Fifth Five Year Review Report for Sydney Mine Sludge

FIFTH FIVE-YEAR REVIEW REPORT FOR SYDNEY MINE SLUDGE PONDS SUPERFUND SITE HILLSBOROUGH COUNTY, FLORIDA

MARCH 2021

Prepared by

U.S. Environmental Protection Agency Region 4 Atlanta, Georgia

Digitally signed by RANDALL RANDALL CHAFFINS Date: 2021.04.13 CHAFFINS 4/13/21 ------11:31:36 -04'00' ------Randall Chaffins, Acting Director Date Superfund & Emergency Management Division

Table of Contents LIST OF ABBREVIATIONS AND ACRONYMS ...... iv I. INTRODUCTION ...... 1 Site Background ...... 1 FIVE-YEAR REVIEW SUMMARY FORM ...... 2 II. RESPONSE ACTION SUMMARY ...... 4 Basis for Taking Action ...... 4 Response Actions ...... 4 Status of Implementation ...... 6 Systems Operations/Operation and Maintenance (O&M) ...... 10 III. PROGRESS SINCE THE PREVIOUS REVIEW ...... 10 IV. FIVE-YEAR REVIEW PROCESS ...... 10 Community Notification, Community Involvement and Site Interviews ...... 10 Data Review ...... 11 Site Inspection ...... 14 V. TECHNICAL ASSESSMENT ...... 14 QUESTION A: Is the remedy functioning as intended by the decision documents? ...... 14 QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the remedy selection still valid? ...... 15 QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy? ...... 15 VI. ISSUES/RECOMMENDATIONS ...... 16 OTHER FINDINGS...... 16 VII. PROTECTIVENESS STATEMENT ...... 16 VIII. NEXT REVIEW ...... 16 APPENDIX A – REFERENCE LIST...... A-1 APPENDIX B – CURRENT SITE STATUS ...... B-1 APPENDIX C – SITE CHRONOLOGY ...... C-1 APPENDIX D – SITE MAPS ...... D-1 APPENDIX E – PRESS NOTICE ...... E-1 APPENDIX F – INTERVIEW FORMS ...... F-1 APPENDIX G – SITE INSPECTION CHECKLIST ...... G-1 APPENDIX H – SITE INSPECTION PHOTOS...... H-1 APPENDIX I – DATA FIGURES ...... I-1 APPENDIX J – DETAILED ARARS REVIEW TABLES ...... J-1 APPENDIX K – SCREENING-LEVEL RISK REVIEW ...... K-1 APPENDIX L – RESTRICTIVE COVENANT ...... L-1

Tables Table 1: COCs, by Media ...... 4 Table 2: Groundwater COC Remediation Goal ...... 5 Table 3: Summary of Planned and/or Implemented Institutional Controls (ICs) ...... 7 Table 4: 2011 Restrictive Covenant Usage Restrictions by Area ...... 8 Table 5: Protectiveness Determinations/Statements from the 2016 FYR ...... 10 ii

Table 6: Maximum Detections of COCs (μg/L) in the Bone Valley Unit ...... 12 Table C-1: Site Chronology ...... C-1 Table J-1: Groundwater Remediation Goal Comparison...... J-1 Table K-1: Screening Level Evaluation of 2010 Soil Sampling ...... K-1 Table K-2: Screening-Level Vapor Intrusion Risk Evaluation of January 2020 Shallow Groundwater VOC Results ...... K-1

Figures Figure 1: Site Vicinity Map ...... 3 Figure 2: Institutional Control Map ...... 9 Figure 3: Detailed Site Map ...... 13 Figure D-1: 1989 ROD Site Map ...... D-1 Figure D-2: Hydrogeologic Cross Section ...... D-2 Figure D-3: Groundwater Monitoring Groundwater Elevation ...... D-3 Figure D-4: 2010 Soil Sampling Location Map ...... D-4 Figure I-1: Historical Trends of Benzene in Bone Valley Unit (2010-2020) ...... I-1 Figure I-2: Historical Trends of Benzene in Spoil Row, Oil Pond and North Dike Wells (2010-2020) .. I-2 Figure I-3: Historical Trends of Vinyl Chloride in Bone Valley Unit (2010-2020) ...... I-3 Figure I-4: Historical Trends of Vinyl Chloride in Bone Valley Unit (2010-2020) ...... I-4

iii

LIST OF ABBREVIATIONS AND ACRONYMS

ARAR Applicable or Relevant and Appropriate Requirement CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations COC Contaminant of Concern EIP-USA Energy Industrial Park-Urban Service Area EPA United States Environmental Protection Agency ESD Explanation of Significant Differences FDEP Florida Department of Environmental Protection FDER Florida Department of Environmental Regulation FYR Five-Year Review IC Institutional Control LLC Limited Liability Company μg/L Microgram per Liter MCL Maximum Contaminant Level mg/kg Milligram per Kilogram NCP National Contingency Plan NPL National Priorities List O&M Operation and Maintenance OU Operable Unit PRP Potentially Responsible Party RAO Remedial Action Objective RCRA Resource Conservation and Recovery Act ROD Record of Decision RPM Remedial Project Manager UU/UE Unlimited Use and Unrestricted Exposure VOC Volatile Organic Compound

I. INTRODUCTION The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy to determine if the remedy is and will continue to be protective of human health and the environment. The methods, findings and conclusions of reviews are documented in FYR reports such as this one. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them.

The U.S. Environmental Protection Agency is preparing this FYR pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the National Contingency Plan (NCP) (40 Code of Federal Regulations (CFR) Section 300.430(f)(4)(ii)), and considering EPA policy.

This is the fifth FYR for the Sydney Mine Sludge Ponds Superfund site (the Site). The triggering action for this policy review is the completion date of the previous FYR. The FYR has been prepared because hazardous substances, pollutants or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure (UU/UE). The Site consists of one operable unit addressing soil and groundwater contamination.

EPA remedial project manager (RPM) Shelby Johnston led the FYR. Participants included Theresa Pepe, Florida Department of Environmental Protection (FDEP) and Michael Townsel, Hillsborough County. The potentially responsible party (PRP) was notified of the initiation of the FYR. The review began on 5/26/2020. Appendix A provides additional resources. Appendix B includes site status information. Appendix C includes the Site’s chronology of events.

Site Background The 9.5-acre Site is located in Brandon, Hillsborough County, Florida, within a 1,754-acre former phosphate mine (Figure 1). In the 1930s and 1950s, operators performed phosphate strip mining on site. From 1958 to 1973, workers disposed of phosphatic clay wastes and tailing sands in retention areas on the Site. The clay wastes and tailing sands came from phosphate ore processing that continued on adjacent land. By-products of mining operations spread over the Site included: overburden in continuous linear rows (the Spoil Row unit) ranging from 10 to 25 feet in thickness; phosphatic clay wastes between and over the spoil rows; retention dikes to contain accumulating clay waste; and sand tailings spread over the entire Site, varying in thickness from 1 to 30 feet. In the 1970s, site operators built disposal pits in the Sand Tailings unit to receive a variety of wastes, including septic and grease trap wastes and automotive spoils. From 1973 to 1982, the Hillsborough County Public Utilities Department leased the Site for permitted disposal of septic wastes, waste automobile oils, grease trap wastes, and manufacturing oils; they placed about 16 million gallons of liquid wastes in three unlined pits. The Site is mostly grassy with some trees. The area around the Site is primarily undeveloped and is heavily vegetated. State Route 60 is about a half-mile north of the Site. There are scattered residential and commercial areas immediately north of state Route 60. The Site is fenced.

Turkey Creek is about a half-mile east of the Site’s former waste disposal pits. Natural surface water runoff patterns were drastically altered by mining activities, construction of the disposal pits, and by remediation activities. South and west of the Site, surface water runoff collects in a ditch south of the access road. Water in this ditch goes to a larger ditch, which flows east and discharges to Turkey Creek. East of the Site, surface water runoff flows east. During the rainy season, the perched groundwater around the Site rises, forming ponds and springs.

Phosphate mining altered the original site hydrogeology (Appendix D, Figure D-2). A blanket of surficial sands (maximum thickness of 30 feet) covered most of the area before mining. The Bone Valley Formation is below the surficial sand blanket. The Bone Valley Formation is divided into upper and lower units. The upper unit was generally a non-phosphatic clay that was removed during mining operation. The lower unit, termed the “matrix” by the phosphate industry, was made of clays and sands rich in phosphate ore. A dike, called the north dike, runs east-west across the middle of the Site, creating a groundwater divide. There is a perched water table and a water table surficial aquifer in the site area. The local water table aquifer is hydraulically connected to the surface water systems by drainage systems west of the Site and to Turkey Creek. The Hawthorn Formation is below the Bone Valley Formation; it is made of low-permeability clay layers with lenses of water-bearing limestone. The Floridan aquifer is below the Hawthorn Formation, generally separated by confining clays. Overall groundwater flow in the Bone Valley is to the north/northwest. Local variations in flow direction exist (Appendix D, Figure D-3). Groundwater from the Hawthorn Formation is the local water supply.

FIVE-YEAR REVIEW SUMMARY FORM

SITE IDENTIFICATION Site Name: Sydney Mine Sludge Ponds EPA ID: FLD000648055 Region: 4 State: FL City/County: Brandon/Hillsborough

SITE STATUS NPL Status: Final Multiple OUs? Has the Site achieved construction completion? No Yes

REVIEW STATUS

Lead agency: EPA

Author name: Shelby Johnston

Author affiliation: EPA with support provided by Skeo Review period: 5/26/2020 - 3/1/2021 Date of site inspection: 10/13/2020 Type of review: Policy Review number: 5 Triggering action date: 3/23/2016 Due date (five years after triggering action date): 3/23/2021

Figure 1: Site Vicinity Map

Sydney Mine Brandon,• Sludg'e Ponds FL: Superfund Site

0 0.25 0.5 Legend Mile CJ Approximate Site Boundary Sources: ESRI, U.S. Census Bureau 2019 TIGER/Line Geodatabases, Bureau of Transportation Statistics, Digita/Globe, GeoEye, Earthstar Geographies, DeLorme, Tele Atlas, AND, First American, UNEP-WCMC, USGS, CNES/Airbus DS, USDA, AeroGR/O, IGN, the G/S User Community and the 2016 FYR.

() Sydney Mine Sludge Ponds Superfund Site NORTH City of Brandon, Hillsborough County, Florida

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding the EPA’s response actions at the Site.

II. RESPONSE ACTION SUMMARY

Basis for Taking Action In 1979, the EPA and the Florida Department of Environmental Regulation (FDER, now FDEP) included the Site in their inventories of potential hazardous waste sites, which resulted in the EPA investigating surface water and groundwater. Investigations did not find volatile organic contaminants (VOCs) above detection levels or heavy metals above background levels in nearby potable wells. Monitoring wells near the sludge and oil pits contained VOCs and metals. Sediment in Turkey Creek had elevated metal concentrations. Subsequently, FDER began monitoring the Site. In late 1980, the Hillsborough County Division of Public Utilities notified the EPA of hazardous waste activity at the Site in accordance with the Resource Conservation and Recovery Act (RCRA) notification requirements. In 1981, the EPA further investigated and evaluated site conditions in response to local citizens’ inquiries about air and water quality and human health effects. In 1981, FDER denied a permit for waste disposal and the Site was closed.

Hillsborough County completed a human and ecological risk evaluation as part of the endangerment assessment completed in 1989. The endangerment assessment evaluated risks from potential exposure to contamination left at the Site after the completion of extensive voluntary remediation in 1986. The endangerment assessment evaluated potential human and ecological exposures to contaminants in groundwater, soil, surface water and air. The endangerment assessment identified only future residential use of on-site groundwater as posing cancer risks greater than 1 x 10-4, the upper bound of the EPA’s risk management range of 1 x 10-6 to 1 x 10-4. The risks and noncancer hazards for off-site potable use of groundwater were within acceptable limits. No unacceptable ecological risks were noted for soil or surface water. The contaminants of concern (COCs) that contributed to the most unacceptable risk in on-site groundwater were nine VOCs (Table 1).

Table 1: COCs, by Media COC Media 1,1,1-Trichloroethane Groundwater 1,1-Dichloroethane Groundwater 1,2-Dichloroethane Groundwater 1,1-Dichloroethene Groundwater Benzene Groundwater Chlorobenzene Groundwater Ethyl Benzene Groundwater Toluene Groundwater Vinyl Chloride Groundwater

Response Actions In 1982, Hillsborough County (the County) began voluntary remedial actions. The County consulted with FDER to determine a cleanup plan. In 1984, the County completed a slurry wall to contain waste pit contents. During 1985 and 1986, the County excavated and incinerated 10,900 cubic yards of disposal pond wastes (Appendix D, Figure D-1) in an on-site mobile incinerator. In 1987, the County built a surficial aquifer pump-and-treat system to treat contaminated groundwater.

