN  CREZCG^e  VGRKS  SITE
       PENSACC'LA, FLGRIDA

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                                 -13-
                               Table 5.1
                        CARCIMOGENICITY OF PAHa
Chemicals for which there is sufficient evidence that they are
carcinogenic in.animals:
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(j)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Dibenzo(a,h)acridine
Oibenzo(a/j)acridine
Dibenzo(a/h)anthracene
7H-Dibenzo(c,g)carbazole
Dibenzo(a,a)pyrene
Dibenzo(a,h)pyrene
Dibenzo(a/i)pyrene
Dibenzo(a/1)pyrene
Indeno(1,2,3-c/d)pyrene
5-Methylcrysene
Chenicals for which there is limited evidence that they are
carcinogenic in animalas
Anthanthrene
Benzo(c)acridine
Carbazole
Chrysene
Cyclopenta(c,d)pyrene
Dibenzo(a,c)anthracene
Dibenzo(a,j)anthracene
Dibenzo(a/e)fluoranthene
2-, 3-, 4-, and 6-Methylchrysene
2- and 3-MethyIfluoranthene
Chemicals for which the evidence is inadequate to assess their
care inogenic ity 8
Benzo(a)acridine
Benzo(g,h,i)fluoranthene
Benzo(a)fluorene
Benzo(b)fluorene
Benzo(c)fluorene
Benzo(g,h,i)perylene
Benzo(c)phenanthrene
Benzo(e)pyrene
Coronene
1,4-DimethyIphenanthrene
Fluorene
1-Methylchrysene
1-Methylphenanthrene
Perylene
Phenanthrene
Triphenylene
Chenicals for which the available data provide  no  evidence that  they
are carcinogenic:
Anthracene
Fluoranthene
Pyrene
Source:  IARC  1983,  1984

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                                 -14-


5.8   Sediment and Surface Water

An examination of the ditch and bay data revealed the  presence of
sediment1 transport of PAH compounds down the ditch and into the bay.
The sediment at the mouth of the ditch is contaminated with PAH
compounds at a total level of 4/000 ug/kg while no PAH compounds were
found in a sample of bay sediment 400 feet east of the mouth  along
the shoreline.  The data from the June 1988 sampling of the shallow
(<20 feet) aquifer was compared to the USGS data and the NUS  RI data
on the shallow.aquifer.  These comparisons suggest that the shallow
ground water contamination is declining.  This fact plus the  slow
movement (low hydraulic potential) of shallow water to the bay
suggests that the shallow ground water will not adversely affect the
bay water quality.  However/ sediment transport of contaminated soil
particulates from the site to the ditch via rainwater runoff  is a
distinct possibility/ particularly if on-site vegetation is not
maintained.  There is an apparent transport of contaminated soil
particles down the ditch which are being deposited into the delta  of
the ditch mouth.  Additional bay sediments and biota sampling will be
needed to assess the impact on biota living in the bay sediment.


6.0   Summary of Site Risks

6.1   Identification of the Contaminants of Concern (Indicator
      Chemicals)

Over 100 different compounds were identified in the analyses  of the
soil samples.  To bring meaning to this large database/ compounds
were grouped according to chemical and toxicological
characteristics.  The following is a listing of the classes  of
compounds found on site and selected as indicator compounds.   The
indicator compounds were selected on the basis of their frequency of
occurrence at the site and their toxicologic properties.  The groups
selected to be carried through the analysis were:

1.    Carcinogenic PAHs
2.    Non-carcinogenic PAHs
3.    Phthalates
4.    Phenols
5.    Pentachlorophenol
6.    Chlorinated dioxins-dibenzofurans

Other classes of compounds were found/ but  only  sporadically, at  low
concentrations.


6.2   Exposure Assessment Summary

The risk assessment  for this  site was  developed  using a mathematical
modeling program designed to  perform probabilistic  risk analysis
using a Monte Carlo  technique.

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                                 = 15- '


In this program, risk-related parameters (such as  body weights,
absorption factors and exposure frequency)  are input  as  ranges with
probability distributions,  and probability  distribution  of risk  is
the output.

The pathways considered for development  of  the cleanup goals  for the
contaminated surface soil were:

1.    Oral and dermal exposure to surface soil in  the following
      locationsi

      a. American Creosote Works site
      b. Residential areas
      c. Drainage ditch area
      d. Condominium block

2.    Inhalation exposure to airborne particulates from ACW site
      surface soil which may be experienced by individuals residing
      in nearby residential areas.

3.    Ingestion of home grown crops in contaminated soil in
      residential areas.


6.3   Summary of the Toxicity Assessment of the Contaminants of
      Concern

Cancer potency factors (CPPs) have been developed by BPA's
Carcinogenic Assessment Group for estimating excess lifetime cancer
risks associated with exposure to potentially carcinogenic
chemicals.  CPFs, which are expressed in units of («ig/kg-day)   ,
are multiplied by the estimated intake of a potential carcinogen, in
mg/kg-day, to provide an upper-bound estimate of the excess lifetime
cancer risk associated with exposure at that intake level.  The term
"upper bound" reflects the conservative estimate of the risk
calculated from the CPF.  Use of this approach makes underestimation
of the actual cancer risk highly unlikely.   Cancer potency factors
are derived from the results of human epidemiological studies or
chronic animal bioasaays to which animal-to-human extrapolation and
uncertainty factors have been applied.

Reference doses (RfDs) have been developed by EPA for indicating the
potential for adverse health effects from exposure to chemicals
exhibiting noncarcinogenic effects.  RfDs, which are expressed  in
units of mg/kg-day, are estimates of lifetime daily exposure levels
for humans, including sensitive individuals.  Estimated intakes of
chemicals from environmental media (e.g., the amount of a chemical
ingested from contaminated drinking water) can be compared to the
RfD.  RfDs are derived from human epidemiological studies or animal
studies to which uncertainty factors have been applied  (e.g., to
account for the use of animal data to predict effects on humans.)
These uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse noncarcinogenic effects to
occur.

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                                  -16-


To characterize the toxicologic properties of dioxins-dibenzofurans'/
the Toxicological Equivalent Factor (TEF)  approach,  aa developed by |
BPA, waa uaed to relate all dioxin/furan congeners to the more  toxic
2,3,7,8-TCDD.  Carcinogenic PAHs were all assigned the carcinogenic
potency factor (CPF) developed with benzo(a)pyrene data by EPA.
Phthalates were represented toxicologically using critical toxicity
values for bis-(2-ethylhexyl)-phthalate and phenolic compounds  by
toxicologic parameters derived for 2,4-dimethylphenol.
Compound-specific toxicologic data were used for pentachlorophenol.
Risks for exposure to non-carcinogenic PAHs were characterized  using
toxicologic parameters for naphthalene.


6.4   Risk Characterization Summary

The receptor population was separated into four age groups.  They are
1 to 6, 7 to 11, 12 to 18, and over 18 years old.  Separate skin
surface ranges, body weight ranges, exposure frequencies, and soil
ingestion rates were used for each group.  Non-carcinogenic risks
were calculated for each age group.  Lifetime cancer  risks were
calculated by summing the risks for each age group.

