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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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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2.0 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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—•-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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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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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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5,0 Summary of Site Characteristics
5.1 G
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-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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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.
-------
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
-------
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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