In 1987, contractors identified more buried waste next to the pits; they excavated about 15,000 cubic yards of wastes, air-dried them with residuals and disposed of them in a solid waste landfill. Contractors excavated soils until a composite sample from the bottom and side walls had VOC concentrations less 4 than 0.5 milligram per kilogram (mg/kg). Contractors used overburden soils with total VOC concentrations less than 0.5 mg/kg and sand to backfill the Site. The EPA proposed the Site for the Superfund program’s National Priorities List (NPL) in 1986 and placed it on the NPL in 1989.

On September 29, 1989, the EPA issued the Record of Decision (ROD) for the Site. The Site’s ROD did not establish formal remedial action objectives (RAOs) but listed this scope for the Site’s operable unit: protect public health and the environment by controlling potential migration of contaminated groundwater to the Hawthorn Formation. The Hawthorn Formation serves as a local drinking water supply.

The 1989 ROD cleanup included:

x Continued operation of the groundwater recovery and treatment system; x Continued monitoring of groundwater; x Monitored natural attenuation; x Evaluation and modification, if necessary, of the groundwater recovery and treatment system to improve its effectiveness and efficiency; and x Evaluation of the need for deed restrictions for areas of the Site that might continue to be impacted by groundwater contamination after the best available remediation technology has been implemented. Deed restrictions will protect future users of the water supply in the immediate area of the Site.

Table 2 shows the groundwater COC cleanup goals established in the 1989 ROD.

Table 2: Groundwater COC Remediation Goal Groundwater COC ROD Remediation Goal (μg/L) 1,1,1-Trichloroethane 200a 1,1-Dichloroethane 3a,b 1,2-Dichloroethane 3a 1,1-Dichloroethene 7a Benzene 1a Chlorobenzene 100c Ethyl Benzene 100c Toluene 2,000c Vinyl Chloride 1a Notes: a. State of Florida Primary Drinking Water Standard b. In the absence of sufficient toxicity data, the primary drinking water standard for the structurally similar compound, 1,2-dichloroethane, will be used. c. Proposed federal Maximum Contaminant Level (MCL) μg/L = micrograms per liter Source: Table 9.1 of the 1989 ROD

A 1991 Explanation of Significant Differences (ESD) modified the remedy to include investigation and cleanup of VOC-contaminated groundwater that spread into the upper portion of the deeper Bone Valley water-bearing unit. A 2017 ESD included the need for institutional controls in the form of a restrictive covenant and groundwater delineated area as part of the groundwater remedy for the Site.

Status of Implementation Hillsborough County voluntarily remediated soil and began operating a surficial aquifer groundwater treatment system before the 1989 ROD.

Groundwater The Bone Valley pump-and-treat system was shut down in August 1997 and the Sand Tailings and Spoil Row systems were shut down in July 1996. In 2000, the Sydney Mine Steering Committee completed a final Natural Attenuation Evaluation Report to evaluate the effectiveness of monitored natural attenuation as a final remedy for groundwater at the Site. The natural attenuation studies showed that attenuating mechanisms were active and have the potential to achieve ROD cleanup goals. No significant difference in rate of contaminant reduction was observed when the pump-and-treat systems were operating. The report concluded that: attenuating mechanisms (including degradation) are active; there was no noticeable difference in attenuation with or without operation of pump-and treat systems; no human or environmental receptors are known to be impacted by the plumes; and there is an adequate buffer area between the plume and the downgradient edge of the property (between 1,000 and 3,000 feet) to allow for monitoring of natural attenuation processes. In 2002, the County decommissioned the groundwater pump-and-treat systems. Semi-annual groundwater monitoring is the only activity taking place at the Site.

In January 2012, the County reviewed well construction information for the Hawthorn Formation wells because benzene and vinyl chloride were consistently above remediation goals in well P-4 despite all COCs being below detection in other monitored Hawthorn Formation wells. Based on a review of well construction information, the County suspected that a poorly grouted borehole for well P-4 may be causing downward migration of contamination from the shallower zone to the Hawthorn Formation. Hawthorn well P-5 was installed next to well P-4 in July 2012 and sampled from July 2012 through January 2014. All COCs have been below detection in well P-5, supporting the theory that well P-4 was compromised. The County abandoned well P-4 in June 2014.

In 2018, the property owner, with approval of the EPA, regraded the Site by adding and reshaping the surface profile of the property. The owner placed on-site soil across the top of the source area to eliminate surface water impoundments to hopefully expedite groundwater attenuation. The Site is currently vegetated with grass.

Soil Since soil excavation and removal was conducted prior to the Site’s listing on the NPL, Hillsborough County conducted soil sampling in 2010 at the request of the EPA to determine if there was any residual soil contamination that may pose an exposure concern. The county compared the 2010 soil data to the state Soil Cleanup Target Levels (SCTLs) and concluded the soils did not pose a health concern. This FYR further reviewed these data based on the most current toxicity criteria, discussed in Question B.

Institutional Control (IC) Review In 2005, Sydney Mine Reclamation, Limited Liability Company (LLC) purchased the Site. In 2010, University Energy Park, LLC purchased the Site. In 2010, the Hillsborough County Planning Commission rezoned the previously-mined site area (1,754 acres) to a newly-designated zoning class, Energy Industrial Park-Urban Service Area (EIP-USA).1 This EIP-USA zoning designation allows the land to be used for alternative energy production, research facilities, warehousing, industrial research and office buildings, as well as retail use at the entries to the project area.

In 2011, the restrictive covenant was filed with Hillsborough County (Appendix L).2 Table 3 summarizes institutional controls outlined by the restrictive covenant. Restrictive covenant restrictions apply to four designation areas, shown in Figure 2 and described in Table 4. The four designated areas cover three property parcels. These parcels are all owned by University Energy Park, LLC. The areas are:

x Area of institutional control: a 325.8-acre area; x Delineation area: a 246.5-acre within the area of the institutional control. The delineation area is a Florida groundwater delineation area, which restricts well installations; x The Superfund area: a 56.4-acre area; and x The Superfund site: a 9.5-acre area.

Restrictions are enforceable by the EPA, FDEP and their successor agencies.

Table 3: Summary of Planned and/or Implemented Institutional Controls (ICs) Media, Engineered Controls, and Areas ICs Called Title of IC Instrument That Do Not ICs for in the IC Impacted Parcel(s) Implemented and Date Support UU/UE Needed Decision Objective (or planned) Based on Current Documents Conditions

U-28-29-21-ZZZ- 000004-13680.0 2011 Restrictive Covenant Restrict the Instrument # 2011112446 Groundwater Yes Yes U-28-29-21-ZZZ- use of Book 20443 000004-13680.1 groundwater Page 962-971

U-27-29-21-ZZZ- 000004-13630.0

2011 Restrictive Covenant Area specific, Instrument # 2011112446 Soil No No None see Table 4 Book 20443 Pages 962-971

1 Hillsborough County future land use designations located at: http://gis.tpcmaps.org/apps/Production/pima/. 2 Searched by owner at: University Energy Park LLC: https://www.hillsclerk.com/Records-and-Reports. 7

Table 4: 2011 Restrictive Covenant Usage Restrictions by Area Area of Institutional Control (includes Superfund Area Superfund Site delineation area) No use of groundwater except for groundwater investigations and/or X X X remediation activities No drilling for water except for groundwater investigations and/or X X X remediation activities No wells shall be installed on the property other than monitoring wells X X X or extraction wells pre-approved by the EPA and FDEP No stormwater detention or retention -- -- X facilities or ditches No person shall engage in any excavation activity below grade -- -- X except for investigation and/or remediation activities Construction of buildings or utilities requires placement of 2 feet of clean -- X -- fill beneath the building pad No agricultural use of the land, including forestry, fishing and mining; no hotels or lodging; no recreational uses, including amusement parks, parks, camps, museums, zoos or -- X X gardens; no residential uses; and no educational uses such as elementary and secondary schools or day care services Notes: X = indicates restriction applicable to area -- = indicates restriction is not applicable to area

Figure 2: Institutional Control Map

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0 0.25 0.5 Legend Mile

Sources: ESRI, U.S. Census Bureau 2019 TIGER/Line Geodatabases, Bureau of c:J Approximate Site Boundary CJ Area of Institutional Control Transportation Statistics, DigitalGlobe, GeoEye, Earthstar Geographies, DeLorme, Tele Delineation Area Atlas, AND, First American, UNEP-WCMC, USGS, CNES/Airbus OS, USDA, AeroGRID, D Parcel i_-2 IGN, Hillsborough County GIS Department, the GIS User Community and the 2016 FYR. [Z] Superfund Area Sydney Mine Sludge Ponds Superfund Site ~Skeo · 0 City of Brandon, Hillsborough County, Florida NORTH

Systems Operations/Operation and Maintenance (O&M) The 1989 ROD required a quarterly monitoring program to analyze for groundwater constituents of concern. Following remedial action completion, the EPA will conduct a review every five (5) years should contamination remain above health-based levels. After the first review, monitoring continues annually provided the review does not identify a need for further remedial action or monitoring, or provided that health-based levels have been attained throughout the aquifer systems. This language is directly from the 1989 Rod and while this language is no longer used in documents it is consistent with sites that have moved from the active remedy into the monitored natural attenuation stage of the remedy.

Water quality monitoring activities were conducted in accordance with the 2004 Settlement Agreement between the EPA, Hillsborough County and the 106 Order Group. Hillsborough County currently conducts O&M activities, which include:

x Semi-annual monitoring of the groundwater; x Grass maintenance as needed is conducted by the property owner; x Verification of the integrity of fencing, gates and locks; and x Maintenance of access roads is conducted by the property owner.

Given the presence of 1,1,1-trichloroethane as a COC at the Site, the 2021 groundwater sampling plan was updated to include analysis of 1,4-dioxane and it will be conducted semi-annually moving forward.

III. PROGRESS SINCE THE PREVIOUS REVIEW

This section includes the protectiveness determinations and statements from the previous FYR. The previous FYR did not identify any protectiveness issues at the Site.

Table 5: Protectiveness Determinations/Statements from the 2016 FYR Protectiveness OU # Protectiveness Statement Determination The remedy at the Site is protective of human health and the environment. Ongoing monitoring is ensuring that there is no Sitewide Protective unacceptable exposure to contaminated groundwater and that the Hawthorn Formation remains protected from contamination.

IV. FIVE-YEAR REVIEW PROCESS

Community Notification, Community Involvement and Site Interviews A public notice was made available by a public notice in the Tampa Bay Times, on 12/3/2020 (Appendix E). It stated that the FYR was underway and invited the public to submit any comments to the EPA. The results of the review and the report will be made available at the Site’s information repository, Brandon Library located at 619 Vonderburg Drive, Brandon, Florida.

During the FYR process, interviews were conducted to document any perceived problems or successes with the remedy that has been implemented to date. The interviews are included in Appendix F and summarized below.

Ms. Theresa Pepe, FDEP project manager, stated that the remedy is protective of human health and the environment. A groundwater plume of mostly low levels of benzene and vinyl chloride appears to be stable and contained on site. Institutional controls in the form of deed restrictions add another layer of protection. A representative of the property owner has inquired about changing some of the land use restrictions. FDEP recommends continued dialogue with all parties involved.

Mr. Michael Townsel, Hillsborough County representative, stated that the groundwater at the Site continues to naturally attenuate. Mine reclamation work in 2018 and 2019 reshaped the area to allow for adequate surface water drainage. The Site is maintained by the property owner and more routine mowing of the vegetation is required. Reuse of the property is potentially viable should the property owner wish to discuss the Declaration of Restrictive Covenants with FDEP and the EPA. Hillsborough County is conducting a statistical evaluation of the groundwater in early 2021 to discuss a reduction in monitoring locations and sampling frequency. The draft report is anticipated to be available by mid- 2021.

Data Review The County conducts groundwater sampling semi-annually on 33 wells in the Bone Valley Member, Spoil Row, Oil Pond, North Dike areas and the deeper Hawthorn Formation. A description of the groundwater units is below:

x Spoil Row – this groundwater unit consists of silty sands material located in long, parallel rows trending north-south at locations south of the north dike. The spoil row is underlain by clay. The wells are labelled SRW;

x Oil Pond – this area is where the oil pond wastes and septic pond wastes were disposed of and consists of sand tailings derived from the mining process and underlain by clay. The wells are labelled OPRW;

x North Dike – this area consists of silty sand tailings that were contaminated and obtained from the spoil row area. The wells are labelled ND; and

x Bone Valley – this unit represents the base of the mining operations and underlies the above man-made units. This unit consists of an upper layer of clay followed by sand and more permeable phosphatic sands. The clays of this formation were breached by mining operations allowing downward migration of contaminants into sands of this unit. The wells are labelled BV.