Excess lifetime cancer risks are  determined by multiplying the  Intake
level with the cancer potency factor.  These risks are probabilities
that are generally expressed in scientific notation      fi
(e.g., IxlO"6).  An excess lifetime cancer risk of  lxlO"p|s
indicates that, as a plausible upper bound, an individual has a  one^
in one million chance of developing cancer as a result of
site-related exposure to a carcinogen over a 70-year  lifetime under
the specific exposure conditions  at a site.

Potential concern for noncarcinogenic effects of  a  single contaminant
in a single medium is expressed as the hazard quotient  (HQ).  The  HQ
is the ratio of the estimated intake derived from the contaminant
concentration in a given medium to the contaminant's  reference  dose.
By adding the HQa for all contaminants within a medium  or across all
media to which a given population may reasonably  be  exposed, the
Hazard Index (HI) can be generated.  The  HI provides  a  useful
reference point for gauging the potential  significance  of multiple
contaminant exposurea within a single medium or  across  media.

The total upperbound lifetime carcinogenic risks  from
dermal-ingestion exposure of both carcinogenic PAHs and dioxins in
the various study areas aret

   Area   	   Median	  gQth percentile estimate

   On-site                2.6 x  10~4         1.2  x 10"3

   Residential            1.6 x  10~6         6.6  x 10"6

   Ditch                  2.7 x  10'6         1.2  x 10'4

   Condominium Block      7.4 x  10~5         1.9  x 10"4

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a
                                  -17-


.The risk results also indicate the potential for non-carcinogenic
health risks (in all cases due to exposure to dioxins-dibenzofurans)
in Areas I and IV.  Non-carcinogenic risks are not.predicted to be  a
hazard for exposure to contaminated soil in Areas II and III.  The
median upperbound cancer risk estimate for exposure to airborne
particulates derived from site soil was 6.1x10",  The 90th
percentile risk estimate was 4.1x10" .

The vegetable pathway does not appear to be a pathway of concern
based on analytical data collected during the vegetable garden study
of 1985.  However, to assess present conditions and to provide
assurance of the protection of public health and the environment,
limited sampling will be conducted during the Remedial Design.


6.5  Remediation Goals

Of the six substances selected as indicator compounds, only the total
carcinogenic PAHs, dioxine, and PGP were present in concentrations
requiring remediation considerations.  Surface soil remediation goals
for the total carcinogenic PAHs were developed based on the risk
assessment and the following factors:

    a.   the cancer potency factor  (CPF) for benzo(a)pyrene is very
         conservative and a reduction of this value is being
         considered by EPA;

    b.   the sum carcinogenic PAHs of the concentrations detected  in
         site samples were comprised of only 5 to 10% benzo(a)pyrene
         with individual PAHs having a much lower carcinogenic
         potency comprising the major percentage;

    c.   natural degradation of PAH compounds occurs  in soil,  and
         using a standard 1.25 years of half-life assumption,  the
         calculated decay rate indicates that soil  concentration
         would decrease naturally by an order of magnitude  about
         every five years.

Based on this evaluation, the surface soil  remediation  goal for the
carcinogenic PAHs at the site was established to be 50  parts per
million (ppm).

Surface soil remediation goals for  dioxins  were  also  determined.
Applying the median exposure estimates, a  soil  level  of 0.3 parts  per
billion (ppb) 2,3,7,8-TCDD toxicity equivalency  concentration would
yield an upper risk of 1 x 10~.  The use  of the median estimate
and the 1 x 10~5 is considered to be appropriate  for  protection of
human health.  However, the CPF for 2,3,7,8-TCDD  is very conservative
and under consideration by the Agency for  a tenfold (plus)  decrease
in its numerical value.

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                                  -18-


Also/ ATSDR/CDC .has indicated that 1 ppb 2,3,7,8-TCDD la  a reasonabs
soil level to begin consideration of remedial action.  Therefore, th©
soil cleanup level was established at 2.5,ppb for 2/3,7,8-TCDD
toxicity equivalency for this site.

EPA's interoffice work group, Carcinogen Risk Assessment  Verification
Endeavor (CRAVE), and the Office of Research and Development have
recently reclassified PCP from a  "D" to a "B2" (probable) human
carcinogen.  A cancer potency factor has yet to be determined but ORD
has Indicated that the upper limit of the range of values being
considered is 1.0.  Applying this potency value of 1.0, median
exposure values, and the 1 x 10"5 upper bound risk level determined
for CPAHs and dioxin/ the soil cleanup level for PCP is 30 ppm.

The analytical data was examined based on the cleanup levels for the
carcinogenic PAHs, PCP, and the dioxin/furan.  All sample results
were below the 2,3,7,8-TCDD equivalents (1987 TEQs) cleanup level  of
2.5 ppb.  Figure 6.1 depicts the remediation areas based on PCP and
the carcinogenic PAHs.

Actual or threatened releases of hazardous substances from this site,
if not addressed by implementing  the response action selected in this
ROD, may present an unacceptable  risk to public health, welfare, or
the environment.


7.0 Description of Alternatives

The following alternatives for remediation were evaluated in the Post
Feasibility Study reporti

     1)  No Action
     2)  Capping/Landfilling
     3)  French Drain System
     4)  Ground Water Pump and Treat
     5)  Solidification/Fixation
     6)  On-site Incineration
     7)  Bioremediation: Slurry Phase
     8)  Bioremediation: Solid Phase
     9)  Bioremediationt In situ
    10)  Low Temperature Thermal Aeration

Alternatives 1, 3, 4, 7, 8, and 9 were  developed  to  address  the
contaminated ground water and solidified soil at  the site.
Alternatives 1, 2, 5, 6, 7, 8, 9, and 10 were developed  to  address
the surface soil contamination.   Based  on the cleanup  levels
developed for the American Creosote Works site,  the  estimated volu.---
(worst case estimate) to be remediated  is 23,000  cubic yards.
Additional sampling will be conducted during the  remedial design
phase to further define  the volume  to be remediated.

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                                            PENSACOLA  BAY
LEGEND
CPAH > 50ppm
 PCP> 30pptu and
 'CPAH > 50ppm
FIGURE 6.1

 REMEDIATION

    AREAS
                                                AMERICAN CREOSOTE Rl
                                                  PtNSACOUA, FIOR;CA
                                                   USEPA REGION IV

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            •".--.-•                 -20-


7.1   Alternative li  No Action

The Superfund program requires that the no action alternative be
considered at every site.  Under the no action alternative/  EPA would
take no further action at the site to control the source of
contamination.  The no action alternative serves as a baseline with
which other alternatives can be compared.

Potential health risks associated with current exposure paths would
remain on site.  This alternative exceeds the,target risk range  and
does not attain -applicable or relevant and appropriate requirements
(ARARs).  The no action alternative proposes leaving the site  in its
present condition without disturbing the contaminated surface  soil.
Associated with the no action alternative would be continued
long-term monitoring of ground and surface water, construction of a
perimeter fence/ posting of warning signs on this fence, and ground
water and land use restrictions.  A public health assessment would be
performed every five (5) years to evaluate potential changes in risk
associated with no action.

The estimated present worth cost of this alternative is $408,000
which includes $330,000 for operation and maintenance.


