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Superfund Explanation of Significant Differences %P«O^%/ Eoambia Wood Treating Company Superfund Site Pensaco/A, Escambia County, Florida

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Superfund Explanation of Significant Differences %P«O^%/ Eoambia Wood Treating Company Superfund Site Pensaco/A, Escambia County, Florida ^^'"_:% U.S. ENVIRONMENTAL PROTECTION AGENCY ISS i Superfund Explanation of Significant Differences %p«o^%/ Eoambia Wood Treating Company Superfund Site Pensaco/a, Escambia County, Florida Pensacola, Escambia Coimly, Florida Mardi 2012 to these components do not fiuidainenraily alter the This fact sheet is being issued to document overall cleanup approach. The objective of controlling technical changes made during the Superfund human exposure remains unclianged and has been cleanup at the Escambia Wood Treating achieved by the cleanup, Company Superfund Site in Pensacola Florida. EPA made these changes because the Tliis ESD is being issued as part of EPA's public conditions found during coastmction differed participation responsibilities under Section 13 7(c) of the from the conditions known when the Record of Comprehensive EnvinmmenE^il Response, Compensation Decision was signed. When a Remedial Action and Liability Act (CERCLA), as amended by the is adjusted. EPA documents the decision in an Superfund Amendments and Reauthorization Act ''Explanation of Significant Differ^nces". (SARA). 42 U.S.C. §§ 9601 el seq.. and Section 300,435(e)(2)(i) of the National Contingency Plan Introduction (NCP),40C,F,R.Part300. The U.S. Environmental Protection Agency (EPA) is This FSD will become part of the Administrative Record conducting a remedial action for the soils portion of in accordance with 40 C.F.R, ij 300.825(a)(2) of the Operable Unit 1 (OUl) at the Escambia Wood Treating NCP. The Administrative Record contains documents CompaEiy (ETC) Superfund Site (Site) located in used as the ha.sis for the remedy selected for the Sile, Pensacola. Florida. The EPA issued a Record of including the ROD and Responsiveness Summary. The Decision (ROD) for this remedy ga February 2, 2006. Adminisirative Record documents are available for and began remtdiai constnjction in August 2007. The public review in the ETC Site information repository overall cleanup approach is to treat principal threat located at llie following locations: wastes tKrough soliditicaiion/siabili7.ution and lo permanenlly isolate conlaminalcd soil in an on-site AdmJDistr^iii^e Record and l&focitiatifin RepositorJ<^$ conlainmenl cell. As of July 2010. ihe consiruciion of for the ETC Superfiind Site the cell was complele. Ag of February 2012, the remaining ROD requirements are closeout items, such as West Florida Regional U.S. EPA - Reiiicin 4 dewatering the cell, institutional controls and deed LibrdTv Genealogy Branch Supedund Records restrictions. The EPA carried out ihis cleanup llwougli a 5740 N. Ninth Ave Center partuership wifli the Fiorida Department of Pensacola. Fl 32504 6!FoRtyihSUSW Ai3ania.GA 30303 Environmeiital Protection, which provided teclmical support and 10% of Remedial Action costs. Site History This ExpJana!ion of Significant Differences (ESD) The Site is located al 3910 North Palafox. Street in the explains changes to Llie cleanup goals and to City of Pensacola, Florida. Operable Unit I refers lo construction details specified in tlie ROD, The changes contaminated soils and includes the fonner ETC facihty area, which covers 26 acres, plus about 69 acres of In October 1991, EPA began a removal action to address surrounding neighborhoods purchased by the EPA, immediate risks of exposure and to stabilize the Site. which increases the total area of OUl to approximately EPA excavated about 225,000 cubic yards of 100 acres. contaminated material and stored it under a 60-mil (1.5 millimeters [mm]), High Density Polyethylene (HDPE) The ETC facility manufactured pressure-treated wood liner treated to be resistant to ultraviolet light. The products, primarily utility poles and foundation pilings. former process area and a fomier wastewater From 1942 to approximately 1970, coal-tar creosote was pond/landtlll were excavated to approximately 40 feet the primary wood preservative. Starting in 1963, deep. The removal action was completed in 1992. Pentachlorophenol (PCP) dissolved in No. 6 diesel fuel was also used at the facility and was the sole EPA proposed the Site for inclusion on the National preservative in use from 1970 until 1982 when the Priorities List (NPL) in August 1994 and the listing on facility closed. In 1991, ETC tded for bankruptcy and the NPL was finalized on December 16. 