Over the past five years, the highest residual site contamination above cleanup goals remains primarily in the Bone Valley groundwater unit. Three COCs consistently exceed groundwater remediation goals (benzene, 1,1-dichloroethane and vinyl chloride) (Table 6). Only benzene exceeded cleanup goals in the three Spoil Row unit wells with the most routine exceedances occurring in SRW-5; the benzene concentrations were lower than observed in the Bone Valley. COC concentrations were below cleanup goals or below detection in the Oil Pond and North Dike wells during the past five years.

Table 6: Maximum Detections of COCs (μg/L) in the Bone Valley Unit ROD COC Remediation 1/2016 7/2016 1/2017 7/2017 1/2018 7/2018 1/2019 7/2019 1/2020 Goal 3 2.6 (BV- 2.6 5.8 4.7 3.6 1,1- 3.5 3.3 3.4 3 (BV-1, 1, BVR- (BV- (BVR- (BVR- (BVR- Dichloroethane (BV-1) (BV-18) (BV-1) BVR-6) 6) 18) 6) 6) 6) 19 17 15 18 25 23 21 19 17 Benzene 1 (BV- (BV- (BV- (BV- (BV-21 (BV-17) (BV-3) (BV-17) (BV-3) 17) 17) 21R) 21R) R) 6.4 4.3 3.7 (BV- 3.6 4.4 4.9 5.5 5.8 7.3 Vinyl Chloride 1 (BV-1) (BV-1) 1) (BV-1) (BV-1) (BV-1) (BV-1) (BV-1) (BV-1) Notes: Bold = indicates detection above remediation goal. μg/L = micrograms per liter

Source: January 2016 Analytical Data Report; July/October 2016 Analytical Data Report; January 2017 Analytical Data Report; July 2017 Analytical Data Report; January 2018 Analytical Data Report; July 2018 Analytical Data Report; January 2019 Water Quality Monitoring Report; July 2019 Water Quality Monitoring Report; January 2020 Water Quality Monitoring Report and Supplemental Sampling in May 2020.

While no trends are obviously discernable from monitoring during this review period, historical monitoring indicates concentrations are generally decreasing (Appendix I, Figures I-1, I-2, I-3, I-4). Bone Valley monitoring well BV-21R has exhibited an upward trend in benzene during this review period. A slow increase in vinyl chloride over the evaluation period occurred in BV-8 and BV-21R. Continued monitoring will be necessary until all COCs are below remediation goals. Benzene and vinyl chloride plumes are delineated (Figure 3). No VOCs were detected in the three wells monitoring the Hawthorne Formation during this FYR period.

Figure 3: Detailed Site Map

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0 125 250 500 Legend Feet Approximate Site Boundary Sources: ESRI, Digita/Globe, GeoEye, Cl Earthstar Geographies, DeLorme, Tele ■- • -. Benzene lsoconcentration - 1 µg/L (2020) Atlas, AND, First American, UNEP .. ■ ■ I WCMC, USGS, CNES/Airbus OS, USDA, AeroGRID, /GN, the G/S User Vinyl Chloride lsoconcentration - 1 µg/L (2020) Community, the 2016 FYR and the 2020 Water Quality Monitoring Report. Monitoring Well 0 Sydney Mine Sludge Ponds Superfund Site NORTH City of Brandon, Hillsborough County, Florida

Site Inspection The site inspection took place on 10/13/2020. Participants included Michael Townsel, Tiffany Aguilar and Jeffery Greenwell with Hillsborough County and Claire Marcussen from EPA support contractor Skeo. The purpose of the inspection was to assess the protectiveness of the remedy. The site inspection checklist and photographs are provided in Appendix G and Appendix H, respectively.

Participants met at the gated site access road off of State Route 60. The dirt road was in good condition. Participants viewed the former sludge pit area that had been graded in 2018 and is now completely covered with thick grass. Monitoring wells in the former sludge pond area and downgradient of this area were observed to be labelled and secured with locks. The County noted that historically all-terrain vehicles and motorbikes would sometimes drive on the Site but such activity has not occurred during the past five years as site access is hindered by the locked gate and by a barbed wire perimeter fence that appeared to be in good condition. Some cattle grazing occurs on the Site and these are sold for meat. One sign was knocked down. The County replaced the sign, securing the sign with heavier hardware, during the semi- annual groundwater monitoring event on January 11, 2021. No trespassing signs are posted throughout the site perimeter and within the former sludge pond area; the signs identify the Site as a Superfund site and provides a phone number to contact the County for further information. The site surface is covered with thick grass vegetation and there was no erosion observed. Site inspection participants viewed the culvert installed under the access road bridge as part of a surface water management plan, which allows an unnamed stream to flow under the road.

Skeo personnel called the designated site repository: Brandon Library, 619 Vonderburg Drive, Brandon, Florida. The library has the second five-year review report and the administrative record index.

V. TECHNICAL ASSESSMENT

QUESTION A: Is the remedy functioning as intended by the decision documents?

Question A Summary: The remedy is functioning as intended by decision documents to protect groundwater in the Hawthorn Formation. All COCs were below detection limits in the Hawthorn Formation during this FYR period. Groundwater pump and treat has been shut down since 1997. Groundwater data indicate monitored natural attenuation is effectively reducing remaining contamination.

Soil excavation and removal were done before the Site’s listing on the NPL. Soil sampling was conducted in 2010 and was not determined to pose a health concern. The data were further reviewed based on current toxicity information and discussed in Question B.

A restrictive covenant is in place to restrict use of the Site and the area around the Site. The restrictive covenant effectively reduces the potential for exposure to soil and groundwater. However, the EPA, FDEP and County are planning to evaluate the restrictions for possible future uses of the Superfund Site and Superfund Area that could be compatible with the remedy. FDEP and the EPA will work with the site owner to determine their possible reuse goals and ensure the covenant is appropriate while allowing

14 for uses that will not result in exposure to remaining contamination. Currently the owner is evaluating a possible solar field reuse. Cattle were grazing onsite during the site inspection. They are sold for meat.3

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the remedy selection still valid?

Question B Summary: The exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the remedy selection remain valid.

There have been no changes in exposure pathways. The remedy is progressing as expected toward meeting the remedy goals. Table J-1 in Appendix J provides a comparison of groundwater performance standards to current standards. Standards established in the 1989 ROD have not changed or have become less stringent since the signing of the ROD, with the exception of toluene. Groundwater monitoring indicates toluene has been below the more stringent standard of 1,000 μg/L during this review period.

Table K-1 in Appendix K provides a residential screening level evaluation of the maximum soil concentrations identified during the 2010 sampling event (locations shown in Appendix D, Figure D-4). The evaluation indicates that the remaining soil contamination may be protective for uses that had been previously excluded by the restrictive covenant. However, the soil sampling depths used for that effort were down to 18 inches below the surface. Generally, EPA considers the top 12 inches to be surface soil for risk considerations. In order to properly evaluate if the site may support a less restricted reuse, additional soil sampling would be needed in the top 12 inches of soil and locations need to be coordinated between EPA and FDEP. Alternatively, the owner could add two feet of clean backfill which would mitigate the risk from contaminants that could be located in the surface soil.

Since the decision documents have been issued for the Site, there has been one significant change to the EPA’s standardized risk assessment methodology. A vapor intrusion pathway evaluation is now a part of the standard methodology. This FYR conducted a screening-level vapor intrusion and exposure pathway evaluation using the maximum concentrations of VOCs detected in groundwater (Appendix K, Table K- 2). The current monitoring data indicate that the vapor intrusion exposure pathway does not pose an unacceptable future residential risk if homes were to be constructed on the Site.

QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy?

No other information as come to light that could call into question the protectiveness of the remedy.

3 Based on conversations with the County, grazing cattle is not restricted. EPA determined that there is no unacceptable risk from consuming meat from cattle grazed at the Site. 15

VI. ISSUES/RECOMMENDATIONS

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the FYR: 1

OTHER FINDINGS Several additional recommendations were identified during the FYR. These recommendations do not affect current and/or future protectiveness.

x Evaluate groundwater sampling results to determine if 1,4-dioxane is present in groundwater; x Update the Site’s document repository; and x Review the restrictive covenant with the owner to evaluate for potential compatible uses.

VII. PROTECTIVENESS STATEMENT

OU-1 & Sitewide Protectiveness Statement Protectiveness Determination:

Protective Protectiveness Statement: The remedy at the Site is protective of human health and the environment. Groundwater data indicate monitored natural attenuation is effectively reducing remaining contamination.

VIII. NEXT REVIEW

The next FYR Report for the Sydney Mine Sludge Ponds Superfund site is required five years from the completion date of this review.

APPENDIX A – REFERENCE LIST

Analytical Data Report – January 2016. Sydney Mine Waste Disposal Site. Hillsborough County. April 13, 2016.

Analytical Data Report – January 2017. Sydney Mine Waste Disposal Site. Hillsborough County. June 19, 2017.

Analytical Data Report – January 2018. Sydney Mine Waste Disposal Site. Hillsborough County. May 24, 2018.

Analytical Data Report – July/October 2016. Sydney Mine Waste Disposal Site. Hillsborough County. December 5, 2016.

Analytical Data Report – July 2017. Sydney Mine Waste Disposal Site. Hillsborough County. October 3, 2017.

Analytical Data Report – July 2018. Sydney Mine Waste Disposal Site. Hillsborough County. December 26, 2018.

Explanation of Significant Differences. Sydney Mine Superfund Site. September 16, 1991.

Explanation of Significant Differences. Sydney Mine Superfund Site. July 13, 2017.

Fourth Five-Year Review Report for Sydney Mine Sludge Ponds. Brandon, Hillsborough County, Florida. United States Environmental Protection Agency. Region 4. March 23, 2016.

Record of Decision Declaration. Sydney Mine Sludge Ponds. Hillsborough County, Florida. U.S. Environmental Protection Agency. September 29, 1989.

Soil Boring Investigation Report. Sydney Mine Disposal Superfund Site. Hillsborough County. July 2010

Water Quality Monitoring Report – January 2019. Sydney Mine Waste Disposal Site. Hillsborough County. April 19, 2019.

Water Quality Monitoring Report – January 2020 and Supplemental Sampling in May 2020. Hillsborough County. May 29, 2020.

Water Quality Monitoring Report – July 2019. Sydney Mine Waste Disposal Site. Hillsborough County. October 18, 2019.

A-1

APPENDIX B – CURRENT SITE STATUS

Environmental Indicators - Current human exposures at the Site are under control. - Current groundwater migration is under control.

Are Necessary Institutional Controls in Place? All Some None

Has EPA Designated the Site as Sitewide Ready for Anticipated Use? Yes No

Has the Site Been Put into Reuse? Yes No Cattle grazing was observed during the October 2020 site inspection.