7.2   "Alternative 2:  Capping/Landfilling

The capping/landfilling alternative would consist of placing the
contaminated soil into a double-lined land vault with a permanent ca
over the facility in accordance with the Resource Conservation and
Recovery Act  (RCRA) regulations.  The landfill would occupy about
five (5) acres of the site and would rise to  about  five  (5) feet
above the existing ground level, assuming the total volume of waste
material disposed is 23,000 cubic yards.  The landfill would be
vegetated and would have a perimeter drainage ditch and a perimeter
road.  A new surface drainage system will be  needed to control runon
and runoff.  A 24-inch thick clay capsule will be required.  Other
large volumes of clean fill and drainage material will have to be
brought on to the site.  Also, an additional  fence would be built
immediately surrounding the vault's perimeter road  to preserve the
landfill's integrity.

A semi-annual monitoring program to analyze  for  those ground water
constituents of concern would be  implemented  for a  period of five (5)
years.  A public health assessment would be  conducted by EPA every
five (5) years following remedial action completion.   Following  tha
first assessment, monitoring would continue  annually  for an
additional twenty-five  (25) years provided the  public  health
assessment does not Identify a need for  further  remedial action  or
monitoring.

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                                 -21-


This alternative would serve as an effective  measure  toward
preventing exposure by'ingestion of contaminated  soil,   The vault
roust be maintains^ in perpetuity and will  be  an eyesore  near  prime
Florida water front properties.  This alternative does not meet
CERCLA/SARA's preference for treatment of  contaminants but would
significantly reduce their mobility.

The total present value cost for this alternative is  estimated at
$2,250/000 which includes $330,000 for operation  and  maintenance.


7.3      Alternative 3i  Trench Drain System

Because this operable unit is only addressing remediation
alternatives for the contaminated surface  soil, the french  drain
alternative will not be discussed in this  ROD since it  addresses  the
existing ground water contamination."


7.4      Alternative 4:  Ground Water Pump and Treat

Because this operable unit is only addressing remediation
alternatives for the contaminated surface  soil,  the ground water pump
and treat alternative will not be discussed in this ROD since it
addresses the existing ground water contamination.


7.5 Alternative 5i  Solidification/Fixation

A Portland cement based pozzolan solidification/fixation of
contaminated surface soil would be accomplished by excavating the
contaminated areas to depths determined by the latest (1988)  sampling
effort.  The total estimated volume of contaminated soil to be
solidified is 23,000 cubic yards.  The solidified material would then
be disposed of by backfilling into previously excavated areas of the
site.  Standard construction equipment would be utilized.  When
solidification is complete, a 12-inch thick vegetated cover would be
placed over the solidified mass.

Treatability or bench-scale studies would be required to determine
the proper waste pozzolan rating and the particular pozzolan
constituents.

In the first five  (5) years following completion  of this alternative,
semi-annual ground water monitoring would occur.  At five  (5) years,
a public health assessment would be conducted by  EPA.   Following this
assessment, monitoring activities would be terminated,  provided that
the public health assessment does not identify a  need for  further
remedial action or monitoring.

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                                 -22-


Ground water use restrictions would be imposed within a  reasonable
distance from the site.  Land use restrictions would  be  imposed on
the site tb prevent disturbance of the solidified material.  Support
activities include removing debris, repairing the fence,  clearing and
grubbing the vegetation, and grading the site.

This alternative should effectively break the ingestion  exposure
pathway.  Solidification/fixation, an established technology with
improving techniques would immobilize contaminants, minimize
potential leaching, and improve the handling characteristics of the
contaminated media; however, it would increase the volume.   The
organic compounds would not 'interfere with the setting,  curing, and
performance of the solidified material..

Solidification/fixation processes are successful with soil containing
up to 10,000 ppm PAHs; the bonding of contaminants to the stabilizing
agent should not be impacted by long-term site-specific
characteristics.

The total present value cost for this alternative is  estimated to  be
$3,249,600 which includes $339/600 for operation and  maintenance.


7.6   Alternative 6s  On-site Incineration

Prior to incineration, all of the waste would ta excavated and
screened.  Size reduction equipment such as shredders would be used
to reduce solid particle size.  During excavation, temporary erosion
control devices would be required to prevent detrimental effects  to
the surface water quality south and southeast of the site.  Specific
incinerator unit availability is uncertain; however,  it is probable
that demand for units would dictate supply.  A number of portable
rotary kiln incinerators are available with capacities up to 500 tons
per day.  If this alternative ia used, it would be necessary to
conduct test burns.  Pollution control equipment, such as cyclones
and scrubbers, youId be necessary  to collect  and treat exhaust gases
and suspended particulates.  The lack of fine particles  (except for
portions of the contaminated clay  cap already in place)  in  soil feeds
will not result in high particulate loading  in flue  gases.  This
excessive loading would occur with fine particles due to the
turbulence in the rotary kiln  (if  a rotary kiln  incinerator is
utilized).  Therefore, pollution control activities  can  be  expected
to be of average intensity  at  the  Bite,

A semi-annual ground water  monitoring program to analyze for  those
ground water constituents of concern would be implemented  for a
period of five  (5) years after  the completion of the incineration.
At that time a public  health assessment would be conducted by EPA.

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                                 -23-


Following thia assessment,  monitoring would, be  terminated, provided
the public health assessment does not identify  a  need  for  further
remedial action or monitoring.   Ground water use  restrictions would
be imposed within a reasonable  distance of  the  site  in keeping with
the establishment of ground water quality standards.

This alternative would permanently and effectively destroy the
contamination present in the surface soil that  exceed  cleanup goals.
All risk of exposure by ingestion of contaminated soil would be
eliminated.  Incineration is a  proven technology  at  hazardous waste
sites and reduces toxicity, mobility, and volume  of  hazardous
materials.  This alternative meets all ARARs.

The total present value cost for this alternative is estimated  to be
$9/990,000 which includes $330,000 for operation  and maintenance.


7.7   Alternative 7»  Bioremediation - Slurry Phase

This technology involves the treatment of contaminated surface  soil
in a large (mobile) bioreactor.  This system maintains intimate
mixing and contact of microorganisms with the hazardous compounds and
creates the appropriate environmental conditions  for optimizing
microbial biodegradation of target contaminants.   There may be air
emissions 'from the bioreactor which may cause complaints from the
community.  The bioreactor would have to be enclosed and air
pollution control equipment utilized to mitigate the air emissions
from the bioreactor.

The total volume of contaminated surface soil is estimated at 23,000
cubic yards.  The soil would have to be excavated and screened.
Excavation of the contaminated soil would require erosion control
measures to prevent impact to the surface water quality south and
southeast of the site.  The soil is then mixed with water to obtain
the appropriate slurry density.  The water source would likely be
contaminated ground water.  The typical soil slurry contains about
fifty (50) percent solids by weight.  The slurry is mechanically
agitated in the reactor vessel to keep the solids suspended.
Nutrients, oxygen, and pH control chemicals may be added to maintain
optimum conditions.  Microorganisms may be added to maintain the
correct concentration of bioroass.  The volume of the bioreaction and
the residence time for each batch will determine the amount of ti.-ne
necessary to biotreat the contaminated material.   Once biodegradati.cn
of the contaminants is completed, the treated slurry  is dewatered.
The residual water may require further treatment prior to disposal.
Fugitive air emissions of VOCs can be controlled by enclosing the
bioreactor.  Three or more companies have working slurry-phase
bioreactors immediately available for scheduling.

