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Record of Decision (Rods) RECORD OF DECISION SUMMARY OF REMEDIAL ALTERNATIVE SELECTION ESCAMBIA WOOD TREATING COMPANY SUPERFUND SITE OPERABLE UNIT 2 (GROUND WATER) PENSACOLA, ESCAMBIA COUNTY, FLORIDA PREPARED BY: U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA, GEORGIA T' SEPTEMBER 2008 10588777 Record of Decision Page ii Escambia Wood Treating Superfund Site Operable Unit 2 (Ground Water) September 2008 TABLE OF CONTENTS PART 1: THE DECLARATION 1.1 Site Name and Location 1 1.2 Statement of Basis and Purpose 1 1.3 Assessment of Site .1 1 1.4 Description of Selected Remedy 1 1.5 Statutory Determinations 2 1.6 Data Certification Checklist 2 1.7 Authorizing Signature 3 PART 2: THE DECISION SUMMARY 2.1 Site Name, Location, and Brief Description 4 2.2 Site History and Enforcement Activities 4 2.2.1 Operational History 4 2.2.2 Regulatory and Enforcement History 7 2.2.3 Previous Investigations 9 2.2.4 Remedial Investigation/Feasibility Study 15 2.3 Community Participation 17 2.4 Scope and Role of Operable Unit or Response Action 17 2.5 Site Characteristics 18 2.5.1 Concephjal Site Model 18 2.5.2 Site Overview 18 2.5.3 Geology 20 2.5.4 Hydrogeology 21 2.5.5 Nature and Extent of Contamination 23 i2.6 Current and Future Land Use 29 2.6.1 Current Land Use 29 2.6.2 Future Land Use 29 2.7 Summary of Site Risks 29 2.7.1 Summary of Human Health Risk Assessment 31 2.7.2 Summary of Ecological Risk Assessment 35 2.8 Remedial Action Objectives 35 2.8.1 Cleanup Levels ........;...; 39 2.9 Description of Alternatives 42 2.9.1 Detailed Remedial Altematives Evaluation..,., 42 2.9.2 Common Elements and Distinguishing Features of the Altematives 71 2.10 Comparative Analysis of Alternatives ..:....... 71 2.10.1 Overall Protection of Human Health and the Environment ; 73 2.10.2 Compliance with Applicable or Relevant and Appropriate Requirements....73 2.10.3 Long-Term Effectiveness arid Permanence 75 2.10.4 Reduction of Mobility, Toxicity, or Volume through Treatment...... 80 2.10.5 Short-Term Effectiveness 80 2.10.6 Implementability 81 2.10.7 Cost 82 Record of Decision Page iii Escambia Wood Treating Superfund Site Operable Unit 2 (Ground Water) September 2008 2.11 Principal Threat Wastes 82 2.12 Selected Remedy 84 2.12.1 Rationale for the Selected Remedy 84 2.12.2 Description ofthe Selected Remedy 84 2.12.3 Summary of Estimated Remedy Costs 89 2.12.4 Expected Outcomes ofthe Selected Remedy 89 2.13 Statutory Determinations 91 2.13.1 Protection of Human Health and the Environment 91 2.13.2 Compliance with ARARs 92 2.13.3 Cost Effectiveness 92 2.13.4 Permanent and Altemative Treatment Solutions 92 2.13.5 Preference for Treatment as a Principal Element 93 2.13.6 Five-Year Review Requirement 93 2.14 Documentation of Significant Changes 93 2.15 References 93 PART 3: RESPONSIVENESS SUMMARY 3.1 Overview and Summary 95 3.2 Written Public Comments 95 3.3 Public Meeting Comments 107 Record of Decision Page iv Escambia Wood Treating Superfund Site Operable Unit 2 (Ground Water) September 2008 LIST OF FIGURES Figure 1. Site Location Map 5 Figure 2. Site Conceptual Model 19 Figure 3. General Stratigraphy ofthe Site 20 Figure 4. Cross-Section ofthe Site Hydrostratigraphy (Parallel to Ground Water Flow Direction) 22 Figure 5. Extent of Naphthalene Contamination in Surficial Zone 25 Figure 6. Extent of Naphthalene Contamination in Lower Permeability Zone 26 Figure 7. Extent of Naphthalene Contamination in Main Producing Zone 27 Figure 8. Cross-Section of Naphthalene Contamination Showing Plume Areas Based on Concentration 28 Figure 9. Planned Future Use ofthe Site 30 Figure 10. Physical Layout of Remedial Altemative SP-4 83 Figure 11. Physical Layout of Remedial Altemative HCP-3 85 LIST OF TABLES Table 1. Occurrence, Distribution, and Selection of Chemicals of Potential Concem in Ground Water 32 Table 2. Summary of Ground Water Chemicals of Potential Concem and Medium Specific Exposure Point Concentrations 33 Table 3. Risk Characterization Summary - (Carcinogens) 37 Table 4. Risk Characterization Summary - (Non-Carcinogens) 38 Table 5. Final Site-wide Ground Water Remedial Cleanup Levels for Escambia OU2...40 Table 6. Final Source and Highly Contaminated Zone Ground Water Remedial Cleanup Levels for Escambia OU 41 Table 7. Comparative Evaluation of Remedial Altematives for Escambia 0U2 74 Table 8. Chemical-Specific ARARs, Criteria, and Guidances for Escambia 0U2 76 Table 9. Action-Specific ARARs, Criteria, and Guidances for Escambia OU2 .77 Table 10. Comparison of Remedial Alternative Costs for Escambia OU2 83 Table 11. Estimated Remedy Capital Costs for Escambia 0U2 90 Table 12. Estimated Remedy Present Value O&M Costs for Escambia 0U2 ....91 LIST OF APPENDICES Appendix A - Public Meeting Transcript .. Record of Decision Page V Escambia Wood Treating Superfund Site Operable Unit 2 (Ground Water) September 2008 LIST OF ACRONYMS and ABBREVIATIONS ADD average daily dose amsl above means sea level ARAR applicable or relevant and appropriate requirement Black & Veatch Black & Veatch Special