B-1

APPENDIX C – SITE CHRONOLOGY

Table C-1: Site Chronology

Event Date Phosphate mining occurred 1930s and 1950s Mining operations ceased 1958 Tailing sands and phosphatic clay wastes disposed of on site 1958-1973 Hillsborough County Public Utilities Department leased the Site for permitted 1973-1982 disposal of septic wastes, waste automobile oils, grease trap wastes and manufacturing oils The EPA and the FDER, now FDEP, included the Site in their inventories of potential 1979 hazardous waste sites, which resulted in the EPA investigating surface water and groundwater Hillsborough County notified the EPA of hazardous waste activity at the Site in 1980 accordance with the RCRA The EPA further investigated and evaluated site conditions in response to local 1981 citizens’ inquiries about air and water quality and human health effects FDER denied a permit for waste disposal and the Site closed. American Cyanamid Corporation sold the property to Waste Management, Inc. Hillsborough County began voluntary remedial actions 1982 Hillsborough County constructed a soil slurry wall, excavated contaminated soil and 1984-1986 began groundwater recovery and treatment The EPA proposed the Site to the Superfund program’s NPL June 10, 1986 Hillsborough County began groundwater recovery and treatment 1987 Hillsborough County excavated and conducted air-drying on additional wastes identified with off-site residual disposal The PRPs conducted the Remedial Investigation/Feasibility Study 1988-1989 The EPA finalized the Consent Decree for Hillsborough County to complete the May 12, 1989 Remedial Investigation/Feasibility Study and endangerment assessment The EPA issued an administrative order to the six PRPs (PRP Group) to take over May 24, 1989 O&M at the Site Hillsborough County ceased conducting O&M of the groundwater recovery and May 31, 1989 treatment system and was ordered by the EPA to turn O&M over to the PRP group The EPA signed the ROD September 29, 1989 The EPA finalized the Site on the NPL October 4, 1989 The EPA issued a Unilateral Administrative 106 Order to the PRP group to initiate July 10, 1990 remedial design activities The EPA signed an ESD modifying the remedy September 16, 1991 PRPs completed remedial design March 31, 1992 Groundwater monitored natural attenuation evaluation initiated 1996 Sand Tailings and Spoil Row groundwater treatment system ceased operations Bone Valley groundwater treatment system shut down 1997 The PRP group completed a final Natural Attenuation Evaluation Report 2000 The EPA signed the Site’s first FYR September 13, 2001 Groundwater pump-and-treat systems decommissioned 2002 Hillsborough County assumed role of project management November 2003 Sydney Mine Reclamation, LLC purchased the Site August 30, 2005 The EPA signed the Site’s second FYR September 14, 2006 Hillsborough County removed 55-gallon drums 2007 Hillsborough County installed three groundwater monitoring wells for delineation C-1

Event Date Hillsborough County installed 10 soil borings and collected 20 soil samples 2010 associated with borings Hillsborough County Planning Commission rezoned the Site to Energy Industrial Park-Urban Service Area University Energy Park, LLC purchased the Site December 14, 2010 The EPA signed the Site’s third FYR September 28, 2011 Hillsborough County reviewed well construction information for January 2012 well P-4 Hillsborough County abandoned well P-4 June 2014 Hillsborough County completed a Desktop Groundwater Treatment Evaluation August 8, 2014 The EPA signed the Site’s fourth FYR March 23, 2016

C-2

APPENDIX D – SITE MAPS Figure D-1: 1989 ROD Site Map

-3-

S.R. 60

Dike

_r-1-,. + 200 0 200 400 Nor.~ Scale 1n Feet

SITE MAP-SYDNEY MINE WASTE DISPOSAL SlTE Figur~2.2

Source: Figure 2.2 from the 1989 ROD.

D-1

Figure D-2: Hydrogeologic Cross Section

on !'.!! ~ FORMER SOUTH OILPONO AREA Af£A N9flTtLAfleA ~ PERCHED I I WATER 100 IAijll ,---A-, 6/I ) J HH r:a~:,. "' 6/13/66 I ii i ~i ;:- 90 t ld lei 1,_ 1:::::r~iki~R~::::::::(:::77::::::::::::•: RO ·::::_SANO•:•:•:•:•:•:• 10? k .J

~ ~ I Id .J 7 0 40 .= .J< lei JO II'. I z wiiH WEAlHI ~ - AND PHOSf'' 0 I ,-= °' 20 ._,_.· .. .· tHORI •I > lei .J 10 w it.iEs'r6N~

SEA I ( '/ t-:L

· 10

-:W IN0ICA T[S APPROXIMATE r----r--,- -- ·- --,- - POSITION Of CONT.t.MINATION o· , oo· 200· :soo· 400· sou· FB OCTOBER 19116 HQlf L HORIZONTAi. SCALE I OH I IU[ Of CROSS SECTION SU f 11;unl l 7 AGUE 5.4 Hydrogeologlc Cross Section; Sydney Mine Waste Disposal Site -r--- - ·- E:iJJ:J/!J- - - Source: Figure 5.4 from the 1989 ROD

D-2

Figure D-3: Groundwater Monitoring Groundwater Elevation

FIGURE 8

SYDNEY MINE GROUNDWATER ELEVATION CONTOUR DIAGRAM

TOWNSHIP RANGE SECTION 29-21-27 Hillsborough ~ County Florida

s EXISTING 80HE VALLEY GROUNDWATERMOftlITORJNGW'EUS ... - R.eclillecl c:] c.r.... n , Gtccn -1111 ... ,11 ...

a 125 250 ----====:::iFeet

...... ,,...... ~ ... "·"·'"_..... ,...... -~ ...... _,.. , 1==~""'•·•·--10, f'\O" '" ' "'MO .MH"• •f. --~-,~,=-·~.. , ._...... ---...... _ ..... ,,...... _, .. ~- ~·- I la nof .. , , .. . ·. ----. .... ,,~ ...... , ... _ , ...... --... ~...... --M...... ,, ...... ~,- ..M---'••- - - N•-· •~- -

Ul N. U lk-M9• 4 J,._ I ..... p .. ,fllUIII A

FUl.h U '1..ANOF•LL\Sy1r"")' Mir,.; L~·,af• I\SyJi.. y Mu; ,8',n,j '•'d~ ~ 4_;,o_:1{2~_2 ~ " oJ

Source: Figure 8 from the January 2020 and Supplemental Sampling in May 2020 Water Quality Monitoring Report

D-3

Figure D-4: 2010 Soil Sampling Location Map

I I I ~ ~ ! ~ ~ : i 3 e ~ II) ~ i 0 !C 1~ ,.2 §a ~§ ~'.# C C II ~ B ~ f e_, ~ ( ( ~ ~ - - C u [:] :J 0~ !::: ::::, (9 > > Cl) Cl) Cl) 0 z z z UJ :J :::E LL ...J ...J Cl) Cl) 0 0 a.. 0 a.. 0:: z z <( UJ w UJ ~ :::E a.. <( ~ •N :J -, :'.j ~ N -

Source: Soil Sampling Location Map, July 22, 2010 from Hillsborough County’s Soil Boring Investigation Report, July 2010.

D-4

APPENDIX E – PRESS NOTICE

0000125490-0 I Tampa Bay Times oEPA Published Daily Purpo,e/Objectiv~ The EPA is conducting a Five-Year Review of the remedy for the Sydney Mine Sludge Ponds superfund site (the Site) in Brandon, Florida. The STATE OF FLORIDA purpose of the Five-Year Review is to make sure the selected cleanup actions effectively protect human health and the environment. COUNTY OF Hillsborough }ss Site Background : The 9,5-acre Site Is part of a rural area south of Florida State Road 60 in Hillsborough County, 15 miles southeast of downtown Tampa. From the 19305 through the 19505, mining of phosphate ore took ~ace across a 1,700-acre area that included the Site. From 1973 to 1982. Hillsborough County operated a liquid waste disposal facility on site that accepted s!uctge, grease trappings and Before the undersigned authority personally 1 0 1 oppenred Virg:i.aia Marshall who ~~~~~1t';.~~mi ·11~~t!h~~h~~%~~nd~!;;~~-~~ a~c::arr~~~es List (N PL) in 1989. Site contaminants Include volatile organic compounds (VOCs) on oath says that he/she is Legal Advcrtisinz Representative of the Tampa such as benzene. Cleanup Actions : The Site's potentially responslble parties (PRPS) began a Bay Timu a daily newspaper printed in St. Petersburg, in Pinellas County. voluntary cleanup of the Site in 1984. It Included a below-ground barrier wall, removal of incinerated pit contents, groundwater pumping and treatment in the surficlal aQuifer. and excavation and Incineration of contaminated soils and Florida; that the attached copy of advertisement, being a Legal Notice in the sediment The EPA selected the final groundwater remedy- additional pumping and treatment- In the Site's 1989 Record of Decision (ROD). The EPA updated the remedy in 1991, requiring matter RE: Skto/EPA- Sydnty Mint cleanup of voe-contaminated groundwater In the uppef Sl•dgt Ponds Site was published in portion of the deeper Bone Valley Water-Bearing Unit. Following these activities, the groundwater pump-and-treat system has been decommissioned. The EPA Tampa Bay Timcs: Jl/ 1/20 in said newspaper in the issues of Bayliak updated the remedy In 2017 to require Institutional controls In the form of a restrictive covenant artd a groundwater delineated area. The restrictive covenant prevents the use of groundwater at the Site and prohibits residential use of the Site. HiUsborougb Groundwater monitoring is ongoing. Flw-Year Review SChedule : The National contingency Plan requires review of remedial actions that result in any hazardous substances, pollutants or contaminants remaining at the Site above levels that allow for unlimited use and unrestricted exposure every five years to ensure the protection of human health Affiant further says the said Tampa Bay Timr.s is a newspaper published in and the environment. The fifth of the Five-Year Reviews tor the Site will be completed by March 2021. When the Five--Year Review is completed, It will be Hillsborough County. Florida and that available online at: https://www.epa.gov/superfund/search•superfund-five-year the said newspaper has heretofore been reviews. continuously published in said Hillsborough County, Florida each day and has The EPA Invites Community PartlclpatJon In the ffv~Year Review Process : The EPA is conducting this Five-Year Review to evaluate the effectiveness of the Slte·s remedy and to ensure that the remedy remains protective of human health been entered as a second clll.$s mail matter at the post office in said Hillsborough and the environment. As part of the Five-Year Review process, EPA staff Is available to answer any questions about the Site. Community members who have questions about the Site or the Five-Year Review process, or who would like to participate in a County. Florida for a period of one year next preceding the first publication of community interview. are asked to contact: the attached Shelby Johnston, EPA Remedial Project Manager copy of advertisement, and affiant further says that h,/she neither Phone: (404) 562-8287 Email: [email protected] paid not promised any person, firm or corporation any discount, rebate, L'Tonya Spencer-Harvey, EPA Community Involvement Coordinator Phone: (404) 562·8463 commission or refund for the purpose of securing this advc Email: [email protected] Mailing Address: U.S. EPA Region 4, 61 Forsyth Street, s.w., 11th Floor, publication in the said newspaper. Atlanta, GA 30303-8960

Additional information Is available at the Site's local document repository, Brandon Regional Library, located at 619 Vonderburg Drive, Brandon, Florida 33511 (consider ~o:;,~~~~~~~~;:~u~od~;~~~y'.~fn~~:l~~:~.d online at 0000125490 12/02/2020bn

X or produced identification

Type of identification produced

E-1 APPENDIX F – INTERVIEW FORMS

SYDNEY MINE SLUDGE PONDS SUPERFUND SITE FIVE-YEAR REVIEW INTERVIEW FORM Site Name: Sydney Mine Sludge Ponds EPA ID: FLD000648055 Interviewer name: Interviewer affiliation: Subject name: Theresa Pepe Subject affiliation: FDEP Subject contact information: [email protected] Interview date: 10/30/2020 Interview time: Interview location: Tallahassee, Florida Interview format (circle one): In Person Phone Mail (_ -Email ) Other: Interview category: State Agency

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)?

Overall impressions are positive. Hillsborough County is managing the site, including maintenance and routine groundwater sampling.

2. What is your assessment of the current performance of the remedy in place at the Site?

The remedy is protective of human health and the environment. A groundwater plume of mostly low levels of benzene and vinyl chloride appears to be stable and contained onsite. Institutional controls in the form of deed restrictions add another layer of protection.

3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial activities from residents in the past five years?

A representative of the property owner has inquired about changing some of the land use restrictions. No complaints that I am aware of.

4. Has your office conducted any site-related activities or communications in the past five years? If so, please describe the purpose and results of these activities.

FDEP reviews semi-annual groundwater monitoring reports and provides comments, as needed. FDEP participated in the last 5 Year review and concurred with the 2017 ESD.

5. Are you aware of any changes to state laws that might affect the protectiveness of the Site’s remedy?

No.

F-1 6. Are you comfortable with the status of the institutional controls at the Site? If not, what are the associated outstanding issues?

Yes, FDEP is comfortable with the Institutional Controls. The only outstanding issue is the request from the property owner stated above. FDEP recommends continued dialogue with all parties involved and consultation with our Office of General Counsel, if required.

7. Are you aware of any changes in projected land use(s) at the Site?

FDEP is aware of plans to develop an Energy Industrial Park. Development is not prohibited as long as the property owners adhere to current institutional control measures.

8. Do you have any comments, suggestions or recommendations regarding the management or operation of the Site’s remedy?

None at this time. Semi-annual groundwater monitoring appears sufficient to monitor the plume.

9. Do you consent to have your name included along with your responses to this questionnaire in the FYR report?

Yes

F-2 SYDNEY MINE SLUDGE PONDS SUPERFUND SITE FIVE-YEAR REVIEW INTERVIEW FORM Site Name: Sydney Mine Sludge Ponds EPA ID: FLD000648055 Interviewer name: Claire Iviarcussen Interviewer affiliation: Skeo (EPA Contractor) Subject name: Michael D. Townsel Subject affiliation: Hydrogeologist - Hills. Co. Subject contact information: [email protected]; (813) 663-3222 Interview date: 10/22/2020 Interview time: N/A Interview location: Interview questionnaire completed online. Interview format (circle one): In Person Phone Iviail Email: X Other: Interview category: O&M Contractor

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)?