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                                  -24-


A prerequisite for the use of the slurry-phase bioreactor may be  th
design and construction of a ground water extraction system so that
ground water may be used for slurry water.  Also, further water
treatment may be necessary before ground water may be sent to a
publicly owned treatment works (POTW) or disposed of in another
fashion.

This alternative would permanently and effectively destroy the
contamination in the surface soil.  All risk of exposure by ingestion
of contaminated soil would be eliminated.  Slurry-phase
biodegradatlon is a proven technology at hazardous waste sites and
reduces the toxicity, mobility, and volume of hazardous contaminants
in soil and ground water.

The decanted ground water resulting from the settling of the
bioreactor sludge may be reused in the bioreactor or be tested and
disposed by simply being sent to the local POTW.

A semi-annual monitoring program to analyze for those constituents of
concern would be implemented for a period of five (5) years upon
completion of the remedy.  A public health assessment would be
conducted by EPA at the end of the five  (5) years.  Following this
assessment/ monitoring activities would be terminated, provided that
the public health assessment does not identify a need for further
remedial action or monitoring.  This alternative meets all ARARs.
 •»

The total present value cost for this alternative is estimated to be
$3,258,000 which includes $330,000 for operation and maintenance..


7.8   Alternative 8:  Bioremediation - Solid Phase

With this technology, the contaminated surface soil  (23,000 cubic
yards) would be excavated, disaggregated, and screened as in the
description of the slurry-phase bioremediation and stockpiled  in a
lined contaminant area on-site.  Excavation of soil would require
temporary erosion control measures to preserve surface water quality ,
south and southwest of the site.

The on-site excavated areas to be used for a land treatment area
would be filled and leveled with clean fill.  The treatment area
would have been graded to flow water and leachate to one  corner of
the area.  The land treatment area would be lined with a  high  density
polyethylene (HOPE) geomembrane liner with welded seams.  Over the
liner, flat perforated plastic pipe covered with filter  fabric would
form a drainage system to conduct water  and leachate to  a retention
pond.  The liner and drainage system would be covered with at  least
six (6) inches of clean sand to promote  drainage.  Contaminated soil/
having been disaggregated, would be laid on the sand in  six  (6) inch
lifts.

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                                   -25-


  Local  naturally-occurring bacteria would be used to seed the spread
  soil and  nutrients, and moisture would be added to promote the growth
  of biomass.  Leachate and drain water would be collected and sprayed
  over the  treatment area when the soil moisture content fell too low.
  The soil  would be tilled periodically to facilitate soil
  particle/bacteria contact.  Some PAHs would be eliminated by
  photolysis and by volatilization due to the direct sunlight and hot
  weather.  Air emissions may be a problem at certain times and may
  cause  complaints from nearby residences.

  The land  treatment area and the stockpile area would occupy all of
  the site  area.  A fence already exists around the site, but may have
  to be  re-set or added to.  Treatment of 23,000 cubic yards of
  PAH-contaminated soil would probably take at" least two (2) years.
  Treated soil could be left where they lay or spread over  the entire
  site.
    4
  Continuous monitoring of the dissolved oxygen, pH, nutrients, soil
  moisture  content, etc., would be required.  A temperature range of
  50-100°F. would be required.  Air emissions  from the treatment area
  due to volatilization would be significant just after the initial
  spreading of the soil when levels of  soil contamination are still
  high.

  Contaminated soil would be effectively treated and the ingestion
  exposure  pathway broken.  Given time, solid-phase bioremediation
  would  satisfy most AR&Rs at the site.

  A  semi-annual monitoring program to analyze  for those constituents  of
  concern would be implemented for a period of five  (5) years.  A
  public health assessment would be conducted  at that time.   Following. ..
  this assessment, monitoring activities would be terminated, provided
  that the  public health assessment does not identify a need  for
ffurther remedial action or monitoring.  Ground water use  restrictions
/  would  be  imposed within a reasonable  distance  from the site.  Land
j  use restrictions would be imposed to  prevent use of the site  for
  residential purposes.

  Implementation time for this alternative  is  expected to be  several
  years.  However, the projected unit costs make  this alternative
  competitive with other technologies.  This alternative would be  as
  effective towards the protection of public health  and  the environment
  as other  treatment technologies.  In  addition,  climatic  conditions  of
  the site  are favorable for this type  of treatment.

  The total present value cost for this alternative  is estimated to be
  $2,275,000 which includes $319,000  for operation and maintenance.

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                                  -26-


7.9   Alternative 9«  Bioremediation - In Situ

In situ bioremediation would require the design of a ground w^ter
pumping and reinjectlon system both on-site and off-site,   soil would
not require excavation.  The natural biodegradation process would be
enhanced by injecting nutrients (i.e., phosphorus, nitrogen, etc.),
oxygen (e.g., hydrogen peroxide), and even cultured bacterial
strains.  Adjustments to pH may also be made.  The ground water
pumping and reinjection would circulate nutrients and oxygen through
a contaminated aquifer and the associated soil.  Aerobic
biodegradation generally proceeds more rapidly than anaerobic
biodegradation.

In situ bioremediation would directly attack both soil and ground
water contamination.  Ground water use restrictions would be imposed
within a reasonable distance from the site.  Land use restrictions
would not need to be imposed if both soil and ground water
contamination were reduced to insignificant levels.

Continuous monitoring of the dissolved oxygen, pH, nutrients, etc.
would be required.  Temperatures in the subsurface soil and in ground
water at various depths would have to be monitored.  Odors may be
forthcoming from the extraction/reinjection system and may cause
complaints from the public.  Odors may be emitted from the process
area.  Ground water would not be able to be used for drinking or
irrigation by anyone in the site area because of the high bacterial
counts and the intermediate breakdown products of the
biodegradation.  High bacterial count in the ground water during
processing would prohibit the use of ground water even for
irrigation.

ROD cleanup levels and additional alternate concentration levels
(ACLs) may not be able to be completely met by this alternative in a
short period of time.  The original time for implementation may have
to be extended.

A semi-annual monitoring program to analyze  for those constituents of
concern would be implemented for a period of five  (5) years  after the
completion of the remedial action.  A public health assessment would
be conducted at that time.  Following1 this assessment, monitoring
activities would be terminated, provided that  the public  health
assessment does not Identify a need for further remedial  action or
monitoring.

This alternative should be able to satisfy most ARARs over a period
of time.

The total present value cost for  this alternative is estimated  to  b«
$2,299,000 which includes $319,000  for operation  and maintenance.

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                                 -27-


7,10  Alternative 10:   Low Temperature Thermal  Aeration

Twenty-three thousand (23/000)  cubic yards  of  surface  soil  would be
excavated, disaggregated,  screened/  and stockpiled.  The  prepared
soil would then be introduced to the low temperature thermal  aeration
(LTTA) equipment (processing equipment which would operate  at its
maximum temperature of 800°F.)    Process residuals would  be
processed soil/ ash from the afterburner or spent carbon/ and stack
gases.  A bench-scale or small  pilot-scale  test burn would  be needed
to evaluate the technical  effectiveness and cost-effectiveness of  the
process at this site.