Projects Corporation bis below land surface BRA-HH Baseline Eiisk Assessment for Human Health CCA chromated copper arsenate CDD chlorinated dibenzo-p-dioxins CDM Camp, Dresser and McKee, Inc. CERCLA Comprehensive Environmental Response Compensation Liability Act CFR Code of Federal Regulations CLP Contract Laboratory Program cm square centimeter COC chemical of concem COPC chemical of potential concem CSF cancer slope factor cy cubic yards DO dissolved oxygen DP dilute plume DPT direct push technology EPA U.S. Environmental Protection Agency ERT Emergency Response Team ESD Explanation of Significant Differences FAC Florida Administrative Code FDEP Florida Department of Environmental Protection FDER Florida Department of Environmental Regulation FS Feasibility Study ft bis feet below land surface GRA general response action HCP high concentration plume HI hazard index HQ hazard quotient ILCR incremental lifetime cancer risk ISEB in situ enhanced bioremediation LADD lifetime average daily dose LMJA Larry M. Jacobs & Associates, Inc LPZ Low permeability zone m^/kg cubic meter per kilogram MCL maximum contaminant level Hg microgram Hg/L micrograms per liter mg/kg milligrams per kilogram mg/kg-day milligrams per kilogram per day mg/L milligrams per liter MPZ Main producing zone Record of Decision Page vi Escambia Wood Treating Superfund Site Operable Unit 2 (Ground Water) September 2008 M/T/V mobility/toxicity/volume NCP National Contingency Plan NOV Notice bf Violation NPDES National Pollutant Discharge Elimination System O&M operation and maintenance OU Operable Unit PAH polynuclear aromatic hydrocarbons PCE tetrachloroethylene PCP pentachlorophenol POTW Public Owned Treatment Works RCRA Resource Conservation and Recovery Act RAGS risk assessment guidance RD Remedial Design RfC reference concentration RAO Remedial Action Objective RME reasonable maximum exposure RI Remedial Investigation ROD Record of Decision SARA Superfund Amendments and Reauthorization Act "Site" Escambia Wood Treating Superfund Site SGA sand and gravel aquifer SP source plume SVOC semi-volatile organic compounds SZ Suficial zone TBC to-be-considered TCDD tetrachloro-dibenzo-p-dioxin TEQ toxicity equivalent quotient TOP Temporary Operating Permit TPH total petroleum hydrocarbons UWF University of West Florida WHO World Health Organization Record of Decision Page 1 Escambia Wood Treating Company Superfund Site Operable Unit 2 (Ground Water) September 2008 PART 1: THE DECLARATION 1.1 Site Name and Location This Record of Decision (ROD) is for the Escambia Wood Treating Company (ETC) Superfund Site, Operable Unit 2 (Ground Water) that is located at 3910 North Palafox Street in the city of Pensacola, Escambia County, Florida. The U.S. Environmental Protection Agency (EPA) Site Identification Number for the ETC Superfund Site is FLD008168346. 1.2 Statement of Basis and Purpose This decision document presents the Selected Remedy for the Escambia Wood Treating Company Superfund Site (the "Site"), 0U2 (Ground Water) that 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 Contingency Plan (NCP). This decision is based on the Administrative Record for the Site. This decision represents the final remedy selection for the Site, and, following completion of the remedial action, the Site will be ready for reuse. The State of Florida, as represented by the Florida Department of Environmental Protection (FDEP), has been the support agency during the remedial investigation/feasibility study process for the Site. In accordance with 40 Code of Federal Regulations (CFR) Section 300.430, as the support agency, FDEP has provided input during the process. 1.3 Assessment of Site The response action selected in this ROD is necessary to protect the public health or welfare and the environment from actual or threatened releases of hazardous substances to the environment. 1.4 Description of Selected Remedy The overall cleanup strategy for the OU2 final remedy is aggressive treatment of source areas which act as a source for continued contamination of the ground water and active in situ treatment of ground water contaminated above selected natural attenuation monitoring criteria. A key objective ofthe aggressive treatment is to address principal threat waste and create aquifer conditions suitable for ISEB.. The selected remedy for 0U2 is compatible and works in conjunction with the remedy for OUl (Soil). Following completion ofthe rernedy for 0U2 the remedy will be protective of both human and ecological receptors and will attain unlimited use and unrestricted exposure criteria. The selected remedy is compatible with the plarmed future use ofthe Site. The major components ofthe selected remedy include: a Installationof vertical and horizontal injecfion and extraction wells; a ISCO and ISEB using vertical and horizontal wells in source plume areas (SP-4); a ISEB in high concentration plume areas (HCP-3); • MNA in dilute plume areas (DP-2); a Operation & Maintenance; a Institutional controls; and a Five-Year Reviews.
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