The groundwater at the Sydney Mine Superfund Site continues to naturally attenuate over the period of record as the selected remedy in place continues to be effective. Mine reclamation work conducted in 2018 and 2019 by the property owner has reshaped the area by preventing standing water near the source area and allow for adequate surface water drainage. The site is maintained by the property owner and more routine mowing of the vegetation is required. Reuse of the property is potentially viable should the property owner wish to discuss the Declaration of Restiictive Covenants with the Florida Department of Environmental Protection (FDEP) and U.S. EPA Region 4.

2. What is your assessment of the current performance of the remedy in place at the Site?

The selected remedy in place is effective as natural attenuation of groundwater continues over the period of record. The County has conducted preliminary discussions with U.S. EPA Region 4 and FDEP to request optimization of the groundwater monitoring plan for the Site. Optimization would include, but not limited to, the reduction in monitoring locations and reduction in sampling frequency from semi annual to annual. To substantiate the position, a statistical evaluation of the groundwater shall be provided by Hillsborough County to U.S EPA Region 4 and FDEP in early 2021.

3. What are the findings from the monitoring data? What are the key trends in contaminant levels that are being documented over time at the Site?

The analytical data supports ongoing reduction of volatile organic constituents (VOCs) within the groundwater. Specifically, benzene and vinyl chloride continue to attenuate within the Bone Valley Member of the Peace River Formation. The deeper Upper

F-3 Hawthorne monitoring wells have exhibited no vertical migration of overlying groundwater contamination over the period of record.

4. Is there a continuous on-site O&M presence? Ifso, please describe staff responsibilities and activities. Alternatively, please describe staff responsibilities and the frequency of site inspections and activities ifthere is not a continuous on-site O&M presence.

O&M activities continue to be active at the Superfund Site. Hillsborough County Public Utilities continues to proceed with semi-ammal groundwater sampling, posting and maintaining proper Superfund warning signs, and monitoring well maintenance. Periodic site mowing is conducted by the property owner since mine reclamation activities have been completed. The County continues to ensure the monitoring wells are properly labeled and secured by conducting periodic site inspections and ensure signs identifying the Superfund Site are visible.

5. Have there been any significant changes in site O&M requirements, maintenance schedules or sampling routines since start-up or in the last five years? If so, do they affect the protectiveness or effectiveness of the remedy? Please describe changes and impacts.

There have been no changes to the O&M requirements or schedules at the site for the ongoing groundwater sampling.

6. Have there been unexpected O&M difficulties or costs at the Site since start-up or in the last five years? If so, please provide details.

There have been no unexpected changes or costs for Hillsborough Comity in the last 5- years.

7. Have there been opportunities to optimize O&M activities or sampling efforts? Please describe changes and any resulting or desired cost savings or improved efficiencies.

After preliminary discussions with EPA during the 5-Year Review phone call earlier this year, there is an opportunity to review and present optimization of the groundwater sampling efforts. Based upon the flndings of a statistical evaluation of the groundwater trends and the reduction in contamination, a discussion is warranted to reduce the groundwater monitoring from semi-annual to annual monitoring and removal of groundwater wells that do not present any value to the ongoing attenuation of the site.

8. Do you have any comments, suggestions or recommendations regarding O&M activities and schedules at the Site?

As previously mentioned, Hillsborough County will coordinate with EPA and FDEP on optimization of the groundwater monitoring activities.

F-4 9. Do you consent to have your name included along with your responses to this questionnaire in the FYR report? Yes

F-5 APPENDIX G – SITE INSPECTION CHECKLIST

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site Name: Sydney Mine Sludge Ponds Date of Inspection: 10/13/2020 Location and Region: Brandon, FL 4 EPA ID: FLD000648055 Agency, Office or Company Leading the Five-Year Weather/Temperature: 82 degrees, sunny Review: EPA Remedy Includes: (Check all that apply) □ Landfill cover/containment □ Monitored natural attenuation □ Access controls □ Groundwater containment ~ Institutional controls □ Vertical barrier walls ~ Groundwater pump and treatment □ Surface water collection and treatment □ Other: - Attachments: ~ Inspection team roster attached □ Site map attached II. INTERVIEWS (check all that apply) 1. O&M Site Manager Michael Townsel Hillsborough County 10/22/2020 Name Title Date Interviewed □ at site □ at office □ by phone Phone: - Problems, suggestions □ Report attached: - 2. O&M Staff - - - Name Title Date Interviewed □ at site □ at office □ by phone Phone: - Problems/suggestions □ Report attached: - 3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices). Fill in all that apply.

Agency -FDEP Contact Theresa Pepe -Project 10/30/2020 - Name Manager Date Phone No. Title Problems/suggestions □ Report attached: -

Agency - Contact - Name - - - Title Date Phone No. Problems/suggestions □ Report attached:-

Agency - Contact - - - - Name Title Date Phone No. Problems/suggestions □ Report attached:-

Agency - Contact - - - - Name Title Date Phone No. Problems/suggestions □ Report attached: G-1

Agency - Contact - - - - Name Title Date Phone No. Problems/suggestions Report attached: □ 4. Other Interviews (optional) □ Report attached: -

III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply) 1. O&M Documents □ O&M manual □ Readily available □ Up to date ~ N/A □ As-built drawings □ Readily available □ Up to date ~ N/A □ Maintenance logs □ Readily available □ Up to date ~ N/A Remarks:

- 2. Site-Specific Health and Safety Plan □ Readily available □ Up to date ~ N/A □ Contingency plan/emergency response plan □ Readily available □ Up to date ~ N/A

Remarks:

- 3. O&M and OSHA Training Records □ Readily available □ Up to date ~ N/A Remarks:

- 4. Permits and Service Agreements □ Air discharge permit □ Readily available □ Up to date ~ N/A □ Effluent discharge □ Readily available □ Up to date ~ N/A □ Waste disposal, POTW □ Readily available □ Up to date ~ N/A □ Other permits: - □ Readily available □ Up to date ~ N/A Remarks:

- 5. Gas Generation Records □ Readily available □ Up to date ~ N/A Remarks:

- 6. Settlement Monument Records □ Readily available □ Up to date ~ N/A Remarks:

- 7. Groundwater Monitoring Records □ Readily available □ Up to date ~ N/A Remarks:

- 8. Leachate Extraction Records □ Readily available □ Up to date ~ N/A Remarks:

- 9. Discharge Compliance Records □ Air □ Readily available □ Up to date ~ N/A □ Water (effluent) □ Readily available □ Up to date ~ N/A Remarks:

- G-2

10. Daily Access/Security Logs □ Readily available □ Up to date ~ N/A Remarks:

- IV. O&M COSTS 1. O&M Organization □ State in-house □ Contractor for state ~ PRP in-house □ Contractor for PRP □ Federal facility in-house □ Contractor for Federal facility

□- 2. O&M Cost Records □ Readily available □ Up to date ~ Funding mechanism/agreement in place ~ Unavailable Original O&M cost estimate: -□ Breakdown attached Total annual cost by year for review period if available From: - To: - - □ Breakdown attached Date Date Total cost

From: - To: - - □ Breakdown attached Date Date Total cost

3. Unanticipated or Unusually High O&M Costs during Review Period

Describe costs and reasons: - V. ACCESS AND INSTITUTIONAL CONTROLS ~ Applicable □ N/A A. Fencing 1. Fencing Damaged □ Location shown on site map ~ Gates secured □ N/A Remarks: - B. Other Access Restrictions 1. Signs and Other Security Measures □ Location shown on site map □ N/A Remarks: No tresspassing signs located in appropriate locations. C. Institutional Controls (ICs)

G-3

1. Implementation and Enforcement Site conditions imply ICs not properly implemented □ Yes ~ No □ N/A Site conditions imply ICs not being fully enforced □ Yes ~ No □ N/A Type of monitoring (e.g., self-reporting, drive by): - Frequency: - Responsible party/agency: -PRP Contact - - - - Name Title Date Phone no. Reporting is up to date □ Yes □ No ~ N/A Reports are verified by the lead agency □ Yes □ No ~ N/A Specific requirements in deed or decision documents have been met □ Yes □ No ~ N/A Violations have been reported □ Yes □ No ~ N/A Other problems or suggestions: □ Report attached

2. Adequacy ~ ICs are adequate □ ICs are inadequate □ N/A Remarks: - D. General 1. Vandalism/Trespassing □ Location shown on site map ~ No vandalism evident Remarks: - 2. Land Use Changes On Site □ N/A Remarks: The Site is being used for cattle grazing. It is unclear whether this is an appropriate use based on the current restrictions in place.

3. Land Use Changes Off Site ~ N/A Remarks: - VI. GENERAL SITE CONDITIONS A. Roads □ Applicable ~ N/A 1. Roads Damaged □ Location shown on site map □ Roads adequate □ N/A Remarks: - B. Other Site Conditions

Remarks: - VII. LANDFILL COVERS □ Applicable ~ N/A A. Landfill Surface 1. Settlement (low spots) □ Location shown on site map □ Settlement not evident Area extent: - Depth: - Remarks:

- 2. Cracks □ Location shown on site map □ Cracking not evident Lengths: - Widths: - Depths: -

G-4

Remarks:

- 3. Erosion □ Location shown on site map □ Erosion not evident Area extent: - Depth: - Remarks:

- 4. Holes □ Location shown on site map □ Holes not evident Area extent: - Depth: - Remarks:

- 5. Vegetative Cover □ Grass □ Cover properly established □ No signs of stress □ Trees/shrubs (indicate size and locations on a diagram) Remarks:

- 6. Alternative Cover (e.g., armored rock, concrete) □ N/A Remarks:

- 7. Bulges □ Location shown on site map □ Bulges not evident Area extent: - Height: - Remarks:

- 8. Wet Areas/Water Damage Wet areas/water damage not evident □ □ Wet areas □ Location shown on site map Area extent: - □ Ponding □ Location shown on site map Area extent: - □ Seeps □ Location shown on site map Area extent: - □ Soft subgrade □ Location shown on site map Area extent: - Remarks:

- 9. Slope Instability □ Slides □ Location shown on site map □ No evidence of slope instability Area extent: - Remarks:

- B. Benches □ Applicable □ N/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.) 1. Flows Bypass Bench □ Location shown on site map □ N/A or okay Remarks:

2. Bench Breached □ Location shown on site map □ N/A or okay Remarks:

- 3. Bench Overtopped □ Location shown on site map □ N/A or okay Remarks:

- C. Letdown Channels □ Applicable □ N/A (Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side G-5

slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.) 1. Settlement (Low spots) □ Location shown on site map □ No evidence of settlement Area extent: - Depth: - Remarks:

- 2. Material Degradation □ Location shown on site map □ No evidence of degradation Material type:- Area extent: - Remarks:

- 3. Erosion □ Location shown on site map □ No evidence of erosion Area extent: - Depth: - Remarks:

- 4. Undercutting □ Location shown on site map □ No evidence of undercutting Area extent: - Depth: - Remarks:

- 5. Obstructions Type: - □ No obstructions □ Location shown on site map Area extent: - Size: - Remarks:

6. Excessive Vegetative Growth Type: - □ No evidence of excessive growth □ Vegetation in channels does not obstruct flow □ Location shown on site map Area extent: - Remarks:

- D. Cover Penetrations □ Applicable □ N/A 1. Gas Vents □ Active □ Passive □ Properly secured/locked □ Functioning □ Routinely sampled □ Good condition □ Evidence of leakage at penetration □ Needs maintenance □ N/A Remarks:

- 2. Gas Monitoring Probes □ Properly secured/locked □ Functioning □ Routinely sampled □ Good condition □ Evidence of leakage at penetration □ Needs maintenance □ N/A Remarks:

- 3. Monitoring Wells (within surface area of landfill) □ Properly secured/locked □ Functioning □ Routinely sampled □ Good condition □ Evidence of leakage at penetration □ Needs maintenance □ N/A Remarks:

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4. Extraction Wells Leachate □ Properly secured/locked □ Functioning □ Routinely sampled □ Good condition □ Evidence of leakage at penetration □ Needs maintenance □ N/A Remarks:

- 5. Settlement Monuments □ Located □ Routinely surveyed □ N/A Remarks:

- E. Gas Collection and Treatment □ Applicable ~ N/A 1. Gas Treatment Facilities □ Flaring □ Thermal destruction □ Collection for reuse □ Good condition □ Needs maintenance Remarks:

- 2. Gas Collection Wells, Manifolds and Piping □ Good condition □ Needs maintenance Remarks:

- 3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings) □ Good condition □ Needs maintenance □ N/A Remarks:

- F. Cover Drainage Layer □ Applicable ~ N/A 1. Outlet Pipes Inspected □ Functioning □ N/A Remarks:

- 2. Outlet Rock Inspected □ Functioning □ N/A Remarks:

- G. Detention/Sedimentation Ponds □ Applicable ~ N/A 1. Siltation Area extent: - Depth: - □ N/A □ Siltation not evident Remarks:

2. Erosion Area extent: - Depth: - □ Erosion not evident Remarks:

- 3. Outlet Works □ Functioning □ N/A Remarks:

- 4. Dam □ Functioning □ N/A Remarks:

- H. Retaining Walls □ Applicable ~ N/A 1. Deformations □ Location shown on site map □ Deformation not evident Horizontal displacement: - Vertical displacement: - G-7

Rotational displacement: - Remarks:

- 2. Degradation □ Location shown on site map □ Degradation not evident Remarks:

- I. Perimeter Ditches/Off-Site Discharge □ Applicable igJ N/A 1. Siltation □ Location shown on site map □ Siltation not evident Area extent: - Depth: - Remarks: - 2. Vegetative Growth □ Location shown on site map □ N/A □ Vegetation does not impede flow Area extent: - Type: - Remarks:

- 3. Erosion □ Location shown on site map □ Erosion not evident Area extent: - Depth: - Remarks:

- 4. Discharge Structure □ Functioning □ N/A Remarks:

- VIII. VERTICAL BARRIER WALLS □ Applicable igJ N/A 1. Settlement □ Location shown on site map □ Settlement not evident Area extent: - Depth: - Remarks:

2. Performance Monitoring Type of monitoring: - □ Performance not monitored Frequency: - □ Evidence of breaching Head differential: - Remarks:

- IX. GROUNDWATER/SURFACE WATER REMEDIES igJ Applicable □ N/A A. Groundwater Extraction Wells, Pumps and Pipelines □ Applicable igJ N/A 1. Pumps, Wellhead Plumbing and Electrical □ Good condition □ All required wells properly operating □ Needs maintenance □ N/A Remarks:

- 2. Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances □ Good condition □ Needs maintenance Remarks:

- 3. Spare Parts and Equipment □ Readily available □ Good condition □ Requires upgrade □ Needs to be provided G-8

Remarks:

- B. Surface Water Collection Structures, Pumps and Pipelines □ Applicable igJ N/A 1. Collection Structures, Pumps and Electrical □ Good condition □ Needs maintenance Remarks:

- 2. Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances □ Good condition □ Needs maintenance Remarks: - 3. Spare Parts and Equipment □ Readily available □ Good condition □ Requires upgrade □ Needs to be provided Remarks:

- C. Treatment System □ Applicable igJ N/A 1. Treatment Train (check components that apply) □ Metals removal □ Oil/water separation □ Bioremediation □ Air stripping □ Carbon adsorbers □ Filters: - □ Additive (e.g., chelation agent, flocculent): - □ Others: - □ Good condition □ Needs maintenance □ Sampling ports properly marked and functional □ Sampling/maintenance log displayed and up to date □ Equipment properly identified □ Quantity of groundwater treated annually: - □ Quantity of surface water treated annually: - Remarks:

- 2. Electrical Enclosures and Panels (properly rated and functional) □ N/A □ Good condition □ Needs maintenance Remarks:

- 3. Tanks, Vaults, Storage Vessels □ N/A □ Good condition □ Proper secondary containment □ Needs maintenance Remarks:

- 4. Discharge Structure and Appurtenances □ N/A □ Good condition □ Needs maintenance Remarks:

- 5. Treatment Building(s) □ N/A □ Good condition (esp. roof and doorways) □ Needs repair G-9

□ Chemicals and equipment properly stored Remarks:

- 6. Monitoring Wells (pump and treatment remedy) □ Properly secured/locked □ Functioning □ Routinely sampled □ Good condition □ All required wells located □ Needs maintenance □ N/A Remarks:

- D. Monitoring Data 1. Monitoring Data

~ Is routinely submitted on time ~ Is of acceptable quality

2. Monitoring Data Suggests:

~ Groundwater plume is effectively contained ~ Contaminant concentrations are declining

E. Monitored Natural Attenuation 1. Monitoring Wells (natural attenuation remedy) ~ Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition □ All required wells located □ Needs maintenance □ N/A Remarks:

- X. OTHER REMEDIES If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction. XI. OVERALL OBSERVATIONS A. Implementation of the Remedy Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant plume, minimize infiltration and gas emissions). The original groundwater remedy of pump and treat has been shut off for some time. Current monitoring of the natural of attenuation of contaminants indicates the plume is contained and concentrations are declining, mostly nearing performance goals. B. Adequacy of O&M Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy. Discussions are ongoing to optimize the remedy, including abandoning unnecessary monitoring wells. C. Early Indicators of Potential Remedy Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised in the future. No indicators of potential issues were observed. D. Opportunities for Optimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. Opportunities for optimizing are being discussed, described in the O&M section.

Site Inspection Participants Michael Townsel, Tiffany Aguilar and Jeffery Greenwell, Hillsborough County Claire Marcussen, Skeo

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APPENDIX H – SITE INSPECTION PHOTOS

Entrance gate to the Site

Flowing culvert under entrance road

H-1

Access road

Locked monitoring well 2

H-2

Regraded area of the Site

Looking south of the waste areas; cattle visible in background

H-3

One damaged sign located on site

Visible signage on site

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APPENDIX I – DATA FIGURES

Figure I-1: Historical Trends of Benzene in Bone Valley Unit (2010-2020)

Figure 2 - Sydney Mine Bone Valley Member - Benzene Concentration$

-' ~"- 1'""

lC: , "' - -·~ - ff.~~+----,- -~ - I . :: •-" f ---- ~~-~ / ;--;~ -~.a. '----.....:, __ - . .>. -::,;: ' '-.L' ----,.,.~--~-c::-,...... " ~ - -.=- -- --~ - ~

~.;n~lO-_-__ -V- --,--==-- ~------Ju! lJ Jan 11 ------.:==--- -~ ------<>•< ~,. - --- - ,ul-12. _ --sv 1 B'J 3 -- , n-:S ~ul 13 >M 14_ -_,.- _ - - •. ,. ' -=-= ,. 5V 23 eV-24 BV I ~ 0 - " ev1a BV-19 SVR-Jsv~20 --BV-6 8VR-6 Jt,;J-U Jan 1S Jul-JS I BV-15 -Ei'l--o,« -2.6 BVBV-15-27 --eV-1ti__ ,.MQ. 3V-17 Jt.<\-18 Jar-19__ ...... :;Joi. 19 J~-,0 -- --BV-21 ----BY -21A -- SV-7 --•,o •• It -

Source: Figure 2 from the January 2020 and Supplemental Sampling in May 2020 Water Quality Monitoring Report.

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Figure I-2: Historical Trends of Benzene in Spoil Row, Oil Pond and North Dike Wells (2010-2020)

i(l g ~ 1/!• ls ~~ :cl s ,; ' ' I I I I I I I I I I I I I I I I I I I I I : ;i " i ii ~ ~ ;; .i .. .. i i ~ ~ ! i Si t d ~ 1 ;: I I 1

Source: Figure 3 from the January 2020 and Supplemental Sampling in May 2020 Water Quality Monitoring Report.

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Figure I-3: Historical Trends of Vinyl Chloride in Bone Valley Unit (2010-2020)

Figure 4 - Sydney Mine Bone Valley Member- Vinyl Chl.oride Concentrations 1)

~ 6 ~

Jan-1,0 Jul-to l.an-11 .>Lil-ll far--12 Jul-12 ; ao-13 Ju1-l3 Jan-14 JU-·14 l.arH~ JUl·l~ Jar.-l 5 Jul-l6 san-11 Jul-ll Jan-18 ~u:-lS J.an-l~ Jul-19 .:an-20 -- BV-1 --BV -3 --aV R-4 --s v-6 - B\IR-6 8\/-7 -- sv-s -- av-9 --lw-B - sv-14 --S\1-J..S -- ev-t6 --\n CL

Source: Figure 4 from the January 2020 and Supplemental Sampling in May 2020 Water Quality Monitoring Report.

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Figure I-4: Historical Trends of Vinyl Chloride in Bone Valley Unit (2010-2020)

Figure 5 - Sydney Mine Bone Valley Member - Vinyl Chloride Concentrations

2.,

~ 1.S \ \ ~ ------~ IJ--~+~r-~ " ...--_____ ------ 1 ---""' / .. ~~ - IA ./11. - '-. --/I ·. \ ;- - "v~ / 0.5 \ / x~ \ 1// /\1 / \ 0 ------/;m-10 JuH O J,:u~l l Jul-i1 J<1n-ll Jul-U Jar--13 Jul-H !dl"l·l 4 Jul-14 U n -~ Jul-1~ Jan-16 J\Jl-16 Ja~ll Jul•l/ Jc1n-t8 JIJ!-18 Jnn-19 Jul-19 ~An-lO

BV· 17 -- B>J-1R BV-19 - av-20 EIV-21 -- .av-l:Hl 1w-n -- av-n B\1-24 IW-2.i -- .!3V-l:6 BV-17 --MU.

Source: Figure 5 from the January 2020 and Supplemental Sampling in May 2020 Water Quality Monitoring Report

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APPENDIX J – DETAILED ARARS REVIEW TABLES

CERCLA Section 121(d)(1) requires that Superfund remedial actions attain “a degree of cleanup of hazardous substance, pollutants, and contaminants released into the environment and control of further release at a minimum which assures protection of human health and the environment.” The remedial action must achieve a level of cleanup that at least attains those requirements that are legally applicable or relevant and appropriate. In performing the FYR for compliance with applicable or relevant and appropriate requirements (ARARs), only those ARARs that address the protectiveness of the remedy are reviewed.

The 1989 ROD identified state of Florida primary drinking water standards or proposed federal maximum contaminant levels as ARARs for the Site. When ARARs were not available, the cleanup goals were based on Agency reference doses for non-carcinogens and a risk range for carcinogens of 10-7 to 10-4. Table J-1 compares 1989 ROD remediation goals with current standards and shows the final maximum contaminant level (MCL) for toluene is more stringent than the ROD cleanup goal. The ARARs remain valid because toluene is consistently below detection in all wells monitored.

Table J-1: Groundwater Remediation Goal Comparison Current Florida 1989 ROD Current Federal Primary Drinking COC Remediation Goal MCLa Change Water Standardsb (μg/L) (μg/L) (μg/L) 1,1,1-Trichloroethane 200c 200 200 No change 1,1-Dichloroethane 3c,d 5 3 No change 1,2-Dichloroethane 3c 5 3 No change 1,1-Dichloroethene 7c 7 7 No change Benzene 1c 5 1 No change Chlorobenzene 100e 100 100 No change Ethyl Benzene 100e 700 700 Less stringent Toluene 2,000e 1,000 1,000 More stringent Vinyl Chloride 1c 2 1 No change Notes: a. National Primary Drinking Water Regulations, located at: https://www.epa.gov/ground-water-and-drinking- water/national-primary-drinking-water-regulations (accessed 9/30/2020). b. Florida Primary Drinking Water Standards, located at: https://floridadep.gov/water/source-drinking- water/content/standards-and-health-effects-drinking-water-contaminants (accessed 9/30/2020). c. Based on state of Florida primary drinking water standard d. In the absence of sufficient toxicity data, the primary drinking water standard for the structurally similar compound, 1,2- dichloroethane, will be used. e. Based on proposed federal maximum contaminant level μg/L=micrograms per liter

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APPENDIX K – SCREENING-LEVEL RISK REVIEW

Table K-1: Screening Level Evaluation of 2010 Soil Sampling Residential Regional 2010 Soil Screening Levelb Investigation Noncancer (mg/kg) Cancer Contaminant Maximum Hazard Hazard Riskc Concentrationsa Quotientd 1 x 10-6 Risk Quotient = (mg/kg) 1.0 Metals Silver 0.45 NA 390 NA 0.001 Arsenic 1.5 0.68 35 2 x 10-6 0.04 Barium 60 NA 15,000 NA 0.004 Cadmium 4.4 2,100 71 2 x 10-9 0.06 Chromium (total)e 44 0.3 230 1 x 10-4 0.2 Lead 62 400 NAf Selenium <0.83 NA 390 NA 0.002 Mercury 0.039 NA 11 NA 0.004 VOCs Benzene <0.0029 1.2 82 2 x 10-9 0.00004 Bis (2-ethylhexyl)phthalate 0.063 39 1,300 2 x 10-9 0.00005 Vinyl chloride <0.0029 0.059 70 5 x 10-8 0.00004 SVOCs Benzo(a)pyrene 0.028 0.11 18 3 x 10-7 0.002 Pyrene 0.024 NA 1,800 NA 0.00001 Notes: The 2010 soil investigation samples were taken from depth down to 18 inches which is outside of the general EPA risk review of surface soil depths that are generally from the top 12 inches. a. Soil data obtained from Soil Boring Investigation Report, July 2010. b. Current EPA RSLs, dated May 2020, are available at https://www.epa.gov/risk/regional-screening-levels- rsls-generic-tables (accessed 10/2/2020). c. The cancer risks were calculated using the following equation, based on the fact that RSLs are derived based on 1 x 10-6 risk: cancer risk = (cleanup level ÷ cancer-based RSL) × 10-6. d. The noncancer HQ was calculated using the following equation: Hazard Quotient = cleanup level ÷ noncancer-based RSL. e. To provide a conservative evaluation, chromium VI is used from the regional screening tables because total chromium does not have established toxicity criteria. f. The EPA has not developed cancer or noncancer-based toxicity values for lead and evaluates lead exposure using blood-lead modeling. The cleanup goal is compared directly to the blood-lead based RSL. HQ = hazard quotient NA = not applicable; toxicity criteria not established mg/kg = milligrams per kilogram