Presently/ Weston Services, Inc. has a system available which can
process up to 7.5 tons/hour.  The process should produce removal
efficiencies greater than 90 percent for 1, 2,  and 3-ring PAHs.  PAHs
with four or more rings would need higher temperatures for
volatilization.  If necessary/  other technologies could be  used for
these remaining PAHs.   Stack gases would have to be continuously
monitored to ensure that air pollution was  not occurring.

A semi-annual monitoring program to analyze for those constituents of
concern would be implemented for a period of five (5)  years after the
completion of the remedial action.  A public health assessment would
be conducted at that time.  Following this  assessment/ monitoring
activities would be terminated/ provided that the public health
assessment does not identify a need for further remedial action or •
monitoring.

This alternative would probably permanently and effectively strip
contaminated soil that exceed cleanup goals.  All risk of exposure by
ingestion of contaminated soil would be eliminated.  Low temperature
thermal aeration should reduce the toxicity, mobility/ and volume of
hazardous constituents in the soil.  This alternative should satisfy
most ARARs.

The total present value cost for this alternative is estimated to be
$3/048,000 which includes $330/000 for operation and maintenance.

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                                .  -28-


8.0   Summary of Comparative Analysis of Alternatives

This section provides the basis for determining which alternative
provides the best balance of trade-offs with respect to the
evaluation criteria.  The major objective of the Post Feasibility
Study (FS) was to develop/ screen/ and evaluate alternatives for
remediating the American Creosote Works site.  This decision document
deals with the contaminated surface soil.  Several remedial
technologies were identified for the surface soil cleanup.  These
technologies were screened based on their feasibility given the
contaminants present and the site characteristics.

Those which remained after the initial screening were evaluated in
detail based on the nine criteria required by SARA.  Cost was used to
compare alternatives only when they provided similar degrees of
protection and treatment.  A summary of the relative performance of
the alternatives  with respect to each of the nine criteria is
provided in this section.  A glossary of the evaluation criteria is
offered in Table 8.1.

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                                 -29-


                               Table 8.1

                    qLQSSARY OF EVALUATION CRITERIA

Overall Protection of Human Health and the Environment - addresses
whether or not a remedy provides adequate protection and describes
how risks posed through each pathway are eliminated, reduced,  or
controlled through treatment, engineering controls, or institutional
controls.


Compliance with ARARs - addresses whether or not a remedy will meet
all of the applicable or relevant and appropriate requirements of
other Federal and State environmental statutes and/or provides
grounds for invoking a waiver.


Long-term Effectiveness and Permanence - refers to the magnitude of
residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time once cleanup
goals have been met.


Reduction of Toxicity. Mobility, or Volume - is the anticipated
performance of the treatment technologies that may be employed in a
remedy.


ghort-term Effectiveness - refers to the speed with which the remedy
achieves protection,  as well as the remedy's potential to create
adverse impacts on human health and the environment that may result
during the construction and implementation period.


Implementability - is the technical and administrative feasibility of
a remedy/ including the availability of materials  and services needed
to implement the chosen solution.


Cost - includes capital and operation and maintenance costs.


State Acceptance - indicates whether the State concurs with,  opposes,
or has no comment on the preferred alternative.


Community Acceptance - will be  assessed  in  the Responsiveness Summary
in the appendix of the Record of Decision after  reviewing  the public
comments received on the Post Feasibility Study  *nd the  Proposed
Plan.

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                                 -30-


        Protection of Human Health and the Environment

      All of the alternatives with the exception of the  no action
      alternative would provide adequate protection of human health
      and the environment by eliminating, reducing, or controlling
      risk through treatment, engineering controls, or institutional
      controls.

      Because the no action alternative would not be protective of
      human health and the environment, it is not considered further
      in this analysis as an option for the site.


Compliance with Applicable or Relevant and Appropriate Requirements

      All alternatives would meet their respective applicable or
      relevant and appropriate requirements of Federal and State
      environmental laws; however, Alternative 2 - RCRA Landfilling,
      does not meet SARA'S (Superfund Amendments and Reauthorization
      Act) preference for treatment.


Long-term Effectiveness and Permanence

      Long-term effectiveness and permanence would be provided by ali
      alternatives through elimination of risk posed by contaminants!
      at the ACW site.


Reduction of Toxicitv. Mobility, or Volume

      Alternative 2 does not provide for a reduction of toxicity or
      volume of the contaminants but would, reduce  their mobility.
      Alternative 5 would reduce toxicity and mobility but not volume
      of the contaminants.  Alternatives 6, 7,  8,  9, and 10 would
      reduce toxicity, mobility, and/or  volume,


Short-term Effectiveness

      The alternatives will require varying amounts of  time to
      achieve cleanup of the site.  All  alternatives would have a
      degree of short-term effectiveness.  Compared to  the other
      alternatives, the  in situ bioremediatlon  alternative would not
      have as great a degree of short-term effectiveness due  to the
      time required for  bacterial culture  growth.   Any  short-term
      risk to workers involved  in construction  of  the remedy  would be
      reduced through implementation  of  a health and  safety plan.

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                                 -31-
Implementability-
Cost
      All alternatives are implementable,  however/  it  is  important  to
      note that all alternatives would require various steps  to  reach
      full-scale implementation.  These initial activities  would
      Include items such as treatability studies, bench-scale or
      pilot-scale studies, test burns, and culturing of bacterial
      strains.
      The present estimated cost of EPA'a selected remedy ranges  from
      2.3 million to 3.3 million dollars.  The selected remedy
      provides overall effectiveness proportional to its costs such
      that the remedy represents a reasonable value for the money.
      When the relationship between cost and overall effectiveness  of
      the selected remedy is viewed in light of the relationship
      between cost and overall effectiveness provided by other
      alternatives/ the selected remedy appears to be cost-effective.


State Acceptance

      The State of Florida as represented by the Florida Department
      of Environmental Regulation' is in favor of the selected remedy
      for remediating the surface soil at the ACW site.


Community Acceptance

      Based on comments made by citizens at the public meeting held
      on September 6, 1989, and those received during the public
      comment period/ the community believes the selected remedy will
      effectively protect human health and the environment.


9.0   Selected Remedy
                                                           i
EPA selects biological treatment (bioremediation) as the most
appropriate alternative technology to remediate the ACW site.  Based
on available data and analysis to date, solid phase bioremediation
(Alternative 8) is expected to be the most appropriate solution- for
meeting the goals of the initial surface soil operable unit at the
American Creosote Works site.  However, treatability studies would be
conducted during the pre-design phase to determine the most effective
type of biological treatment (i.e. slurry phase/ solid phase/ or in
situ phase).   Solid phase bioremediation includes excavation and
treatment of soil in an on-site land treatment area.  At the present,
EPA is successfully applying this technology at another Superfur.d
site in Florida.

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                                 -32-


Based on current information,  the selected provides  the best balance
among the nine criteria that EPA uses to evaluate alternatives.  The'
rationale- for choosing this alternative includes  .the following
reasons:

      provides immediate protection to human health  from  the
      potential threats associated with direct contact with the
      contaminated surface soil;

      contributes to the implementation of a more permanent remedy
      at the site;

      ie consistent with additional site actions  and will be
      compatible with the final site remedy;


10.0  Statutory Determinations

The U.S. EPA and PDER have determined that this remedy will satisfy
the statutory requirements of Section 121 of CERCLA by providing
protection of human health and the environment/ attaining ARARs,
providing cost-effectiveness,  and utilizing permanent solutions and
alternative treatment technologies or resource recovery technologies
to the maximum extent practicable.  Sections 10.1 and 10.5 below are
the statutory requirements for this site.