1994. Cleanup abandoned the Site. The company defaulted on its actions were divided into two Operable Units; OUl environmentalliabilities, and the case was referred to the addresses soil contamination and OU2 addresses Department of Justice (DoJ) lo pursue settlement with contaminated ground water. the owners. DoJ reached a final settlement with the owners in 2002. In 1997, an biterim ROD was issued, selecting permanent relocation of 358 households from the The primary wastes managed at the facility were process neighborhoods north of the facility (Rosewood Terrace, wastewater and contaminated runoff from the former Oak Park, and Escambia Arms) and the Goulding treatment area. From the mid-1940s tlirough the mid- (Hennan and Pearl Streets) neighborhoods south of the 1950s, wastewater was sent to an unlined pond located site. The relocation was carried out as part of the in the northeastern part of the Site. After the mid-1950s, National Relocation Pilot Project. The relocation this pond was used as a landfill and process wastewater occurred from November 1997 to August 2005. The and contaminated runoff were managed by two separate Clarinda Triangle neighborhood was added to the systems. hiterim Remedy in the 2006 Final OUl ROD. The relocation of the residents in the Clarinda Triangle area Previous EPA Actions occurred from December 2006 to 2009. In total, more than 400 households and about 500 people were Starting in 1982, EPA and Ihe State of Florida cited the relocated, and about 70 acres of land was acquired by the ETC facility for numerous violations, including Federal Government. uncontrolled ground water contamination and inadequate financial assurance under hazardous waste regulations. OUl Final Remedial Action In June 1990, EPA conducted a Facility Assessment at the ETC facility to verify the fmdings of an earlier tile The 2006 Final OUl ROD presented the final remedy review, to assess the release or the potential for release for the contaminated soils. The overall cleanup strategy of hazardous wastes or constituents from the facility, and for the OU-1 final remedy is to treat principal tlireat to assess if further action was needed. The assessment wastes tlirough solidificationy stabilization and to identified 32 permanently isolate soil contaminated above the selected Solid Waste Management Units (SWMUs) and cleanup levels in an on-site contaimnent system in order recommended the entire facility be treated as an Area of to protect both human and ecological receptors. The Concern (AOC). The site was uncontrolled, and there major components of the Remedy include: were immediate pathways of exposure to open waste pits, contaminated soil, and chemical drums. • E.xcavation of contaminated soil on- and off-site; In response to the bankruptcy of ETC and the • Contaimnent of the containinated soil in a lined cell abandonment of the facility in 1991, EPA Region 4 followed by installation of a multi-layer cap over the activated the EPA Environmental Response Team to contaimnent area compatible, to the extent possible, with the intended future commercial use of the perform a preliminary assessment of the Site. The property; investigation indicated that a removal action was needed. ' Solidification/stabilization of identified principal based on achieving a residual excess cancer risk for threat waste to form a sub-cap beneath the multi-layer direct exposure of less than one in a million (IxlO"'') for cap; future cormnercial/industrial land use and protection of • Operation & maintenance of the cap and containment groundwater from leaching of contaminants above system; drinking water standards. The key contaminants of concern (COCs) for OUl are chemicals related lo wood • Long-term monitoring of the containment system; treating operations that were identified in both soil and • Institutional controls to restrict future use of the Site to ground water. For Dioxin and PAHs, COCs found in commercial uses compatible with the remedy; soil, but not in ground water, the 2006 ROD clean up • Five-year reviews of the remedy to ensure goals were based on the direct human exposure pathway. protectiveness is maintained; and For COCs found in groundwater, the 2006 ROD cleanup goals were based on a groundwater exposure pathway, • Residential relocation within and immediately adjacent to the Clarinda Triangle neighborhood. and were calculated using the Summers model (EPA, 1989). Remedy Implementation The cleanup goals in the 2006 ROD have two limitations Construction activities began at the ETC site on that became evident during the remedial construction; September 24, 2007. The construction consisted of cleanup goals were not developed for all potential excavating, stockpiling, and placing containinated soil pathways for all contaminants, and the Summers model and debris in a containment cell. The bottom of the resulted in cleanup goals that were overly conservative. containment cell was lined with a composite liner made Of the nine COCs in the 2006 ROD, two were based on of 60 mil HDPE and a geosynthetic clay liner. The the direct exposure pathway, and seven were based on sloped walls of the contaimnent cell were lined with a 60 the groundwater exposure pathway, as shown in Table I. mil HDPE liner. The top of the containment cell was This ESD establishes cleanup goals for all COCs based lined with a composite liner to exclude water from on both the direct exposure and leaching-based entering the cell. A drainage system was installed above groundwater protection pathways. This ESD also the containment cell. During excavation and replaces the Summers model derived cleanup goals with construction, EPA conducted air monitoring, dust updated site-specific cleanup goals for groundwater control, and sile restoration to minimize the impacts of protection. the construction on the coinmunity.
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