Table K-2: Screening-Level Vapor Intrusion Risk Evaluation of January 2020 Shallow Groundwater VOC Results Residential Evaluation Groundwater Concentration VOC (μg/L)a Cancer Riska Non-cancer HQa 1,1-Dichloroethane 3.4 (BV-1) 4 x 10-7 NA 1,2-Dichlorobenzene 8.7 (BV-17) NA 0.003 1,2-Dichloroethane 1.5 (BV-1) 7 x 10-7 0.01 1,3-Dichlorobenzene 1.5 (BV-3, SRW-2) NA NA 1,4-Dichlorobenzene 2 (BV-3 and BV-17) 8 x 10-7 0.0002 K-1

Residential Evaluation Groundwater Concentration VOC (μg/L)a Cancer Riska Non-cancer HQa Acetone 5.3 (BVR-6) NA 0.0000002 Benzene 25 (BV-21R) 2 x 10-5 0.2 Chlorobenzene 22 (SRW-2) NA 0.05 Chloroethane 7.9 (SRW-4) NA 0.0003 Ethyl Benzene 0.47 I (BV-6) 1 x 10-7 0.0001 Methylene Chloride 10 (BV-26) 1 x 10-8 0.002 Tetrachloroethylene 1.2 (BVR-4) 8 x 10-8 0.02 Vinyl Chloride 7.3 (BV-1) 5 x 10-5 0.08 Xylene 4.2 (BVR-6) NA 0.001 Cumulative Total 7 x 10-5 0.3 Notes: a. Risk and hazard quotient calculated using the EPA’s May 2020 VISL calculator (https://www.epa.gov/vaporintrusion/vapor-intrusion-screening-level-calculator) assuming a residential exposure and default groundwater temperature of 25 degrees Celsius. μg/L = micrograms per liter I = Reported value is between the laboratory method detection limit and the laboratory practical quantitation limit. NA = Not applicable Source: 2020 Water Quality Monitoring Report. Tables 1-4. Prepared by Hillsborough County. May 2020.

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APPENDIX L – RESTRICTIVE COVENANT INSTRUMENT#: 2011112446, BK: 20443 PG: 962 PGS: 962 - 971 04/04/2011 at 04:32:01 PM, DEPUTY CLERK:ADANIEL Pat Frank ,Clerk of the Circuit Court Hillsborough County

This instrument prepared by and return to: Patrick T. Lennon, Esquire Macfarlane Ferguson & McMullen P.O. Box 1531 Tampa, Florida 33601-1531 IJ.

DECLARATION OF RESTRICTIVE COVENANT

(;------=-;;-- THIS DECLARATJON OF RESTRJCTIVE COVENANT (hereinafter, "Declaration") is made ~{, · S- this~ day of March, 2011, by University Energy Park, LLC, a Florida limited liability company (hereinafter the "GRANTOR") and its successors and assigns; and the Florida Department of Environmental Protection (hereinafter, "FDEP").

RECITALS

""'\ A. GRANTOR is the fee simple owner of that certain real property situated in the County of O,o Hillsborough, State of Florida, more particularly described in Exhibit II A II attached hereto and made a part hereof (depicted on Exhibit "B" as the Superfund Area and Superfund Site); and is the fee simple owner of that certain adjacent real property situated in the County of Hillsborough, State of Florida, more particularly described in Exhibit "C" attached hereto and made a part hereof (depicted on Exhibit "B" as the Area of Institutional Control (which includes the Delineation Area), less the Superfund Area and Superfund Site. The property depicted in Exhibits A and C is defined, for purposes of this Declaration, as the "Property."

B. The FDEP Delineation Number for the Property is 29993432. The facility name at the time of this Declaration is the Sydney Mines Sludge Ponds Site (the "Site").

C. The Property was formerly strip mined for phosphate ore during the 1930s and 1950s. A portion of the Property was later used in the 1970s by Hillsborough County as a liquid waste disposal facility. (The area used for liquid waste disposal is indicated as the Superfund Site in Exhibit B.) Wastes such as used oil and septage were disposed in unlined clay pits. When groundwater from wells at adjacent properties was found to be impacted with volatile organic compounds (VOCs), it was determined that disposal should cease and remediation was undertaken. Liquid wastes were removed and sent off site for disposal, and a limited amount of soil was excavated and incinerated on site and placed back in the excavation area. Subsequent to this remediation, additional groundwater contamination was identified in four water-bearing units at the Property. The U.S. EPA conducted ""'\ further evaluation, ranked the Site, and listed it on the National Priorities List. A Record of Decision (ROD) was issued by U.S. EPA in 1989 that mandated groundwater cleanup by the Potentially -O,o Responsible Parties (PRP) Group for nine constituents of concern, including (ROD cleanup goal indicated in parts per billion (ppb)): benzene (I ppb); chlorobenzene {100 ppb); 1,1-dichloroethane (3 ppb); 1,2-dichloroethane (3 ppb); 1,1-dichloroethene (9 ppb); ethylbenzene (700 ppb); toluene (2,000 ppb); 1,1,1-trichloroethane (200 ppb); and vinyl chloride(! ppb). Groundwater pump and treat was implemented as the remedial measure and was conducted until 1997 when the systems were shut

Sydney Mines Slud&e Ponds Site I of 10 Declaration of Restrictive Covenants R

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down so monitored natural attenuation (MNA) could be studied as a long-term remedy for Site groundwater. In 2001, the U.S. EPA approved transition to MNA as the remedy for the Site. 0 Monitoring of this remedy is currently ongoing. The following reports, which are located at EPA Region 4 in Atlanta, Georgia, as well as at the Site Repository at the John F. Germany Library, 900 North Ashley Drive, Tampa, Florida 33602-3988, discuss historical environmental activities completed at the Property, and are incorporated herein by reference:

l . ROD, October 1989; 2. Unilateral Administrative Order ((]AO) for Remedial Design and Remedial Action, US. EPA Docket No. 90-59-C; 3. Explanation ofSignificant Differences, U.S. EPA, October 1991; 4. Final Remedial Design Report, BBL, February 1992; 5. Remedial Action Repon, BBL, April 1993; 6. Phase II Natural Attenuation Evaluation Final Report, CRA, June 2000; 7. Sydney Mines-Analytical Data Reports; 8, Superfund Five-Year Review Reports; 9. Bone Valley Remedial Design, April 1997; and JO.Bone Valley Remedial Action Report, May 1995.

D. The reports noted in Recital C set forth the nature and extent of the contamination on the Property. These reports confirm that contaminated groundwater, as defined by Chapter 62-780, Florida Administrative Code (F.A.C.), exists on the Property.

E. ft is the intent of the restrictions in this Declaration to reduce or eliminate the risk of exposure of the contaminants to the environment and to users or occupants of the Property, and to reduce or eliminate the threat of migration of the contaminants.

F. GRANrOR deems it desirable and in the best interests of all present and future owners of the Property that portions of the Property ("Portions of the Property") be held subject to certain restrictions, all of which are more particularly hereinafter set forth. Exhibit "B" depicts a site plan map with four principal designated areas where specific restrictions apply: (1) the Area of Institutional Control (325.8 acres); (2) the Delineation Area (246.5 acres); (3) the Superfund Area (56.4 acres); and (4) the 0 Superfund Site (9.5 acres). G. It is the intention of all parties thafU.S. EPA is a third party beneficiary of said restrictions and that said restrictions shall be enforceable by U.S. EPA, FDEP, and their successor agencies.

NOW, THEREFORE, in compliance with the ROD and UAO (Docket No. 90-59-C), and for other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged by each ofthe undersigned parties, GRANTOR agrees as follows:

I. The foregoing recitals are true and correct and are incorporated herein by reference.

2. GRANTOR hereby imposes on the identified Portions of the Property the following restrictions: a. Within and/or under the Area of Institutional Control, which includes the Delineation Area, there shall be no use of groundwater on the property, except for groundwater investigations and/or remediation activities. There shall be no drilling Sydney Milles Sh1dge Pond., Sit• 2 of I 0 Declaration of Restrictive Covenanu Revisocl by k

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for water conducted on the property, except for groundwater investigations and/or remediation activities, nor shall any wells be installed on the property other than monitoring wells or extraction wells pre-approved by U.S. EPA and FDEP. b. Within and/or under the Superfund Site there shall be no use of groundwater on the property, except for groundwater investigations and/or remediation activities. There shall be no drilling for water conducted on this portion of the property, except for groundwater investigations and/or remediation activities, nor shall any wells be installed on the property other than monitoring wells or extraction wells pre-approved by U.S. EPA and FDEP. Additionally, there shall be no stormwater swales, stormwater detention or retention facilities or ditches on this portion of the property. No person shall engage in any excavation activity below grade except for investigation and/or remediation activities within the Superfund Site. Any contaminated soils that are excavated for investigation and/or remediation activities must be removed and properly disposed of pursuant to Chapter 62-780 F.A.C. (or subsequent contamination site clean-up rule(s)). c. Within and/or under the Superfund Area, there shall be no use of groundwater on the property, except for groundwater investigations and/or remediation activities. There shall be no drilling for water conducted on this portion of the property, except for groundwater investigations and/or remediation activities, nor shall any wells be installed on the property other than monitoring wells or extraction wells pre-approved by U.S. EPA and FDEP. GRANTORS will submit a stormwater management plan to FDEP and U.S. EPA for their approval of any stormwater facilities that are to be utilized within the Superfund Area. For any dewatering activities, a plan, approved by FDEP and U.S. EPA, must be in place to address and ensure the appropriate handling, treatment, and disposal of any extracted groundwater that may be contaminated. GRANTOR and its successors and assigns will not allow natural groundwater flow to be materially altered, or allow any groundwater contamination to spread, change its natural flow, impact natural attenuation or allow material adverse effect to the existing groundwater conditions. Within the Superfund Area, any construction of buildings or utilities shall require placement of two feet of clean fill beneath the building pad, compacted to a minimum 90 percent proctor at the location of the use. Clean .fill is defined as material that meets residential direct exposure criteria and leachability based on groundwater criteria specified under Chapter 62-777, FAC, and Soil Cleanup Target Levels. Penetration of the current grade shall not occur regarding any construction, buildings, structures or utilities. d . Within the Superfund Site and Superfund Area, there shall be no agricultural use of the land including forestry, fishing and mining; no hotels or lodging; no recreational uses including amusement parks, parks, camps, museums, zoos, or gardens; no residential uses; and no educational uses such as elementary and secondary schools, or day care services. These prohibited uses are specifically defined by using the North American Industty Classification System, United States. 1997 (NAJCS). Executive Office of the President, Office of Management and Budget. The prohibited uses by code are: Sector l I Agriculture, ForestrY, Fishing and Hunting; Subsector 212 Mining (except Oil and Gas); Code 512132 Drive-In Motion Picture Theaters; Code 51412 Libraries and Archives; Code 53 I I I Lessors of Residential Buildings and Dwellings; Subsector 611 Elementary and Secondary Schools; Subsector 623 Nursing and Residential Care Facilities; Subsector 624 Social Assistance; Subsector 711 Performing Arts, Spectator Sports

Sydney Min,s Sludge Ponds Site 3 of 10 Declaration ofRcstricti¥e Covenants Revised by ker 10.7.2010

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and Related Industries; Subsector 712 Museums, Historical Sites, and Similar Institutions; Subsector 713 Amusement, Gambling, and Recreation Industries; Subsector 721 Accommodation (hotels, motels, RV parks, etc.); Subsector 813 Religious, Grantmaking, Civic, Professional, and Similar Organiz.ations; and Subsection 814 Private Households. However, subject to the restrictions set forth in this Paragraph 2, nothing prohibits the Superfund Area property outside and excluding the Superfund Site from being utilized and developed for non-prohibited uses as long as all uses are not objected to in the UAO, ROD, or Scope of Work to the ROD.