10.1  Protection of Human Health and the Environment

The selected remedy of solid phase bioremediation provides protection
of human health and the environment by eliminating the direct threat
through dermal contact with contaminated surface soil.  The source of
contamination, the surface soil, will be excavated and treated.  For
a short period following excavation, concentrations of contaminants
might exceed ARARs but this concentration will decrease after time
with treatment.


10.2  Attainment of the Applicable or Relevant and,Appropriate
      Requirements (ARARs)       ,

Remedial actions performed under CERCLA, as  amended by SARA, must
comply with all applicable or relevant and  appropriate requirements
(ARARs).  All alternatives considered  for the ACW site were evaluated
on the basis of the degree to which they complied with these
requirements.  The recommended alternative  was found  to meet or
exceed the ARARs.

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                                 -33-


when ARARs are not available for specific compounds or exposure media
(such as soil), the cleanup goals are based on Agency reference doses
(RfD) for nonearcinogens and 10~5 risk levels for carcinogens
derived by use of Agency potency factors and site specific exposure
assumptions.

No Federal or State contaminant-specific ARAR has been identified for
PAH, PCP, or dioxin-contaminated soil.

Potential Federal location-specific ARARs for the ACW site include
the following:

      Resource Conservation and Recovery Act (RCRA) location
      requirements - Mandates that hazardous waste treatment,
      storage, or disposal facilities located within a 100-year
      floodplain must be designed,  constructed, operated, and
      maintained to avoid washout.

      Fish and Wildlife Coordination Act - Requires adequate
      protection of fish and wildlife if any stream or other body of
      water is modified.                                              "
                                                                      :*M-
      Endangered Species Act - Requires action to conserve endangered f"  ;*
      or threatened species for activities in critical habitats upon  '-*  -f
      which these species depend.                                     ~  T

      National Historical Preservation Act - Requires that action be
      taken to preserve or recover historical or archaeological data
      which might be destroyed as a result of site activities.           s:

Federal regulations that contain potential action-specific ARARs for' ±""' f
the site are listed below*       ~~	  -                             '*? *

      4Q CFR Section 264.99  Compliance Monitoring Program -
      Establishes criteria for monitoring ground water quality when
      contaminants have been detected,  This involves development of
      a ground water quality data base sufficient enough  to
      characterize seasonal fluctuations in ground water  quality at
      the site.

      Clean Water Act (CWA) - Provides criteria  for ground water
      remediation and discharge into surface waters.

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                                 -34-


               Conservation and Recovery Act fRCRAl -  The provisions
      of RCRA pertinent to the ACW site have been promulgated under
      40 CFR Parts 257, 260, 261, 262,  263,  264,  269,  and 280.  EPA
      has determined that the above regulations are applicable  to
      RCRA characterized or listed hazardous wastes (40  CFR Part 260)
      which were either»  1) were disposed at a site after
      November 19, 1980; or 2) the CERCLA remedial action consists of
      treatment, storage, or disposal as defined by RCRA (40 CFR Part
      264).  In addition, the regulations are relevant and
      appropriate to RCRA hazardous wastes disposed at a site prior
      to November 19, 1980,  Examples of RCRA requirements  include
      minimum technology standards, monitoring requirements, and
      storage and disposal prohibitions.

      Clean Air Act  (CAA) - The CAA requirement's may be applicable  in
      cases where on-site thermal destruction is considered.

      Land Disposal Restrictions - The LDRs are applicable  to the
      waste on-site if the soil is excavated and removed or excavated
      and treated.  In alternatives where the LDRs are applicable,
      the soil must be treated to the interim treatment levels  prior
      to land disposal.

      Section 121(d^ of the Superfund Amendments and Reauthorization
      Act fSARAV - SARA requires that the selected remedial action
      establish a level or standard of control which complies with
      all ARARs.  At the ACW site, ground water discharges into
      Pensacola Bay and, therefore, beyond the boundaries of the
      site.  Applicable statutory language concerning cleanup
      standards under CERCLA is found in Section 121(d)(2)(B)(ii). of
      SARA.  SARA does not allow any increase in contaminants in
      off-site surface water.  To relate health-based standards for
      contaminant concentrations to potential receptors, a
      current-use scenario was employed.  Under an evaluation of the
      current-use scenario, there are no direct receptors of ground
      water at or downgradient of the site.  Rather, the closest
      potential receptors are associated with surface water use where
      affected ground water discharges to Pensacola Bay.


10.3  Cost-Effectiveness

The present estimated cost of EPA's selected remedy ranges  from $2.3
million to 3.3 million dollars.  The selected  remedy  affords overall
effectiveness proportional to its costs  such that  the remedy
represents a reasonable value for the money.  When the  relationship
between cost and overall effectiveness of the  selected  remedy  is
viewed in light of the relationship between cost  and  overall
effectiveness afforded by other  alternatives,  the  selected remedy
appears to be cost effective.

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                                 -35-


10.4  utilization of Permanent Solutions and Alternative Treatment
      Technologies to the Maximum Extent Practicable

The U.S. EPA believes this remedy is the most appropriate cleanup
solution for initiating the first operable unit at the ACW site and
provides the best balance among the evaluation criteria for the
remedial alternatives considered.  This remedy provides effective
protection in both the short- and long-term to potential human and
environmental receptors/ is readily implemented, is cost-effective,
and is consistent with future response actions to be undertaken at
the site.  Bioremediation of the contaminated surface soil represents
a permanent solution (through treatment) which will effectively
reduce and/or eliminate mobility of hazardous wastes and hazardous
substances into the environment.


10.5  Preference for Treatment as a Principal Element

The statutory preference for treatment will be partially met because
the selected remedy described herein only treats the contaminated
surface soil.  Future remedial actions to be performed  at  the  site
will treat the principal threat posed by the contaminated  ground
water and the solidified sludges and underlying subsurface soil.

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            APPENDIX A



             SITE DATA









American Creosote Works,  Inc. Site



Fensacola,  Escarobia County, Florida

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                     TOTAL SELECT PAH CONCENTRATION QN-SITS
                        AMERICAN CREOSOTE WORKS
                           PENSACOLA,  FLORIDA
                       TOTAL SELECT PAH CONCENTRATION (JC/KG)
                                DEPTH ELS (INCHES)
SAMPLE
LOCATION
1 f*VW-Wn^,,f
34
35
36
37
38
39
40
41
42 ,
43
44
45
46
47
48
49
50
51
60
4-12
	
57.00
7.34
41.40
40.20
11.89
24.10
42.40
___
1.16
3.41
102.6
31.40
13.49
51.80
498.0
7.17
35.80
3.01
6.97
18-24

1078.0
—
2.25
-___ *
1.91
— _»_
12.18
10.15

J«B._L_
39.00
____
1.83
1.84
70.2
9.22
55.80
._...
— — .
VADOSE ZONE

„, 	
1.18
0.16
-
-
*»*»».
0.40
0.91
-.
n-.j.j
1.79
--
-
0.08
0.48
0.30
29.41
. -
— -
	MATERIAL WAS ANALYZED FOR BUT NOT DETECTED

