UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
) A OFFICE OF
f ‘J I OJ SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: ditional Gi.j4dance on Delegation of Selection of
meñ t,P ’itY to Regions
FROM: ,‘WI 4cG i
cting Assistant Administrator
TO: Regional Administrator
Regions I — X
On March 3, 1985, the Administrator signed the Superfund
delegation authority which allows Regional Administrators to sign
Records of Decision (RODS) and Enforcement ecision Documents
(EDDs) for several specific kinds of remedies. The delegation
guidance dated January 16, 1985, described the criteria to be
used in selecting the types of remedies that would be delegated
to tI e Regions. The major Regional comments on this guidance
concerned the extent of delegation and the requirement for
submission of documents to support the delegation requests.
The delegation criteria should only be viewed as a general
guide and, in order to meet our target of 60 percent delegations,
we will be delegating a large number of RODs/EDDs that have
significant issues. TO understand these issues and assist with
their resolution, a minimal amount of information needs to be
submitted in the delegation analysis summary. The attached
delegation summary for the Whitehouse, Florida, site should be
used as a guide.
In order to increase delegation to the Regions in FY 86,
additional guidance will be prepared and only remedies that
involve complex area—wide contamination, permanent relocation,
betterment, public welfare, fund balancing or nationally
significant enforcement cases will be retained by the AA—tSWER.
We anticipate that 90 percent of the remedies will be delegated
in FY 86.
I believe the delegation process is running smoothly and
request that your staffs continue to work closely with the
Office of Emergency and Remedial Response and Office of Waste
Programs Enforcment staffs. If you have any specific questions
please contact Bill Hanson for remedial (FTS) 382 2345 and Bob
Mason for enforcement (FTS) 475—8235.
Attachment

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s1 IO y UH1JUdUy
Whjtehouse Oil Pits
Whitehouse, Fl.
Program lead/state
I. Delegation CrDeria :
General remedial measures in which off—site contamination is
limited.
TI. Site Description :
See site plan (attached)
— 10 miles west of Jacksonville, Fla. (rural area).
— 7 acre site
— Former oil reclamation process, fish kills and oil spills
documented in past.
— Shallow, intermediate, and linestone aquifers within iS O
feet of surface, limestone aquifer i seperated by 70 foot
aquiclude and is used as drinking water source in area.
ioridian aquifer (Class I) approximately OO feet .below
surface.
a. Previous response activity :
— Pits were drained, fluids we?e treated, and sludge
stabilized.
— Sludge was re—deposited in original seven pits,
covered with trash and soil.
— Dike stabilization work.
b. Current Site Status — Hazardous Compounds Present :
— 83,000 cubic yards of contaminated (metals, organics)
sludges, soils, and waste in 7 pits. Average depth
of contamination is 15 feet, with top 5 feet being
fill material
— PCR contamination (minimal) in small, off—site stream
area.
— 20 million gallons of contaminated ground water (metals,
organics) in shallow and intermediate aquifers.
Contaminated surface water and leachate collecti on-site.
c, Risk to Receptors via Pathways :
Direct contact threat from soils, sludges, waste
leachate, and sediments.
— Local drinking water supply (limestone aquifer) thre. tenec
by contaminants from shallow and intermediate a ulfers
migrating vertically through aquitard.
— Water quality in adjacent stream effected by
contaminants in groundwater migratin. 7 laterally.
d. Status of Current PT or Fc :
— R I completed 12/Rd
PS to be completed by 04/R4

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I!!. Remedial Objectives/Criteria/MternatiVeS
a. Operable units :
ROD will be final action, no operable units planned.
b. Remedial objectives and criteria :
— Prevent dirøct con$ act threat From soils, sl idg ,
waste, leachate, and sediments.
— Prevent further contamination of shallow and
intermediate aquifers and prevent migration of this
contaminated ground water to limestone aquifer.
— Prevent further contamination of stream.
c. Remedial alternatives :
— See decision summary table (attached)
IV. Other
a. Enforcement
— There is limited possibility of recovering remedial
activity cost.
h. Public comments
— Public comments period to be held in Future.
— Rumors of relocation.
c. Schedule
— Final Draft PS 03/04/AS
— Beginning of public comment period 03/fl4/85
— ROD presentation to RA 06/15/85
d. Future actions
— O&M requirements if on—site landfill selected.
— O&M requirements if ground water treatment system
selected.
V. Issues :
1. State of Florida has promulgated regulation that will
not permit a new hazardous waste landfill to be permitted,
however, on—site disposal would be more cost eFfective than
off—site disposal as per CERCLA 101(24). Headquarters
recommends that the decision for an on—site disposal unit be
based on technical factors only.

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*itehouse, Pl,flec lsjç,n Suitnary Table
C) • Remove sludges,
soil, waste
• Stabilization
o On—sIte landfill
o GW trt
D) ° R nove sludges,
soil, waste
• Stabilization
o Off—site disposal
o cw trt
E) • R nove sludges,
soil, waste
• On-site inciner-
at ion
o On-site landfill
• cw trt
F) • P vove sludges,
soil, waste
• Off—site
incineration
• 0ff—site landfill
• GW trt
Public Realth
Qns iderat ions
Direct contact
Qntaninat ion of
drinking water
Potential for
drinking water
contaninat Ion
Inert waste
placed in
landfill
Landfill
overl ies class I
aquifer
Inert waste
placed in
landfill
E nviror nental
a ns iderat ion
Direct contact
Off—site
migration of
contaninated
ground water
‘1’ chnical
Q ns Iderat ions
Slurry wall
may not be
a npa table
with waste
Waste may
not be
suitable
for
stabilization
Waste may not
he suitable
Ibuble lined
facility may be
great distance
Incinerator
must he mobile
or designed
State has
pranulga ted
regulation
ajainst
new ]andfill
Possible
public
opposition
Possible public
opposition
Alternative
A) ° No Aciton
B) • CAP/Slurry Wall
c 4 trt.
Other
0
I 4
6 4
R6M
67 14
Waste destroyed
Waste destroyed
Waste destroyed
Waste destroyed Facility may
be great distance
CaTmercial Capacity
may be limited

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IJid DROP STRUCTU
FLOW D 1RECTIQ
TOE OF SLO
TREATMENT PLANT AREA
PIT
WOODED
NORTHEAST TRIBUTARY OF
UCOIRTS CREEK
TO
MCGIRTS CREEK
FIGURE I-I : OVERALL. SITE SKETCH
ADOPTED FROM: FINAL DRAFT REMEDIAL
ACTION MASTER PLAN
ECOLOGY ENVIRONMENT.INC.
J
I
MACHELLE DR.
•ITCH
GRAYSON ST.

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