3. For the purpose of monitoring the restrictions contained herein, U.S. EPA, FDEP, or their respective successors and assigns, shall have access to the Property at reasonable times and with reasonable notice to the ORANTOR and its successors and assigns.

4. It is the intention of ORANTOR that the restrictions contained in this Declaration shall touch and concern the Property, run with the land and with the title to the Property, and shall apply to and be binding upon and inure to the benefit of the successors and assigns of ORANTOR, and to FDEP, its successors and assigns, and to any and all parties hereafter having any right, title or interest in the Property or any part thereof; provided, however, that notwithstanding anything contained herein to the contrary, no part of GRANTOR'S property not specifically included within the four delineated areas identified in Paragraph F shall be impacted or affected by the restrictive covenants contained herein. The FDEP, its successors and assigns, may enforce the terms and conditions of this Declaration by injunctive relief and other appropriate available legal remedies. Any forbearance on behalf of the FDEP to exercise its right in the event of the failure of the GRANTOR or its successors and assigns to comply with the provisions of this Declaration shall not be deemed or construed to be a waiver of the FDEP rights hereunder. This Declaration shall continue in perpetuity, unless otherwise modified in writing by ORANTOR. or its successors and assigns, and the FDEP, or its successors and assigns, as provided in Paragraph 6 hereof. These restrictions may also be enforced in a court of competent jurisdiction by any other person, firm, corporation, or governmental agency that is substantially benefited by this restriction.

5. In order to ensure the perpetual nature of these restrictions, GRANTOR, and its successors and assigns, shall reference these restrictions in any subsequent deed of conveyance, including the recording book and page of record of this Declaration.

6. This Declaration is binding and enforceable until such time as a release of covenant is executed by the FDEP Secretary (or designee) and GRANTOR, and such release is recorded in the Hillsborough County land records. To receive prior approval from FDEP to remove any requirement herein, cleanup target levels established pursuant to the ROD issued in October I 989, and any amendments thereto, must have been achieved. This Declaration may only be modified in writing. Any subsequent modification must be executed by ORANTOR and the FDEP, or their respective successors or assigns, and must be recorded by ORANTOR, or its successors and assigns, as an amendment hereto. FDEP shall not consent to any amendment or release without the consent of U.S. EPA.

7. If any provision of this Declaration is held to be invalid by any court of competent jurisdiction, the invalidity of such provision shall not affect the validity of any other provisions hereof. All such other provisions shall continue unimpaired in full force and

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effect.

0 y 8. GRANTOR covenants and represents that on the date of execution of this Declaration, that GRANTOR is seized of the Property in fee simple and has good right to create, establish, and impose this restrictive covenant on the use of the Property. GRANTOR also covenants and warrants that the Property is free and clear of any and all liens, mortgages, or encumbrances that could impair GRANTOR'S right to impose the restrictive covenant described in this Declaration, or that would be superior to the restrictive covenant described in this Declaration.

9. It is expressly agreed that U.S. EPA is not the recipient of a real property interest, but is a third party beneficiary ofthe Declaration, and as such, has the right of enforcement.

[THE REMAINDER OF THIS- PAGE HAS BEEN LEFT BLANK INTENTIONALLY]

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Sydney Mlnes Sludge Ponds Site 5 of 10 Declaration of Rcstricrive Covenants Reviied by ker 10.7.2010

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Bk 20443 Pg 967

U. C () IN WITNESS WHEREOF. T he Grantor has executed this instrument. this 2.1 day of March. 2011.

Signed. scaled and !le livered in the presence of:

Printed Name: Darrell I la11son O,o J"itlc: Manager Address: 2500 Main Street l'ort Myers Ueac h. Florida 3393 I

The foregoing instrument was ackuowledgcd before me thiC\ ':__ day of March. :!O 11. by Oarrdl I lanso11 as manager of llnivcrsily Energy Park. LI .C. a Florida. limited liability company. on behalf of the company.

Persona lly Known .. ✓ _OR Produced ldcntilication Type ofldcntification Produced

Commissillll No.~'I \d.. \ l)'I

Co111111ission 1-:xpin:~

.•~,;J.li< '~- PATRi"CiAJ PAYNE !°•: ':•\ MY COMMISSION# 00712107 \ . .,r .. ./ EXPl[

~>iln..:~ \fou.~ :,O, lmlj•C l'tmds 'i1t~ IA:d.1r.1tmn uf tfrstncll\t' ('m·c1t:i11t$ u. K~'\ l!-4..'db) l..c1 l(1720Hl C ()

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Bk 20443 Pg 968 -

onmental Protection, Office of General

IN I ESS WHEREOF, the Florida Department of Environmental Protection has executed this instrument, this 2Q__ day of March, 20 I l.

Signed, sealed and delivered in the presence of:

FLO E

Title: e.dctr Division of: t;: 2a..de Hq "'a.j~Q.~

Bureau of; _V~IR~F-:_e:e_:r,~o~~:i:z~·~s__ o_F~F_ 1c.-_io__ _

Mailing Address: 2'-00 P,,l,,Jl.1.C Sro,.H: Rot..P M:i 4-500 City: 1Au..A 1-!ASSeE ,FL:32392

Date: ~ -:?>o ·z.011 ~J'J,~ 1 ltneSS Print Name: L IN lJtr /11. Fr

STATEOF R..o1Z-1DA COUNTY OF-=U:=--oc..c..,,______,

The foregoing instrument was acknowledged before me this :3o"' day of M¼J.l by R?TT'1 v11..T'-Z... as representative for the Florida Department of Environmental Protection. ✓ Personally Known ___ OR Produced Identification ____ Type of Identification Produced ______---==-- - -

Commission No. ee n2'>82. _,-•·2 d,?'4 ~ .~ '); Signature ~Public Commission Expires -.e1r. 1° 2.Q1-+, Print Nam,e of Notary Public

Sydney M;ncs Sludge Ponds Site 7of10 OcclaratK»l of ReSlrictiYe Covenants Rcvuedbykcr 10.7.2010

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Bk 20443 Pg 969 -

EXHIBIT A Legal Description

LEGAL DESCRIPTION: SUPERFUND AREA

A PARCEL OF LAND LYING IN SECTIONS 27 AND 28 TOWNSHIP 29 SOUTH, RANGE 21 EAST, HILLSBOROUGH COUNTY, FLORIDA. SAID PARCEL BEING MORE PARTJCULARLY DESCRIBED AS FOLLOWS:

COMMENCING AT THE SOUTHWEST CORNER OF THE NORTH 1/2 OF THE NORTHWEST 1/4 OF SAID SECTION 28; THENCE SOUTH 89°36'28" EAST, 5,186.36 FEET TO THE POINT OF BEGINNING OF THE HEREIN DESCRIBED PARCEL; THENCE NORTH 90°00'00" EAST, 1,611.56 FEET; THENCE SOUTH 00°00'00" WEST, 1,524.29 FEET; THENCE SOUTH 89°58'52" WEST, 1,610.28 FEET; THENCE NORTH 00°02"53" WEST, 1,524.82 FEET TO THE POINT OF BEGINNING.

SAID PARCEL CONTAINS 56.4 ACRES, MORE OR LESS.

S)dney Mines Sludi< Ponds Site 8 of IO Dec lam.ion of Restrictive Covcnaru.,; Revisedbykcr 10.7.2010 0

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"' .... 0 0 (") ~ ~ ~ N ft : I ! ll S!.. ~ ~ ~ ...... u DA--!"l" ,c.,,. s.w;w '-'·"'• SA-i'llt DA-Ni t.,.sr ...... Dt\.Nlr11 OMYI Dt.-5\\ DA•Slt DA CORl'lt:.a ___ -- lege Superf\lnd - A-NWI,, .. . .. •• "I• e N£1i • ., · · ' ' a ' • • c t 3oo - nd Redlrn.ation PR-1(1"1ac:lfw) OelloeaDOl"IArN 11,:u.s 11,.mu 1Uffl'J6 17 ll 21.,~1, lUJIU7 J7J"°'I 21 27 JU.U71?' JUJ.l'l'H J.U.lll76 JU.M1M JUJl106 JUJOOJ1' ZT.,J.1114 n,.)U86 U Boundaries UllOJJ ... . .t . . . .-ulll ,w11 •.JOJN tZl617 fflSS .0 . !!!!!!!!!!!!!!! .. 116 ... ·• 5 Q Boundaries " s ...... , .auo77!!1J .ftl07._. ..f1.lf7ffl .11201 ~1.ltTCIO!I -11.lttlU -1uci,.t1.t -tU:tUSJ -11.IMIJ --11.20'512 4UOT7!!1J ~19720 _.1.ltlOff · -1119111' Ut711:I 1 . 200 .. .. - , , 1 I 1 if • l l1"5'"UllJfi z ·- 1"' : rw&t'J ~lilolongl'll.ffafonJer. I I '5'JUJJ4"' o..o J "' ... .n-12 ... r,1:v,._- FCVandE.., ' )6.."7•" ~m~Wlltocltiontw«•~bo/HlbborouO'tCOUntrSotldWllteMgr,t.~bouli:IIMS8'9 twd-chl,,nDa,edon~Ol-piett:Wt FECJt,Cdolll I I J '-8 ...q,ai21n I I 6ms11 nrtgautnMttw .!!!!h MR I I tttlll!C'fdbouncl,Wy INVl:ltSITYMJ.t,.._,AM,,LLC -·~.:;: HM•-•- lf .. ":""'" eRe:stttct!YeCovenM«t0Jmert a'ld~• bit ::::: CIIIU,•n: B B .!:' m.ty wry :. NI lnlOcalion - by• NC -100fMt. .,_.:.-,_ •--- ,t::.--:::: 1 !'IIU. tu ftlEPOEUHfATl()t,j ~COIMfY.!A.OA!Cri\ 9CMCWl'V n&21 , TWl"111a1111:1o01'1 L OCAnc>NIUJI l ,_,)oUJ 1E I • • - I°"., - IOQ .0 \tlOI O I

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EXHIBITC Legal Description

LEGAL DESCRIPTION: AREA OF INSTITUTIONAL CONTROL LESS THE SUPERFUND AREA

A PARCEL OF LAND LYING IN SECTIONS 27 AND 28 TOWNSHIP 29 SOUTH, RANGE 21 EAST, HILLSBOROUGH COUNTY, FLORIDA. SAID PARCEL BEING MORE PARTICULARLY DESCRIBED AS FOLLOWS:

COMMENCING AT THE SOUTHWEST CORNER OF THE NORTH 1/2 OF THE NORTHWEST 1/4 OF SAID SECTION 28; THENCE SOUTH 89°36'28" EAST, 3,720.80 FEET TO THE POINT OF BEGINNING OF THE HEREIN DESCRIBED PARCEL; THENCE NORTH 00°00'49" WEST, 990.32 FEET; THENCE NORTH 90°00'00" EAST, 3.782.58 FEET; THENCE SOUTH 00°00'00" WEST, 3,751.85 FEET; THENCE NORTH 89°57'26" WEST, 3,781.68 FEET; THENCE NORTH 00°00'49" WEST, 2,758.71 FEET TO THE POINT OF BEGINNING.

LESS AND EXCEPT THE SUPERFUND AREA AS DESCRIBED BELOW: A PARCEL OF LAND LYING IN SECTIONS 27 AND 28 TOWNSHIP 29 SOUTH, RANGE 21 EAST, HILLSBOROUGH COUNTY, FLORIDA. SAID PARCEL BEING MORE PARTICULARLY DESCRIBED AS FOLLOWS:

COMMENCING AT THE SOUTHWEST CORNER OF THE NORTH 1/2 OF THE NORTHWEST 1/4 OF SAID SECTION 28; THENCE SOUTH 89°36'28" EAST, 5,186.36 FEET TO THE POINT OF BEGINNlNG OF THE HEREIN DESCRIBED PARCEL; THENCE NORTH 90°00'00" EAST, 1,611.56 FEET; THENCE SOUTH 00°00'00" WEST, 1,524.29 FEET; THENCE SOUTH 89°58'52" WEST, 1,610.28 FEET; THENCE NORTH 00°02"53" WEST, 1,524.82 FEET TO THE POINT OF BEGINNING.

SAID PARCEL CONTAINS 56.4 ACRES, MORE OR LESS.

SAID PARCEL CONTAINS 269.2 ACRES, MORE OR LESS.

Sydney Mines Sludge Ponds Site 10 of 10 Declaration of Restrictive Covenants Rev~ed byker 10.7.2010

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