4-12  INCHES BLS REPRESENTS A SAMPLING DEPTH
18-24 INCHES BLS REPRESENTS B SAMPLING DEPTH
VADOSE ZONE      REPRESENTS C SAMPLING DEPTH

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              CIOXIN/DIBENZOFURAN CONCENTRATIONS ON-SITE
                        AMERICAN CREOSOTE WORKS
                          PENSACOLA, FLORIDA
           TOTAL DIOXIN/DIBENZOFTJRAN CONCENTRATION IN TEQs1
                                (UG/KG)
                          DEPTH BLS  (INCHES)
SAMPLE
LOCATION
4-12
TEQ
18-24
TEQ
VADOSE ZONE
TEQ
    1 (background)     	        	        ---«
    36                 1,03        	        	
    38                 0.66        0.75        .01
    40                 1.31        1.86        .01
    46                 0.07        .003
    48                 1.39        .01         —•
.	 MATERIAL WAS ANALYZED FOR BUT NOT DETECTED

4-12  INCHES BLS REPRESENTS A SAMPLING DEPTH
18-24 INCHES BLS REPRESENTS B SAMPLING DEPTH
VADOSE ZONE      REPRESENTS C SAMPLING DEPTH
1 NOTEs    Specific dioxina/dibenzofurans are converted to
           2,3,7,8-TCDD toxicity equivalents (1987 TEQa) using the
           toxicity factors from Table 3-3 in the risk assessment
           (June 1988), i.e.t

           2,3,7,8 - Hexa  CDDe 	  ,04
           2,3,7,8 - Hepta CDDs 	  .001
           2,3,7,8 - Penta CDFs 	  .1  "
           2,3,7,8 - Hexa  CDFS -—  .01
           2,3,7,8 - Hepta CDFs 	  .001

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                    PENTACHLOROPHENOL CONCENTRATIONS ON-SITE
                             AMERICAN CREOSOTE WORKS
                               PENSACOLA, FLORIDA
SAMPLE
LOCATION
1 (background)
34
35
36
37
33
39
40
41
42
43
'44
4S
46
47
43
49
50
51
60
PENTACHLOROPHENOL CONCENTRATION (MG/KC)
DEPTH BLS (INCHES)
4-12 18-24 VADOSE ZONE
a •
« «
11.0
3.6
5.6
3.4
9.4
16.0

. .
1.5
15.0
5.2
6 a
110. 0
a Q
2.9
5.0
• a
0.34
- - » «
• • « «
- - • •
• • • .
- • • .
5.2
» -
17.0
5.5
0 * • •
0.2
2.4
a a « .
« « • •
«• *
0.74
. 5.5
a a « w
• * » • *
0.34
••  MATERIAL WAS  ANALYZED FOR BUT NCT DETECTED

4-12  INCHES BLS  REPRESENTS A SAMPLISC. DEPTH
18-24 INCHES BLS  REPRESENTS B SAft? :.:•;<; DEPTH
VADOSE ZONE       REPRESENTS C SAM?:.:-:G DEPTH

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                  RAMOE AND FREQUENCY OF CHeMlCAL CONTAMINANTS
                                  IN VARIOUS MEDIA
                        AMERICAN CREOSOTE WORKS, INC, SITE
                ALL CONCENTRATIONS IN mgAg (SOILS) AND  vg/1 (WATER)
                                Soitl
      Contaminant
 Concentration
 Range end No.
ef Observations
 PolvcveUe Aromatic Hydrocarbons (PAHal
benjo(B)anthracene
ben*o(a)pyrene
benzo(b)fluoranthene
chrysene
antnracane
ben:o(ghi)pervlene
figorene
phenanthrene
dibenzo(a.h)anthrecene
lndeno(l.2,3-cd}pyren«
pyrana
8.8-870 (16)
6.7-UO (10)
9.2-480 (17)
7.9-8.7 (2)
5.8-750 (19)
7.2-1,600 (17)
5.4-20 (5)
7.1-1,800 (13)
5.7-29.000 (21)
7.8-91 (2) .
8,1-210 (5)
7.2-9.000 (29)
Othar Add and Basa/Nautral OrganIcs
acanaphthana
fiuorjnthena
naphthalane
difcanzofuran
2-mathyinaphthalana'
pantachlorophanol

Volatila Qrqanics

banzana
athytbanzana
toiuana
acatona
o-xyiana

Paaticldaa «•

bata-BHC
andOSulfan
7.3-6,900 (12)
8.1-10.000 (30)
74-1,100 (7)
58-880  (8)
39-540  (7)
7.2-2.500 (10)
0.04-0.13 (3)
0.03-0.26 (5)
0.01-0.22 (7)
0.08 (1)
0.01-0.35 (10)
  Qroundwstar
 Concentration
 Ranga and No.
                                            _S_idim«nt
           -oncantrition
           ^ang«  and No.
          of
                         7,300 (1)

                         8,300 (1)
6.400-430.000'(2)

50-140,000- (13)
30-1,300 (10)
2.200 (1)
40-140.000'
80-2.700 (3)
35-580.000-
4^-660  (6)
35-3,630 (8)
(U)

(17)
              5.700 (1)
              20.000 (1)
              15,000 (1)
18.000 (1)
6-150 (15)
15-110  (15)
$-150 (15)
400-2.700 (8)
5-240 (16)
                     *0.66-09 (5)
                     **0.47 (2)
    Ona rapoaad concentration @ 230*
    Same sample as above. 12 ug/l
    May ba in error owing to nonrepresen:ative data

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            APPENDIX B
      RESPONSIVENESS SUMMARY


American Creosote Works,  Inc. Site
Pensacola,  Escambia County, Florida

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                        RESPONSIVENESS SUMMARY
The United States Environmental Protection Agency (EPA)  and the
Florida Department of Environmental Regulation (FDER)  established a
public comment period from September 6, 1989 through September 27,
1989 for interested parties to comment on BPA's and FDER'8 Proposed
Remedial Action Plan (PRAP) for the first operable unit at the
American Creosote Works, Inc. (ACW) site.  The comment period
followed a public meeting conducted by EPA held at the Escambia
County Health Department Building in Pensacola, Florida.  The meeting
presented the studies undertaken and the preferred remedial
alternative for the site.

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 ACW site.
                                 1
This responsiveness summary for the ACW 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.

II.      Background on Community Involvement and Concerns   This
         section provides a brief history of community interest and
         concerns regarding the ACW site.

Ill.     Summary of Malor.Questions Received During the Public
         Comment Period and EPA'a or FDER's Responses   This  section
         presents both oral and written comments submitted during  the
         public comment period/ and provides responses to these
         comments.

IV.      Remaining Concerns   This section discusses community
         concerns that EPA should be aware of  in design and
         implementation of the first operable  unit and  in planning
         for the second operable unit.

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I.   Overview;.

The preferred remedial alternative was presented to the public in  &
public meeting held on September 6, 1989.  The recommended'
al-ternative is an operable unit Record of Decision (ROD)  which
addresses the surface soil contamination.  The major components of
the recommended alternative for the surface soil include:

    - Excavation/ screening/ and stockpiling of contaminated surface
      soil

    - Treatment of the stockpiled soil by bioremediation

    - On-site disposal of remediated soil.

The community, in general, favors the selection of the recommended
alternative.

II.  Background on Community Involvement and Concerns

The Pensacola community has been aware of the contamination problem
at ACW site for several years.  A public meeting was held at the
Pensacola Yacht Club to inform the membership of the findings of the
remedial investigation.  A second public meeting was held on August
15, 1985 to present the draft feasibility study and allow for public
comment.
                         •t
EPA and PDER conducted the third public meeting on September 6,
1989.  The purpose of this meeting was to explain the results of thU
site studies, to present the recommendations of EPA and FDER for the
site cleanup, and to accept questions and comments from the public on
the site or its cleanup.  At this meeting/ the key issues and
concerns identified were?

    Time;  The public was concerned with the amount of time that it
    will take to cleanup the site.

    Public Noticet  The public wanted to be better informed of  site
    activities.

III. Summary of Malor Questions and Comments Received During the
     Public Comment Period and EPA's or FDER'a Responses;

1.)  One commenter Inquired how would the public be notified.

EPA Response;  EPA developed a community relations plan  that  outiir.oi
EPA's role in communicating with the public.  As a part  of  the
community relations plan, a mailing list was developed which  inc'. •.;-!»-I
residents, the media, local, state/ and  federal officials.  When  EPA
conducted the first public meeting, a sign-in sheet  for  interesr.*--;
individuals who wanted to be added to the mailing  list was  made
available.  The proposed plan fact sheet was mailed  to  all  the  ;>:•
who were on the mailing list.  In addition to the  proposed  plar,   i
public notice was published in the legal section of  the  newspaper

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2.)  One commenter inquired about bioremediation  studies  and their
effectiveness with the type of contaminants  on site.

EPA Response;  There are a number pf bioremediation  studies that
apply to treatment of sites contaminated with creosote.   The studies
have indicated that bioremediation is effective as a cleanup method
for creosote.                                      .

3.)  One commenter inquired if the contaminated soils were being
spread by the City or .County when they graded the soils.

EPA Response;  At this time there is no immediate concern, but we
will be doing additional studies and will keep this  in mind.

4.)  One commenter inquired if all of the bioremediation would be
done on the site.

EPA Response;  Yes.

5.)  One commenter expressed concerns about the Bay.

EPA Response;  EPA will be working with experts to ensure that the
Bay is not adversely affected.  We have done some sampling of the    ,;
Bay, and plan to conduct more sampling during the remedial design
phase.  Wi^h the currently available data, BPA has no indication that*
the Bay has been adversely affected.

6.)  One commenter inquired if the capped areas on site would remain
in their current state or if they would be treated.

EPA Response:  The capped areas will be addressed in a second phase
for this site.  Additional studies are required before an appropriate
decision can be.made for the solidified materials, ground water, and
the bay.

7.)  One commenter inquired if the contaminated soils were going to
be excavated and treated on the site.

EPA Response;  Yes/ the soils will be excavated and treated on-site.

8.)  One commenter inquired if a lot of equipment would be brought to
the site.

EPA Responses  Yes, there will be some equipment.  EPA wants  to  have
another public meeting to provide the citizens with  information  about
the type of equipment and how long the remedy  is going to take.

9.)  One commenter inquired if all of the soils would be  excavated at
the same time.

EPA Response;,  No, all of the soil will not  be treated at the same
time.  The soils will be treated in  layers;  once a  layer  had  reached ,
the cleanup goal, another layer of contaminated  soil would be
excavated and treated.

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10.)  One commenter inquired how long would it take to clean up  the
site.

EPA Response;  EPA will atart remedial action on the site in
September 1990.  EPA has estimated that it will take two years to
remediate the site.  Once the remedial design has been completed, EPA
will be able to define the actual amount of'time necessary to clean
up the site.

11.)  One commenter inquired if EPA felt relatively comfortable  that
the site was contained right now.

EPA Response;  Yes, EPA has alleviated the immediate threat at the
site.

12.)  Two commenters expressed the need for more public notice,  and
stated that some residents did not receive their Proposed Plan Fact
Sheets.

EPA Response;  EPA did mail a large number of residents the Proposed
Plan Pact Sheet.  In addition/ EPA released a public notice in  the
newspaper to inform the citizens of the public meeting.

IV.  Remaining Concerns;
   i
The community's concerns surrounding the ACW site will be addressed
in the following areast  community relations for the second operable^
unit, inco.rporation of comments/suggestions in the remedial design,
and community relations support throughout the remedial design and
the remedial action.

Community relations should consist of making available  final
documents (i.e., Remedial Design Work Plan, Remedial Design Reports,
etc.), in a timely manner, to the local repository, and issuance of
fact sheets to those on the mailing list to provide the community
with project progress and a schedule of events.  The community will
be made aware of any principal design changes made during project
design.  At any time during remedial design or remedial action,  if
new information is revealed that could affect the implementation of
the remedy, or, if the remedy fails to achieve the necessary design
criteria, the Record of Decision may be revised  to incorporate  new
technology that will attain the necessary  performance  criteria.

Community relations activities will remain an active  aspect  of  the
remedial design and the remedial action phases of this project.

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            APPENDIX C
   STATE CONCURRENCE MEMORANDUM


American Creosote Works,  Inc. Site
Pensacola,  Escambia County, Florida

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         Florida  Department of Environmental Regulation

         Tw"1 Toners Office Bldg. • 26OO Blair Stone Road  • TiUlaha.s*cc, Florida 32399-2'»00
         B°h Marriiier, Governor           Dale .TVathrmdnn, Scrrefary          John Shearer. 4s5isr30( Scoaary



                                           November 14, 1989
                                                         « .^
Mr. Greer Tidwell
Regional Administrator
U. S. Environmental  Protection
   Agency, Region  IV
345 Courtland St., NE
Atlanta, Georgia  30365                             '                   '

Dear Mr. Tidwell:

The  Florida  Department of  Environmental Regulation concurs with  the  selection
of  bioremediation  as  the  remedial  alternative  for  Operable  Unit  1  of  the
American Creosote Works Superfund site 1n Pensacola,  Florida, as  described  in
Section 9.0 of the Record of Decision.

This  alternative   consists of   the  excavation  and   biological  treatment  of
contaminated on-$1te surface  soils.  All  soil having  greater than  50 mg/kg of
total carcinogenic  indicator compounds  or 30 mgAg  pentachlorophenol will  be
treated to attain  these cleanup  goals.

The  remedy  selected provides  an effective and permanent means  of eliminating
the  long-term  threat   to  public  health  and   the  environment  posed   by
contaminated  soils  at  the  site.   Depending  on  the  specific- method   of
bioremediation  chosen  for  the  site,  the  cost of  the selected  remedy  ranges
from $2.3  to $3.3  million, Including  $319,000  to  $330,000  for  operation  and
maintenance.  The  state's share  of  these costs is $230,000 to $330,000,

The remedial alternative  to be  Implemented for Operable Unit 2, which Includes
stabilized  sludges,  underlying  soils  and  groundwater, will  be  addressed  in  a
second Record  of  Decision.  It  1s  anticipated, that  this  alternative will  fce
selected within the  next nine months.         ''

We look  forward to the successful completion of this remedial  action.  '
                                          , Sincerely,	-,
                                           Dale Twachtmann
                                           Secretary
OT:lc

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